The Concerned Waterways Alliance (CWA) is a network of community and environment groups from Gippsland to the Otways. We share a deep concern about the degraded state of southern Victoria’s rivers, wetlands and aquifers, and are committed to improving their health for the benefit of current and future generations. We welcome the opportunity to comment on the draft strategy ‘Water for Life’.

General comments

The strategy correctly recognises the impending crisis in Melbourne’s water supply. Climate change has already reduced inflows to Melbourne’s water supply catchments by around 20%[1] with a much larger decline to come according to projections. Meanwhile, the city’s population has a long-term trend of rapid growth and is likely to double by 2070. The strategy predicts a potential shortfall in the city’s water supply of 85 GL by 2030, rising to 600GL by 2070. Rivers and aquifers are completely unable to provide any more water for consumption and are in desperate need of a bigger share of their own water to prevent ecological collapse. The situation is urgent and the solution must be found in alternate sources of water with every conceivable option for future supply on the table for consideration.

Yet the strategy lacks any real sense of urgency. It admits that the city has been fortunate to receive good rains in the last couple of years, with reservoirs at their highest level since 1997, but that the situation could change rapidly. The return of drought conditions could see the city’s water storage drop by 50% within four years yet the strategy’s actions to increase supply all have longer timeframes. Most projects have an 8 to 10 year time frame for planning and construction. We cannot afford to delay with an 85GL shortfall in supply looming in 8 years’ time and a ‘worst case’ future scenario of demand exceeding system yield as early as 2023[2].

Even more important is meeting targets for returning water to rivers to improve their condition and to Traditional Owners as set out in the Central and Gippsland Region Sustainable Water Strategy (CGRSWS). The rivers of the region are in poor condition due to the over-extraction of water and are bearing the brunt of reduced inflows due to climate change[3]. The impact of the many dams and weirs goes beyond reduction in river flows and disturbs the entire food supply of the river ecosystems. Their cumulative effect serves to starve the river of an important quantum of food such that although all the trophic levels may be found downstream, the overall abundance is significantly lower than if those weirs did not trap most of the available organic matter. Our consumption is driving rivers to the brink of ecological collapse.

The Yarra and Thomson rivers alone have a combined 10-year environmental water recovery of 26 GL[4] which must also be found out of increased supply, bringing the total required for 2030 to over 100GL.

Lack of certainty about actual demand in 2030 is no reason for delay. The first action in the strategy ‘Enhance our understanding of water use to improve short, medium, and long-term water use projections’[5] is not due for completion until 2027. All the past work over the last 20 years must surely be available. Precaution dictates that we cannot afford to wait for five years for better projections to be available. We need to commit to action now.

The final strategy should have clearly defined options and timelines to meet a 100GL supply shortfall by 2030. The draft strategy estimates that Melbourne must add 12 GL per year to the water supply to meet the needs of a growing population. Where is the timeline for the 60GL required over the next five years? We cannot afford to fall back on using current entitlements to surface water to their maximum extent every year: the damage to rivers could be terminal.

The strategy notes the importance of increased efficiency and Integrated Water Management (IWM) but sets no targets. What of all the work done in the IWM forums over the last 3 years? How much water can be saved through increased efficiency and what can be achieved in short-term timeframes, say by the end of 2023? What are the targets for IWM at any time scale? What is a realistic volume for stormwater capture and the target for recycled water uptake by 2030? The appendices give some indications but this kind of information needs to be front and centre of the strategy. Genuinely large-scale options such as the city-wide recycled and stormwater system flagged on the CGRSWS will take longer to plan and implement so we are dependent on smaller-scale options to meet the shortfall in the short-term.

If the worst case does not eventuate and the overall shortfall in 2030 is less than 100GL, then more water will be available to be returned to rivers and First Nations. The water recovery targets in the CGRSWS are much less than what is required to halt the ecological decline of our rivers[6] and may turn out to be a case of ‘too little too late’. Earlier water recovery will provide a buffer against future disturbance and greatly reduce the chance of local or regional extinctions and protect the continuing contribution of rivers and aquifers to the consumptive pool into the future.

Consultation on the Discussion Draft of the CGRSWS revealed that consumers are prepared to pay more for water to enable water to be returned to the environment and protect river health. The government’s report on consultation states that:

‘There was strong support for water bills contributing to new water supplies to:

• enable water to be returned to the environment (96% strongly agree or agree)
• to help the water sector adapt to climate change (84% strongly agree or agree)
• provide social, wellbeing or recreational benefits (71% strongly agree or agree)
• avoid large price increases for future generations (71% strongly agree or agree).’[7]

This willingness to pay for improved river health is not considered in any meaningful way, despite the strategy title “Water for Life”.

