Warragamba Dam Raising

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.

Reasons for in Principle Support of the Proposal.
[A]. Raising the Wall Should Stop Warragamba Feeding
Small H-N Floods.
Flooding in the Hawkesbury-Nepean River [H-N] system will occur without any water being discharged from Warragamba Dam. This flooding is caused by high rainfall in the Nepean catchment and the water bypasses Warragamba.
History has shown that flooding from the Nepean catchment occurs quickly and can be above 9.0 metres at Windsor, which is enough to cut most evacuation routes on the flood plain.
With climate change, and by 2090, these floods could be as high as 11.5 metres at Windsor [my estimate]. The catchment is close to the Illawarra escarpment and on occasions can be subjected to much higher rainfall than the Warragamba River catchment, except for rain that falls on the Eastern Blue Mountains escarpment. Climate change may increase this orographic type rainfall.
The February 2020 flood was 9.2 metres at Windsor with no water coming from Warragamba. Rainfall at Robertson NSW was 395mm in one day and the water reached Windsor in 24 hours. Because Warragamba was at a low level, all the inflow from the catchment, more than 1000 GL was contained. Adding 1000 GL of FMZ would fully contain this type of inflow without any discharge into a flooded H-N. The flood however, could have been much higher if more rain had fallen on the Grose catchment. It could have been a 1:10 flood at Windsor, and with climate change a 1:20 flood by 2090 [my estimate].
The 2020 flood was unique in recent times, not just because no water came from Warragamba, but because it also showed clearly without being masked by Warragamba water, what the Nepean catchment’s flow contribution could be to a normal H-N flood.
Conclusion 1.
The 2020 flood rose rapidly and cut the evacuation routes on the flood plain. This will happen again regardless of what is done at Warragamba, and will remain forever at least a 1:15 flood threat. This is type of flooding, which cuts access roads on the H-N flood plain, is not fully analyzed or discussed in the EIS. However, it is important to prevent Warragamba water adding to this type of flood.

[B]. Main Effect of Raising the Wall.
Warragamba inflows during the 1961 and 1978 floods exceeded 1500 GL [my figure based on published reports] over 4 days, and the release of this water was the main cause for 1:20 to 1:100 flooding in the H-N. Assuming the February 2020 flow rate could approximate the Nepean catchment component of a 1961 or 1978 type flood, this flow caused the river at Windsor to stay above 5.5 metres for 4 days [in February 2020]. Assuming a 1500 GL inflow into the dam, a raised Warragamba would hold back 1000 GL [if at FSL to start], but there would be an uncontrolled discharge of 500 GL, which would take place during the same 4-day period of the maximum dam inflow and at the same time the downstream flood would be peaking. This will increase the flood height at Windsor from 9.2 metres [February 2020] to maybe 12.2 metres [my estimate], equivalent to a 1:10 to 1:20 flood.
If one of the aims of the project is to protect the H-N valley from a 1:20 to 1:100 flood, the FMZ needs to be at least 1500 GL. This requires the main spillway project height to be increased by 17.0 metre [my estimate].
Conclusion 2.
Instead of waiting [before 2090] to raise the main spillway from 12.0 to 15.0 metres because of climate change, do it now, but make it 17.0 metres.

[C]. ‘Piggy Back’.
The idea of ‘piggy back’ discharges which are planned to begin as soon as a H-N flood peaks, and to mirror the normal river draining process is a positive for reducing the time the World Heritage Area is submerged and also restores the FMZ as soon as possible. If a 100 GL per day outflow from the dam can cause a 5.5 metre flood at Windsor [EIS Table 15-29], it is clear that a discharge of 100 GL per day into a falling flood level is not going to happen, if bridges and flood plain roads are to be cleared. Consequently, it is going to take more than 10 days to restore the 1000 GL FMZ, during which time another rain event could occur. The ‘piggy back’ action will prolong flood levels and add to the misery of people using the flood plain. If there is anyway the proposed ‘piggy back’ process time frame can be reduced, or modified, it will be a positive for the H-N valley and the World Heritage Area. However, there does not appear to be an easy answer to this problem.

