Warragamba Dam Raising

I strongly oppose the proposal to raise Warragamba Dam due to the project’s potential negative environmental impacts, including to the Blue Mountains World Heritage Area. In particular, increasing the footprint of the dam will unacceptably increase the extinction risk of the critically endangered Regent Honeyeater by removing critical habitat. Such habitat cannot be replaced through biodiversity offsets due to the ecology and life history of the species. Protecting habitat within the proposed Warragamba Dam footprint is therefore essential for the conservation of this species and should be a high priority for the NSW Government, especially in the wake of the environmental catastrophe that was the 2019/20 bushfires. As these bushfires affected up to half of the already fragmented habitat for Regent Honeyeaters, any and all further threats to this species should be avoided, including the removal of unburnt habitat in the proposed Warragamba Dam footprint.

I oppose the project as a bird lover as is my young family and this day and age, we should act responsibly and protect and nurture what is remaining,
not risk to destroy it. There are only a handful of contemporary breeding sites for Regent Honeyeater and during the assessment of the project a total of twenty one (21) Regent Honeyeaters, including active nests, were recorded within the impact area. Any breeding habitat is considered habitat critical for survival of the species under the National Recovery Plan for Regent Honeyeater and it states “It is essential that the highest level of protection is provided to these areas and that enhancement and protection measures target these productive sites”. The destruction or degradation of a contemporary breeding site for Regent Honeyeaters would have dire consequences for the species as a whole. The destruction and degradation of breeding habitat for Regent Honeyeaters is incongruous with the time and money that the Federal and NSW Governments have invested into the recovery program, including the Regent Honeyeater Captive Breeding and Release program. It is unacceptable and inconsistent with the National Recovery Plan for any avoidable loss or degradation of breeding habitat to occur.  I strongly oppose the Project’s offset strategy for the Regent Honeyeater. Offsets are rarely an appropriate response to proposed biodiversity loss and especially for critical habitat for the survival of a species, in this case breeding habitat for the Critically Endangered Regent Honeyeater. There is no evidence that breeding habitat for Regent Honeyeaters can be successfully offset and any offsets would be unlikely to provide direct benefits for both the local affected population and the species. Please consider these points and the birds dire situation. Thankyou, Joel

Submission Against Raising the Warragamba Dam wall

As an active bushwalker and member of a two bushwalking clubs with 700+ members combined, I hold serious concerns regarding the proposal to raise Warragamba Dam Wall. The areas that will be inundated will have an enormous detrimental impact on the biodiversity value of the Blue Mountains.

My concerns include:
• The project threatens 48 threatened species found in the 4,700 hectares to be inundated, including the critically endangered Regent honeyeater (Australia’s rarest bird) and the Camden White Gum. ‘
• It will destroy Sydney’s only remaining wild river and wilderness streams, including the iconic Kowmung River.
• The project will also undermine the ‘Outstanding Universal Values’ which led to the park being inscribed as a World Heritage Site thus threatening its status as a World Heritage site.
• The Warragamba Dam wall raising will not prevent flooding as Sydney flooding is fed by multiple catchments. It will however promote more development in risky areas, effectively increasing the number of people exposed to high flood risk.
• Nearly half the floodwaters that have historically impacted the floodplain come from rivers outside the Warragamba catchment.
• Raising the Warragamba Dam wall will inflict terrible damage on the environmental and cultural values of the catchment. It will decimate 5,700 hectares of National Parks, 1,300 hectares of World Heritage Area, more than 60 kilometres of wilderness rivers and thousands of Aboriginal sites and places of cultural significance.
• What we need is better urban planning, not short-sighted expensive capital projects that will only encourage development in flood prone areas.

