13 July 2015

SEPP Waters Review

Department of Environment, Land, Water and
Planning PO Box 500
MELBOURNE VIC 8002
Via email: W ater.SEPPreview@delwp.vic.gov.au
SUBJECT: VICTORIAS STATE ENVIRONMENT PROTECTION POLICY (WATERS) REVIEW
Cement Concrete & Aggregates Australia (CCAA) welcomes the opportunity to provide a submission
to the Department of Environment, Land, Water and Planning on the State Environment Protection
Policy (Waters) Review.
Introduction
CCAA is the peak industry body for the heavy construction materials industry in Australia including
the cement, pre-mixed concrete and extractive industries. For your information, a list of CCAA
Victorias members is provided in Appendix 1.
CCAA members account for approximately 90% of the $7.21 billion in revenues generated by
these industries that, between them, employ 18,000 Australians directly and a further 80,000
indirectly.
CCAA members operate rock quarries, sand and gravel extraction sites, cement production
and distribution facilities and concrete batching plants throughout Australia.
There are approximately 540 operating quarries across Victoria that produced some
47.4 million tonnes of stone, limestone, gypsum, sand and gravel in 2012/13 which was used to produce
building and construction materials such as cement, bricks, concrete, tiles, pavers and road paving.
The value of production from these quarries is estimated to be $737.4 million.
3

The Victorian premixed concrete industry produced 6.5 million m of premixed concrete in 2012/13
worth around $1.4 billion. This is enough to build around 100,000 new homes, 100 Eureka Towers or
44 Bolte Bridges. Further value is added through the manufacture of concrete products and delivering
concrete services.
CCAAs members service local, regional and national building, construction and infrastructure
markets. The reliable and cost-effective supply to these markets is fundamental to sustainable growth
and it is CCAAs aim to promote policies and planning frameworks that recognise the importance of
these materials to Australias sustainable future.
CCAA welcomes efforts to simplify the regulation and enforcement of water policy that provides
increased certainty, reduced costs and reduced time to industry and results in better outcomes for
all stakeholders.

CCAA makes the following comments on key aspects of the SEPP.

The SEPP should be clear about requirements for seasonal and intermittent waterways
compared to permanent streams and also should be clear about requirements for urban drains
v's waterways. The definition of waterway issue is important as it impacts on industrys ability
to secure authority approvals for new quarries and/or extensions of existing operations. The
major problem being a waterway can be a large flowing river or a small ephemeral channel
that might only convey receding floodwaters during very infrequent floods or even a gently
shaping inverted contour formation on open, cleared land. When assessing projects, the
requirement for waterway protection does not take in account the different types they are all
deemed to have the same importance.

The SEPP should be clear to allow an operator to understand what the 'base case criteria, acceptable
to EPA are'. If these are not achieved then scientific modelling and baseline records may need to be
th
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established, but at the current point in time it is not clear when 90 percentiles apply, or 80
percentiles apply and so on. There should be a basic rule and if this basic rule of thumb cannot be
achieved due to whatever reason, site assessment and scientific analysis should then occur.

The Attainment Programs and Indicators and Objectives Review may impact the ability of industry
to discharge waters (groundwater and stormwater) to stormwater drains, rivers and other defined
waterways as a consequence of the review and changes to the Indicator discharge limits for
various beneficial uses. Current operations may be compromised by the setting of higher water
quality requirements.

A key question for industry is how will any changes be implemented and what effect it will have
on current Discharge Licences. Industry strongly supports reasonable transitional arrangements
with the basic right that any new regulation should not be retrospective and preserve existing
use rights.

Any expansion in the number of indicators will increase the testing and audit costs for discharges or
diversions. Any increases in costs to industry should be offset by increased benefits such as reduced
regulatory burden and red tape or streamlined administrative processes in other areas of the SEPP.
The Victorian planning and regulatory environment needs to be internationally competitive to continue
to attract capital to invest in Victoria to ensure a sustainable and competitive heavy construction
materials industry. This in turn facilitates Victorias improved productivity, housing affordability and
lower infrastructure costs.
CCAA looks forward to working with Government to achieve these key objectives.
Please do not hesitate to contact me to discuss any of these issues in more
detail. Yours sincerely

Brian Hauser
State Director Vic/Tas

CCAA Submission on Victorias SEPP (Waters) Review July 2015

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APPENDIX 1
CEMENT CONCRETE & AGGREGATES AUSTRALIA
MEMBERSHIP
FOUNDATION MEMBERS

Boral Construction Materials

Cement Australia Pty Ltd

Hanson Australia Pty Ltd

Boral Cement Limited

Holcim (Australia) Pty Ltd

VICTORIA
ORDINARY MEMBERS
Aidan J Graham Pty Ltd

Baxters Concrete

Alsafe Pre-Mix Concrete Pty Ltd

Broadway & Frame Premix

Concrete Pty Ltd

Axedale Sands & Gravel

Barossa Quarries Pty Ltd
Barro Group

Fulton Hogan Construction Pty Ltd

Hillview Quarries Pty Ltd
Hymix Australia Pty Ltd

Independent Cement & Lime Pty

Ltd
Mentone Pre-Mix
Premier Resources T/A Hy-Tec
Industries Pty Ltd
Rocla Pty Ltd

ASSOCIATE MEMBERS
Agi-Kleen Pty Ltd
BASF Construction Chemicals
Australia Pty Ltd
Concrete Colour Systems

Concrete Waterproofing
Manufacturing Pty Ltd T/a
Xypex Australia
Grace Construction Products

Sika Australia Pty Ltd

WAM Australia