Warragamba Dam Raising

Dear Committee
I am responding to the Warragamba Dam raising wall proposal in a written submission with an attached document.
I object to this project for the following reasons-negative environmental and cultural issues, valid concerns raised by different organisations and agencies, systematic failings of the EIS process, community safety concerns and an attack on a world heritage site. There are alternatives that I strongly urge the government to explore further to reduce flooding of low-lying areas. Raising the dam wall will not completely solve the flooding issue and these communities will continue to suffer.

Please see attached letter outlining my concerns regarding risks to water quality.

The raising of the dam wall will cause irreversible damage to the environment, destroying habitat, wildlife, and many sites of great cultural significance to the indigenous community. The better way to minimise impact of flooding would be to restrict development within the floodplain.

• The National Parks Association – Milton Branch objects to the proposal to raise the wall of the Warragamba Dam.

• The reasons for objection are set out in the attached submission. In summary the key objections are:
o the project is fundamentally flawed;
o it will lead to intolerable environmental impacts;
o there is no consent from traditional owners and a lack of protection for cultural heritage;
o the Environmental Impact Statement is unreliable and inaccurate;
o and the concept of comparable biodiversity offsets for a World Heritage Listed area is fundamentally unsound.

Submission: Warragamba Dam Raising Project Environmental Impact Statement
To Whom it May Concern,
I am making a submission on the Environmental Impact Statement for the proposed raising of the wall of Warragamba Dam.
I live in Sydney and have spent all my life walking, canyoning and holidaying in the Blue Mountains. The place has enormous significance to me and my family who, over several generations, have enjoyed the unique beauty of its landscapes, waterways, and its diverse native flora and fauna. The Blue Mountains is a place with a wild and rugged character that has been deservedly declared World Heritage.
The Environmental Impact Statement (EIS) fails to properly recognise the true value of the Blue Mountains World Heritage: its unique irreplaceable Biodiversity, Wilderness values, Wild Rivers and Indigenous Cultural Heritage, nor does the EIS adequately address the incalculable loss to the Blue Mountains World Heritage and to the community that raising the Warragamba Dam Wall would bring.
The proposal to raising the Warragamba Dam wall by 17 metres will periodically inundate an appreciable part of the Blue Mountains World Heritage Area above the existing Lake Burragorang impoundment. In doing so it will flood the lower reaches of the Kowmung River and destroy its status as a declared ‘Wild River’. The Kowmung is an iconic wild river that has been loved and visited by bushwalkers for generations. The lower Kowmung and the Kedumba Valley also supports unique vegetation communities, including a major population of the vulnerable Camden White Gum, that will be lost due to inundation. Flooding of part of the World Heritage Area will diminish Wilderness values , cause irrevocable damage to unique Blue Mountains ecosystems and destroy one of the last remaining significant habitats of the beautiful and critically endangered Regent Honey Eater.
The Traditional Owners have expressed concern that most of their remaining cultural sites will be destroyed by the intermittent flooding caused by the proposed raising of the dam wall. These concerns have not been adequately recognised by the EIS. So much Indigenous heritage has already been lost through the original flooding of the Burragorang Valley when Warragamba Dam was first built. Therefore I strongly urge the NSW government to preserve the remaining Indigenous heritage and abandon any plans to raise the Warragamba Dam wall.
The NSW State Government argues for the need to raise the Warragamba Dam wall as a measure for reducing the risk of floods for residents in the Hawkesbury Nepean Floodplain. However, I am concerned that raising the dam will result in a push for rezoning of flood prone areas for residential development. Nearly half of the floodwaters in the Hawkesbury Nepean Floodplain come from catchments that are not part of the Lake Burragorang impoundment, such as the Grose River and South Creek. Therefore major floods will still happen and more residential development in flood prone areas will in the long-term place more residents to the risk of flooding rather than mitigate the risks. There are other flood-mitigation measures that need to be considered such as improving emergency egress from flood-prone areas and stronger planning regulations for housing built and infrastructure in the flood plain.
The protection of the Blue Mountains as World Heritage is the result of tireless advocacy by individuals, walking clubs and community groups over several generations, so that future generations could enjoy this unique and iconic natural environment. The work and vision that went into protecting the magnificent natural values of the Blue Mountains should not be undone by raising the Warragamba Dam wall and inundating an irreplaceable part of the Blue Mountains World Heritage Area. So again I urge the NSW government to abandon any plans to raise the height of the Warragamba Dam Wall and give full weight to protecting the Blue Mountains World Heritage Area.