[D]. Auxiliary Spillway Design.
The new auxiliary spillway is a positive design change and will remove the threat to the H-N valley that has been present ever since the existing ‘fuse plug’ spillway was commissioned in 2002.

I strongly oppose the project to raise the height of Warragamba Dam.
My objections are threefold:
1 it impacts the habitat of the Regent Honeyeaters,
2 it impacts on Aboriginal sacred sites, and
3 I suspect that the real agenda of the State government is to allow further urban development downstream from the dam.

I live downstream of the Dam at Emu Plains. I purchased my property in full knowledge of the flood risks that the river presented, including the knowledge that in the last 150 years, what is now my property had been subject to significant inundation. That is the risk that I took in purchasing the property where I live.
All people who live in the Hawkesbury/Nepean flood plain are abundantly aware of this risk. We built our homes and businesses in the knowledge that they would either be at risk from flooding or we built them in a way that mitigated that risk. In exchange, we get to live in a beautiful area, covered with rich soils and with the last substantial remnants of the woodlands that used to cover this area. Native wildlife is still present (although it is visibly retreating over time) and what areas have been cleared still represent a significant amount of the open green space that keeps western Sydney habitable through moderation of temperature extremes and some capacity to reduce air pollution.
The fact of the matter is that the only properties that are truly adversely affected by the floodwaters are those that are planned to be built on what will no longer be flood affected land once the dam wall is raised. Even those farmers who suffered setbacks in the recent floods cannot deny that the deposition of new topsoil results in an increase in their productivity over time - those soils which will be catastrophically depleted if all flooding is stopped as a result of the dam wall increasing.
Even the river itself benefitted from the floods of March 2021 - the riverbanks have been scoured clear of the debris and tangles that have choked them for so long - in many places you can finally see the river for the first time in years. Due to weed and debris growth, parts of the river were becoming unnavigable to boats (at least, not without collecting several tonnes of weed). Flooding is a necessary part of the being of a river, for it's ecology and for it's aesthetic. Without it, the river will choke and die. It already struggles to maintain its banks because of the Dams that cut off a majority of its silt supply, but now the centre is at risk because the river doesn't get to flush itself back to health.
The broader community have been loud and clear about this issue - a one-off flood event every 30 years (or more) does not justify the destruction of the World Heritage status of the Blue Mountains, something which cannot be replaced or rebuilt once destroyed. I, along with many of the other voices, are also sick and tired of being lied to about the purpose behind the dam raising - one need only look at the development along Richmond Rd to know that this is not about protecting the existing properties, it's about opening up the entire floodplain to huge levels of development, development which is uninsurable unless the river is tamed completely.
Also worthy to note is the coverage in the media shows that the project already suffers from poor governance - the cost of the project is already spiralling out of control, the environmental assessments have been shown to have questionable reliability and the ministers refuse to accept that their actions will fundamentally increase the ability for Western Sydney to be developed with hundreds of thousands of more undersized and poorly serviced residential properties. There can be no confidence that the cost-benefit analysis, of which this environmental plan forms a part of (by quantifying that which will be destroyed), has any actual merit nor overall value to the people of New South Wales.
The phenomenon that was COVID has shown that Sydney need not be the centre of this state any more. It has shown that the spread to the regions can be done in a way that is sustainable and productive and better utilises the resources of this state, rather than requiring the continued development of this mega-city into an unwieldy beast akin to Los Angeles. This should be enough to inform a broader look at the plan for this state and conclude that preservation of what is left of the native parts of Sydney and its surrounds, particularly the Blue Mountains, must be made a priority over the extension of a dam that, for all intents and purposes, is going to create nothing but destruction.
I object to the project and reject its premise. I object to the representation made on my behalf by my local MP that this is the will of the people in this area. I object to this underhanded attempt to open the Hawkesbury Nepean floodplain to development at the expense of the health and wellbeing not just of the residents who live on the floodplain, but all the rest of Sydney, who rely on the green spaces the moderate the climate in which they live.