I believe in the preservation of our native avifauna, fauna and flora and am concerned about the proposal to raise the walls of the Warragamba Dam.
The Wollondilly Shire Council has unanimously reasserted, only last week, its strong opposition to the raising of the Warragamba Dam wall and was critical of inadequacies in the Environmental Impact Statement (EIS) presented for public comment in September.
The draft EIS noted potential impacts to the Blue Mountains World Heritage Area and breeding habitats, especially of the Critically Endangered Regent Honeyeater, which “cannot be avoided or minimised”.
The destruction of these habitats, which are critical for the species survival, is in direct contrast with the investment made by the New South Wales Government into recovery programs such as the Regent Honeyeater Capture Breeding and Release Program.
There is also no evidence that the proposed offset strategy for the Regent Honeyeater would be successfully implemented. Loss of their critical breeding habitat would not only seriously impact the remaining population of this endangered bird (endemic to southeastern Australia), but would also impact negatively on many other species sharing this habitat and interacting with the Regent Honeyeater.
In keeping with the objectives of the “National Recovery Plan for the Regent Honeyeater” by the Commonwealth of Australia (2016), and with as few as 350 Regent Honeyeaters remaining in the wild, this nectar feeding bird’s habitat should be enhanced and protected by increasing its quality and area, and not be degraded or destroyed.
Thank you for considering my view

WaterNSW, an agency of the NSW Government, has released an Environmental Impact Statement (EIS) proposing to raise the wall of the Warragamba Dam. Their justification for the project is that raising the dam wall is required to reduce the risk of future flooding to residents and businesses across Western Sydney. This is simply not the case.
The project rationale is deeply flawed, with nearly half the floodwaters that have historically impacted the floodplain coming from rivers outside the Warragamba catchment.
Raising the dam wall will encourage further ill-advised development in vulnerable areas without providing any guarantee of future protection.
What we need is better urban planning, not short-sighted fixes that will only encourage development in flood prone areas.
Intolerable environmental impacts

The World Heritage listed Blue Mountains National Parks have been given the highest possible international status and protection in recognition of the area’s extraordinary biodiversity and ecological integrity.
The Commonwealth and NSW Governments made a commitment to future generations to protect the Greater Blue Mountains World Heritage Area forever. This is the last place that any government should sacrifice to enable further expansion of floodplain development.
Raising the Warragamba Dam wall will inflict terrible damage on the environmental and cultural values of the catchment. It will decimate 5,700 hectares of National Parks, 1,300 hectares of World Heritage Area, more than 60 kilometres of wilderness rivers and thousands of Aboriginal sites and places of cultural significance. The area that will be destroyed contains some of the best remaining grassy woodland ecosystem in NSW, complete with healthy populations of dingo, quoll, woodland birds and many other native species.
The rising water will drive threatened species into extinction, including NSW’s rarest bird, the Regent Honeyeater.
Australia is a signatory to the World Heritage Convention and required to do everything in its powers to protect the ecological integrity of the Greater Blue Mountains World Heritage Area. This proposal falls far short of that obligation, and if the EIS is approved it will confirm our growing international reputation as environmental vandals.
No consent has been obtained from the Gundungurra Traditional Owners for the work that will significantly impact their cultural heritage.
Totally inadequate environmental impact assessment

The purpose of raising the dam wall is to hold water at a level up to 17 metres higher than the present dam. Even if the water is only held at these elevated levels for a few months, the unavoidable reality is that the habitats, flora, fauna, cultural sites and soils within the inundation zone will be devastated.
Despite the EIS having been in preparation for more than 5 years, the environmental and cultural surveys on which it relies are woefully inadequate. The EIS relies upon biodiversity and cultural surveys conducted before the unprecedented wildfires of 2019/20, which burnt 81% of the Greater Blue Mountains. Those fires changed the face of the Blue Mountains and drove many species to the brink of local extinction. It is not sufficient to do a ‘desktop’ analysis of the impacts of the fires on the project area, a new survey is needed.
The Commonwealth Department of Environment and the International Council on Monuments and Sites have both pointed out very serious failings in the assessment of the impact on the cultural heritage of the Gundungurra traditional owners.
The proposal relies upon the payment of biodiversity offsets to mitigate the irreparable environmental damage to the biodiversity of this unique and internationally significant area.
Calculations based on the NSW Government’s own biodiversity laws and offsets trading scheme suggests that the total cost of biodiversity offsets will be around $2 billion.
Shockingly, rather than disclose the true cost to NSW citizens and taxpayers, the EIS does not calculate the biodiversity offset liability for the project.
The wrong time and the wrong place

NSW is still reeling from the 2019/20 mega-fires, record levels of land clearing and a species extinction crisis. If there is any time and any place where the protection of nature must be prioritised, surely it is in now in World Heritage listed National Parks?
Has the NSW Government learnt nothing from the desecration of Juunkan Gorge about the importance of protecting Aboriginal cultural heritage?
Aboriginal cultural heritage, National Parks, World Heritage and threatened species need protection, not destruction.