The attached submission has all my comments of objection.

Submission on Warragamba Dam Raising EIS by Peter Prineas
– Wednesday 24 November 2021

I object to the Warragamba Dam Raising.
The project is unnecessary as there are alternatives that are better and cheaper.
The project must not be allowed to proceed on the basis of this faulty and inadequate EIS.

1. Alternatives to raising Warragamba Dam are for the most part ignored
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. The EIS fails to acknowledge this fundamental flaw in the project.
Alternative options were not comprehensively assessed in the EIS. The assessment of alternatives does not take into account the economic benefits that would offset the initial cost of implementation.
There are alternatives to raising the Warragamba Dam wall that would protect existing floodplain communities. An approach with multiple options is recommended as the most cost-effective means of flood risk mitigation. This would involve (1) reducing the maximum high water level of the Warragamba reservoir to provide flood mitigation, with the lost water being made from new sources including additional desalination capacity, development of urban stormwater and wastewater recycling, and (2) enhancing the flood resilience of developed areas on the flood plain that are at risk by modifying housing and other structures, removing those most at risk, and by providing flood infrastructure such as raised evacuation roads.

2. The project has unacceptable impacts on a world heritage area, national parks, wilderness areas and wild rivers, biodiversity and Aboriginal cultural heritage
The Blue Mountains World Heritage area is inscribed on UNESCO’s World Heritage list in recognition of its outstanding universal value for the whole of mankind. Raising the Warragamba dam with its consequent damage to natural and cultural values would be a clear breach of Australia’s obligations under the World Heritage Convention.
Many kilometres of wild rivers, part of a wilderness area, and 5,700 hectares of national parks, native species habitat, and numerous Aboriginal cultural heritage sites, could be inundated intermittently and/or adversely affected as a result of the project. This includes:
The Kowmung River - declared a ‘Wild River’, protected for its pristine condition under the National Parks and Wildlife Act 1974;
The Kanangra Wilderness Area, declared under the NSW Wilderness Act, 1987.
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.
Hundreds of Aboriginal cultural heritage sites (noting also that the Aboriginal cultural heritage assessment has been found wanting by the Australian Department of Environment and the International Council on Monuments and Sites).

3. The EIS has serious failures
Severe fires during the summer of 2019/20 devastated 81% of Blue Mountains World Heritage Area, yet 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 and 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 is outlined in the EIS.
The EIS attempts to relieve the project of massive biodiversity costs by falsely claiming that the costs are not direct. These costs could triple the cost of the project and must be taken into account in determining 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.

4. The project will adversely impact habitat of NSW’s most endangered bird species, the Regent Honeyeater
The project has unacceptable impacts on 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 suggests 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 this project’s impact area.
Any breeding habitat is considered habitat critical for survival of the species under the national recovery plan for the Regent Honeyeater which states “It is essential that the highest level of protection is provided to these areas and that enhancement and protection measures target these productive sites”.
The project’s destruction or degradation of a contemporary breeding site for Regent Honeyeaters would have dire consequences for the species as a whole.
The project’s destruction and degradation of breeding habitat for Regent Honeyeaters negatives the effort and expenditure the Federal and NSW Governments have invested in the recovery program, including the Regent Honeyeater Captive Breeding and Release program.

5. The offset strategy for the Regent Honeyeater lacks credibility
I strongly oppose the Project’s offset strategy for the Regent Honeyeater. It is unacceptable and inconsistent with the National Recovery Plan for any avoidable loss or degradation of breeding habitat to occur. 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.

To the Warragamba Dam Assessment Team ,
Attached and below is my submission on the Warragamba Dam Raising project -SSI-8441. I strongly object to the proposal on the basis of the loss of outstanding biodiversity and cultural heritage values of national and international conservation significance and failure of the proposal to protect the community from flooding.

To Whom it may concern,
I oppose the raising of the Warragamba dam wall project.

