There has been some ambiguity as to the applicability of the code on redevelopment sites, particularly where areas of road are being developed or re-developed.

In brownfield sites it is sometimes hard to meet the standards and it is unreasonable in some instances as there are treatments provided further downstream.

the rules for water tank size should be either:

based onthe block size or completing the 40% water reduction spreadsheet

It should be stated as a RULE that the water tank size is based on the block size as is the RULE now or that the 40% water reduction spreadsheet can be used as also as a RULE . To submit plans down the merit path just because you are using the 40% water reduction spreadsheet is stupid & a waste of time. They both save water & the water reduction spreadsheet is actually a very good way to go as owners can see by selecting star rating & energy efficient fixtures/fitting, etc the actual water reduction

 calculation is see before there eyes as they enter the information.

multiple agencies

significant time delays in assessment

No building supplier understands AS2700

No Gov person understands L.a.b, RGB or RAL

So colour based approval delays are subjective and time wasting

Delays caused by neighbours registering comments that were positive toward the development however this caused an auotmatic delay by ACTPLA to process the information - positive or negative!

if its positive, why does this trigger the need to process?

Too much red tape.

I do for irrigation but when it cannot be used to drinking this is ridiculous, as a large number of houses in country towns use rainwater for drinking, why can't it be used in the ACT?

I feel if the government wants to charge people for the dam infrastructure, etc. and therefore shouldn't make tank a requirement but give tax exemptions or reductions in water rates, etc. to encourage people to make the choice rather than 'just comply' with a standard as when tanks are installed to 'comply' they are not fully integrated into the building and really just become a maintenance issue.

WSUD elements within a suburb can be used to enhance the aesthetics if done and maintained well

The ACT water plan should incorporate:

1. Develop a more comprehensive system of wetlands and urban water reserves - through improved land management practices for Canberra's reserves, public spaces and parks - e.g. planted swales and berms that keep water in situ, filter reduced runoff and add to the biodiversity of the area.

2. Increased planning for tree plantings, as tree canopy creates a micro-climate and contributes to atmospheric water levels to create rainfall. Recognise and plan to maximise the different properties of native/introduced species to contribute shade, wind protection and evaporation.

3. Strategies to encourage residential capture of rainwater and in situ run-off treatment - water tanks, grey water systems and downpipe to garden diversion.

3. Development (particularly for larger structures) to incorporate modern water capture and re-use plans in buildings, infrastructure and open space designs. (Green canyon buildings, shared use zones and dual purpose designs for roads and pathways to ensure water capture, storage and recycling).

4. Recognise the value add to the city and region of a modern green, water sensitive urban environment.

I believe the code works well although the short comings come in two different phases:

- no one is checking the results that are submitted with the drawings. there should be a requirement to submit DRAINS/MUSIC etc data and results to prove that the engineer isnt just fudging the numbers

- the private certifiers arent caring that specified WSUD features are not on site at final handover. ive seen many case where rainwater tanks are not onsite even though the drawings have specified them.

It is important to set water consumption targets. If these are too high we could run out of water and we would not comply with the MDB agreement. If they are too low the sewerage system may clog up due to lack of through put.

The design code must be structured between these two limits.

We should also use enough water to maintain our urban forest, our playing fields and parks and also our gardens.

Water quality in our lakes should be such that they can be used all the year round.

I tried to find the code to understand be able to answer this properly, but the link does not work - it was in garbled code with only some points in real English!

Please provide a link to explain all the points in q.23.

There is mention above of biodiversity yet I couldn't find the detail. In addition to the obvious water savings and quality, I would STRONGLY support any moves to increase/improve biodiversity with rich use of structurally diverse endemic plants in all raingardens, and along all waterways, including existing ones which are currently bare or eroded. Conserving and providing wide corridors for wildlife is vital eg. in maintaining populations of small birds and preventing isolated remnant pockets from developing. These would reduce the genetic diversity and threaten species already being reduced by habitat loss and the rise in aggressive birds (eg Noisy Miners).

It was not easy to determine who was responsible for the advice of pool removal.

There needs to be simpler procedures instead of all the red tape and misinformation provided during the process.

Until I visited the Dickson office for a way ahead the whole process as frustrating

The calculator need refinement.

The tickbox specifying whether you have a tank increases the % reduction, even if tank size is set to Zero Litres.

There are several similar quirks

1. Broadly, the code is reasonable and requirements are typically in line with other jurisdictions.

2. The ACT lacks guidelines to support a consistent approach to water modelling. Specifically, the code refers to using MUSIC models to demonstrate water quality targets are met for a particular development. However there is no guidance on treatment node parameters, which can make a significant impact on the results. Existing guidelines include Water by Design, Melbourne Water, FAWB etc provide some guidance though are not always suitable for Canberra Conditions.

3. We need to consider how to address detention requirements for smaller scale blocks. In new estate developments, it is likely more practical to have single basin that can provide detention for upstream blocks. However, if the upstream blocks are multi unit dwellings over 2000m2, then the developer also has to provide on block detention - this leads to over servicing and provision of unnecessary basins.

4. Aside form achieving water quality/quantity targets, there is no incentive for developers to provide beneficial ecosystems. In terms of land take, it may be beneficial for a developer to adopt bio-retention treatments, though a wetland of permanent water body may be better overall.

5. More needs to be done to support water quality in existing areas, many of which have very little or no treatment devices, not just new developments.

6. There doesn't appear to be a great deal of technical resources from ACT Government to discuss proposals before lodging the DA.

