Warragamba Dam Raising

I am a resident of the Southern Highlands of NSW who has walked in the Blue Mountains World Heritage Area extensively and also in the Burragorang Valley, and has had the privilege of watching platypus in the waterholes of the rivers that will be periodically inundated if the proposal goes ahead.
I am also familiar though first-hand experience of the impact of flood events on communities and families, including the significant risks of flooding in the Hawkesbury system, so I have tried to keep an open mind about the proposal to raise Warragamba Dam for flood mitigation purposes, and have read numerous articles and reports to ensure my opinion is as objective as possible, including those published by Water NSW.
Through this process I have formed a view that, while the proposal may assist in moderating some major flood events, it is not certain to do so reliably, and it is not worth the negative impacts on the Blue Mountains World Heritage Area or on the cultural legacy of the Gundungurra First Nations people, who appear overwhelmingly opposed to the project. I think it should be remembered that these traditional owners were forced out of the entire Burragorang Valley within living memory, and in my view they have sacrificed enough for the water supply and flood management needs of greater Sydney.
Further, it seems quite clear that raising the dam would not be necessary if planning authorities including the NSW Government had been more responsible and had limited development on the floodplains of the Hawkesbury-Nepean valley rather than allowing developers to profit from placing families in harm's way. Having failed so spectacularly in what was arguably a moral duty, it is not right to seek to mitigate this risk by sacrificing thousands of hectares of world heritage wilderness, native habitat and indigenous cultural sites.
At the same time I have some sympathy for those who live on the downstream floodplains, and I would like to see mitigation measures explored that will not have these negative impacts upstream. My reading to date indicates such possibilities exist, and that they have not been adequately explored.
One report I read was the NSW Government's own report: Inquiry into Water NSW Amendment (Warragamba Dam) Bill 2018. This report gives the cost (around $10 billion) as a reason not to relocate residents below the 1967 flood level (page 9), however in consideration of the billions recently squandered by the Commonwealth on unnecessary corporate welfare in the form of JobKeeper payments to businesses that increased their profits during the pandemic, I'm not convinced this option should be dismissed so readily. The report also appears (on page 10) to suggest a reason to proceed with the project is reduced insurance premiums for downstream residents. I think it is highly offensive to tell the Gundungurra Elders that the loss of their cultural heritage is necessary to give people who made decisions to settle on the floodplain cheaper insurance.
My reading has indicated that many key stakeholders oppose the proposal or have significant reservations, including traditional owners, environmental experts, local governments on both sides of the area (Blue Mountains and Wollondilly), Commonwealth Government agencies, experts in emergency management, the head of the Insurance Council of Australia, and a great number of people familiar with the proposal and the area it will damage.
There are also numerous concerning mainstream media reports of less than entirely transparent conduct by the NSW Government and its agencies, principally Water NSW, in relation to the proposal, including pressuring ecological consultants to downplay ecological impacts, failure to adequately consult traditional owners and seeking to avoid paying compensation.
I have no doubt that there is a need to address the significant risks of flooding to downstream communities, but my research suggests this proposal is viewed by many experts as fundamentally flawed. It is also possible that it may, by encouraging further development on flood-prone land downstream, actually increase risk. I note that the EIS executive summary appears to dismiss the option of disallowing future development on flood-affected land downstream, which would appear to be an obvious and sensible first step, on the basis that some developments have been approved and land zoned for development (page 25). This was frankly quite shocking to read, and I think most people would agree that the NSW Government should and must immediately rescind all such approvals and review all land zoning in flood-affected areas in the Hawkesbury-Nepean basin. It is appalling that this important and eminently sensible step would not be taken on the apparent grounds that it might cost some developers and speculators some future income.
I would like to see the projected cost of this project (hundreds of millions - before the cost blowouts we have come to accept as routine for state projects) instead spent on risk mitigation measures that do not have these negative impacts, and may in fact have positive impacts on those downstream communities. Improved access to information and warnings and well-planned, high-capacity evacuation routes would seem a good place to start, and I was somewhat encouraged to read in the Inquiry Report that these are being pursued. However I also think it would be sensible to consider some relocations of the most at-risk residents, with appropriate education and consultation of those communities.

