Two of the country’s leading manufacturers and suppliers of stormwater management infrastructure have supported the push for performance validation protocols of proprietary devices. 

Dr Charles Kelly, Commercial Manager (Water Solutions) from Humes and Stephen D Baker, Manager Water Quality of Rocla offered their support in separate communications with the Bulletin’s editorial team. 

Dr Kelly said, "Performance validation of proprietary devices is imperative if the industry is to move forward with a balance of options available to key specifiers and asset owners. 

"The development of these protocols will, however, not be a five minute job. 

"For a start, detailed input will be required from academics, leading consultants within the field, authorities as asset owners, authorities as assessors, regulators at both the state and federal levels and suppliers of all levels of treatment," Dr Kelly added. 

"Importantly, all participants must be heard regardless of their size and/or perceived presence and standing in the industry, with a view to a completely open and fair discussion as to the features and benefits of such an approach."

Dr Kelly was particularly interested in the protocol development process. 

"It is very important that there is no self-proclaimed policing entity that has the perceived power or authority to veto the discussions or recommendations from others without there being a full and open discussion around each and all of the points of view amongst all parties. 

"I know that will add time but the only way we can do this properly is to set up an effective engagement process right from the beginning and ensure it is followed through at all stages of discussion." 

Dr Kelly went on, however, to point out that we should not start from scratch. 

"We need to avoid the development of protocols that demand a completely new set of field-based experiments, because some industry participants have previously or are currently investing significant funding in field-based research on multiple devices. 

"Basically, it would be silly to disregard all the previous hard work and investment in this area but we need to make sure those involved in protocol development have the capability to review the research that has been conducted and have that research assessed in line with the protocols they are working on." 

Stephen D Baker, Manager, Water Quality for Rocla Pipeline Products offered similar views but also encouraged the industry to take a couple of steps back before diving into writing protocols. 

"I think the industry has confused itself of late by trying to jump straight to a solution for what is a not so easily defined nor agreed problem," Mr Baker said. 

"This protocol development process and the products of the process offer a great opportunity to the industry if we get it right.  It will provide an excellent base for similar future activities. 

"I believe however that the first step in establishing a sound base for this project is to go back to the point of reaffirming why stormwater treatment is important, the scope of the problem, the cause of the problem and the specific pollutants associated with the problem. 

"We need to spend time on describing these pollutants in order to remove ambiguity and make each definition mutually exclusive. 

"We then need to ensure there is an agreement on the specific physical properties of the pollutants, the critical parameters of those pollutants and from there agree on the specific methods which demonstrate performance to the identified parameters," Mr Baker continued. 

"We also have to make sure the specific methods designed to demonstrate performance provide consistent results and are repeatable. 

"We may have to agree that more than one test could be required for a particular pollutant as a one size fits all may not be appropriate." 

Mr Baker went on to say that there was more to this project than agreeing on testing and measurement methods. 

"The protocol should also include a standard protocol for reporting of test results. 

"When that is established, existing reports could be reinterpreted to the new protocol by recognised experts which would save the expense of re-testing." 

Mr Baker also supported Dr Kelly and Mr Brown’s (Stormwater360) views that a new protocol should not mean everyone who has spent a lot of money on testing needs to start again from scratch. 

‘All of the leading companies and a number of regulatory and other agencies have spent a great deal of money in developing their own performance protocols. 

‘We need to take this into account when developing an industry wide assessment system. 

Mr Baker also stressed that the development of protocols should not lead to "performance points tables or direct comparison between market products". 

"Comparisons between products should be done on a project by project basis by the consultant or owner manager as part of the design process using the information within the reporting frameworks agreed in the protocol and the specific outcomes required by the project. 

"This project is not a five minute task but it is a very important task for the credibility and future of the industry. 

"When we do this well, the outcomes will be organisations striving to improve their performance against agreed standards and assessment agencies, planners and designers specifying high performance products to achieve their environmental objectives.

"And when those objectives are achieved the bottom line will be better protected local environments and in the end that is what we are all about," Mr Baker concluded.