State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Name:
Organisation: Southern Grampians Shire Council
Date: 13 July 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?
Municipal Councils use Water SEPPS when evaluating, investigating, making decisions and
advocating in relation to town planning, management of domestic wastewater, stormwater,
waterbodies and natural resource management matters. Councils undertake these activities
to ensure sustainable land use and to ensure that the community has access to amenity, safe
drinking and recreational waters to prevent irreversible threats to health of humans or the
environment.
Municipal Councils, the Environment Protection Authority (EPA) , Catchment Management
Authorities (CMAs), Water Authorities and the Department of Environment , Land, Water and
Planning (DWELP) work together in harmony.
1
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?
We use the Waste and Wastewater Management section of Water SEPP. Section 32, Onsite
domestic wastewater management requirement needs to be expanded to include domestic
wastewater management systems without a Septic Permit. Most septic systems within the
local government area have been installed prior to introduction of Septic Permits. It is
difficult to regulate domestic wastewater management of systems without a Septic Permit
where systems are failing due lack of regulation by the Environmental Protection Act and lack
of direction in the Water SEPP.
The Water SEPP should promote the extension of reticulated sewerage systems to properties
which currently have domestic wastewater systems (septic systems or similar) within
Residential Zones.
Throughout Victoria there are many existing dwellings and business with septic systems on
small blocks which are having difficulties maintaining their wastewater effluent onsite to
prevent the contamination of waterways and soils. These dwellings and business are within
unsewered and sewered townships, but there is no imperative or incentive for Water
Authorities and property owners to connect to reticulated sewer.
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?
2
State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
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?
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?
The proposed SEPP (Waters) objective is supported as it aligns with ecologically sustainable
development principles, with a message that is concise and easily understood.
We support the need for development in rural townships alongside the protection of waters.
Currently development is being hampered by the need for a large land area to retain waste
water onsite. Support from EPA and water authorities is needed to identify and develop
affordable solutions as a feasible alternative to the traditional gravity sewer, which cannot be
justified in small townships with a low rate of population growth.
The challenges of balancing economic and social development with protecting and improving
water quality include:
 Issues assessed financially not holistically leading sustainable developments and not
rectifying existing issues
 Economic developments are often perceived as more beneficial that social
developments
Emphasis should be placed on ecological sustainable principles to balance economic and
social development.
There is potential for severe and permanent damage to groundwater quality caused by
fracking during the process of onshore gas extraction. The SEPP (Waters) needs to prioritise
the protection of groundwater over any possible economic development related to this
industry.
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?
It is expected that there may be some issues arising from creating one consistent SEPP but
these may not become obvious until the SEPP is adopted and implemented. It is
recommended that the new SEPP is reviewed within two years to address any unforseen
issues.
3
State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
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?
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?
4
State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
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?
The following beneficial uses should be protected to ensure rural areas can maintain animal
health and food production without negatively impacting water resources:
 Groundwater used for agricultural and irrigation.
 Rivers, wetlands and lakes used for stock watering
Question 15: What method or approach could be used to apply
the beneficial uses to segments and sub-segments?
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?
Question 17: What do you think about the current indicators, the
approach for deriving objectives and the proposed changes?
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?
5
State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
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?
Many existing dwellings have insufficient area to retain their waste water which is
contributing to pollution of surface and ground waters. As time goes on, more will fail as they
reach the end of their functioning lives and homeowners on small allotments don’t have
space to install new trenches so the problem will continue to grow. The existing SEPP states
that Councils must ensure domestic waste water management is improved but when there is
inadequate land available there is nothing Councils can do. It also states that Water
authorities must work with the EPA and DEWLP to minimise the impact of waste water but
they also should work with and support Councils to do so regarding septic systems.
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)?
Any other information you would like to share:
6