Warragamba Dam Raising

To whom it may concern,
Warragamba Dam Raising submission

I am a long-time bushwalker with 20 years experience as a walks leader with The Blue Mountains Conservation Society, Upper Blue Mountains Bushwalking Club, Springwood Bushwalking Club and the WEA (Workers Educational Association) in Sydney. This walking has inspired me to write a book about my walks in Gundungurra country and to research the pre- and post-contact history of the Gundungurra nation. I’ve led haiku walks, meditative walks, history walks and bushwalks. My book is in the last stages of completion but I‘ve published a history paper on the Burragorang Valley ( Blue Mountains History Journal #7, 2017). I’m also a published poet, most recently I was a feature poet on ABC RN’s “God Forbid” program during Poetry Month, August 2021 . I’ve visited many sites of the Gundungurra, networked with members of the Gundungurra community and shared my understandings with as many others as I can. There is still much to learn, and for the Gundungurra themselves, there is an ongoing process of unearthing and renewing culture and language.
The same could be said of flora and fauna, there are now 99 eucalypts in the Greater Blue Mountains World Heritage Area with a further 11 awaiting formal classification. There is a population of critically endangered Regent Honeyeaters and Sydney’s last emu population there. I have seen emu engravings in a number of places. Neither engravings nor birds should be put under stress, or erased. The waters of Lake Burragorang have already erased many important sites and the mere fact of the dam makes indigenous cultural processes complex, difficult and out of range for many. The archaeological survey that was conducted for the EIS was pitifully small, minute even. Raising the dam wall by up to 17 metres will scar 4,700 hectares of World heritage-listed National Parks and 1,800 hectares of declared Wilderness areas. There are 5 choke points of the Hawkesbury-Nepean River which cause floodwaters to spread out across a vast flood plain. Dyarubbin ( the H-N river) always did, always will, flood because of this “bathtub” effect. I’m also a kayaker, have explored the river and its tributaries. The dam only makes a difference to 45% of the waters flowing downstream when there’s a flood.
Do we value our heritage - 60,000 years of the longest continuing culture on the planet? - or do we continue the slow process of destruction even while we as Australians learn more and more about the shameful history of colonisation? Do we continue to push ecological communities such as Grassy Box Woodland closer to erasure? For what? When I looked at Warragamba dam recently (Feb 2021) I saw an insanely difficult valley to tamper with any further. This proposal is akin to the destruction of Jukaan Gorge by Rio Tinto, it is preferable to preserve heritage rather than apologise after its destruction. It is wasteful of NSW’s money and will not achieve safety for people living on a flood plain. Concomitant with stress for native flora and fauna, will be more opportunities for weeds and pests along the bigger cleared zone, which is exposed when the dam is low. I oppose this idiotic idea and encourage Water NSW to focus their energies on the water needs of primary producers in regional communities.

My partner and I are avid bushwalkers who frequent areas that would be affected if the dam wall was raised, like the kedumba valley which is rich in ancient and modern history. Also it has a raft of wildlife including platypus. Since the last fires over 80% of the blue mountains national Park have been affected. It should be left alone. It has been named a world heritage site for a very good reason.

To whom it may concern,world heritage sites must be protected from damage for now and the future for all people to enjoy especially the indigenous owners whose rights must be respected.

