Warragamba Dam Raising

I object to the Raising of the Warragamba Dam Wall -SSI-8441

The reason I object to the raising of the dam wall is because of the unacceptable risk to the environment of the Blue Mountains World Heritage Area and the threatened species that live there. Following the Black Summer Bushfires of 2019/2020, Birdlife Australia suggested that up to 50% of the Critically Endangered (State and Federally) Regent Honeyeater habitat had been burned. That land was crucial for breeding and foraging. The birds, of which there may be as few as 350 individuals, are currently nesting and foraging in the potential impact zone, 21 birds being identified during surveys alonside a number of active nests in the area. Any breeding habitat is seen as crucial for the survival of the Regent Honeyeater under the National Recovery Plan
- a species for which there has been a great deal of investment by the NSW and Federal Government using Tax-payer money.

The Draft EIS itself concludes the project potentially threatens current breeding habitat for the critically endangered Regent Honeyeater that "cannot be avoided or minimised".
In considering the project, it is important to acknowledge that this land around the dam has become a refuge, as land near waterways often is when fires threaten. The impact zone should the dam wall be raised has distinct ecological value.. the availability of water, its unburnt nature, the loss of so much crucial habitat in the fires, the unviability of offsetting land when it comes to habitat that hosts a critically endangered species such as exists in this case and our responsibility to protect different populations in order to safeguard the longterm survival of the Regent Honeyeater are all reasons that this project should not go ahead.
It is unacceptable and also inconsistent with the National Recovery Plan for any loss or degradation of breeding habitat to occur. The offset strategy for the Regent Honeyeater is wholly inappropriate as this is CRITICAL BREEDING HABITAT of a CRITICALLY ENDANGERED SPECIES. They breed there because it meets their particular requirements. We cannot assume to reproduce this. There is no evidence to support offsetting the breeding habitat of this species and as such any offsets would likely be detrimental to the survival of the Regent Honeyeater population as a whole, and most certainly damaging to the locally affected population, thereby further threatening the long-term future of the species.
Long-term viability requires having numerous populations that give the species some hope, should a fire, for example, extinguish one population.
As the National Recovery Plan states -
"It is essential that the highest level of protection is provided to those areas and that enhancement and protection measures target these productive sites".
Please reject this proposal.

I object to this project.
Please find attached my submission against the raising of Warragamba Dam.
Regards
Fiona Manwaring

On behalf of the Australian Institute of Landscape Architects, please find attached our submission Objecting to the raising of the dam wall.
Please do not hesitate to get in touch with me shall you have any comments or questions regarding our submission.
Best regards,
Tessa Faucheur, AILA NSW Chapter Manager

I am very against this proposal to raise the walls of the Warragamba Dam. This region is habitat for threatened species like the Critically Endangered Regent Honeyeater. As a result of the devastating 2019/20 bushfires, the Regent Honeyeater had up to 50% of its contemporary foraging and breeding habitat burnt. How much more can this species be expected to endure when their lifelines are already so tenuous? The reality is, if this project were to go ahead, this will push the species that much closer to extinction. It will also signal a flagrant betrayal of the stated aim of the National Recovery Plan for the avoidance of any loss or degradation of breeding habitat.

There are a very small number of contemporary breeding sites now available for the Regent Honeyeater so that means that all sites must be given the utmost protection. Proposals like this are absolutely unacceptable with an acknowledgement of this.

Thankyou for the opportunity to comment on this proposal.

I live in in the Blue Mountains oppose raising the Warragamba Dam wall.

Raising the wall will cause irrevocable environmental damage to the region and will result in little benefit to anyone including those who are potentially affected by flooding downstream of the dam wall.

There is considerable detail in the EIS which is presented in a manner that makes it difficult to assess. I consider the confusing format in which information has been provided to be a problem and suggest that, at least, no decision should be made until the pros and cons of the project have been presented more accessibly. Such a presentation should fairly summarise the case for and against raising the wall; presenting the arguments and rejoinders for both sides of the issue.

Cutting through all the detail, my response can be boiled down to two points.

