To whom it may concern,
Warragamba Dam Rasiing project Submission
I have serious objections to the proposal.
1) the serious cultural and heritatge aspects of what this proposal have been overlooked. The proposal lacks the sernsitivity to heritage which other government actions have manifested, like the impact on the Blue Mountains World Heroitage area, of the second airport. Unfortunately it seems part of an attitude of a throw-away society, which ignores the value and significance of heritage.

2) the traditional owners have not given their consent. We need to show real respect to our Indigenous people. For example, we cannot loudly criticize China's attitude towards the uighurs and disrespect and ignore our own 1st Nation people.
3) I empathize with the NSW government's problems with a shortage of housing but building on the Penrith flood plains is simply repeating the Brisbane mistake under Jo Petersen.
4) Alternative sites (and styles) for housing must be sought. Medium density housing ideas from other countries should be researched.
(Does the present housing planning strategy in Penrith take into account the rising temperatures of Penrith?)
5) the EIS has been criticized by many experts. Their voices shiould be taken seriously.

I object to the raising of the Warragamba Dam wall as the floodwaters would –
• irreparably damage the Greater Blue Mountains World Heritage Area (GBMWHA) including the Kanangra-Boyd and Nattai Wildernesses
• destroy indigenous sites, artefacts and sacred places.
I also found the EIS to be flawed to an extent that discredits it. But underpinning all of this, is a false belief that raising the wall would prevent floods on the floodplains.
GBMWHA & Wilderness Areas
As is now shown on the shores of Lake Burragorang, the occasional high water levels of the lake permanently destroys the vegetation it touches. It doesn’t recover. Instead, as the water subsides all that remains is silt and dead trees.
Of particular concern is that thousands of hectares of old growth native vegetation, with its threatened species and yet to be discovered flora species, would be lost if the dam wall is raised.
Indigenous Impact
The initial construction of Warragamba Dam cost the Gundungurra dearly.
It's estimated that they lost about 80% of the sites that were along the river.
If the Warragamba Dam wall is raised, the Gundungurra’s ancestral homeland, and any remaining traces of habitation in the area, will be inundated or washed away in the next flood.
It is believed that it could see the destruction of over 1,200 culturally significant Aboriginal sites.
The EIS Chapter 8: Biodiversity - Upstream
The section 8.8.4 Assessment limitations states that -
A precautionary approach has been adopted in assessing potential upstream biodiversity impacts including the adoption of the precautionary principle where sufficient information does not to exist to confidently assess potential impacts. Application of the precautionary principle requires that a lack of scientific certainty about the potential impacts of an action does not in itself justify a decision that the action is unlikely to have an impact.
This is translated a few paragraphs later when it is stated –
It takes a precautionary approach to impacts by assuming loss of all vegetation within the upstream impact area.
So effectively raising the dam wall will see the loss of thousands of hectares of mainly old growth native vegetation.
The EIS contains a list of affected flora species. There are three that I am familiar with –
• Callistemon megalongensis (Megalong Valley Bottlebrush)
• Zieria covenyi (Coveny’s Zieria)
• Leionema lachnaeoides.
The EIS states for all three that "Temporary inundation resulting from the Project may adversely impact this species." If any of these species gets inundated then we're in a great deal of trouble.
• Zieria covenyi The only known population is 1,040m above sea level on the Narrow Neck Plateau.
• Callistemon megalongensis The only known population is near Megalong Creek in Nellies Glen. Although Megalong Creek flows into Coxs River that is some 4km away, that junction in the Coxs River is some 30km upstream from Lake Burragorang.
• Leionema lachnaeoides It is described in the NSW Government’s Threatened Species webpages as “Populations occur on exposed sandstone cliff tops and terraces, at 960 - 1000m altitude”.
These few examples show that the EIS was prepared with little knowledge of these species and the area to be affected. The fact is that we don’t know what wonders may be in the thousands of hectares it is suggested we destroy.
I need to add that the whole notion of offsets is a false premise as there is no other place like the Kanangra-Boyd and Nattai Wildernesses. If there was, it would quite rightly already be protected.
Floodwaters and Floodplains
There is a false belief that raising Warragamba Dam’s wall will prevent floods on the Nepean/Hawkesbury floodplain. The inconvenient truth is that there are several unregulated rivers that also provide this floodwater - including the Upper Nepean and Grose Rivers. There is also the effect of rivers downstream, such as the Colo River, preventing the quick escape of floodwaters when they too are in flood.
Building more homes on the floodplain means more hard surfaces which will provide even more run-offs in storms. Not to mention the residents of these new housing estates requiring more quick exit roads.

