State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Name:
prepared on
behalf of the River Basin Management Society and its members
Organisation: River Basin Management Society
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?
The purposes of the association are to provide a means for communication between and
within the various disciplines and interests in the practice of River Basin Management for
the benefit of the Community. The applicable objective of the society in this instance is:
“To provide independent professional comment when required on river basin
management issues”
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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?
N/A. See response to “Any other information you would like to share”.
Question 3: Do you have any concerns about the proposed
working title of State Environment Protection Policy (Waters)? If
so, what are they?
The RBMS is comfortable with the working title, but only if there is no net loss in
environmental outcomes as a result of combining the Groundwater and Surface Water SEPPs.
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?
Our understanding of an environmental objective should be developed enough to determine
whether an appreciable difference can be made to meet the objective in a ten year
timeframe. If science, planning, policy, financial constraints cannot be overcome in a ten year
timeframe then the objective is aspirational and shorter term goals should be developed to
progressively work towards the objective. If an appreciable difference can be made within a
ten year time frame then the objective is feasible.
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?
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?
Why do we need to provide for economic and social development with this Policy? Economic
and Social development is supported through other initiatives and have been progressing
despite existing shortcomings in SEPP WOV Objectives. The RBMS believes the addition of
economic and social development objectives detracts from the purpose of this policy.
As above.
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
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?
Improved WQ doesn’t have an economic return in the short term which makes it a
challenging objective to aim for. The question of trade-offs implies that there has to be a
trade-off. Instead we should be investing time into progressing solutions that have shown to
produce win-win-win outcomes.
One combined SEPP is perfectly reasonable and is supported by the RBMS but only if
appropriate exceptions are defined to capture the physiological differences between ground
and surface water.
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?
Much of the introduction and justification for the SEPP can be consistent for ground and
surface water however it would be detrimental if the value of two separate policies was lost.
If done well this is an opportunity to acknowledge to interconnectivity of both systems whilst
catering for the different environmental threats, parameters, intervention techniques,
timescales and beneficial uses. A risk is losing out on the best of both policies whilst the
opportunity is to benefit both i.e. coequal goals.
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?
No. Effort should really go into defining beneficial uses for all waterbodies.
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?
The current segments are overly complex and were developed over time i.e. more and more
schedules to cater for our understanding of the complex differences between aquatic
ecosystems. The RBMS believes it’s the appropriate time to be resetting how segments are
defined.
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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?
No problems have been identified with existing spatial arrangements or segment boundaries.
As per Q. 10 the identified issues are that many of the schedules are inconsistent and have all
been developed at different points in time.
The RBMS is broadly supportive of the new segments but believes that further work should be
undertaken to break down the Groundwater Segments into more meaningful segments.
Question 12: What do you think are the advantages or problems
with the new approach to segments and sub-segments?
For instance, consideration of the National Aquifer Framework and the National Groundwater
Information System could be used to define segment boundaries. Currently only TDS is used
to categorise GW and the RBMS believes that this doesn’t reflect the aquifer typology and
structure.
Question 13: Are there any features of the landscape that you
would like to see as a standalone segment or sub-segment?
As per the above the RBMS believes further work could be undertaken to define Groundwater
segments. For instance areas such GW discharge/recharge zones. i.e. beneficial use is the
symbiotic relationship b/w groundwater and surface. An example could be the peat
bogs/sphagnum bogs at top of 7 creeks catchment/Strathbogies.
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?
Yes. As per the response to Q9 effort should be spent defining beneficial uses for all
waterbodies.
Question 15: What method or approach could be used to apply
the beneficial uses to segments and sub-segments?
Beneficial uses should be set by the best available science and with input from the
community. i.e. Community perception should drive whether a river should be swimmable or
not. Whether people currently swim there should not be used to determine whether the
waterway should be swimmable in the future. Beneficial uses should not be determined or
influenced by whether or not the objectives required to maintain or achieve these uses are
aspirational or beneficial.
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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?
RBMS suggests that Groundwater Ecosystems could exist as a standalone beneficial use. Or
inclusion of Groundwater in the existing Aquatic Ecosystems.
Question 17: What do you think about the current indicators, the
approach for deriving objectives and the proposed changes?
The suite of indicators is deemed acceptable however as per feedback in earlier questions,
the RBMS strongly believes further work is required to determine indicators in groundwater.
It is not clear how the balance between competing beneficial uses in ‘sustainable working
rivers’ will be determined. This represents the greatest risk when deriving objectives because
it is possible that few/no aspirational targets will be set in areas such as ports/irrigation areas
where multiple uses exist.
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?
Can load caps be retained with inbuilt concentration limits for point sources? Nutrient load
targets seem particularly in managing or setting targets for multiple diffuse sources where
regulation or enforcement is impractical.
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?
A range of statutory mechanisms should certainly be explored and the trend should be for
clear, simple and enforceable actions. Current levels of regulation and enforcement on known
pollutant sources are not adequate so the emphasis in the development of management
actions should be ensuring that management actions are enforceable and that adequate
resources are provided to carry out enforcement.
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)?
The RBMS believes the requirement for an adaptive approach and the mechanisms to enable
knowledge gaps to be progressively filled should sit inside the SEPP however whether the
SEPP’s role is to identify or fill knowledge gaps or whether this sits outside of the policy is not
deemed critical. If a funding stream to undertake this process is more attainable if the
function sits within the SEPP then this is where it should reside.
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
The River Basin Management Society is a member based organisation comprising policy
professionals, scientists, engineers, economists and practitioners from academia, not for
profit organisations, government and private enterprise working in the field of catchment and
waterway management. The RBMS has approximately 230 members with an average work
experience of 10 years, creating a knowledge base of over 2,000 years. The objectives of the
RBMS include:

Any other information you would like to share:



To provide a forum in Australia for interchange of multidisciplinary knowledge and skills in the
field of river basin management.
To recognise, declare, promote and disseminate advances in river basin management.
To encourage the interchange of those engaged in river basin management within Australia
and overseas.
To provide independent professional comment when required on river basin management
issues.
The scope, effectiveness and efficiency of legislation, policy and strategies governing the
management of Victoria’s waterways and catchments are of particular interest to the RBMS.
We welcome the opportunity to comment on the SEPP WOV Review. The RBMS canvassed its
members for any comments and also ran a special reading group session to discuss the
Review. This submission is based on that feedback.
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