WATER QUALITY OFFSETS FRAMEWORK: AN INNOVATION IN WATERWAY REGULATION

WATER QUALITY OFFSETS FRAMEWORK: AN INNOVATION IN WATERWAY REGULATION Author: Kate Berg Western Water, Sunbury, VIC, Australia ABSTRACT Western Water has led the development of the Victorian Water Industry and Victorian Environment Protection Authority (EPA) endorsed Water Quality Offsets Framework (WQOF or the Framework) for regulatory compliance in waterways. The Framework used the impact of the Gisborne Recycled Water Plant (RWP) discharge into Jacksons Creek as a case study. Smart Water Fund, The University of Melbourne Carlton Connect Fund and five regional water corporations including Western Water have contributed funding. INTRODUCTION The WQOF project consisted of two phases: the Framework development and the Gisborne RWP case study. Water Quality Offsets Framework This project has seen the development of a Victorian water industry WQOF, endorsed by EPA, which may allow for flexibility in achieving regulatory compliance whilst ensuring positive outcomes for the environment and the community. The Victorian WQOF will provide alternative options for management or treatment of point source water emissions and pave the way for best practice, cost effective environmental management in waterways across the state. Alluvium was engaged to develop the Framework in collaboration with the Victorian water industry, EPA and Department of Environment, Land, Water and Planning (DELWP) (former DEPI). The Framework built upon previous work, case studies, and comparable offset Frameworks throughout Australia and internationally. Gisborne RWP case study The case study, used to test the Framework, aimed to investigate the opportunity for utilising offsets to improve water quality in Jacksons Creek, and to allow the benefical use of recycled water discharged from the Gisborne RWP for environmental flows. The Centre for Aquatic Pollution Identification and Management (CAPIM) was engaged to carry out an aquatic ecosystem assessment and hydrological modelling of Jacksons Creek to identify the major stressors in the waterway and the significance of the recycled water contribution. This component of the case study began approximately 6 months before the commencement of the Framework development, and then the two phases were undertaken in parallel. The outcomes of the aquatic ecosystem assessment were to be utilised in the development of the case study and to inform offset options that provide equivalent or greater protection of the benefical uses of Jacksons Creek and the broader catchment. In addition to the CAPIM work, a number of previous studies informed the case study. The objectives of the case study more broadly were to: Understand the impacts of the Gisborne RWP discharge Identify offset opportunities Engage the community on offset opportunities Develop a life cycle assessment to identify the preferred offset option Identify next steps to investigate recycled water as a beneficial use to Jacksons Creek; Inform long term recycled water investment at Gisborne RWP BACKGROUND Water Quality Offsets Framework An environmental offset is an action(s) to address an adverse environmental impact of resource use, a discharge, emission or other activity at another

location to deliver net environmental benefit. (EPA, 2008) The use of offsets has been recognised in Australia for some time. It is currently included as a protection measure in the Environment Protection Act (1970). Clause 26 of The State Environment Protection Policy Waters of Victoria (SEPP WoV) outlines an off-set measure can be put in place to off-set actions that have the potential to degrade environmental quality with actions which enhance environmental quality (EPA, 2003). However the policy gives no further guidance to water corporations to carry out offsets if they so desire. Offset Frameworks, developed in Australia and internationally, have provided cost effective instruments to manage environmental impacts. Queensland s Department of Environment and Heritage Protection released their Voluntary market-based mechanism for nutrient management in April 2014 outlining flexible options for managing point source water emissions. The purpose of the mechanism is to provide an alternative investment option for licensed point source operators to meet their water emission discharge requirements under the Environmental Protection Act 1994, while delivering an improvement in water quality in the receiving environment (DEHP, 2014). The environmental offset methodology acknowledges the existing health of the waterway and the multiple pollutant sources. It requires investigating external sources of pollutants in the waterway and identifying mitigation measures. A life cycle