I strongly object to the proposal to raise the Warragamba Dam wall. It seems inconceivable to me that the NSW Government would seriously propose an action that will potentially have major and irreversible impacts on the Greater Blue Mountain World Heritage area and a range of threatened fauna and flora species. The landscapes that will be inundated and lost forever – 4,700 hectares of National Park and 65 kilometres of wild rivers are precious to not only the indigenous communities whose country it is but to all Australians who, like myself, find value and identity in our remote, unique bushland.
While I know there are rare plant species and animals such as the Koala that are threatened by this proposal, the main driver for my submission is the fate of the Regent Honeyeater. This is a beautiful bird that I have been lucky enough to see in the wild just once in my thirty years of birdwatching. However, I seriously doubt that the coming generations will even have that opportunity. According to the draft EIS, the impacts of the dam raising project on the current breeding habitat for the Regent Honeyeater “cannot be avoided or minimised”. With so much of its habitat lost through the 2019-20 bushfires, each breeding site is invaluable. During the assessment of the project, according to Birdlife Australia, a total of 21 Regent Honeyeaters including active nests were recorded in the impact area. As such this project could be the final ‘nail in the coffin’ for what is thought to be as few as 350 individuals left in the wild. This project would help lead to the extinction of this species in the wild.
There has been serious investment by NSW and Australian Governments in recovery efforts including captive breeding and release – indeed a Hunter Valley release was witnessed not so long along by Minister Matt Kean. Now what appears to be some of the best breeding habitat for the Regent Honeyeater is proposed to be obliterated.
Nor will the offset strategy proposed be likely to be effective according to experts in Birdlife Australia. They claim that there is no evidence that the breeding habitat of the Regent Honeyeater can be successfully offset and any offsets would be unlikely to provide direct benefits to locally affected populations or the species as a whole.
Once again, an irreplaceable landscape and the species and cultural artefacts within it will be wilfully destroyed. It is the incremental loss of habitat through clearing, mining, logging – and fire – that has created such a dire situation for a beautiful, unique Australian bird that once was seen in its thousands.
The raising of the Warragamba Dam wall is at a cost that the communities of NSW should not have to pay. Please reconsider this project and be fully cognisant of the damage it will do to the natural ecosystems of NSW and the UNESCO World Heritage.
Yours faithfully

Judith Christie

I am objecting to this project as I am concerned about the loss of habitat to our native animals, for benefits that are unclear.
Additionally, as per many articles in the media, ie https://www.theguardian.com/environment/2021/nov/08/ecologist-so-troubled-by-warragamba-dam-wall-environmental-impact-statement-she-resigned the NSW government is failing to listen to the advice of experts that the government has engaged.

Construction projects, especially at this scale cannot be at the cost of our natural environment for current and future generations.

Listen to your own experts.

Sincerely, Patrick Saunders

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, including the Regent Honeyeater, Xanthomyza phrygia.
The Regent Honeyeater is listed as Critically Endangered at both State and Federal level, with as few as 350 individual birds remaining in the wild. During the assessment of the project, a toral of only twenty-one (21) Regent Honeyeaters, including active nests, were recorded in the impact area.
Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/2020 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.
Any breeding habitat is considered habitat critical for survival of the species under the National Recovery Plan for the Regent Honeyeater and the Plan states that “It is essential that the highest level of protection is provided to these areas and that enhancement and protection measures target these productive sites
It is therefore completely unacceptable and totally inconsistent with the precepts of the National Recovery Plan for any loss or degradation of breeding habitat to occur.
The destruction and degradation of any contemporary breeding site for the Regent Honeyeater is incongruous with the time and money that the Federal and NSW Governments have invested in the Recovery Program, including the Regent Honeyeater Captive Breeding and Release Program
The draft EIS itself concludes that the project poses potential significant impacts to contemporary breeding habitat for the Regent Honeyeater that cannot be avoided or minimised.
There is no evidence that breeding habitat for Regent Honeyeaters can be successfully offset. Offsets are rarely an effective replacement for loss of biodiversity, and any offsets would be unlikely to provide direct benefits for both the local affected population and the species as a whole.
The draft EIS also mentions that on some occasions flooding of downstream areas occurred even when the Warragamba Dam was not at full capacity, being caused by flows from rivers which bypass the Dam.
In view of this fact, and that flooding from the Warragamba Dam is not a frequent occurrence, I submit that the raising of the dam wall should not be permitted, and other downstream mitigation measures be investigated.