I oppose the proposal and the inadequate EIS for many reasons including those stated below.
• An average 45% of floodwaters into the Nepean-Hawkesury come from areas outside of the tributaries upstream of Warragamba Dam. So a higher dam wall will not prevent flooding downstream in the Hawkesbury-Nepean Valley but will create a false sense of security for people living on the flood plains.
• The plans of Minister Stuart Ayres to build homes for 134,000 more people on the floodplains on the basis that they will now be safe is, in my view, criminally irresponsible.
• The flood plains should not be developed as they are critical to our food security and the region’s ecological health. It is utter madness on the most arid continent on Earth to build suburbia on our best agricultural land which requires flooding for its rejuvenation.
• The government needs to stop all further development and improve drastically its evacuation routes and strategies.
• Up to 65 Kilometres of wild rivers, and 5,700 hectares of National Parks, including 1,300 hectares of the Greater Blue Mountains World Heritage Area, will be flooded by the Dam project. This includes the Kowmung River declared a ‘Wild River’ under the National Parks and Wildlife Act 1974; unique eucalyptus species diversity which was the primary reason for the Blue Mountains’ World Heritage listing; 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.
• Only 27% of the impacted area was assessed for Aboriginal Cultural Heritage. The Gundungurra community, whose Country this is, are implacably opposed to the destruction of more of their heritage and of the natural environment by the raising of the dam wall.
• Where is the modelling in the EIS of the flood and economic benefits of the dam wall?
• The threatened species surveys do not meet the standard requirements. Field surveys were not all completed, and expert reports were not obtained.
• Snowy Mountains Engineering Company (SMEC) that undertook the EIS was bought by Singapore-based Surbana Jurong in 2016. In 2017, the World Bank imposed sanctions on subsidiaries of the SMEC after an investigation into corporate misconduct. Why should we have any confidence in the work of this foreign-owned company with an appalling governance record.
• In 2020, Australia’s biggest insurer, Insurance Australia Group (IAG) AGM withdrew its support for raising the Warragamba Dam wall.

To whom it may concern,
I strongly oppose the proposed raising of the Warragamba Dam Wall. I have lived in Western Sydney for 65 years and during that time have regularly visited various part of the Greater Blue Mountains World Heritage Area.
Some, but not limited to, reasons why I oppose the proposal:
• Failure to properly and respectfully meet and engage with the Aboriginal Traditional Custodians.
• Failure to recognise and protect Aboriginal Cultural sites.
The Commonwealth Department of the International Council of Monuments and Sites have both stated very serious failings in the assessment of the impact on the cultural heritage of the Gundungurra Traditional Owners.
• Failure to protect endangered and critically endangered biodiversity and their habitat.
The irreversible impacts, include but are not limited to;
• Current Lake Surface Area - 7,300ha
• New Lake Surface Area - 12,300ha
• Wilderness Area Destroyed - 1,800ha
• World Heritage Submerged - 1,000ha
• National Parks Lost - 4,700ha
Flawed EIS
• The EIS does not pass the ‘pub test’ with sections of the original EIS omitted and facts and figures seemingly altered to provide an ‘enhanced’ picture for the proponents aims.
• Why would an EIS need to be altered unless there are facts that are not being provided to the Public? Surely this negates the ‘modified’ EIS? Clearly in the interest of the community the full, unaltered EIS as provided by the Consultants engaged to conduct it should be made available to the Public.
• It should also be noted that the biodiversity and cultural surveys were undertaken prior to the 2019/20 bushfires which burnt 81% of the Greater Blue Mountains. To gain a true picture of the current biodiversity and cultural status a new EIS should be commissioned before any decision is reached.

Failure to provide intergenerational equity
Future generations should be assured of intergenerational equity and not be ‘robbed’ of their rights to experience what the previous and current generations have enjoyed.
Aboriginal Culture and Cultural Sites should be conserved and given the highest protection possible so that future generations can learn about Aboriginal culture from Aboriginal Australians.
The GBMWHA should be given the highest protection possible by the present generation to ensure World Heritage status is never put at risk of being lost.

My research indicates there is a great deal of opposition from many, including but not limited to, Aboriginal Traditional Owners and people, other sectors such as the Insurance sector, politicians, local Councils, many conservation groups and a large number of the general Public.
So why is there so much opposition by such broad sectors of the Community?
Who is going to gain mainly for the raising of the Dam Wall? Developers? Some Politicians?
Have other options to reduce the impact of major floods been fully investigated?
This ‘solution’ to the flooding issues is near sighted and poorly researched with the long term effects being ignored or minimised. Irreversible damage and loss will occur and the risk of losing World Heritage status is real.
I support the submissions of the Colong Foundation for Wilderness, National Parks Association of NSW, Blue Mountains Conservation Society and all Aboriginal organisations and individuals opposing the raising of the dam wall.

