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State Significant Infrastructure

Withdrawn

Dungowan Dam

Tamworth Regional

Current Status: Withdrawn

Development of a new dam at Dungowan and augmented delivery pipeline from the proposed dam to the junction with the pipeline from Chaffey Dam to the Calala Water Treatment Plant in the Peel Valley region of NSW.

Attachments & Resources

Notice of Exhibition (1)

Application (1)

SEARs (2)

EIS (29)

Response to Submissions (4)

Agency Advice (19)

Additional Information (1)

Submissions

Filters
Showing 1 - 20 of 62 submissions
Friends of Pilliga
Object
Coonabarabran , New South Wales
Message
Attachments
Phillip Spark
Object
Tamworth , New South Wales
Message
Attachments
Lynette Allen
Object
EAST TAMWORTH , New South Wales
Message
Received by mail on 1 December 2022.
Attachments
Australian Floodplain Association
Object
North Branch , Queensland
Message
Received by email 9 December 2022
Attachments
Helen Webb
Object
ARMIDALE , New South Wales
Message
Please find attached detailed reasons for objection to the project plus photographs of erosion of Richmond River bank adjacent to Casino following extreme rainfall event of February 2022.
Attachments
Terry Lustig
Object
KENSINGTON , New South Wales
Message
It would be irresponsible and a corruption of the Major Projects process to approve this project, which has such a low benefit-cost ratio.

The proponent needs to justify what other benefits override the economic unsuitability of this proposal, and it has not done so.

The project at its highest appears to be benefiting private interests with public money.

The economic benefits of alternative uses of these funds for Tamworth have not been adequately explored.
Hunter Environment Lobby Inc
Object
EAST MAITLAND , New South Wales
Message
HEL objects to this Development Proposal
Attachments
Leandra Martiniello
Object
TERANIA CREEK , New South Wales
Message
I object to the Dungowan dam for the following reasons:
1. The project does not meet the NSW Treasury guidelines for a cost to benefit ratio of >1.
2. The project is detrimental to the ecology of the area which it would inundate and permanently alter stream flows.
3. Industry ad governments are open that dams don't supply water through drought, a diversified water portfolio including non-rainfall dependant options such as recycled water and demand management are drought- resilient. This is very important as we move deeper into climate change.
4. The cultural heritage of the area that would be destroyed and the ongoing cultural genocide of First Nations people by the colonial regime.
5. Dams are dangerous in flood situations or if the wall fails at any time, potentially killing and causing harm to many people and property below the dam wall in the event of a failure.
Name Withheld
Object
OGUNBIL , New South Wales
Message
The costs have blown out to an insane amount for this dam. No one can confirm if its going ahead or not and how and when. The road is terrible and thin and windy and more trucks would cause danger to residents as well as considerable noise and air pollution. An extra 60 trucks each way per day the project team have stated will drive up this terrible road which currently has no reception past Dungowan. Again there is no confirmation of how this reception issue will be addressed for safety, just thoughts and hopes and dreams. Cattle crossing and tractor movements regularly occur on the road. There is rural bus pickups on the thin side of the road for young kids to get to school.
The noise and air pollution will be horrid, with residents who have paid alot of money for their quiet privacy will be impacted for years with no renumeration.
Nanette Nicholson
Object
THE CHANNON , New South Wales
Message
I am a farmer from the Northern Rivers. I am opposed to a different dam in our region - the Dunoon dam proposed by Rous County Council. Whilst not directly affected by the proposed Dungowan Dam, I am vitally interested in the subject of dams and I believe that, as citizens, we need to look after other regions as well as our own.

It is apparent that new dams have problems in common. These are generally: excessive cost for the amount of water gained, lack of drought resilience in a changing climate, destruction of Indigenous and natural heritage, damage to river health, massive emissions of methane, and social divisiveness. The Dungowan Dam appears to be no exception.