Please see attached submission.

I object to the development for a number of reasons. Firstly, there has been inadequate consultation with community (I am a Wollondilly resident and haven’t been consulted, and I don’t know of any residents who have), suggesting the State Government has made the decision to proceed without genuine engagement with the community. The period for public submissions is totally inadequate given the size of the document and technical jargon and data (even with extension of deadline). I have 2 university qualifications and it would take me months to wade through and interpret the document fully. On my first reading I have serious doubts re the rigour and accuracy information pertaining to impacts to the Blue Mountains World Heritage area, and the scope of field studies into impact on sites of indigenous heritage. I share the concerns of Aboriginal groups about the development. I am concerned about the lack of supporting evidence as regards impact on threatened flora and fauna. I note evidence provided to a parliamentary committee by several experts that their reports were edited, amended, or had sections omitted in order to present a picture more favourable to the development (Sydney Morning Herald 9.11.2021). Ecologist Rachel Musgrave reveals pressure from WaterNSW to ‘water down’ (my words) her report by modifying terminology to suggest less risk to threatened plant and animal species. SMEC’s refusal to comply with Ms Musgrave’s subsequent request to remove her name from the report is condemned. Ross Crates indicates sections of his report were omitted, diluted, or amended, again apparently suggesting reduced impact to biodiversity and creating a report more favourable to the development. In the interests of transparency and credibility, the government must make public all changes made to the draft EIS, so we are fully aware of what has been amended, omitted, or altered in the final version. In the absence of this being clearly communicated, one can only draw the conclusion the EIS has been ‘massaged’ in favour of the proponents. This behaviour casts immense doubt over the credibility and independence of the entire EIS process, and would on the face of it, appear to be highly questionable and most likely unethical.
As regards the rationale for raising the dam wall, I question government’s assertion that the development is primarily for the purposes of flood mitigation, and suspect property development downstream is the primary motivating factor. A broader discussion around the use of floodplain area for development, which incorporates innovative thinking about moving development to less flood prone areas in future, is required.
Thank you for reading my submission, unfortunately I suspect the decision to raise the dam wall has already been taken by the State Government and public submissions critical of the EIS and the development will be disregarded.

I strongly oppose the proposal to raise the Warragamba Dam for the following reasons:
1) It will lead to the flooding and inevitable degradation of the surrounding natural environment, including vast parts of the Blue Mountains World Heritage Area and 65 kilometres of wild rivers such as the pristine Kowmung river.
2) It poses a direct threat to the area's ecosystem and biodiversity of flora and fauna, including the future survival of the critically endangered Regent Honeyeater as impact upon the Honeyeater’s breeding habitat cannot be avoided or minimised according to the project's EIS.
3) It will cause further destruction of Indigenous sites that are culturally and historically significant to the Gundungurra people.
4) The project is in contravention of Australia’s binding international responsibility to protect and conserve World Heritage Sites and may result in the Blue Mountains World Heritage Area being stripped of its World Heritage status.
5) The inadequacy, lack of transparency and lack of integrity of the project's EIS to properly survey the full environmental consequences, particularly in the context of climate science, recent bushfires, and Indigenous cultural heritage.
6) The period permitted to make submissions is insufficient to properly satisfy governmental accountability given the length of the EIS.
7) Ecologists, Indigenous people, Wollondilly Shire Council, Blue Mountains City Council, the insurance industry, UNESCO, and the National Park Association are amongst the many who have actively opposed or expressed concern about the project.
8) The concern that the project is motivated by future profit in developing the area rather than by the risk of flooding to people's homes.
9) Our collective moral responsibility to preserve natural sites for the benefit of future generations.
10) No amount of monetary compensation can "offset" the destruction of an irreplaceable environment.