I am a resident, business owner, artist and author from the Hawkesbury Valley. I oppose the project for environmental reasons. I love hiking and I love the remote World Heritage Area. On my most recent hike (this past weekend, Mt Solitary via Kedumba River) I reflected on how precious it is to humans to be able to access places that are unaltered (much) by man. My brain and body is refreshed for the next round of Suburban grind.

I also reflected on the benefit to the economy tourism brings to the Blue Mountains. We saw the new dinosaur display at Scenic World - people come from all over the globe to venture into the Australian wilderness. With my history in Australian Scouting (including Assistant Scout Leadership), I've learned passion and pleasure for environmental conservation begins with small steps. Access to the wilderness environment is essential to humanity; because people will develop the internal drive to care for the environment.

I strongly oppose the raising of the Dam wall on grounds of flood risk, which includes risk to life. I believe such an act would be criminally negligent, because raising the dam wall will not prevent flooding in the Hawkesbury district. It will minimise minor flooding, sure; causing a one in one hundred year flood to take residents by fatal surprise. There are four tributary water sources flowing into the Hawkesbury River, of which Lake Burragorang is only one, but the average punter does not know this, and raising the dam wall sends a deceptive message to them.

I have no worries about my submission being published in whole or in part. I have no political affiliations and am not in the habit of making political donations.

To whom it may concern,
I write to you to voice my desperate hope that the Warragamba Dam wall not be raised. It is unconscionable and unforgivable, that native wildlife and Indigenouse heritage will be destroyed so that flood plains can be deemed 'safe' for humans to habitat.
I find it breathtaking that politicians can be so utterly focussed on development and economic profit that they lose sight of what is truly important. I drive to work every day through Marsden Park and along Schofields Road and I see the ugliness of housing estates. I see the destruction of nature and a sea of colourbond rooves. What was once a beautiful natural bush area is now an abomination.
To think that the NSW Government wants to raise the Warragamba Dam wall, destroying native habitat and Indigenous history, so that a natural flood plain can host more hideous housing developments just beggars belief.
When the platypus and the regent honey eaters have died and our First Nations people have lost their cultural sites, who will put their hand up and claim responsibility?

To whom it may concern,
I do not support raising of Warragamba Dam Wall for several reasons:
- I care about the environment and the impact of inundation on native species, including critically endangered and other threatened species. No amount of offsetting can make up for the true impact of loss of this habitat. These species and habitats have intrisic value in addition to and beyond that which is held by humans for recreational, cultural and other purposes.
-The Environmental Impact Assessment is flawed. Data collected about threatened species that will be impacted is inadequate and incomplete. Fully-informed decision-making is not possible based on this inadequate report.
-Raising the dam wall further will still not provide adequate flood protection for impacted communities in the Hawksebury-Nepean Valley. The best way to protect communities within the flood plain is to stop further development within the flood plain and buy-back the most impacted areas. Engineering solutions will always have their limitations in the face of extreme weather events and raising the dam wall is no exception. More development in the Valley will lead to more human impacts, no matter how high the dam wall is. It is just a matter of time.
I hope that other flood mitigtion strategies are implemented as an alternative to raising the dam wall.

It seems obvious that a higher dam wall would reduce the frequency and extent of flooding in the Hawkesbury-Napean valley, and that this would reduce future harms to life and property in the valley.

The former is true; the latter is false. Or, to be more precise,
conditional: IF raising the dam wall makes no difference to the population and the extent of development in the valley, THEN less flooding will reduce future harms to society.
It seems to me (without having read the entire EIS) that the Proponent is making this assumption in its analysis of project benefits. [1]

But raising the dam wall WILL lead many people to suppose that they are protected from floods, if they even think about the issue at all.
And there are commercial interests that will reinforce this message.
Thus, development will increase with a higher dam wall.

So, if you are considering approving this project, you should make it conditional on there being a ban on new development in the floodplain, or some similar limitation to the growth of building density in the area.


[1] For example, §15.7.3 and §15.7.6 of the EIS say:
‘The benefits to evacuation come from the reduction in flood peak
reducing the number of people to evacuate for a given flood event.’
and
‘The Project would reduce the frequency, extent and depth of floods,
and consequently current flood hazards would be reduced.’

