Archived: Total Water Cycle Management Plans

Integrated Water Cycle Management (IWCM) seeks to plan water management activities to complement each other and provide optimal outcomes for the community and the environment. IWCM is an important aspect of the future of the urban water industry but is often hampered by institutional, political, planning and cost barriers.

Total Water Cycle Management Plans (TWCMPs) were created by the State Government in an attempt to enforce integrated water cycle management by larger local governments. The legislation created a mandatory planning and reporting requirement under the Environmental Protection (Water) Policy 2009, which is subordinate legislation to the Environmental Protection Act 1994. The requirements were introduced in 2009 despite concerns expressed at the time by the industry but with an offer that councils would have meaningful input to the development of regulatory guidelines in the future. A key issues is that TWCMPs overlap considerably with a range of existing mandatory plans but do not integrate with them. The industry position is that IWCM must be complementary to existing planning requirements to be effective.

Summary Facts- TWCMPs

Mandatory Yes
Relevant Period 2013 - 2014
Exemptions not required for councils with populations less than 25,000 people
Penalty Provisions none 
Penalty units none
Approved No
Reporting Once (within 4 yrs) or at request of the Regulator.

TWCMP Coverage

TWCMPs must include provisions about the collection, treatment and recycling of waste water, stormwater, ground water and other water sources and integration of water use within a council's area (s 19). This includes provisions for sewage (effluent, recycling, overflows and biosolids management - s 20), stormwater (quality improvement, PiPs, harvesting recycling and reuse opportunities, and water sensitive urban design - s 21) and trade waste (waste prevention, treatment, recycling and impact on the environment, OHS and council infrastructure). The Environmental Protection Policy also states that when local governments plan and implement their TWCM Plans, they ‘must have regard to guidelines published by the department about total water cycle management’. 

Guidelines for SEQ were created by the Water by Design group of the Healthy Waterways Partnership with significant consultation with the SEQ industry, including the distribution and retail entities, and published in December 2010. Some councils and water entities in SEQ have strongly embraced the concept of IWCM and have developed extensive TWCMP processes consistent with existing planning schemes in the region.

In regional Queensland development of Guidelines by the Regulator has been laboured and tortuous (see Timeline below). TWCMPs are required for all local governments with populations exceeding 25,000, qldwater has repeatedly reinforced the importance of these guidelines to the success of IWCM and the need to make guidelines that are sensitive to regional needs and existing water industry planning requirements. A later deadline for TWCMPs in regional Queensland (compared with SEQ) was granted by the Regulator after significant advocacy and was extended again, by another year, in July 2012.

The draft Guidelines have been in development for two years with repeated requests to the Regulator for industry and council input. The first draft of the TWCMP guidelines was finally provided confidentially for review by qldwater in January 2012. Feedback to the Regulator highlighted the need to focus on the needs of regional Queensland and to integrate with existing planning requirements. qldwater later received verbal advice that all feedback had been incorporated into the draft guidelines but was not provided with an updated document.

Draft versions of the guidelines were circulated to the eight largest regional councils in October 2012 with three weeks to provide a formal response. This process and the timeframe provided caused significant concern given the two-year long process preceding it and the repeated assertions of meaningful stakeholder involvement by the Department.

Approval, Reporting and Review Requirements

The TWCMP must be independently certified by an RPEQ (s 23) and placed on the Council's website and then be reviewed within 5 years (s 17).


There are no legislative penalties. Councils that fail to meet mandatory requirements could be ordered to undertake and Environmental Management Plan.

When are they required?

Local governments in South East Queensland were initially required to develop and start implementing a TWCMP before 1 July 2012. However, in early 2012, following substantial advocacy by the water industry, the Regulator extended the date for SEQ Plans by one year to 1 July 2013.

In regional Queensland deadlines for TWCMPs were initially delayed until 1 July 2013 (for those >50,000 population) and 1 July 2014 (25,000-50,000). In July 2012 the due date for larger councils was extended to 1 July 2014. This means that the 16 largest regional councils must all complete TWCMPs in mid 2014.


