Warragamba Dam Raising

This submission is to expresses a strong opposition to the proposal of raising the Warragamba Dam Wall, and also offer a safe, scientifically proven, environmentally and culturally beneficial alternative that will prepare the effected communities for extreme weather events now and into the future. Attached Dam Wall Submission Final document offers a summary of the alternative proposal from Regen Action Wingecarribee. Kind regards, Kirstine McKay - Chair - Regen Action

I am totally opposed to this proposal for reason below.
I walk often in the Blue Mountains and have done so for nearly the last fifty years. This dam proposal has been of interest to me for many years and so I commissioned an undergraduate thesis student to research the idea in 2014 ( Chemical Engineering, The University of Sydney) She came to a similar conclusion.
The summary of the reason I oppose the dam are below. I am sure there will be many making a stronger and better argued case. I would support their arguments. I list the most important issues for consideration below .
It encroaches and threatens the World heritage area
• 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.
The EIS is not a comprehensive study and it contains Systematic failures
• 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.


Alternatives to raising Warragamba Dam wall
• There are many alternative options to raising the Warragamba Dam wall that would protect existing floodplain communities.
• I believe that lowering the normal operating level of Warragamba to 60% in order to reserve 40% as air space for fold mitigation would do the trick. To increase security of water supply, the existing desalination plant could be run harder, and build a new desalination plant – to be run on renewable energy. This would adequately provide the necessary security for Sydney metropolitan areas.
• Alternative options were not comprehensively assessed in the EIS. Any assessment of alternatives does not consider the economic benefits that would offset the initial cost of implementation.
Effectiveness of flood protection by raising the Dam wall
• 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
Traditional owners
• 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.
Trade off between World Heritage area and Development.
• This proposal has come about because of the desire to build ever more houses in the flood plain areas of the river catchment. This “growth for the sake of it” concept is itself flawed, but beyond the scope of this project. Nevertheless , adequate protection could be given to allow these developments to proceed without undue flood risk as explained above ( lower dam level to 60%)
For all these reasons, please reject this proposal

I oppose the project, based on:
• Damage to the World Heritage Area, upstream of the dam (impacting World Heritage Values, Environmental and Indigenous Heritage)
• Inadequate considerations of alternatives, given the impacts of Climate Change and options enabled by the associated decarbonising economy

I strongly oppose plans to raise Warragamba Dam’s wall. This plan must be rejected as inadequate due to the following considerations:

The unacceptable impacts on threatened species in the Blue Mountains World Heritage Area; including the devastating impacts on breeding and foraging habitat for the critically endangered Regent Honeyeater.
• With only 350 Regent Honeyeater birds left in the wild, it is essential that their contemporary breeding ground and foraging habitat – habitat critical for their survival - be protected, especially in light of the 2019/20 bushfires having burnt approx. 50% of their habitat.
• I strongly oppose the project’s offset strategy for the Regent Honeyeater as inappropriate and lacking evidence as a workable response.

The damage that will be inflicted on 5,700 hectares of National Parks, 1,300 hectares of World Heritage Area, over 60km of wilderness rivers along with thousands of culturally significant sites and places of First Nations Peoples. This area also includes threatened ecological communities like the Grassy Box Woodland that supports quolls, dingoes and woodland birds; habitat for Sydney’s last Emu population and unique eucalyptus species such as the Camden White Gum, classified as having Outstanding Universal Value by UNESCO.
• As a signatory to the World Heritage Convention, Australia is obliged to do everything it can to protect the ecological integrity of the Greater Blue Mountains World Heritage Area.
• This plan to raise the dam wall will destroy rather than protect this important ecosystem
• Over 1,541 culturally significant sites will be inundated
• Consent by the Gundungarra Traditional Owners for the work has not been sought

With approximately 45% of flood water coming from sources upstream of Warragamba Dam, this plan will not successfully mitigate the flooding that will occur more frequently as climate change forces more frequent extreme weather events.
• No matter how high the wall, it will not prevent flooding of the Hawkesbury-Nepean Valley further downstream
The state government must not sacrifice this area to enable further inappropriate development of Western Sydney flood plains
• Allowing development of flood plains is irresponsible planning.
• We cannot continue to pave over flood plains and build homes, hoping for the best – this had led to people being put directly in harm’s way and potentially no longer being able to insure their homes.
• Flood plains must be respected for what they are and the work they do in heavy rains and extreme weather events.