assessment comparing all mitigation options and associated costs should then be undertaken to determine the most suitable option. The WQOF (previously known as the Environmental Offsets Framework) was one of five projects identified by the previous Victorian water industry and EPA working group as a strategic project in 2011. A key recommendation of this project was that a high level Offsets Framework be tested and further developed through the implementation of a real world pilot project. The working group also proposed a high-level framework that would align with EPA s 2008 Offsets Position Paper. It stated that any future framework should: 1. Deliver net environmental benefit compared to actions that would otherwise be required. 2. Be cost-effective and in proportion to the significance of the adverse environmental impact being addressed. 3. Not facilitate or reward poor environmental management practices that pose significant risk or create inappropriate market distortions. (EPA VWI, 2011) Melbourne Water, through an Memorandum of Understanding (MoU) with EPA, used the priciples of offsets to meet their regulatory requirements relating to the 1-5 sewer spill exceedances in the Upper Dandenong Creek Catchment. The study identified that the primary pollutant sources in the catchment were not related to sewer spills, which allowed alternative catchment improvement works to defer the need to upgrade the sewer main (the traditional approach). Deferring the upgrade has resulted in a cost saving of around $12 million, of which a significant portion has been reinvested in offset opportunities. Gisborne RWP case study There have been multiple studies undertaken for Jacksons Creek, prior to and as part of developing the WQOF, however the major contributing studies were the: CAPIM Aquatic Ecosystem Assessment (2015) Hydrology and Water Quality Impact Modelling (GHD, 2013) Ecological Risk Assessment of Gisborne, Sunbury and Woodend Recycled Water Plant (GHD, 2013) The Melbourne Water Healthy Waterways Strategy (2013) identifies the Implementation of appropriate environmental flow regimes particularly in Jacksons Creek downstream of Rosslynne Reservoir as the priority action for the Maribyrnong catchment. Re-use of recycled water in waterways to provide environmental flows is recognised in Clause 31 of SEPP WoV (2003) so long as the benefical uses of the receiving waters benefit from the flow, and are not detrimentally affected from the recycled water supplies. The Hydrology and Water Quality Impact Modelling study carried out in 2013, indicated recycled water discharged into Jacksons Creek provides a hydrological benefit of 20% of base flows to the waterway (GHD, 2013). However, the Ecological Risk Assessment revealed that the recycled water discharged into the creek is having an impact on water quality, with a mixing zone extent of up to 10km. When determining the mixing zone for phosphorus, more thn 50% of data was excluded which highlighted the issues around secondary pollution issues in the creek and the need for further work to be conducted. Western Water is permitted to discharge from the Gisborne RWP under its EPA corporate licence. EPA Water Plan 3 Guidance (publication 1406.1) directs water corporations to reduce discharge impacts and mixing zones by 2018 and have little to no significant environmental impact, or net

environmental benefit provided in the future (EPA 2011) The residential population in Western Water s region is forecast to more than double in the next 20 years. The Gisborne RWP inflows will increase from 552 ML in 2012/13 to 626 ML in 2017/18.. Western Water will have more recycled water and potentially fewer recycled water customers if current rural zones are rezoned as residential. There is currently a demand for around 200ML/yr for recycled water on the Gisborne Recycled Water Scheme (RWS). The bulk of the interested Class B recycled water customers, in a reasonable vacinity to the RWS, are currently supplied. Extending the RWS as a potential option to reduce the mixing zone will be both expensive and difficult to find new demands. There are no plans to upgrade the Gisborne RWP to Class A recycled water due to the size of the town and reletively low growth expected in the region. To enable the Gisborne RWP discharge to be considered an environmental flow, the beneficial uses outlined in the SEPP WoV must be protected. Traditional engineering solutions can address this through treatment plant upgrades or recycled water scheme extensions but may not provide the best environmental outcome or the lowest cost for the communities. Water quality offsets provide an innovative solution to allow a proponent to trade one management approach for another, so as to ensure the