Warragamba Dam Raising

Please consider how unique the environment is that will be submerged, It has already been protected and this should be continued. We are rapidly loosing the last of our natural habitats to the countless endangered native plants and animals, especially after the 2019 bushfires. This is a World Heritage Area for a very good reason!

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. The Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild. It is unacceptable and inconsistent with the National Recovery Plan for any avoidable loss or degradation of breeding habitat to occur.

The Regent Honeyeater is critically endangered......this project involves significant risk to the natural habitat of this bird which has fewer than 400 individuals remaining in the wild....to continue this project flies directly in the face of conservation efforts to protect Australia's vital ecosystem by directly threatening the survivability of one of the most endangered bird species left.

The draft EIS concludes that the project poses significat impacts to the Regent Honeyeater breeding habitat that "cannot be avoided or minimised", on these grounds I strongly oppose the proposal to rise Warragamba Dam. The project poses unacceptable impacts on the environment, including the Blue Mountains World Heritage area and threatened species.
The regent Honeyeater is listed as critically endangered at both state and federal level, with as few as 350 individuals remaining in the wild. Any breeding habitat is considered habitat critical for survival of the species, under the Regent Honeyeater National Recovery Plan.

This impacts on the environment including to the Blue Mountains World Heritage Area and threatened species.
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 Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild. 
Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.
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 find my comments in the attachment

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.

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 Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild. 

Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.

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.

Making dams bigger is no solution. It poses unacceptable risks. It wastes important habitat.
A better plan is for stormwater reuse, water tanks on all new and old properties (at a minimum plumbed to the toilets, but also plumbed to the laundry is good) and education campaigns to reduce usage.
Also specifically in the case of Warragamba Dam, I strongly oppose the proposal to raise due to the project’s unacceptable potential impacts on the environment including to the Blue Mountains World Heritage Area and threatened species.
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 Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild. 
Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.
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. Making dams bigger is no solution. It poses unacceptable risks. It wastes important habitat.
A better plan is for stormwater reuse, water tanks on all new and old properties (at a minimum plumbed to the toilets, but also plumbed to the laundry is good) and education campaigns to reduce water usage.
Also specifically in the case of Warragamba Dam, I strongly oppose the proposal to raise due to the project’s unacceptable potential impacts on the environment including to the Blue Mountains World Heritage Area and threatened species.
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 Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild. 
Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.
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.

Australia is the leading country in the extinction of mammals. We are an extraordinary ancient land of extreme biodiversity with a narrow green belt becoming more narrow exponentially. As a result our flora and fauna are becoming more and more threatened to the point of extinction. Such is the situation of the Regent Honey Eater, amongst others. Raising of the dam wall would threaten an already threatened species, amongst others, eliminating one of the last breeding grounds where there are likely only 350 breeding birds left in the wild. Does NSW wish to be among the world leaders in the extinction of yet another species. This is a World Heritage Area and must be protected. I strongly oppose the project’s offset strategy, there is no evidence to support such a strategy would work, nor support those existing birds and their existing populations. Using the “captive breeding and release” strategy is no replacement for natural selection. Thank you for your time.

To whom it may concern

I object to the raising of the Warragamba dam wall.
From what I can ascertain the wall height will be raised up to 17 metres higher than the existing height? This will clearly impact the inundated areas behind the dam wall such as Picton which has already endured many flood events.
From my research the EIS was commissioned before the 2019/20 bushfires. This alone deems it an obsolete study due to the changed landscape and damage done to flora and fauna in the Greater Blue Mountains World Heritage Area.
I know this because I was working in the fire zones at the time and witnessed first hand the mass destruction.
I strongly advise that alternate options and costs be looked at in no particular order -

1. Consult or get consent from the traditional Gundungurra owners, this would have helped years prior to the 2019/20 bushfire management disaster.

2. Actually seek advice from qualified experienced people such as Stuart Khan from Uni of NSW who is an environmental engineering professor,
as opposed to certain vocal politicians with development agendas in flood zones.
Stuart believes a more sustainable option could be keeping the dam level lower by managing it with alternatives.

3. Commission a current study into what the biodiversity offset liability cost will be. From my quick calculation it looks like it will be substantial.

4. The time frame and cost to extend the wall will also be substantial. This will need to be calculated to include time and cost blowouts which always occurs with projects of this magnitude.

