MORDIALLOC BEAUMARIS CONSERVATION LEAGUE INC.
SEPP (Waters) Review
Department of Environment, Land , Water and Planning,
PO Box 500,
Melbourne Vic 3002
6-7-2015
Dear Sir, Discussion Paper-State Environment Protection Policy (Water) Review
In responding to the SEPP (Water) Review it is intended to address the need for the greatest possible
protection for Victoria's groundwater system. Australia is an old, dry continent with only 6% of its total
land mass arable farm land mainly along the eastern seaboard and in South and East Gippsland where
there is good soil and reliable rainfall. Most of Victoria's prime agricultural land lies to the south east of
Melbourne, and as Victoria's population increases, it is essential that this land is preserved and protected
to provide food security for the State as the effects of climate change become more pronounced.
Victoria's groundwater resources have been widely used. In 1991, of the States 69,000 bores, over 24,000
were in use supplying sixty Victorian towns totally dependent on groundwater for domestic
supplies.1.Today large potato and carrot producers near Murrayville and Kaniva are relying on
groundwater drawn, 24/7, from aquifers fed from the Murray Darling Basin. The demand for water in the
South Eastern Province will continue to grow as the Berwick/ Pakenham Growth Corridor develops. The
demand for irrigation water is likely to centre principally on the Cranbourne region where vegetable crops
are already established. Future intensification of production will increase the demand for the beneficial
use of this water resource. 2.
Groundwater from the Fyansford-Brighton Group aquifers in the Southeast Province is considered to be
a significant source of water to wetlands particularly in the Carrum-Seaford area and is therefore an
important beneficial use worthy of protection. More detailed water balances should be computed to
accurately determine the magnitude of the groundwater component and to develop management plans to
ensure that the environmental integrity of the wetlands is maintained. 3.
Groundwater is subject to the dynamics of underground flow from recharge to discharge areas and to
chemical, physical and biological interaction with the surface and subsurface environment. The rate of
aquifer discharge depends on factors such as climate, vegetation cover and human activities, for example
adding waste water contaminants from coal seam gas mining to the rivers and aquifers, as is happening to
Queensland Rivers and the Great Artesian Basin as a result of fracking.4. Resource depletion occurs when
there is over pumping resulting in confined and unconfined aquifers allowing intrusion of inferior quality
groundwater from another aquifer, river, lake or sea.
1.5. Future significant threats to water quality as stated p.8,
*population growth leading to changing land use and increasing urbanisation
*greater intensity of agriculture particularly export markets under foreign ownership
*effects of climate change on flow regimes and extreme events such as droughts and floods
*moratorium lifted to permit coal seam gas fracking to commence in Victoria
There are challenges ahead if Victoria's water resources are to be protected and yet “the current Water
SEPPs have no compliance or enforcement clauses'. Therefore in answer to Question 19 : it is felt that
:-The preferred method of management for at-risk areas requires greater intervention:- mandatory codes
of practice and regulation via licensing. The EPA must also be well resourced and have mandatory means
of intervening when there are breaches of codes of practice and threats to water quality.
As foreign ownership of large holdings of agricultural land intensifies in Victoria it is essential that
mandatory codes of practice are in place to ensure that penalties for polluting and over-use of finite water
resources can be enforced.
Policy goals and principles
The principles upon which the policy should be based must continue to be:(i)
polluter pays: those who generate pollution and waste should bear the cost of containment,
avoidance or abatement;
(ii)
(iii)
intergenerational equity: the present generation should ensure that the health, diversity and
productivity of the environment is maintained or enhanced for the benefit of future
generations;
precautionary principle: where there are threats of serious or irreversible
environmental damage,lack of full scientific ce1iainty should not be used as a reason for
postponing measures to prevent environmental degradation. 5
Questions 5,6,and 7 of the Summary of questions queries the need to "balance economic and social
development" and "protect and improve the quality of Victoria's water while providing for economic and
social development" and "How should we manage appropriate 'trade-offs' between them?"
Only 6 per cent of this driest inhabited continent is arable land. The continued rate of development over
productive farmland is raising concerns about the neglect of food security thus it is doubtful if there
could be any 'appropriate trade-offs' or balance when food security is in danger. The emphasis must be
on protecting what is a distinctly finite resource- our water.
1. "Foolish planning forgets about food." Age Editorial 25 May 2012
2. Leonard,John. Port Phillip Region Groundwater Resources-Future Use and Management,
Department of Water Resources Victoria p250
3. Ibid P.270
4. Great Artesian Coal Seam Gas Risk in the Australian 7 November.
5. State Environment Protection Policy. Groundwaters of Victoria. December 1997.