Warragamba Dam Raising

Please see the document attached.

Please refer to the submission attached.
Francis Breen
President
Ryde Hunters Hill Flora & Fauna Preservation Society

See attached file (which I have also emailed).

I object to the proposal because it will irreparably damage the natural and aboriginal cultural landscape of the Burragorang Valley , severely impact on threatened and rare plants and animals including one of NSW rarest birds, and put the Greater Blue Mountains World Heritage Area status at risk. It will contravene Australia's international obligations.

My objections are summarised under the following topics.

Unacceptable impacts to Blue Mountains Wilderness
The impacts this project will have to the Blue Mountains National Park, a UNESCO inscribed World Heritage area are unacceptable. Looking at the nature of land use changes since European colonization of Australia, and the extent of native flora and fauna impacts, places like the Blue Mountains wilderness are both unique, undervalued and must be protected in perpetuity. The constraints and protections that legislative processes such as federal EPBC 1999 and state EP&A 1979 Acts might afford notwithstanding, when I consider this in the broader picture of historical land use changes, further encroachment of this nature is unacceptable whatever the project justification. There’s just so little wilderness left, and the value of this wilderness is never adequately captured in cost-benefit analyses.

Integrity of the EIS
As has been covered in news media, the proponent has edited or leaned on consultant SME’s to alter and “water down” the significance of the impacts stated in their technical reports for the EIS: https://www.smh.com.au/national/nsw/selective-editing-warragamba-expert-self-reported-over-changes-to-research-20211108-p596zf.html. This is unacceptable and undermines the whole impact assessment and EIS process.
The maps included in the EIS that show future inundation extents within the national park appear to be created in such a way so as to deliberately obfuscate the full extent of the impact. This is consistent with the accusation of selective editing of text noted above, and also unacceptable.

Unacceptable impacts to Aboriginal cultural heritage
As is very well documented, including in Smith, J. 2017, The Aboriginal People of the Burragorang Valley, 2nd edition, Blue Mountain Education and Research Trust, the valley is rich with Aboriginal heritage. In the post-Juukan Gorge Australia, a significant shift in the respect for and protection of Aboriginal cultural heritage is essential. This project is unacceptable on these grounds alone, and is contrary to the message of the interim and final parliamentary inquiries into Juukan. It is also likely that the integrity concerns of the EIS noted above apply to the Aboriginal Cultural Heritage Study.

Inadequate analysis of alternatives
The analysis of alternatives does not include adequate consideration of various combinations of alternatives, which is the most likely counter-factual scenario. The analysis of alternatives focuses on the use of Warragamba Dam’s existing capacity for use as an alternative “air space” (i.e. by dropping the dam level by -12 metres), but it does not consider a lower drop in conjunction with doing something similar in conjunction with the Avon, Cataract, Cordeaux and Nepean Dams. The existing Sydney desalination plant has rarely been in operation since its opening in 2010. The claim that alternatives using the desalination plant would only be viable with the construction of a second plant, and that these would pass unacceptable costs onto consumers does not stack up. The analysis of alternatives does not discuss the predictable nature of drought and flood patterns in Eastern Australia using tools such as the ENSO index, making inappropriate assumptions that -12 metres operational dam level for Warragamba would increase risks of algal blooms etc. It could be feasibly operated at lower levels when floods are expected, and vice-versa. Presumably this already occurs to an extent.
The analysis of alternatives needs to more thoroughly consider combinations of alternatives e.g. lowering combined existing operational capacities + use of desalination + levee construction + road upgrades + incentives to relocate the most flood affected residents + rezoning to prevent further occupation of low-lying areas + sensible use of weather forecasting etc.

I also note the objections raised by the Blue Mountains Conservation Society and the Colong Foundation for Wilderness, as follows:

• 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.

Gundungurra Traditional Owners have not given Free, Prior and Informed Consent for the Dam Proposal to Proceed
• 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.

The dam raising is being driven by developer interests on the Hawkesbury-Nepean floodplain. The NSW Government has stated in its principle document advocating the dam proposal that it plans to allow an additional 134,000 people to reside on western Sydney floodplains after the dam is raised.
Minister Ayres, the Minister for Western Sydney has himself said that he plans for future development across the low-lying Penrith floodplain "as far as the eye can see" in the coming years.

I humbly request that you reject this proposal and stop this nonsense now and for good.

I have noted the opposition to this project by the Wollondilly Advertiser and having read their submission, I back this up word for word.

