Warragamba Dam Raising

To whom it may concern,
Dear Sir/Madam,
I am deeply concerned by the proposal to raise the Warragamba Dam wall. If it goes ahead, it will be the largest destruction of conservation land ever proposed in NSW. The NSW Government is right that flood mitigation needs to be considered for Western Sydney and in particular, the Hawkesbury Nepean Valley but raising the dam wall is an insufficient solution and better tackled by exploring alternative options.
World Heritage status for a natural area implies an area of outstanding and universal value, accompanied by a solemn promise by our leaders to protect that area forever. Only 16 years after gaining World Heritage status, the NSW Government first proposed the raising of the dam wall. Does World Heritage status have no meaning anymore?
This proposal will effectively devastate 5,700 hectares of National Park, 1,300 hectares of World Heritage area, degradation of over 60 kilometres of wilderness rivers, loss of hundreds of Aboriginal sites, impact on native species as well as driving threatened species to extinction and over $2 billion in biodiversity offsets that would need to be found to compensate for these losses. Clearly, the outstanding value of this natural area far surpasses any potential gains in raising the dam wall for flood mitigation, particularly that the Warragamba catchment contributes around half of the flood waters to the Hawkesbury Nepean Valley.
The Environmental Impact Statement (EIS) is also flawed in its data gathering and analysis. This document has underestimated the real damage and impacts to the area that will be flooded, as field work has been woefully inadequate in assessing 65 kilometres along the watercourse. The report also omitted areas of flood damage during the biodiversity offset valuation thereby not providing a realistic appraisal of the damage and impacts. Furthermore, only about ¼ of the impact area was assessed for Aboriginal cultural heritage.
I strongly urge the NSW Government to show true leadership on this matter and explore alternative options for flood mitigation. A good place to start is to review policies on urban planning in flood zones and not allow development in floodplain areas. When the NSW government assessed flood control options, it only evaluated the options where it would reduce the costs of flood damage vs capital costs of implementing flood measures. I urge the NSW Government to consider the triple bottom line in this issue: the environmental, social and economic costs versus benefits NOT just the economic. Furthermore, how will new residents feel when they purchase property in the floodplain, only to experience at some point in time, flood damage to their property, which is inevitable. The major tributaries of the Hawkesbury catchment contribute nearly half of floodwaters and these are not controlled, not to mention the challenges of the natural landscape of narrow sandstone gorges that plug the catchment causing backup of floodwaters. It is therefore ethically irresponsible to create a false sense of security for people that raising of the dam wall will solve the flooding challenges of this catchment.
I look forward to your reply.

This is not clever. The increased probability of high rainfall events, the flow rate of the most recent dam overflow (measured in Sydney Harbour volumes), the increase in energy levels of overflow at increased wall height, all add up to the potential of future catastrophic floods on the Hawkesbury river flood plain. The loss of precious land above the current dam level will include, inundation of the lower Kowmung River, threatened plant communities and rare species, and a reduction of critically endangered Regent Honeyeater habitat. The plan has not beeen or is ever likely to be approved by the Gundagurra traditional owners of the land and they stand to lose many cultural sites of outstanding significance. I cannot understand why a comprehensive EIS, that would have identified all of these points was not implemented. Surely there is enough information available in the scientific literature to detail the hazards of raising dam wall levels in areas where high rainfall is experienced. I must seriously question the level of competence of those that undertook the EIS and engineering studies associated with this project, and I must also question the motives of those that iniated the project, as it smells of a conflict of interests.

To whom it may concern,
I am writing to you to ask you to stop the raising of Warragamba Dam.
With climate change and deforestation the lack of flora and fauna we need more control over our resources not a blatant engineering response.
If water cost more to use maybe it would be more respected.

There must be another way to deal with water storage and use that does not destroy glorious bush land, threaten ecosystems, impinge on tourist vistas and totally ignore the heritage and culture of indigenous people. Please find it.