best environmental, social and economic outcomes overall. In light of other known diffuse pollution sources in the catchment, the requirement for further work was identified by Western Water to understand the significance of the recycled water contribution in relation to other impacts in the catchment and to identify if there was an opportunity to use offsets. METHODOLOGY Water Quality Offsets Framework The Framework was developed using the following methodology: 1. A review of literature on other offset schemes in Australia and internationally 2. A series of workshops with stakeholders (including EPA) to develop the Framework and to ensure alignment with EPA policy and guidelines 3. Developing a Draft Framework to be reviewed by stakeholders 4. Testing the Framework with the case study 5. Final Framework distributed to the Victorian water industry. Stakeholder Engagement A stakeholder engagement process has been central to the development of this project, to gain support and traction throughout the water industry. At the WQOF project inception, a Project Advisory Committee (PAC) was established to drive the project. The group had representatives from Western Water, Smart Water Fund, Wannon Water, Central Highlands Water, Coliban Water, Gippsland Water, EPA, DELWP, Melbourne Water, Yarra Valley Water, City West Water and South East Water. These representatives attended 3 key workshops and provided guidance and feedback on the draft framework and discussion paper. Gisborne RWP case study The case study development broadly used the following methodology: 1. Integrate key findings of Aquatic Ecosystem Assessment of Jacksons Creek (see methodology below) 2. Further development of the offset opportunities recommended 3. Community engagement to understand what the community values about Jacksons Creek, community acceptance of using offests and willingness to pay for various offset opportunities. 4. A Life Cycle Assessment of offset options to identify a preferred option using a cost benefit analysis approach 5. Recommendation of an offset option to improve water quality in Jacksons Creek. Aquatic Ecosystem Assessment An integrated catchment approach was utilised to assess the aquatic stressors in the Jacksons Creek Catchment and the potential impacts of the Gisborne RWP discharges. The study area ranged from the top of the catchment upstream of the Rosslynne Reservoir to upstream of the Sunbury Township (Hassell, K. 2015). To understand the impacts in Jacksons Creek, CAPIM used a multiple evidence approach: 1. A literature review to establish the existing state of knowledge of the catchment, and to identify knowledge gaps that would inform research priorities; 2. A catchment-wide environmental study which incorporated chemical, ecotoxicological, and biomonitoring assessments in order to understand the nature of any impairment occurring within the catchment, and the effects of discharges from the RWP on Jacksons Creek; and 3. Hydrological modelling using an urban runoff model. (CAPIM 2015)

DISCUSSION AND RESULT ANALYSIS Water Quality Offsets Framework A literature review was carried out to develop an understanding of offset schemes internationally, in Australia, and in Victoria (this was primarily done through the consultation of industry experts). The literature review found that: The principal component of successful offset schemes, both internationally and Australia wide, consist of a like for like offset trading component. Well understood regulation is the foundation for successful offsets schemes EPA offset principles (outlined below) are the common elements of successful offset Frameworks. (Alluvium, 2014a) Stakeholder engagement was a pivotal component of the Framework development. Stakeholders came together predominantly from water corporations across the state, EPA and DELWP, to be involved in various workshops, aiming to come to an agreement on how the Framework should be developed. The first WQOF workshop involved the initial stages of development using various case studies from across the water industry and agreement of the Offset Principles that EPA identified in their 2008 discussion paper. The principles state that offsets should be: Measurable the impacts, benefits and outcomes must be reliably measurable, and take account of risks and uncertainty Verifiable using an appropriate standard where available Additional demonstrated to be additional to business as usual operations Counted once the same emissions reduction cannot be counted towards more than one offset or emission reduction scheme Reviewed periodically as technology improves and/or more accurate information becomes available Enforceable through licence conditions, notices, a contract or other means Timely must