Dungowan Dam

Please receive correspondence ref:221207_Dungowan Dam EIS_Submission.

The project, through constraints imposed by government in the scoping phase fails to provide a value for money solution to address water security for the residence of Tamworth. Cheaper, more cost effective options were deliberately excluded from consideration such as industrial water recycling which will yield significant water savings for a fraction of the cost of the proposed project. The willingness for the community to pay the $1.3 Billion for the proposed project has not been tested. This is a failing of the EIS documentation in that there is no evidence presented to show the communities willingness for such an investment to be undertaken. All that is provided is wording of the form "the project is consistent with government policy". There is also reference In the project justification to the fact that government policy is such that town water supply augmentation should not be at expense of general security license holders. The placing of irrigator's interest above town water supply is inconsistent with the Water Management Act (2000). For this to be used as a justification for proceeding with project is a significant error.

Community feedback also has clearly shown that there is unease about the cost. The community is also concerned about their ability to pay the ongoing repair and maintenance bill for the project once constructed. IPART principles demand cost recovery. The Peel valley water users already pay some of the highest water use charges in NSW. The building of another dam in their catchment will only double water use charges. No where in the project proposal documentation is there analysis of the long term impacts on water pricing for the Peel Valley. This is a serious deficiency in the project proposal paperwork and this lack of information makes any assessment of the economic viability of the project deficient. How can a project be deemed "affordable " when the long term cost implications form the construction are not reported.

It is also of note that the Productivity Commission in 2021 deemed the project to be a " failing in government process" and a complete waste of money determining that cheaper more cost effective options existed. The EIS documents do no address the comments made by the Productivity Commission. The EIS however still proclaims that the project is cost effective and affordable which is in clear contradiction to the published evidence.

Objection to Dungowan Dam & Pipeline Project SSI – 10046

This submission is an objection to the Dungowan Dam & Pipeline Project.

I object to the proposed dam in the Peel River catchment. The proposed dam is estimated to cost $1.3 billion and will only provide an average of an additional 7,000 ML per year. This is not enough to secure Tamworth water supply into the future. The project will not meet its objective to provide the most cost effective or efficient option for securing Tamworth water supply.

Water Infrastructure NSW cannot justify the clearing and flooding that would occur with a new Dungowan dam when much cheaper solutions to Tamworth’s water security exist. The alternatives to a dam, like using more of Tamworth’s 16.4 gigalitre urban licence from Chaffey Dam seems to have been rejected. Measures such as water recycling, saving rain water, saving storm water or purchasing redundant water licences were not even considered.

A review of the proposed dam in August by Infrastructure Australia found that the costs (1.3 billion dollars) far outweighed the benefits. The proposal’s economic benefits were said to be very low and ensuring that Tamworth’s full allocation of water from Chaffey Dam was a vastly lower cost solution.

There is no assessment of other, more beneficial, cost effective long-term solutions that will not damage the natural environment.

This project will have a negative effect on the area’s biodiversity. Biodiversity impacts include;
• A significant area of critically endangered ecosystem and koala habitat will be cleared, including habitat for many other endangered mammal and bird species
• The Dungowan EIS faunal and floral lists have shown a large number of threatened species both listed in NSW and the Commonwealth EPBC Act. A number of important species and communities are acknowledged are being significantly affected by the proposed dam, eg Box Gum Woodland, the Koala, Spotted-tail Quoll, Border Thick-tailed Gecko, Tall Velvet Seaberry, Regent Honey Eater, Swift Parrot and Platypus.
• Koalas have been found at site of proposed dam. Listed as endangered under BC and EPBC Acts. Our national icon is under pressure from threats such as global warming, bushfires, habitat clearing and disease.
• Dungowan creek and the Peel River are platypus breeding areas. Potential impacts to the Platypus of a new dam at Dungowan are genetic separation, a reduction in feeding habitat or loss of breeding habitat due to lowered water levels, loss of food source (macroinvertebrates) due to temperature change from CWP and various construction impacts including prevention of fauna passage, direct impacts to burrows and entrapment in trenches or infrastructure. These factors risk driving the platypus to local extinction and place further pressure on a near threatened species.