To whom it may concern,
I am writing to ask the minister to scrap the proposed raising of the dam wall at Warragamba.
It seems clear that raising the wall will allow flooding of vast areas of the Colong wilderness and potentially the World Heritage listed Blue Mountains national park, with associated species loss, habitat destruction and loss of Indigenous sites.
It is also likely that raising the wall would have minimal impact on reducing severe flooding on the Hawkesbury floodplain. Modelling i have seen suggests only a reduction of around 1 metre, with a severe flood still impacting life and property in much the same way as at present.
The financial cost of raising the wall is also extreme, especially given its destructive effect on wilderness and limited potential benefit.
I call on the NSW government to scrap the dam wall raising and redirect funds to better protect the floodplains, including buying out existing developments and stopping housing construction in badly affected areas.

To whom it may concern,
• 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.
• 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.
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.
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:
• 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.
• Over 1541 identified cultural heritage sites would be inundated by the Dam proposal.
• 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.
• 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.
• 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.
• 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 it may concern,
I am opposed to the raising of the Warragamba Dam Wall.
Raising the wall will flood World Heritage Wilderness and destroy Aboriginal sacred and cultural sites. This cannot be allowed to happen.
Also, surely the 3.5 billion dollars allocated for this destructive project could be much better spent supporting people and communities who are struggling, particularly after the bushfire, floods and the pandemic of the last few years.
I urge you to abandon this misguided project. There are better alternatives which don't have the enormous cost of putting our Aboriginal and World Heritage at risk. Don't destroy our priceless gifts.

To whom it may concern
I am the Honorary Secretary of the Clarence Environment Centre, and organisation that has maintained a physical presence in Grafton for more than 30 years, with a proud record of environmental advocacy.
As the former Premier of NSW, Bob Carr, famously said, "We move beyond last century's solutions. Building a dam would be an expensive, ineffective response - it would take years to build and even longer to fill, not to mention the damage done to the surrounding farmland and natural areas.”
The proposed raising of Warraganba Dam is no different, except it is irreplaceable natural bushland that will be lost, and the only possible winners appear to be those speculative developers that will rush to turn the Richmond valley into more concrete suburbs.
Another well-known politician, Malcolm Turnbull, also pointed out, as then Minister for the Environment, that "It is important to note that freshwater flows through catchments or into the ocean is an essential element of downstream ecosystems.”
There is no real justification for raising the dam to prevent downstream flooding as is claimed.
The cost would be enormous and the benefits few. Sydney has a desalination plant as back-up and the money would be better spent developing tidal or wave energy to produce clean reliable renewable energy to run it on those rare occasions when it is needed.
There are a long list of other reasons against the building of dams which are less relevant given the dam already exists. However, raising the dam would simply exacerbate those negative impacts, and increase to long-term chances of dam failure, something that would be truly catastrophic.
Dam decommissioning is occurring all around the world as enlightened nations realize the environmental and social damage they have caused, and economic impacts they have had on industries and communities relying on natural river flows.
Therefore, we are strongly opposed to any raising of the Warragamba Dam wall.

To whom it may concern,
I have been a resident of the Blue Mountains for close to four decades. It is a place I love for its natural beauty, birdlife and peacefulness.
In regards to the proposed raising of the Warragamba Dam wall I am concerned for a number of reasons:
• The EIS is flawed, putting the ecology of the area at extreme risk, and thus it cannot be trusted
• Unique and irreplaceable places, flora and fauna will be affected, including the critically endangered Regent Honeyeater
• Significant Gundungurra cultural sites will be lost, without the consent of the traditional custodians
• The raising of the dam wall will not prevent flooding in the Hawkesbury-Nepean Valley, though it will enable a development boom, indicating that the proposal is in fact about money-making, not flood mitigation
I strongly oppose the raising of the dam wall.
At a time when the natural world is at such risk from climate change, over-development, and countless other human incursions, we must tread carefully and act with extreme caution. We must show respect for the natural world by limiting any further development, and doing all we can to protect the wild places that remain. We must also show respect for the traditional custodians and their sacred sites, which give us a link to, not only our own history, but to a history of deep time, which has much to tell us about how we should live on this planet.