Firstly it is clear and largely undisputed that the wall raising will cause considerable environmental damage. In my opinion, the EIS understates the extent of the damage which will be caused upstream of the raised wall. For example, the use of the term ‘temporary inundation’ is misleading. Any temporary inundation will cause extensive damage which, at best, is long term and may be permanent.

Secondly raising the wall does not solve the problem of flooding downstream of the wall. Flooding will still occur. The EIS argues that raising the dam wall will allow better management of flood waters and will reduce the height of future floods and so save some people being flooded. However the EIS does not adequately consider alternative means of achieving these results.

I Object to the Raising of Warragamba Dam Wall
My connection:
I am a resident in the Wollondilly Shire LGA and a property owner. My connection extends back to settlement of the area c 1830 when my ancestors, both free and convict settled in this area, made it their home and made significant contributions to developing the community they and their descendants became part of. My grandparents lived and worked in Burragorang Valley, raising 12 children, they were very much a part of the Valley Community. Family members were also affected by the creation of Warragamba Dam and the clearing of Burragorang Valley that created the catchment for Warragamba Dam when the then MWSDB acquired all of the properties and moved everyone out.
In Burragorang, my ancestors lived and worked alongside Indigenous Gundungurra people who had been there well before European settlement. The Indigenous/European relationship was a harmonious one despite the fact that the Gundungurra people lost their land as settlement developed. Finally in the 1950’s everyone lost out as the land was acquired for water storage.
Importance then and now:
Lake Burragorang is the water storage basin for Warragamba Dam, built to ensure a plentiful water supply for a then growing Sydney which had been under pressure from severe droughts and an extended one, at the time of its construction. So Warragamba Dam’s predominant and core use is as a water supply dam.
On completion, an exclusion zone was created that would safeguard the water quality and it was managed very effectively to that outcome over the next sixty years. Moving on more than half a century the Burragorang has become a pristine part of the Blue Mountains National Park, protects an abundancy of threatened wildlife and vegetation and provides Sydney with a reliable water source. For those families who were removed it still grieves us and remains close to our hearts as our ancestral home.
So, did all of those important management practises, exclusion zones, creation of National Park areas and water quality importance issues mean nothing now plans are to inundate large areas and create turbidity, create large tracts of flotsam and jetsam for extended periods?
The stored water quality will be severely compromised during these periods of ‘short term inundation’ and perhaps the dam wall itself may be impacted.
The effects of Raising Warragamba Dam Wall will primarily affect the Wollondilly LGA and its residents. So to say I am passionate about the Burragorang is an understatement.
History:
In the 1950’s Burragorang Communities (and Yerranderie and surrounds) were sacrificed for a water storage dam that was to provide this reliable drinking water supply for Sydney.
In Burragorang there is an abundance of European historical sites as well as Indigenous sites.
Creating Lake Burragorang drowned much of the history but above the full water level there is still a wealth of historical sites evidenced and I have included several images of some of these sites at the end of the document. So as part of this EIS it should fully encapsulate all of the historical information that is still evidenced. I have seen no reference to any European history documentation and I support my fellow Gundungurra First Nation people because their history has only been partially documented and as well as sites, they stand to lose a significant proportion of their creation story if this project proceeds. Many archaeological sites are evident and can be found along the edges of the stored water in the Catchment. These include grave sites, building remains, road and bridge remains and many other too numerous to note. Initially when the team ‘selling’ the Dam Raising Project process approached us they were ill informed and had no idea of the extent of the raised inundation levels in the upper end of the catchment which is still very questionable.
Alternatives:
Raising the Dam wall and expecting the Warragamba System will reduce the flood impact is again questionable. Developers will facilitate further housing development on the Penrith Plains, another snarling urban nightmare!
Extensive development on the on Penrith Plains is the issue and the Warragamba system only a very small part of contributing flood water to the area. Flood evacuation routes need upgrades and education on flood risks and management of impacts need addressing.
How do the politicians think they can prevent a natural phenomenon by raising one dam wall?
Finally:
We need to protect what is important and prevent the decimation of our Indigenous and European heritage and native flora and fauna that, once destroyed, can never be replaced.
It is very concerning that only a small percentage of the impacted area was looked at in the EIS, and the investigation was very limited, so we don’t even know the full extent of what will be lost.
I don’t want Warragamba Dam Wall raised! This is of major importance to me personally, as a resident of Wollondilly and as a part of the Burragorang Community that sacrificed all in the 1950’s. This is a water storage dam and other alternatives need to be investigated.