There are no exemption provisions for TWCMPs, but the requirements only apply to councils with SEQ Distribution and Retail entities or to councils with populations exceeding 25,000 people. In regional Queensland this includes Toowoomba, Fraser Coast, Bundaberg, Gladstone, Rockhampton, Mackay, Townsville and Cairns (>50,000) and Cassowary, Central Highlands, Gympie, South Burnett, Southern Downs, Whitsunday, Western Downs, Tablelands (25,000 - 50,000).

Interaction with Other Plans and Regulatory Requirements

The EPP (Water) allows other pre-existing plans to be used to comply with the Policy if they meet the appropriate requirements (s 18).


July 2009 qldwater and LGAQ are given three days to provide comment on the draft EPP (Water). Comments note (among other things) the need to remove overlap with other planning requirements, particularly those under the Water Supply (Safety and Reliability) Act
September 2009 EPP(Water) released with no consideration of initial comments provided by qldwater and LGAQ.
Early 2010 Work on Draft TWCMP guidelines for SEQ commences.
April 2010 Letter to Regulator from LGAQ and qldwater responding to draft guideline document and reiterating the need for realistic timeframes and integration with existing planning requirements particularly those under the Water Supply (Safety and Reliability) Act
May 2010 Regulator acknowledges the need for a separate, fit-for-purpose consultation approach (and Guidelines) for Regional Qld councils on advice of LGAQ and qldwater.
June 2010 Regulator commences work on regional guidelines emphasising their “intention to integrate with planning frameworks under the Water Supply (Safety and Reliability) Act and the SEQ Water (Distribution and Retail Restructuring) Act 2009
August 2010 Deadline for regional TWCMPs delayed by one year with a concurrent aim of harmonising the plans with existing statutory planning requirements.
September 2010 First Draft SEQ guidelines released for comment.
December 2010 TWCMP guidelines published for SEQ (with strong support from some councils and water service providers).
March 2011 Industry request for update on progress of regional guidelines (no yet commenced).
April 2011 Industry request for update on progress of regional guidelines (no yet commenced).
June 2011 The State confirmed that: The statutory framework for TWCM planning will be detailed in the guidelines-showing relationships/linkages to relevant legislative instruments”, and
The consultation draft Guideline is targeted for August [2011] completion. Subsequently, formal contact will be made with each large LG (i.e. population greater than 50,000).
September 2011 Industry request for update on progress of regional guidelines (not yet complete).
November 2011 Industry request for update on progress of regional guidelines (not yet complete).
December 2011 Industry request for update on progress of regional guidelines (not yet complete).
January 2012 qldwater  and LGAQ receive confidential copies of the draft guidelines and provided feedback including:
"..the Draft Guidelines disregard all previous feedback from urban Water Service Providers (WSPs) and do not appear to integrate or inform TWCMP with existing WSP planning. There is little support provided to regional councils despite the recognised importance of TWCMP and the strong level of resourcing directed to South East Queensland. If the draft guidelines are correct that “achieving TWCM requires behavioural and institutional change with sufficient resources, communication and organisational commitment” (p. 3), then they do little to assist in this process and need to be substantially reviewed.
"Importantly, despite the repeated requests referred to above, the Draft Guidelines did not encompass existing statutory planning requirements under the Water Supply (Safety and Reliability) Act.
"The guidelines do not address clearly-stated WSP concerns over the integration of existing planning responsibilities (including numerous regulatory requirements overseen by DERM) with TWCMPs. This has been the primary concern of the industry and has been raised on numerous occasions so the silence on this issue in the draft guidelines is surprising and concerning. Regardless of the future of other statutory planning requirements, TWCMPs is strongly linked with much planning in regional Queensland in the past. DERM has repeatedly acknowledged that TWCMPs will need to be harmonised with this history of planning and yet the draft guidelines do not clarify, assist and barely recognise this need.
March 2012 Draft letter to Council CEOs was provided by the Regulator to qldwater and LGAQ and was supported. qldwater  sent an industry letter to all affected councils to suggest options for dealing with TWCMPs. Draft guidelines were not received by the councils.
June 2012 Industry request on progress with guidelines (not yet available).
July 2012 Deadline for TWCMPs in regional Queensland extended by another year.
October 2012 Draft Guideline document sent to councils with three weeks to provide feedback.


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