Melbourne Water's Submission

Melbourne Water’s Submission Draft Victorian Floodplain Management Strategy

Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 1 Waterways, drainage and floodplains are essential to life and liveability. The rivers, creeks, estuaries, wetlands and floodplains of our region support economic activities and rich ecosystems and are valued places of gathering, recreation and contemplation. The floodplains and drainage systems built to convey stormwater aim to protect people, properties and infrastructure from floods. Integrated and collaborative flood risk management, including whole of water cycle management, will play a key role in keeping Melbourne one of the world’s most liveable cities as we respond to the challenges of a growing population and a variable climate.

Melbourne Water’s aim is to deliver valued flood solutions responsive to customer needs, and that make the most of opportunities for integration and collaboration in planning and delivery. Melbourne Water’s Role in Floodplain & Drainage Management Melbourne Water is a statutory corporation, fully owned by the Victorian Government. Melbourne Water is a water resource manager with three main areas of responsibility: 1. Provision of wholesale water and recycled water services to retail water businesses 2. Provision of wholesale sewerage services to retail water businesses 3. Provision of waterways and drainage services in the Port Phillip and Westernport (PP&WP) region, which includes the greater Melbourne community.

Our area of responsibility covers the 12,800 square kilometre PP&WP region, which includes the river basins of Werribee, Maribyrnong, Yarra and Bunyip with a significant portion of the region highly urbanised. Melbourne Water’s drainage and flood management responsibilities are outlined in the Water Act 1989 and our Statement of Obligations. As the regional drainage and floodplain management authority for the region, Melbourne Water is responsible for the management and maintenance of 223 retarding basins, 226km of levee banks, 21 pump stations, 442 wetlands and waterways treatment systems, 310 monitoring stations, 170 urban lakes, 8,400km of rivers and creeks, and 1,487km of drains.

2 Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission Melbourne Water’s floodplain management functions include:  Undertaking flood studies and flood mapping;  Identifying flood affected land and assessing flood risks;  Undertaking flood prevention works, such as retarding basins and pipe augmentation;  Managing and maintaining networks of rainfall, flow and river level data gauging stations;  Assisting the Bureau of Meteorology with flood forecasting and warning;  Advising planning authorities regarding appropriate land use and development of flood affected areas through our role as a planning permit referral authority, and supporting councils to amend municipal planning schemes;  Assessment of planning permit applications to subdivide land or develop flood affected land;  Supporting community education and awareness programs and working in partnership with the Victorian State Emergency Service (VicSES);  Supporting social research to better understand the community impacts of flooding;  Planning regional drainage systems to ensure new urban development meets appropriate standards of flood protection and environmental performance;  The ownership and maintenance of drainage assets where the catchment area is greater than 60 hectares;  Working with councils (and the VicSES and others) to develop Flood Management Plans for each municipality; and  Developing and implementing regional floodplain management strategies for the PP&WP region.

Some of Melbourne Water’s other functions of relevance to the draft Strategy and this submission also include:  Managing stormwater for waterway health, water quality and whole-of-watercycle purposes;  Managing environmental flow releases (as the Environmental Water Holder);  Managing waterway health and water quality;  Issuing permits for works on waterways;  Supporting research activities and reviews, such as the review of the Australian Rainfall and Runoff (AR&R) guidelines; The PP&WP region faces significant floodplain management and drainage challenges that require a coordinated and collaborative approach by flood managers and the community.

In the PP&WP region, over 100,000 properties are at risk of being

Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 3 flooded by overflows from rivers, creeks and Melbourne Water’s regional drainage system during heavy rain or storms. 2007 Flood Management and Drainage Strategy for the Port Phillip and Westernport Region In 2007 Melbourne Water published the Flood Management and Drainage Strategy for the Port Phillip and Westernport Region. The strategy was prepared following discussions between government departments, councils, emergency service organisations, and other agencies about how we can improve the management of flood risk across the region.

