To whom it may concern,
Think beyond short term goals.. do not ruin this world heritage area for everyone, animals and plants included.

To whom it may concern
As a long-term resident of Greater Western Sydney and a concerned citizen of NSW, I strongly object to the proposal to raise the Warragamba Dam wall. I believe this is an ill-considered plan which will do enormous damage, without providing the posited advantages.

First and foremost, the proposal does not have the approval of the traditional custodians, the Gundungurra people. This should actually be the end of the story! No doubt the custodians were horrified to learn more than 1500 cultural heritage sites would be inundated, and thus damaged or lost, were the wall to be raised (and that’s just the number of sites identified to date, with reportedly only 27% of the impacted area assessed for cultural heritage). I understand the relevant Aboriginal Cultural Heritage Assessment Report has been criticised by the Australian Department of Environment and the International Council on Monuments and Sites due to its inadequacies. Unless the traditional custodians have been fully involved and informed, the whole area has been assessed, and the custodians have agreed, the proposal should not proceed.

Evidence provided to the recent NSW Parliamentary Inquiry into the wall-raising proposal uncovered serious concerns about the integrity and accuracy of the Environmental Impact Statement (EIS) prepared on behalf of Water NSW. Expert ecologists’ advice on adverse impacts was minimised and/or selectively edited, with one resigning rather than have her name included in the statement. Threatened species surveys did not comply with guideline requirements. Some field surveys did not even include expert reports. And seemingly there was no modelling of the stated flood and economic benefits. At the same time, alternative options were not fully assessed.

The environmental and ecological damage caused by raising the wall would be significant, with many hectares of national parks and kilometres of wilderness rivers affected. “Threatened Ecological Communities” and “Critically Endangered Species” would be severely impacted. The beautiful Regent Honeyeater, of which there may only be around 350 in the wild, would lose foraging and breeding habitat. Sydney’s last emu population could also be at risk. Although so much of the Blue Mountains flora was destroyed in the 2019-20 bushfires, I gather there have been no field surveys since, which is a clear lack.

Given that around a quarter of affected area is within the Greater Blue Mountains World Heritage area makes it even more important to protect it, rather than destroy and damage parts of it for nebulous benefit. The area, with its unique eucalypts and rare and threatened flora and fauna, has been internationally acknowledged as a treasure and this should be respected. Of course, it is also a major tourist attraction, with all the attendant benefits of that.

In addition to the traditional custodians, multiple experts and numerous organisations have expressed grave reservations or opposition to the proposal, including for example Heritage NSW, the Insurance Council of Australia, the UNESCO World Heritage Committee, the National Parks Association of NSW, the Colong Foundation and local councils. The chair of the Parliamentary Inquiry Committee Justin Field wrote: “It is unequivocal that the project will have significant, if not devastating, impacts on upstream biodiversity, including on critically endangered species like the Regent Honeyeater and pristine wild rivers like the Kowmung” (reported in the Sydney Morning Herald, 5/10/21). Once this is done, it cannot be undone.

Of course, no one wants towns and suburbs to be flooded either. It would’ve been better if housing and other developments hadn’t been put in a flood-prone areas in the first place. (And certainly, more should not be allowed.) But raising the dam wall will not mitigate the risk. I understand that nearly half of the floodwaters potentially affecting the Hawkesbury-Nepean Valley would come from upstream of the dam. And during or after major rain events, the dam could still flood anyway. Even Liberal and National Party members of the Parliamentary Committee have supported examination of alternative flood mitigation options (also reported in the Herald article quoted above).

No doubt, many expert submissions will be made addressing the problems with the wall-raising proposal and the EIS in greater detail. Public opposition to the proposal is gaining momentum as its implications become more widely known. It would be better not to raise the wall, and I hope intelligence will prevail in that regard.

Yours sincerely
Anne McLean
15 December 2021

Warragamba Dam Wall Raising


I wish to register my objections to the proposed raising of the Warragamba Dam wall.

My primary reason for objecting is the impact on the Greater Blue Mountains World Heritage Area, in particular the wilderness area of the Kowmung River. Any damage to this area is akin to destroying Lake Pedder in Tasmania or the Juukan Gorge caves.

