Dungowan Dam

Dear Mesdames and Sirs
This is a Submission is in objection to the project Ref No SSI-10046
The TRRRA is a non-profit association whose charter is to represent to Tamworth Regional Council (TRC) and other government bodies on behalf of TRC residents on matters that affect their interests by any person, organisation or government body.
The below comments are made as a matter of public interest to assist Tamworth Regional Council in its decision making.
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 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. The proposal to build the Dungowan Dam is constrained by the terms of references set by the State and Federal Governments.
There are two major criticisms of the proposal for Dungowan Dam:
First, the Federal Government has announced on 25 October in the Budget that funding will be deferred for four years, saving $900 million on the budget over that four year period. There is no current funding for the Dam and it seems unlikely to emerge in the foreseeable future
Second, the water sharing plan, whether a new Dungowan Dam is built or not, would ideally include a section or clause, giving power to Tamworth Regional Council to require immediate arbitration, or mediation, with recourse to the Land and Environment Court and appeal from the Land and Environment Court to the Supreme Court of NSW if there was failure to agree between Water NSW and/or its successors and or the Minister for Water and or their successors, if Tamworth Regional Council determined that releases were excessive. That section or clause should also require that all releases from Chaffey Dam and/or Dungowan Dam shall cease except for the minimum environmental flows and the Tamworth water supply during the continuance of arbitration, mediation or appeal to the Courts. A repetition of the management of Chaffey Dam that occurred between 2017 and 2020 in the Peel Valley cannot be countenanced.
We regard the EIS as being competently prepared by the Water NSW personnel within the terms of reference that they were provide with, but however make the following 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 potable 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 summary 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 political promise that all construction costs will be granted does not meet current user pays policy for new water infrastructure in NSW and increased water costs will be imposed by IPART;
 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 – it was constructed by FIFO workers;
 Local concerns raised about loss of river flows and fish populations;
 Loss of cultural connections and place.

Yours sincerely,
Tamworth Regional Residents and Ratepayers Association

Peel Valley Water Users Association provides the following submission. We support the project with the recognition that the current irrigation allocations are not impacted.

Please see the submissions of the Gomeroi Applicant in the attachment titled 'Gomeroi Applicant submissions'.

I am making a comment

Dungowan Dam is located on Dungowan Creek near Tamworth NSW. The Dam currently supplies water to Tamworth via a 55-kilometre pipeline. The Dungowan Dam Replacement project will see the existing dam replaced with a larger structure. construction of a new dam wall 3.5 kilometres downstream of the current wall. The proposal will
decommission the existing Dungowan Dam, and construction of a 55-kilometre large diameter pipeline between Dungowan Dam and the Callala Water Treatment Plant. 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. This will not secure Tamworth's water supply into the future. This water would cost an estimated $70,000 per ML. Many cheaper alternatives are available. It is a very expensive National Party political promise with no assessment of more beneficial, cost effective long-term solutions that will not damage the natural environment. The project lies within Barnaby Joyce's seat and he hopes to make political capital out of this project. I hope the assessors will look at political donations in relation to this.
The Dungowan Dam project has been promised $675 million from state and federal governments. In light of the coming NSW state election in March 2022, this project will not attract favorable support from tax payers, when the details are known.
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. An examination of the invoices that the meat processing plants pay for their use of the water must be included. Political donations may be relevant here.
 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, There is evidence from University of NSW that platypus populations separated by a dam wall become inbred due to isolation. This weakens their genetic ability to resist diseases. Our platypus population is declining and is already on the endangered list.
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 two critically endangered plants.
5. Aboriginal cultural heritage impacts
 Many sites of high cultural significance will be impacted. The Aboriginal community has not been adequately consulted.
 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

Please see attachment.

See attached document

I object to the NSW Government committing $600 million to the Dungowan Dam proposal because it is not the most efficient investment for taxpayers of NSW, will not meet the project objectives into the future and will further damage the health of Murray-Darling Basin river systems.
The project assessment demonstrates that many threatened species will be impacted, both aquatic and terrestrial. The proposed offsets will not replace important loss of sensitive riverine habitat for threatened native fish and platypus. It is unacceptable for Koala habitat to be destroyed along with bushland that supports other iconic threatened species such as the Greater Glider.
Tamworth water security can be improved through a combination of non-rainfall dependent infrastructure options and rules based changes to water management in the Peel Valley. Dungowan Dam should not be deemed critical state significant infrastructure – because it does not benefit most people, including Tamworth ratepayers.
While both Chaffey Dam and the current Dungowan Dam are full, thus securing water supply for the next few years, there is an opportunity to improve water management and decision-making protocols to improve drought security while other more beneficial projects are funded and implemented.