The EIS Chapter 17 Non Aboriginal Heritage is inadequate and does not fully recognise or address the impacts on our heritage.
It threatens the World heritage Status of the Greater Blue Mountains Area (Australia) N917.
The NSW Government may not have been transparent as to the real outcome of this project.
The identified impact on Aboriginal Cultural heritage is totally inadequate resulting from incomplete assessment and consultation.

My name is Kazan Brown
Please see the included 7 attachments

Refer to attachment

Please see the attachment, objecting to this proposal and suggesting a way forward.

If this project goes ahead, it will compound the significant negative health and wellbeing impacts that have already affected First Nations Traditional Owners of the Burragorang Valley. The cumulative impacts of intergenerational trauma caused by dispossession, the destruction of Culture and Country will be perpetuated by yet another NSW State Government.
The health and wellbeing impacts on Traditional Owners is not considered in Chapter 16 of the EIS (Health and Safety) despite this chapter clearly outlining that Aboriginal people are vulnerable and suffer factors such as a lower life expectancy and higher rate of health concerns, including suicide.
The SEARS required the EIS to “discuss how, in the broader social and economic context of the project, the project will minimise negative health impacts while maximising the health benefits”. That the health impacts on Traditional Owners is not addressed is a flaw in the EIS relative to the requirements of the SEARS.
For Aboriginal people, being disposed of Country has major negative impacts on mental and physical health. We are intrinsically linked to Country including waterways and my family’s Songlines and Dreaming stories traverse the Burragorang Valley and its surrounds. Despite being fit and healthy, my own father died in 1998 at age 52 and at the time he was fighting for access to the Burragorang Valley. His own father, Walter Thomas Riley, grew up in the Burragorang Valley suffering the trauma of being constantly hidden by his mother so he was not again taken by authorities (which did happen once) and later being removed from Country.
If more Country in the Valley is flooded, it will be the fourth time our family has witnessed its destruction and been dispossed. For us, our Country is our “social infrastructure” and the negative health impact of its destruction are profound and creates intergenerational trauma. Our ancestors once traversed the Burragorang Valley freely and it has been recorded that they were lean and fit. Now our access has been denied and our basic human rights ignored. The first dispossession for our family was at colonisation, the second was when despite working hard we were again denied our basic human rights and were not allowed to purchase land by the ‘Aborigines Protection Board’, and the third occasion was when the valley was flooded and we were permanently removed.
Our late Aunty Ivy Brookman has widely been recorded as stating “If we left the valley our hearts would break”. In her book ‘Gungarlook, the Story of the Aboriginal Riley Family of the Burragorang Valley’ (co-authored with historian Jim Smith), Aunty Ivy further states, “We love the Burragorang Valley and now it’s gone” (page 30).
The Riley family also has a spiritual connection to the native flora and fauna of the valley. Biodiversity offsets cannot replace the key habitat that will be destroyed if this project goes ahead as animals do not simply ‘move on’– including habitat for species such as the critically endangered Regent Honeyeater. The EIS does not adequately address the impacts on sensitive and endangered flora and fauna, which is highlighted by numerous submissions. We cannot trust a document or agency when the ecologists involved in its preparation have stated that their expert advice was changed to meet the needs of the proponents.
The EIS is clearly not compliant with Section 10 of the SEARS as Aboriginal Traditional Owners have not been adequately consulted prior to investigations. The “significance of cultural heritage values for Aboriginal people who have a cultural association with the land must be documented in the EIS” requirement has not been met in any meaningful or culturally appropriate manner. Only a small proportion of the affected area has been surveyed and sites that will be destroyed due to temporary inundation have not been considered. There is no appropriate Indigenous Values Report, no dating of sites and flora and fauna impacts were not addressed relative to Aboriginal heritage. This project will see our Spirit Animals drowned and the habitat destroyed of many of this County’s endemic species. It is not appropriate that Aboriginal sites have been assessed collectively and not individually. If this project goes ahead, sites that are not currently recorded will be destroyed, as well as known sites.
If our Valley is further flooded, this will be Australia’s next Juukan Gorge disaster however this time it will be perpetuated by a State Government at a time when the ongoing destruction of Aboriginal Culture is no longer socially acceptable.
There are other viable solutions to flooding downstream – such as buy back options if this is required.
In preparing this submission, I wish I had degrees in law and ecology so my submission could be more technical. Instead, I am a time poor mother trying to raise children while working full time because, as Aboriginal people whose country was taken, we do not enjoy intergenerational wealth. It is appreciated that time extensions were provided, however closing submissions a week before Christmas seems ineffective. Closing submissions at the end of January when we had more time to work on them over the holidays would have been appreciated.
This project is opposed by numerous organisations including impacted local Councils and environmental groups. I beg you to take our feedback on board and prevent the further destruction of Country, which will impact on current and future generations of Traditional Owners.

