190 Sugarloaf Road, Eildon 3713 PO Box 21 Eildon 3713 ACN

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1 190 Sugarloaf Road, Eildon 3713 PO Box 21 Eildon 3713 ACN Attention: Jacobs Consultancy LEHIA Submission to Houseboat Greywater System Review Discussion Paper LEHIA is appreciative of the opportunity to provide input into the Draft Report. LEHIA has always been supportive of measures to ensure the best possible water quality for Lake Eildon whilst permitting Recreational Use of Lake Eildon. LEHIA has always had a goal to ensure where practical the houseboats on Lake Eildon embrace environmental best practice. Having said this, the introduction of the Lake Eildon Recreational Area, Houseboats Regulations 2013 with the requirement for all houseboats to treat Grey Water by 2020 to Australian standards resulted in unforeseen circumstances which have had significant impacts on many owners of houseboats on Lake Eildon. Many Industry Members have been part of this journey re the introduction of GWTS for many years. Before the formation of LEHIA, GMW staff held Stakeholder Meetings and to some of these meetings GMW brought representatives from South Australian Companies that were providing GWTS to the S.A. Houseboat Industry. The strong contention was that these two systems were working to appropriate standards on houseboats on the Murray River in S.A. Since then, one of these systems has been withdrawn and is no longer produced. The other system is available for use on Lake Eildon. As a result of the presentation of these two systems, that were portrayed to be operating without issues, the case was made that there is technology available to treat Grey Water to the appropriate Australian Standards for houseboats. GMW up to this stage had permitted containment of Grey Water on houseboats for newly constructed houseboats and them pumping out at the Point Worner Pumping Station. Two issues were then assessed by GMW; One was the volume of effluent that would now be pumped through the Point Worner Pumping Station and the issues this would create. Two, the availability of two GWTS on the market that could treat the Grey Water and return it to the Lake. Consequently, in the 2013 Regulations the Policy permitting Containment and Pumping Grey Water was discontinued. Therefore the situation imposed on the Houseboat Industry was no containment as there were two systems working satisfactorily that met the Australian Standards that could be fitted to houseboats. Post 2013 the reality has been different to the situation envisaged in the 2013 Houseboat Regulations.

2 Of the two systems on the market at that time, one is no longer produced. A new third system was approved and after many teething problems it is no longer produced. A fourth system was approved and is still being fitted to houseboats. However, when talking to the Business installing this system there has been significant Research & Development undertaken over the last 4 years to overcome issues arising when translating this system from a domestic household situation to being on a Houseboat. Only very recently, a fifth system has been approved by GMW for use on Houseboats. In talking with the owner of a houseboat in mid-january 2017, where this system was installed in December 2016, he indicated that the system had worked and not caused any issues. Taking all this in, it is not difficult to understand that Houseboat Owners have little faith in the GWTS, especially with the significant costs involved. Further, the introduction of the 2013 Houseboat Regulations were based on the premise of there were systems available to treat Grey Water to Australian Standards and these systems would cost around $18,000 installed to retrofit a houseboat. GWTS One & Four require 240 volt power/ electricity to operate. Most older houseboats do not have 240volt power available and are based on 12 volt power. Therefore, the cost of retrofitting an older houseboat with a GWTS rises significantly. Many older houseboats also are close to the maximum of their buoyancy with their current pontoons. Adding a GWTS and the Solar Electrical House Batteries required could require a greater expenditure on buoyancy issues with increased pontoon capacity required. With smaller older houseboats this adds to the costs which can make many of these houseboats unviable. This has consequences particularly with people trying to sell their assets. Evidence from LEHIA Houseboat Broker Members has indicated these issues have had a significant negative impact on the values of people s property and their ability to sell their asset. This has led to a very messy situation where a person can sell their asset but GMW is not permitted to transfer the Lake Eildon Houseboat Licence unless the houseboat has a GWTS installed. Many people are in financial situations where they do not have access to the $20K plus (particularly with older houseboats) required to install a GWTS. This is causing significant grief with some houseboat owners. What the Houseboat Brokers have learnt is that it is far better for the onus to install a GWTS be with the Purchaser and not the Vendor/Seller for a number of reasons. Having laid out the issued as understood by Members of LEHIA, we turn our focus to possible solutions. Firstly, LEHIA would have appreciated a copy of the full draft Jacobs Lake Eildon Houseboat Greywater Review being made available to the Industry and not just the Executive Summary. If Government wants to engage the Industry in an open transparent manner please put all the information in front of the Industry not 2 days before the deadline for Submissions.