4. Just before the drought broke in 2019 there was talk of possibly connecting Warragamba dam to Woronora dam that supplies south of Sutherland and north of Wollongong. This should be explored as these areas were weeks away from running out of water as the desalination plant does not supply these growing areas.
Sincerely

John Whatmough

Dear Sirs,
About myself: I am 78. I have walked down the Kowmung River many times. For 15 years I was a director of the Colong Foundation for Wilderness Ltd and for many years a member of the National Parks Association NSW. Colong fought to obtain World Heritage status for the Greater Blue Mountains National Parks. This is important for the Australian Tourism Industry. Retaining unique biodiversity and ecological integrity heritage for posterity to benefit future generations.
I do not support any change to the height of the Warragamba Dam Wall.
FLAWS IN THE ENVIRONMENT IMPACT STATEMENT TO RAISE THE DAM WALL
1. About half of the floodwaters to the Penrith plain come from rivers outside the Warragamba catchment.
2. The EIS allows for flooding of 60 km of wilderness rivers and thousands of Aboriginal sites. SMEC spent three hours surveying for Koalas and one day for Platypus. The extent of inundation is seriously understated: Only 1400ha of the 6,000 ha impact area. The rising water would drive threatened species to extinction like the Regent Honeyeater.
3. The EIS relies on surveys conducted before the Bush Fires 2019-20 which burnt 81% of the Greater Blue Mountains. A new survey is needed.
4. No experts were engaged to undertake studies of the impact of the dam project on the Outstanding Universal Values established in 2000.
CONCLUSION
4,000 page EIS issued despite opposition from the Insurance Industry: The Hawkesbury – Nepean flood plain is no place to expand development. Hostility from UNESCO ignored by the Member for Western Sydney now deputy to Premier NSW: Hon. Stuart Ayres
I strongly oppose the raising of the Warragamba Wall by 17 metres. In times of drought Sydney has a Saltwater Treatment Plant at Kurnell.

Yours sincerely, Ian Tanner.

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. 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 Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild.  Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019-20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.
There are only a handful of contemporary breeding sites for Regent Honeyeater and during the assessment of the project a total of 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. 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.

I strongly oppose the raise the Warragamba Dam EIS, as it will place at risk habitat for the State and Federal Critically Endangered Regent Honeyeater Bird. It is not acceptable to destroy the habitat of a critically endangered native bird species. The survival of this species requires the government to make decisions that will not endanger its habitat. These birds are not migratory, and can not simply 'find another place to live' they will cease breeding and die out. Research indicates that even migratory birds return to the same place all their lives, for nesting, breeding and feeding. So if we destroy the habitat of this species, they are not likely to 'know where' to relocate. With only 350 birds remaining in the wild, we can not continue as a nation to make decisions that ensure the extinction of native species. The draft EIS concludes that the project poses a significant impact to the Critically Endangered Regent Honeyeater breeding habitat that 'cannot be avoided or minimised'. As there is a Regent Honeyeater National Recovery Plan in place to assist with ensuring this species survives, then the raise the Warragamba Dam project is in direct contradiction of the Regent Honeyeater National Recovery Plan and will therefore not ensure the species survival. We need to make better decisions for generations to come, both human and native fauna and flora. This project does not do that. It favors one outcome only, which ensures the destruction of all other species in its path. This is not a humane or sustainable proposal.

Hello. Once again the precious wildlife of Australia suffers at the expense of progress and development. The flooding will knock out habitat of the critically endangered Regent Honeyeater and other wildlife. All Regent Honeyeater habitat is vital - and the loss of this site will contribute to their extinction. After all the conservation efforts, including government efforts, made to help this animal and others - this project will destroy all that good work. If we continue to lose our biodiversity - humanity will suffer. Biodiversity is necessary to ongoing human life. We can't keep making these decisions that have such an impact on nature. It is not sustainable!!

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.
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 Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild. 
Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.
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.

Thank you for your time

Take care, stay safe

I believe the natural and indigenous heritage values of the area needs to be protected, I do not believe that this project should go ahead. I am most concerned about the threat to the critically endangered Regent Honeyeater and the many indigenous sites in the area that is proposed for inundation.

