Sullivans Creek Catchment Group Inc Environment, Communications, Information Technology and the Arts References Committee Senate Water Inquiry Submission Sullivans Creek Catchment Group Inc. (SCCG) is well positioned to bring a community perspective to the Senate Water Inquiry regarding urban stormwater management in the ACT. SCCG has taken an advocacy, planning and on-ground implementation role to progress best practice stormwater management in Sullivans Creek Catchment. SCCG has undertaken these roles through the development and maintenance of an effective and cooperative working relationship with the ACT Government at all levels. The work on Sullivans Creek Catchment provides a model that is applicable across all urban subcatchments in the ACT. For the purposes of this submission, SCCG has focused on the constraints and barriers to achieving established community goals regarding the best practice restoration of Sullivans Creek. The barriers and constraints relate to agency institutional arrangements, the development of (community/government/business) partnerships, existing policy and the provision of funding for planning and on-ground action. The barriers and constraints discussed have directly impacted upon SCCG’s ability to plan and implement on-ground action in Sullivans Creek Catchment. SCCG has also made some more general observations regarding barriers and constraints to more broadscale implementation of sustainable stormwater management in the ACT. SCCG has noted that the new ACT Government appears to have engaged with the issues around sustainable stormwater management and significant planning progress has been made over the last four months. Declarations: Where SCCG is Coming From SCCG believes that the ACT must take responsibility for minimising stormwater pollution entering the Molonglo and Murrumbidgee Rivers. The ACT is the largest urban city in the Murray Darling Basin and located in the upper Murrumbidgee catchment and therefore has a significant impact on downstream human, flora and fauna communities. 1 The only major pollution issue in the ACT is stormwater pollution. Stormwater management should therefore be the highest priority issue on which to focus pollution minimising efforts in an environmental context. SCCG believes that active and effective catchment based community groups have a fundamental role in the planning and implementation of best practice stormwater management in the ACT. This belief stems from the fact that each individual living and working in an urban catchment impacts directly on stormwater quality. The broader community must be engaged adequately enough with the issues and understand their impacts as an individual to maximise the reduction of stormwater pollution. Community groups are well placed to increase community action and individual responsibility to reduce negative behavioral impacts on stormwater quality. It is impossible for governments to achieve sustainable stormwater management alone. There are many stakeholders (many of who are notorious for noncompliance) that will need to embrace sustainability principles voluntarily. The active participation of stakeholders such as the consultant industry (engineers, architects and landscape architects), land development and construction industry (developers and contractors) is fundamental to the success of best practice stormwater management. Community groups can provide the means to help engage these groups with a “responsible business / corporate citizen” approach that may work towards minimising the use of the adversarial “big stick” approach to implementation. The ACT has the highest rate of volunteerism in Australia and many volunteers demonstrate a concern for environmental health. Volunteers are a priceless resource and should be incorporated into the process of achieving sustainable stormwater management through a variety of participatory mechanisms. SCCG consider neighborhood wetlands/vegetated channels together with Water Sensitive Urban Design (WSUD) measures incorporated on all blocks (redeveloped and greenfield) to be an integral component of what constitutes ecologically sustainable stormwater management in an urban context. These measures meet multiobjectives relating to extended detention, water re-use and conservation, urban biodiversity, recreational opportunities, community development, and visual quality of the creek corridors. SCCG has certain parameters around which it operates regarding planning and implementation of activities. These are to: Involve the community in all levels of catchment management and planning Base planning directly on community consultation outcomes Coordinate the successful integration of stakeholders in a process of shared decision making Facilitate agreement on objectives and actions Incorporate specialists to ensure technical and practical feasibility Provide a model for other urban catchments Publicise activities to the broader community. 2 SCCG’s Major Achievements to Date SCCG produced a draft version of the “Sullivans Creek Catchment Management Plan” (SCCMP) in 2000. The plan outlines strategies and actions to restore Sullivans Creek Catchment with an emphasis on best practice stormwater management. The plan envisages the restoration of the concrete lined creek channel through the construction of strategically located wetlands and vegetated channels. The SCCMP also outlines strategies to participate in and promote the implementation of WSUD in ACT Greenfield and re-developments. SCCG is keen to facilitate the development of Community/Government /Business partnerships. SCCG focus on engaging the broader catchment community and the private (business) sector to increase the level of engagement that the urban community has towards the issues raised and implementation of the SCCMP. The SCCMP outlines a wetland restoration strategy that identifies 14 sites for tributary located wetlands in the urban part of the catchment. The first of these wetlands was constructed on the O’Connor Tributary in 2001. SCCG lodged a Development Application (DA) and Preliminary Assessment (PA) which were approved by Planning and Land Management (PALM), Department of Urban Services (DUS). The wetland was