I object to this project on the grounds that it will destroy cultural heritage.
I object to this project on the grounds of environmental destruction
I object to this project on the grounds that it is not necessary

I most strongly oppose the proposal to raise Warragamba Dam due to the project’s unacceptable potential impacts on the environment including to the Blue Mountains World Heritage Area and many threatened species.
In particular , the Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild.  We cannot afford to lose not one more single bird!
Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.
There are only a handful of contemporary breeding sites for Regent Honeyeater and during the assessment of the project a total of twenty one (21) Regent Honeyeaters, including active nests, were recorded within the impact area.
Most notably, The draft EIS concludes that the project poses potential significant impacts to contemporary breeding habitat for the Regent Honeyeater that “cannot be avoided or minimised.”
I fail to see how there can be a logical reason and debate otherwise.
The National Recovery Plan for Regent Honeyeater states “It is essential that the highest level of protection is provided to these areas and that enhancement and protection measures target these productive sites”.
The destruction and degradation of breeding habitat for Regent Honeyeaters is incongruous with the time and money that the Federal and NSW Governments have invested into the recovery program, including the Regent Honeyeater Captive Breeding and Release program.
It is unacceptable and inconsistent with the National Recovery Plan for any avoidable loss or degradation of breeding habitat to occur.
I also very strongly oppose the Project’s offset strategy for the Regent Honeyeater.
Offsets are rarely an appropriate response to proposed biodiversity loss and especially for critical habitat for the survival of a species, in this case breeding habitat for the Critically Endangered Regent Honeyeater.
There has been no evidence at all that breeding habitat for Regent Honeyeaters can be successfully offset and any offsets would be unlikely to provide direct benefits for both the local affected population and the species.

My own personal views are fully and wholly supportive of the following reasons as to why this ill conceived project should not go ahead.
I strongly oppose the proposal to raise Warragamba Dam due to the project’s unacceptable potential impacts on the environment including to the Blue Mountains World Heritage Area and threatened species.
The draft EIS concludes that the project poses potential significant impacts to contemporary breeding habitat for the Regent Honeyeater that “cannot be avoided or minimised.”
The Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild. 
Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.
There are only a handful of contemporary breeding sites for Regent Honeyeater and during the assessment of the project a total of twenty one (21) Regent Honeyeaters, including active nests, were recorded within the impact area.
Any breeding habitat is considered habitat critical for survival of the species under the National Recovery Plan for Regent Honeyeater and it states “It is essential that the highest level of protection is provided to these areas and that enhancement and protection measures target these productive sites”.
The destruction or degradation of a contemporary breeding site for Regent Honeyeaters would have dire consequences for the species as a whole.
The destruction and degradation of breeding habitat for Regent Honeyeaters is incongruous with the time and money that the Federal and NSW Governments have invested into the recovery program, including the Regent Honeyeater Captive Breeding and Release program.
It is unacceptable and inconsistent with the National Recovery Plan for any avoidable loss or degradation of breeding habitat to occur.
I strongly oppose the Project’s offset strategy for the Regent Honeyeater.
Offsets are rarely an appropriate response to proposed biodiversity loss and especially for critical habitat for the survival of a species, in this case breeding habitat for the Critically Endangered Regent Honeyeater.
Valentine Franks

I am an Wiradjuri Aboriginal woman from the unceded lands around the Abercrombie River region just west of the Blue Mountains. I am also resident of the Wollondilly shire, and I extremely and strongly object to the further raising of the Warragamba Dam Wall. My ancestors traversed the lands of the Burragorang valley since time immemorial and I have epistemologically valid evidence to prove this. The sacred sites and dreaming stories located within the Burragorang Valley form part of a wider picture of culture, story and spirituality. A story which has lost eighty percent of its pieces by the desecration that comes with colonisation (like when the wall was first constructed). What is less known, from a western colonial perspective, is that these sites are not seen as singular sites to Aboriginal people but form a larger story for all Aboriginal people in this country who have lost so much of these pieces since 1788. As a Aboriginal woman with cultural, spiritual and family ties to these remaining 20% of sites, the loss of these sites in the Valley add up to the ongoing loss for all Aboriginal peoples in this country (see Juukan George, in WA for one recent example). The ancient songlines that connect all areas of this country speak of the traditional custodians ways of being of a time that began well before 1788. These songlines traversed the Burragorang Valley and 80 % have already been destroyed 50 years ago. By the raising of the dam wall, these remaining songlines will all be destroyed with no retrievable way of reconnection. In addition, the cave paintings, dreaming stories and other sacred sites form stories that were passed on for thousands of years. This is likened to tearing up old family photo albums and pages of a bible for me (ones that have already lost most of their pages). If the dam wall goes up these ancient paintings will be washed away with a single flood. As a Aboriginal person this accounts to no less than cultural and spiritual homicide. As with the Juukan George case in WA, the government has been called upon to do more to protect sacred Aboriginal sites. IF this project goes ahead, this government will go down in history and be known internationally, as knowingly destroying the remaining sites of the oldest living continuous culture on the planet, shame on you.

