Integrated Water Management
Framework for Victoria
Submission
January 2017
MAV submission to Integrated Water Management Framework for Victoria - Jan 2017
© Copyright Municipal Association of Victoria, 2017.
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submission to Integrated Water Management Framework for Victoria - Jan 2017.
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The MAV is the statutory peak body for local government in Victoria. While this paper aims to
broadly reflect the views of local government in Victoria, it does not purport to reflect the exact
views of individual councils.
MAV submission to Integrated Water Management Framework for Victoria - Jan 2017
Table of contents
1
Executive Summary ............................................................................................................ 5
2
Introduction ......................................................................................................................... 6
3
Recommendations for the framework and its implementation ............................................. 7
4
Conclusion .........................................................................................................................17
MAV submission to Integrated Water Management Framework for Victoria - Jan 2017
1 Executive Summary
The Municipal Association of Victoria (MAV) appreciates the opportunity to provide a
submission in response to the Department of Environment, Land, Water and Planning’s
(DELWP) Draft Integrated Water Management Framework for Victoria.
The MAV welcomes the Victorian Government’s commitment to building an integrated water
management (IWM) approach into the planning and delivery of projects that will enable our
towns and cities to be more liveable and resilient. We recognise the challenges of anticipated
reductions in water supply due to climate change occurring at the same time as densification of
cities and towns due to greater population growth mean that new ways of approaching water
management are required.
We are broadly supportive of the approach outlined in the proposed framework and consider it
provides a useful structure for organisations with interests in water use, supply and urban
stormwater management to work collaboratively with each other. The framework will help
shared values and goals to be identified and financially smart innovative integrated water
management solutions to be delivered.
The Victorian Government investing time and effort in delivering the framework as one of the
priority projects in the Water for Victoria plan (action 5.7, p 93) will assist in raising the profile of
IWM within senior echelons of local government. This is particularly timely given that all
agencies need to plan and be smarter in their project delivery now, to be able to deliver
community assets and local liveability outcomes in the face of changing climate and population
changes.
We have a number of improvements to suggest to strengthen the potential for the IWM forums
to be delivered to their full potential. In particular, these include:





Provision of a ‘water liaison planning team’ to assist councils prepare for the forums
before they commence
Clearer articulation in the framework about the benefits of practising IWM, and that the
purpose of the framework is to enable accountabilities to be transcended
Simplification of the descriptions in the proposed IWM planning process diagram
Developing a systematic funding program for release of any state-contributed funding for
projects that may emerge from the process
Developing a methodology for option identification and criteria for prioritisation
Developing tools and supporting materials before the forums commence will be vital to the
success of the framework. Quality of preparation, not speed, will be important ingredients to
ensure councils are both engaged and enabled to participate in forums.
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MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
Given the number of strategies being developed and implemented within the water sector, it will
be important to be mindful of the impacts on council staff time. This is particularly relevant for
councils in rural and regional areas where resources are constrained and there are many state
government strategies and plans requiring their input.
Where there are existing forums in operation involving water authorities and regional groups of
councils, we suggest the framework be flexible in enabling these to practise the framework
methodologies without requiring new forums to be established or independent chairs needing to
be appointed. Another alternative is to hold only a small number of meetings with executive
staff in reaching agreement about principles and topics to be explored in the forums. These
discussions could be agreed in writing, which would then provide a high-level authorising
environment for agency delegates to work on developed detailed proposals. These
arrangements could be re-assessed once there is a general review of the program.
Councils and water authorities are also under increasing pressure to deliver services more
efficiently to higher standards. To avoid resources and funding being impediments to
participation, it would be helpful for the Victorian Government to provide grant opportunities to
renew drainage and water infrastructure in a way that meets future community needs as well as
assists in advocacy for grants to the Australian Government. We note that the Australian
Government already plays a significant role in assisting with road renewal. This would help
councils to be able to innovatively address legacy drainage issues that often results in local
urban flooding during minor rain events as well as deliver new stormwater harvesting and re-use
projects.
While there is further ground-work required to maximise the potential for councils to be involved,
we are pleased to see that the Victorian Government is bringing IWM to the forefront of local
and regional planning.
2 Introduction
The Municipal Association of Victoria (MAV), is the peak representative and advocacy body for
Victoria's 79 councils. The MAV was formed in 1879 and the Municipal Association Act 1907
appointed the MAV the official voice of local government in Victoria.
Today, the MAV is a driving and influential force behind a strong and strategically positioned
local government sector. Our role is to represent and advocate the interests of local
government; raise the sector's profile; ensure its long-term security; facilitate effective networks;
support councilors; provide policy and strategic advice; capacity building programs; and
insurance services to local government.
Practising integrated water management is not new to local government, with many councils
applying IWM strategically through municipal policies and IWM strategies, and initiating local
water sensitive urban design and stormwater harvesting projects for open spaces, and more.
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MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
3 Recommendations for the framework and its implementation
While we are supportive of the approach outlined in the framework, we have some suggestions that will strengthen the capacity of
councils to participate. In the table below we have highlighted elements which could be enhanced, accompanied by
recommendations to further strengthen the framework.
Element of
Framework
Comment
Suggestion for changes to the
document
Introducing
IWM
While IWM is a familiar term for some, it
is not well understood by everyone.
Although a definition is found in the
glossary, it would be beneficial to
include a definition early in the
document.
Insert a definition of IWM in the
introduction p 5.
Rationale for
practising IWM
The benefits which can be achieved
from IWM and the implementation of
the framework could be more clearly
articulated. Section 5 of the framework
provides information about shared
values and figure 5 provides examples
of projects rather than examples of
potential benefits which will entice
councils and other organisations to
participate in the forums.
Improve articulation of benefits by:
7
Suggestions for
implementation
 Describing what councils will get out
of participating in the framework
E.g. greater investment in projects
from other organisations, community
benefits such as cooler greener
cities and towns, flood protection
and more.
 Introducing call out boxes with short
punchy key statements and facts for
each case study. For example, “Six
organisations pull resources
MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
Element of
Framework
Comment
Suggestion for changes to the
document
Suggestions for
implementation
together to transform a concrete
creek into an environmentally
friendly cool, green space the
community can enjoy”. Or
“Stormwater harvesting project
prevents pollution entering the river
while keeping local urban parks
green”. Also highlight the value
proposition. For each project, what
helped organisations to decide to
invest in the project?
 Introducing more or different case
studies relating to smaller regional
towns.
 Merging the ‘examples of IWM
opportunities’ diagram on p 17 with
the ‘collaborative integrated urban
water planning process’ diagram on
p15 to demonstrate the shared
value.
Geographic
location
8
The framework will enable councils to
be involved at a catchment scale and