I live on the edge of the Chiltern - Mt Pilot National Park in Victoria - another critical habitat of the Regent Honeyeater. I am connected both physically and emotionally to the Regent's plight. The Regent Honeyeater is Critically Endangered. I cannot sit by and watch it become extinct. The smallest impact will push them into extinction and the raising of the Warragamba Dam could be that small impact. Thousands of hours of voluntary and paid work and hundreds of thousands of dollars has gone into saving this iconic bird. The bird and all this time and money will be lost if this proposal should go ahead. How can this information be known and the project even be given consideration ?

To whom it may concern,

Submission – Warragamba Dam Raising Project – SSI-8441

I strongly OBJECT to the Warragamba Dam Raising Project (the ‘Proposal’), for the reasons outlined below.

I am a NSW taxpayer who strongly supports the conservation and protection of nature for humanity’s future. Together with my family, I enjoy bushwalking in the Blue Mountains and many other National Parks in NSW. I am appalled by the mis-management of NSW conservation areas over the past decade or more, and the rampant developer-led expansion of Greater Sydney, under the Coalition government. More specifically, I object to the current and future expansion of housing in the Hawkesbury-Nepean floodplains. Such development is unnecessary, poorly planned and heedless of the environmental impacts and future costs to taxpayers to mitigate losses after foreseeable flooding events. The Proposal to raise the Warragamba Dam Wall is simply ridiculous, as it will NOT prevent future flooding in the downstream valley and instead will destroy valuable cultural and natural heritage which should be preserved. I further submit that the Proposal is unlawful, as it would put Australia in breach of its obligations under the World Heritage Convention.

The Blue Mountains World Heritage area is not just a world class National Park, and vital for protecting and conserving threatened species and natural heritage. In 2000 it was inscribed on UNESCO’s World Heritage list in recognition of its Outstanding Universal Value for the whole of mankind. Raising the Warragamba dam wall and consequent damage to natural and cultural values would be a clear breach of these undertakings and Australia’s obligations under the World Heritage Convention. I strongly object to the use of NSW taxpayer’s resources to fund this desecration of our protected World Heritage area. Specifically, an estimated 65 kilometres of wilderness rivers, and 5,700 hectares of National Parks, 1,300 hectares of which is within the Greater Blue Mountains World Heritage Area, would be inundated by the Dam project. I understand that this includes:
• The Kowmung River - declared a ‘Wild River’, protected for its pristine condition under the National Parks and Wildlife Act 1974;
• Unique eucalyptus species diversity recognised as having Outstanding Universal Value under the area’s World Heritage listing such as the Camden White Gum;
• A number of Threatened Ecological Communities, notably Grassy Box Woodland;
• Habitat for endangered and critically endangered species including the Critically Endangered Regent Honeyeater and Sydney’s last Emu population.

I am also concerned that severe bushfires during the summer of 2019/20 devastated 81% of Blue Mountains Heritage Area, yet no post-bushfire field surveys have been undertaken before the EIS for this Proposal published. The EIS is also defective as threatened species surveys are substantially less than guideline requirements, and where field surveys were not adequately completed, expert reports were not obtained. Further, only 27% of the impact area was assessed for Aboriginal Cultural Heritage. Over 1541 identified cultural heritage sites would be inundated by the Dam proposal, yet Gundungurra Traditional Owners have not given free, prior and informed consent for the Proposal to proceed. 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 community members.

The EIS that has been conducted is fundamentally flawed and the engineering firm that undertook the environmental and cultural assessments for the project (SMEC Engineering) has been widely discredited, recently being barred from the world bank. The firm has an established history abusing Indigenous rights. Further, no modelling of the stated flood and economic benefits of the dam wall raising are outlined in the EIS. The integrity of the environmental assessment is fundamentally flawed, and cannot be accepted as a basis for further decision-making by the Minister for Planning.