I am an Environmental Scientist and I strongly oppose the proposal to raise Warragamba Dam due to the project’s unacceptable potential impacts on the environment including to the Blue Mountains World Heritage Area and threatened species.

Scientific research does not support this project for many reasons including:
- Upstream inundation caused by this project would also endanger already threatened plant and animal species, destroy Sydney’s last wild river - the mighty Kowmung - and risk the Blue Mountains World Heritage Listing itself.
-Regent Honeyeaters are one of Australia’s most threatened species, with a current population estimate of only 350 birds. If this amazing bird is going to survive and recover, we must protect the precious places where they breed and raise their young.
The Burragorang Valley, located within the Warragamba Dam-raising footprint, was one of only three areas used for breeding across all of NSW in 2017, and is considered a key site for the conservation of the Regent Honeyeater into the future. The vast majority of the few remaining Regent Honeyeaters now breed around the edges of the Greater Blue Mountains and we must protect every breeding site, especially those situated inside a World Heritage-listed National Park.
The draft EIS concludes that the project poses potential significant impacts to contemporary breeding habitat for the Regent Honeyeater that “cannot be avoided or minimised.”
Any breeding habitat is considered habitat critical for survival of the species under the National Recovery Plan for Regent Honeyeater and it states “It is essential that the highest level of protection is provided to these areas and that enhancement and protection measures target these productive sites”.
The destruction or degradation of a contemporary breeding site for Regent Honeyeaters would have dire consequences for the species as a whole.
It is unacceptable and inconsistent with the National Recovery Plan for any avoidable loss or degradation of breeding habitat to occur.
I strongly oppose the Project’s offset strategy for the Regent Honeyeater.
Offsets are rarely an appropriate response to proposed biodiversity loss and especially for critical habitat for the survival of a species, in this case breeding habitat for the Critically Endangered Regent Honeyeater.
There is no evidence that breeding habitat for Regent Honeyeaters can be successfully offset and any offsets would be unlikely to provide direct benefits for both the local affected population and the species.
-There are 80 known species of threatened flora and fauna at and upstream of Warragamba Dam. The inundation of national parkland and part of the Greater Blue Mountains World Heritage Area, for at least two weeks at a time, will have significant detrimental impacts on threatened species. This includes two critically endangered ecological communities being the White Box-Yellow Box-Blakely’s Red Gum Grassy Woodland and Derived Native Grassland, and the Shale Sandstone Transition Forest of the Sydney Basin Bioregion. Threatened animals that will be impacted include the endangered Macquarie Perch.
- There is a very real threat that raising the Warragamba Dam wall may result in the de-listing of the Greater Blue Mountains from the UNESCO World Heritage List. This is because it will impact upon the values for which the park was listed. The Australia International Council on Monuments and Sites, an Australian Committee for the body which advises UNESCO, has warned of the potential for the Blue Mountains to be placed on the World Heritage in Danger List if the dam raising were to proceed.
- It was never intended to be a flood mitigation dam. Its purpose to provide 80 per cent of Sydney’s drinking supply.
- Thousands of sites of Aboriginal importance are also in the development’s path.
- “We’ve got to trade off some environmental impact to be able to protect properties downstream,” Mr Ayres says. Floods are a natural occurence amd a flood plain is a flood plain. Mr Ayres argues the government the inundation is temporary and only occurs during big floods, despite the ecologists saying the impacts would be permanent.
- That assumed the project would cost $690 million. But documents released under FOI laws suggest the construction could cost as much as $1.6 billion. And the leaked draft EIS documents show compensation for environmental damage could add nearly another $3 billion. This indicates a non-finanacially viable project and an unwise 'investment' of tax payers money.
- Jamie Pittock, a water management expert at ANU, says the most important thing to do is to stop development in the floodplain.“I would really rather see that money invested in a permanent safety solution of moving people out of harm’s way,” Professor Pittock says.
- Flood experts, the International World Heritage Committee, and even NSW Government members continue to raise significant questions about the need for this project.