As Matt Keen said in 2019, the environmental compensation cost would be too big to allow the project to be viable while committing to be “a very large and robust voice speaking up for Blue Mountains National Park when it comes to the raising of the Warragamba Dam wall”.
• Despite the proposal of raising the wall another 14m, the “offset” compensation has been reduced to only 7.5m “impact area”, reducing the compensation of inundation damage by over 50% and more than $1 billion in offset environmental compensation.
• The proposal must be assessed on the full 14m of inundation impact, however biodiversity offsets will not mitigate the irreparable damage to the significant environment and cultural heritage of this area.

The logical solution to the problem of flooding on flood plains is for the State Government to buy back the homes that have been built and revert the land back to what it does best - acting as a flood plain. As Dr Ian Wright from Western Sydney University states, buying back properties in these flood-prone areas “absolutely makes sense”.

I object to the project see attachment

I object to the raising of the dam wall.

The proposal to raise Warragamba Dam wall presents unacceptable impacts and should be rejected. The impacts of the proposal, including to biodiversity and world heritage values, and the financial cost, do not outweigh the benefits. Impacts to up to 76 threatened flora species and 16 fauna species are unacceptable. Alternative and more effective options to mitigate flooding are available and should be pursued instead.
The EIS is flawed in its assessment of key impacts, particularly upstream impacts. Flooding and hydrology information presented in the flood and hydrology assessment has discrepancies which understate upstream inundation impacts, and these discrepancies are repeated in EIS Chapter 8 – Biodiversity. This appears to lead to an inaccurate assessment of biodiversity impacts.
Other issues with the EIS:
• The EIS does not sufficiently consider the impacts of climate change and changes to frequency and size of flood events as a result.
• The EIS does not sufficiently consider the potential flood impacts/mitigation of repeated large rainfall events over short time periods, at dam FSL. There will be limited ability for the raised wall to mitigate once the FMZ is full. This is possible during wet or La Nina periods, increasingly so considering likely increases in severity of flood events due to climate change.
• The EIS does not sufficiently address the potential risk of flooding from other rivers that do not flow in to Warragamba Dam, and which cannot be mitigated by the proposal
• The EIS argues the impact area is 0.03% of the total Blue Mountains World Heritage Area (BMWHA). This ignores the fact the impacts are limited to sensitive riparian areas of major rivers including declared wild rivers. This statement is misleading and also unhelpful.
• Alternative flood mitigation options have not been given sufficient consideration
• No updated field studies were conducted after black summer bushfires that impacted a significant proportion of upstream predicted impact areas
• The flooding and hydrology information presented in the EIS provides insufficient information and does not give sufficient detail on extent of upstream temporary inundation impacts. More detail and resolution should be provided on extent of upstream temporary impacts around rivers within the world heritage area.

I object to the raising of the dam wall due to the impact it will have on the Greater Blue mountains World heritage Area. The Habitat of critically endangered species including the Regent Honeyeater, Koalas colonies and Sydney's last Emu population would be drowned or displaced by a raised dam wall. We have to stop the ongoing impact on the few remaining natural wilderness areas left in NSW and the Aboriginal cultural heritage. It is like a death of a thousand cuts. How many more endangered species and Aboriginal Cultural Heritage sites are going to be lost before we stop our relentless damage and impact on the natural world. The damage to natural and cultural values caused by this project is a clear breach of Australia's obligations under the World Heritage Convention. The is a waist of public money on the claim that raising the dam wall will reduce flooding on the lower Nepean Hawkesbury river. There is been no mention of natural surface over flow created by developing the flood plain. Other Countries have stopped developing on land below a 1:100 flood levels due to the risks of more intense storms due to climate change. There are other alternatives that should be sort.