I believe that this project should not proceed as it cannot be justified on (a) the economic hardship imposed on the the current generation of taxpayers, or (b) the damage that it would cause to the cultural and environmental assets that we hold in trust for future generations.

We must move beyond dams as solutions to our water supply issues. We must also confront the fact that limits to growth have now become obvious as governments admit that our water supplies are not endless.
Tane Schmidt
Object
Wollar , New South Wales
Message
I strongly object to the Dungowan Dam project because it is a waste of NSW taxpayers money. Better options to secure Tamworth water supply into the future can be implemented for much less cost. The three large meat processing plants that use up to 50% of Tamworth's drinking water supply should be funding their own water security options or at least contributing to the costs of improving overall water security for the city.
Name Withheld
Object
WOOLLAHRA , New South Wales
Message
Background
The proposed Dungowan Dam in the Peel River catchment is estimated to cost $1.3 billion to provide only an average of an additional 7,000 ML (million litres) per year and will not secure Tamworth water supply into the future. This water would cost an estimated $70,000 per ML while much cheaper alternatives are available. It is a very expensive National Party promise, made politically, with no assessment of more beneficial, cost effective long-term solutions that will not damage the natural environment.
Key points :
1. The Environmental Impact Statement (EIS) fails to comply with the Secretary of Planning assessment requirements (SEARs). The EIS does not:
• analyse and optimise alternatives,
• assess all threatened species including those listed under Federal law,
• provide all assumptions used in modelling

2. The project will not meet its objective to provide the most cost effective or efficient option for securing Tamworth water supply.
• There is no analysis of the benefits of the proposed Tamworth Regional Council industrial water recycling project.
• The EIS fails to identify industrial use of town water supply. In Tamworth up to 50% of drinking water supply is used by three large meat processing plants.
• Options analysis was constrained by terms of reference developed in 2015 and does not reflect current best practice
• Limited options were analysed in the final business case

3. River health impacts:
• Loss of 192 km2 of high quality native fish habitat and loss of migration opportunities for Federally listed threatened Murray Cod, Silver Perch and Eel-tailed Catfish.
• Dungowan Creek is within the threatened Lowland Darling River aquatic ecological community. Offset measures for impacts on threatened native fish are not adequate.
• Dungowan Creek and Peel River have a healthy Platypus population that will be genetically separated
• The loss of flows in the Peel River will cause a failure to meet the Environmental Water Requirements of the Murray-Darling Basin Plan and impact on environmental health of the Namoi River catchment.

4. Biodiversity impacts:
• A significant area of critically endangered ecosystem and Koala habitat will be cleared, including habitat for many other endangered mammal and bird species
• The EIS fails to assess 18 threatened species known or likely to be in the area of impact including 6 threatened species protected under Federal law such as the Greater Glider and 2 critically endangered plants.

5. Aboriginal cultural heritage impacts
• Many sites of high cultural significance will be impacted
• Many sites require further research and not all of the pipeline easement was assessed
• There are no cultural flow allocations in Dungowan Creek or the Peel River

6. Cost impacts
• The project does not meet the NSW Treasury guidelines for a cost to benefit ratio of >1
• The political promise to grant construction costs does not meet current user pays policy for new water infrastructure in NSW
• Taxpayers of NSW do not want to pay for a project with no cost benefit and significant environmental damage
• The Federal Productivity Commission deemed the project poor value

7. Social impacts
• The required workforce will compete with other industries and intensify labour shortages
• Regional infrastructure spending to fix flood damaged roads should be prioritised
• Local jobs were not generated by Stage 1 pipeline project – constructed by FIFO workers
• Local concerns raised about loss of river flows and fish populations
• Loss of cultural connections and place