I am also concerned about the taxpayer funding for the flood mitigation works will just serve to benefit downstream landowners and developers. Any financial benefits from the scheme should flow back to taxpayers.

The Need for Dam Wall Raising

Warragamba Dam was built for potable water capture and storage. Although the construction of the dam caused significant environmental impacts at that time, the need for a water supply for Sydney and the technology available at that time led to the current existing dam.

The proposal to raise the dam level to use the augmented storage for flood retention and prevention of downstream flooding will cause significant further impacts.

I understand that there is no need for structural works on the dam to ensure dam safety.

I understand that there is currently no intention of using the augment dam capacity for addition water storage for Sydney’s water supply.

The entire rationale for the dam raising of the dam is to reduce flooding of downstream areas. It is noted that much of the flooding comes from other than the Warragamba catchment.

Environmental Impacts

When any development is proposed, the environmental impacts must be considered.

The principles of dealing with impacts are:-

1. avoid the impacts
2. unavoidable impacts should be mitigated
3. offset impacts

To avoid the impacts on the upstream areas, the raising of the Warragamba wall should not proceed. This would mean that properties and infrastructure downstream would still be subject to flooding. Since most of these works should not have been built in the first place (going back to Governor Macquarie), I have no problems with this. I suspect, however, that the political imperatives will govern, and the works on the dam wall raising will proceed.

Consideration must therefore be given to the mitigation of the impacts.


Mitigation of Impacts on Wilderness Areas (Kowmung River)

Vegetation permanently inundated will eventually die. The proposal is to only use the additional dam storage as a temporary measure, so with proper management the native vegetation should be able to be saved, especially for those areas inundated in the most extreme events.

Key areas of the wilderness areas should be given remedial works after any flooding event. This would certainly be for any parts of the Kowmung River that may be flooded, and possibly the Cox’s River. Any areas that become damaged by flooding must be reinstated by planting appropriate native vegetation, and any exotic weed species that are likely to establish in cleared and vulnerable flood affected areas must be eliminated.

There are a number of National Park, Council and Landcare Groups which would be capable of carrying out such remedial works when required. Compared to the capital costs of the scheme, ongoing and infrequent maintenance and regeneration works would be minimal.

The critical areas requiring consideration for ongoing treatment after flooding must be identified prior to completion of any wall raising works. A number of creeks and rivers feeding into the dam should be so treated, though the Kowmung River would be considered the most important.

Ensuring no loss of existing vegetation will minimize erosion problems and subsequent increase of sediment within the dam.

Additional offsets to (e.g. extra land added to National Parks) have been proposed, and these should still proceed, as even with remedial works after flooding, the overall loss of vegetation could be significant.


Mitigation of Impacts on Indigenous Heritage

I am not an expert in these matters, but I understand that there could be significant sites within the affected areas.

Before any works commence there must be a complete survey of the entire affected area. Any resulting action can be determined at that time, but we can not allow destruction or damage without a full understanding of what is likely to be affected.


Floodplain Development

The proposal to raise Warragamba Dam wall is to protect downstream infrastructure in the floodplain, particularly around Windsor and Richmond. Current development has occurred over many years, guided by a variety of (generally inadequate) rules on flooding likelihood and flood levels. This has resulted in much development that should not have occurred, but has meant some people with vulnerable properties were unaware of the extent of the risks. I therefore do understand the aims of the Government to resolve these issues.

Currently undeveloped land within the floodplain should not be developed as a result of mitigation works resulting from the Warragamba Dam raising. Any beneficial gains from development of land, which is currently unsuitable because of potential flooding, should flow to the government of NSW. Ideally, any additional land could be used as recreational land (including national parks) to further offset upstream losses and to provide additional recreational land in an area of Sydney which is rapidly expanding and losing such areas.


Summary

Ideally, no raising of the dam wall.

If dam wall is raised:-

• Never use the additional dam capacity for permanent water storage.

• Provide addition areas of National Parks as offsets

• Carry out rehabilitation works in critical upstream areas after each flooding event.