I completely oppose the proposal to raise Warragamba Dam.

I have worked on the water and in the catchment areas surrounding Lake Burragorang / Warragamba Dam in various capacities since 2006. I have directly observed the quality of the remnant vegetation and habitat that is protected within the drinking water catchment area to be significant. Raising the dam wall will irrevocably destroy this habitat. As such I strongly oppose the proposal to raise Warragamba Dam due to the project’s unacceptable potential impacts on the environment including to the Blue Mountains World Heritage Area and threatened species.

I note that the area is habitat for the Regent Honeyeater, which is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild, and that under the National Recovery Plan for Regent Honeyeater it states “It is essential that the highest level of protection is provided to these areas and that enhancement and protection measures target these productive sites”.

Furthermore I strongly oppose the Project’s offset strategy for the Regent Honeyeater. Offsets are rarely an appropriate response to proposed biodiversity loss and especially for critical habitat for the survival of a species, in this case breeding habitat for the Critically Endangered Regent Honeyeater. There is no evidence that breeding habitat for Regent Honeyeaters can be successfully offset and any offsets would be unlikely to provide direct benefits for both the local affected population and the species.

I work in the water industry and am well aware of the need to secure water supply, however there are more efficient and effective ways to do this without unnecessary habitat destruction of the Lake Burragorang / Warragamba Dam area, including expanding Sydney's Desalination capacity and increasing utilisation of recycled water. There are vast amounts of treated waste water released into the Hawkesbury-Nepean catchment and offshore that could be used, with increased treatment and network enhancement, for irrigation/industrial purposes or even supplementing the drinking water supply.

In summary raising the dam wall is not just entirely inappropriate, and significantly destructive to the environment, it is also a completely unnecessary waste of significant amounts of taxpayer money.

Raising the Warragamba Dam wall will cause intolerable environmental impacts. It will inflict terrible damage on the environmental and cultural values of the catchment. It will decimate 5,700 hectares of National Parks, 1,300 hectares of World Heritage Area, more than 60 kilometres of wilderness rivers and thousands of Aboriginal sites and places of cultural significance. The area that will be destroyed contains some of the best remaining grassy woodland ecosystem in NSW, complete with healthy populations of dingo, quoll, woodland birds and many other native species.

The rising water will drive threatened species into extinction, including NSW’s rarest bird, the Regent Honeyeater.
Australia is a signatory to the World Heritage Convention and required to do everything in its powers to protect the ecological integrity of the Greater Blue Mountains World Heritage Area. This proposal falls far short of that obligation, and if the EIS is approved it will confirm our growing international reputation as environmental vandals.

Further, no consent has been obtained from the Gundungurra Traditional Owners for the work that will significantly impact their cultural heritage.

The whole concept of raising Warragamba Dam to enable more development on a floodplain and so wipe out fragile ecology and Aboriginal heritage in a World Heritage area is fundamentally wrong however you look at it.

The NSW government pretends that the whole project is to protect current residents from flooding. This is simply untrue as most floodwater arrives from outside the Warragamba catchment'

The Blue Mountains National Park has been endowed with World Heritage status and protection for vitally important reasons. It is a place of spectacular beauty, natural wonder and amazing biodiversity. To inundate a vast area of this special place with water would not just be be a crime against the people of NSW and Australia but against global citizenry. It would also dishonour the Federal and NSW Government's written pledge to conserve and protect the area for posterity.

Raising the dam wall would decimate 5,700 hectares of National Parks, 1,300 hectares of World Heritage Area, more than 60 kilometres of wilderness rivers and thousands of Aboriginal sites and places of cultural significance. The area that will be destroyed contains some of the best remaining grassy woodland ecosystem in NSW, complete with healthy populations of dingo, quoll, woodland birds and many other native species. It is a priceless natural ark . Raising the water levels will drive threatened species into extinction, including NSW’s rarest bird, the Regent Honeyeater. What kind of government would do this for no valid reason?