Indeed, the Proponent may even be making the stronger assumption
that the population and extent of development in the valley
will remain at their current levels.

To whom it may concern,
As a Sydneysider the Blue Mountains is one of the places I really treasure. We are so lucky to have this extensive naturalness as our doorstep.
I therefore strongly object to raising Warragamba dam wall as it will reduce the World Heritage area by a considerable amount, flood beautiful river valleys where I enjoy walking and camping, and flood areas which are of considerable cultural importance to the local Aboriginal people of the area, and which contain some of the last links with their ancestors and a heritage of tens of thousands of years.
It has been said by some experts that the EIS does not fully assess Aboriginal cultural sites and relics, making the wall-raising a decision based on insufficient study. There is also talk that the EIS did not take into account the full area that would be flooded. If that is correct, this proposal could be seen as corruption.
No matter how high the wall is built, there will inevitably be a rain event that results in overflow of the wall.
Floodplains are fertile areas which should be used for agriculture and horticulture, not human residences which will always be at risk of floods.
There do not appear to be other options under consideration for providing water and housing for a growing city. Many people have suggested smarter ways than this proposal.
I urge you not to proceed with raising Warragamba and flooding large areas of ever-dwindling Australian bush, but to listen to many experts and consider less damaging options.

It is unwise to raise the wall and shallow flood a vast area.

To whom it may concern,
I am concerned with the raising of the Warragamba Dam wall for the following reasons;
1. Even though it supposed to hold water back for only a number of days it will be enough to kill most of the plants the water will cover. This will permanently damage habitat including some threatened plant communities that still support some endangered creatures.
2. For what good reason? Not all floodwater in the Hawkesbury/Nepean Valley comes over Warragamba Dam. Nepean, Avon and Cordeaux Dams overflow into the Nepean River, which is all below Warragamba Dam. I have seen large volumes of flood water coming down the Grose River; enough to put the Hawkesbury River into flood when the Nepean River level wasn't all that high. There are at least 4 other notable tributaries to the Hawkesbury further downstream. Raising the Warragamba Dam wall makes no difference to this source of floodwater
3. Could there be other options? Could Sydney's tunnelling machines be used to open up or create a detour/shortcut for floodwater around the bottleneck areas near Sackville? Let's try to think laterally here.
Thank you for letting me have my say and please DON'T raise the Warragamba Dam Wall.

I object whole heartedly to the raising of the warragamba dam. As a Blue Mountains Resident I am disturbed that the natural heritage, and indigenous heritage, is being systematically erroded. I want my young daughter to be able to grow up knowing that she lives in a society that does everything it can to protect wilderness and natural and indigenous heritage. As a professional peacebuilder who has worked in countries in conflict, I know that there are often solutions that have not been explored that provide a win win rather than a win lose. I believe that alternative solutions have not been sufficiently explored. The question 'how do we mitigate flooding risks, whilst also fully honouring and protecting our natural wilderness and indigenous cultural sites ' must be explored more deeply and a better win win solution found.
Indigenous groups have objected. Community groups have objectved. Even a 7 year old is selling lemonade to raise money to protect the area.

My key objections are:
1.Indigenous owners haven't given consent to inundate the 1541 cultural sites in the area. In the wake of the cave explosions, more of the public are waking up to the fact that you can't just continue to destroy cultural heritage without permission and consent of the traditional owners.

2. Alternatives have not been sufficiently explored. Whilst I appreciate the goverment's interests in protecting Sydney from flooding and finding more areas for development, ways to meet these goals must be done in ways that respect local communities, world heritage and indigenous cultural heritage.

3. 5700 hectares of national park, including 1300 ha within the Blue mountains world heritage national park will be indundated. This is not ok. It is a national park for a reason and this must be protected.

Please do not allow this to go forward. I beseech you.
thank you
SERENA Rix Tripathee

Australia is a land of "drought and flooding rain" and raising the dam wall will make it worse for down-stream communities as future politicians or contractors will want to store as much water as possible for future droughts, which should have different solutions.
Immense cost better spent on a fund to raise living-area parts of residencies above floods levels. Any money left can be spent similarly on other similar buildings in the state and even for fireproofing houses at bush-fire risk. This could also assist residents in reducing the cost of insurances into the future.