THE Sunraysia branch of the Victorian Farmers Federation has defied the peak farm body's head office over water trading.

And VFF chief executive Wayne Harvey has accused the branch of undermining the organisation.

The Sunraysia branch lodged its own submission to the Australian Competition and Consumer Commission on water trading on Monday using the VFF logo and the name "VFF Sunraysia Branch".

The Weekly Times understands debate took place about the use of the VFF logo and title, with the branch choosing to use the name and logo despite protests from Melbourne.

"The branch affirms its right to independently determine water policy issues if and as necessary and to advocate independently with respect to such issues," the submission said.

It also noted "some views put forward in the submission may differ from those put forward in the submission by the Victorian Farmers Federation".

Some Sunraysia irrigators are furious at the VFF's strong advocacy of the 4 per cent cap on trading water out of any irrigation district.

They say the cap prevents them selling their water to the Federal Government's water buyback scheme; that an exemption of low reliability water from the cap advocated by VFF fails to assist them as they have no access to low reliability water; and that the VFF water council is dominated by dairy farmers.

The submission said irrigators' water security had reduced and said there had been "ongoing upward pressure on the temporary water market resulting from over-allocation and the extensive extra plantings of more than 30,000ha of permanent horticulture ... requiring 300 gigalitres annually ... due primarily to ... enhanced water trading and the activities of managed investment schemes".

VFF chief executive Wayne Harvey said Sunraysia's independent submission to the ACCC was "certainly not according to the conventions of the VFF".

"We can't have every group who disagrees with the VFF putting in submissions using the VFF banner," Mr Harvey said.