offset the impact of the adverse environmental impact over an appropriate time scale Socially and locally acceptable taking into account the range of possible local community and environmental impacts Located appropriately they must offset the impact at an appropriate scale and location to effectively offset the environmental impacts being managed. (EPA, 2008). The stakeholders identified the need to address the principles of environmental protection under the Environmental Protection Act (E.g. the waste hierarchy) and that the principles would be accepted. EPA identified the need to use a risk-based assessment (RBA) approach in developing offsets. As described in the EPA Victoria publication, RBA provides not only an objective and transparent process but also clear statements of goals, understanding, outcomes of actions and uncertainty as well as accurate technical information that is needed by both EPA Victoria and the proponents to make an informed decision. (Alluvium, 2014b) The first workshop identified key challenges for the Framework development including: Defining and achieving equivalence Currency Like for like vs. non- like for like offsets. (For example, Like for like would consist of offsetting nitrogen in the discharge for nitrogen in the catchment and non-like for like would consist of trading nitrogen in the discharge for fish ladders within the catchment) The second stakeholder workshop included a similar representation, and this time aimed to address these challenges as well as obtain feedback from stakeholders on the proposed offsets The Framework was presented in Alluvium s draft discussion paper. Defining and achieving equivalence was addressed through ratios. Ratios were proposed to address three different categories of uncertainty. They are: 1. The time of implementation of the offset option 2. The uncertainty and reliability of the offset action proposed 3. The location of the offset action relative to the impact (Alluvium, 2015) Currency and like for like vs. non- like for like were addressed through changing the terminology and adopting three categories to analyse offsets: 1. Same currency, same beneficial use. When offset options are compared using a common parameter which acts on the same beneficial use (e.g. different methods of reducing nitrogen discharge in a catchment are assessed based on their impact on a downstream bay). 2. Different currency, same beneficial use. When offset options are compared even though different parameters act on a given beneficial use (e.g. one option may increase flows to a flow stressed system and their impact on fish communities, another may decrease pollutant loads that affect water quality for those fish) 3. Different currency, different beneficial use. The analysis considers options that act in

different ways as above but also considers different uses (e.g. one option may consider the impact of phosphorus on fish but another considers the discharge of metals on an irrigation off take) (Alluvium, 2015) The third stakeholder workshop involved resolving remaining technical issues and ensuring industry acceptance of the refined Framework. A core value that was identified in the workshops is that water corporations are not aiming to avoid their regulatory responsibilities: put simply, the Framework is a tool that enables broader thinking when adopting the best outcomes for the waterway, the community, and the water corporation when balancing the cost of large asset investments against the societal benefits these deliver. The Framework proposes 5 phases: Phase 1: Preliminary assessment Phase 2: Assessment of risks to beneficial uses Phase 3: Offset evaluation Phase 4: Offset implementation Phase 5: Offset review Phase 1 is aimed at scoping the issue around the regulatory driver, impact to beneficial uses and gaps in the data. A decision tree aids the process, as can be seen in Figure 1. Phase 2, the proponent will have enough information to decide if offsets are possible. Phases 1 and 2 are based on the steps contained in EPA s risk assessment process (Alluvium, 2015). Phase 3 contains the analysis and evaluation of various offset options. Each option is compared against a number of criteria, which are in line with the offset principles (as outlined above): (Alluvium, 2015) Phase 4 involves offset implementation. When a preferred offset option has been identified, a MoU or other contractual arrangements are proposed between the proponent and the EPA. Phase 5, the Offset Evaluation and Review, ensures that the offsets were implemented and tracked in accordance with the MoU. It is also aimed at reviewing and informing the Framework. Gisborne RWP case study Aquatic Ecosystem Assessment A literature review was conducted prior to