State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Name: Alyson Macdonald
Organisation:
(please note however the responses
provided are my individual view and do not necessarily reflect those of
).
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):
I agree with the approach of integrating the groundwater and surface water SEPPs, for a much
more consistent and streamlines approach.
Question 1: What is your understanding of your roles and
responsibilities under Water SEPPs?
We need to refer to the SEPPs in undertaking environmental audits, and apply the criteria to
assess protected beneficial uses.
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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?
As a company that undertakes environmental audits, we use the SEPPs to assess whether
water pollution has occurred and whether it needs to be remediated.
Question 3: Do you have any concerns about the proposed
working title of State Environment Protection Policy (Waters)? If
so, what are they?
No – good idea to integrate.
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?
I’m not sure why we need ‘feasible’ objectives. Point source emissions should be permitted
based on aspirational (risk-based) objectives, and diffuse source should still be aiming to
reach the aspirational objectives, even though this may not be achieved in the short term. My
understanding is there is currently no penalty for failing to meet aspirational objectives for
example at stream or beach monitoring points, so EPA should still be monitoring when
aspirational objectives are not being met and also highlighting improvements via long term
trend analysis.
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?
It needs to be defined further – eg SUSTAINABLE economic and social development.
Otherwise it could be interpreted as development at all costs.
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?
Again, I think this needs to be specifically defined to avoid it being used as a cop-out. What is
the baseline here for protection of the water environment (minimum standard)? For
example, is protection of groundwater sufficient grounds to deny mining rights? This aspect
should not be open to interpretation.
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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?
Everybody has a different idea of how these things should be balanced. The definition needs
to be as specific and measurable as possible – perhaps consider adopting international
sustainable development or triple bottom line concepts.
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?
No, I think it’s a great idea.
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?
Perhaps these type of environments should have their own segment category. For example,
you still want to protect the birds which will contact these lagoons, but other fauna and flora
will be less relevant.
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?
Overall, yes. For groundwater it may be appropriate to better define yield as a secondary
consideration, for example what yield is considered low enough that groundwater extraction
is not feasible?
Question 11: Are there any problems with the spatial
arrangements or segment boundaries in the existing Water
SEPPs? If so, what are they?
Yes, the exact segment boundaries are currently mapped only on Figure 1 of the Waters SEPP,
with no spatial references such as GPS coordinates or surface features overlaid. It would be
much clearer if a map was provided with, for example, major roads or other features marked
and it would be also very useful if this data was provided as an interactive map which could be
zoomed in to check a specific area (eg on Visualising Victoria’s Groundwater website).
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Question 12: What do you think are the advantages or problems
with the new approach to segments and sub-segments?
Advantage: more consistent with the land SEPP. Disadvantage: Are we admitting defeat by
requiring a lower level of protection where the environment is already degraded by humans?
Question 13: Are there any features of the landscape that you
would like to see as a standalone segment or sub-segment?
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?
Yes.
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?
Also consider vapour intrusion from groundwater to be consistent with the ASC NEPM –
protection of buildings and structures should include consideration of vapours in indoor air
originating from groundwater.
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State Environment Protection Policy (Waters) Review
Response to questions from discussion paper
Question 17: What do you think about the current indicators, the
approach for deriving objectives and the proposed changes?
Some specific values are outdated, based on current scientific knowledge. They should be
made consistent with the Australian Drinking Water Guidelines for example.
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?
Greater regulation/management – cumulative impacts of point source emissions, particularly
when considering approvals for new developments such as land rezoning or mining leases.
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:
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