To whom it may concern,

Submission – Warragamba Dam Raising Project – SSI-8441

I strongly OBJECT to the Warragamba Dam Raising Project (the ‘Proposal’), for the reasons outlined below.

I am a NSW taxpayer who strongly supports the conservation and protection of nature for humanity’s future. Together with my family, I enjoy bushwalking in the Blue Mountains and many other National Parks in NSW. I am appalled by the mis-management of NSW conservation areas over the past decade or more, and the rampant developer-led expansion of Greater Sydney, under the Coalition government. More specifically, I object to the current and future expansion of housing in the Hawkesbury-Nepean floodplains. Such development is unnecessary, poorly planned and heedless of the environmental impacts and future costs to taxpayers to mitigate losses after foreseeable flooding events. The Proposal to raise the Warragamba Dam Wall is simply ridiculous, as it will NOT prevent future flooding in the downstream valley and instead will destroy valuable cultural and natural heritage which should be preserved. I further submit that the Proposal is unlawful, as it would put Australia in breach of its obligations under the World Heritage Convention.

The Blue Mountains World Heritage area is not just a world class National Park, and vital for protecting and conserving threatened species and natural heritage. 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. I strongly object to the use of NSW taxpayer’s resources to fund this desecration of our protected World Heritage area. Specifically, 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. I understand that 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.

I am also concerned that severe bushfires during the summer of 2019/20 devastated 81% of Blue Mountains Heritage Area, yet no post-bushfire field surveys have been undertaken before the EIS for this Proposal published. The EIS is also defective as threatened species surveys are substantially less than guideline requirements, and where field surveys were not adequately completed, expert reports were not obtained. Further, only 27% of the impact area was assessed for Aboriginal Cultural Heritage. Over 1541 identified cultural heritage sites would be inundated by the Dam proposal, yet Gundungurra Traditional Owners have not given free, prior and informed consent for the Proposal to proceed. 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 EIS that has been conducted is fundamentally flawed and the engineering firm that undertook the environmental and cultural assessments for the project (SMEC Engineering) has been widely discredited, recently being barred from the world bank. The firm has an established history abusing Indigenous rights. Further, 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.

In conclusion, this unlawful, ineffective and poorly assessed Proposal should NOT be allowed to proceed. 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. However, alternative options were not comprehensively assessed in this defective EIS. Any assessment of alternatives does not take into account the economic benefits that would offset the initial cost of implementation. As has been widely published, 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 floodplains.

The NSW Government has a duty to its citizens to make informed, sensible and cost-effective decisions. Implementing this Dam Raising Project would be the height of incompetence and a massive waste of taxpayers’ money, in addition to significantly damaging natural and cultural values in breach of Australia’s obligations under the World Heritage Convention.

I live on the edge of the Chiltern - Mt Pilot National Park in Victoria - another critical habitat of the Regent Honeyeater. I am connected both physically and emotionally to the Regent's plight. The Regent Honeyeater is Critically Endangered. I cannot sit by and watch it become extinct. The smallest impact will push them into extinction and the raising of the Warragamba Dam could be that small impact. Thousands of hours of voluntary and paid work and hundreds of thousands of dollars has gone into saving this iconic bird. The bird and all this time and money will be lost if this proposal should go ahead. How can this information be known and the project even be given consideration ?