The 2007 strategy defines five flood management objectives and outlines actions that will be undertaken to achieve each objective and guide priorities and expenditure by Melbourne Water. Objective 1 – Completing the knowledge base Objective 2 – Potential long term future pressures on existing drainage systems Objective 3 – An agreed approach to managing existing regional flooding problems Objective 4 – Enhanced community education, flood awareness and preparation Objective 5 – Agreed responsibilities and improved collaboration between flood management agencies Throughout the strategy there is broad recognition that no single organisation and no single approach can deliver an effective response to flood management issues.

While Melbourne Water and local councils will continue to use engineering solutions to mitigate flood risks, it is recognised that this approach must be accompanied by a range of non-structural responses including planning controls and public awareness programs. In particular, the strategy recognises the importance and benefits of improved education in assisting the community prepare, respond and recover from floods.

The strategy has seen the delivery of numerous programs and activities, many of which have been undertaken in collaboration with councils, government agencies and communities.

4 Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission A New Regional Flood Strategy for the Port Phillip and Westernport Region Melbourne Water is coordinating the development of a new regional floodplain management strategy for the PP&WP region. This will fulfil Melbourne Water’s obligations to develop a regional floodplain management strategy as set out in the draft Victorian Floodplain Management Strategy (VFM Strategy) [Proposed Action 9a], and will align with State policies and objectives.

It is anticipated that the new regional PP&WP floodplain management strategy will adopt a similar high level approach to the 2007 strategy, with detailed planning and prioritisation (and hence delivery of many VFM Strategy draft Actions) occurring as part of regional strategy implementation.

Working with our partner agencies and the community, we will together map out a strategy that identifies a collective vision for floodplain management across the PP&WP region, and identifies objectives and activities to achieve this vision. The outcome of the new strategy will be to collectively meet existing, and future, challenges and opportunities of floodplain management. Melbourne Water has sought to take a genuine collaboration and partnership approach to developing the new strategy, and has enlisted a Project Control Board (PCB) to oversee and contribute to its development, and ultimately to its implementation.

The PCB includes representatives from agencies and organisations with key flood and drainage management roles and responsibilities, including the Department of Environment and Primary Industries (DEPI), the Office of Living Victoria (OLV), Melbourne Water, VicSES, Emergency Management Victoria, the Municipal Association of Victoria , 3 local governments, 2 water retailers, the Bureau of Meteorology, the Department of Human Services, the Municipal Planning Authority, and the Insurance Council of Australia.

By drawing on the expertise, knowledge, values and experiences of the PCB agencies, agencies in general, stakeholders and communities across the region, we aim to develop a truly collaborative strategy that appropriately recognises the complexities and opportunities of floodplain and drainage management. Following extensive consultation and a series of workshops, we anticipate releasing a Key Directions paper in September 2014 to inform development of the new strategy during 2015. Where appropriate, comments provided in this submission on the draft VFM Strategy take into account the preliminary directions of the new regional PP&WP Flood Strategy.

Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 5 Melbourne Water’s Strategic Direction Melbourne Water is committed to ‘enhancing life and liveability’, which is our vision for the future. Day to day we manage Melbourne’s water supply catchments, treat and supply drinking and recycled water, remove and treat most of Melbourne’s sewage and manage waterways and regional drainage systems in the PP&WP region. Our strategic direction outlines six key business activities that underpin the achievement of our vision. We are taking a fresh approach to the way we accomplish these activities by being more customer-focused, commercial, innovative, sustainable, engaging and adaptable.

Of particular relevance to flood management is the focus on providing services which are valued by customers, with managing flood risk and adapting our assets to address climate change and variability. We will provide for continuity of service by improving the way we plan for, respond to and recover from extreme events, such as major floods. We will promote collaboration and partnerships, and take opportunities to achieve multiple benefits from our natural and built assets.