funded largely by the private sector (CIC Pendon and Community Housing Canberra $165,000) with the remaining funds provided by the Federal Government (Natural Heritage Trust (NHT) $35,478.30) at a total cost of $200,478.30. This wetland is the first to be retrofitted into a densely populated and developed urban area in the ACT. The project was initiated, developed and managed by SCCG. Volunteer community members were involved in all phases of the project and undertook the landscaping component. SCCG is keen to finalise the SCCMP in 2002. To do so, the following components of the plan need to be developed, agreed upon between stakeholders and documented in the SCCMP. Identification and agreement of priority actions Identification and agreement on roles and responsibilities of government agencies and community and business stakeholders Costing of priority actions Investigation of a range of ACT and external funding sources to implement agreed priority actions Negotiation with DUS of an agreed program of works, allocated funds and timeframes based on priority and capacity for implementation. SCCG has had much difficulty making arrangements for this necessary planning work to be undertaken. SCCG has also been unable to program further on-ground works for 2002/2003. 3 BARRIERS AND CONSTRAINTS The break-up of government into business areas has caused fragmentation in capacity to deliver services to the community and to perform basic functions, for example, protection of property from flooding. Each agency has decreased ability to appreciate interdependencies between business areas, and therefore decreased control over managing ecological systems across a catchment landscape. There is an apparent lack of coordination and strategic planning across DUS agencies to enable the department to seek sustainable outcomes through stormwater /waterway management. That is, urban catchments are generally not managed for water quality or conservation outcomes. The conventional focus has been on a waterway’s drainage function that involves ensuring stormwater is removed from residential suburbs as quickly as possible through hard infrastructure. There has been a significant value shift in this approach stemming from the ACT community, whereby stormwater is now valued as a resource to be harnessed and used (and re-used) on site and waterways are now valued as living systems. Community Participation in Best Practice Stormwater Management and the Development of Community / Government / Business Partnerships “An Integrated Catchment Management Framework for the ACT” (Environment ACT, 2000), is a policy that provides community groups with important principles to guide their contribution to the implementation of Integrated Catchment Management (ICM). Community produced sub-catchment plans are given a central role in achieving ICM in the ACT. The implementation of ICM focuses on the integration of land and water management on a sub-catchment basis. That is, recognising the interdependencies between the biophysical functions of the various natural resources and managing them for the desired outcome. In an urban area natural resources need to be managed so that a healthy and safe environment exists for all inhabitants, including endemic flora and fauna. The ICM Framework provides a foundation for the argument that more integrated (effective, cooperative and coordinated liaison) between government agencies is required to meet ICM objectives. It is implied in the ICM framework that a formalised structure for increased coordination within DUS is necessary to drive the further integration of natural resource management based activities. That is, the programming of priority actions, identification of roles and responsibilities, and associated human resources and budgets. 4 SCCG has attempted to progress this policy approach with the ACT Government to finalise the SCCMP. It appears that community interest in catchment management is driving ACT policy, however there is no policy framework to determine for SCCG how the community produced SCCMP has been received by Government. There have been verbal statements of in principle support for the SCCMP and comments provided from Government on the content detail. As is stands, there is no formal indication from Government of the level of commitment for the SCCG regarding the long-term implementation of the plan. The ICM framework and its implementation plan fail to address this fundamental issue. It is clear that the ACT lacks adequate policy to guide sustainable water resource management and provide appropriate means for community proposals / participation. Environment ACT, DUS has indicated that work is currently being undertaken to develop a comprehensive Water Management Strategy as part of the review of the Water Resources Act. A statutory mechanism that outlines a framework for the implementation of a range of sustainable management activities is required. SCCG will welcome this strategic initiative. SCCG would like to see this policy provide for community participation through the development of joint projects. SCCG has also proposed the formation of an ICM government / community coordination committee (membership from all major DUS agencies and health and education agencies and community representatives) responsible for overseeing the preparation of annual subcatchment implementation plans. SCCG has managed to produce a catchment plan through engaging a range of stakeholders to provide technical advice that included government representatives from all relevant DUS agencies. The capacity for SCCG to work effectively with government agencies has been reliant upon developing of effective working relationships with individuals in agencies. It has been difficult at times for SCCG to arrange access to information regarding plans for redevelopment projects where SCCG could contribute positively to the water aspects of a development through an advisory or participatory role. SCCG is in a position to arrange for technical specialists to advise on appropriate water measures on a site or encourage land developer contribution to an off-site project such as an urban wetland. SCCG is keen to implement the SCCMP in partnership with government that will involve a sharing of the financial contribution. SCCG has proposed that a legislative (or strong administrative) requirement for the ACT government to produce Implementation Plans with each budget cycle so that Territory funding is committed through the Capital Works Program and other specified sources in the budget. A Water Management Strategy may perform this necessary role. SCCG would then be in a position to participate as a partner in the implementation of the SCCMP and draw in external funding from a range of sources including the Federal Government (NHT) and the private sector on a project by project basis. Projects undertaken would have a “community face” to draw community participation, build community capacity, strengthen community development and significantly reduce costs of projects through attracting in-kind and cash contributions. 