To whom it may concern,
Im an avid bushwalker and lover of what is left of our natural environment. It would be devastating and irresponsible to endanger or destroy such a natural wonder.
There are 80 known species of threatened flora and fauna at and upstream of Warragamba Dam. The inundation of national parkland and part of the Greater Blue Mountains World Heritage Area, for at least two weeks at a time, will have significant detrimental impacts on threatened species. This includes two critically endangered ecological communities being the White Box-Yellow Box-Blakely’s Red Gum Grassy Woodland and Derived Native Grassland, and the Shale Sandstone Transition Forest of the Sydney Basin Bioregion. Threatened animals that will be impacted include the endangered Macquarie perch and the critically endangered regent honeyeater. Fewer than 400 mature regent honeyeaters remain in the wild. It is a species on the brink of extinction.
At the World Heritage Committee Meeting held in Azerbaijan in 2019 the UNESCO World Heritage Committee stated “the inundation of areas within the property resulting from the raising of the dam wall are likely to have an impact on the Outstanding Universal Value of the property”. In 2018, Ian Travers then president of Australia ICOMOS stated the raising of the dam had the potential to place the Greater Blue Mountains World Heritage Area on the World Heritage Committee’s List of World Heritage in Danger.

Adverse Impacts
• Fragments and degrades two World Heritage list wilderness national parks
• Degrades world famous scenery of the southern Blue Mountains
• Reduces rare biodiversity, including 40% of the Nationally threatened Camden White Gum forest
• Aboriginal cultural heritage destroyed
• Loss of classic bushwalking areas, historic campsites drowned and access restricted
• Further urban sprawl on the floodplain and degradation to the Hawkesbury-Nepean River.
A better solution is to lower the full supply level for flood mitigation. This provides most of the benefits of the proposed dam wall raising and respects our international obligations to protect World Heritage.

To whom it may concern,
Submission re project no. SSI-8441- re raising Warragamba Dam Wall

I am Margaret Potts and I live in Wentworth Falls in the Greater Blue Mountains World Heritager Area, and this is a great privilege. I have chosen to move here from the inner Western suburbs on my retirement. I wished to be able to access more easily the walks, the flora and fauna in this wonderful area. I was fortunate as a child the my parents brought us to the Blue Mountains for holidays and day trips. They shared with us the joy of walking in the National Park, and of understanding our environment.And I have continued these activities all my life with great pleasure.
I object to the raising of the wall of Warragamba Dam for the following reasons.
1. The damage that would be done to the Greater Blue Mountains Heritage Area by the higher water levels, even if the submerging of country is not permanent.
The denuding effects of dammed water on the usually submerged environment have been seen when the water levels are low in the current dam. Raising the dam wall will increase markedly the area inundated,even if only for several weeks, and hence, more denudation upstream from current water levels. This will involve wilderness areas and 'wild rivers' such as the Kowmung. The Kowmung has been protected for its pristine condition under the National Parks and Wildlife Act since 1974
Inundation above current non drought levels will drown habitat for critically endangered Regent Honeyeaters, Koala colonies and Sydney's last Emu population.
Apparently a very short time, such as 3.5 hours, was spent by assessors searching for Koalas, and perhaps a day assessing the impacts to aquatic life, including the threatened Platypus.These are incredibly short times for assessing inconspicuous fauna.
Unique eucalyptus species diversity recocnised under the World Heritage listing, and a number of threatened ecological communities, notably Grassy Box Woodland will be inundated with raising the dam wall.
Not only have the Gundungurra Traditional Owners not given free, prior and informed consent for the dam proposal to proceed, but over 1541 identiefied cultural heritage sites would be inundated by the Dam proposal
Such damage will threaten our World Heritage status with the damage to natural and cultural values. The area's World Heritage status is a strong drawcard for tourism to the area, and very important for all the above reasons to the people fortunate to live in and value this environment.
2. The water draining to Warragamba Dam is only part of the cause of flooding in the Hawkesbury- Nepean floodplain.The Grose and the Colo are signiificant contributors to the flooding. And with climate change, more storms, and hence more flooding will occur.
Other ways of defusing the flooding issues could include a decrease by, eg ,12 m would free airspace for flood control. Water recycling and desalination plants could increase Sydney's water security.
People's lives and property damage due to floods could be prevented by not placing housing and hence people in extremely flood prone areas, such as floodplains.

