Environment Victoria (Accessible version)

Environment Victoria response to State Environment Protection Policy
(Waters) Review Discussion Paper
Environment Victoria is the state’s peak non-government, not-for-profit environment
organisation. Our Healthy Rivers Campaign is dedicated to working with government, business
and communities for the restoration and protection of our state’s great river systems. Our
vision is for a future where healthy rivers sustain abundant life and prosperous communities,
providing us with good food, clean water and places to love and enjoy.
We welcome this opportunity to submit a response to the SEPP (Waters) Review Discussion
Paper. We will focus on the questions for comment where we have most experience.
What is your understanding of your roles and responsibilities under Water SEPPs?
What aspects of Water SEPPs does your organization currently use? How could Water
SEPPs be improved to assist your organization's day-to-day operations and longer-term
strategic planning?
Environment Victoria has no specific role or responsibility under the Water SEPPs. We see
them as a mechanism to protect and improve water quality in Victoria but have always found
them a difficult framework to understand and interact with. Community knowledge about
SEPPs is low and the documents are complex and lacking plain English interpretation. There is
little or no public reporting on their effectiveness and their interaction with other reporting
mechanisms eg Index of Stream Condition and CMA report cards is opaque.
Water SEPPs could be improved by making them easier to understand, easier to enforce and
report on and with clearer pathways to attainment of an appropriate water quality standard.
3. Do you have any concerns about the proposed working title of SEPP (Waters)?
No. The integration of surface and ground waters into one policy is an improvement. However
to be effective the management of surface and ground water needs to be better integrated
and they need to be treated as part of the same water cycle, not as separate systems as is so
often the case.
What is the best way to reflect what is feasible versus what is aspirational in the context
of a 10-year policy cycle?
Melbourne University’s Waterways Ecosystem Research Group discusses the importance of
aspirational objectives in driving research and innovation and we endorse their submission.
An important but often absent dimension of policy making is an agreed vision of what level of
ecosystem health is acceptable and desirable, a response to the question “what do we want
our waterways to look like?”. The Victorian Catchment Management Council, Commissioner
for Environmental Sustainability etc have commented many times on the lack of an
overarching framework for catchment management and planning to support ecosystem
processes. The SEPP should be an integral part of the necessary framework to drive long term
improvements in water quality as well as setting interim targets and goals.
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
We have severe reservations about this objective because for us it ignores the crucial role
played by natural capital in supporting social and economic capital. If ecological values and
ecosystem processes are not protected then social and economic development cannot take
The objective should be revised to include this vital step. Suggested wording could be “protect
and improve the quality of Victoria’s waters to support the ecological values and ecosystem
processes that are the basis of economic and social development”.
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?
No, an explicit attempt to achieve ‘balance’ is doomed to failure because there is an
underlying imbalance between environment and economy – the economy relies on the
environment but not vice versa. There is also little consensus as to what ‘balance’ actually
means in practice. It is a concept that has bedeviled the implementation of the Murray-Darling
Basin Plan and even though the Commonwealth Water Act 2007 is one of the few pieces of
legislation that is quite explicit in how the Plan should be constructed with environmental
requirements determined first. Social and economic considerations are obviously crucial in
how environmental objectives are achieved, but should not be the major considerations in
deciding wheat those environmental objectives are.
The policy principles in the current SEPPs provide guidance in how social and economic
considerations can be taken into account. The precautionary principle is particularly important
for groundwater as so little is known about it. A recent Auditor General’s report concluded
that ‘The Department of Sustainability and Environment (DSE) and water corporations do not
know whether groundwater use is sustainable.’ 1 The same applies to the protection of
groundwater quality.
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?
The SEPP’s job is to set targets for improved water quality and to protect and enhance the
beneficial uses. It should not be looking for trade-offs as a first option but only when
implementation of the objectives is under consideration.
Any discussion of trade-offs should be transparent and robust, and be informed by a rigorous
examination of the environmental, social and economic costs. In the past environmental
valuation has often lagged behind social and particularly economic valuation. If the SEPP is to
consider tradeoffs it should do so on the basis of an accurate valuation of natural capital on a
1 VAGO (2010) Sustainable Management
of Victoria’s Groundwater Resources
similar basis to social or economic capital. Anything less runs the risk of underestimating the
costs of degraded environments, overestimating the costs of environmental protection
measures, and the loss of potential co-benefits of innovative solutions.
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?
We think a consistent SEPP across all Victorian water will be a benefit and be easier for the
public to interact with.
Waterwatch is a very popular community monitoring program and many of the parameters
stipulated in the SEPP are those that are monitored by these groups (pH, dissolved oxygen,
phosphorus etc). There would appear to be a huge opportunity for the data collected by these
groups to be better used by the EPA and CMAs in monitoring the outcomes of the SEPPs.