Rosie White
Attachments
Hans Maes
Object
KINGSWOOD , New South Wales
Message
please see attachment
Attachments
Name Withheld
Object
BELLEVUE HILL , New South Wales
Message
To whom it may concern,
I am making a submission in objection of the proposed new Dungowan Dam and pipeline. The impacts of this project on biodiversity are, in my opinion, too great. Specifically, the loss of a cumulative 88.7 ha of PCT388 and 591 is a highly significant reduction in extent of these communities, with obvious impacts to the associated TECs listed under both the BC and EPBC Act. The argument that the proposal has minimised impacts by restricting most of vegetation loss for these PCTs to edges and fragmented areas fails to recognise the ecological importance of these patches as connectivity for fauna within the project site, especially mobile fauna. Furthermore, the integrity of this vegetation means that it is still valuable as intact patches of the TECs and is quality potential habitat for fauna and flora, including threatened species, even though parts of it may occur closer to areas that have been disturbed previously.

Impacts to threatened fauna, especially the Border Thick-tailed Gecko are also significant. The impact to this species is specifically worrisome, as it is unable to disperse widely from suitable habitat and would not be able to effectively escape mortality during construction. The proposed mitigation measures are incredibly weak and do not account for specific impacts to this species. As a result, should the proposal go ahead, there would a high likelihood of localised extinction for this population should a large enough proportion of individuals occur within the project site. This would contribute to a primary key threatening process (KTP) for the species (KTP listed as 'Clearing and fragmentation of areas of rocky dry open forest and woodland for agriculture and development').

Finally, impacts to aquatic species would be immense. The construction of the new dam would exacerbate current issues with connectivity for fish from the existing dam. This would further change the hydrology of the system and cause degradation of habitat for a multitude of threatened freshwater fish as well as for the Platypus. Changes to hydrology would constitute an irreversible impact that would further threaten all these species in the local area within the catchment.

Offsets are evidently the primary mitigation strategy for the proposal, as many impacts would be unavoidable should the proposal proceed. However, as has been made clear in recent reviews of the Biodiversity Offset Strategy, offsetting is failing biodiversity in NSW. The intended offsetting pathway of 'combination of payment into the Biodiversity Charge Fund (BCF), purchase of credits from existing offset sites, and creation of new offset (stewardship) sites' as well as payment to the Fish Conservation Trust Fund (FCTF) does not fully account for the loss of biodiversity the project would cause. Specifically, payment into the BCF and FCTF does not ensure like-for-like offsetting. As the project offsetting strategy is unlikely to completely involve retiring credits in new offset sites (considering the significant impacts to large areas of BC Act listed TECs as well as habitat for a multitude of threatened species) the project is highly likely to ultimately cause a net-loss of biodiversity on a significant scale.
Thank you for receiving my submission,
Don White
Object
LAGUNA , New South Wales
Message
This submission is an objection to the project
Background
The proposed Dungowan Dam in the Peel River catchment is estimated to cost $1.3 billion to provide only an average of an additional 7,000 ML (million litres) per year and will not secure Tamworth water supply into the future. This water would cost an estimated $70,000 per ML while much cheaper alternatives are available. It is a very expensive National Party promise, made politically, with no assessment of more beneficial, cost effective long-term solutions that will not damage the natural environment.
Key points for submission:
1. The Environmental Impact Statement (EIS) fails to comply with the Secretary of Planning assessment requirements (SEARs). The EIS does not:
• analyse and optimise alternatives,
• assess all threatened species including those listed under Federal law,
• provide all assumptions used in modelling

2. The project will not meet its objective to provide the most cost effective or efficient option for securing Tamworth water supply.
• There is no analysis of the benefits of the proposed Tamworth Regional Council industrial water recycling project.
• The EIS fails to identify industrial use of town water supply. In Tamworth up to 50% of drinking water supply is used by three large meat processing plants.
• Options analysis was constrained by terms of reference developed in 2015 and does not reflect current best practice
• Limited options were analysed in the final business case

3. River health impacts:
• Loss of 192 km2 of high quality native fish habitat and loss of migration opportunities for Federally listed threatened Murray Cod, Silver Perch and Eel-tailed Catfish.
• Dungowan Creek is within the threatened Lowland Darling River aquatic ecological community. Offset measures for impacts on threatened native fish are not adequate.
• Dungowan Creek and Peel River have a healthy Platypus population that will be genetically separated
• The loss of flows in the Peel River will cause a failure to meet the Environmental Water Requirements of the Murray-Darling Basin Plan and impact on environmental health of the Namoi River catchment.