I would urge that the Dam wall not be raised for the above reasons.
Additionally,this project going ahead would undermine the legislation which is the foundation of environment protection in N.S.W. Approval of the project would set a dangerous precedent for Australia's World Heritage and National Park protections.

To whom it may concern,
When I was approached early in 2019 - in my capacity as a filmmaker and longterm Blue Mountains resident - to work on the production of a video explaining the issues relating to the raising of Warragamba Dam wall, I did not hesitate. After considerable research into the history and environment of the Blue Mountains National Park and World Heritage area, the country under threat is fairly well known to me. Perhaps you are also aware of some this history - the hunting grounds of a thousand generations of Indigenous inhabitants, including those who were among the first to meet and intermarry with European settlers. During the 1950s their descendants were finally moved out when the first dam wall went up. Large portions of what little was left to them is now being considered for destruction.
After two centuries of upheaval and disinheritance, the Gundungurra remain the custodians of a unique and ancient culture, uprooted yet inseperable from these traditional lands. It seems outrageous that we could consider further damaging their Country today.
Of course there are numerous other reasons for concern, and each will no doubt be discussed in detail by many qualified individuals - issues with future water quality and threatened species, for instance, and all under the pretence of water security, of which I have seen nothing to convince me during the long process of proposals and debate on this subject.
In the first years of the 20th century conservationists began their campaigns to protect these now threatened areas in earnest, realising that without them we are all diminished, that so few wild places like this remain. Read the journals and letters of people like conservationist Myles Dunphy, whose memoirs were recently celebrated in an exhibition at the State Library of NSW, and it is clear that a hundred years ago Australians were willing to dedicate their lives protecting what was then already fast disappearing.
They realised they weren't the last generation.
I want my children to see these places, to drink fresh water, and to discover the Australia of the Gundungurra.
For these reasons I also did not hesitate when the opportunity arose to serve as a Director of the Colong Foundation for Wilderness to assist in raising awareness about flooding our World Heritage.
Nothing I have learnt about this proposal convinces me that its benefits outweigh the losses we face if it goes ahead.
As a producer of the Give A Dam film, I encourage you to watch it and please consider it a supplement to my submission.