The Regent honeyeater deserves protection and not to become extinct because of mismanagement of precious resources.

Dear NSW Government

Raising the height of the Warragamba Dam wall is not the solution to mitigating nature. With climate change and other unknown risks, we know we cannot predict nature and to pretend to do so is a folly, insincere, and an untruth. The law also supports this view.

You say the project is to provide temporary storage capacity for large inflow events into Lake Burragorang to facilitate downstream flood mitigation. You hope it’s a temporary solution, but you and nobody else can say that with certainty. What does temporary mean in any case? Any additional storage whatsoever will create additional impacts. Haven't we done enough damage to the Burragorang Valley and all other areas to be impacted by the project?

The impacts of the project include: more than 1,500 sites of cultural, national and historical significance like indigenous cave art, occupation and burial sites, which are likely to be drowned under silt-laden waters thus destroying their value and access; the Kowmung River (declared a ‘Wild River’ under the National Parks and Wildlife Act 1974 for its pristine condition), including approximately 65KM of other wild rivers; up to 6,000 hectares of the World Heritage-listed Blue Mountains National Parks could be inundated and destroyed, further endangering already threatened species like the Regent honey-eater and the Camden White Gums (recognised, amongst others as having Outstanding Universal Value under the World Heritage listing); a number of Critically Endangered species such as the Regent Honeyeater, and Sydney’s last Emu population; and, Threatened Ecological Communities, notably the Grassy Box Woodland. Threatened species surveys are substantially less than guideline requirements. Where field surveys were not adequately completed, expert reports were not obtained.

Severe fires during the summer of 2019/20 devastated 81% of Blue Mountains Heritage Area. No post-bushfire field surveys have been undertaken. We do not understand the impacts of the fires and we do not understand the cumulative effect raising the dam wall will have on these fire-effected areas.

Of the cultural heritage sites that would be inundated by the project, the Aboriginal Cultural Heritage Assessment Report has been severely and repeatedly criticised by both the Australian Department of Environment and the International Council on Monuments and Sites (ICOMOS) for not appropriately assessing cultural heritage in meaningful consultation with Gundungurra Traditional Owners. The Gundungurra have not given Free Prior Informed Consent for the project to proceed, as required under the United Nations Declaration on the Rights of Indigenous Peoples which has been adopted by Australia. This Declaration includes that States shall provide effective mechanisms for prevention of, and redress for, any action which has the aim or effect of depriving them of their integrity as distinct peoples, or of their cultural values, ethnic identities or resources. Indigenous peoples also have the right to maintain, protect and develop the past, present and future manifestations of their cultures, such as archaeological and historical sites, artifacts, designs, ceremonies, technologies and visual and performing arts and literature. Arguable, these rights are being breached by the project, and regardless have not been properly considered. Only 27% of the impact area was assessed for Aboriginal Cultural Heritage.

Of the western Sydney homes to purportedly be protected by the project, many are already within the 1:100 year flood event levels. Why put more homes within 1:100 and also mislead home-owners re: risk. Insurance costs will be high ultimately the NSW Government liable for losses. Primarily only property developers want to build within 1:100. Smarter places to build must be found. Increased density maybe the key. All growth is not necessarily good. The EIS does not explore these issues.

The EIS does not provide serious alternatives to raising the dam wall, including an analysis of views such as those expressed by Associate Professor Jamie Pittock of the ANU in his Sep 18 report entitled: "Managing flood risk in the Hawkesbury – Nepean Valley - A report on the alternative flood management measures to raising Warragamba Dam wall". Assessment of alternatives does not take into account the economic benefits that would offset the initial cost of implementation. On average, 45% of floodwaters are derived from areas outside of the upstream Warragamba Dam catchment, so no matter how high the dam wall is constructed, it will not be able to prevent flooding in the Hawkesbury-Nepean Valley downstream. No modelling of the stated flood and economic benefits of the dam wall raising are outlined in the EIS.

The litigation risks and costs with respect to managing dam waters was seen in the case against Seqwater, SunWater, and the State of Queensland for damages arising out of the flooding caused by their dam management after heavy rainfalls in Jan 11 in the Brisbane River Basin. Many homes and businesses were flooded, lives were lost, as the Brisbane River, the lower Bremer River and Lockyer Creek broke their banks. The defendants were sued in negligence, nuisance and trespass. Such a risk already occurs downstream of the Warragamba Dam, and it would increase if the dam wall was raised and more homes built in the flood plain.