There are further endangered species known in the area that were not considered in the EIS;
• The Booroolong Frog, listed as endangered in NSW and under the EPBC act.
• Davies tree frog listed as vulnerable in NSW and known in Terrible Billy catchment.
• The powerful owl, listed as vulnerable in NSW is known in the catchment.
• The masked owl and Sooty Owl are vulnerable in NSW and are both known in the area.
• The Glossy Black Cockatoo, vulnerable in NSW, is known in the catchment.
• The Turquoise Parrot, Barking owl, Brown Tree Creeper, Black Chinned Honeyeater and Flame Robin are all vulnerable in NSW and likely found in the area.
• The Greater Glider endangered under EPBC are also known in the catchment.
• The Yellow Bellied Sheathtail Bat is listed as vulnerable in NSW and is known in the area, as is the Greater Broad Nosed Bat.
• The vulnerable blue billed duck is also a possibility in the area
• The EIS also did not consider the endangered Brush tailed wallaby (endangered in NSW, vulnerable EPBC), the square tailed kite or the Hooded Robin (SE form) both vulnerable in NSW and are likely to occur around Dungowan.
• The yellow bellied glider (vulnerable in NSW and EPBC) is also likely to occur.
• Listed plants, Euphrasia arguta known from around Nundle (endangered in NSW, critically endangered BPBC), Dichanthium setosum (bluegrass) vulnerable and Asterolasia beckersii (Dungowan starbush) endangered in NSW and critically endangered BPBC) are all likely to be found in the area.

The project will also have an impact on river health. River health impacts include;
• Dungowan Creek is within the threatened Lowland Darling River aquatic ecological community. Offset measures for impacts on threatened native fish are not adequate
• Loss of 192 km2 of high quality native fish habitat and loss of migration opportunities for Federally listed threatened Murray Cod, Silver Perch and Eel-tailed Catfish.
• Dungowan Creek and Peel River have a healthy Platypus population that will be genetically separated
• The loss of flows in the Peel River will cause a failure to meet the Environmental Water Requirements of the Murray-Darling Basin Plan and impact on environmental health of the Namoi River catchment.

Reference: Infrastructure Australia, New Dungowan Dam and Pipeline, Business Case Evaluation Summary.

Objection to Dungowan Dam & Pipeline Project SSI – 10046


I would like to object to the proposed Dungowan Dam and pipeline. For many people, building a dam is the logical alternative to securing water for Tamworth. However, an assessment of the project shows significant flaws in the proposal.
At the current projected cost of $1.3 billion Dungowan Dam will only add an extra 7,000ML per year at an estimated $70,000 per ML. NSW taxpayers will not be getting value for money. Recently the Federal Productivity Commission deemed the project as poor value.
There has been little assessment of alternative means of saving water or a look at the various industries and the development of water efficient processes. Since the three meat processing plants in Tamworth use 50% of the drinking water supply, a thorough look at the benefits of industrial recycling should be examined.
Successful recycling would save taxpayer money, water, and avoid the detrimental effects on the environment. These businesses would also be more self-sufficient in extreme circumstances.

The recent floods and fires have highlighted the impacts of extreme weather events. These have been supercharged by climate change and in many cases people and communities have been reduced to living in third world conditions. What can be done?
Australia has the world record for animal extinctions. The incremental and accumulative impacts of settlement on the country have resulted in the fracturing and destruction of the land. Tree clearance, overallocation of water and various ad hoc developments have looked to short term gains. This dam will be another project in that category. It will have a negative impact on e.g., the native fish habitat and a significant area of endangered ecosystem. Clearing which affects koalas will also impact many other species. River health across the state has already resulted in loss of fish stock during both drought and flood. Therefore, it is critical that we protect this river catchment from such a fate.
Therefore, I oppose the Dungowan Dam and pipeline proposal because of cost, the failure to fully investigate recycling initiatives and the environmental impacts that will follow.

