Melbourne Water's Submission - Draft Victorian Floodplain Management Strategy
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Melbourne Water’s Submission Draft Victorian Floodplain Management Strategy
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.
Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 1Melbourne 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-water-
cycle 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
2 Melbourne Water’s Draft Victorian Floodplain Management Strategy Submissionflooded 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.
Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 3A 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.
4 Melbourne Water’s Draft Victorian Floodplain Management Strategy SubmissionMelbourne 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)
Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 5Melbourne 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.
6 Melbourne Water’s Draft Victorian Floodplain Management Strategy SubmissionOverview 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.
Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 7 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;
8 Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 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
Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 9are 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.
10 Melbourne Water’s Draft Victorian Floodplain Management Strategy SubmissionSome 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.
Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 11Working 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),
12 Melbourne Water’s Draft Victorian Floodplain Management Strategy Submissionensuring 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
Melbourne Water’s Draft Victorian Floodplain Management Strategy Submission 13generate 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.
14 Melbourne Water’s Draft Victorian Floodplain Management Strategy SubmissionYou can also read