In conclusion, this unlawful, ineffective and poorly assessed Proposal should NOT be allowed to proceed. There are many alternative options to raising the Warragamba Dam wall that would protect existing floodplain communities. A combined approach of multiple options has been recommended as the most cost-effective means of flood risk mitigation. However, alternative options were not comprehensively assessed in this defective EIS. Any assessment of alternatives does not take into account the economic benefits that would offset the initial cost of implementation. As has been widely published, on average, 45% of floodwaters are derived from areas outside of the upstream Warragamba Dam catchment. This means that no matter how high the dam wall is constructed, it will not be able to prevent flooding in the Hawkesbury-Nepean floodplains.

The NSW Government has a duty to its citizens to make informed, sensible and cost-effective decisions. Implementing this Dam Raising Project would be the height of incompetence and a massive waste of taxpayers’ money, in addition to significantly damaging natural and cultural values in breach of Australia’s obligations under the World Heritage Convention.

I am an Wiradjuri Aboriginal woman from the unceded lands around the Abercrombie River region just west of the Blue Mountains. I am also resident of the Wollondilly shire, and I extremely and strongly object to the further raising of the Warragamba Dam Wall. My ancestors traversed the lands of the Burragorang valley since time immemorial and I have epistemologically valid evidence to prove this. The sacred sites and dreaming stories located within the Burragorang Valley form part of a wider picture of culture, story and spirituality. A story which has lost eighty percent of its pieces by the desecration that comes with colonisation (like when the wall was first constructed). What is less known, from a western colonial perspective, is that these sites are not seen as singular sites to Aboriginal people but form a larger story for all Aboriginal people in this country who have lost so much of these pieces since 1788. As a Aboriginal woman with cultural, spiritual and family ties to these remaining 20% of sites, the loss of these sites in the Valley add up to the ongoing loss for all Aboriginal peoples in this country (see Juukan George, in WA for one recent example). The ancient songlines that connect all areas of this country speak of the traditional custodians ways of being of a time that began well before 1788. These songlines traversed the Burragorang Valley and 80 % have already been destroyed 50 years ago. By the raising of the dam wall, these remaining songlines will all be destroyed with no retrievable way of reconnection. In addition, the cave paintings, dreaming stories and other sacred sites form stories that were passed on for thousands of years. This is likened to tearing up old family photo albums and pages of a bible for me (ones that have already lost most of their pages). If the dam wall goes up these ancient paintings will be washed away with a single flood. As a Aboriginal person this accounts to no less than cultural and spiritual homicide. As with the Juukan George case in WA, the government has been called upon to do more to protect sacred Aboriginal sites. IF this project goes ahead, this government will go down in history and be known internationally, as knowingly destroying the remaining sites of the oldest living continuous culture on the planet, shame on you.

My own personal views are fully and wholly supportive of the following reasons as to why this ill conceived project should not go 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.
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.
Valentine Franks

I most 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 many threatened species.
In particular , 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.  We cannot afford to lose not one more single 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.
Most notably, 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.”
I fail to see how there can be a logical reason and debate otherwise.
The National Recovery Plan for Regent Honeyeater 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 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 also very 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 has been no evidence at all 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 object to this project on the grounds that it will destroy cultural heritage.
I object to this project on the grounds of environmental destruction
I object to this project on the grounds that it is not necessary

Please see attached.