To whom it may concern,
I have sincere concerns about the plan to raise Warragamba Dam. As a resident of the Blue Mountains, and someone committed to the preservation of the environment, I lodge this submission.
I am most concerned about the native flora and fauna. The Blue Mountains is a national park, meaning that it holds significance to the nation and to the Australian and wider world's ecosystem. This designation should provide protection to the area. This plan is in contradiction to this preservation and sets a dangerous precedent.
We already know that large numbers of flora and fauna are in danger of extinction due to logging, urban sprawl and the recent devastating bushfires, this plan could further endanger these species. I am particularly concerned for the future of koalas who after the recent bushfires, need support and care, not to have more of their homes destroyed.
I am also concerned about the impact on local indigenous cultures, who are in desperate need of Australians and government organisations to stand up for them and protect their culture. We are so close to losing all of that rich and important history. This is a real opportunity for the department to show their respect for First Nation people.
I will be honest - I don't know what the solution is for this flooding problem. But surely there is a better way that protects this important ecosystem, and I trust the department will consider all aspects of the issue before making a decision.

To whom it may concern,
The Blue Mountains is an area so special that it has been granted World Heritage status. It has been a special place for traditional custodians for millenia.
Yet raising the wall of the Warragamba Dam is being considered - an act which would flood the valleys, destroying both heritage and environmental values that exist nowhere else on the planet.
SMEC Engineering, who were commissioned to assess the cultural and environmental values, have been barred by the World Bank for previously ignoring the rights of First Nations peoples. It should not be up to an engineering company to tell traditional custodians what is or isn't Aboriginal heritage. Their report is partial and inadequate in the areas of threatened species surveys, flood modelling, and a detailed cost beneift analysis of raising / not raising the wall.
Raising the wall is not the only solution to flood mitigation. A more cost-effective, less harmful combination of multiple options would be a better alternative - yet this alternative was not assessed in the Environmental Impact study. Finally, research has shown that about 45% of floodwaters are derived from areas outside of the upstream Warragamba Dam catchment which 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.
For these and other reasons I oppose the proposal to raising the dam wall. Many other citizens are also opposed, especially the Gundungurra traditional custodians who don't want over 1500 of thier precious sacred sites destroyed and inaccessible forever. If you look after country, country looks after you. If country dies, people die. This I know to be true.

To whom it may concern,
As Blue Mountains resident I love living in the World Heritage area. We regularly bushwalk in the area. During lockdown we were fortunate to have the whole BMCC LGA to explore, it really is a special place. I would hate for the world heritage listing to be stripped away from us. Every day we appreciate the birds and wildlife that we are so fortunate to share this place with.
Prior to living in the Blue Mountains City Council we lived in the Hawkesbury City Council region, which is also part of this Greater Blue Mountains area. We stil have family that live in the area. Yes they were stranded in the floods of March 2021 but they live on high ground in the Kurrajong area & were fortunate to have plenty of supplies to get them through.
I oppose the dam wall raising and the over development of the flood plains in Western Sydney. The EIS is flawed and wasn't a complete assessment of the potential impact.
Please don't go ahead with the raising of the dam wall there are alternatives that can be made.

To whom it may concern,

I live in the Kanimbla Valley in Lithgow City Council area, at the Coxs River. I visit the Blue Mountains around Katoomba and Kanangra regularly for bushwalking, including the Kowmung River.

Regarding raising the dam wall at Warragamba Dam for flood protection, I have two major concerns:

1) inconsistent justification of the proposal

2) substantial and irreversible ecological impacts in a world-heritage conservation area.

Re 1) The justification for the proposal (EIS Chapter 03) is not only based on protecting existing human settlements in the Hawkesbury River area, but also on projected population growth. The following are verbatim quotes from EIS Chapter 03:

“2. Establishing the different levels of urban development (population) that could occur in the valley by 2041 under current planning arrangements.” P. 3-2
“The Greater Sydney Plan sets a 40-year vision (to 2056) and establishes a 20-year plan to manage growth …”
“Given the forecast increase in population within the Hawkesbury-Nepean Valley,” p. 3-6
“The risk would increase as the number of people, properties and businesses in the catchment increases over time.” P. 3-10

However, this growth is not a given fact, it is a political decision that can but does not have to be implemented. Clearly, if there is a risk of flooding in the area, it would be injudicious, risky and irresponsible to put even more people in harm’s way.