the ecosystem assessment, and found that the condition of Jacksons Creek was poor due to a number of stressors. The primary issue was that Rosslynne Reservoir has altered the hydrology of the Creek, in addition to degraded riparian vegetation and poor condition of macroinvertebrates throughout the catchment. Fish populations are limited due to the stress of decreased flows during the Millennium drought (Hassell, K. 2015) The results of the aquatic assessment were that nutrients were high throughout the entire Jacksons Creek catchment within the study area, and regularly exceeded ANZECC (The Australian and New Zealand Environment Conservation Council) trigger values both upstream and downstream of the RWP. (Hassell, K. 2015) The assessment found that Gisborne RWP was a source of nutrients in the creek; however agriculture land use and direct cattle access to the creek were also significant contributors (Hassell, K. 2015). The hydrological modelling indicated that total nutrient loads are likely to decrease in Jacksons Creek with future urbanisation, as a result of changing land use. (Hassell, K. 2015). It should be noted that this finding is contrary to some literature and conventional thinking. Figure 1. Key steps in preliminary assessment (Alluvium, 2015) In Phase 2 if additional data is required a full risk assessment should be carried out. At the end of Various stormwater drains in the Gisborne township were identified as significant contributors to heavy metals, pesticides and petroleum hydrocarbons in the creek (Hassell, K. 2015). The stormwater drains, in addition to the Gisborne RWP and Riddells Creek, were also sources of toxicity and biological impairment to taxa in the creek (Hassell, K. 2015). In contrast to nutrient loads, future

urbanisation is expected to increase metal and pesticide pollution, and associated with that, toxicity and biological impairment are also likely to increase in Jacksons Creek downstream of the urban growth areas (Gisborne and Riddells Creek townships). (Hassell, K. 2015) Further work was recommended to understand the impacts of endocrine disrupting chemicals from the Gisborne RWP. However, this was considered to be of secondary importance, whilst lack of adequate water is considered the key stressor and of primary concern (Hassell, K. 2015). The impact of the Gisborne RWP was as follows: 1. The RWP has a positive influence on flows. A continual discharge from this plant would help sustain flows during droughts. 2. Increased nitrogen loads are considered of minor concern compared to the positive effect that the discharge flows have on the ecosystem downstream. 3. Other pollutants (e.g. endocrine disrupting chemicals) were detected in the RWP discharge. Such pollutants are often associated with wastewater treatment facilities, and may affect the health of fish and other organisms. (Hassell, K, 2015) CAPIM provided a number of offset options that were utilised in the community engagement activities including: Identify the sources of pollutants entering Jacksons Creek at Prince St and reduce this pollutant load Water Sensitive Urban Design (WSUD) practices, in new developments. Reduce the pollutants entering into Jacksons Creek from the RWP through monitoring and toxicity testing. Ensure sufficient flows in Jacksons Creek to maintain healthy fish and platypus populations. Improve riparian vegetation along Upper Jacksons Creek Identify any sources of pollutants that might impact the fish and platypus populations and reduce this pollutant load (Kellar et. al, 2015) Community Engagement Community engagement was imperative to understanding how the community valued Jacksons Creek and whether they would support the use of offsets. The community consultation consisted of an online survey and workshop. Through the community survey, 141 Western Water customers in the Gisborne region (accessed through Western Water s Online Panel), were asked about what they value about Jacksons Creek, their support for upgrading the Gisborne RWP, like-for-like and non-like-for-like offset options, and their willingness to pay to have offset options implemented (Alluvium, 2015). The community workshop utilised Western Water s Macedon Ranges Community Reference Group and used the survey as a base to gather data for the same items. The workshop results mirrored the survey results that indicated that the local community highly valued Jacksons Creek, were supportive of the use of offsets, and confirmed a willingness to pay to protect the values of Jacksons Creek. The first WQOF discussion paper highlighted that good offset implementation needs to be socially inclusive and that the level of community interaction needs to be guided by the degree of impact. (Alluvium, 2014a) Life