4. Biodiversity impacts:
• A significant area of critically endangered ecosystem and Koala habitat will be cleared, including habitat for many other endangered mammal and bird species
• The EIS fails to assess 18 threatened species known or likely to be in the area of impact including 6 threatened species protected under Federal law such as the Greater Glider and 2 critically endangered plants.

5. Aboriginal cultural heritage impacts
• Many sites of high cultural significance will be impacted
• Many sites require further research and not all of the pipeline easement was assessed
• There are no cultural flow allocations in Dungowan Creek or the Peel River

6. Cost impacts
• The project does not meet the NSW Treasury guidelines for a cost to benefit ratio of >1
• The political promise to grant construction costs does not meet current user pays policy for new water infrastructure in NSW
• Taxpayers of NSW do not want to pay for a project with no cost benefit and significant environmental damage
• The Federal Productivity Commission deemed the project poor value

7. Social impacts
• The required workforce will compete with other industries and intensify labour shortages
• Regional infrastructure spending to fix flood damaged roads should be prioritised
• Local jobs were not generated by Stage 1 pipeline project – constructed by FIFO workers
• Local concerns raised about loss of river flows and fish populations
• Loss of cultural connections and place

Prof Don White
Attachments
Name Withheld
Object
WEST TAMWORTH , New South Wales
Message
The project will not meet its objective to provide the most cost effective or efficient option for securing Tamworths water supply.
There are other cost effective climate independent water sources which were not assessed.
The Environmental Impact Statement fails to comply with the Secetary of Planning assessment requirements.
Loss if 192 sq km of high quality native fish habitat
Loss of koala habitat
Loss of platypus habitat
No cultural flow allocations in Dungowan Creek or the Peel River
Anne Reeves
Object
Glebe , New South Wales
Message
I submit that the EIS for the Dungowan Dam Project (The Dam Project) should NOT be approved.

A major failing is the lack of compliance with the Secretary of Planning Assessment Requirements (SEARs) to properly evaluate alternative cost-effective options to the proposal. Critically this includes ways of minimising risk to the water supply for Tamworth in extended dry periods. The Business Case Evaluation Summary by Infrastructure Australia sets out the issues: I have highlighted some of the most relevant points in the document which I intended to attach but system will not accept to my dismay

It is to be noted that the Secretary of Planning Assessment Requirements call for
(e) a description of how alternatives to and options within the project were analysed and optimised to inform the selection of the preferred alternative option. The description must contain sufficient detail to enable an understanding of why the preferred alternative was selected over other options(s) considered for achieving the project strategic objective

The EIS fails to demonstrate why The Dam Project should be selected over other cost effective long term solutions to water supply risk, including the proposed Tamworth Regional Council industrial water recycling project. These options offer significant benefits at much lower cost, in a much shorter timeframe, and with lesser environmental impact, noting that the benefits of The Dam Project proposal are not anticipated to be realised until 2030 and have very significant cost.

The Ecological Footprint
With respect to the listed fauna and flora directly affected by loss of habitat and or changed water regime as an outcome of The Dam Project, it is disappointing to read in the EIS of the dependence on yet-to-be-identified ‘offsetting’ arrangements. A number of recent reports (cf Laura Chung, SMH, 24/11/22 ‘fundamentally broken’: Biodiversity offset scheme needs overhauo, government report finds) about the failures of offsetting processes to deliver on claimed compensation outcomes demonstrate that the offsetting proposals should be scrutinized in greater depth. This is particularly important in the light of rising concern over threats to increasingly vulnerable and endangered species both directly and through loss of habitat.