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>>>>>>> Warragamba Dam Raising Project -SSI-8441-Patricia Schwartz, Co-ordinator Glenorie Maroota Bio-Regional Forum Inc.
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>>>>>>> Thank you for the opportunity to comment on the Warragamba Dam EIS.
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>>>>>>> The following comprises an objection to the proposal to raise the dam wall for flood mitigation. Please find issues supporting the objection listed below.
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>>>>>>> 1. The ecological assessment for upstream and downstream impacts are inadequate. This has been publicly stated by a number of organisations and community bodies and in particular has been revealed by testimonials to the NSW Upper House Parliamentary Inquiry on raising the dam wall.
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>>>>>>> 2 The former primary assessor for biodiversity surveys and analysis for the EIS refused to sign off on the project because of ‘substantive changes’ to the EIS.
>>>>>>> This action immediately triggers a lack of faith in the reliability of this EIS.
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>>>>>>> 3 The United Nations World Heritage Committee has raised concerns for the Heritage-listed Blue Mountains National Park. In the light of these concerns the offset strategy for the proposal discussed in the EIS is too open. Specifically land that fits the offset requirements could be nominated. For example there are sizeable land holdings in NW Sydney, adjacent to National Parks and around the Maroota area that have very high biodiversity values that have previously been of interest to the National Parks Estate.
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>>>>>>> 4 A cross party NSW parliamentary committee recommended that alternatives to raising the dam wall for flood mitigation should be sought. Alternatives to raising the dam wall have been dismissed in the EIS as not economic. These alternatives need to be discussed further in the EIS with a view to future management strategies for the floodplain. Further to this the Insurance Council of Australia has withdrawn its support for the Warragamba project.
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>>>>>>> 5 SMEC Engineering, the consultants for the EIS has been the subject of allegations regarding some overseas projects that concerned indigenous matters.(Government Newsletter 10th October 2019).
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>>>>>>> 6 The geomorphology technical assessment in the EIS says assessment of large scale geotechnical landslide/land stability/failure issues caused by water infiltration of basal surfaces and/or land surface disturbance of lake Burragorang Valley has not been performed.
>>>>>>> The explanation for this is that this information has been provided in a previous SMEC EIS from 2020. However given that 1000 gigalitres (Sydney Harbour holds about 500 gigalitres) is planned to be held back for flood mitigation a technical assessment of risks to land stability should be included in this EIS.
>>>>>>> On March 9, 1973 Warragamba Dam experienced a magnitude ML 5.5 earthquake followed by 300 aftershocks (Earthquakes and Dams in Australia, Gary Gibson Seismology Research Centre). This was a result of reservoir induced siesmicity. In other words the impact of the huge amount of water held in the dam.
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>>>>>>> 6 In light of the location of Warragamba Dam sitting above the very large population of Western Sydney, comprehensive risk management concerning any level of future dam failure should be included in the EIS. Two documents that might be relevant to this are Earthquakes and Dams in Australia (already mentioned) and Preparing for Dam Failure by Chas Keys State Planning and Operations Coordinator. Neither of these documents appear in the bibliography of the EIS.
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>>>>>>> 7 The limitations to the proposal for flood mitigation as expressed in the EIS is demonstrated by the March 2021 flood where the Warragamba catchment contributed less than 60% of the flow. The below dam flows contributed the rest of the flood water.
>>>>>> The impacts of downstream flooding are undeniable. Other mitigation measures should be found that do not impact the upstream environment in the World Heritage National Park.

To whom it may concern,
I am strongly opposed to the proposed raising of Warragamba Dam wall.

I have been a resident of the Blue Mountains for 24 years and my opposition to the proposal is based on the following:

- There are several of serious flaws in the EIS. These include a lack of updated field surveys since the 2019/20 bushfires that burned significant areas of the Warragamba catchment area; Threatened species surveys are substantially less than guideline requirements. It has been reported that in some cases, endangered species surveys were completed in less than a day, which is completely inadequate for such a large area. Where field surveys were not adequately completed, expert reports were not obtained; Only 27% of the impact area was assessed for Aboriginal Cultural Heritage; modelling of the expected economic benefits is not included in the EIS; impacts to Sydney's drinking water supply upstream of the dam wall, have not been adequately considered. There will be impacts to water quality from flood/drying/regrowth/flood cycles in currently vegetated areas (newly flooded) that should be fully considered as there is potential to affect 80% of Sydney’s drinking water supply

- The Blue Mountains World Heritage listing (already under threat from the Western Sydney Airport) of the Blue Mountains National Park will be further threatened. Raising the Warragamba dam wall and consequent damage to natural and cultural values would be a clear breach of Australia’s undertakings and obligations under the World Heritage Convention.

- Raising the Dam wall will not prevent severe flooding risk downstream in the Hawkesbury Nepean valley, but will allow rezoning of currently flood prone land for development. Estimates show that 45% of floodwaters are derived from areas outside of the upstream Warragamba Dam catchment. With more development, additional human lives will be placed at risk in flood events, with significantly more complexity and time required to effect evacuation and rescue

- Gundungurra Traditional owners have not given free, prior and informed consent for the proposal to proceed. Over 1541 identified cultural heritage sites would be inundated by the Dam proposal. The Aboriginal Cultural Heritage Assessment Report has been 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

- alternative, more cost effective combined approaches to flood mitigation have been recommended but not comprehensively assessed in the EIS

The current environmental assessment is fundamentally flawed and as such, cannot support a decision to raise the Warragamba Dam wall. The proposal should be shelved and alternative flood mitigation strategies for the Hawkesbury Nepean Valley given full and proper consideration.

