State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Name:
Organisation: VicRoads
Date: 13.7.2015
This template is provided to help you respond to the State Environment Protection Policy (Waters) discussion paper. Please answer as many or few questions as
you would like to provide input for. All submissions will be considered by DELWP in the development of the draft policy and policy impact assessment. Any
group or individual that provides comment will be kept informed and included in further consultation.
The information you provide in your submission will only be used by DELWP and EPA for the purpose of reviewing Water SEPPs. However, it may also be disclosed
to other relevant agencies as part of the consultation process. All submissions will be treated as public documents and may be published online for public access.
While formal requests for confidentiality will be honoured, please note that freedom of information access requirements will apply to all submissions.
If you wish to access information in your submission once it is lodged with DELWP, you may contact the SEPP (Waters) Review team by email at
Water.SEPPreview@delwp.vic.gov.au.
Questions from discussion paper
Please enter your response
Any general comments on the proposed scope of State
Environment Protection Policy (Waters):
Question 1: What is your understanding of your roles and
responsibilities under Water SEPPs?
 VicRoads has a responsibility to comply with the Environmental Protection Act 1970 and
the associated Water SEPPs
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Question 2: What aspects of Water SEPPs does your organisation
currently use? How could Water SEPPs be improved to assist
your organisation’s day‐to‐day operations and longer‐term
strategic planning?
The aspects of the Water SEPPs that are used by VicRoads include:
 26 (Offset Measures) – VicRoads and Melbourne Water have an offsetting arrangement
for new road works which do not meet best practice standards as per the Best Practice
Environmental Management Guidelines.
 46 (2) (Urban Stormwater) – VicRoads is guided by the Best Practice Environmental
Management Guidelines (as amended).
 56 (Construction Activities) – VicRoads is guided by the Environment Protection Authority
with regards to minimising discharge of sediments and pollutants to surface waters during
construction activities.
 57 (Roads) – VicRoads is guided by the priorities as stated in the SEPP.
Question 3: Do you have any concerns about the proposed
working title of State Environment Protection Policy (Waters)? If
so, what are they?
Question 4: What is the best way to reflect what is feasible
versus what is aspirational in the context of a 10‐year policy
cycle?
Question 5: Do you support the proposed SEPP (Waters)
objective of “this policy is to protect and improve the quality of
Victoria’s waters while providing for economic and social
development”? Why?
This objective is consistent with the principle of triple bottom‐line assessment as per the
Transport Integration Act 2010 (Section 16):
“The principle of triple bottom‐line assessment means an assessment of all the economic,
social and environmental costs and benefits taking into account externalities and value for
money”.
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Question 6: Do you support the need to balance economic and
social development with overall protection and improvement of
water quality for Victoria’s water environments? Why?
As per Question 5, this approach is consistent with the principle of triple bottom‐line
assessment as per the Transport Integration Act 2010.
Question 7: What are the challenges of balancing economic and
social development with protecting and improving water quality?
How should we manage the appropriate trade‐offs between
them?
In the road context, some of the key challenges include land availability for water quality
treatment (especially in urban areas) and the cost of maintaining water quality treatment
systems.
An example of an approach to managing trade‐offs is the VicRoads Tree Planting Policy, which
uses a principle‐based approach to manage trade‐offs between road safety, traffic flow and
tree planting.
Question 8: Do you foresee any problems or opportunities that
may arise from creating one consistent SEPP to apply to all
Victorian waters? Are there other options for streamlining the
policies that we should consider?
Question 9: Are there any specific types of water environments,
for example, a wastewater treatment lagoon, where you think
beneficial uses should not be protected?
Question 10: Do you think the current measures for classifying
surface water and groundwater segments are still appropriate?
Are there other measures that should be explored?
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Question 11: Are there any problems with the spatial
arrangements or segment boundaries in the existing Water
SEPPs? If so, what are they?
Question 12: What do you think are the advantages or problems
with the new approach to segments and sub‐segments?
Question 13: Are there any features of the landscape that you
would like to see as a standalone segment or sub‐segment?
Question 14: Do you believe that all beneficial uses set out in
Table 2 of the discussion paper should still be protected under
the new SEPP (Waters)? Where do you think a beneficial use
would not apply? Why?
Question 15: What method or approach could be used to apply
the beneficial uses to segments and sub‐segments?
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Question 16: Are there any additional beneficial uses that you
believe should be protected? Are there any that you think should
no longer be protected? Why?
In relation to road projects, the indicators and objectives are only of relevance when they are
used to set targets for stormwater runoff quality from a road project.
Question 17: What do you think about the current indicators, the
approach for deriving objectives and the proposed changes?
Ideally, any indicators and objectives used to measure the impact of a road project (or any
project) would be relevant and simple. They should be 'relevant', in that they demonstrably
correlate the impact of the project upon the receiving water. They should be 'simple', in that
they are affordable to measure. There are some measures, such as transient water quality
indicators, which are generally not appropriate for measuring the impact of road projects
upon receiving waters (because it is expensive to measure and provides limited indication of
the impact of the road project upon the receiving waterway).
There is no simple answer to the problem of developing simple and relevant indicators and
objectives, and it is understood that research continues into this area. However, lasting
impacts (such as sediment and macroinvertebrate sampling) rather than transient impacts
(such as water quality) may provide a more meaningful assessment of the impact of road
projects upon receiving waters.
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Nutrient load targets have been useful for road projects, because they provide a clear design
objective for water quality treatment measures associated with road projects. They also
provide the basis for an offset arrangement with Melbourne Water. (Designing for nutrient
load targets is made possible through the use of the MUSIC software and supporting guideline
documents.)
Question 18: How have nutrient load targets been useful in
driving environmental investment outcomes? Would you like to
see a different approach, and if so, what might that be?
By focusing on the nutrient load targets, the water quality treatment systems are also
effectively removing other contaminants of concern, such as suspended solids and heavy
metals (which are predominantly attached to solids). However, by focusing on nutrients, the
treatment systems may not be as effective as they could be in managing other pollutants such
as dissolved heavy metals, hydrocarbons or flow volumes.
If there were to be a different approach, care would need to be taken to ensure that the
resulting designs of treatment systems provide environmental outcomes which are an
improvement on the current approach. This would require consideration of the impact of
design outcomes upon all key pollutants, not only the target pollutant. Any new approach
would also need to balance economic and social considerations.
Question 19: What is the preferred method for management of
at‐risk areas? Are there activities that need greater intervention
or regulation? What would the intervention be, for example,
voluntary or mandatory codes of practice, regulation via
licensing?
Question 20: What do you think the role of SEPP (Waters) should
be in identifying and filling knowledge gaps over the life of the
policy? How can we assure an adaptive approach within SEPP
(Waters)?
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Any other information you would like to share:
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