Furthermore, not all aspects of the ecological footprint of The Dam Project are properly addressed, including carbon emissions during the construction period. Recent findings in court cases have recognized the relevance to present and future generations of carbon and other emissions in the assessment of fossil fuel developments because of the contribution to climate change. (egWaratah Coal Pty v Youth Alliance findings, 25/11/2022). Major construction works should similarly be assessed for their contribution to climate change including from construction materials such as concrete and from fuel dependent machinery.

As a private citizen and taxpayer I have over many years followed the emergence of environmental impact assessment processes in order to help governments get the best bang for their buck in deciding on whether to approve or reject proposed developments. The Dam Project should be rejected as seriously failing to deliver and at great cost to the taxpayer..

Anne Reeves, OAM
PO Box 591
BROADWAY, NSW 2007.

Attachment: system will not load to my dismay
Attachments
Jean Coady
Object
Tamworth , New South Wales
Message
This project will not make a significant improvement to Tamworth's water security. However, the environmental impacts would be significant. This development would impact the habitat of local platypus populations, an animal which is becoming rarer. There are also turtles and frogs which rely on us not disturbing their habitat further. Vulnerable and endangered bird species have also been seen in the vicinity.
It has not been properly costed.
There are far better and more sustainable ways to improve water security. For example, recycling sewerage water, encouraging installation of rainwater tanks and encouraging water saving gardens.
Name Withheld
Object
Calala , New South Wales
Message
State that your submission is an objection to the project. Include your name and address.
The main point for submission is that
The project will not meet its objective to provide the most cost effective or efficient option for securing Tamworths water supply.
There are other cost effective climate independent water sources which were not assessed.
The Environmental Impact Statement fails to comply with the Secetary of Planning assessment requirements.
Loss of 192 sq km of high quality native fish habitat
Loss of koala habitat
Loss of platypus habitat
No cultural flow allocations in Dungowan Creek or the Peel Rive
Penelope Milson
Object
EAST TAMWORTH , New South Wales
Message
The proposed Dungowan Dam is not the most cost effective option for securing our water and by impacting on natural habitat. poses a threat to threatened native species such as the platypus and fish.
The 2018/19 drought highlighted the capacity and willingness of Tamworth residents to respond to education and change their water use behaviors; even after Level 5 restrictions were lifted.
The 'new' Dungowan Dam is not a good investment for the tax payer when there are a number of other vastly cheaper alternatives available. With climate change, rainfall has, and will continue to decline and hotter Summers will result in massive evaporation from any above-ground water storage infrastructure such as the one proposed.
Building a big new dam is an outdated approach to shoring up water security. As we are now seeing in the energy sector, the cheaper and more sustainable model is to move away from immensely expensive, centralised infrastructure to localised independent systems.
All levels of Government should work together to design and adopt a suite of water efficiency measures that would eliminate the need for another dam for Tamworth. Examples include:
- Storm water capture and storage;
- Rain water tanks for households and local industry such as meat processors;
- Water recycling;
- Groundwater storage of storm water (eliminating evaporation);
- Increasing community education to improve water efficiency;
- Collection and re-use of domestic wastewater; and
- Support for local industry to adopt wastewater recycling, water storage and efficiency measures.
Tamworth Regional Council is already facilitating residential and industry water efficiency at the development application stage in addition to water recycling for our meat processing industries.
The public purse is under enormous strain from the pandemic. We must not be irresponsible and push projects through when they are clearly supercharged by a political agenda! I strongly oppose this project. Please use common sense.
I want to see innovation and a suite of measures that offers water security in a sustainable and fiscally responsible manner.
Thank you

Pagination

Project Details

Application Number
SSI-10046
Assessment Type
State Significant Infrastructure
Development Type
Water supply & management
Local Government Areas
Tamworth Regional

Contact Planner

Name
Benjamin Cox