Please find attached the Insurance Council of Australia's submission into the Warragamba Dam EIS.

The Advisory Committee for the Greater Blue Mountains Area World Heritage property (GBMA) is jointly appointed by the NSW and Commonwealth environment ministers to provide advice on the protection, conservation, presentation and management of the GBMA and issues concerning surrounding land uses that have the potential to impact on the area.

The Advisory Committee considers the proposed raising of Warragamba Dam wall has the potential to affect the integrity of the Greater Blue Mountains Area World Heritage property and, therefore, to impact adversely upon the Outstanding Universal value of the property. This is contrary to Australia’s obligations under the World Heritage Convention. In summary the Committee considers the EIS is deficient in that it does not adequately:
• consider the impacts of the project on all the elements of Outstanding Universal Value (OUV) for the property as a whole
• specifically address impacts on the all the attributes of the values
• properly address the “integrity” component of the World Heritage Area, including with respect the Aboriginal cultural heritage of Outstanding Universal Vale

The EIS recognises but does not address the statutory obligation to assess the impact on National Heritage Values, in particular matters relating to Aboriginal cultural heritage. The EIS should be withdrawn and the statutory assessment requirements be undertaken.

Attached are the Advisory Committee’s detailed comments.

Bruce Leaver AM, Chair, GBMA Advisory Committee

I have very strong objections to the Warragamba Dam raising proposal based on the unacceptable impacts to the environment, Aboriginal and archaeological sites and values, and social and recreational values and the serious flaws in the EIS. These objections and the reasons for these are in the attached submission.

I am a Conservation Officer and member of the Committee of Cumberland Bird Observers Club Inc (CBOC). I lodge this submission on behalf of CBOC. CBOC is an affiliate of Birdlife Australia. CBOC understands that BIrdlife Australia has lodged an objection to this project. CBOC fully supports the objection lodged by BIrdlife Australia and the reasons therefore as expressed by them in their submission.

I strongly oppose the project. Please see attachment with submission.

I object to the proposal to raise the Warragamba Dam wall because of the potential destruction of bushland and flora and fauna. Increasing population density in the flood prone areas is also extremely risky to human life. I have walked along the Kowmung river, in addition to many other bush walks in the area and don't want this area destroyed.