To whom it may concern,
I am currently studying a Masters of Conservation Biology and as such I am seeing the huge devastation that human developments such as dams have on both our environment and Indigenous cultural heritage/connection to Country. Although I understand that the safety and lives of people must be a high priority, I believe there are alternative options to the raising of the Warragamba Dam wall that need to be considered such as discontinuing development in flood zones, reinforcing existing structures, and creating updgraded roads and emergency infrastructure for future floods (which will continue to occur regardless of the raising of the Warragamab Dam wall). And if a raising of the wall was to occur, I would urge it to be at a much lower level.
In flooding World Heritage listed environments, conservation areas, national parks and identified Indigenous Australian cultural sites, sets an example that no matter how valued or protected an area is at the local and/or international level, mass destruction can still occur with little consideration for the environmental or cultural impacts.
Another concern I have is that offsets for the destruction of vital areas of biodiversity are not good enough. For one, there is no way to offset extinctions such as the threatened regent honey eater who will be affected by the raising of the wall. It will also be impossible to offset the destruction we will see on biodiversity and ecosystems within the inundation area.
In terms of Cultural Heritage offsets, access to other cultural sites within the area bi-annually is not good enough, nor are photos of what will be lost adequate offsets. I urge that at very least, if the wall was to be raised, that offsets create opportunities for Indigenous Australians who have ties to the land and who have been disconnected from the land due to original Warragambah Dam creation. Opportunities such as co-management of the land and increased access for cultural connection. Even without the raising of the wall, I would encourage these actions to occur.
I object to the raising of the Warragamba Dam due to the devastating losses that will occur to the environment and Indigenous cultural sites.

To whom it may concern,
I do not want the dam wall raised. It will impact on the Blue Mountains National Park & associated wilderness areas. Impacts include raising river water levels in the Cox's , Kowmung & Wollondilly river systems. The associated restricted access area around the dam will enlarge & affect access by bushwalkers & paddlers to these beautiful & wild areas.
As both a paddler & bushwalker this saddens me due to the affect on wildlife & limited access to the dam affected areas.
Sydney is a huge city & we need to preserve surrounding wilderness/ National parks for quality of life of city folk. Mental & physical well being is increased through access to National parks for rest, relaxation & physical exercise. Allowing the degradation by raising the dam wall will impact on the access & existence of some prized bushwalking & paddling country.
Further expansion to the city through building on flood plains will increase population pressure in outer North -Western Sydney areas such as Penrith, Richmond & Windsor areas. The vegetable growers in these areas use the fertility of the flood plains for growing fresh food & a number of turf farms exist in this area. Lower density living in outer areas allows for horse riding & bike riding. These areas permit diversity of recreational & work choices & lifestyles.
The rugged terrain around the Sydney Basin has facilitated the area being perserved in National Parks due to the challenging nature of accessing these areas. This has facilitated a range of habitat for our nature flora & fauna. We are loosing habitat & species currently at an amazing rate & need to look after the remaining biodiversity that exists in areas such as the Blue Mountains including the Regent Honey Eater & our dangered Koala's that have been so impacted by extensive bush fires 2 years ago.
It is a world heritage site & this status may be endangered by further erosion of wilderness areas. Preserve this area for the sake of future generations & the economy of the Blue Mountains communities that depend on income from visitors all over the world to see & experience this amazing area.
Please don't increase the size of Warragamba Dam value the intact World heritage area & all it's biodiversity. Leave a wilderness area which can be accessed by local & Sydney people for generations to come.

Submission–Warragamba Dam Raising Project –SSI-8441 –Hornsby Shire Council, Hornsby

Hornsby Shire Council (HSC) has reviewed the EIS for Warragamba Dam Raising Project from both a flooding and an ecological health perspective. This submission includes consideration of hydraulic impacts, along with recreational use and activities, the potential ecological impact on riparian vegetation, aquatic fauna and flora and the needs of commercial operators across the lower section of the Hawkesbury estuary (namely Estuary Prawn Trawl Fishery, Estuary General Fishery and Oyster Aquaculture operators).