Submission
EIS New Dungowan Dam and Pipeline Project
Application number SSI-10046

On behalf of the Tamworth Local Aboriginal Land Council, I am pleased to enclose a submission in response to the Environmental Impact Statement for the New Dungowan Dam and Pipeline Project.

The Tamworth LALC is grateful for the opportunity to put its views forward for consideration. If you require any further information or would like to discuss any of the points made in our submission please feel free to contact me on (02) 6766 9028.

Dungowan Dam proposal submission

I wish to object to the Dungowan Dam proposal

While I have recently moved to Sydney, I have spent the last 45 years in the Coonabarabran area and Tamworth was important for the provision of many services. Water security for Tamworth is essential but the proposal for a new dam on Dungowan Creek is not the solution.

As with all dams it is an extremely expensive project and there are cheaper methods of ensuring water security. Essentially all water is recycled and the proposed Tamworth Regional Council Industrial Water Recycling projects, among other projects, would have great benefits and be much less expensive.

Dams are not magic. They don’t create water, they take water away from downstream uses. The proposal is based on 2015 data. Since that time we have had extreme drought followed by extreme rainfall. With Climate Change predictions of rainfall are increasingly unreliable. Building of any new dams is a very shortsighted activity.

Downstream impacts would include
• Isolating significant populations of native fish and platypus,
• Reduction in river water flows and thus damage to the riverine environment,
• Similarly shortage of available water for downstream agriculture,
• Probable drawdown of groundwater aquifers,
• Failure to meet Murray Darling Basin Plan environmental water objectives.

Other impacts would include
• Flooding of significant Indigenous cultural sites upstream,
• Clearing of critically endangered ecosystems and koala habitat.

This expensive and politically motivated project should not go ahead.

Regards
Jane Judd

Please find a PDF submission from Healthy Rivers Dubbo

I object to proposed Dungowan Dam & Pipeline Project SSI – 10046.
This proposal is not the solution to the challenges within the Namoi catchment of ensuring improved water security within the inevitable constraints of a changing climate on inland NSW.
It seems a largely politically driven project similar to the raising of Chaffey Dam some years ago: an expensive dam that was quickly sucked dry during the last drought by downstream irrigators.
If not politically/ideologically driven, it is unclear why government has ignored the various independent assessments of the proposal that have determined its "cost ineffectiveness".
It is an expensive project that is not supported by robust assessment of alternative water security options that could be delivered more cheaply, fairly and without the ecological devastation of yet another dam within the Namoi catchment an important tributary of the Murray Darling River system.
There is inadequate assessment of the full ecological impacts of the proposal on a range of protected fauna, flora and Aboriginal cultural heritage items - future generations will bear the repair costs and trauma of more collapsed ecosystems.
The cumulative impact of poorly considered proposals such as SSI-10046 means the fast pace of biodiversity loss in Australia continues much to the concern of most Australians.
The EIS has failed to consider the full extent of biodiversity loss caused by the proposal and the Commonwealth legislative requirements to fully assess impacts and protect listed species.
Using cheaper options to ensure water security for regional towns such as Tamworth means taxpayer money could be better spent on road repairs to assist in the community rebuilding of many communities heavily affected by recent flooding.

Please find attached a submission from Nature Conservation Council NSW, objecting to the project