I live downstream of the Dam at Emu Plains. I purchased my property in full knowledge of the flood risks that the river presented, including the knowledge that in the last 150 years, what is now my property had been subject to significant inundation. That is the risk that I took in purchasing the property where I live.
All people who live in the Hawkesbury/Nepean flood plain are abundantly aware of this risk. We built our homes and businesses in the knowledge that they would either be at risk from flooding or we built them in a way that mitigated that risk. In exchange, we get to live in a beautiful area, covered with rich soils and with the last substantial remnants of the woodlands that used to cover this area. Native wildlife is still present (although it is visibly retreating over time) and what areas have been cleared still represent a significant amount of the open green space that keeps western Sydney habitable through moderation of temperature extremes and some capacity to reduce air pollution.
The fact of the matter is that the only properties that are truly adversely affected by the floodwaters are those that are planned to be built on what will no longer be flood affected land once the dam wall is raised. Even those farmers who suffered setbacks in the recent floods cannot deny that the deposition of new topsoil results in an increase in their productivity over time - those soils which will be catastrophically depleted if all flooding is stopped as a result of the dam wall increasing.
Even the river itself benefitted from the floods of March 2021 - the riverbanks have been scoured clear of the debris and tangles that have choked them for so long - in many places you can finally see the river for the first time in years. Due to weed and debris growth, parts of the river were becoming unnavigable to boats (at least, not without collecting several tonnes of weed). Flooding is a necessary part of the being of a river, for it's ecology and for it's aesthetic. Without it, the river will choke and die. It already struggles to maintain its banks because of the Dams that cut off a majority of its silt supply, but now the centre is at risk because the river doesn't get to flush itself back to health.
The broader community have been loud and clear about this issue - a one-off flood event every 30 years (or more) does not justify the destruction of the World Heritage status of the Blue Mountains, something which cannot be replaced or rebuilt once destroyed. I, along with many of the other voices, are also sick and tired of being lied to about the purpose behind the dam raising - one need only look at the development along Richmond Rd to know that this is not about protecting the existing properties, it's about opening up the entire floodplain to huge levels of development, development which is uninsurable unless the river is tamed completely.
Also worthy to note is the coverage in the media shows that the project already suffers from poor governance - the cost of the project is already spiralling out of control, the environmental assessments have been shown to have questionable reliability and the ministers refuse to accept that their actions will fundamentally increase the ability for Western Sydney to be developed with hundreds of thousands of more undersized and poorly serviced residential properties. There can be no confidence that the cost-benefit analysis, of which this environmental plan forms a part of (by quantifying that which will be destroyed), has any actual merit nor overall value to the people of New South Wales.
The phenomenon that was COVID has shown that Sydney need not be the centre of this state any more. It has shown that the spread to the regions can be done in a way that is sustainable and productive and better utilises the resources of this state, rather than requiring the continued development of this mega-city into an unwieldy beast akin to Los Angeles. This should be enough to inform a broader look at the plan for this state and conclude that preservation of what is left of the native parts of Sydney and its surrounds, particularly the Blue Mountains, must be made a priority over the extension of a dam that, for all intents and purposes, is going to create nothing but destruction.
I object to the project and reject its premise. I object to the representation made on my behalf by my local MP that this is the will of the people in this area. I object to this underhanded attempt to open the Hawkesbury Nepean floodplain to development at the expense of the health and wellbeing not just of the residents who live on the floodplain, but all the rest of Sydney, who rely on the green spaces the moderate the climate in which they live.

I strongly oppose the project to raise the height of Warragamba Dam.
My objections are threefold:
1 it impacts the habitat of the Regent Honeyeaters,
2 it impacts on Aboriginal sacred sites, and
3 I suspect that the real agenda of the State government is to allow further urban development downstream from the dam.

Reasons for in Principle Support of the Proposal.
[A]. Raising the Wall Should Stop Warragamba Feeding
Small H-N Floods.
Flooding in the Hawkesbury-Nepean River [H-N] system will occur without any water being discharged from Warragamba Dam. This flooding is caused by high rainfall in the Nepean catchment and the water bypasses Warragamba.
History has shown that flooding from the Nepean catchment occurs quickly and can be above 9.0 metres at Windsor, which is enough to cut most evacuation routes on the flood plain.
With climate change, and by 2090, these floods could be as high as 11.5 metres at Windsor [my estimate]. The catchment is close to the Illawarra escarpment and on occasions can be subjected to much higher rainfall than the Warragamba River catchment, except for rain that falls on the Eastern Blue Mountains escarpment. Climate change may increase this orographic type rainfall.
The February 2020 flood was 9.2 metres at Windsor with no water coming from Warragamba. Rainfall at Robertson NSW was 395mm in one day and the water reached Windsor in 24 hours. Because Warragamba was at a low level, all the inflow from the catchment, more than 1000 GL was contained. Adding 1000 GL of FMZ would fully contain this type of inflow without any discharge into a flooded H-N. The flood however, could have been much higher if more rain had fallen on the Grose catchment. It could have been a 1:10 flood at Windsor, and with climate change a 1:20 flood by 2090 [my estimate].
The 2020 flood was unique in recent times, not just because no water came from Warragamba, but because it also showed clearly without being masked by Warragamba water, what the Nepean catchment’s flow contribution could be to a normal H-N flood.
Conclusion 1.
The 2020 flood rose rapidly and cut the evacuation routes on the flood plain. This will happen again regardless of what is done at Warragamba, and will remain forever at least a 1:15 flood threat. This is type of flooding, which cuts access roads on the H-N flood plain, is not fully analyzed or discussed in the EIS. However, it is important to prevent Warragamba water adding to this type of flood.