I strongly oppose the project. It will provide minimal benefits to downstream locations while causing significant biodiversity loss to upstream locations. Please see my attached comments

I object to the nth degree over the proposal to increase the height of the Warragamba Dam wall. The original pamphlet in our letterbox stated it was not for flood mitigation in the Nepean Valley but that is exactly what this is about. Greedy developers have enticed councils into letting dwellings be built in the 1 in 100 year flood zone. Spend the millions of dollars buying back those houses and leave the Indigenous art and flora and fauna in the Blue Mountains World Heritage Area alone. It would be far cheaper to do this than increasing the height of the dam wall. Once these are lost to Australia and the rest of the world, they can never be recovered. You only need to look at what has been done to Aboriginal sites by mining companies to see that the almighty dollar is king. Would the people of Sydney encourage St Mary's Cathedral to be desecrated? Would Americans encourage the Grand Canyon to be flooded, never to be seen again? The areas that would be flooded due to backing up of water don't only belong to Australia, that is why it's designated a WORLD HERITAGE AREA! These areas need to be protected for the generations of people to come, not just a bandaid fix for the current generation. Australia has lost too much flora and fauna and will continue to do so due to current short sightedness. Look to the long view instead of what is just in front of us. Have the guts to stand up and value our heritage, not just a "quick fix" which loses thousands of years of history. Does this government want to be known as the government which destroyed part of the oldest living culture on earth?

I object to raising the dam wall as it does not make good sense on a number of fronts. Firstly there will be significant cost to the taxpayer for this construction with no guarantees that it will future proof flooding events in the future. Secondly the government should not be considering further development in flood prone areas of Sydney. Thirdly the impacts on significant communities of flora and fauna is unacceptable in this day and age. The need to avert future flooding surely could be addressed by restoring wetlands and flood plains across this region. By creating high density urban centres along the river systems you will only continue to exacerbate the problem. A more comprehensive and sensitive approach is what is needed.

I have attached detailed comments

I oppose the NSW Government’s proposed raising of Warragamba Dam on the basis that it will not prevent flooding of the Hawkesbury River flood plain and it will have significantly negative impacts on the Greater Blue Mountains World Heritage Area (GBMWHA) and other natural areas impacted by raised water levels. Details are in teh attached submission.

I have included my concerns in the below attachments

I object to the raising of the Warragamba Dam Wall. This project will destroy priceless Blue Mountains World Heritage river systems and woodlands. Some of these woodlands are home to the critically endangered Regent Honeyeater, the endangered Grassy Box Gum ecological community and the vunerable Camden White Gum. The beautiful Kowmung River, a declared and legally protected 'Wild River' will have its lower reachs periodically flooded and damaged beyond recovery.
The Environmental Impact Statement is totally inadequate, botanical and zoological surveys did not achieve guideline levels required, survey's of Aboriginal Cultural Heritage were only 27% completed, incredibly no surveying was done after the severe 2019/20 bushfires. SMEC Engineering who undertook the cultural and environmental assessments has a long and dubious history of dodgy processes and reports from all over the world and this EIS follows in the footsteps of SMEC's work overseas.
No serious alternatives to raising the dam wall as flood mitigation are considered in this EIS. Dredging the sedimentation that has occurred since building the dam(thereby increasing the dam's capacity) and lowering the current dam level could be undertaken at much lower cost and no environmental damage.
The Blue Mountains will almost certainly lose World Heritage status if this dam wall raising to put more housing on the flood plain in Western Sydney goes ahead. 45% of flooding on the flood plain of Western Sydney does not come from the Warragamba Dam catchment. Building more housing on an unsafe flood plain environment rather than removing the most heavily endangered residents and increasing local flood mitigation measures is sure to endanger many more lives in an era of climate change and increasingly severe weather events predicted due to climate change.

I object to the Project on the following grounds:
The operation of the current dam has had a very significant impact on upstream biodiversity and aquatic ecology. The operation of the Project would add to this impact. I consider that the cumulative impact of the Project on biodiversity and aquatic ecology to be unacceptable and therefore the Project should be rejected, and the Minister withhold approval.

I also have the following comments and recommendations:

Flawed adopted upstream impact area. The EIS has adopted an upstream impact area as the area between 2.8 metres and 10.3 metres above full supply level (FSL). I consider this to be flawed because it ignores the increased duration of flooding of the zone between the FSL and 2.8 metres above the FSL that would result from the project. In this regard it is noted that the EIS states on page 30 of the Executive Summary that “There would be an increased extent and duration of temporary inundation of native vegetation in the catchment adjacent to Lake Burragorang when the flood mitigation zone is operational (the flood mitigation zone is defined as the area between the full supply level and 10.3 metres above the full supply level).” Further the impacts would be expected to be greatest in this 0.0 metres to 2.8 metres area above the FSL than the area between 7.5 metres and 10.3 metres above the FSL due to the increased duration of flooding.
Recommendation – The ‘Project upstream impact area’ be redefined as the area between the FSL and 10.3 metres. The current impact assessment be reviewed and extended having regard for this definition of the Project upstream impact area’.

Potentially flawed offsetting approach. The EIS states that to compensate for and offset the assessed impact on the Greater Blue Mountains World Heritage Area the project would purchase and manage additional and appropriate land containing the values of the Greater Blue Mountains World Heritage Area to achieve no net loss. This is only a valid statement if the land purchased was otherwise at real risk of being cleared of native vegetation of the same type of ecological community(s) as exists within this impact area.
Recommendation – The criteria for land containing suitable offsets include that the land would otherwise be at real risk of being cleared of native vegetation.