Cycle Assessment Through the CAPIM aquatic ecosystem assessment and Melbourne Water s Healthy Waterway Strategy (2013), the following offset options were further developed and analysed through a Life Cycle Assessment LCA): Revegetation of riparian zones and reduction in stock access along Jacksons Creek to reduce pollutants entering the waterway Extending recycled water network to reduce discharge of wastewater in Jacksons Creek Returning treated recycled water to Rosslynne Reservoir to reduce discharge in Jacksons Creek Implementing stormwater treatment (e.g. wetlands and rain gardens) to reduce pollutants from existing urban areas of Gisborne Increasing targets for stormwater treatment in new developed areas to reduce nutrient loads from stormwater discharge in Jacksons Creek (beyond current legislated targets) Implement stormwater control measures to improve water quality at hot pollution spots in Gisborne Township (Alluvium, 2015) All options were assessed in comparison to an upgrade of the Gisborne RWP (the base case) to achieve fit for purpose water for environmental flows. A high-level overview of costs was utilised based on load reductions to Jacksons Creek. This method was selected given the availability of data. To determine costs for each offset option a levelised

cost of $/kg of nitrogen removed was used. (Alluvium, 2015). Through the LCA it was determined that the Gisborne RWP upgrade was the most cost effective option in comparison to the other offset options. Testing the Framework To test the Framework, using the Gisborne RWP case study, only Phases1-3 were tested. Phases 4 and 5 were not applicable as they were not in the project scope. The outcomes of Phase 1 (Preliminary Assessment) showed the driver for offset options in this case study were offsetting the recycled water quality impacts to the beneficial uses of Jacksons Creek, to allow the long term re-use to waterways as an environmental flow. Through reviewing the available data, including the CAPIM study and the previous GHD study, it was found that it was likely that the Gisborne RWP discharge was having an impact to beneficial uses. Phase 2 (Assessment of Risks to Beneficial Uses) using a RBA found that risks to beneficial uses in the mixing zone will increase given the projected increase in inflows to the treatment plant over the longer term (Alluvium, 2015). Phase 3 (Offset Evaluation) analysed the options used in the LCA in comparison to the base case. A same currency, same beneficial use approach was used to analyse the offsets. The options were assessed for net environmental benefit against each offset principle and ratios were applied to the Equivalence, Timely, and Located Appropriately principles (Alluvium, 2015). The socially acceptable principle was assessed through the community engagement. From undertaking the first three phases of the Framework, it was established that offsets were appropriate, but unlikely for the Gisborne RWP (Alluvium, 2015). Upgrading the treatment plant was the most cost effective way of alleviating impacts on Jacksons Creek. It should be noted, that this cost effectiveness applies when purely assessing the cost to remove and treat nitrogen and phosphorus. The multiple benefits provided by some of the offset options could deliver greater environmental outcomes for Jacksons Creek. Subject to potential funding by stakeholder beneficiaries, the preferred offset option could be reprioritised. FINAL FRAMEWORK The Final Framework was provided to stakeholders in April 2015. Guidance on community consultation (based on International Association of Public Participation IAP2 Framework) and the development of LCA s have been included as part of the final Framework. EPA has indicated that they support the use of the Framework and see it as current best practice within the Victorian water industry; however, it will not sit within their jurisdiction to manage the Framework. Therein lays the challenge of finding a home for the Framework to ensure its ongoing effectiveness. Ideally, this Framework would be considered in the SEPP WoV that is anticipated to be reviewed in the 15/16 financial year. The dissemination of this Framework is also critical to its success. An action plan to roll out the use of this Framework state-wide is under way. A reference group will be required to update and manage the Framework and Water Industry associations have been approached to play a role in this. LESSONS During the consultation process, EPA identified their preference to use a RBA in the Framework to identify impacts of beneficial uses. This has meant that the Framework is lacking some flexibility that was initially proposed. Integration of the aquatic ecosystem assessment has proven difficult. In