See attached submission

Submission attached

Objections in attached submission

I OBJECT to the proposal because
1 The environmental impact statement is inadequate
2 The proposal is not the most efficient option to achieve the stated objective
3. There would be serious and irreversible impacts on the health of the river, biodiversity, and Aboriginal cultural heritage.
4. The project is of poor value and does not meet the NSW Treasury Guidelines for a positive benefit/cost ratio
5. The adverse social impacts are unacceptable.

I object to the proposed new Dungowan Dam.
I object due to many reasons: climate change will make the dam ineffective, the dam does not deliver on its strategic objectives, its impact on local wildlife, and the massive cost.
1. As rainfall patterns become more and more disrupted due to Climate Change, non-rainfall dependent water solutions are needed. Having a dam does not solve water issues if there is less rain falling. Climate Change should be factored into the case around this dam, and I do not believe that it has adequately been so. There are also other options available that are more reliable and save more water – such as recycling. Tamworth Regional Council and local businesses have said that they support industrial water recycling. There are also projects that are going ahead in this area even if the dam is approved, indicating that business experts do not believe that the dam will be adequate.
2. The dam does not deliver on its strategic objective of providing enough water to Tamworth residents. This is proved in The Summary Business Case which states this, and which also states that additional options will be identified in the Namoi Regional Water Strategy. This complete failure of one of its objectives shows that the project should not go ahead.
3. Dams are often the cause of loss of habitat for native animal, fishes, and plant species. There will be a loss of 192 sq kms of habitat that is suitable for native fish species if this dam is built. The dam would also affect platypus habitat by changing Terrible Billy Creek. The area around the dam is important koala habitat, and the ongoing construction as well as loss of trees will negatively affect them. Koalas are now listed as endangered, meaning that all their habitat is extremely important and displacing them is extremely irresponsible.
4. The proposed Dungowan Dam cost is just too high to be conscionable. The return on investment ratio, provided by The Summary Business Case, is a mere 0.09. It would be fiscally irresponsible to proceed with a project that does not give good value for money to Australians. There is also the issue of cost recoupment, which will of course fall to both ratepayers and tax payers. Tax payers across Australia should not be forced to pay for this dam that does not stack up financially, and tax payers in NSW will be paying for it twice due to the cost split between the Federal and NSW Governments. Tamworth ratepayers could also see a significant increase in their payments if this dam goes ahead. There are cheaper projects that will be ready within 4 years already being approved by council and industry that will keep costs down for both tax and rate payers.

I strongly object to the Dungowan Dam & Pipeline Project.
This expensive project will not secure Tamworth’s water supply.
The EIS fails to properly assess alternative measures which would be more cost effective. The most effective of these is town water recycling. The plan put forward by Tamworth Regional Council to recycle the 50% of the town’s water which is being used in three meat processing plants. Other measures which all towns need to adopt are household water saving measures. Providing grants to residents to purchase water saving products would contribute to protecting the town water supply.
The dam project is estimated to cost $1.3 billion. Regional roads have suffered serious damage during the floods and will require large amounts of money to repair. Regional Councils do not have sufficient funds to repair the roads. My view is that this project should be cancelled and instead water recycling and road repair be given the funds they need.
I strongly object to an additional 192 km2 of high-quality native fish habitat being destroyed. The dam would also block the migration of fish such as murray cod, silver perch and eel-tailed catfish.
This dam will have detrimental impacts on the healthy platypus population by isolating platypus in Dungowan Creek from those in the Peel River. Isolation and reduction in size of populations is knows to reduce genetic vigour within populations.
The impacts of the proposal on nationally listed threatened species have not been adequately assessed. The EIS fails to assess 18 threatened species which are known to occur or may be found the area. The reservoir would drown substantial areas of native vegetation including threatened ecological communities.
I also object to the loss of Aboriginal cultural heritage which has been inadequately assessed, for example, not all of the pipeline route has been surveyed.
I find it interesting that the Federal Productivity Commission considered this project to have poor value.
Across the world dams are being removed to restore the health of rivers. This dam proposal is extremely expensive and will not achieve its stated aims of providing a secure water supply for Tamworth. Its greenhouse gas emissions need to be recalculated in view of current knowledge of climate impacts.
Please record my submission as an objection

Submission of objection attached

Inland Rivers Network objection to the project is provided in the attached detailed submission

This is to submit for your consideration a strong objection to the proposed Dungowan Dam on the Peel River catchment. The objection to the Dungowan Dam proposal is based on the following reasons:

1. the proposed project will not provide the most cost effective nor efficient option for securing Tamworth's water supply. Only limited options were analysed in the final business case of the Dungowan Dam proposal. It excluded, for example, consideration or analysis of the significant benefits of the proposed Tamworth Regional Council industrial water recycling project. Water from the proposed dam would cost an estimated $70,000 per ML which compares unfavourably to much cheaper alternatives;