Flawed assessment of cumulative impacts. The EIS states that the assessment of cumulative impacts included consideration of the Project in conjunction with other major projects that have been approved for which construction has not commenced, has commenced or has been recently completed. In the context of the area upstream of the current dam wall including and bounded by NPWS reserves the most significant impacts to date have arisen from the inundation of the area up to the FSL and the current temporary inundation area of 2.8 metres. The assessment of cumulative impacts should include consideration of the current inundation area. This is consistent with the contained in the DPIE publication dated July 2021 and titled Cumulative Impact Assessment Guidelines for State Significant Projects where it states ‘Cumulative impacts are a result of incremental, sustained and combined effects of human action and natural variations over time and can be both positive and negative. They can be caused by the compounding effects of a single project or multiple projects in an area, and by the accumulation of effects from past, current and future activities as they arise.’
Recommendation – The assessment of cumulative impacts be revised to have regard for the impacts associated with the inundation arising from the current dam including the current temporary inundation area of 2.8 metres.

Thank you for reading my submission. I will keep it short since the Give A Dam campaign has already made a comprehensive scientific and political of the proposal. I fully support their reasoned opposition to raising the Warragamba Dam wall raising.
I just want to add my voice as a resident of Blackheath, a father and an academic at the University of Sydney. I am shocked and saddened that this proposal is even under consideration. And I am quite angry at the NSW Government's dismal and frankly offensive EIS. To whoever is reading my submission, I ask you to take a moment from this mundane task to reflect on how you represent the many submissions opposing the project. Think of the reasoned objections and think too of the future you want for yourself, your family and friends, and all Australians. The Blue Mountains are the lungs of this desert continent and of the world. We know that raising the Dam wall height will not appreciable reduce the risk of flooding, which can also be managed by a combined approach of mitigation. Raising the Dam will not only accelerate irreversible climate change, it will make our country increasingly uninhabitable.
Think of this if you are tempted to lump all opposition together into a faceless group. All I ask of you is to give an honest voice to the many who oppose this proposal and its dire statement that our collective future can be sacrificed to a short-term solution that will devastate this beautiful country without ending (and in fact increasing) the long-term risks of climate change.
Thank you again.

Please see attached file with my submission

The proposed Warragamba Dam Wall raising will inevitably destroy and degrade the environmental biodiversity and indigenous cultural values of an extensive area of the World Heritage Area within the Greater Blue Mountains National Park.

In 2000 World Heritage listing was granted due to the ‘outstanding and universal value’ of the area - backed with a commitment that Australia would protect the area.

The NSW Government’s ditching of this international commitment - in favour of the largest destruction of conserved lands ever proposed, undermines the validity of Australia’s commitments of any kind towards international formal agreements.

If the commitments of a rich liberal democracy like Australia are worthless - what hope is there for the future of the world and youth?

A progressive and sustainable and financially responsible alternative to this proposal would maintain the Greater Blue Mountains National Park unique environmental and cultural heritage values and investigate and commission a program of flood plain property buy backs, down-zoning and a range of effective climate change resilient mitigations.

Yours sincerely
Robert Symington

My submission looked at six specific areas (chapters) covered in EIS being:
• effects on Biodiversity
• National Environmental Significance – Biodiversity
• impacts on Aboriginal Heritage
• impacts on Non-Aboriginal Heritage
• effects on Protected lands
• impacts on Visual amenity
Comments in my submission indicate more work needs to be done on these six specific areas and that therefore there are grounds for not supporting the Project.

This project must be reconsidered. Flooding a World-Heritage environment in the midst of a climate emergency is an extremely poor decision.

Mulwaree Aboriginal Community Inc (MACI) whole heartedly supports the Gundungurra Traditional Owners of the Burragorang Valley in their opposition to the raising of the Warragamba Dam Wall. MACI represents Aboriginal people living in Upper Lachlan and Goulburn Mulwaree Local Government Areas, which are areas linked through kinship ties, songlines and Dreaming Stories to the Burragorang Valley. Gundungurra people lived throughout the Burragorang Valley, the Upper Lachlan Council area and Goulburn Mulwaree Council area, where they met with the Ngunnawal people living to the South of Goulburn. The EIS process is seriously flawed and does not meet the requirements specified in the SEARs regarding consultation with Traditional Owners and does not effectively assess or consider the impacts on all Aboriginal cultural sites. MACI fully supports the submissions of Aboriginal Traditional Owners, including Kazan Brown who has spoken eloquently throughout the process regarding Traditional Owners' concerns and the lack of consultation. We encourage the NSW Government to listen to the voices of Traditional Owners and ensure further destruction of this Country and its Cultural Sites, Waterways, Native Fauna, Flora and more does not occur.