There is no recognition in the draft strategy of rivers as whole living entities, connected from source to sea and to wetlands and floodplains, with ecological processes and functions intact and healthy. This concept mirrors First Nation understanding of rivers as living, breathing entities, as Wurundjeri Woi Wurrung describe the Yarra-Birrarung, for example[8]. This concept is central to the Yarra River Protection (Wilip-gin Birrarung murron) Act and is referenced in plans such as the Rivers of the West Action Plan but has not yet found its way into water regulation generally. Water for Life makes some effort to address the lack of access to water for Traditional Owners but this welcome development should not be allowed to obscure the lack of focus on the environmental needs and values of rivers that are crucial to Greater Melbourne’s liveability and to its water supply. Without rivers, there is no Greater Melbourne.

Detailed comments on strategy chapters

Executive summary

The summary says all the right things about the impacts of climate change and a growing population on water resource availability (p10) but the “What the strategy will deliver’ is not an adequate response to the challenge:

• Supply Systems Augmentations should include modernisation of the current harvesting mechanisms – many are old and crude and have significant impact on stream process continuity.
• Redundant harvesting infrastructure – not used for many years – needs removal, for example the weir on Flume Creek, tributary Bunyip River. Some existing systems that supply poor quality water could also be considered for decommissioning, for example, Mt Macedon, Rosslyn and Merrimu reservoirs.
• ‘We need a lot of water’ is almost certainly an underestimate as it does not include interconnections to other water supply systems, in particular, supply to Geelong and South Gippsland.
• ‘We need to start now’ has been a catch cry since the release of the original Central Region Sustainable Water Strategy in 2005 when potential supply shortfalls due to climate change were first clearly identified. Planning for alternative solutions was subsequently derailed by the ‘silver bullet’ solution of the Victorian Desalination Project. The final strategy must spell out what our options are NOW, not at some future point when drought hits again and we revert to crisis planning.
• ‘Increased system resilience’ is referenced but not explained. What are the tangible outcomes both for water supply and for river health?

Key deliverables in the next 5 years

This section appears to be well behind government proposals in chapter six of the Discussion Draft CGRSWS. The CGRSWS chapter contains some detail of how supply augmentations will be identified and assessed. It indicates that supply options will be identified and evaluated by water corporations through their urban water supply strategies[9]. As the final CGRSWS is due for release in coming weeks along with the first iteration of the Water Supply Plan, it could be assumed that this planning is well under way. Yet ‘Water for Life’ has no detail other than ‘investing in readiness activities’ and ‘working with government’ etc. If this strategy is not the place for detail, we are left struggling as to where the appropriate place is. We hope that the final strategy, Implementation Plan and ‘adaptive planning approach’ will provide the necessary details.

Another related issue is the mechanism for reducing reliance on river water for consumptive use. Both the CGRSWS and Water for Life state that over time river water will be less available due to climate change and that it will provide a smaller volume to meet consumptive needs. Yet there is no mechanism proposed for reducing Bulk Entitlements held by water corporations to enable the return of water to rivers or for decommissioning existing supply infrastructure that will no longer be required. We hope to see some detail of a mechanism to reduce Bulk Entitlements in the final CGRSWS that will need to be incorporated into Water for Life.

This section makes little reference to returning water to the environment to support the ecological health of waterways, pledging only to support government actions through the CGRSWS. Melbourne Water has assumed the role of caretaker of river health in its water supply catchments and is responsible for the Healthy Waterways Strategy. The latest 2021 report card indicates that water recovery targets in that document are ‘significantly off track’ in all catchments.[10] The current Water for Life strategy significantly underplays the role that healthy rivers and catchments play in providing safe and reliable water supply for Greater Melbourne.

Water for Life seeks to lead the transition to greater use of ‘fit for purpose’ recycled water. We strongly support the aim but note that treatment plants will need to be substantially upgraded to provide water that is truly fit for purpose and of suitable quality for reuse, including for return to streams. This will require EPA guidelines for nutrient load, salinity parameters and chemical composition (including pharmaceuticals and long-lasting contaminants such as PFAS) and a significant upgrade of treatment plants to meet them.