This project should not go ahead because it is unnecessary: there are other cost-effective and climate-friendly ways to improve the supply of water to residents of Sydney.
1. Sydney already has adequate rainfall for its needs but fails to catch, store and rationally use it. It’s a legacy of the bad old days when many householders in NSW were forbidden to supply their own needs with rainwater, fined for having rainwater tanks, and instead forced to pay for reticulated “town water’. At the same time there was the cost of expensive stormwater removal systems, which failed to recycle the abundant supply of free rainwater. These failures are still evident in Sydney, where during rain events, the stormwater systems are often overwhelmed.
There is more than enough rain falling on the city, yet still it is not being captured on-site, stored and managed in a rational way. Mandated rainwater capture and use is necessary, along with education, water-wise appliances, and demand management. Rainfall in the city is better than in the Burragorang catchment, so it is false economy to try to harvest more rain by raising the height of Warragamba Dam.
2. Raising the Warragamba Dam wall would not reduce the risk of future flooding to residents and businesses across Western Sydney (as proposed in the WaterNSW EIS).
We know that half the floodwaters come from rivers outside the Warragamba catchment, and the Nepean River is particularly important. It enters below Warragamba Dam so raising the dam wall not intercept its waters or mitigate flooding from the Nepean. These floods have to be seen to be believed, so extensive and persistent are they, yet they are part of the river ecosystem that no amount of engineering will control. I lived in Burragorang from birth and I witnessed this flooding in the 1950s and early 1960s, particularly in Camden, Elderslie and Narellan. The Chinese market gardens in Camden where we bought vegetables, were typical of the successful horticulture on alluvial soil of the Nepean floodplain.
It is no accident that colonial agriculture was so successful in Camden and surrounding areas. It would be inappropriate to destroy a valuable food growing asset so close to the city of Sydney and its markets, in order to build flood-prone housing that will probably become uninsurable.

3. Raising the dam wall will exacerbate the flood problem by encouraging suburban development in vulnerable areas, resulting in vegetation being replaced by vast areas of hard surfaces that prevent infiltration of rainfall. Sydney’s urban sprawl also contributes to climate change as it generates local higher temperatures (and the loss of trees and green areas that would have ameliorated this), more roads, more ICE vehicles needed for residents to reach their workplaces, poor air quality and resulting health issues, more need for artificial cooling and heating, and more demand for energy.
If this continues to happen we will see profits for the few, loss of life and property for the many, and pointless despoliation of World Heritage areas. Instead of endless urban sprawl to the south and west of Sydney city, we need better urban planning to avoid development in flood prone areas.
4. Environmental degradation in the Blue Mountains should stop, not continue. Millions of trees were cleared (destroyed) when the dam was made at the confluence of the Nattai, Cox and Wollondilly rivers in Burragorang Valley, which I remember well. Nattai village was removed and transplanted to the top of the mountain road, near the current Burragorang Lookout. Our home and everyone else’s, all other buildings and even the cemetery were removed so that the dam catchment would not be contaminated. Such destruction would surely not even be considered today; yet similar damage will result from raising the wall.
This area and its ecosystems, its First Nations heritage and its unique wildlife have already suffered so much damage. The National Parks Association (NPA) has calculated that the raising of the dam 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 including threatened species.
5. The EIS is not fit for purpose because since it was done, even more destruction has hit the Blue Mountains. During Black Summer 80% of the World Heritage listed Greater Blue Mountains Area was affected by the fires. Across NSW 5.3 million hectares (6.7% of the State) was burnt, including 2.7 million hectares in national parks (37% of the State’s national park estate). Some 800 million native animals perished in NSW and their populations have not recovered – they may never recover.

Other critical reasons to leave this area alone, include the accelerating rates of vegetation clearing/deforestation throughout NSW, among the worst in the developed world. Also the mounting threat of climate change is being made worse by removal of trees that should be retained to sequester carbon.

6. Ineffective offsets and hidden costs are unacceptable. The proposal wants to use offsets to mitigate environmental damage in this area, yet this is impossible because of its status. As the NPA says, “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.” Also the EIS does not calculate the biodiversity offset liability for the project, and this is unacceptable. The claim by NPA that it could cost taxpayers $2 billion, needs to be addressed immediately.