therefore more likely to benefit from
initiatives which require connecting
resources and impacts up and downstream. Although there are advantages
Where councils sit in more than one
defined region, make it clear that:
 Councils will not need to join all
forums and that they may choose
the forum which best suits them.
Where councils are having
difficulty in choosing which
forum to attend, advice
should be sought from
DELWP to help make an
MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
Element of
Framework
Comment
Suggestion for changes to the
document
Suggestions for
implementation
of planning at a catchment scale, the
larger boundary may favour larger
projects as opposed to smaller more
localised projects. Councils will also
need to show how projects that they
seek external funding for fit into a
bigger regional picture.
 DELWP will play a role as a broker
of information to those forums
councils will not attend.
informed decision.
The framework provides an opportunity
to work outside of the current
institutional arrangements where there
is a shared vision and community need.
Communication messages
need to be developed
emphasising that the
purpose of the forums is to
facilitate shared planning
and flexible delivery
options.
It is unclear for councils who sit within
multiple regions about where and how
they should participate. Some councils
are concerned that they will not be able
to feasibly participate because their
resources will be stretched between
multiple numbers of forums.
Institutional
arrangements
and stakeholder
involvement
There are internal contradictions in the
framework. On the one hand there is a
strong focus on agencies
understanding institutional
arrangements (p 12), while at the same
time a recognition of the need to be
flexible and work outside of the
institutional arrangements.
Rather than focussing on ‘clarifying’
arrangements (p 12), it would be
beneficial for the framework to focus on
how IWM has a purpose which
There are many reviews occurring on
transcends individual accountabilities
institutional arrangements which may
providing the opportunity to innovatively
lead councils to be concerned about the deliver a shared vision, often with
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MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
Element of
Framework
Comment
Suggestion for changes to the
document
potential for them to face new
requirements which they believe are
more the remit of water authorities.
multiple benefits. All organisations may
equally need to step outside their
existing responsibilities for this
approach to be successful.
Councils also have quite a different
remit to that of water authorities, with
much of their accountabilities derived
from local priorities and enabling
legislation, rather than prescriptive
requirements. This contrasts with the
water sector which has quite prescribed
institutional accountabilities.
Coordination with other state
government agencies and departments
such as Vic Roads, Vic Track, Parks
Victoria, DEDJTR and DELWP Land
and Planning departments will also
need to be explored.
It is not clear how the community voice
and that of developers will be heard
within the forums. Further discussions
will be required about how they can be
involved.
10
Suggestions for
implementation
Change title of Section 4 (p 12) to
‘Organisational urban water
management activities’.
Change title of Table 1, p 12 to
‘Organisational urban water
management activities’.
Change ‘Accountability’ heading in
Table 1, p 12 to ‘Activities’.
Remove the following text in Table 1, p
12 under local government ‘Drainage’,
‘Urban flooding (except where
managed by Melbourne Water)’ and
replace with ‘Urban stormwater
management’.
MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
Element of
Framework
State
Government
investment
Comment
Suggestion for changes to the
document
Suggestions for
implementation
A number of institutions are also
working in IWM (E.g. CRC for Water
Sensitive Cities on the Elster Creek
catchment). It is also unclear how their
work will feed into the forums and sub
groups.
Include detail on how state government
agencies and departments, institutions,
developers and the community will be
able to participate in forums or project
work.
Give more consideration to
how community and
developer views can be
accommodated in the
forums.
The framework will allow potential
projects to come to the attention of a
multitude of organisations, including
DELWP, which will increase funding
opportunities for councils.
Release any funding for
IWM projects in a
systematic prioritised format
to encourage councils to
prepare for forums and to
want to participate in forums
by providing an incentive.
DELWP funding for the planning and
delivery of projects appears to be
opportunistic.
Resources
required by
participating
agencies
We are pleased that DELWP has
committed resources to support the
forums. We are also supportive of
water authorities leading the approach,
given their specialist water
management knowledge.
Many councils are concerned they do
not have enough staff, expertise or time
to commit to participating in the forums.
This is particularly true of regional /
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Articulate in the document that DELWP
will outline guidance and information
before the first forums to lay the
groundwork in setting out expectations
and what agencies need to bring to
them.
Provide a ‘water liaison
planning team’ to support
councils / forum groups to
understand the
opportunities and
challenges within their
region.
There is an opportunity to
provide further support to
councils through the
MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
Element of
Framework
Comment
Suggestion for changes to the
document
rural councils and smaller metropolitan
councils where there are limited human
resources and constrained budgets.
There’s range of agencies involved and
initiatives being undertaken to develop
tools, such as those through the
Resilent Melbourne plan, through the
CRC for Water Sensitive Cities,
Clearwater, Living Rivers and the
Monash Sustainability Institute. All
have a place in supporting councils to
practice IWM.
Suggestions for
implementation
provision of tools and
templates. E.g.
 Terms of reference
templates which take
into consideration
private landholders.