Water can be stored in a variety of ways. Dams clearly are needed for bulk fresh water storage for Canberra. I am concerned about intercepting runoff in domestic storage tanks that are made from plastic. I think that plastic water tanks are simply duplicating the mass water storage dam at the Cotter. The environmental cost of plastic water tanks needs to be assessed as these tanks will all end up in landfill at some future time.

There is a cost concern here also. Why spend ACT tax revenue on the enlarged Cotter Dam and then ask consumers to also pay for the installation of domestic water tanks?

The other issue of concern to me is the interception of water by Canberra residents ( of which I am one) thereby reducing environmental flows to our creeks and rivers. Reduced flows in riparian environments compromises biodiversity. It also reduces much needed water supply to our downstream neighbors in the Murray Darling Basin.

I believe that the ACT governments Urban Waterways Program is excellent. The creation of urban wetlands has many benefits. Biodiversity, recreational, social and aesthetic values are enhanced. Storm water flow abatement and pollution control are also enhanced.

Keep the WSDU as simple as possible.

I don't understand the current requirement for minor extensions. Why are driveways and car parking areas involved. The previous system worked well. Roof areas assessed for water storage collection.

Not one bucket of water has ever left planet earth !

Let us only have to flush our toilets once.

Let us put down the toilet brush and have wider trap design!

Let our lake's be blue green algae free.

There are!

IN the event it is unrealistic to comply perfectly with the Code it would be desirable to move in the right direction even a little ... I do not feel it should be all or nothing at whatever cost.

Thankyou

A lot of my houses are just passing even though the end result is people typically using 70% rainwater and only 30% mains water. This is because the tool doesn't take into account whole house use as well as having a very crude way of working out how much water you will use on the garden based on block size.

I can see a situation arising when there is a four bedroom house with 100sqm catchment and a 3000litre tank not passing even though a family using a whole house system will only be using 125kl of mains water on average per annum. Increasing the tank to 9000litres will only drop that usage down to 120kl per annum.

Unless the tool becomes more sophisticated and takes into account whole house I reckon it should probably be scrapped. Rainwater tanks just to the garden, toilet and laundry typically do very little to reduce consumption and might even have a negative effect as people use more water thinking that it is Ok to use a bit more water as they have got a tank.

Instead of legislating that everyone needs a tank it is better to dramatically increase water fees after say 100kl/annum to encourage people to get one and use it properly.

The Water Catchments Code is in more urgent need of a re-write. It's very difficult to interpret as there are no apparent rules or criteria.

Since WSUD rules and criteria are written into all of the development codes, the WSUD code really only needs to be a handbook on how to meet them. Or, if you write rules and criteria into the WSUD Code then you should remove them from all of the development codes.

Question 7 is not set up properly you can only tick extremely important for one aspect

I last submitted a DA in 2009 and got my certificate of occupancy in July 2010 so I was not affected by the new code but I believe my new garage would have complied with the new code.

The single biggest reduction in water use is reduction in block size and setback to boundaries. Compare Forrest water bills with Gungahlin.

Long term water restrictions lead to poor suburban streetscapes in most suburbs (20 to 40 year old suburbs).

Yeap.... I understand that some current developments are planning against 1 in 100,000 floods.

I would be very happy to have my home completely destroyed and my family and friends wiped out every 20000 years or so.

And, unless i'm mistaken, since we only have a few hundred years of records or less, I dare say it's utter rubbish anyway.

The current code is a very poor fit for commercial and industrial land development projects.

The mandatory targets for water demand reductions are irrelevant for developments that do not demand any mains water, such as infrastructure projects (roads, drains, car parks) or for the creation of empty blocks that later are assessed under the code. The potable water demand reduction targets should be specified to apply to buildings serviced with water and possibly landscape works. The application of a mandatory rule under the Territory plan to reduce demand below zero adds no value.

I feel it is a good step forward and something that can be easily incorporated into design processes, however,

this industry should not take the fall for the public using water within their homes at an unsustainable level. Most people shower morning and night - why?

Why shower in the morning - most use the excuse, "to wake me up". Well, thats not good enough. If we are going to make a conscious effort about water useage, lets go back and provide every home with a tank and thats all the water they have to use. All farmers have to live like this and can manage, why cant city people do the same? I know its a very primitave comment but maybe education at an early age would assist.

There are many homes in gunghalin that have been built with instantaneous HWS that are wasting water daily because of the layouts of the wet areas and the run of water taking up to 90sec before the hot water reaches the tap. These homes are still being built! But can you ask the home owner to provide secondary HWS at a cost starting around $2000? I dont have the answer because energy efficiency, high quality and housing affordability do not cooperate!

The last comment I would like to make about this is:

In 2011 I was invited to ACTEW on behalf of the construction industry about discussing the use of water within our industry and where and how can we save water. On residential dwellings, water useage is quite minimal unless a random act or accident may occur. I asked the question, "who here twice daily"? All of the ACTEW staff present at that meeting raised their hands. What we dont know, is how long they shower for and if this small act was able to be scrutinised then I think the savings would be huge!!

How are we going to achieve this?

It is important that the code is assessed and implemented in an even and unbiased way across all developments by appropriately qualified individuals who understand what is being done and why.

It is also important that the requirements make sense and are practical. The territory plan and the WSUD manual are not consistent, and the WSUD manual is not consistent within itself. Clarity should be provided as to the exact requirements.

Many instances of non compliant outcomes have been installed since implementation of the code.

Regulation of code compliance and installation recommended.