I have been a resident of the Blue Mountains Springwood/Winmalee area most of my life since birth. I have a passion for our natural environment and for Aboriginal and European Heritage in Australia.
I appeal to you NOT to raise the dam wall. It will achieve little:
• allowing developers to build on floodplain will still result in flooding during peak seasons of rainfall. It is completely irresponsible to allow people to build in flood-prone or bushfire prone areas.
• vast areas of wilderness and important Indigenous sites will be lost forever. Consultation has NOT occurred with the local Gundungurra people and they have NOT given their permission for the project to go ahead.
• Over 1541 identified cultural heritage sites would be inundated by the Dam proposal.
• Internationally we would lose standing and credibility for destroying natural and cultural heritage of a UNESCO World Heritage Listed National Park. The Blue Mountains was listed in recognition of its Outstanding Universal Value for the whole of mankind.
• Natural beauty that would be lost includes
o An estimated 65 kilometres of wilderness rivers, and 5,700 hectares of National Parks, 1,300 hectares of which is within the Greater Blue Mountains World Heritage Area.
o The Kowmung River - declared a ‘Wild River’, protected for its pristine condition under the National Parks and Wildlife Act 1974;
o Unique eucalyptus species
o A number of Threatened Ecological Communities, notably Grassy Box Woodland;
o Habitat for endangered and critically endangered species including the Critically Endangered Regent Honeyeater and Sydney’s last Emu population.
Lastly, WHAT IS THE POINT??? The massive floods we have had recently showed that on average, 45% of floodwaters are derived from areas outside of the upstream Warragamba Dam catchment. This means that no matter how high the dam wall is constructed, it will NOT BE ABLE TO PREVENT FLOODING in the Hawkesbury-Nepean Valley downstream.

RAISING THE DAM WALL WOULD BE AN EXERCISE IN FUTILITY

Please show our Indigenous Australians that we care about them and their heritage. Let’s stop ignoring them and belittling their culture. Let’s support them, lift them up and show that we care and value them and their cultures.

Another important consideration is the EIS was NOT COMPLETED PROPERLY and as such should not be used to justify the raising of Warragamba Dam wall.
• SMEC Engineering who undertook the environmental and cultural assessments for the project have an established history abusing Indigenous rights, recently being barred from the world bank.
• Severe fires during the summer of 2019/20 devastated 81% of Blue Mountains Heritage Area. No post-bushfire field surveys have been undertaken.
• Only 27% of the impact area was assessed for Aboriginal Cultural Heritage.
• Threatened species surveys are substantially less than guideline requirements. Where field surveys were not adequately completed, expert reports were not obtained.
• No modelling of the stated flood and economic benefits of the dam wall raising are outlined in the EIS.
• The integrity of the environmental assessment is fundamentally flawed, and cannot be accepted as a basis for further decision-making by the Minister for Planning.
• Alternative options were not comprehensively assessed in the EIS. Any assessment of alternatives does not take into account the economic benefits that would offset the initial cost of implementation.

The facts speak for themselves. We do NOT NEED to RAISE THE DAM WALL. Think of all the other things that money could be spent on …..

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. 

I strongly oppose this we need to start thinking about our wildlife like our regent honey eaters, the impact on the environment,

I do not support raising the Warragamba Dam Wall.

I do not believe raising the wall will deliver the claimed benefits because I have seen in the past flooding in the Hawkesbury region while Warragamba Dam was well below 100% capacity. (below 50% in Feb 2020)

I do believe raising the dam wall will place at risk some areas of the Blue Mountains environment and Indigenous cultural heritage could be devastating should the raising of the dam wall go ahead.

