There has been increasing alarm from river advocate groups across Victoria regarding the levels of treated waste water entering our waterways.

Dramatically increasing population levels and development are driving increased volumes of waste water being produced by water authorities, while at the same time there have been equally dramatic reductions in stream flows due to climate change in many Victorian rivers.

On the ground we are experiencing our receiving streams losing their capacity to provide suitable dilution levels yet water authorities are pushing the EPA for licence adjustments to allow for greater discharges.

In a recent case before VCAT, Coliban Water argued for and were granted a dilution factor of 2 parts treated waste water to 1 part river water for a third of the year. https://concernedwaterwaysalliance.org/coliban-water-vs-the-epa-at-vcat/

In response to wide concern about the issue one of the actions included within the Central and Gippsland Sustainable Water Strategy released in 2023 was to develop up better guidelines for discharges to waterways.

Action 8-22 committed the government to collaborate with the EPA to “Develop guidelines for using recycled water for the environment” with the aim of “improving the overall health of the waterways while protecting human health.”.

The resultant guidelines, published in February 2024 under the title “EPA: Recycled water use in surface waters guidelines”, were finalized with minimal fanfare and lacked public consultation. The document can be found here: https://www.epa.vic.gov.au/aboutepa/publications/3005-recycled-water-use-in-surface-waters

The Concerned Waterways Alliance has been critical of the document. Members felt that rather than being prescriptive “the guideline appears to facilitate treated wastewater discharges into the environment”, that it lacked “a proper mechanism for evaluating whether such usage yields a net benefit to the receiving waterway” and “the guidelines appear more of a product of executive directive than a substantive, prescriptive EPA publication.” Our full critique can be found here: https://concernedwaterwaysalliance.org/epa-recycled-water-use-in-surface-waters-guidelines-cwa-critique-may-2024/

The CWA position stated within the critique is:

“There should be no allowance for substandard discharges of treated effluent water into
ephemeral or seasonal streams where the discharge constitutes a significant portion of
flow. The quality of such discharges must meet stringent standards, devoid of
eutrophication, high dissolved solid levels, algal loads, toxicants, surfactants, high
sodium adsorption ratios, pharmaceuticals, or persistent chemicals, while maintaining
high dissolved oxygen levels and neutral pH. Retrograde allowances for poor water
quality discharges must be rejected in favour of scientifically sound approaches that
prioritize environmental preservation and justify the limited use of treated wastewater
in waterways.
The CWA does not believe the case for using treated wastewater in flow stressed
streams for supposed environmental benefit has been made. Simply providing base
flows or timing discharges to mimic environmental flows is not enough when the
detrimental impacts of treated water on our waterways are for the most part already
well understood. It is time to engage the wider community on this issue and have the
type of conversations which honour the role of community in catchment management.”

The CWA will seek to engage with agencies to have that very conversation. Without it there is little to no social licence for agencies or the government to proceed with adjusting discharge licences for greater volumes of treated waste water to be entering our waterways.