• Carry out a full investigation of all impacts on indigenous heritage

• Carry out no further development in current flood prone areas



Geoff Bowmaker

To whom it may concern,
I do not agree with the raising of the Warragamba Dam wall. I do not want to see any more threatened species or indigenous sites destroyed as a result of an inadequate, floored and misleading EIS. Please do not do this.

To whom it may concern,
I am very worried about the effect this dam will have on the World Heritage listing and cultural sites.
I also worry about builing more reidences on a known flood plain.
No matter how high the dam wall is constructed, it will not be able to prevent flooding in the Hawkesbury-Nepean Valley downstream.

To whom it may concern,
I fail to see the point of raising the dam wall as a flood mitigation measure, apparently it would have dellayed toe onset of the recent Hawkesbury floods by about 12 hours, and that delay is of no use to anyone, and is not worth destroying the Greater Blue Mountains World Heritage Area for such an insignificant delay.
Further, as an engineer, I an greatly concerned at the ability of a dam built in 1960 and increased in height in 2006 to take an additional 17 metres without endangering the security of the dam.
This whole proposal appears to be anti environment. amto First Australian and will only appraise Hawkesburt Valley developers.

To whom it may concern,
The EIS systemically fails to address the following issues
Threatened species
The following would be inundated by the Dam project:
• 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.
Severe fires during the summer of 2019/20 devastated 81% of Blue Mountains Heritage Area. YET no post-bushfire field surveys have been undertaken as I understand. Threatened species surveys are substantially less than guideline requirements. Where field surveys were not adequately completed, expert reports were not obtained.
No amount of money could nor should offset the loss of species.
Aboriginal Culture
Only 27% of the impact area was assessed for Aboriginal Cultural Heritage. Not only that, The engineering firm (SMEC Engineering) who undertook the environmental and cultural assessments for the project have an established history abusing Indigenous rights, recently being barred from the world bank.
This is not good enough. At this time and age, we know better and we should do better
Business Case
The whole proposal is clearly to enable developeres to build on the floodplains. This is putting people's lives at risk when it's the only solution put forward and a risky one at that;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.
Alternative options were not comprehensively assessed in the EIS. Any assessment of alternatives does not take into account the economic benefits that would offset the initial cost of implementation.
The proposal to raise the dam wall should be rejected

To whom it may concern,
We employ public servants at the Department of Planning to ensure that irreparable damage does not happen in NSW. It is critical that we stop interfering with nature. There is always an alternative plan. Find it!
Save the environment for future generations.

To whom it may concern,
As a regular visitor and walker to Blue Mountains National park over many decades, I am alarmed at the proposal to raise the dam wall due to many reasons.
ALTERNATIVES TO RAISING THE DAM WALL:
• There are many alternative options to raising the Warragamba Dam wall that would protect existing floodplain communities. A combined approach of multiple options has been recommended as the most cost-effective means of flood risk mitigation.
• Alternative options were not comprehensively assessed in the EIS. Any assessment of alternatives does not take into account the economic benefits that would offset the initial cost of implementation.
• On average, 45% of floodwaters are derived from areas outside of the upstream Warragamba Dam catchment. This means that no matter how high the dam wall is constructed, it will not be able to prevent flooding in the Hawkesbury-Nepean Valley downstream.
SYSTEMIC FAILURES OF THE EIS:
• The engineering firm (SMEC Engineering) who undertook the environmental and cultural assessments for the project have an established history abusing Indigenous rights, recently being barred from the world bank.
• Severe fires during the summer of 2019/20 devastated 81% of Blue Mountains Heritage Area. No post-bushfire field surveys have been undertaken.
• Only 27% of the impact area was assessed for Aboriginal Cultural Heritage.
• Threatened species surveys are substantially less than guideline requirements. Where field surveys were not adequately completed, expert reports were not obtained.
• No modelling of the stated flood and economic benefits of the dam wall raising are outlined in the EIS.
• The integrity of the environmental assessment is fundamentally flawed, and cannot be accepted as a basis for further decision-making by the Minister for Planning.