The current NSW government sadly has a shocking track record on environmental and cultural stewardship. When even our iconic koalas are assessed to become extinct by 2050 then something is seriously wrong with policy and processes. The COP 15 Conference in China is currently assessing the shocking damage that is being wrought on global biodiversity and emphasising the need for better conservation management. They will look at NSW's record on logging, land clearing water extraction, species extinction and disregard for World Heritage with a very critical eye.

Do not proceed with this harmful proposal.

I wish to object to the raising of the Warragamba Dam wall and, in particular, the Environmental Impact Statement (EIS) currently on exhibition.

I live in the Blue Mountains and spend a lot of time bushwalking with family and friends. This is a beautiful and unique environment, as recognized by its World Heritage status. It is absolutely scandalous that the NSW Government is even considering raising the dam wall given the extremely damaging impact this development would have upon the natural and cultural values of the Blue Mountains World Heritage Area. The World Heritage status of the Blue Mountains also means that Australia has obligations under the World Heritage Convention. Among other things, this means that Australia ‘should ensure that…[the site’s] Outstanding Universal Value, including the conditions of integrity and/or authenticity at the time of inscription, are sustained or enhanced over time’ (Operational Guidelines for the Implementation of the World Heritage Convention, para. 96). The Warragamba Dam Raising Project and the EIS on exhibition manifestly fail to ensure this.

I am concerned that the environmental and cultural assessments in the EIS were developed by SMEC Engineering, a firm known to have abused Indigenous rights, and which was recently debarred from accessing World Bank finance due to its lack of corporate integrity. It is also inexcusable that only 27% of the impact area was assessed for Aboriginal Cultural Heritage. Local indigenous groups are aware of many more highly significant cultural sites within the area, which will be negatively impacted by the raising of the dam wall. Threatened species surveys also fail to meet the minimum requirements set out in the guidelines. No expert reports were sought to supplement the inadequate field surveys. It is simply not possible for an informed decision to be made regarding the environmental and cultural impacts of the proposed raising of the dam wall on the basis of this poorly executed EIS.

The EIS also fails to model the impact of the raising of the dam wall on flooding and economic outcomes downstream. While the raising of the dam wall will presumably give the green light to developers to build residential properties on the western Sydney floodplains, there is no clear evidence that residents of these properties (and existing housing) will not be exposed to unacceptable flood risks. Some 45% of floodwaters affecting this area originate outside of the Warragamba Dam catchment so will be unaffected by any raising of the dam wall.

Further residential development on the western Sydney floodplains benefits only one interest group—developers. It comes at the high price of exposing western Sydney communities to unacceptable risks and destroying irreplaceable natural and cultural values in the Blue Mountains World Heritage Area. I strongly urge the Government not to rely on this flawed EIS. It would be both unethical and politically disastrous for the NSW Government to proceed with this project, which demonstrates such blatant disregard for both human and ecological communities up- and down-stream from Warragamba.

I am objecting to the proposed raising of the Warragamba Dam for the following reasons:
1. Raising the dam wall to reduce the risk of future flooding is a poor reason. Long term planning accounting for climate change should have prevented assets being built on land vulnerable to flooding in the first place. Raising the dam is just a short term solution.
2. The project has an unacceptable impact of a world heritage listed environment and endangered species (Regent Honeyeater). If you are not going to protect these areas what are you going to protect?

I have been a permanent resident of the Blue Mountains since 2005 and prior to that visited every weekend since 1985. Since moving here I have been active in protecting and regenerating the local environment including bushcare , propagation of native plants and participation in the Blue Mountains World Heritage Institute Ecomonitoring project.
I oppose the Warragamba Dam Raising Project for the following reasons:
- it will damage the World Heritage Area and adjoining areas, including damage to the environment, and cultural features.
- Gundungurra Traditional Owners have not given Free, Prior and Informed Consent for the Dam proposal to proceed.
- it will not provide the flood protection promised as significant flows also come from the Nepean, Grose and Colo catchments.
- the EIS is incomplete as it fails to properly assess damage to the environment , including endangered species and to the many cultural sites affected by the proposal, and also fails to evaluate alternative flood mitigation options.
- the cost of the project would be better spent improving the resilience of the flood prone area
- the project will be used to justify further development of the flood prone area which will lead to future problems as it can never be fully protected from flooding.