Water for Life Actions

Many actions are described as ‘ongoing’ or have 2030 timeframes. This is the opposite of SMART planning where actions are Specific, Measurable, Attainable, Relevant and Timebound. Some actions meet one or more of these criteria (for example 4.3 ‘Develop and deliver a joint Water Efficiency Plan increasing our focus on water conservation and efficiency to provide cost-effective water savings’ by December 2022) but even with the extra detail given in chapter 4 these lack specificity (e.g., ‘Develop a joint Water Efficiency Plan to save XX GL by 2025…)

• Action 2.3 will require an upgrade of Melbourne’s sewage treatment plants to ensure better water quality, with very low levels of salts, nutrients, pharmaceuticals, for-life chemicals such as PFAS and dissolved oils, etc.
• Action 4.3 is very unclear on the meaning of “all approved source options”. Does this include taking all water from all existing approved sources under the current bulk entitlements to their maximum extent? Such a course of action would lead to an inevitable decline in river health due to over-extraction and be contrary to actions in the CGRSWS to halt further extraction of river water.
• Action 4.6 ‘Plan and operate the existing water supply system to maximise water availability’ is similarly unclear and could lead to unsustainably high rates of water harvesting under current BEs.
• Action 4.7 does not indicate how the proposed augmentation decision-making process will interact with the Water Supply Plan framework in the CGRSWS. It is still unclear how decisions will be made and by whom.
• Action 4.8 is of little help in this respect.
• Action 5.5 must do more than ‘support’ the discussion draft CGRSWS proposals to return of water to TOs and the environment. The return of water to stressed rivers is a key government priority and action of the CGRSWS, and this water supply strategy will be the main way of achieving it. The water corporations must find ways to reduce their bulk entitlements to return water to rivers, which should be an explicit action of Water for Life.
• Action 5.6 should explicitly link annual operating plans with the Healthy Waterways Strategy to link the water supply and river health functions of Melbourne Water and drive real improvements in riverine environmental health.
• Action 6.1 in support of environmental flow targets is welcome but must go further to include appropriate passing flow rules and the restoration of key organic ecosystem processes, nutrient flows, food webs etc.
• Action 6.5 ‘investigate whole of life cycle performance for stormwater and rainwater and how to increase effectiveness’, etc. There is a need to understand the customers and performance of rainwater tanks, urgently investigate precinct roof water harvesting schemes and lock in some key projects.

Missing actions

• Establishing a progressive retirement of older Water Harvesting Assets to enable re-establishment of stream continuity and ecosystem processes.
• The need to retrofit diversion weirs with organic matter bypass mechanisms to sustain downstream ecosystems.
• Allowance for the progressive return of waterway flows from older harvesting systems after the changeover to MWC supplies in older outer areas- Melton, Sunbury, Macedon, Gisborne, Riddells Creek Romsey etc.
• Retrofit of existing harvesting structures with mechanisms that aid the transfer of waterway energetics, organisms, fish, autochthonous and allochthonous material to improve waterway ecosystems downstream of diversion weirs e.g., Stoney Creek, Ballan Weir, Bachus Marsh Weir, Werribee Weir, Lerderderg Gorge weir (Goodman’s/Pyrites), Armstrong’s (East and West), Coranderrk, Graceburn, Starvation, McMahons Creek, Donnelly’s etc.

Chapter 2

The water balance figure (Fig 16, p54) shows total inflows from catchments as 758GL, but also notes that average inflows from 1997-2020 were 427GL/year. This is a massive discrepancy, and the authorities need to decide which scenario they are planning for. The figure also describes all river flows as ‘release to waterways’, which is an extraordinarily mechanistic way of describing the values that those flows support. Somehow rivers are seen as dependent on releases from storages for their very existence. While this may be a realistic assessment of the current state of play where the needs of water consumers take priority over the more intangible values of a healthy river, ultimately it will lead to ecological collapse and localised extinctions, and the loss of all the ecosystem services that rivers provide.

The section ‘We need an integrated, adaptive approach to a resilient future’ (p59) is a clear statement of where the strategy should be heading. The rest of the document should provide meaningful details on how this approach will be achieved.

Chapter 3

The community vision for ‘A future with pristine, precious, secure and sustainable water’ includes a desire for healthy rivers and catchments (p68) but somehow the focus remains on water supply that is pristine and precious, not the rivers that support it. The document does not tell us what advice the community panel received from stream ecologists or other river health experts on the impacts of water extraction on river health or the damage that water supply infrastructure does to the ecological processes that support all river life.

To cover this potential omission, a further strategic focus area ‘ensuring the way we harvest protects stream ecology continuity at existing diversion and harvesting structures’ should be added to the framework on p69.