My objections are detailed in the attached document

To whom it may concern,
I was alarmed to hear that the NSW Government plans to raise the Warragamba Dam wall and as a Blue Mountains resident for most of my adult life, I am writing to record my opposition to this proposal.
The Blue Mountains is a World Heritage Area with unique plants and animals many of which would be put at risk by this proposal.
Not only will complex eco systems be affected by flooding but significant cultural heritage of First Nations peoples will be lost forever.
How is any of this consistent with our stewardhip of this area of international significance? And for what? The raising of the dam wall cannot solve the problems of flooding of the plains downstream. Other solutions must be found to avoid the devastating effects of flooding in the Nepean-Hawkesbury. These are not new problems in an area that is a flood plain and which is not suitable for an extension of housing development.
I hereby add my name to those of others who strenuously oppose this flawed proposal.

To whom it may concern,
I am a member of the Springwood Bushwalking Club and I have walked in the areas that will be affected by the raising of the dam. I do not want the dam wall raised and believe that it should not be raised on the basis that it will detrimentally affect a National Park and a UNESCO listed World Heritage area.

To whom it may concern,
On 4 January 2020 Penrith was the hottest place on Earth at 48.9 C at the same time as bush fires were raging through NSW. Building more housing and increasing suburban heat in this already dangerously hot environment is criminally insane. The NSW Government must implement suburb greening initiatives to reduce the heat and make Penrith safe for families trying to live a normal life.
Raising the wall will not prevent flooding because floodwaters will come from other areas upstream. The existing and new families who would move to this hellish climate will also be flooded. As shown in Australia and world wide floods are getting worse. Flood remediation is another project the NSW Government should be addressing to improve the life of existing Western Sydney residents.
When previous governments proposed raising the dam wall common sense prevailed and the plans were shelved. With our intense awareness of climate change, in this case relating to the heating and flooding of Australian homes, the proposal is now even more unreasonable.

To whom it may concern,
I live in the Blue Mountains and often enjoy walking in the southern part of the National Park and World Heritage area.
I am most concerned about the proposal to raise the wall of Warragamba Dam.
The resulting rise in water levels upstream of the wall, will destroy parts of the World Heritage area and National park
- vegetation, including rare and threatened species
- habitiat for native animals and birds including endangered species which we should be protecting
- cultural heritage sites. Surely the NSW government does not want to follow in the steps of Rio Tinto and receive the same worldwide condemnation.
Correcting the past errors of allowing residential housing on a known flood plain should not come at the expense of our natural environment and cultural heritage. Further inappropraite development on the Nepean and Hawkesbury flood plains should cease immediately.
The Warragamba Dam was built for water storage for Sydney, which it provides admirably, not for flood mitigation purposes.
I object to the proposal to raise the Warragamba Dam wall.

