To whom it may concern,
I am appalled to hear of the destruction to this world heariatege area. Raising the dam wall will flood vast areas of wilderness. As an out door enthusiast I cannot support this, please consider alternatives.
Yours sincerely,
Tim Clare

Dear Sir/Madam,
I a writing as a regular bushwalker in the Blue Mountains and NSW taxpayer and I strongly object to the proposal to raise the Warragamba dam wall.
I have read the EIS and as a scientist, I believe it to be of poor quality and not thorough enough for such a significant project with no cost benefit to the majority of the residents of Western Sydney being stated in the EIS. The photos in the EIS of recent floods downstream are misleading, as are claims that a plantation of Camden white gums would behave like those to be flooded by raising the dam wall. One cannot compare these two groups of individual trees, so many of the variables are different and claiming that they will only be flooded for 2 weeks is an erroneous estimate. Additionally, stating that offset habitat will protect the critically endangered Regent Honeyeater is fantasy. These birds know what habitat is essential to their survival and they are inhabiting it now, it will be flooded by raising the dam wall which means they will have reduced habitat. When an already threatened species is impacted negatively, it does not have the numbers to be resilient like other species and there is a real threat of extinction here. Guideline requirements for threatened species assessments have not been met and this proposal should not advance until they are. Surveys post the 2019/20 bushfires need to be completed before proper assessment of impacts of raising the dam wall can be properly and fully determined.
This part of the Blue Mountains upstream of Warragamba Dam has been classified as World Heritage by UNESCO and the impacts on this area by raising the Warragamba dam wall will seriously breach Australia's obligations under World Heritage Convention. This is serious because 65 km of wilderness rivers and 5,700 ha of national park, including 1,300 ha of Greater Blue Mountains World Heritage Area will be inundated by raising the dam wall. The EIS estimates flooding upstream as temporary, and probably only lasting 2 weeks. All you have to do is look at the current flood scars upstream of the dam and you"ll see that vegetation does not survive repeated flooding, even if it is for only a few weeks, which is not the case for many high dam levels. There are so many variables that will affect dam levels and the EIS is simplistic and inaccurate in its modelling and projections.
Aboriginal assessments and impacts of flooding post raising the dam wall have been poor and do not satisfy local First Nations people such as the Gundungurra traditional owners. Furthermore the traditional owners have not given free, prior and informed consent for the dam wall raising project to proceed. Over 1541 cultural heritage sites would be flooded by raising the dam wall. Denying First Nations people access to their culturally significant sites has been proven to damage and destroy culture and wellbeing in communities. This proposal to raise Warragamba dam wall in its current form is disrespectful and disempowering to our indigenous communities in western Sydney and the Blue Mountains.
Finally, there are other, less destructive actions NSW could be taking to protect existing floodplain communities in western Sydney. Alternative options have not been comprehensively assessed by the EIS. Around 45% of western Sydney floodwaters in question come from areas outside the Warragamba dam catchment so raising the dam wall will never be able to lessen impacts from these floods in the Hawkesbury Nepean floodplain. A multifaceted approach is what is necessary and this should be adopted ASAP.
I hope that this proposal will be seen as too expensive to the population of NSW, with little benefit to western Sydney and obvious destruction of much valued and irreplaceable iconic vegetation and land on which threatened species and our First Nations communities depend.
Yours sincerely,
Fiona Tate

To whom it may concern,
I am writing in relation to the proposal to raise the wall of the Warragamba Dam - project number SSI-8441.
As an avid bush walker, I love nothing more than heading to the beautiful wilderness that is the Blue Mountains and getting to appreciate the flora and fauna that reside here.
I am extremely concerned about the impact that raising the dam wall would have on this special place. The majority of the national park and heritage area are still recovering from the 2019/2020 bushfires which caused huge loss of habitat for threatened and endangered wildlife. This project would further inundate 65km of rivers, 5700 hectares of National Parks and 1300 hectares of the World Heritage Area and reduce habitat even further.
There are also many cultural heritage sites within the affected areas which are hugely significant to the Dharug, Gundungurra, Wanaruah, Wiradjuri, Darkingjung and Tharawal people. Raising the dam wall and inundating these sites would be an act of cultural vandalism and a backwards step in Australia's reconcilliation with its First Nations People.
Undermining the legislative protections afforded to World Heritage Areas and National Parks would be an extremely dangerous precedent to set.
There are many alternatives to raising the dam wall, and I would urge you consider these options.
Yours sincerely,
Natalie Hardbattle