Chapter 4

The key theme for future options ’Enhancing and expanding our existing system’ (Fig 24, p82) is truly alarming as it envisages increased use of river water in the supply system – ‘new dams, more water out of existing rivers, diversion from existing rivers’. This flies in the face of explicit policy direction in the CGRSWS, where these types of options are repeatedly ruled out. For example, ‘Building more dams is not a solution: in the longer term there will be less rain to fill them’ (CGRSWS p 120). ‘Building more dams isn’t the solution, because there are no remaining viable dam sites to service this region and in the future there won’t be enough rain to fill them’. (CGRSWS, p11) ‘The majority of waterways in the region are fully allocated. This means that finding new river water to meet demand is not an option’ CGRSWS p14). ‘Continued reliance on water extraction from rivers risks accelerating environmental harm to rivers, lowering water quality, and damaging ecosystem health. In short, river water cannot meet our future needs, and we need diverse alternatives’ (CGRSWS p 14). These messages, which we strongly support, are reiterated throughout the SWS. To see such options included in Water for Life is unconscionable.

Similarly, the theme in Figure 24 includes potentially increased groundwater use to meet demand. This is clearly not a realistic option and again contradicts policy in the CGRSWS. ‘Groundwater use is capped and fully allocated in most areas of the region. Less than 6 per cent (about 14 gigalitres) of groundwater is unallocated in the region’ (CGRSWS p38).  There is no available resource waiting for use and it is alarming to see the prospect raised here.

The theme ‘Integrated Water Management solutions’ seems to exclude the approach of precinct roof water harvest, treatment, and local injection. These methods are long-term and far more reliable than rainwater tanks under private management.

We are fully supportive of the concept of IWM (Action 4.2), but it must be realistic and fit for purpose. For example, there is no recognition of the soil sodicity problem in stormwater runoff across all the northern and western growth corridors in both stormwater management and reuse, plus the need to treat wastewater to lower the sodium adsorption ratio to overcome long-term reuse issues in this terrain.

Action 4.4 appears to lack consideration as to the environmental impacts on waterways in the list of criteria beyond water quality, such as loss of stream process continuity, and does not reference the return of environmental water to rivers as part of the supply augmentation process. These considerations are referenced in Action 5.5  but should also appear in the overarching narrative of this action.  Action 4.4 does contain a welcome reference to reform of bulk entitlements, but there must be a mechanism to reduce these entitlements to return water to stressed rivers. The reform could also open up opportunities for improved passing flow regulations to meet environmental needs.

The options evaluation criteria (Figure 27, p90) do not include the liveability, amenity, social and recreational benefits of healthy waterways. ‘My Victorian Waterway’[11] surveys have repeatedly shown the value community members ascribe to their waterways, and this theme has been picked up in the water corporations own community surveys.  It should be added to the criteria.

The adaptive plan pathways again omit the additional supply required to return water to rivers. There’s also little discussion about the long-term certainty of the various options. Each option should guarantee a certain quantum of supply.  Investment in low reliability, low certainty options is potentially a recipe for disaster.

Action 4.6 (p101) contains a very concerning statement ‘Initially, this will include reviewing options to fully utilise the existing Greater Yarra System Thomson River Pool entitlements by December 2022’. This sounds like a proposal to increase surface water take to the absolute maximum permitted under the bulk entitlements. Appendix B gives some information on the entitlement but not current levels of use. Examination of the Victorian Water Accounts[12] indicate that urban extraction is quite variable from year to year and bulk entitlements are not necessarily fully utilised. Far more detail on this action is required for us to be comfortable with it.

Chapter 6

This chapter omits to discuss the massive impact water harvesting currently has on river health.  It is not just the releases of EWR but how the harvesting mechanisms are having major detrimental impacts on the downstream waterways through loss of stream process continuity and transfer of organic organism and matter.  Currently, many waterways are in poor to very poor health because of water harvesting, Werribee River, Lerderderg River, Goodman’s Creek, Pyrites Creek, Jacksons Creek, Riddell Creek (and tribs), Maribyrnong River, Yarra River, Armstrong’s Creek, McMahons Creek, Starvation Creek, O’Shannessy River, Coranderrk Creek, Graceburn Creek, Watts River and Donnelly’s Creek amongst them.

Table 3 on IWM is missing key opportunities such as precinct scale roof water harvesting. This is an effective way to reduce adverse stormwater impacts and increase potable water supplies. Such programs can decrease volumes by 40-50 % and increase potable water supplies. The suburbs surrounding Greenvale reservoir would be a good place to start. 

IWM on precinct scale makes sense but seems to be focused on outer growth area e.g., Sunbury. The assumption that making a purple pipe available in peri urban growth areas will increase the demand for recycled water is misplaced. These developments have very small gardens often with water wise plants that do not require much water so demand for outdoor watering is low. 