To whom it may concern,
Submission to NSW Department of Planning, Industry & Environment: Objection to the Raising of the Warragamba Dam Wall
I object to the raising of the Warragamba dam wall and support the Wollondilly Council’s efforts to oppose it on the following grounds:
First, It does not provide a long-term solution to future water needs. If there is a real prospect of future water shortages, the solution is not to be found in a larger dam but in tertiary treatment plants. These are proven cost-efficient systems that provide other benefits, including waste reduction, and self-sustaining energy production that can assist Australia in reducing its carbon emissions. Water reuse has to be the focus of any developments in increasing water security, such as that adopted by Israel where nearly 90% of its water is now recycled. If water security is an objective of the project, the dam wall proposal utterly fails on this measure.
Secondly, It does not protect current or future residents from flooding. If the aim of Water NSW is to mitigate flood risk in the Hawkesbury-Nepean valley, raising the height of the wall is not a solution as "no dam can stop the largest of floods, so this proposal will put more people in harm’s way regardless of whether the dam wall is raised”. Indeed, it only changes the risk in that while it might make a spillover or flooding event less likely, it would make the devastation that much greater because of the increased load of water. If the flood risk is great enough to warrant raising the dam wall at taxpayers’ expense, it beggars belief that developers are to pocket the profits from selling yet another 134,000 dwellings to unsuspecting buyers. The original error of allowing anyone to build there is further compounded. Given the costs of other flood incidents and the unknown risks posed by climate change, insurers will most certainly take it seriously and most, if not all, residents and new purchasers will find they have uninsurable properties.
Thirdly, raising the wall 'would flood 50 Aboriginal heritage sites’, which clearly covers only those that are known. There are likely to be many others yet to be identified. Given this area has been listed on UNESCO’s World Heritage list in recognition of its universal value, it is an unacceptable trashing of aboriginal cultural heritage. The rock art sites, burial sites and ochre deposits of the Gundungurra, Dharawal and Dharug people are of immeasurable value to us all.
It threatens native flora and fauna already under pressure The Kowmung River, declared a ‘Wild River’, protected for its pristine condition under the National Parks and Wildlife Act 1974; unique eucalyptus species, e.g., the Camden white gum; ecological areas of grassy box woodland and the habitats of the endangered Regent Honeyeater and a remnant emu population.
In summary, the alternatives are to buy back dwellings already at risk, prevent further housing and infrastructure development, and invest in tertiary water treatment plants. Let us not compound the original error of allowing people to live in harm’s way but seek better and more long-term alternatives of water security and flood mitigation.

To whom it may concern,
I grew up on the Hawkesbury Flood Plain. On a school excursion I saw Warragamba Dam under construction. Like the infamous 'war to end all wars' statement about World War I, Warragamba Dam was meant to end all flooding of the Hawkesbury District as well as supplying fresh water. The NSW Government insists migration and population growth in the Sydney Basin. This is clearly unsustainable both in terms of housing on flood plains and providing a reliable water supply. There is also the obvious and evident destruction this approach wreaks on the natural environment and its essential roles in ecology, and interrelated human, Aboriginal Australian, flora and fauna heritage, health and wellbeing.
Please consider my honest and heartfelt blog post and my accompanying photo essay. I have produced them from a position of direct experience and observation, education and research.
My photo essay on Warragamba Dam and housing estates on the Hawkesbury Flood Plain: https://www.michaelmangold.com.au/sydney-on-the/rocks
My blog post on Warragamba Dam and housing estates on the Hawkesbury Flood Plain: https://www.michaelmangold.com.au/blog/2020/sydney-on-the-rocks
The NSW Government's proposal to raise the height of Warragamba Dam is a case of policy expediency over vision, especially in this Anthropocene Era of Climate Change and pollution.

To whom it may concern,

The habitat of the flora and fauna must be protected and prioritised. Nothing is more important. This wilderness is not ours to take. It's existence secures our existence. Leave it be.

To whom it may concern,
I completely disagree with any plans to raise the water capacity of Waragamba Dam and flood the national park. There simply must be a stop to overdevelopment in Sydney instead.