retrospect, if the case study was completed after the Framework development it would have been realigned to meet the Framework s (and EPA s) requirements of an RBA. (I.e. the study would have been scoped to look at risks to beneficial uses). Likewise, it was difficult to retrofit the Melbourne Water case study to test the Framework, as it did not consider risk to beneficial uses. CAPIM s work is gaining traction throughout the water industry through their innovative, multiple lines of evidence approach, and going beyond the traditional method of assessing the health of an ecosystem. Through the revision of the Framework, there should be scope to use innovative approaches to understand point source impacts. CONCLUSION Through the WQOF, Victorian Water Corporations will now have the opportunity to meet regulatory compliance in a way that ensures the best outcomes for the environment and the community at least cost to the customer. Further work will be required to ensure that the Framework further develops to meet the evolving needs of the Victorian Water Industry and that there is a strong willingness to participate and

acknowledgement by the water industry that this is an important area for future involvement and investment of time, energy and resources. The Framework alongside the case study, including the CAPIM assessment, will be pivotal to assessing Western Water s recycled water investment decisions including, the potential to contribute recycled water for environmental flows to improve the health of Jacksons Creek. The next step for Western Water will be to engage with the relevent stakeholders to further this opportunity. ACKNOWLEDGMENTS Funding bodies/ Parners Smart Water Fund (Damien Connell) Carlton Connect Fund Coliban Water Gippsland Water Wannon Water Central Highlands Water The following contrators and consultants were engaged to assist in the development of the Framework and case study including, Alluvium, CAPIM, Marsden Jacob Associates, Karoo Consulting, Waterscience and Volders Consulting. NOMENCLATURE Beneficial use: use of the environment, which is conducive to public benefit, welfare, safety, health or aesthetic enjoyment and requires protection from the effects of waste discharges (EPA, 2003) Currency: Parameter that is causing the impact and used to determine equivalency of an offset action (e.g. pollutant load) (Alluvium, 2015). Like for like offsets: Actions that offset the impact of a regulation not being met using the same currency (E.g. if wastewater discharges exceed their total nitrogen requirements, a like for like offset would be to reduce total nitrogen entering the waterway with an upstream wetland.) (Alluvium, 2014a) Non-like for like: offsets Actions that offset the impact of regulation not being met using a different currency (e.g. if the regulation impacts on public health issues, and the risk is assessed to be low, Then works to improve amenity of the waterway could be considered). (Alluvium, 2014a) REFERENCES Alluvium (2014)a. Water quality offsets Framework: summary paper. Report by Alluvium Consulting Australia for Smart Water Fund and Western Water. Alluvium(2014)b. Water quality offsets Framework: Offer of Services. Report by Alluvium Consulting Australia for Smart Water Fund and Western Water. Alluvium (2015) Final Report Water Quality Offsets Framework Department of Environment and Heritage Protection (DEHP), 2014, Flexible options for managing point source water emissions: A voluntary market-based mechanism for nutrient management, Brisbane, QLD, Australia EPA Victoria, 2003. State Environment Protection Policy (Waters of Victoria), Government Gazette No. S107, 2003. Environment Protection Agency (EPA) Victoria 2008. Discussion paper: Offsets. EPA publication no. 1202.3, June 2008. Environment Protection Agency of Victoria (EPA) and Victorian Water Industry (VWI) 2011. Environmental Offset Framework. June 2011 Environment Protection Agency of Victoria (EPA), 2011, EPA Water Plan 3 Guidance publication 1406.1 GHD 2013. Gisborne RWP Recycled Water Return to Stream Hydrology and Water Quality Impact Modelling. Report prepared for Western Water Corporation, January 2013. Kellar et. al, 2015, Identifying the factors influencing aquatic ecosystem health in the upper Jacksons Creek catchment Final Report (CAPIM), University of Melbourne, Victoria, Australia Hassell, K. 2015. An integrated catchment management approach to assess the impact of treated wastewater discharges on aquatic ecosystems : Jacksons Creek Study Summary of Findings, Centre of Aquatic Pollution Identification and Management (CAPIM), University of Melbourne, Victoria, Australia Melbourne Water 2013. Healthy Waterways Strategy. Chapter 5 Maribyrnong catchment, November 2013.