Current linkages are not obvious to Waterwatch groups and a better understanding of how
their observations (which are of a highly consistent standard) inform decision making would be
of great benefit to (and provide additional motivation for) the groups.
9. Are there any specific types of water environments, for example, a wastewater
treatment lagoon, where you think beneficial uses should not be protected?
Water treatment plants can provide crucial drought refuges when natural wetlands are dry. In
2007 the largest concentration of waterbirds in southern Victoria was at the Western
Treatment Plant and in northern Victoria at the Mildura Sewage Farm. Therefore all water
bodies can have at least some beneficial uses under some circumstances and only those that
are specifically toxic eg tailings dams should be excluded from consideration.
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?
Bringing groundwater and surface water together poses a few questions for segmentation –
for example where is the boundary for ground and surface water? Where do groundwater
dependent ecosystems (GDEs) fit in? How do the parameters of groundwater quality change to
surface water quality when it comes to the surface?
11. Are there any problems with the spatial arrangements or segment boundaries in the
existing Water SEPPs?
The classification of Gippsland Lakes as a marine environment would seem to confirm its
transition to a marine environment rather than seeing it as a freshwater environment that is
under threat of becoming marine. Having sub segments will help address this but massive
trade-offs have already been made through the dredging of the Entrance. Standards should be
set so that further trade-offs are fully apparent.
The proposed new sub-segment for urban/industry in the Latrobe valley creates some
problems as water leaving this sub-segment will have to meet the standards set downstream
for cleared hills and coastal plains an subsequently Lake Wellington. Since the industrial area is
the site of discharges from coal mines, power stations etc, which can be highly polluted, and
where there is drawdown of groundwater, setting a different standard and assuming that any
impacts will be diluted by the time the downstream boundary is reached is contrary to the
precautionary principle. Better to set a higher standard that will mean industrial discharges
will also have to meet higher standards.
12. What do you think are the advantages or problems with the new approach to
segments or subsegments?
13. Are there any features of the landscape that you would like to see as a standalone
There are specific waterway types that warrant special protection, such as ephemeral stream
and rare types of waterways such as chain-of-ponds. GDEs are another sector that may require
specific protection/segmentation.
14. Do you believe that all beneficial uses set out in Table 2 should still be protected under
the new SEPP (Waters)? Where do you think a beneficial use would not apply?
15. What method or approach could be used to apply the beneficial uses to segments?
16. Are there additional beneficial uses that you believe should be protected? Are there
any that you think should no longer be protected?
We will take these questions together.
The existing beneficial uses remain valid but we think the framework could be better
integrated with other aspects of waterway management and have more focus on the
ecological processes and ecosystem services that are the basis of the beneficial uses.
For example, how does the concept of ‘beneficial use’ integrate with the objective of the
Environmental Water Reserve? How do the objectives of the SEPP line up with the Victorian
Waterway Management Strategy and its constituent regional strategies? How are the many
agencies identified in the VWMS with a role in water quality management 2 making use of the
concept of beneficial use?
The beneficial uses are not framed in terms of the ecosystem services that the water
environments provide. It could be useful to look at what ecosystem processes underlie each of
the beneficial uses and then consider what water quality standard is required to support that
ecosystem process.
Finally there are many inconsistencies and mysterious gaps in the way the beneficial uses are
applied. For example, why are important uses such as fish passage and indigenous riparian
vegetation, that are important throughout the state, restricted to the Yarra segment? Why is
aquifer recharge limited to the Latrobe and Thomson catchments when it occurs across the
state and certain catchments eg the Ovens are known to have a close interconnection? What is
the difference between ‘potable water supplies’ and ‘water for human consumption’? Why are
no cultural or spiritual value s assigned to groundwater? ‘Agriculture irrigation’ and
‘agriculture parks and gardens’ all extract water from rivers, wetlands and groundwater.
Some of the results in Tables 3 and 4 are equally mystifying. Where are the rivers and wetlands
that do not provide aesthetic enjoyment? Or the rivers that do not provide water for human
consumption – even if they don’t have an offtake pipe to a water treatment plant they are
undoubtedly tributaries of rivers that do. There is a tendency to underestimate the beneficial
uses our waterways provide.
Only 5% of rivers in Melbourne Water’s catchment are said to provide non-indigenous cultural
and spiritual values. Given the central place the Yarra and Maribyrnong Rivers occupy in
Melbourne’s history, culture and psyche this is an extraordinary statement. Improvements to
2 VWMS p
water quality in these rivers has an incredible economic and social benefit, particularly for
recreation and tourism, and standards should not be lowered for urban areas. As Melbourne
University’s research in Stringybark Creek shows, it is possible to drive significant
improvements through relatively simple measures which could be scaled up in a cost effective
17. What do you think about the current indicators, the approach for deriving objectives
and the proposed changes?
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?
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, or
example, voluntary or mandatory codes of practice, regulation via licencing?
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)?
These questions are outside our area of expertise.
For further information please contact:
16 July 2015
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