[B]. Main Effect of Raising the Wall.
Warragamba inflows during the 1961 and 1978 floods exceeded 1500 GL [my figure based on published reports] over 4 days, and the release of this water was the main cause for 1:20 to 1:100 flooding in the H-N. Assuming the February 2020 flow rate could approximate the Nepean catchment component of a 1961 or 1978 type flood, this flow caused the river at Windsor to stay above 5.5 metres for 4 days [in February 2020]. Assuming a 1500 GL inflow into the dam, a raised Warragamba would hold back 1000 GL [if at FSL to start], but there would be an uncontrolled discharge of 500 GL, which would take place during the same 4-day period of the maximum dam inflow and at the same time the downstream flood would be peaking. This will increase the flood height at Windsor from 9.2 metres [February 2020] to maybe 12.2 metres [my estimate], equivalent to a 1:10 to 1:20 flood.
If one of the aims of the project is to protect the H-N valley from a 1:20 to 1:100 flood, the FMZ needs to be at least 1500 GL. This requires the main spillway project height to be increased by 17.0 metre [my estimate].
Conclusion 2.
Instead of waiting [before 2090] to raise the main spillway from 12.0 to 15.0 metres because of climate change, do it now, but make it 17.0 metres.

[C]. ‘Piggy Back’.
The idea of ‘piggy back’ discharges which are planned to begin as soon as a H-N flood peaks, and to mirror the normal river draining process is a positive for reducing the time the World Heritage Area is submerged and also restores the FMZ as soon as possible. If a 100 GL per day outflow from the dam can cause a 5.5 metre flood at Windsor [EIS Table 15-29], it is clear that a discharge of 100 GL per day into a falling flood level is not going to happen, if bridges and flood plain roads are to be cleared. Consequently, it is going to take more than 10 days to restore the 1000 GL FMZ, during which time another rain event could occur. The ‘piggy back’ action will prolong flood levels and add to the misery of people using the flood plain. If there is anyway the proposed ‘piggy back’ process time frame can be reduced, or modified, it will be a positive for the H-N valley and the World Heritage Area. However, there does not appear to be an easy answer to this problem.

[D]. Auxiliary Spillway Design.
The new auxiliary spillway is a positive design change and will remove the threat to the H-N valley that has been present ever since the existing ‘fuse plug’ spillway was commissioned in 2002.

I strongly oppose the proposal to raise Warragamba Dam due to the project’s unacceptable potential impacts on the environment including to the Blue Mountains World Heritage Area and threatened species.
The draft EIS concludes that the project poses potential significant impacts to contemporary breeding habitat for the Regent Honeyeater that “cannot be avoided or minimised.”
The Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild. 
Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.
There are only a handful of contemporary breeding sites for Regent Honeyeater and during the assessment of the project a total of twenty one (21) Regent Honeyeaters, including active nests, were recorded within the impact area.
Any breeding habitat is considered habitat critical for survival of the species under the National Recovery Plan for Regent Honeyeater and it states “It is essential that the highest level of protection is provided to these areas and that enhancement and protection measures target these productive sites”.
The destruction or degradation of a contemporary breeding site for Regent Honeyeaters would have dire consequences for the species as a whole.
The destruction and degradation of breeding habitat for Regent Honeyeaters is incongruous with the time and money that the Federal and NSW Governments have invested into the recovery program, including the Regent Honeyeater Captive Breeding and Release program.
It is unacceptable and inconsistent with the National Recovery Plan for any avoidable loss or degradation of breeding habitat to occur.
I strongly oppose the Project’s offset strategy for the Regent Honeyeater.
Offsets are rarely an appropriate response to proposed biodiversity loss and especially for critical habitat for the survival of a species, in this case breeding habitat for the Critically Endangered Regent Honeyeater.
There is no evidence that breeding habitat for Regent Honeyeaters can be successfully offset and any offsets would be unlikely to provide direct benefits for both the local affected population and the species.