The Coastal Waterways and Wetlands Alliance has lodged its submission on the draft Third Victorian Waterway Management Strategy, Sustaining Living Waterways.
The submission focuses on Victoria’s coastal, estuarine and Ramsar-listed wetlands, including the Gippsland Lakes, Corner Inlet and Nooramunga, Western Port, Port Phillip Bay Western Shoreline and Bellarine Peninsula, Edithvale-Seaford Wetlands, and the Glenelg Estuary and Discovery Bay. These are internationally significant places, but they are also living systems under increasing pressure from both directions: upstream catchment decisions and downstream marine change.
The central message of the submission is simple: Victoria’s waterway strategy must manage coastal wetlands from catchment to coast.
Coastal wetlands and estuaries are not shaped by one influence alone. They depend on freshwater flows, catchment runoff, water quality, stormwater, land-use decisions, tides, salinity, entrance conditions and sea-level rise. Yet too often these issues are managed through separate frameworks, with no single line of accountability for the ecological character of the receiving wetland.
The submission argues that the Victorian Waterway Management Strategy should close that gap.
What we felt the draft Strategy gets right
The Alliance welcomes a number of important directions in the draft Strategy. These include recognition of waterways as living and connected entities, stronger long-term water quality monitoring, clearer attention to estuaries, and support for community stewardship and citizen science.
The submission particularly supports the draft Strategy’s commitment to habitat linkages, landward migration corridors and the identification of critical habitat. These measures are essential for coastal wetlands as sea levels rise and saltmarsh, mangroves and other habitats need room to move inland.
The Alliance also welcomes the Strategy’s recognition of the Marine and Coastal framework. However, the submission argues that this connection must be made operational, not merely acknowledged.
The key concern: ecological character must not be treated as tradeable
A major theme of the submission is that ecological character is not just one value to be balanced against social, cultural and economic uses. It is the living foundation on which those uses depend.
For Ramsar-listed wetlands, this point is even stronger. Their ecological character is protected under international and national frameworks and should be maintained or restored, not managed down to a lower condition because protection is considered difficult, costly or inconvenient.
The submission warns that several parts of the draft Strategy risk allowing “managed decline” of protected sites through undefined terms such as “feasible”, “cost-effective” or “where resilience cannot be achieved”. The Alliance argues that these terms must be defined or removed where they affect formal protected-site obligations.
Catchment-to-coast accountability
The submission calls for the Strategy to create a clear catchment-to-coast line of accountability. This would mean that regional waterway strategies, water quality targets, stormwater controls, estuary entrance decisions, land-use planning and monitoring programs are all directed to maintaining the ecological character of coastal receiving environments.
In practical terms, this means catchments draining to Ramsar and other high-value coastal sites should be treated as priority areas for stronger stormwater management. It also means water quality and salinity targets should be based on the needs of the receiving environment, not only on generic freshwater stream objectives.
The submission also asks that salinity be reinstated as a Strategy theme for saline-dependent coastal systems. For places such as estuaries, coastal lakes, saltmarsh and seagrass systems, salinity is not a side issue. It is part of the ecological character of the site.
Planning for sea-level rise and coastal squeeze
The Alliance’s submission also highlights the risk of coastal squeeze. As sea levels rise, saltmarsh and other coastal habitats will need to migrate landward. If development, roads, levees or other hard barriers occupy that future migration space, these habitats may simply be lost.
The submission therefore calls for landward migration space to be identified and protected through forward-looking planning controls before development forecloses those options. This is especially important for Ramsar wetlands and other formally protected coastal systems.
Monitoring, funding and delivery
The submission also stresses that commitments mean little without funding, monitoring and clear responsibility.
The Alliance calls for character-based, threat-aligned monitoring for every coastal Ramsar site, reported against the ecological character present at the time of designation. Community monitoring and citizen science should be supported, but they must complement, not replace, properly funded agency-led monitoring.
The submission also argues that actions required to maintain or restore Ramsar ecological character should not be deferred through discretionary budget processes. Protected-site obligations should be treated as core responsibilities, not optional projects.
A constructive submission
The Coastal Waterways and Wetlands Alliance supports the broad ambition of the draft Strategy and acknowledges the important foundations it contains. The submission is intended to strengthen the Strategy so that it delivers on those foundations for Victoria’s coastal wetlands and estuaries.
Its recommendations ask the Strategy to give practical effect to standards Victoria has already accepted through its waterway, marine and coastal, planning and Ramsar obligations.
At its heart, the submission asks for a Strategy that treats coastal wetlands as living, connected systems; manages them from catchment to coast; and ensures that internationally significant wetlands are maintained and restored, not slowly traded away.