Submission Guide: Objection to Dungowan Dam & Pipeline Project SSI - 10046 Deadline: Wednesday 7 December 2022
Lodge at: https://www.planningportal.nsw.gov.au/major-projects/project/30026
This submission is an objection to the project
Background
The proposed Dungowan Dam in the Peel River catchment is estimated to cost $1.3 billion to provide only an average of an additional 7,000 ML (million litres) per year and will not secure Tamworth water supply into the future. This water would cost an estimated $70,000 per ML while much cheaper alternatives are available. It is a very expensive National Party political promise with no assessment of more beneficial, cost effective long-term solutions that will not damage the natural environment.
Key points for submission: (use your own words and include additional knowledge)
1. The Environmental Impact Statement (EIS) fails to comply with the Secretary of Planning assessment requirements (SEARs). The EIS does not:
 analyse and optimise alternatives,
 assess all threatened species including those listed under Federal law,
 provide all assumptions used in modelling
2. The project will not meet its objective to provide the most cost effective or efficient option for securing Tamworth water supply.
 There is no analysis of the benefits of the proposed Tamworth Regional Council industrial water recycling project.
 The EIS fails to identify industrial use of town water supply. In Tamworth up to 50% of drinking water supply is used by three large meat processing plants.
 Options analysis was constrained by terms of reference developed in 2015 and does not reflect current best practice
 Limited options were analysed in the final business case
3. River health impacts:
 Loss of 192 km2 of high quality native fish habitat and loss of migration opportunities for
Federally listed threatened Murray Cod, Silver Perch and Eel-tailed Catfish.
 Dungowan Creek is within the threatened Lowland Darling River aquatic ecological
community. Offset measures for impacts on threatened native fish are not adequate.
 Dungowan Creek and Peel River have a healthy Platypus population that will be genetically
separated1
1 https://www.theguardian.com/environment/2022/nov/04/large-dams-may-threaten-survival-of-platypus- populations-research-find    
The loss of flows in the Peel River will cause a failure to meet the Environmental Water Requirements of the Murray-Darling Basin Plan and impact on environmental health of the Namoi River catchment.
Biodiversity impacts:
A significant area of critically endangered ecosystem and Koala habitat will be cleared, including habitat for many other endangered mammal and bird species
The EIS fails to assess 18 threatened species known or likely to be in the area of impact including 6 threatened species protected under Federal law such as the Greater Glider and 2 critically endangered plants.
Aboriginal cultural heritage impacts
Many sites of high cultural significance will be impacted
Many sites require further research and not all of the pipeline easement was assessed There are no cultural flow allocations in Dungowan Creek or the Peel River
Cost impacts
The project does not meet the NSW Treasury guidelines for a cost to benefit ratio of >1 The political promise to grant construction costs does not meet current user pays policy for new water infrastructure in NSW
Taxpayers of NSW do not want to pay for a project with no cost benefit and significant environmental damage
The Federal Productivity Commission deemed the project poor value
Social impacts
The required workforce will compete with other industries and intensify labour shortages Regional infrastructure spending to fix flood damaged roads should be prioritised
Local jobs were not generated by Stage 1 pipeline project – constructed by FIFO workers Local concerns raised about loss of river flows and fish populations
Loss of cultural connections and place
If you would like further information contact [email protected] have trouble lodging a submission contact Project Planner: Benjamin Cox 99965524

I understand that this EIS does not comply with the Secretary of Planning Assessment requirements. It should have listed alternatives and analyse and assess those alternatives. It should also look at what species might be threatened, some of which are required under Federal laws. We should also be able to see what assumptions you have used in this EIS.
Because you have not analysed alternatives, the benefits of the proposed Tamworth Regional Council industrial water recycling project have not been analysed. You have also not taken into account that 50% of the drinking water in Tamworth is used for industry, namely meatworks. I understand that the terms of reference were established in 2016 and do not take into account best practices that have been developed in the last 6 years.
The environmental facts have not been assessed adequately at all. 192 km2 of high quality native fish habitat will be lost along with loss of migration opportunities for Federally listed threatened Murray Cod, Silver Perch and Eel-tailed Catfish. Dungowan Creek also lies within the threatened Lowland Darling River aquatic ecological community. The impacts on threatened native fish will be dramatic and treatment of these impacts are not adequate.
Koala habitat will be destroyed. Our koalas are iconic and NSW is losing the battle to look after their populations now. There are another 18 threatened species that belong in this area. 6 of these are protected under federal law. These include the greater glider. These threats have not been assessed. Dungowan Creek and Peel River have a healthy Platypus population that will be impacted adversely
There are also Aboriginal cultural heritage sites that will be destroyed if this dam goes ahead. Has the NSW government not done enough harm to our indigenous people over the last 200+ years? Must we continue to destroy evidence of their occupation of this land for more that 60,000 before white men came?
This project does not meet the NSW Treasury guidelines for a cost to benefit ratio of >1.  The political promise to grant construction costs does not meet current user pays policy for new water infrastructure in NSW . Taxpayers of NSW do not want to pay for a project with no cost benefit and significant environmental damage.  The Federal Productivity Commission has deemed the project to be of poor value.
I do not understand how a project with so many flaws can have arrived at this point.
Please consider all the facts and analyse this project properly before going any further

