State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
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.
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?
SEPPs set the objectives and standards for receiving waters (bays) for stormwater runoff from new developments. MPA needs to ensure that the Urban stormwater standards (e.g. Section
46 of the Consolidated SEPP) are upheld during the planning for new developments (precinct structure plans).
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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?
At a precinct planning scale, the specific stormwater targets outlined in the Best Practice
Environmental Management Guidelines (1999) are used during the detailed integrated water management assessment typically undertaken for precinct structure plans, and now being referred to during planning for inner area redevelopment planning.
Question 3: Do you have any concerns about the proposed working title of State Environment Protection Policy (Waters)? If so, what are they?
There are no concerns about the proposed title
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?
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?
Demonstration of “feasibility” is linked to identifying the available funding and resources within the 10 year policy cycle. The ability to fund the required improvement works is critical to feasibility.
An “aspirational” end point is important to provide the framework within which successive
“feasible” programs are delivered. There is of course also an element of value in setting aspirational objectives – despite being difficult to attain, aspirational targets should demonstrably deliver values in excess of expected costs.
This objective is supported in principle because a balance between environmental, economic and social outcomes is considered to be important. A critical issue will be the assessment of performance and the costs to achieve the desired outcomes.
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
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?
A limited focus on environmental issues can ignore current government policy which aims to accommodate future population growth whilst maintaining housing affordability.
Development and growth needs to consider water and environmental issues, but this should be part of a wider approach which deals with these issues in existing established areas of
Melbourne as well.
The balance also needs to explicitly consider whether the value of improved water environments is in excess of expected costs and that beneficiaries, especially where this involves protection of values for the benefits of the whole Victorian community, contribute to the necessary funding.
In Melbourne’s growth areas, a high standard of water and environmental outcomes is being achieved through the delivery of best practice stormwater treatment and protection of environmentally sensitive areas. This is in stark contrast when compared to the existing established areas which can be already degraded with little scope for improvement.
A major challenge is to maintain equity of funding and outcomes between green-field development and existing redevelopment areas recognising the broad beneficiaries of improved water environments and avoiding greenfield being expected to carry the funding burden for all Victorians.
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?
Consistency is good – but how to ensure local water needs are protected and embraced by the new policy?
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?
Highly modified urban waterways that are currently in poor condition.
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
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?
No comment
Question 11: Are there any problems with the spatial arrangements or segment boundaries in the existing Water
SEPPs? If so, what are they?
No comment
Question 12: What do you think are the advantages or problems with the new approach to segments and sub-segments?
No comment
Question 13: Are there any features of the landscape that you would like to see as a standalone segment or sub-segment?
No comment
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?
No comment
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Question 15: What method or approach could be used to apply the beneficial uses to segments and sub-segments?
No comment
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?
No comment
Question 17: What do you think about the current indicators, the approach for deriving objectives and the proposed changes?
No comment
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?
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?
Caps may be a useful measure, however they provide little guidance on how best to address high loads – especially as a low concentration in a large flow could contribute to a high load, but be very difficult to address, while a high concentration in a lower flow source may be more amenable to abatement. Load seems more relevant to receiving waters, while concentration may be more relevant to stream health.
No comment
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
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)?
No comment
Any other information you would like to share:
A clear and publicly reviewed assessment of approaches to managing at-risk needs to be developed as part of or as a required activity of the SEPP. This needs to include implantation plans that explicitly address prioritisation, cost-effectiveness, funding sources and responsibilities and beneficiaries to ensure a balance between the aspirations of the SEPP and economically responsible actions. This could well include the development of codes of practice related to responsibilities, technical guidance, etc. The development of aspirational improvement programs without consideration of the relationship between costs and benefits can lead to misallocation of resources and sub-optimal outcomes.
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