• Dear Sir/Madam,
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 EIS has concluded 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.  Reintroduction programs organised by the NSW government and others have not been successful in increasing the dwindling population of this once common 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.
• 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.
I also object to the inadequate amount of investigation and survey of aboriginal cultural heritage significance. Not enough of the potential flooded area has been surveyed by Water NSW and the local indigenous community is not satisfied and have identified many sites of significance that will be destroyed by raising the dam wall. Further survey and investigations need to be undertaken before any progression of this project.
I urge the NSW Government to adopt all 16 Recommendations outlined in the Iterim Report on the Proposal to Raise the Warragamba Dam Wall, October 2021 before any further progression of this proposal is undertaken.
Yours sincerely,
Ifeanna Tooth

Dear NSW Government

Raising the height of the Warragamba Dam wall is not the solution to mitigating nature. With climate change and other unknown risks, we know we cannot predict nature and to pretend to do so is a folly, insincere, and an untruth. The law also supports this view.

You say the project is to provide temporary storage capacity for large inflow events into Lake Burragorang to facilitate downstream flood mitigation. You hope it’s a temporary solution, but you and nobody else can say that with certainty. What does temporary mean in any case? Any additional storage whatsoever will create additional impacts. Haven't we done enough damage to the Burragorang Valley and all other areas to be impacted by the project?

The impacts of the project include: more than 1,500 sites of cultural, national and historical significance like indigenous cave art, occupation and burial sites, which are likely to be drowned under silt-laden waters thus destroying their value and access; the Kowmung River (declared a ‘Wild River’ under the National Parks and Wildlife Act 1974 for its pristine condition), including approximately 65KM of other wild rivers; up to 6,000 hectares of the World Heritage-listed Blue Mountains National Parks could be inundated and destroyed, further endangering already threatened species like the Regent honey-eater and the Camden White Gums (recognised, amongst others as having Outstanding Universal Value under the World Heritage listing); a number of Critically Endangered species such as the Regent Honeyeater, and Sydney’s last Emu population; and, Threatened Ecological Communities, notably the Grassy Box Woodland. Threatened species surveys are substantially less than guideline requirements. Where field surveys were not adequately completed, expert reports were not obtained.

Severe fires during the summer of 2019/20 devastated 81% of Blue Mountains Heritage Area. No post-bushfire field surveys have been undertaken. We do not understand the impacts of the fires and we do not understand the cumulative effect raising the dam wall will have on these fire-effected areas.

Of the cultural heritage sites that would be inundated by the project, 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 Traditional Owners. The Gundungurra have not given Free Prior Informed Consent for the project to proceed, as required under the United Nations Declaration on the Rights of Indigenous Peoples which has been adopted by Australia. This Declaration includes that States shall provide effective mechanisms for prevention of, and redress for, any action which has the aim or effect of depriving them of their integrity as distinct peoples, or of their cultural values, ethnic identities or resources. Indigenous peoples also have the right to maintain, protect and develop the past, present and future manifestations of their cultures, such as archaeological and historical sites, artifacts, designs, ceremonies, technologies and visual and performing arts and literature. Arguable, these rights are being breached by the project, and regardless have not been properly considered. Only 27% of the impact area was assessed for Aboriginal Cultural Heritage.

Of the western Sydney homes to purportedly be protected by the project, many are already within the 1:100 year flood event levels. Why put more homes within 1:100 and also mislead home-owners re: risk. Insurance costs will be high ultimately the NSW Government liable for losses. Primarily only property developers want to build within 1:100. Smarter places to build must be found. Increased density maybe the key. All growth is not necessarily good. The EIS does not explore these issues.

The EIS does not provide serious alternatives to raising the dam wall, including an analysis of views such as those expressed by Associate Professor Jamie Pittock of the ANU in his Sep 18 report entitled: "Managing flood risk in the Hawkesbury – Nepean Valley - A report on the alternative flood management measures to raising Warragamba Dam wall". 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, so no matter how high the dam wall is constructed, it will not be able to prevent flooding in the Hawkesbury-Nepean Valley downstream. No modelling of the stated flood and economic benefits of the dam wall raising are outlined in the EIS.