The Dungowan Dam proposal was the result of a hasty political promise with no proper investigation. It seems to be a tax-payer subsidy to one or more of 3 meat-processing companies. The EIS is flawed for the reasons listed in the attached pdf, and also for the following reasons:
1. There is an existing Dungowan Dam that has blocked environmental connectivity between upper and lower Dungowan Creek. The proposed dam would be built downstream and would block connectivity of several extra tributaries from lower Dungowan Creek. The EIS does not have a map showing which additional tributaries will be blocked (e.g. Terrible Billy Creek) and the extent of those tributaries. Given this omission, I can have no confidence that the effects of this reduced connectivity have been properly assessed.
2. Reading the GHD report on the project, there has been no geological investigation of the site. This is of great importance for the reasons listed in the GHD report. GHD had to refer to an out-of-date Tamworth 1:250,000 scale geological map that shows a large region around the proposed Dungowan Dam site as undifferentiated Woolomin Beds. That is entirely unacceptable for a proposed dam site. Within the Woolomin Beds there will be a large amount of diversity of rock type and geological structure, all of which will influence the potential success of a dam. This Dungowan Dam proposal has been on the table for years, but still there is no detailed geological mapping. I am a very experienced geologist with decades of mapping experience and some background in engineering geology.
3. There is already a decrease in flow of Dungowan Creek below the existing dam. The dam wall and this decrease in flow are both contributing to lack of environmental connectivity for species such as fish and platypus. The proposed new dam will further reduce the flow in lower Dungowan Creek, increasing the disconnect between species above and below the dam. I is likely there will be times when there is no water in long sections of lower Dungowan Creek.
4. Any new dam in the Northern Basin will reduce frow into the Barwon-Darling. This project is a negative for the Murray Darlin Basin Plan.

Objections attached re Dungown Dam upgrade proposal

See attached

I am a professional civil engineer with a background in dam and reservoir benefits and optimisation.
The timing of the decision to proceed with Dungowan dam seems to have been made prior to a comprehensive project planning and without an assessment of more beneficial, cost-effective long-term solutions that will not damage the natural environment.
The planning process for Dungowan dam was initiated as a response to water security concerns across the state due to the impending drought. Planning and review resources were constrained due to evaluation of three (or perhaps four) dam projects being performed by WNSW and specialist consultants simultaneously. Now that the emergency has passed a more comprehensive assessment can be made.
Regarding the current proposal, the Environmental Impact Statement (EIS) appears to not comply with the Secretary of Planning assessment requirements (SEARs). The EIS does not analyse and optimise alternatives, assess all threatened species including those listed under Federal law or provide all assumptions used in modelling
The project will not meet its objective to provide the most cost effective or efficient option for securing Tamworth water supply. There is no analysis of the benefits of the proposed Tamworth Regional Council industrial water recycling project. The EIS fails to identify industrial use of Tamworth’s water supply where up to 50% of potable water is used by three large meat processing plants. Only limited options were analysed in the final business case.
The storage will lead to the loss of almost 200 km2 of high-quality native fish habitat and loss of migration opportunities for Federally listed threatened Murray Cod, Silver Perch and Eel-tailed Catfish. Dungowan Creek is within the threatened Lowland Darling River aquatic ecological community. Offset measures for impacts on threatened native fish are not adequate.
I think a more considered and complete options study and comprehensive EIS is required to satisfy the people of Tamworth, State taxpayers and the environment.