Australia has not yet committed at COP 26 to net zero carbon by 2050 in it's UNFCCC NDC under the Paris Agreement 2015. Even if it does, and so to all major global greenhouse gas emitters, serious harm from climate change is not guaranteed to reduce. If Australia will not make its own commitment, how can we expect others to? By raising the dam wall you seem to be expecting to have to mitigate further serious natural hazard events. The precautionary principle needs to be applied and the wall not be built. We need to expect increased hazardous climate events, not hope we can control and mitigate them. Recent global climate change litigation shows clearly the obligation on government to find a permanent solution to climate change to protect its current and future citizens, not short-term solutions such as a raising dam walls that also destroy natural systems.

At Paragraph 57 of "Minister for the Environment and Heritage v Queensland Conservation Council Inc [2004] FCAFC 190" the court found that "It is sufficient in this case to indicate that “all adverse impacts” includes each consequence which can reasonably be imputed as within the contemplation of the proponent of the action, whether those consequences are within the control of the proponent or not." Clearly the EIS does not consider "all adverse impacts" or cumulative impacts - such as was upheld in NSW in Prineas v Forestry Commission of NSW (1983) 49 LGRA 402. The Australian Government accepts the theory of cumulative impacts with respect to natural resource management, see: https://soe.environment.gov.au/theme/coasts/topic/2016/cumulative-impacts-and-management-multiple-uses. The cumulative impacts of the project are not adequately addressed by the EIS.

In 2000, part of the project area was listed as the Greater Blue Mountains World Heritage Area by UNESCO due to Outstanding Universal Value for the whole of mankind. The values recognised included the unique biodiversity of the region's plant and animal communities which supports more than 90 eucalypt species, ranging from tall rainforests through to woodlands, shrub lands and stunted mallees, and the hitherto thought to be extinct Wollemi Pine. We don’t know what other unknown species may be impacted by the project. The government said the listing would focus the attention of all levels of government on the region's environmental credentials and on their responsibility to maintain these, and that it would boost tourism and that the Blue Mountains was one of Australia's premier tourist destinations (Hansard Wednesday, 6 December 2000 Page: 23570). The EIS does not state how NSW can now negatively impact these world Heritage values, and why the criticisms of the IUCN in this regard are being ignored - see: https://www.iucncongress2020.org/motion/082. Raising the dam wall and the consequent damage to natural and cultural values would breach World Heritage values and hence Australian obligations under the World Heritage Convention.

For the reasons mentioned in this submission, the integrity of the environmental assessment is fundamentally flawed, and cannot be accepted as a basis for further decision-making. To do otherwise would be a reckless endeavor for which taxpayers will ultimately bear the risk whilst also losing some of their last natural places. It’s lose lose.

l have lived in the areas the project will impact and l hope to return. As a young lady my mother visited the Burragorang Valley in horse and trap and visited farming relatives there. Her stories of the beauty of the fertile valley and the indigenous remains were wonderful. Please do not destroy any more of this otherwise pristine landscape and give our children the inheritance of what's left of the Australian commons they deserve. My brother and sister concur with most of my views in this submission.

We will never see this landscape again, let’s not take anymore.

Yours faithfully
David Denniston

• Dear Sir/Madam,
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.
• The EIS has concluded that the project poses potential significant impacts to contemporary breeding habitat for the Regent Honeyeater that “cannot be avoided or minimised.”
• The Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild.  Reintroduction programs organised by the NSW government and others have not been successful in increasing the dwindling population of this once common bird.
• Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.
• 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.
I also object to the inadequate amount of investigation and survey of aboriginal cultural heritage significance. Not enough of the potential flooded area has been surveyed by Water NSW and the local indigenous community is not satisfied and have identified many sites of significance that will be destroyed by raising the dam wall. Further survey and investigations need to be undertaken before any progression of this project.
I urge the NSW Government to adopt all 16 Recommendations outlined in the Iterim Report on the Proposal to Raise the Warragamba Dam Wall, October 2021 before any further progression of this proposal is undertaken.
Yours sincerely,
Ifeanna Tooth