I am opposed to this proposal to raise the Warragamba dam wall. It will cause unacceptable environmental impacts which cannot be offset.
1. Flood Risk
The region has the highest flood risk exposure in New South Wales, if not Australia (Executive Summary, [ES] page 1). It is reasonable to assume that no one lives there without knowing this. There are around 140,000 people living and working on the floodplain. (ES page 3) This number will increase because (we are told) that to halt development would be 'costly and difficult.' (ES page 25) The purpose of the project is to reduce flood risk exposure. The most obvious first step is to stop further population growth.
The ES states that it is not possible to stop floods - the aim of the project is to reduce impacts. The difficulty is that in endeavouring to reduce impacts on people (who have knowingly chosen to live there) the project creates other impacts on the environment - impacts which cannot be offset.
2. World Heritage Area
This proposal impacts the Greater Blue Mountains World Heritage Area. According to the Australian Government 'World Heritage sites are places that are important to and belong to everyone.' 'They have universal value that transcends the value they hold for a particular nation.' 'Places are carefully assessed as representing the best examples of the world's cultural and natural heritage.' (environment.gov.au/heritage, downloaded 13 October 2021)
Three hundred hectares of the upstream impact area is within the Greater Blue Mountains World Heritage Area (ES page 32). (Incidentally, I found both Figures 7 and 31 impossible to read.) The ES states that this is 0.03% of the World Heritage Area - the implication being that such a small area cannot be significant. It is only a small percentage because the World Heritage Area is so large. It is three hundred hectares - a huge site in anyone's language. And it is not just any land. It is protected bushland.
It is inappropriate to adversely impact any World Heritage Area. These places belong to the world and should not be tinkered with by local, state or federal governments.
The New South Wales Government is not entitled to intentionally and significantly adversely impact the Greater Blue Mountains World Heritage Are.
3. The Regent Honeyeater
The Regent Honeyeater is classified as critically endangered under both federal and state legislation. The total population is estimated to be 350 individuals. The species is challenged by climate change and bushfires (including the 2019/20 bushfires). But the main reason for the species being critically endangered is habitat loss. If the species is to survive, protection of the bird's remaining habitat is essential. The Regent Honeyeater has very few breeding sites. One such site is in the impact area. To lose one crucial site could well lead to extinction of the species.
Both the Australian and New South Wales Governments have invested funds into the Regent Honeyeater recovery program. It is quite inconsistent for the New South Wales Government to consider funding a project which will destroy Regent Honeyeater breeding habitat.
4. Offsets
Offsets sound reassuring, but unfortunately they are rarely an appropriate response to lost biodiversity. The impacted area is crucial breeding habitat for the Regent Honeyeater which cannot be offset.
5. Conclusion
Please do not raise the wall of the Warragamba Dam. Please do not impact a World Heritage Area. Please do not impact any breeding habitat of the Regent Honeyeater.

Elizabeth Chase – Submission Against Raising Warragamba Dam Wall
October 15th, 2021

Dear Minister
I wish to lodge an objection to the raising of the Warragamba Dam wall. I am a Blue Mountains resident who goes walking regularly in the bush and I am concerned about significant negative environmental impacts that will be caused if the dam wall is raised.

Supposed benefits are not modelled / Alternatives are not explored
The supposed economic and flood benefits of raising the dam wall are not actually modelled in the EIS. Furthermore, alternatives to raising the wall have not been adequately canvassed – and since up to 45% of floodwaters come from areas outside of the Warragamba Dam catchment - a raised dam wall will not be able to prevent extreme flooding events in the Hawkesbury.

Flawed existing EIS / Lack of consultation / Limited assessments
I am concerned that the existing environmental assessment is flawed and limited for a number of reasons. SMEC Engineering does not have a good record with regard to assessing indigenous cultural and environmental impacts. They did not consult meaningfully with local Gundungurra Traditional Owners who claim that over 1541 identified cultural heritage sites would be flooded by the Dam proposal. This lack of consultation has been highlighted by the Australian Department of Environment and the International Council on Monuments and Sites (ICOMOS). As one telling example, only 27% of the area has been assessed with regard to any potential impact on Aboriginal Cultural Heritage. The threatened species surveys are inadequate and below guideline recommendations and, in addition, no post-bushfire surveys have been taken, which is a serious omission. The EIS is flawed and is no basis upon which to proceed.

World Heritage Convention / Loss of habitat / Threatened species
The Blue Mountains National Park is World Heritage listed and we have obligations to our children and grandchildren because of its outstanding universal value. It is disturbing that an estimated 65 kilometres of rivers and 5700 hectares of National Parks will be flooded if this Dam project proceeds. This wonderful place is home to the Kowmung River, the Camden White Gum, Grassy Box Woodland, the Regent Honeyeater and Sydney’s last Emu population. Once lost, our landscape, indeed our country, is diminished in ways that cannot be quantified.