Warragamba Dam Raising Proposal - World Heritage Assessment Submission,
Lachlan Laurie 19/12/2021

Summary
The EIS does not adequately assess impacts to Biodiversity Values (BV) of the Greater Blue Mountains World Heritage Area (GBMWHA). It does not adequately demonstrate that it meets the World Heritage impact assessment principles in the IUCN Advice Note: Environmental Assessment.
The MNES report and World Heritage assessment report, along with the three supporting biodiversity assessment reports, is incorrect, inconsistent, lacking in required detail, lacking in evidence for claims, contains out-of-date or invalid information, and is incomplete. There appears to be no aquatic ecology assessment or climate change assessment.
More broadly, no particular field assessment were carried out to consider biodiversity World Heritage values (WHV) that may be components of the listing criteria, including the various species, communities and their habitats, nor, as a result, considered the in-situ spatial or temporal impacts the proposal would likely have on these.
Particular Issues
• No so-called ‘impact area’ used in the FBA relates to broadly an area of land between the 20% AEP existing and with project. The EIS does not adequately quantify or adequately consider impacts below or above this area of land in order to measure the WHV likely occurring or likely impacted within the probable maximum flood or even up to floods more significant than the 20% AEP.
• No targeted surveys were carried out for biodiversity WH values that may be components of the WH listing criteria. Any data collected relates directly to three biodiversity assessment reports, principally vegetation community mapping and any prescribed or assumed presence of only threatened species, with often limited or even zero targeted threatened species surveys, not surveys for any or all of those BV that may occur within impacted GBWHA or indirectly the GBMWA more broadly.
• Inaccurate, inconsistent and underestimated depths and durations of flood events across the GBMWHA and more broadly across the area impacted upstream by the proposal.
• In addition to no targeted surveys or on-ground consideration of BV in the GBMWHA or more broadly, the nature and extent of impacts is generalized to assumptions that any BV impacted in the GBMWHA would be minor in relation to the assumed presence and viability of those BV elsewhere in the GBMWHA.
• The artificially truncated nature of the area impacted along the Colo reduces the area considered for impacts in the GBMWHA.
• The EIS content is incorrect, inconsistent, lacking in detail, lacking in evidence for claims, contains out-of-date or invalid information, and is incomplete. The World Heritage report in particular appears to have been written by an author with no ecological skills or understanding, or any ecological understanding of the site and its BV. The degree of these inadequacies are profound such that it is often impossible to even assume what the base data or arguments may be.
• There is poor and incomplete discussion of one of the key components of the WHV namely primitive or relictual plant species, including Gondwanan affinities, despite many of these species known or likely to occur in the area impacted by the proposal.
• Misrepresentation and selective assessment of BV’s flood tolerance and impacts from the proposal: few species are discussed, with that discussion lacking in any detail relating to the site, inconsistencies within the EIS, and unsupported claims relating to the ecology and likely nature of impacts to even those selected species. The EIS often appears to be disingenuous and unnecessarily argues, with no scientific substantiation, that impacts will be minimal or of no material impact to BV, often with contradictory evidence-based arguments elsewhere in the EIS.
• This World Heritage and MNES reports, in its very limited and misguided discussions relating to schlerophylly as a WHV, infer that only 52.5% of the upstream study area has sclerophyllous dominated communities, where it would likely be much higher than this. Separate to that, diversity among sclerophyllous species isn’t adequately discussed.
• It seems likely that the author of the biodiversity reports did not visit the site.
• The MNES and World Heritage reports appear not to have been prepared by an ecologist.

Please find attached the official submission by the Colong Foundation for Wilderness to the Warragamba Dam Raising SSI project.
Attached below is the submission and seven appendices (A to G).

Submission–Warragamba Dam Raising Project –SSI-8441 –Hornsby Shire Council, Hornsby

Hornsby Shire Council (HSC) has reviewed the EIS for Warragamba Dam Raising Project from both a flooding and an ecological health perspective. This submission includes consideration of hydraulic impacts, along with recreational use and activities, the potential ecological impact on riparian vegetation, aquatic fauna and flora and the needs of commercial operators across the lower section of the Hawkesbury estuary (namely Estuary Prawn Trawl Fishery, Estuary General Fishery and Oyster Aquaculture operators).

Flooding and hydraulic impacts

Hornsby Shire Council (HSC) is an active project partner in several technical working groups investigating flood modelling and mitigation strategies for the Hawkesbury-Nepean catchment. In particular we are currently involved in Infrastructure NSW’s Hawkesbury-Nepean River Flood Study and we have recently engaged consultants from Rhelm to assist a consortium of Councils managing the Hawkesbury estuary in filling in knowledge gaps for a Tidal inundation study at the entrance section of the Hawkesbury River system as part of the development of the Hawkesbury-Nepean Coastal Management Program (CMP, further information on this program below).

Wisemans Ferry area represents the upstream LGA boundary for Hornsby Shire. The EIS identifies, based on the downstream hydrological modelling, Wisemans Ferry area as the furthest downstream section of the river system that will be slightly impacted by the Dam Raising project.

