State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Name:
Organisation: North East Water
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):
Whilst the combining of SEPPs into one policy seems to be a good idea, there is the potential
that it could make the policy confusing.
Question 1: What is your understanding of your roles and
responsibilities under Water SEPPs?
The roles and responsibilities of water corporations are clearly defined within current SEPP
policy. Clearly defined roles and responsibilities within the new SEPP policy is essential to
ensure implementation of the policy. Having the Water Corporations clearly identified
acknowledges the important role we play In overall Victorian catchment water quality.
Collectively this could drive sensible state outcome through being emphasized.
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?
North East Water uses current SEPP policy for strategic planning, in particular for wastewater
strategies. Particular sections (Beneficial Uses, Water Quality Objectives and Biological
Objectives) of SEPP are used extensively in Ecological Risk Assessments completed by North
East Water.
The new SEPP policy could be improved by providing a clear path or framework for decision
making.
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?
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?
Yes. To ensure the adoption of this policy, the policy needs to allow for economic and social
development whilst also protecting the environment.
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?
Finding a balance between economic/social development and protection/improvement of
waterways is the cornerstone of this policy. This policy needs to develop rigorous
methodology for ensuring this, as it is often difficult to find the balance between economics
and environmental impact. Additionally, it is often difficult to place a dollar value on the
environmental improvements that can be obtained.
2
State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
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?
See question 6.
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?
Borders for surface water segments and groundwater segments may not align.
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?
3
State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Question 11: Are there any problems with the spatial
arrangements or segment boundaries in the existing Water
SEPPs? If so, what are they?
These comments refer specifically to catchments in North East Victoria. The current
boundaries place the entire length of a river within one segment. For example, Nariel Creek
(also known as Corryong Creek in lower reaches) begins in the Northern slopes of the great
dividing range. The upper catchment is forested and remains relatively intact with good water
quality. Comparatively, the lower section of the river has been largely cleared and water
quality is highly impacted by agriculture and other activities. Despite this under the existing
SEPP the same water quality and biological objectives apply to entire length of the creek.
Perhaps a ‘topographic’ approach would provide for a better representation of water quality
objectives for rivers and streams.
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?
The existing SEPP does not consider raw water storages. These storages could be considered
given the importance of water quality for potable supply systems. Recent policy changes with
increased access to the public may have a detrimental to beneficial uses.
Some clarification of where natural springs sit within the new SEPP policy may also be
required i.e. groundwater vs surface water.
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?
4
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?
The best method to apply beneficial uses would be in individual CMA waterway strategies.
Marine estuaries → Potable water supplies
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?
The aquatic ecosystems beneficial use needs to be broken down into more specific areas as
current definition is too broad.
There is currently no beneficial use which encompasses the value of potable water supplies to
communities.
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?
Consideration should be given to additional groundwater quality indicators such as
manganese, arsenic, iron, E.coli and enterococci.
Consideration should be given to including alkalinity as a surface water quality indicator.
North East Water recently invested significant CAPEX at the North Wangaratta WWTP to
increase winter storage and reclaimed water capacity. This has reduced the requirement to
discharge to Reedy Creek (an ephemeral waterway) particularly during periods of low flow.
This irrigation expansion has considerably reduced nutrients loads in the waterway due to
reduced discharges from the Wangaratta WWTP. However, due to the current EPA licence
using annual medians for compliance it resulted in the site no longer being able to achieve
compliance, as discharges to water now only occur during winter periods when total nitrogen
and ammonia concentrations are highest. To address this issue North East Water submitted a
licence amendment to EPA Victoria to increase the licence limits for total nitrogen and
ammonia. EPA Victoria approved this licence amendment which ensures improved waterway
quality whist also assisting for greater licence compliance.
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?
The new SEPP policy needs to provide a clear (pathway, framework, tool) for how at risk areas
need to be managed i.e. recovery plan for threatened species.
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)?
As is highlighted in the discussion paper the SEPP review needs to address the current gap of
diffuse source impacts to waterways.
Any other information you would like to share:
North East Water generally supports the responses to the SEPP review submitted by Vic
Water. There was however a number of areas where North East Waters view of the current
SEPP differ to that of other Victorian water corporations. In particular it is North East Water’s
opinion the existing SEPP policy allows for the use of risk based decision making when
applying the ERA framework.
SEPP should remain as relatively high level policy, and should direct tactical implementation
via regional strategies eg. CMA strategies need to provide framework and guidance. These
strategies should drive the specific priorities, and local issues which need to be addressed,
which may also shift over the life of the policy.
6