Enhancing Life and Liveability Water is central to living. It sustains the communities we live in, the natural environment we value and the economy we depend on. We will improve the quality of life and prosperity of the region by providing safe, secure and reliable water services, desirable urban spaces and thriving natural environments supported by healthy waterways and bays. Every day, we will work with others to develop shared solutions to manage rainwater, seawater, stormwater and treated sewage as one integrated system. This approach will deliver the best economic, social and environmental outcomes for all, now and in the future.

Melbourne Water’s Strategic Direction (2012)

6 Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission Melbourne Water Welcomes the Draft Victorian Floodplain Management Strategy Melbourne Water welcomes the release of the Draft Victorian Floodplain Management Strategy (the VFM Strategy) and the contribution it makes to addressing and responding to the recommendations of the Victorian Floods Review (VFR) and the Environment and Natural Resource Committee’s (ENRC) Parliamentary inquiry into flood mitigation infrastructure, as well as to relevant actions in the Emergency Management Reform White Paper.

Melbourne Water also welcomes and supports the draft VFM Strategy’s focus on clearly outlining agency responsibilities and accountabilities, and the consideration of flooding from a whole-of-water-cycle-management (WWCM) and urban stormwater perspective (Chapter 15), given our role as the regional drainage and floodplain manager for the PP&WP region. Melbourne Water is keen to work with DEPI, local Councils, the VicSES, OLV and the wider industry to implement innovative, adaptable, considered and collaborative approaches to understanding and better managing flood risks across our region, as well as to manage floodplains for their environmental and waterway health benefits.

Through our role as the floodplain manager for the PP&WP region, we have a unique responsibility and opportunity to participate in many aspects of floodplain, drainage and waterway management, and our submission reflects views from across the organisation.

Our submission highlights a number of areas where we support the draft VFM Strategy, as well as areas where we believe adjustments to the draft VFM Strategy are required. Further and more detailed comments are also provided in Attachment 1, which should be read in conjunction with this document. Our submission also outlines aspects of our role and contribution to regional drainage and floodplain management across the PP&WP region.

Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 7 Overview of Key Submission Points The following table provides an overview of Melbourne Water’s key points in regards to our submission on the draft VFM Strategy.

Further details and discussion are provided in later sections, and in Attachment 1. Assessment of Flood Risks, Flood Mitigation Approaches & Future Risks  Melbourne Water’s approach to assessing flood risks, and to evaluating flood mitigation options, includes a broader consideration of social and other impacts, compared to the draft VFM Strategy’s focus primarily on damages or average annual damage (AAD).

Melbourne Water proposes to continue to adopt a broader assessment approach for the PP&WP region, and encourages DEPI to also further consider and incorporate social impacts into relevant methodologies (Chapter 7 and Chapter 9.2)  There are various comments throughout the draft VFM Strategy with regards to future flood risks, however, Melbourne Water feels that these discussions and supporting actions could be strengthened. Section 2 in particular would benefit from the inclusion of an introductory discussion as to what are the future risks, and clearer accountabilities and actions regarding the implementation of State Planning Policy in relation to sea level rise.

Waterway Management & Environmental Considerations  Melbourne Water proposes that policies in Chapter 14 be strengthened to better account for and manage waterway health impacts of flood mitigation works. For example, a ‘no net loss’ approach could be applied with a risk based assessment and offsets.  Chapter 14 should also include consideration of works that may be required after other extreme events, such as bushfires, which may alter ‘normal’ catchment runoff responses and flooding characteristics.

Community Resilience & Education  There is much evidence to suggest that the draft VFM Strategy should include greater discussion of what is meant by community resilience, and the roles that information provision, education, and awareness and engagement activities have in supporting and enabling community empowerment and resilience.

8 Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission  Melbourne Water proposes that the draft VFM Strategy clearly outlines responsibilities and accountabilities relating to these activities, and ensure alignment of activities with desired outcomes. Working in Partnership to Deliver Floodplain Management Outcomes, & the Monitoring & Evaluation of Activities  Melbourne Water strongly supports, both through the current (2007) regional flood strategy and through the development of the new regional flood strategy for the PP&WP, working collaboratively and in partnership with other agencies and communities to achieve floodplain and drainage management objectives and actions.