I lived in the Blue Mountains for 35 years 1980- 2015 and bushwalked regularly in all parts of the Mountains. I have visited the Warragamba Dam on several occasions and am familiar with developments that have happened in the surrounding areas over the past three decades. I was involved with organisations in Penrith such as Penrith Visual and Performing Arts (board member) and I have friends who live in areas likely to be affected by the proposal.

I am deeply concerned about shortcomings in the environmental and cultural assessments made for the project, particularly the failure to substantiate benefits claimed for the raising of the wall, and the inadequacy of the assessment of impact of raising the wall on Aboriginal cultural heritage and threatened species.

As a passionate supporter of the unique Blue Mountains environment, I shared the universal pleasure when the area was granted World Heritage status. But much of this proposal is in flagrant breach of Australia’s obligations arising from the recognition.

Were this project to proceed, a massive part of the World Heritage Area would potentially be inundated, causing irreparable damage to endangered species, threatened communities of endemic plants and a pristine wild river, as well as many hundreds of identified Aboriginal cultural heritage sites, without adequate community consultation.
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At this critical time in the world’s efforts to mitigate the effects of catastrophic climate change, this proposal cannot be justified on any grounds. We have no way of knowing how the conditions that gave rise to it in the first place (such as the demand for continued development on the Cumberland Plain) may change radically in the future and confirm it as totally unnecessary and infinitely destructive.

It must not proceed.

I live in southern NSW but within 100km of the Warragamba area. I have a strong interest in the natural world and in the cultural heritage of indigenous people. As a concerned member of the public, I wish to object to the proposal to raise the Warragamba Dam.

My objection is based on the project’s unacceptable potential impacts on the environment including to the Blue Mountains World Heritage Area, which is part of the heritage of all people in the world now and of future generations, not something which a state government can damage for short term gain. The proposed increase to the area of water storage will severely impact important cultural sites for local indigenous people, as well as threatened species, for example, the critically endangered Regent Honeyeater.

In regards to the latter, the draft EIS concludes that the project poses potential significant impacts to contemporary breeding habitat for the Regent Honeyeater that “cannot be avoided or minimised.” The destruction or degradation of a contemporary breeding site for Regent Honeyeaters would have dire consequences for the species as a whole, with the area impacted being used by a significant number of birds of a species of which only as many as 350 individuals remain in the wild.

I object to the Project’s offset strategy for the Regent Honeyeater, since this kind of strategy is rarely an appropriate response to proposed biodiversity loss and especially to critical habitat for the survival of a species. Besides, there is no evidence that breeding habitat for Regent Honeyeaters can be successfully offset and any offsets would be unlikely to provide direct benefits for both the local affected population and the species.

For the above reasons I strongly oppose the project going ahead.

I strongly oppose the proposal to raise Warragamba Dam due to the project’s unacceptable potential impacts on the environment including to the Blue Mountains World Heritage Area and threatened species.

I have walked extensively in the blue mountains wilderness area over the past 30 years. The area is of outstanding natural beauty & the river valleys are particularly spectacular. The Kowmung River is unique and irreplaceable. All of this has been recognized by giving the area World Heritage status & recognition. Raising the dam wall is going to mean sooner or later that vast areas of the wilderness will be inundated by flood waters & the flora & fauna destroyed. It's like drilling the Barrier Reef for oil, unthinkable.
Find another way to protect the floodplain downstream, or better still don't allow any more development on it. It's a flood plain for the obvious reason that it's going to be flooded.

I strongly object to the raising of Warragamba Dam due to the disastrous impact this project would have on critical breeding habitat for the critically endangered Regent Honeyeater. This species is on the brink of extinction and the proposal is inconsistent with the National Recovery Plan for any avoidable loss or degradation of breeding habitat to occur. It has been concluded in the draft Environmental Impact Statement that it is not possible to "avoid or minimise" impact to contemporary breeding habitat for the Regent Honeyeater, therefore pushing a species with fewer than 350 individuals left to their demise. This is not acceptable and completely undermines the time and monetary investment that the Federal and NSW Governments have invested in the recovery program, including the Regent Honeyeater Captive Breeding and Release program.