To whom it may concern,
I am very concerned about the proposal to raise the Warragamba Dam.
I understand that the amin reason for raising the dam would be for flood mitigation purposes for the Hawkesbury Nepean valley. I am aware that the catchment for the dam represents only about half of the potential probable floodwaters for the the system. Surely there are other methods of management that can control potential flooding more effectively. Ironically, I arrived to live in the Blue Mountains over ten years ago when Brisbane was flooded by the inability Wivenhoe Dmas 200% level was breached. I believe that the costs to the environment are not worth the imacts that will be cuased by raising the dam wall.
The cumulative impact on the World Heritage values of the area would be serious. This is especially the case when it is acknowledged that this is yet another human impact on the area. Noise from as yet undisclosed flightpaths, tunnelling in the upper mountains, human induced fire damage all compoound to cause stress on our unique environment.
I do hope that a recommnedation is made to employ flood mitigation methods other than raising the Warragamba dam wall

To whom it may concern,
I am writing to express my opposition to the plan to increase the capacity of the Warragamba damn.
I live in the Blue Mountains and think any plan to destroy our World Heritage listed areas is unthinkable.
It is more important than ever to protect our natural resources and environments - this plan goes against everything that is important in protecting our natural world and the earth we rely on to sustain us.
Please really think about the irreversible damage that this plan would have and make the responsible decision to look after our beautiful country instead of destroying it for cheaply made apartment blocks and the interests of developers.

To whom it may concern,
I oppose the extension of the dam wall and further enlargement of the Warragamba dam system.
1. I live in Leura in the Blue Mountains and can on a good day, see from where I live the likely area to be affected.
2. I moved from Melbourne to Sydney over 42 years ago. One of the key motivational aspects for the move was to spend more time walking and exploring the vast wilderness of the Blue Mountains world Heritage region. I spent many weekends exploring and walking, hosting friends from NSW and interstate, who loved the region.
3. I remain open to the unique and rare gifts offered on a daily basis from this wilderness. Every day in this area is like a new experience. The air, the complex sky, the unpredictable weather, the fabulous intense westerlies, the flora changing 365 days per year, are all part of this unique ecosystem.
4. It is almost trite to simply point to and talk about global warming and environmental degradation, given the raised level of tolerance to these problems from marketing spin and short attention span of media and analysis. What is not trite however is to the constant need to address the practical, functional and evidence-based observation of what will happen in the event of the raising of the dam wall and additional environmental destruction. As addressed below, there is no need to do so for the purposes of water supply, no need to do so for the purposes of safety from floods caused by global warming and human aggradation, or any other factor. It appears rather that financial interests of property owners/developers and real estate interests are dominating the debate.
5. Of course we need more space and access to housing for the growing population however, this does not have to be in a floodplain below the dam waters, and at the cost of environmental destruction. This area had been identified as a risk for over a century. Raising the dam wall does not ameliorate the risk, accommodating peoples housing and social needs can be met without sacrificing world Heritage listed environment and wilderness.
6. For the sake of the next generations and in the public interest, I urge you to oppose raising of the dam wall.
7. Much of the material on WaterNSW site appears to be ideological and party politically driven rather than truly independent assessment. For example, in the “biodiversity impact” section, suggesting that destruction of some of the environment can be overcome by purchasing other land misses the point completely. Purchasing other land the housing people can be done without the destruction of unique rare area. Please reconsider.
From the information at hand it appears that:
8. The engineering firm (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.
9. In contrast to the claimed Biodiversity Impact review, No post-bushfire field surveys have been undertaken following the severe fires during the summer of 2019/20 devastated 81% of Blue Mountains Heritage Area.
10. Only 27% of the impact area was assessed for Aboriginal Cultural Heritage.
11. Threatened species surveys are substantially less than guideline requirements. Where field surveys were not adequately completed, expert reports were not obtained.
12. No modelling of the stated flood and economic benefits of the dam wall raising are outlined in the EIS.
13. 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.
14. The Blue Mountains World Heritage area is not just a world class National Park, 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.
15. 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. This includes:
16. The Kowmung River - declared a ‘Wild River’, protected for its pristine condition under the National Parks and Wildlife Act 1974;
17. Unique eucalyptus species diversity recognised as having Outstanding Universal Value under the area’s World Heritage listing such as the Camden White Gum;
18. A number of Threatened Ecological Communities, notably Grassy Box Woodland;
19. Habitat for endangered and critically endangered species including the Critically Endangered Regent Honeyeater and Sydney’s last Emu population.
20. Over 1541 identified cultural heritage sites would be inundated by the Dam proposal.
21. 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.
Alternatives to raising Warragamba Dam wall
22. 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.
23. 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.
24. 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.