3 Having said that, with regard to Section 8 of the Executive Summary, LEHIA supports existing requirements to install a GWTS to:- (i) All new houseboats regardless of what Category they are. (ii) Houseboats subject to major upgrades. (iii) All Category 6 houseboats by July 2020 or any new date implemented as a result of this review. (iv) Houseboats where they move up a category after renovations. Further in Section 8. Dot Point One:- (a) LEHIA requests a new starting date for the requirement to install a GWTS to align to the 5 7 year slipping of every houseboat. (b) The new starting date will be when the amendments to the Regulations are approved. (c) Understanding that when a houseboat is slipped before a GMW CHIR is approved it will have a GWTS installed. (d) This condition is subject to further comments based on Categories of Houseboats. Dot Point Two:- LEHIA using feedback from Member Houseboat Brokers strongly supports the onus being placed on the Purchaser of the houseboat and providing them with a 12 month grace period to install a GWTS. Dot Point Three:- (a) With regards to the Australian Standards for approving GWTS, LEHIA Members are requesting confirmation that all approved GWTS are equally assessed and all pass the same Australian Standards. (b) As will be discussed further, LEHIA believes that in certain cases containment of Sink Waste should be permitted. Dot Point Four:- LEHIA supports exempting Category 1 & Category 2 houseboats from Regulation 5(3) (b) of the GWTS Regulations. These boats are so small and are really no different in many ways to many speedboats currently using the Lake. In the LEHIA submission to GMW on the future of Houseboating on Lake Eildon (March 2016) Industry indicated there needs to be strategic work untaken with the Industry of how this category is encouraged in the future. Further the cost of installing a current GWTS is far more then these small houseboats are worth. These houseboats do not have the 240volt power to operate a GWTS. Further, LEHIA strongly believes that Category 3 Houseboats be included in this exemption. Table 5.1: GMW Houseboat categories indicates there are only 23 remaining Category 3 houseboats on Lake Eildon. The reality is these houseboats will disappear within the next 5 years as the demand to build new category 6 houseboats continues to grow. Why impost a significant unviable cost on these smaller houseboats when they will be gone before the required date of July 2020.

4 Estimates from LEHIA Members are there will be at least 10 if not more new Category 6 houseboats built in These new houseboats will have to acquire their Houseboat Licences from somewhere. This will be from the cheapest, usually the oldest houseboats on the Lake. Dot Point Five:- In response to this recommendation LEHIA has already provided its position on Category 3 Houseboats. LEHIA has also provided its position on Category 6 Houseboats. This brings us down to Category 4 and Category 5 Houseboats. According to Table 5.1 there are 287 houseboats in Category 4 and 222 in Category 5. As a general rule, Category 5 Houseboats date from mid to late 1990 s until These houseboats are generally with square pontoons, are larger (18 to 20ft in width) and contain more recent electrical technology. Also these houseboats generally would have two kitchens and more accommodation (i.e. more people having showers). These houseboats are normally of a higher value ($350K to $700K). LEHIA s position is that these houseboats should adhere to the LEHIA position in Dot Point One. This then leaves Category 4. This is the area of greatest contention and the greatest difference in capability of these houseboats. Generally these houseboats are older from the mid 1970 s up until the mid 1990 s. These houseboats are generally smaller with less accommodation, single kitchens, smaller round pontoons and importantly many are 12 volt houseboats. LEHIA s position for these houseboats is that their kitchen waste be contained with or in a separate Black Water Waste Tank and pumped out at the Pumping Station. Timelines for this would be according to Dot Point One. However, LEHIA also believes these Category 4 Houseboats should have an approved GWTS before their next 5 to 7 years slipping requirement after the timelines in Dot Point One. LEHIA is of the belief that during this next period:- (i) Technology will advance and these houseboats will be able to have a GWTS installed. (ii) Many of these houseboats will upgrade to the next Category and will be required to install a GWTS according to the Houseboats subject to major upgrades or they move up a Category. (iii) Many of these smaller older houseboats will be removed from the Lake for their Houseboat Licence to enable the build of the newer larger houseboats. Adopting these Recommendations for Category 4 Houseboats will remove significant angst from the current situation and will achieve the water quality objectives of which the overwhelming majority of people support.

5 LEHIA would also like to make the following comments:- (A) Some Members have been unfairly maligned by a small number of houseboat owners as the Members are only providing the product (GWTS) that the State Government has mandated. It is for the State Government Authority to communicate the case as to why the GWTS are required; not the individual businesses. The bigger picture of what is happening elsewhere in the Catchment to enhance water quality and the piece of this Jigsaw that Houseboats play in this has not been adequately communicated, is the opinion of LEHIA. (B) LEHIA strongly believes that the current situation of angst over the imposition of these regulations is symptomatic of the current management regime for Recreation & Tourism on Lake Eildon. Recreation & Tourism on Lake Eildon is a significant Industry and provides many jobs in the communities that surround the Lake. LEHIA has produced data indicating the importance of the houseboat component of this Recreation & Tourism Industry and is willing to share it. Recreation & Tourism has the potential to create significantly more jobs for these local communities. This is not a criticism of GMW; The CORE and PRESCRIBED ROLES for GMW are to provide a well-managed Irrigation System supplying water to their clients. They do this extremely well and this is understood. These roles do not mention Recreation & Tourism. GMW has inherited the Waterway Manager Role and the Recreation & Tourism Roles from their predecessors of RWC & SR&WSC. GMW is not funded to deliver these responsibilities. LEHIA strongly believes that either:- (i) (ii) An appropriate separate Department is set up within GMW, led by someone at General Manager level, with appropriately qualified staff experienced in Recreation & Tourism to manage and develop Recreation & Tourism at Lake Eildon. OR a separate Lake Eildon Recreation & Tourism Authority is setup to manage and develop Recreation & Tourism to achieve its potential to deliver the jobs for the local communities. Recreation & Tourism is already a significant industry but it can deliver so much more with the right management structure. LEHIA is prepared to engage further with Government to develop these proposals. Thank you for the opportunity to provide this submission to this Draft Report. Yours sincerely, Mike Dalmau President LEHIA