As a lifelong resident of Sydney, and a frequent visitor to the natural attractions of the Blue Mountains, I wish to vehemently object to the proposal to raise the Warragamba Dam Wall on a number of grounds:
1 - The wilful environmental destruction of the World Heritage and National Park valley above the dam by flooding, including the impact on 48 threatened species, is an inconceivably terrible outcome - this simply cannot be tolerated, and it therefore must not be permitted.
2 - With the climate and biodiversity crises becoming increasingly dire, NSW and Australia cannot afford to destroy more native forest, as this would increase our carbon impact and reduce biodiversity when we urgently need to be doing the opposite.
3 - The proposal to raise the dam wall contravenes the NSW Net Zero Policy.
4 - The loss of priceless Aboriginal cultural heritage cannot be tolerated.
5 - The proposal to flood the native forest will sever the both the Aboriginal and the wider Australian communities' link with a significant area of the Blue Mountains, and this "human-centred" proposal to raise the dam wall is in contravention of the NSW Draft Connecting with Country Framework.
6 - Proposing to flood the Blue Mountains in order to marginally reduce the flood risk on the Hawkesbury-Nepean FLOOD PLAIN is very poor planning. Instead, no new houses should be built on the flood plain, and a study should be conducted to determine whether any dwellings or housing areas that are currently within the flood plan should follow a "strategic withdrawal" process.
7 - The proposal to raise the dam wall will facilitate highly resource intensive, inefficient, and unwalkable urban sprawl development. Instead of raising the dam wall, more sustainable urban development should be prioritised in flood-free areas with existing transport and social infrastructure.
8 - The proposal to raise the dam wall will create terrible scars in the otherwise beautiful views of the valley from the Blue Mountains. This will destroy natural amenity and reduce tourism income.
9 - As extreme weather events become more frequent and severe, it is conceivable that the proposal to raise the dam wall will never be enough - that in the lifetime of the dam wall, there will be at least one flooding event so great that raising the dam wall will not suffice. This would make the whole exercise and expense of raising the wall futile, and would put human lives of thousands more people downstream at risk.
10 - The multi-billion dollar cost of raising the dam wall is irresponsibly large for the NSW Government to be considering when there are cheaper and far less destructive options available, such as holding additional water capacity behind the existing dam wall.
11 - The massive cost of raising the dam wall is effectively a public subsidy on private development, and is therefore a shameful policy for the NSW Government to be considering.
12 - While the proposal to raise the dam wall will certainly involve massive purchases of environmental offsets, the greatest environmental offset available is to not proceed with this project. Besides, environmental destruction on this scale in this World Heritage place is unlikely to be justifiable with offsets in other places, and highlights the this major flaw in the validity of the offsets mechanism. Other projects in NSW have demonstrated that the NSW offsets system is unfit for purpose and that it enables environmental destruction with insufficient rectification.

I submit that the Warragamba Dam Wall Raising project should be rejected.

I make this statement on the basis that it will:

• cause irreparable damage to the upstream world heritage listed environment

• cost a vast amount of taxpayer’s money

• fail to fully mitigate downstream flooding events while leading to a false sense of security for downstream communities.

In making this statement I draw on over fifty years of involvement in public interest issues, including as an elected local government member and through participation in government and non-government organisations concerned with natural resource management and nature conservation. My comments are also informed by the many soundly researched critiques of the EIS currently on exhibition.

Permanent infrastructure development for housing and commerce on flood-prone lands is inevitably challenging, and becoming more so as climate change delivers more extreme weather events. Some 40 years ago, while wrestling with a local flood-prone development proposal in my council area, I was told of suppressed information on flooding risks for greenfield residential expansion in the Hawkesbury region below Warragamba which nevertheless was approved by politicians reportedly keen to help their ‘mates’ cash in on their properties. History is coming back to bite us, as we face increasing costs, financial and environmental, due to poor decisions of the past.

The 2016 NSW Government decision, arising from the Hawkesbury-Nepean Valley Flood Management Taskforce, to ‘reduce flood risk to life, property and social amenity from regional floods in the Hawkesbury-Nepean Valley now and in the future’ was commendable but far too narrow. The current EIS for the Warragamba Dam Wall Raising project is even narrower, focussing on just one of the Taskforce outcomes.