Flooding and hydraulic impacts

Hornsby Shire Council (HSC) is an active project partner in several technical working groups investigating flood modelling and mitigation strategies for the Hawkesbury-Nepean catchment. In particular we are currently involved in Infrastructure NSW’s Hawkesbury-Nepean River Flood Study and we have recently engaged consultants from Rhelm to assist a consortium of Councils managing the Hawkesbury estuary in filling in knowledge gaps for a Tidal inundation study at the entrance section of the Hawkesbury River system as part of the development of the Hawkesbury-Nepean Coastal Management Program (CMP, further information on this program below).

Wisemans Ferry area represents the upstream LGA boundary for Hornsby Shire. The EIS identifies, based on the downstream hydrological modelling, Wisemans Ferry area as the furthest downstream section of the river system that will be slightly impacted by the Dam Raising project.

As described in the EIS documentation, HSC acknowledges that Warragamba Dam Raising is a project to provide flood mitigation to reduce the significant existing risk to life and property in the Hawkesbury-Nepean Valley downstream of the dam.
HSC supports the information provided for normal operations of the dam that occur when the dam storage level is at or lower than the Full Supply Level (FSL). As noted in the documentation no changes are expected. These operations are essential contributing to environmental flows in the estuary, which is key to sustaining the ecology of the aquatic fauna of the estuary.

Our main concerns are in relation to the downstream impacts from the management of flood operations in the Flood Mitigation Zone (FMZ) when the water level approaches the FSL and/or the ‘controlled discharges’ as per Fig 9-4 included in your documents. We consider these operations will have associated socio-economic and ecological significant impacts that have not been sufficiently considered in the EIS documentation.

When the EIS refers to ‘downstream’ impacts or assessments it focuses mainly in the stretch of river from directly downstream of the dam to Wiseman Ferry after which downstream impacts are negligible. We note that some of the maps provided present the boundary of this project to be the M1 freeway bridge crossing the Hawkesbury from Kangaroo Point to Mooney Mooney. However, most downstream aspects of the various components of the EIS relate to the area from the dam wall to Windsor. Council wish to highlight that this is not entirely accurate from a hydrological, ecological and water quality point of view.

HSC manages six real-time water quality monitoring stations deployed along the main arm and in some of the major creeks of the Lower Hawkesbury (from Wisemans Ferry to the confluence with Cowan Creek at the mouth, HornsbyShireCouncil (mhlfit.net)). These stations not only collect water quality information, but they are also used to provide advice to the oyster industry on the management of their oyster harvest areas, to assist the school prawn industry in identifying best trawling grounds and to provide daily swimming conditions for community to interact with the estuary in a safe way. In addition, a significant amount of work goes into monitoring the water quality of the estuary which includes harmful algae and pathogens. Based on a close inspection of the HSC monitoring stations data and dam releases when the water level is higher than the FSL over the last 2-3 years we see significant impacts including:

• significant drops in salinity levels in the Lower Hawkesbury which has impacts on the ecology of the local aquatic fauna and riparian vegetation (mangroves). Impacts on mangroves, in particular, has been exacerbated by the impact from both recent floods in 2020 and 2021
• significant drops in salinity impacting the period during which oysters can be harvested which creates significant economic consequences to the Hawkesbury oyster industry. This is particularly important when dam releases are around or above 3,500ML/day for longer than 2 weeks.
• changes in salinity and turbidity levels result in changing in the areas used by school prawns and mud crabs which means the industry needs to adapt to these changes
• overall changes in water quality have been observed when discharges exceed 5000ML/d during a week. We are expecting associated downstream changes in nutrient cycles and algae species dynamics (unfortunately last 2 years of HSC’s field monitoring has been impacted by COVID restrictions)
• prolonged discharges also result in changes in tidal exchange and water residence times, in particular for the secondary estuary arms like Berowra Creek, Mangrove Creek, Mooney Mooney Creek and Mullet Creek
• changes in salinity along the river/estuary, not associated with typical catchment run-off (stormwater, rainfall), are impacting the swimmability algorithm currently used to provide advise on swimming conditions in the Lower Hawkesbury estuary