5 The ACT Government through the provision of some baseline funding for projects would be actively supporting SCCG initiatives towards securing corporate funds for on-ground projects. SCCG has demonstrated how this inclusive approach has worked to achieve the construction of O’Connor wetland at no cost to the ACT. The community is leading the way towards sustainable stormwater management in the ACT. The ACT has provided relatively little support (in terms of funding) for community activities to date. There is no formal structure for active groups to contribute to decision making and coordination of government and community activities. Activities need to prioritised, programmed over time, costed and a proportion of the funds committed. SCCG believes that a framework for achieving this is required. The ACT does not appear to be capitalising on opportunities for Federal funding from NHT. The ACT will be required under the new the NHT administration to provide funds that will be matched by NHT. Community groups have a major role in delivering natural resource management in the ACT and therefore need to work closely with Government regarding funding arrangements. The ACT Government is not working actively with community groups to identify opportunities to secure private sector contributions to fund community proposed projects. The production of community produced sub-catchment plans have many benefits to Government. SCCG has identified the following benefits. Community plans: highlight community values to government regarding protection, restoration and enhancement of environmental values in one document; identify for government, the activities the community view as important to meet defined objectives; provide cost-effective solutions to management problems (provision of services); increase communication between government agencies to decrease costs and improve efficiency of planning; stimulate increased contribution of in-kind technical advice to agency planning processes; provide a basis for more integrated and coordinated liaison between agencies for programming government activities and associated budgets; benefit the ACT by community groups securing a non-Territory funding component from federal and corporate sources; provide a means through their development to increase public awareness and education, sharing of information and trust between community and government; provide a basis for agencies to work together to secure political and resource commitment; focus attention on the broader natural resource issues (ie. sub-catchment focus rather than the narrow focus of “a patch”. 6 SCCG Observations: Constraints to Broadscale Implementation of Best Practice Stormwater Management in the ACT There appears to be a lack of strategic planning across DUS to deliver a form of stormwater management that meets shifting community values. This is particularly noticeable in relation to Planning and Land Management (PALM) (responsible for planning) and Roads ACT, City Management (responsible for asset construction and maintenance) regarding treatment of stormwater in re-developments and greenfield developments. There is conflict between ACT Roads and PALM regarding the maintenance costs of currently unspecified WSUD measures and the concern that the provision of capital funds will not be followed up with associated maintenance funds. There is also an apparent perception by developers that there is increased liability associated with WSUD measures due to the lack of specified guidelines and standards for engineering / landscape structures and their associated maintenance requirements. PALM is currently in the process of arranging for a consultant to develop standards and guidelines for broadscale WSUD that will clarify a number of these issues for private sector investors and government agencies. Once these guidelines are in place PALM will then be in a position to incorporate WSUD measures into PALM criteria for assessing DAs and PAs. The consultant industry (architects/engineers), construction industry (contractors/ developers) and PALM DA assessment officers require training in how to apply WSUD principles to both redevelopment and greenfield development. WSUD principles need to be incorporated into DA plans from the beginning to ensure that linkages can occur between the various uses and reuses of water on a site. SCCG understands that training seminars are currently being organised for some of the above stakeholders for mid this year. From a catchment perspective, the review of PALM’s planning process for greenfield residential development should include a more integrated systems approach that includes: Protection/restoration of waterways and drainage lines Incorporation of pollution control ponds/ neighborhood wetlands WSUD measures on residential blocks Open space reserves, and Conservation of endangered communities and threatened species habitat. Essentially the technical solutions to achieve best practice stormwater management and integrated catchment management are available and now require documentation of tailored specifications for the ACT. The approach is relatively cost-effective and meets multi-objectives. The implementation problems relate to strategic planning and coordination of people - inter-governmental and across community and business stakeholders. 7