The Environmental Impact Assessment (EIA) process was first developed as a way to openly and transparently ‘look before you leap’ prior to embarking on projects affecting the environment. An important element was to consider alternatives including a ‘no-go’ option with public opportunity to question and contribute to evaluation. Done properly, an EIS is an invaluable tool. Sadly all too often the EIA process has been relegated to a place-based tick-the-box exercise groomed to provide justification for a development project; the EIS for the Warragamba Dam Wall Raising project appears to fall into this category.

A rethink is needed. The EIS process needs an overhaul.
Flood management and mitigation, important as it is, should be addressed as just one aspect of good governance that cares for country so underpinning sustainable well being for all.

I reiterate that the EIS for the Warragamba Dam Wall Raising is inadequate and that the project should be withdrawn.

Anne Reeves, B.Sc, OAM
19/12/2021

I strongly object to the proposal to raise the Warragamba Dam wall with its consequent periodic flooding of parts of the Blue Mountains World Heritage area.
As a child I was introduced to the Blue Mountains by my parents. My father, a keen bushwalker in his younger days and a member of the Sydney Bushwalking club, took us deep into the bush he loved. My love of this special area has drawn me time and time again to walk through the bushland in what is now recognised as a World Heritage area, our national treasure, a place of grandeur, vista, wildflowers, birds, creeks & rivers, a place that is resilient but increasingly under threat. That we have access to such place on the outskirts of a city such as Sydney is a great blessing for which I thank those far-sighted folk who in years gone by ensured that it was set aside as a haven for wildlife. We must not allow this great legacy to be carelessly frittered away.
This Environmental Impact Statement (EIS) is seriously flawed and should not be relied upon.
The building of Warragamba Dam in middle of last century resulted in the drowning of the Burragorang Valley and the loss of numerous sites important to the local aboriginal peoples of the area, the Gundungurra. Having lost so much these peoples now face the prospect of losing a significant part of what is left of their heritage. It is therefore very concerning that the EIS relies on environmental and cultural assessments of the area to be inundated prepared by Snowy Mountains Engineering Corp (SMEC) Engineering. Subsidiaries of this firm have been censured internationally by the World Bank for failing to adequately assess the impact of dam projects on indigenous people. Nearly three-quarters of the impacted area has not been assessed for Aboriginal Cultural Heritage in the EIS.
The bushfires in the summer of 2019/20 devasted a vast area of the Blue Mountains Heritage Area. Post-bushfire field surveys must be undertaken to assess the impact of these fires which have made unburnt refuges critical to the survival of animal and plant species endemic to this area.
Surveys of threatened species impacted by the inundation area and its surrounds in the EIS are inadequate and substantially less than guidelines require.
The impact on natural systems
The area to be inundated by the proposed dam project includes an estimated 65 km of wilderness rivers and 5,700 ha of National Parks of which over 20% lies within the Greater Blue Mountains World Heritage. At risk is the Kowmung, a declared ‘wild river’ protected since 1974, unique species such as the Camden White Gum and threatened Ecological Communities such as the Grassy Box Woodland. At a time when Australia is slowly starting to realise how many of our unique animal and plant species are being driven to extinction by land clearing and other human activities as well as climate change, this project will drown habitat for critically endangered species such as the Regents Honeyeater. It makes no sense for one arm of governments to spend money restoring habitat for species put on the road to extinction by the indiscriminate actions of their colleagues in a different department. Better surely for the whole of government to work together to ensure that infrastructure to support our society is planned in sympathy with our natural environment.
Alternative options to mitigate flood risk for existing residents on the floodplain should be properly explored
Alternative options to mitigate the flood risk for those who live on the Hawkesbury-Nepean flood plain are not adequately assessed in EIS. On average, 45% of floodwaters that impact this area 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. Certainly raising the dam wall would not allow further development of the flood-plain for housing that would put even more people in harms way.
It is my view that the costs of this project to the natural and other heritage values of the area at risk of inundation, as well as the state budget, far outweigh any perceived benefit in terms of potential for flood mitigation in Western Sydney. This is especially so as Warragamba Dam only has the potential to control one of the catchments that feed into the Hawkesbury-Nepean floodplain. 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.