As described in the EIS documentation, HSC acknowledges that Warragamba Dam Raising is a project to provide flood mitigation to reduce the significant existing risk to life and property in the Hawkesbury-Nepean Valley downstream of the dam.
HSC supports the information provided for normal operations of the dam that occur when the dam storage level is at or lower than the Full Supply Level (FSL). As noted in the documentation no changes are expected. These operations are essential contributing to environmental flows in the estuary, which is key to sustaining the ecology of the aquatic fauna of the estuary.

Our main concerns are in relation to the downstream impacts from the management of flood operations in the Flood Mitigation Zone (FMZ) when the water level approaches the FSL and/or the ‘controlled discharges’ as per Fig 9-4 included in your documents. We consider these operations will have associated socio-economic and ecological significant impacts that have not been sufficiently considered in the EIS documentation.

When the EIS refers to ‘downstream’ impacts or assessments it focuses mainly in the stretch of river from directly downstream of the dam to Wiseman Ferry after which downstream impacts are negligible. We note that some of the maps provided present the boundary of this project to be the M1 freeway bridge crossing the Hawkesbury from Kangaroo Point to Mooney Mooney. However, most downstream aspects of the various components of the EIS relate to the area from the dam wall to Windsor. Council wish to highlight that this is not entirely accurate from a hydrological, ecological and water quality point of view.

HSC manages six real-time water quality monitoring stations deployed along the main arm and in some of the major creeks of the Lower Hawkesbury (from Wisemans Ferry to the confluence with Cowan Creek at the mouth, HornsbyShireCouncil (mhlfit.net)). These stations not only collect water quality information, but they are also used to provide advice to the oyster industry on the management of their oyster harvest areas, to assist the school prawn industry in identifying best trawling grounds and to provide daily swimming conditions for community to interact with the estuary in a safe way. In addition, a significant amount of work goes into monitoring the water quality of the estuary which includes harmful algae and pathogens. Based on a close inspection of the HSC monitoring stations data and dam releases when the water level is higher than the FSL over the last 2-3 years we see significant impacts including:

• significant drops in salinity levels in the Lower Hawkesbury which has impacts on the ecology of the local aquatic fauna and riparian vegetation (mangroves). Impacts on mangroves, in particular, has been exacerbated by the impact from both recent floods in 2020 and 2021
• significant drops in salinity impacting the period during which oysters can be harvested which creates significant economic consequences to the Hawkesbury oyster industry. This is particularly important when dam releases are around or above 3,500ML/day for longer than 2 weeks.
• changes in salinity and turbidity levels result in changing in the areas used by school prawns and mud crabs which means the industry needs to adapt to these changes
• overall changes in water quality have been observed when discharges exceed 5000ML/d during a week. We are expecting associated downstream changes in nutrient cycles and algae species dynamics (unfortunately last 2 years of HSC’s field monitoring has been impacted by COVID restrictions)
• prolonged discharges also result in changes in tidal exchange and water residence times, in particular for the secondary estuary arms like Berowra Creek, Mangrove Creek, Mooney Mooney Creek and Mullet Creek
• changes in salinity along the river/estuary, not associated with typical catchment run-off (stormwater, rainfall), are impacting the swimmability algorithm currently used to provide advise on swimming conditions in the Lower Hawkesbury estuary

Statutory and Coastal Management Framework

In addition, the EIS does not consider the objectives of either the Marine Estate Management Act, 2014 or the Coastal Management Act, 2016. These two overarching statutes govern the management of the NSW marine estate and coastal zone respectively. While we acknowledge that the ultimate goal of the project is to provide flood mitigation to reduce the significant existing risk to life and property in the Hawkesbury-Nepean area, more consideration of the impacts on receiving waters should be provided in the context of the legislation above and the management frameworks, guidelines and programs developed thereunder. In particular:

• Hawkesbury-Nepean River Coastal Management Program (CMP, See: Hawkesbury Nepean River System CMP (www.hawkesburynepeancmp.org)) - The six councils with management jurisdiction over the lower river (Hawkesbury, The Hills, Hornsby, Kur-ring-gai, Central Coast & Northern Beaches) are working collaboratively to develop a whole of system CMP in accordance with the NSW Coastal Management Framework. The study area for this CMP extends from the tidal limit of the river at Yarramundi to the ocean and encompasses the associated estuaries of Brisbane Water, Broken Bay and Pittwater. The development of a CMP follows a risk-based process whereby threats and stressors to the system are identified, assessed and ultimately addressed through the development and implementation of management actions. CMP’s must address the objectives of the Coastal Management Act, demonstrating how these will be achieved and ultimately how management intervention will improve the health and vitality of the coastal zone. The impacts of flooding, particularly the combine process of catchment flooding and oceanic inundation, are key hazards that need to be considered under the CMP. It is recommended that the EIS consider the impacts on the lower river in the context of the CMP with a focus on the first pass risk assessment contained within the stage 1 scoping study and the current Industry NSW (INSW) Flood modelling project.
• Marine Estate Management Strategy (MEMS) Threat and Risk Assessment (TARA, See: Threat and risk assessment (nsw.gov.au)) - MEMS is underpinned by a statewide TARA which identifies key threats to the NSW Marine Estate in order to prioritise funding and management of these processes. Key priority threats to the NSW Marine Estate include modified freshwater flows and flooding which are both likely to be exacerbated under climate change scenarios. The impacts of these processes along the lower river are multi-faceted ranging from social impacts on the ability of the community to utilise the river for recreation, economic impacts on commercial tourism, fisheries and aquaculture and environmentally ranging from direct impacts on riparian zones, foreshores and wetlands to trophic impacts within the river. While these impacts may be of a relatively short duration presently, it is likely that frequency and duration will increase under climate change scenarios. It is recommended that the EIS consider the impacts on the lower river in the context of the MEMS TARA.
• Need for a collaborative approach across all levels of government regarding floods and floodplain management. This has been highlighted in the Resilient communities Hawkesbury-Nepean Valley Flood Risk Management Strategy 2017 prepared by INSW. There appears to be a lack of coordinated and transparent alignment between this Strategy and dam proposal.

In summary, the EIS should recognised the social, economic and ecological impacts from prolonged dam discharges and/or flood operations when the water level is higher than the FSL even if these impacts are not as severe as for the areas directly downstream of the dam wall. The commercial fishing industries and recreational users of the Lower Hawkesbury estuary rely on optimal water quality conditions for their operations and activities. We encourage communication regarding dam’s water release management with downstream users and management practitioners with the aim of managing flood risk resulting in minimal impacts downstream (Wisemans Ferry to the mouth of the Hawkesbury River).

Should you have any enquiries in relation to this matter please contact Tim Macdonald on 02 9847 6848

Please see the submission from The Hills Shire Council attached.

Blue Mountains City Council's formal submission is attached.

Thank you for the opportunity to make a submission on the Warragamba Dam Raising Project. Please find attached a letter on this matter.

Please refer to the attachments.

Thank you for notifying Sydney Water of SSI-8441. Please see the attached response and please do not hesitate to contact the Growth Planning team at [email protected] if you have any queries.

To whom it may concern,Please abandon consent for the Warragamba Dam wall-raising proposal to proceed. Traditional owners have not given their consent & there other alternatives.

To whom it may concern,
I strongly oppose the raising of the Warragamba Dam wall in order to increase its catchment area. My lasting memories of the unique wilderness area during my early days in Australia in the 1950's are the bushwalks I made through the Kowmung and Cox river country. I hope my fortunate experiences may be enjoyed by future generations for centuries. Please consider alternatives to raising the dam wall.

To whom it may concern,
As an 83 yr old I have many holidays spent in the Blue Mountains since I was a small child at the end of the 2nd World War.
I love this country and am concerned of the effect on the landscape and the many special rock sites if the Warragamba Wall was raised as proposed.
please take into account the spiritual and physical beauty of the Blue Mountains so that future generations will appreciate and be strengthened by this area.

This project will irreparably damage the ecology of the Blue Mountains World Heritage area. It is highly unlikely to prevent major flooding and therefore is of no benefit. The NSW government should be preventing any further housing development in the Nepean/Hawkesbury floodplain and buying back residential properties in that floodplain.

To whom it may concern,
I wish to lodge an objection to the raising of the Warragamba dam wall. From the information I have read this will not prevent flooding and will cause immeasurable harm to the ecology of the Blue Mountains World Heritage area.
The real answer is for the NSW government to stop any further housing development in the Nepean flood place and to buy back those properties inappropriately sold off for housing over past decades.