The proposed Dungowan Dam in the Peel River catchment is estimated to cost $1.3 billion to provide only an average of an additional 7,000 ML (million litres) per year and will not secure Tamworth water supply into the future. This water would cost an estimated $70,000 per ML while much cheaper alternatives are available. It is a very expensive National Party political promise with no assessment of more beneficial, cost effective long-term solutions that will not damage the natural environment.
Key points for submission: (use your own words and include additional knowledge)
1. The Environmental Impact Statement (EIS) fails to comply with the Secretary of Planning assessment requirements (SEARs). The EIS does not:
 analyse and optimise alternatives,
 assess all threatened species including those listed under Federal law,
 provide all assumptions used in modelling
2. The project will not meet its objective to provide the most cost effective or efficient option for securing Tamworth water supply.
 There is no analysis of the benefits of the proposed Tamworth Regional Council industrial water recycling project.
 The EIS fails to identify industrial use of town water supply. In Tamworth up to 50% of drinking water supply is used by three large meat processing plants.
 Options analysis was constrained by terms of reference developed in 2015 and does not reflect current best practice
 Limited options were analysed in the final business case
3. River health impacts:
 Loss of 192 km2 of high quality native fish habitat and loss of migration opportunities for
Federally listed threatened Murray Cod, Silver Perch and Eel-tailed Catfish.
 Dungowan Creek is within the threatened Lowland Darling River aquatic ecological
community. Offset measures for impacts on threatened native fish are not adequate.
 Dungowan Creek and Peel River have a healthy Platypus population that will be genetically
separated1

As a person who worked at high levels of Government in agriculture and irrigation development among other things, I was very familiar with Cabinet Submission processes. Therefore I was very embarrassed to read the Dungowan Dam Summary Business Case. In my hands, it would never have got up as far as Cabinet because it fails to analyse any alternatives, fails completely to make a business case despite the title, and reads like a con-job from the NSW Department of Planning and Environment. No wonder it was kept Commercial in Confidence.

Further, as a person who grew up in Tamworth, watched various dams fail (Moor Creek Dam, totally silted up; current Dungowan Dam, not adequate; Chaffey Dam, another ruinous shallow National Party boondoggle) and knows the regional agriculture and topography very well, this proposed new Dam would also be a failure. Although it might get the ‘right’ party elected, it fails on so many grounds it should never be built.

My major arguments against the proposal are
• the ridiculous cost of the water at $70,000 per megalitre, failing all possible cost/benefit analyses
• neither cost effective or efficient in securing Tamworth water supply (up to 50% of the drinking water supply is used by three large meat processing plants at present!)
• major river health impacts including that loss of Peel River flow will cause a failure to meet the Environmental Water Requirements of the Murray-Darling Basin Plan
• the project does not meet the NSW Treasury guidelines for a cost to benefit ratio of >1
• the Federal Productivity Commission deemed the project poor value

More positively, if there are unmet water needs after implementation of the proposed Tamworth Regional Council industrial water recycling project and other local initiatives, a pipeline from the existing Keepit Dam needs to be considered.

For some eight years I was engaged with Premier Colin Barnett in WA over expansion of the Ord River Scheme into the NT. In that time he continually pushed publicly for bringing water from the northern Fitzroy River to Perth. Initially he wanted an open canal, until he was convinced by evidence that the water would all evaporate long before reaching Perth. Then he promoted a pipeline, until he was given evidence that it would be far cheaper to pump the Fitzroy River waters into ships, transport to Perth, dump the water into the sea and then desalinate it!

If I bought the cheapest bottled water from Woolworths at $0.58/litre, it is only eight times the cost ($0.07/lire) of this Dam’s water. Ridiculous.