There is no mention of programs for local precinct stormwater capture, treatment, and reuse in the short term in middle suburbs that are transitioning the old, quarter acre blocks with ample private open space, to medium density developments. These developments increase the housing supply but greatly increase stormwater volumes. As private open space disappears recharge of groundwater diminishes too.  Current WSUD and planning policies do not adequality address this ever-increasing problem. Given the high cost of infrastructure for large scale projects we support funding for local solutions with priority being given to the most stressed waterways. These types of solutions can help mitigate flood risk from excess stormwater but cannot be expected to be effective in the major flood events expected in future.

The Pakenham Cora Lynn Recycled Water Scheme (p128) is a valuable case study in multiple benefits. However, it ignores a major obstacle to implementation as the cost of the recycled water is much higher than the existing sources used by farmers – i.e., groundwater or diversion from stream flows. High cost has been a major barrier to the uptake of recycled water for new uses, particularly in agriculture, with users often choosing to rely on the cheaper (although often inferior) option of river water. The same barrier applies to the uptake of stormwater as an alternate source, an issue that is not discussed in Action 6.2 or elsewhere.

Action 6.1 on protecting the values of waterways and delivering increased environmental flows is welcome. However, EWR must not be the only mechanism to return health to the waterways.  Improving systems on the older diversions assets to allow for transfer of organic matter (fine particulate organic matter FPOM, Coarse particulate organic Matter CPOM, dissolved organic matter DOM, organisms, and fish) around or bypassing the offtake is urgently needed as the systems downstream are starved of this critical flux that sustains the whole energetics of the ecosystem.  Environmental Water Reserve releases are invariable from large impoundments and consist of hypolimnetic water that is devoid of this matter – so the streams are depauperate.  EWR is more about restoring flow variability, providing scouring of physical habitats, and wetting the waterway perimeter vegetation. This strategy which deals with water supply is the appropriate place for considering the risk that water supply infrastructure poses to environmental condition.

Another missing consideration is the need for improved monitoring of flow harvesting systems. Melbourne Water’s website[13] provides data on flows but not on how much water is being harvested at any given time. Details of environmental water delivery and passing flows are not available either. Provision of such data would improve transparency and accountability in Melbourne Water’s operations.

For more information on this submission please contact Juliet Le Feuvre at Environmental Justice Australia, juliet.lefeuvre@envirojustice.org.au or 03 8341 3100.

The Concerned Waterways Alliance represents the following groups

Environmental Justice Australia

Environment Victoria

First Friends of Dandenong Creek

Friends of the Barwon

Friends of Latrobe Water

Friends of Lower Kororoit Creek

Friends of Maribyrnong Valley

Friends of Merri Creek

Friends of Steele Creek

Gippsland Environment Group

Jacksons Creek EcoNetwork

Kooyongkoot Alliance

People for a Living Moorabool

The Waterways Network

Werribee River Association

Yarra Riverkeeper Association

[1] DELWP (2020) Long Term Water Resource Assessment for southern Victoria

[2] Water for Life summary, p20

[3] Long Term Water Resource Assessment for southern Victoria, op cit

[4] DELWP (2021) Discussion draft of the Central and Gippsland Region Sustianable Water Strategy (CGRSWS)

[5] Water for Life, Action 2.1

[6] Paul Boon

[7] DELWP (2022) CGRSWS What we heard Report: Consultation on the discussion draft strategy *CGRSWS-What-we-heard-report–Final-21-March-2022 (1).pdf

[8] ‘The Birrarung is a river of mists and shadows – the river and its environs are a living, breathing entity that follows Wurundjeri songlines and forms a central part of the Dreaming of the Wurundjeri. A Dreaming that links the billabongs, wetlands and swamps in the upstream forests, across the meandering plains and out to the salt water.’ Wurundjeri Woi Wurrung Nhanbu Narran Ba Ngargunin Twarn Birrarung (Ancient Spirit and Lore of the Birrarung): Wurundjeri Input into the Yarra Strategic Plan (N.D), https://s3.ap-southeast-2.amazonaws.com/hdp.au.prod.app.mw-yoursay.files/2315/8984/4614/Wurundjeri_Woi_Wurrung_Birrarung_Water_Policy.pdf

[9] Discussion Draft CGRSWS, s 6.3, p125

[10] Report card | Healthy Waterways Strategy for Port Phillip and Westernport, Victoria

[11] My_Victorian_Waterway.pdf

[12] Home – DELWP Water Accounts Online 2021DELWP Water Accounts Online 2021

[13] Rainfall and river level data | Melbourne Water