In March of 2019, Stormwater Queensland surveyed our members on the Stormwater Quality Improvement Device Protocol (SQIDEP) Version 1.3. We want to thank those who took part in this survey.  The feedback of the survey raised a number areas that Stormwater Queensland has taken the time to investigate and address.  This has included taking clear and transparent steps in how the committee responded to conflicts of interest and investigating a large number of technical elements.
We have now collated the responses and feedback from the survey as well as completed the additional research and have made a submission to Stormwater Australia.  This submission expresses our strong support for the development and implementation of a national stormwater quality improvement device protocol and an independent evaluation process for devices tested using such a protocol.  We are supportive of Stormwater Australia taking the lead in much needed and long overdue pieces of reform.
In particular, the submission covers several SQIDEP administrative matters, SQIDEP scientific/technical matters, as well as Stormwater Queensland’s view on SQIDEP. It was very important throughout developing this submission that any conflicts of interest were managed through a thorough and strict framework, which is also included in the submission. 
Stormwater Queensland’s view is summarised in the following points.
  1. There is strong support for the development and implementation of a national stormwater quality improvement device protocol and an IEP for devices tested using this process.
  2. These are much needed and long overdue pieces of reform which can bring numerous benefits to the industry including greater transparency, credibility, certainty, equity and probity. 
  3. SQ recognises SNat’s initiative and efforts in developing such a protocol.
  4. The matters identified in this submission raise questions about the robustness of SQIDEP. These include loopholes which could enable selective monitoring practices and potentially misleading water quality performance data.
  5. SQ suggests that rather than having a single level of verification, consideration be given to a tiered approach, with different tiers targeting the needs of different manufacturers and regulators.
  6. The implications of these matters are significant and create a constraint for SQ endorsing SQIDEP in its current form. For clarity, SQ does not support the current version of SQIDEP.
  7. It is requested that SNat consider the matters raised in the submission and provide a suitable response to SQ in a timely manner.
  8. SQ is willing to provide support where possible and appropriate.