Further discussion on opportunities for partnering to achieve and deliver the actions of the draft VFM Strategy could be provided, or a reference made to regional strategies being responsible for working out the ‘how’ specific to each region.  While various statements are made in relation to evaluating the effectiveness of the draft VFM Strategy and the outcomes it delivers, Melbourne Water proposes that further detail be provided as to how actions are monitored and evaluated, particularly given the range of accountabilities, policies and actions proposed.

Key Submission Points in Detail Assessment of Flood Risks, Flood Mitigation Approaches & Future Risks Whilst the draft VFM Strategy includes some discussion of populations at risk and vulnerable communities who may be affected by flooding in its discussion of Flood Risk Metrics (Chapter 7), a large proportion of the discussion relating to assessing and comparing flood mitigation options primarily relates to assessing benefits/impacts in terms of economic damages (AAD).

Melbourne Water advocates that a broader assessment approach would likely deliver greater overall benefits to communities and the environment. For example:  Greater consideration of social impacts (and intangible damages) to assess and quantify flood risks;  Greater consideration of social impacts and benefits of different flood mitigation approaches;

Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 9  Greater recognition and consideration of the environmental and waterway benefits of flooding, both currently and into the future, in making decisions around implementing or decommissioning flood mitigation infrastructure. Whilst Melbourne Water supports the VFM Strategy directions and policies, and we recognise the place of our regional PP&WP strategy under the State document, we are proposing to continue to adopt a broader flood risk assessment approach for the PP&WP region, reflecting the populations at risk and significant social impacts of flooding across our area of interest.

We feel the complexities of flooding in our region also support this approach in regards to assessing and comparing flood mitigation options.

We also suggest that the draft VFM Strategy could provide greater discussion and guidance around future flood risks. Section 2 in particular would benefit from the inclusion of an introductory discussion as to what are the future risks, for example, due to population growth, urban consolidation, climate change, etc. There are also opportunities to strengthen some of the supporting actions relating to future pressures, such as developing guidance as to how to interpret and apply rainfall intensity changes (when the updated AR&R is released) and clearer accountabilities and actions regarding the implementation of State Planning Policy in relation to sea level rise.

Melbourne Water strongly advocates for the inclusion of all 1% AEP flood inundation information into planning schemes, and has been working closely with councils to enable this to occur. Most recently, Melbourne Water has been working with Bass Coast Council and the West Gippsland CMA to introduce coastal inundation (including sea level rise) information into Council’s Planning Scheme. Waterway Management & Environmental Considerations Melbourne Water supports the draft VFM Strategy points on waterway management and alignment of floodplain management activities with regional waterway management strategies.

Melbourne Water also supports streamlining authorisations for small-scale (and/or repetitive) works on waterways to improve efficiencies, provided these occur with due regard for environmental impacts and in accordance with best practice and best science. A suggested improvement for the VFM Strategy is to provide a greater recognition of the environmental impacts and benefits of flood mitigation works, including works to decommission existing infrastructure. For example, additional discussion could be added into the document in regards to ensuring that any proposed flood mitigation works also consider natural ‘flood dependant’ features (billabongs etc) and that these

10 Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission are managed appropriately. A ‘no net loss’ approach could be applied with a risk based assessment and offsets for any waterway health impacts. Some further discussion of the beneficial impacts of flooding (floodplain watering) could also be provided (Chapter 9.6), rather than the current focus of the discussions on no third party impacts. There also appears to be an opportunity for further discussion on processes or strategies for better aligning and integrating regional floodplain management strategies with waterway management strategies, particularly with regards to environmental watering of floodplains and the identification and consideration of priority floodplains in developing flood management strategies.