The EIS is flawed, there are numerous alternatives which could be pursued. Please ensure that this project does not proceed – let’s treasure this unique place, for future generations.

Elizabeth Chase
87 St John’s Rd
Blaxland, 2774
PH: 0421997561

Hello, my name is Anda Banikos and I live in Fish Creek, South Gippsland, Victoria.

I am deeply concerned about the alarming rate of biodiversity loss in Australia. The proposed raising of the Warragamba Dam would add to this loss, due to destruction of habitat and contemporary breeding sites for critically endangered species such as the Regent Honeyeater.

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.”
e 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.

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.

I am opposed to the proposal by WaterNSW to raise the wall of the Warragamba Dam as a measure to reduce flooding to residents and businesses across Western Sydney. Considering that much of the floodwaters affecting these areas are coming from rivers outside the Warragamba catchment, increasing the height of the dam wall would not be very effective. However, raising the wall may encourage future unwise development on the flood plain. It would be better to avoid this by making it clear to developers that the flood plain is simply out of bounds for development, not only for safety reasons but also recognising that this deep alluvial soil in the area is itself an important asset and food growing resource.
Raising the dam wall will encourage further ill-advised development in vulnerable areas without providing any guarantee of future protection from flooding.

Environmental impacts
The Blue Mountains National Parks have been given World Heritage listing which is the highest possible international status and protection. This is due to the area’s biodiversity and ecological integrity. This means both The Commonwealth and NSW Governments are obliged to protect the Greater Blue Mountains World Heritage Area forever. It is not appropriate that the NSW government should be allowing any damage to this precious area. .
Raising the Warragamba Dam wall will damage on the environmental and cultural values of the catchment. It will affect some 5,700 hectares of National Parks, including the 1,300 hectares of World Heritage Area. There are also more than 60 kilometres of wild rivers and thousands of Aboriginal sites and places of cultural significance. The area that will be lost contains some of the best remaining grassy woodland ecosystem in NSW, complete with populations of native animals like glider species, dingos, quolls, woodland birds including the Regent Honeyeater and Powerful Owls and many other Important native plants and animal species. Many people have volunteered previously to work in these areas on bushland projects to support the continuing health of species such as koalas, platypus and the Regent Honeyeater.

As Australia is a signatory to the World Heritage Convention it is required to protect the ecological integrity of the Greater Blue Mountains World Heritage Area.

The purpose of raising the dam wall is to hold water at a level up to 17 metres higher than the present dam. Once areas are inundated, even for a short time, all the
habitats, flora, fauna, cultural sites and soils within the inundation zone will be destroyed. It is problematic that the EIS relies upon biodiversity and cultural surveys conducted before the major wildfires of 2019/20, which burnt 81% of the Greater Blue Mountains. In those fires, many species may have been made locally extinct, and there has been no opportunity to properly assess the situation on the ground. New surveys are needed before the EIS can be seen as valid.
The Commonwealth Department of Environment and the International Council on Monuments and Sites have both pointed out failings in the assessment of the impact on the cultural heritage of the Gundungurra traditional owners. No consent has been obtained from the Gundungurra Traditional Owners although the work will impact their cultural heritage.
The Environmental impact assessment:
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. Biodiversity offsets are fraught, and very expensive. It is not possible to find and protect a "like for like" area to offset loss of further parts of the flooded Burragorang Valley. This is a unique place and no amount of reservations and plantings elsewhere can duplicate the special ecosystems that exist here.
My ancestors, the Gaudry family, came from the Burragorang, and their cultural heritage has long been lost or scattered, even their headstones. Perhaps it was warranted at the time to create a better water supply for many people. But to inundate much more land and heritage and natural beauty simply to reduce flooding in areas that should never be developed for housing is not warranted.