Warragamba Dam Wall Objection
I am making a submission to strongly object to raising the wall of Warragamba Dam. I currently live in Blackheath, Upper Blue Mountains, but I have lived in Penrith and Richmond in the past when I saw the flooded Hawkesbury-Nepean River first hand in 1978.
I object for the following reasons:
• The potential destruction of a large area of the World Heritage Blue Mountains National Park, including endangered habitats and precious Aboriginal sites, making a joke of the term ‘world heritage’:
o “World Heritage is the designation for places on Earth that are of outstanding universal value to humanity and as such, have been inscribed on the World Heritage List to be protected for future generations to appreciate and enjoy.” https://whc.unesco.org/en/faq/19
o https://www.nationaltrust.org.au/blog/why-we-shouldnt-raise-the-warragamba-dam-wall/
• The plan to increase residential development on the Hawkesbury-Nepean flood plain, based on the increased capacity of Warragamba Dam, where any major flooding (which will occur even if the wall is raised) will render homes uninsurable.
• Almost 50% of the runoff that caused the recent flood of the Hawkesbury-Nepean River did not come from the dam, but tributaries below/beside the dam, hence raising the wall will only offer some protection to the new home owners on the flood plain.
• The possible catastrophic seismic consequences from a sudden increase in the weight of the water in the dam, detailed by Marieann Duncan:
o https://www.parliament.nsw.gov.au/lcdocs/submissions/65382/0305%20Ms%20Marieann%20Duncan.pdf
• The lack of detailed investigations of alternatives, because the NSW Government is determined to put vast housing developments on the flood plain and requires an EIS that supports this outcome.
• A number of experts have withdrawn their reports included in the EIS, citing the misleading and selective use of their data.
o https://www.smh.com.au/national/nsw/selective-editing-warragamba-expert-self-reported-over-changes-to-research-20211108-p596zf.html
o https://www.theguardian.com/environment/2021/nov/08/ecologist-so-troubled-by-warragamba-dam-wall-environmental-impact-statement-she-resigned
• With so many potentially disastrous consequences, the EIS should be robust and independent, covering all implications, both environmental and cultural, for future generations.

As a resident of the Blue Mountains who cherishes our internationally recognised outstanding natural environment I oppose the proposal to raise the Warragamba Dam wall. Raising the dam wall will create unacceptible environmental damage to the Blue Mountains World Heritage Area and destroy important Aboriginal cultural sites. And for what? So that developers can build housing estates on the flood plain north of Penrith Lakes, as Stuart Ayres proclaimed in a video. This is irresponsible and prioritises the interests of developers at the cost of destroying international environmental values and Aboriginal people's heritage.
Raising the Warragamba Dam wall will not stop flooding from the Grose River in Richmond and Windsor. The money proposed to be spent on raising the dam wall should be spent on less destructive flood mitigation measures and shoring up evacuation routes, not on putting more people in harm's way by building on that floodplain.

I'm deeply concerned about the impact raising the dam wall will have on our precious wild rivers and world heritage listed National park.
It is also dangerous and reckless to continue to build homes on flood plains. The option to raise the dam is more about developer profits and a balanced strategy for the flood plains.
Our wild rivers and national parks will incurre irreversible damage and destruction due to inundation.

Please do not proceed with the raising of the dam.