Taken from BirdLife Australia, modelling projects up to 50% of contemporary Regent Honeyeater breeding and foraging habitat has been decimated by fire in the 2019/2020 bushfires which ravaged our country. Causing unavoidable damage to the remaining unburnt breeding habitat is abhorrent and should be conserved as the highest priority. Any breeding habitat is considered habitat critical for survival of the species under the National Recovery Plan for Regent Honeyeater and it states “It is essential that the highest level of protection is provided to these areas and that enhancement and protection measures target these productive sites”.

The Project's offset strategy for the Regent Honeyeater is not acceptable and I strongly oppose this notion also. This is a bandaid solution without scientific proof of effectiveness. In fact, the use of offsets are known to have very little effect on biodiversity loss especially in handling the survival of species so close to extinction. There is no evidence that breeding habitat for Regent Honeyeaters can be successfully offset and any offsets would be unlikely to provide direct benefits for both the local affected population and the species.

It it difficult to comprehend how a Project of this nature will move forward when the evidence is clear and environmental impacts significant. There is very little point in pursuing recovery efforts for our native species when efforts are continually undermined. Community expectations would foresee that the protection of the Blue Mountains World Heritage Area is paramount. Destroying vital ecosystems when the consequences have been accounted for is not acceptable.

This Project should not proceed if our State and Federal Governments are serious about halting extinctions and paving a future for our country that protects our biodiversity.

I oppose the proposal to raise Warragamba Dam. If this project proceeds it will result in unacceptable potential impacts on the environment, including to the Blue Mountains World Heritage Area and threatened species. I focus my submission particularly on what these potential impacts mean for the breeding habitat of the Regent Honeyeater. This species is listed as Critically Endangered, both at state and federal levels. There is no ambiguity about it: this bird is on the verge of extinction and to eliminate any part of its breeding habitat only hastens its disappearance. To knowingly eliminate its breeding habitat is ethically indefensible.

My expectation is that we respect our environment, including our unique birdlife. My wish is that all children in Australia have access to our shared environmental fortune. My expectation, and my wish, depends on the decisions we make today, including whether to proceed with the proposed project to raise Warragamba Dam.

My grandparents heard and saw the paradise parrot. I cannot. They could see and hear the stick-nest rat. I cannot. My parents could see and hear the woylie. I cannot. My parents could see the blue-grey mouse. I cannot. They could see the western barred bandicoot almost anywhere in central NSW, Victoria, and South Australia. I can only see it in a couple of fenced sanctuaries.

Of birds alone, I want my grandchildren, and all children, to see and hear the painted snipe, the yellow-tufted honeyeater, the Australian bittern, the orange-bellied parrot, the mallee fowl, the hooded plover, and the swift parrot. They will not see and hear them if we do not protect their habitats because each of these species is under threat.

Children will not see the regent honeyeater if we do not protect its breeding habitat. It is a very simple risk assessment. The Warragamba Dam should not be raised.

Breeding habitat is considered habitat that is critical to a species' survival. The National Recovery Plan for the Regent Honeyeater makes it abundantly clear: 'It is essential that the highest level of protection is provided to these areas [breeding habitats] and that enhancement and protection measures target these productive sites.' Enhancement and protection measures, not reduction.

The EIS documentation is unequivocal about the risk: 'Given that suitable breeding habitat is located in the impact area, including an identified population, it is reasonable to consider that the proposed development could impact the ecology of the local population.' (See Warragamba Dam Raising EIS Appendix K-9-2.)

The remaining size of the Regent honeyeater population is alarmingly small, which places even greater importance on the protection of its breeding habitat. The EIS documentation offers us data of what 'small' really means in terms of survival of the species: 'The local population potentially impacted by the Project comprises a minimum of 21-35 individuals. This includes the number of adult and juvenile birds detected during targeted Regent Honeyeater surveys conducted in November 2017 (21), and the number of nestlings observed at two nests at the time of surveys (4), assuming each fledged successfully. This figure represents 5-7 % of the estimated population of the Regent Honeyeater (DoE, 2016) (Kvistad et al. 2015) and this breeding population represents one of less than five known remaining breeding populations that are known to support at least 20 individuals (DoE, 2016) (Crates et al. 2018).' (See Warragamba Dam Raising EIS Appendix K-9-2.)