Instead of sacrificing protected natural heritage, legislation should be put in place to prevent further growth of human settlement in this (and other) existing flood plains. Because this is in the hands of legislators, I regard the justification for the proposal as flawed and insufficient. Conservation of natural heritage (highest protection status GBMWHA) for future generations must be worth more than developing a flood plain for short-term benefit.

Re 2): 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.

Threatened species surveys are substantially less than guideline requirements. Where field surveys were not adequately completed, expert reports were not obtained.

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. Therefore, alternative approaches should be given more weight.

Kind regards,
Tommy Wiedmann

I accept the Department's submissions disclaimer and declaration
I have not made a reportable political donation in the past two years.

I am a resident of the Blue Mountains and I object to the proposal to raise the Warragamba Dam wall for many reasons.
I moved here for the purpose of enjoying and protecting the outstanding natural and cultural values of the area. This project will certainly damage the globally recognised values of the world heritage area.
I am aware that the Traditional Owners have voiced serious concerns about the negative and irreparable impact the wall raising will have on the ancient cultural heritage of the surrounding area, with something like 1200 sites in jeopardy. Why are their concerns being ignored by the government? That is unacceptable.
There are also numerous environmental concerns. The ecosystems, flora and fauna of the area have still not recovered from the devastating bushfires of 19-20 and the floods that came afterwards. We still don't know the full extent of the damage to the natural environment. Combine this with the ongoing, increasing threat of climate change and it is unbelievable to me that the government would even consider causing further environmental damage to the area.
Finally, the raising of the wall doesn't change the fact that it will rain, and rain falls where it wants, so the floodplain below is going to flood no matter how high the wall is. It's my understanding that it will be cheaper and more practical in the long-term for the government to buy back the land sold on the floodplain and simply choose to develop elsewhere.
Please work with experts to come up with a better vision for NSW. Sydney doesn't need more ill-conceived development - it's already an overdeveloped, dirty, smelly heat-sink. The government needs to invest more in improving our quality of life while rapidly decarbonising our cities and lifestyles. This means investing more in green spaces, encouraging people to live and work in the outer regions, public transport, sustainable green construction initiatives, more desalination plants and less destruction of our already struggling river systems.

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.
There appears to be a lot of interference to get ecologists to produce a report that Water NSW wants not an independent one. https://www.theguardian.com/environment/2021/nov/08/ecologist-so-troubled-by-warragamba-dam-wall-environmental-impact-statement-she-resigned
There does not appear to be evidence that raising the dam wall by the proposed amount will prevent future floods.
https://www.smh.com.au/national/nsw/higher-warragamba-dam-wall-would-not-have-halted-floods-experts-say-20210322-p57cwa.html
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.

Robert & Maria Pozza
29 Bold Street
RENWICK NSW 2575
27 Kerry Street
YERRANDERIE NSW 2787
Re: Warragamba Dam Raising
When the Metropolitan Water and Drainage Board acquired the property in the Burragorang Valley for the building of the Warragamba Dam, the valley people had no choice, they had to move away taking with them memories of their beautiful valley, family, friends, lifestyle and over one hundred years of history, my family and others were still living on the same land their family had owned for that time.
That history included the stories of major floods that came down the Wollondilly River, Nattai River and Cox’s River and how quickly the water would rise.
With the completion of the dam, they allowed years for it to fill, there was an extreme weather event, the dam was full by 1960/61
This will happen again and the raising of the wall will not save the new infrastructure built downstream on the pretext that the area will be safe.
The 150 years of European settlement and heritage sites upstream from the dam have been totally disregarded! Ex-residents and descendance still have strong ties to the Valley and their old home sites.
After attending a meeting of the Yerranderie Management Committee where Water NSW personal gave a presentation on the raising of the Warragamba Dam. I left with more questions than answers and extremely worried about the future of the area down- stream from the dam wall as they could not answer all of the questions asked and at that time had little knowledge of the area upstream from the dam.
They were going to get back to the Yerranderie Committee but that did not happen.
Refer to the submission from the Yerranderie Committee for further information and history.
Regards
Robert & Maria Pozza

See attached submission

See 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.
here 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.
t 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.

My objections to the proposed project are described in the attached document.