There are also opportunities to recognise environmental flow regimes and decision making processes in the discussion of Total Flood Warning Systems (Chapter 12) to ensure that these different, but related, activities are well coordinated. Community Resilience and Education Melbourne Water strongly supports the draft VFM Strategy’s points on community education, behaviour change and resilience, and we note the outcomes on “Communities accessing and acting on high-quality flood risk information” and “Resilient communities taking ownership of flood mitigation” listed in Figure 2. Notwithstanding these existing points and discussion, there is evidence to suggest that the VFM Strategy should include greater discussion of what is meant by community resilience, and further recognise the roles that information provision, education, and awareness and engagement activities have in supporting and enabling community (and individual and business) behaviour change, empowerment and the building of resilience.

The roles of these activities in reducing existing risks and the impacts of floods when they do occur (e.g.through behaviour change), and in managing residual risks (e.g. after a mitigation solution has been implemented) should be discussed further. There is also an opportunity for further discussion in relation to the effective delivery of Total Flood Warning Systems (e.g. with reference to “Awareness Creation” in Figure 7). Additionally, Melbourne Water proposes that the VFM Strategy could more clearly outline responsibilities and accountabilities relating to these activities, and ensure alignment of activities with desired outcomes.

Further discussion on opportunities for partnering to achieve and deliver the actions could also be provided, or a reference made to regional strategies being responsible for working out the ‘how’ specific to each region.

Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 11 Some of the information, handbooks and documents referred to in the draft VFM Strategy support the above statements. For example, Handbook 7: Managing the floodplain: a guide to best practice in flood risk management in Australia (Figure 52 from the Handbook is reproduced in the VFMS) clearly outlines the role of “Communicate and consult” in terms of flood risk management, and contains various comments on education and engagement and government’s role with respect to these topics in the context of strengthening resilience.

The VFR also includes the following statement “There is a need for robust flood awareness and education programs to ensure communities are capable of response” and several recommendations related to education (e.g. Recommendations 31 and 32). The Victorian Government’s submission (17 July 2014) to the Productivity Commission enquiry also stated that “The new emergency management dialogue has shifted to a strategy promoting community resilience and shared responsibility”. Melbourne Water’s 2007 regional PP&WP strategy includes a specific objective relating to “Enhanced community education, flood awareness and preparation”, and we are actively supporting the VicSES to develop and deliver Community Education and Awareness programs.

We anticipate that the new regional strategy will also include a strong position on supporting communities, individuals and businesses to understand flood risks, and to take appropriate action to manage some of these risks. This will only be achieved through complementary education, awareness and engagement activities and programs.

Further to the above, several other relevant national strategies also provide support for building community resilience, and outline the links between resilience and education and understanding, including:  The 2009 COAG Strategy, which provides guidance on “What does a disaster resilient community look like” and outlines a range of actions that can be taken to increase and build community resilience. Two of the actions relate to ‘Communicating with and educating people about risks’ and ‘Empowering individuals and communities to exercise choice and take responsibility’; and  The 2009 National Strategy for Disaster Resilience (as quoted in the draft VFM Strategy) also states the link between a disaster-resilient community and understanding and managing risks.

12 Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission Working in Partnership to Deliver Floodplain Management Outcomes, & the Monitoring & Evaluation of Activities Melbourne Water, while aiming to deliver customer-focused outcomes at an organisational level, recognises that in a flooding context, the scale of the flooding problem, and complexities associated with different agency roles and responsibilities means that flooding cannot be solved in isolation, or by one organisation alone. Whilst the draft VFM Strategy proposes some areas where agencies may partner to deliver specific activities, we suggest that there are opportunities to further emphasise the importance of partnering and working together to achieve the strategy’s overall objectives and vision.

To support this, the VFM Strategy could provide a better introduction to the different agencies involved in floodplain and drainage management across the State, and further highlight and emphasise opportunities for integration, collaboration and partnering. The specific roles of Melbourne Water and the CMAs could also be further discussed. Melbourne Water strongly supports a collaborative, integrated and partnership approach, working across and within agencies and with the community to achieve and deliver the best-value flood-risk-reduction and overall outcomes for a particular area. Some recent examples of Melbourne Water’s collaborative approaches include:  Working with 38 councils (and the VicSES and other agencies) to develop Flood Management Plans for each municipality, and concurrently supporting the VicSES to develop Municipal Flood Emergency Plans as part of their Municipal Emergency Management Plans with each council.