2. the Environmental Impact Statement (EIS) for the proposed dam fails to comply with the Secretary of Planning assessment requirements (SEARs). The EIS does not analyse or properly examine alternative means of water supply. It fails to list all threatened species or to assess the impacts on all species (including those listed under Federal law);

3. the project proposal and EIS fail to acknowledge the substantial component of town water supplies that will be diverted to industrial purposes. Up to 50% of Tamworth's drinking water supply is used by three large meat processing plants;

4. there will be significantly adverse, long term impacts on the health of the key Peel River ecosystem. Very importantly, these negative impacts will include, inter alia:

a) the disappearance of 192 km2 of high quality native fish habitat and forfeiture of key migration corridors for native fish. This will impact seriously on species listed Federally as "Threatened"; i.e. Murray Cod, Silver Perch and Eel-tailed Catfish;

b) in the project proposal, the measures suggested for offsetting/ameliorating the adverse impacts on threatened native fish are inadequate; and

c) the currently healthy populations of platypus in Dungowan Creek and Peel River will suffer due to their physical and genetic separation if the dam goes ahead.

Please do not allow vested commercial and political interests to push through this poorly considered, excessively costly and environmentally damaging proposal.

Please find submission attached

The attached submission is self explanatory.

Regards Peter Bagshaw

I object the proposed Dungowan Dam.
The environmental Impact Statement is not consistent with the SEARS advice as it does not:
• adequately not assess threatened species.
• adequately scrutinise alternatives
How the EIS does not comply with Threatened Species assessment:
One SEARS requirement is “The level of assessment of likely impacts should be commensurate with the significance, degree or extent of impact within the context of the proposed location and surrounding environment”. While the EIS acknowledges there are significant wildlife and ecological communities in the region and a number of important species and communities are acknowledged are being significantly affected by the proposed dam. Namely Box Gum Woodland, the Koala, Spotted-tail Quoll, Squirrel glider, Platypus, Border Thick-tailed Gecko, Regent Honey Eater, Swift Parrot and Platypus. The EIS has overlooked several others recorded in the area including:
• The Booroolong Frog, listed as endangered in NSW and under the EPBC act.
• The masked owl and Sooty Owl are vulnerable in NSW and are both known in the area.
• The Yellow Tailed Black Cockatoo, is known in the catchment.
• There are also records of Turquoise Parrot, Black Chinned Honeyeater and Flame Robin in the area.
• The Yellow Bellied Sheathtail Bat is listed as vulnerable in NSW and is known in the area, as is the Greater Broad Nosed Bat.
These records could have been easily found and considered by drawing on the Atlas of Living Australia. Likewise several listed plants: Euphrasia arguta (endangered in NSW, critically endangered BPBC), Dichanthium setosum (bluegrass) vulnerable and Asterolasia beckersii (Dungowan starbush) endangered in NSW and criticially endangered BPBC) are all likely to be found in the area but have not been considered.
Thus the EIS has also inadequately met the SEARS requirement of: Assessment and reporting of terrestrial biodiversity values and the likely biodiversity impacts of the project in accordance with the Biodiversity Conservation Act 2016 and Biodiversity Conservation Regulation 2017,
How the EIS does not comply with assessment of alternatives:
A SEARs requirement is that the proponent must include in the EIS why the preferred alterative was selected over other options, as well as a description of how alternatives were assessed. Specifically:
• This aspect has been covered by other agencies and it is clear much cheaper solutions to Tamworth’s water security exist. A review of the proposed dam in August by Infrastructure Australia found that the costs (1.3 billion dollars) far outweighed the benefits. The proposals economic benefits were said to be very low and ensuring that Tamworth’s full allocation of water from Chaffy Dam was a vastly lower cost solution. Infrastructure Australia said “Based on our assessment, the Increased Urban Reserve option (Chaffey Dam), which is also considered in the business case, appears to be a feasible, lower cost solution that addresses the problem and warrants further detailed consideration” and “water security risk is more efficiently addressed by options that do not involve the development of new capacity.” This has been both overlooked and not considered in the document
• Alternatives to a dam, like using more of Tamworth’s 16.4 gigalitre urban licence from Chaffy Dam has been rejected. Measures such as water recycling, saving rainwater, saving storm water or purchasing redundant water licences were not even considered. This is despite one stated objective being “to provide efficient and affordable bulk water supplies to Tamworth”.
• Additionally to the point above Tamworth currently only accesses 70% of its urban water allocation from Chaffy Dam the remaining 30% goes to irrigators in the Peel Valley. A simpler process that would be less costly would be to revise the water sharing plan to ensure that the city of Tamworth receives its full entitlement.