The litigation risks and costs with respect to managing dam waters was seen in the case against Seqwater, SunWater, and the State of Queensland for damages arising out of the flooding caused by their dam management after heavy rainfalls in Jan 11 in the Brisbane River Basin. Many homes and businesses were flooded, lives were lost, as the Brisbane River, the lower Bremer River and Lockyer Creek broke their banks. The defendants were sued in negligence, nuisance and trespass. Such a risk already occurs downstream of the Warragamba Dam, and it would increase if the dam wall was raised and more homes built in the flood plain.

Australia has not yet committed at COP 26 to net zero carbon by 2050 in it's UNFCCC NDC under the Paris Agreement 2015. Even if it does, and so to all major global greenhouse gas emitters, serious harm from climate change is not guaranteed to reduce. If Australia will not make its own commitment, how can we expect others to? By raising the dam wall you seem to be expecting to have to mitigate further serious natural hazard events. The precautionary principle needs to be applied and the wall not be built. We need to expect increased hazardous climate events, not hope we can control and mitigate them. Recent global climate change litigation shows clearly the obligation on government to find a permanent solution to climate change to protect its current and future citizens, not short-term solutions such as a raising dam walls that also destroy natural systems.

At Paragraph 57 of "Minister for the Environment and Heritage v Queensland Conservation Council Inc [2004] FCAFC 190" the court found that "It is sufficient in this case to indicate that “all adverse impacts” includes each consequence which can reasonably be imputed as within the contemplation of the proponent of the action, whether those consequences are within the control of the proponent or not." Clearly the EIS does not consider "all adverse impacts" or cumulative impacts - such as was upheld in NSW in Prineas v Forestry Commission of NSW (1983) 49 LGRA 402. The Australian Government accepts the theory of cumulative impacts with respect to natural resource management, see: https://soe.environment.gov.au/theme/coasts/topic/2016/cumulative-impacts-and-management-multiple-uses. The cumulative impacts of the project are not adequately addressed by the EIS.

In 2000, part of the project area was listed as the Greater Blue Mountains World Heritage Area by UNESCO due to Outstanding Universal Value for the whole of mankind. The values recognised included the unique biodiversity of the region's plant and animal communities which supports more than 90 eucalypt species, ranging from tall rainforests through to woodlands, shrub lands and stunted mallees, and the hitherto thought to be extinct Wollemi Pine. We don’t know what other unknown species may be impacted by the project. The government said the listing would focus the attention of all levels of government on the region's environmental credentials and on their responsibility to maintain these, and that it would boost tourism and that the Blue Mountains was one of Australia's premier tourist destinations (Hansard Wednesday, 6 December 2000 Page: 23570). The EIS does not state how NSW can now negatively impact these world Heritage values, and why the criticisms of the IUCN in this regard are being ignored - see: https://www.iucncongress2020.org/motion/082. Raising the dam wall and the consequent damage to natural and cultural values would breach World Heritage values and hence Australian obligations under the World Heritage Convention.

For the reasons mentioned in this submission, the integrity of the environmental assessment is fundamentally flawed, and cannot be accepted as a basis for further decision-making. To do otherwise would be a reckless endeavor for which taxpayers will ultimately bear the risk whilst also losing some of their last natural places. It’s lose lose.

l have lived in the areas the project will impact and l hope to return. As a young lady my mother visited the Burragorang Valley in horse and trap and visited farming relatives there. Her stories of the beauty of the fertile valley and the indigenous remains were wonderful. Please do not destroy any more of this otherwise pristine landscape and give our children the inheritance of what's left of the Australian commons they deserve. My brother and sister concur with most of my views in this submission.

We will never see this landscape again, let’s not take anymore.

Yours faithfully
David Denniston

The Regent honeyeater deserves protection and not to become extinct because of mismanagement of precious resources.

I believe the natural and indigenous heritage values of the area needs to be protected, I do not believe that this project should go ahead. I am most concerned about the threat to the critically endangered Regent Honeyeater and the many indigenous sites in the area that is proposed for inundation.

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.

Thank you for your time

Take care, stay safe