An offset strategy is proposed for the Regent honeyeater. It is a false offering. It is not a risk mitigation strategy - it is neither robust, realistic, or credible. I oppose the offset strategy. Offsets are rarely an appropriate response to proposed biodiversity loss. That is especially so for critical habitat for the survival of a species, in this case breeding habitat for the Regent honeyeater. There is no evidence that breeding habitat for Regent honeyeaters can be successfully offset. Indeed, any offsets would be unlikely to provide direct benefits for either the local affected population or the species.

The Regent honeyeater is a Critically Endangered species. It is at the exit door. Only we can keep it shut. Only we can keep it with us.

Many thanks,

Rob Sheehan

I object to the proposal to raise Warragamba Dam wall.

I am writing as a resident of Wollongong NSW. When I am able to, I visit the national parks west of Sydney for rest and walking. As someone who has not lived in NSW all my life, the Blue Mountains NP has been a revelation to me and my family. It is shockingly beautiful and magnificent - and that is only the very small parts that we have had a chance to visit. Just knowing the Blue Mountains and other national parks exist nearby is a reassurance to me in these troubled times. That something so ancient, wondrous and full of secrets exists so close by alongside the stultifying digitalised work and real life these days, is comforting. When I visit the Blue Mountains, I love the silences as well as the sounds from all types of animals and plants moving in the air; I love the feeling of the air moving against my skin; the heat/the cold; the smell of real cleanness. And it is beautiful! I love that I will NOT have to check-in with some fancy uptodate mobile app.

I understand that ostensibly the reason for Warragamba Dam Wall Raising proposal is to protect the Hawkesbury-Nepean Valley from flooding. However, the EIS does not really thoroughly consider other much less damaging alternatives. It seems to me that this project could go ahead and then there would likely still be a lot of flooding. Instead of looking for quick fixes that actually don't really work, but which perhaps sound good for a short while at least on someone's resume, we should instead consider the problem from a wholistic long-term sustainability lens. This proposal seems designed to benefit developers and not really fix any wider community problem.

This proposal makes no sense when considered through a sustainability lens (which should integrate social/cultural, environmental, and economic considerations for the LONG TERM).

ENVIRONMENTAL:
The project would lead to flooding of 4,700 hectares of the Blue Mountains NP, and destroy 65 kilometres. That is a lot of ecosystems and plants and wildlife that would disappear - at a time when Australia leads the world for loss of mammalian extinctions. Mammals cannot survive without habitat. Why would we destroy yet some more habitat, especially after the bushfires of 2019/2020?

SOCIAL/CULTURAL PROBLEMS:
From a very selfish human and personal point of view, that is a lot of beauty that would disappear from this world. Why do this? This project is also not consistent with recognising and respecting Australian Aboriginal cultural heritage. We have a problem in Australia that we have disinherited the original Australians and this treatment and their disadvantage continues to this day. We need to start respecting and learning from Australia's First Nations peoples instead. We might learn some excellent ideas about how to live and cope with flooding and a changing environment in the context of global warming.

ECONOMIC PROBLEMS:
I have not read the economic case for this project as outlined in the EIS. But clearly this project would cost a lot of taxpayer money. IT would benefit very few, most likely developers and construction companies. The longterm economic benefits are really unclear to me. Yet there are high economic costs. With very adverse impacts on the world-renowned Blue Mountains NP, how many tourism dollars would also disappear? It seems that the wider community and indigenous people (who have cultural heritage in the area that would be inundated) are those who will pay, and yet not reap benefits. And where is the thorough assessment of alternatives that might achieve similar flood mitigation?

It seems to me that various NSW government agencies have expressed concerns with the EIS throughout this assessment process, and I ask that you listen to and heed their expert concerns in detail.

Please do not raise the Warragamba Dam Wall. We cannot afford to do this.