To whom this may concern,

We are extremely concerned with the release of the Environmental Impact Statement for the Warragamba Dam wall raising. Our founder, Frank Austin ‘Paddy’ Pallin was an original member of the Sydney Bushwalkers Club who helped to develop the protection rights of our current day National Parks. Since then, our foundation and business has continued to promote and encourage the protection of our wild places, including the Kowmung Wild Rivers and Kanangra Boyd National Park.

The systematic failures in the proposal to raise the Warragamba Dam wall have been highlighted in the newly released Environmental Impact Statement (EIS). Raising the dam wall will inundate 6,000 hectares of pristine, World Heritage-listed Blue Mountains National Park, home to a variety of endangered species including the Camden White Gum, Regent Honeyeater and Sydney’s last Emu population. The EIS has failed to deliver acceptable threatened species surveys; where field surveys were not adequately completed, expert reports were not obtained.

Our Country and State’s natural environments were placed under immense pressure during the 2019/20 bushfires, with 81% of the Blue Mountains Heritage area devastated during the season. We find it highly disturbing that no post-bushfire field surveys have been undertaken to determine the damage and need for protection of our threatened flora and fauna.

With the inundation of the lower section of the Kowmung River, over 1,541 identified cultural heritage sites will be minimised to collateral if this proposal were to go ahead. The Gundungurra Traditional Owners have not given any form of consent or support to this proposal, they are at risk of losing key heritage sites of significant value and connection. How has SMEC Engineering been allowed to undertake the cultural and environmental assessments when they have an established history of abusing Indigenous rights, recently being barred from the World Bank?

The NSW Government has stated in it’s principle document advocating the dam proposal that it plans to allow 134,000 people to reside on western Sydney floodplains after the dam is raised. They’re saying this scheme will protect houses in the Hawkesbury-Nepean valley from flooding. Yet, almost half of the flooding in the valley comes from waters that are not controlled by Warragamba Dam. The Environmental Impact Statement shows no modelling of the stated flood and economic benefits of the dam wall raising.

Several of the government's own agencies have condemned the proposal. National Parks and Wildlife have stated the proposal has failed to address the way raising the dam wall will impact on species and ecological communities affected by last year’s bushfires.

The Commonwealth Environment Department said the evaluation failed to consider how raising the dam wall would impact on iconic species like the platypus; going so far as to tell the state government to redo the entire heritage assessment.

Heritage NSW said it did not properly consider cultural heritage values of the surveyed area, nor was there sufficient consultation with traditional owners.

Alternative flood mitigation measures have been proposed by respected academic authorities for existing communities that do not require raising the dam wall. Alternatives include providing alternative flood storage in Warragamba Dam by lowering the full storage level by 12 metres, which would result in 795 billion litres in airspace for flood control.

Previous government investigations into flood mitigation strategies have found that effective evacuation is the only measure that guarantees a reduced risk to life in the Hawkesbury-Nepean Valley. Yet, the NSW Government dismissed a critical program of road upgrades to allow evacuations at higher flood levels due to the cost in the 2017 strategy.

Paddy Pallin does not support the raising of the Warragamba dam wall and we are hugely disappointed that our government is choosing profits and development over the safety of their people and World Heritage wild places. This Environmental Impact Statement highlights the systematic issues within this project and we believe the integrity of the environmental assessment is fundamentally flawed and should not move forward any further until a review is completed.

We appreciate your time to reflect on our concerns and we do hope our government does the right thing.