Objection to Dungowan Dam & Pipeline Project SSI - 10046
Vivienne Nano
U4/1A Donnelly St
Armidale 2350
I wish to lodge my objection to the development of the Dungowan Dam and Pipeline Project, which at an estimated cost of $1.3 billion, will do little to provide additional water security to the city of Tamworth. The dam will only provide an additional 7, 000 ML annually and the loss of flows in the Peel River will result in a failure to meet the Environmental Water Requirements of the Murray-Darling Basin Plan. It is my belief that further assessment of less impactful, more cost beneficial alternatives should be undertaken.
The Environmental Impact Statement for this project was undertaken in 2015 and thus no longer reflects current best practice as it did not scrutinise better alternatives sufficiently. Given that it is now known that the project threatens the habitat of 18 endangered species, including koala habitat and 5 other threatened species protected under Federal Law, it should not proceed.
Having recently lived through one of the worst droughts in history and witnessed firsthand how long it takes for a dam to fill after a drought breaks and thus how long it takes for environmental flows to resume, we know that damming a river exacerbates the environmental impact of a drought. 192 square kilometres of high-quality native fish habitat will be impacted, as will migration opportunities for federally listed Murray Cod, Silver Perch and Eel-tailed Catfish.
Given the significant environmental impact cost for such a small gain in the Tamworth water supply, I therefore request that the project not proceed and that more time and effort be given to examining alternatives to secure water for Tamworth.

178 Kentucky St
Armidale NSW 2350

28 November 2022

Submission re Dungowan Dam and Pipeline Project
From: Graham Marshall

To whom it may concern

Thank you for the opportunity to present my views regarding this proposed project.

Although I am not a resident of the Tamworth District that stands to benefit from this project, I have a keen interest in seeing our precious water resources nation-wide being used not only sustainably but efficiently and with least financial imposition on Australian and NSW taxpayers. I have concerns also regarding the consequences of this project for water flows into the Namoi River and the northern Murray-Darling Basin more generally.

I am also hoping that the Tamworth community can set an example to other rural regional communities, including my own around Armidale, on how to sustainably and efficiently solve its water security issues. Earlier this month I attended a forum convened by the Tamworth Water Security Alliance, and came away encouraged that a growing number of people in the Tamworth community were thinking of pursuing water security in more sophisticated ways than in the tradition of large-scale infrastructure exemplified by this project.

For the reasons outlined below, I would like to object to this project.

The proposed Dungowan Dam is estimated to cost $1.3 billion and provide only an average of an additional 7,000 ML per year. This water would cost an estimated $70,000 per ML. Much cheaper alternatives are available. The political promise that all construction costs will be covered from tax revenues does not meet current user pays policy for new water infrastructure in NSW and, more generally, under the National Water Initiative. It is fiscally irresponsible that a cost-benefit analysis of the project has not been undertaken, and I note that the (national) Productivity Commission deemed the project to be of poor value to the nation.

The Environmental Impact Statement (EIS) prepared for this project fails to comply with the Secretary of Planning assessment requirements. It does not: analyse and optimise alternatives; assess all threatened species including those listed under Federal law; and it does not detail all the assumptions used in modelling impacts.

The project is not the most cost effective or efficient option for securing Tamworth’s water supply. The EIS takes no account of the benefits of the proposed Tamworth Regional Council industrial water recycling project. It fails to identify industrial use of town water supply. The options analysed do not reflect current best practice, given that the terms of reference were developed seven years ago (in 2015). In any case, only limited options were analysed in the summary business case.

The project will have deleterious impacts on biodiversity. A significant area of critically endangered ecosystem and Koala habitat will be cleared, including habitat for many other endangered mammal and bird species. The EIS fails to assess 18 threatened species known or likely to be in the area of impact including 6 threatened species protected under Federal law such as the Greater Glider and 2 critically endangered plants.

Many sites of high Aboriginal cultural significance will be impacted by the project. Many of these sites require further research and not all of the pipeline easement was assessed. Cultural flow allocations in Dungowan Creek or the Peel River are not accounted for in the EIS.

The project will have serious impacts on river health. There will be a loss of 192 km2 of high-quality native fish habitat and a loss of migration opportunities for Federally listed threatened Murray Cod, Silver Perch and Eel-tailed Catfish. Dungowan Creek is within the threatened Lowland Darling River aquatic ecological community. The proposed offset measures for impacts on threatened native fish are not adequate. Dungowan Creek and the Peel River have a healthy Platypus population that will be genetically separated as a result of the project. The loss of flows in the Peel River will undermine efforts to meet the Environmental Water Requirements of the Murray-Darling Basin Plan and harm the environmental health of the Namoi River catchment.

Thanks again for the opportunity to provide feedback on this important matter.

Please see attachment