Working with Kingston Council, the local community, and across teams within Melbourne Water to develop a combined wetland and retarding basin to deliver water quality, stormwater harvesting and reuse, flood mitigation and amenity benefits. This project was also partly funded through a Commonwealth grant. As part of the successful implementation of any strategy, there is also a need for clear processes and accountabilities with regards to the monitoring and evaluation of actions, and in reporting how a strategy is tracking to achieve its outcomes. Melbourne Water strongly supports the draft VFM Strategy’s points on evaluating the effectiveness of the Strategy by how well it delivers outcomes (Chapter 3), but we propose that further detail be provided as to how this will occur.

For example, how are actions proposed to be monitored and evaluated, particularly given the range of accountabilities, policies and actions proposed, and when will reporting of achievements occur. This could be considered and discussed further using a program logic type approach similar to the Victorian Waterway Management Strategy (2013),

Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 13 ensuring alignment of actions with Strategy outcomes and identifying parameters for measuring success. Improving monitoring and audit regimes was also a recommendation of the VFR and is a major focus of the Victorian Emergency Management Reform White Paper (2012). General comments Many other comments, both supportive of the draft VFM Strategy discussions and directions, and offering suggestions for additional considerations have been included in an ‘MS-Word’ version of the draft VFM Strategy document. This is provided as Attachment 1.

Some additional general comments are also provided below:  The VFM Strategy could include some general introductory words for each Section to describe the intent of the Section and key information presented.  The VFM Strategy would benefit from a general review and aligning and renumbering of accountabilities, policy and actions . This would assist understanding and cross-referencing. As part of this, a review of the general text for accountabilities, policies and actions that are not explicitly identified as such is also suggested.

The glossary would benefit from a thorough review and the development of consistent definitions that apply both within the PP&WP region, as well as across the State (see examples in Attachment 1).  The VFM Strategy could provide additional discussion aimed at introducing key agencies involved in floodplain management across the state and (briefly) outlining roles, responsibilities and accountabilities re drainage management, and the related responsibilities of flood mapping, flood mitigation and floodplain management for different agencies.

Similar to the above, the VFM Strategy could expand its discussion of “Flooding in Victoria” (Chapter 1) and add commentary to distinguish between Melbourne Water’s role in the PP&WP region, versus CMAs across the remainder of the State.

Melbourne Water strongly supports the draft VFM Strategy’s discussion of the role and importance of Planning and Building regulations to assist with managing flood risks. Some further discussion could be added with regards to the role of planning and future flood risks.

Melbourne Water strongly supports statements in the draft VFM Strategy in relation to working in active partnerships with councils (and other agencies) to

14 Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission generate flood mapping information and to update municipal planning schemes with flood extents.  Melbourne Water supports the draft VFM Strategy’s points on WWCM and linkages with flood management, and also points on multiple benefit approaches.  Melbourne Water supports the draft VFM Strategy points on capacity building and supporting local councils and VicSES, and we will continue to work with others to achieve regional flood management objectives.

However, we propose that the VFM Strategy could further discuss capacity building and extend this discussion beyond planning (Chapter 10) and coastal management (Chapter 11) In Closing Melbourne Water strongly supports the policies and directions outlined in the draft Victorian Floodplain Management Strategy and its role as a guiding document for the State and for the development of Melbourne Water’s regional floodplain management and drainage activities.

We will endeavour to take into account all Melbourne Water and regional flood strategy accountabilities and actions as part of the development of the new PP&WP regional flood strategy, noting any key points made in our submission. We would also welcome the opportunity for further discussion on the points raised in this document (and in Attachment 1) if DEPI would like clarification in regards to any of the comments made. And in closing, we wish to thank DEPI for the opportunity to provide comments on the draft VFM Strategy and look forward to working with DEPI in its implementation.

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