Stakeholder lists with
relevant agencies and
teams.

An FAQ specifically for
councils, including an
outline when and who
from various council
business units should
be involved.

Sample council reports
and policies.
At a metropolitan scale
these could be delivered
through the Resilient
Melbourne initiative. At a
regional scale, these could
be delivered by DELWP,
MAV and Clearwater.
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MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
Element of
Framework
Comment
Suggestion for changes to the
document
Suggestions for
implementation
Economic
evaluation and
cost allocation
process
We support the development of an
economic evaluation and cost allocation
process tool to support the IWM
Framework. Ongoing maintenance and
renewal costs are a significant issue for
councils, and these need to be factored
into any analysis.
Articulate the broad concept of the
economic evaluation and cost allocation
framework process tool within text on p
12 rather than describing the process.
Practically test the process
with a working group
consisting of council and
water industry staff to
ensure there is broad
confidence in the process
tool.
Detail of the process tool in section 8, p
29 is currently unclear and has not yet
been broadly tested by councils and the
water sector to our knowledge.
Remove references to accountabilities
(see comments above on institutional
arrangements).
Given the framework is a high level
document and that the evaluation and
cost allocation process is a tool to help
support the framework, it would be
beneficial to remove the detail on the
cost allocation process from the
framework document to allow flexibility
for changes to be made to it once
greater consultation with councils and
water authorities has been undertaken.
13
Remove figure 11 to allow flexibility in
the development of the tool over time.
Ensure the process tool
considers the lifecycle costs
of proposed assets,
including capital,
operational, maintenance
and renewal. Determining
what is ‘community benefit’
will also require multiagency collaboration.
MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
Element of
Framework
Comment
Project planning
The planning process in Figure 6 (p 19) Articulate in document that DELWP will
could benefit from the addition of simple be developing a methodology prior to
language, for example:
the first forums commencing.





Suggestion for changes to the
document
Work out what’s shared
Choose the project
Work up the detail
Get it into your own plans
Deliver on your part of the
project/s.
Suggestions for
implementation
Develop a methodology for
option identification and
criteria for prioritisation of
options. If this is to occur
within forums, specify that
this will be occurring.
The process to identify values and
options needs to be comprehensive
and strategically guided. While there is
always a place for opportunistic
projects, forums will need to have some
guide on how to identify and prioritise
projects. Without such a methodology,
option identification and prioritisation
could come across as partially informed
hunches rather than a logical process
of assessment and analysis.
Initial forum meetings will need to set
the scene for what will be collaborated
on.
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MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
Element of
Framework
Comment
Suggestion for changes to the
document
Implementation
and
maintenance
Consideration should be given to
delivery and ongoing maintenance
requirements for projects. While this is
not where the discussions should start,
it can become a sticking point between
organisations and is worthwhile
developing material to support
conversations.
Develop draft template
agreements that can be
used to clarify
implementation and
maintenance arrangements.
Monitoring and
reporting
Monitoring, reporting and evaluation is
not strongly featured in the framework.
The sample template in Appendix A has
a ‘monitoring, evaluation and feedback’
section under project ‘implementation’,
however the process for this to occur is
not described in text and there is no
mention of how the full program will be
reported on across Victoria.
Incorporate monitoring,
reporting and evaluation
into the process to evaluate
process, projects, regional
and Victorian outcomes.
It will be important to elaborate on this
area within text to ensure that we:
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
Build on expertise and
knowledge, allowing lessons to
be shared.

Document how successful a
project and /or the framework is
working.
Suggestions for
implementation
Develop transparent
reporting processes that
span across all forums to
communicate the
successes and challenges
arising from the framework.
MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
Element of
Framework
16
Comment
Suggestion for changes to the
document

Test assumptions.

Provide robust evidence for the
business case to fund / continue
to fund the framework.

Monitor the effectiveness of
outcomes.
Suggestions for
implementation
MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017
4 Conclusion
The MAV is supportive of the draft Integrated Water Management Framework for Victoria. We
commend the commitment of the DELWP to work with multiple agencies to achieve positive
outcomes for communities.
We also acknowledge with thanks its funding contribution to enable us to employ an EFT staff
member for 12 months to work with councils on the introduction of the Water for Victoria plan
and integrated water management.
We would welcome the opportunity to work with government to strengthen the framework to
achieve their vision of resilient and liveable towns and cities.
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MAV submission to Integrated Water Management Framework for Victoria - Jan 2017: January 2017