13 July 2015
SEPP W aters Review
Department of Environment, Land, Water and Planning
PO Box 500
MELBOURNE VIC 8002
Via email: Water.SEPPreview@delwp.vic.gov.au
SUBJECT: VICTORIA ’S STATE ENVIRONMENT PROTECTION POLICY (WATERS) REVIEW
Cement Concrete & Aggregates Australia (CCAA) welcomes the opportunity to provide a submission to the Department of Environment, Land, Water and Planning on the State Environment Protection Policy
(Waters) Review.
Introduction
CCAA is the peak industry body for the heavy construction materials industry in Australia including the cement, pre-mixed concrete and extractive industries. For your information, a list of CCAA Victoria ’s members is provided in Appendix 1.
CCAA members account for approximately 90% of the $7.21 billion in revenues generated by these industries that, between them, employ 18,000 Australians directly and a further 80,000 indirectly.
CCAA members operate rock quarries, sand and gravel extraction sites, cement production and distribution facilities and concrete batching plants throughout Australia.
There are approximately 540 operating quarries across Victoria that produced some
47.4 million tonnes of stone, limestone, gypsum, sand and gravel in 2012/13 which was used to produce building and construction materials such as cement, bricks, concrete, tiles, pavers and road paving. The value of production from these quarries is estimated to be $737.4 million.
The Victorian premixed concrete industry produced 6.5 million m
3 of premixed concrete in 2012/13 worth around $1.4 billion. This is enough to build around 100,000 new homes, 100 Eureka Towers or 44
Bolte Bridges. Further value is added through the manufacture of concrete products and delivering concrete services.
CCA A’s members service local, regional and national building, construction and infrastructure markets.
The reliable and cost-effective supply to these markets is fundamental to sustainable growth and it is
CCA A’s aim to promote policies and planning frameworks that recognise the importance of these materials to Australia ’s sustainable future.
CCAA welcomes efforts to simplify the regulation and enforcement of water policy that provides increased certainty, reduced costs and reduced time to industry and results in better outcomes for all stakeholders.

CCAA makes the following comments on key aspects of the SEPP.

The SEPP should be clear about requirements for seasonal and intermittent waterways compared to permanent streams and also should be clear about requirements for urban drains v's waterways. The “definition of waterway” issue is important as it impacts on industry’s ability to secure authority approvals for new quarries and/or extensions of existing operations. The major problem being a waterway can be a large flowing river or a small ephemeral channel that might only convey receding floodwaters during very infrequent floods or even a gently shaping inverted contour formation on open, cleared land. When assessing projects, the requirement for waterway protection does not take in account the different types – they are all deemed to have the same importance.

The SEPP should be clear to allow an operator to understand what the 'base case criteria, acceptable to EPA are'. If these are not achieved then scientific modelling and baseline records may need to be established, but at the current point in time it is not clear when 90 th percentiles apply, or 80 th percentiles apply and so on. There should be a basic rule and if this basic rule of thumb cannot be achieved due to whatever reason, site assessment and scientific analysis should then occur.

The Attainment Programs and Indicators and Objectives Review may impact the ability of industry to discharge waters (groundwater and stormwater) to stormwater drains, rivers and other defined waterways as a consequence of the review and changes to the Indicator discharge limits for various beneficial uses. Current operations may be compromised by the setting of higher water quality requirements.

A key question for industry is how will any changes be implemented and what effect it will have on current Discharge Licences. Industry strongly supports reasonable transitional arrangements with the basic right that any new regulation should not be retrospective and preserve existing use rights.

Any expansion in the number of indicators will increase the testing and audit costs for discharges or diversions. Any increases in costs to industry should be offset by increased benefits such as reduced regulatory burden and red tape or streamlined administrative processes in other areas of the SEPP.
The Victorian planning and regulatory environment needs to be internationally competitive to continue to attract capital to invest in Victoria to ensure a sustainable and competitive heavy construction materials industry. This in turn facilitates Victoria ’s improved productivity, housing affordability and lower infrastructure costs.
CCAA looks forward to working with Government to achieve these key objectives.
Please do not hesitate to contact me to discuss any of these issues in more detail.
Yours sincerely
Brian Hauser
State Director Vic/Tas
CCAA Submission on Victoria
’s SEPP (Waters) Review July 2015
Page 2 of 3

Boral Construction Materials Boral Cement Limited
Cement Australia Pty Ltd
Aidan J Graham Pty Ltd
Alsafe Pre-Mix Concrete Pty Ltd
Axedale Sands & Gravel
Barossa Quarries Pty Ltd
Barro Group
Hanson Australia Pty Ltd
Holcim (Australia) Pty Ltd
Baxters Concrete
Broadway & Frame Premix
Concrete Pty Ltd
Fulton Hogan Construction Pty Ltd
Hillview Quarries Pty Ltd
Hymix Australia Pty Ltd
Independent Cement & Lime Pty
Ltd
Mentone Pre-Mix
Premier Resources T/A Hy-Tec
Industries Pty Ltd
Rocla Pty Ltd
Agi-Kleen Pty Ltd
BASF Construction Chemicals
Australia Pty Ltd
Concrete Colour Systems
Concrete Waterproofing
Manufacturing Pty Ltd T/a
Xypex Australia
Grace Construction Products
Sika Australia Pty Ltd
WAM Australia
CCAA Submission on Victoria
’s SEPP (Waters) Review July 2015
Page 3 of 3