My family is of longstanding residence in the Greater Blue Mountains area and have seen so many schemes to dam the Colo and Grose River for come and go. the original daming of the Warragamba River to create Lake Burragorang ended and destroyed indigenious and settler Culture in the area and I do not want further damage done to the area by the raising of the wall by the current proposal of 17 metres that will impact habitat, cultural and geological sites. There has to be detetrimental impacts to areas that are flooded for periods that have never been subject to such floods.
In my view the EIS is systematically flawed as:
• 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.
Further the Blue Mountains Heritage Areas of which I am extremely proud is under attach and the cultural and natural features will be destroyed or heavily modidied by the impact if this proposal goes ahead, inckuded the theatened habitats emu and regent honeyeater populations
In the current environment it is not tenable that the tradition owners the Gundungurra people have not been given adequate access to cultural sites and that have not given a consent for the raising of the wasl to proceed.

There are also alternatives to the raising of the wall that can be implemented. Also the likely the push for further development on the Hawkesbury- Nepean floodplains will further imapct on Cumberlan Plains vegetation and create greater hazards for resident of these areas
The other options include:
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.

To whom it may concern,
I am deeply saddened by this advancement to raise the Warragamba Dam wall. The continued insensitivity of the impacts on the Gundungurra First Nation people and the detachment from the facts in this EIS is quite incredible. The inadequate length of time for the community to review what is an cumbersome and misleading document is acute dishonesty and poor form.
Gundungurra First Nation
The Gundungurra have already lost so much of their cultural heritage and sacred sites when the dam was built in the first instance. The irreparable damage back then has gone unrecognised and uncompensated by the state government so it is offensive to speak of raising the dam wall again with additional destruction and disregard for the longest continuing culture on earth.
What is needed is a more thorough First Nation Cultural Assessment including further archaeological field surveys as well as substantial and ongoing time meeting with the Gundungurra to discuss their cultural heritage.
What is warranted, is to address the implications to the Gundungurra Indigenous Land Use Agreement established under the Native Title Act 1993 that may potentially extinguish Native Title.
Integrity of the EIS and community engagement
The inconsistency of the 1:20 year flood data over the 1:100 year that was previously used in the preliminary EIA to estimate the ‘Impact Zone’ and required Biodiversity Offsets but then choosing 1:100 year and 1:500 year event data in promoting the flood mitigation values of the dam.
Understating the flood mitigation zone of 14 metre above full supply level and using the 10.3 metres in this EIS. This is particularly concerning for significant flood events, a predicted outcome of climate change, which would result in a much greater and notable inundation area. In addition, the assessment methodologies for climate change risk are out of date and does not meet current standards.
Superficial and exclusionary assessments of water quality, aquatic ecology and biodiversity which outrageously impairs and undermines the impacts and damage to the Blue Mountains World Heritage area.
Inadequate examination and review of alternatives to the dam raising such as hydrological modelling of rainwater and storm water harvesting and reuse as well as flood adaption measures and other water sensitive initiatives across the whole catchment. This kind of approach would bring the EIS in line with the state governments own Draft Great Sydney Water Strategy.
The fact the EIS confirms it cannot prevent significant flooding and it’s only a partial flood mitigation measure is elementary and overlooked.
Furthermore it is appalling that legislation has already been passed (Water NSW Amendment Warragamba Dam Bill 2018) effectively allowing the temporary flooding of the World Heritage Blue Mountains National Park before any serious environmental and cultural assessment has occurred.
In Conclusion
The state government's commitment of community consultation for this EIS has been formed only with the intention of looking the part and bulking out a document so it's bulging with confidence of itself when in fact, it's the equivalent of fattening a turkey for the Christmas slaughter.

I am opposed to the proposed raising of the Warragamba Dam wall. Raising the level of the lake will diminishing the aestehtic values of the World Heritage area by flooding areas such as the lower Kowmung River. It will also destroy areas of indigenous cultural heritage, due to flooding of sites along the margins of the lake. Raising the level of the lake will also require the removal of forest and vegetation around the lake, removing critical habitat for animals and birds. There is not an adequate business case to justify raising the dam wall, destroying further heritage in the state, and creating a huge expense for taxpayers.

I oppose the raising of the Warragamba dam wall due to the significant negative environmental impact on flora and fauna and Aboriginal areas of significance.