Statutory and Coastal Management Framework

In addition, the EIS does not consider the objectives of either the Marine Estate Management Act, 2014 or the Coastal Management Act, 2016. These two overarching statutes govern the management of the NSW marine estate and coastal zone respectively. While we acknowledge that the ultimate goal of the project is to provide flood mitigation to reduce the significant existing risk to life and property in the Hawkesbury-Nepean area, more consideration of the impacts on receiving waters should be provided in the context of the legislation above and the management frameworks, guidelines and programs developed thereunder. In particular:

• Hawkesbury-Nepean River Coastal Management Program (CMP, See: Hawkesbury Nepean River System CMP (www.hawkesburynepeancmp.org)) - The six councils with management jurisdiction over the lower river (Hawkesbury, The Hills, Hornsby, Kur-ring-gai, Central Coast & Northern Beaches) are working collaboratively to develop a whole of system CMP in accordance with the NSW Coastal Management Framework. The study area for this CMP extends from the tidal limit of the river at Yarramundi to the ocean and encompasses the associated estuaries of Brisbane Water, Broken Bay and Pittwater. The development of a CMP follows a risk-based process whereby threats and stressors to the system are identified, assessed and ultimately addressed through the development and implementation of management actions. CMP’s must address the objectives of the Coastal Management Act, demonstrating how these will be achieved and ultimately how management intervention will improve the health and vitality of the coastal zone. The impacts of flooding, particularly the combine process of catchment flooding and oceanic inundation, are key hazards that need to be considered under the CMP. It is recommended that the EIS consider the impacts on the lower river in the context of the CMP with a focus on the first pass risk assessment contained within the stage 1 scoping study and the current Industry NSW (INSW) Flood modelling project.
• Marine Estate Management Strategy (MEMS) Threat and Risk Assessment (TARA, See: Threat and risk assessment (nsw.gov.au)) - MEMS is underpinned by a statewide TARA which identifies key threats to the NSW Marine Estate in order to prioritise funding and management of these processes. Key priority threats to the NSW Marine Estate include modified freshwater flows and flooding which are both likely to be exacerbated under climate change scenarios. The impacts of these processes along the lower river are multi-faceted ranging from social impacts on the ability of the community to utilise the river for recreation, economic impacts on commercial tourism, fisheries and aquaculture and environmentally ranging from direct impacts on riparian zones, foreshores and wetlands to trophic impacts within the river. While these impacts may be of a relatively short duration presently, it is likely that frequency and duration will increase under climate change scenarios. It is recommended that the EIS consider the impacts on the lower river in the context of the MEMS TARA.
• Need for a collaborative approach across all levels of government regarding floods and floodplain management. This has been highlighted in the Resilient communities Hawkesbury-Nepean Valley Flood Risk Management Strategy 2017 prepared by INSW. There appears to be a lack of coordinated and transparent alignment between this Strategy and dam proposal.

In summary, the EIS should recognised the social, economic and ecological impacts from prolonged dam discharges and/or flood operations when the water level is higher than the FSL even if these impacts are not as severe as for the areas directly downstream of the dam wall. The commercial fishing industries and recreational users of the Lower Hawkesbury estuary rely on optimal water quality conditions for their operations and activities. We encourage communication regarding dam’s water release management with downstream users and management practitioners with the aim of managing flood risk resulting in minimal impacts downstream (Wisemans Ferry to the mouth of the Hawkesbury River).

I write as a concerned resident of the Blue Mountains, Registered Psychologist, Registered Teacher, and Accredited Teacher of Permaculture Design.
I live and advocate for Earth Care, People Care, and Shared Care. I have been fortunate to have learnt so much about Planetary Health from Aboriginal Elders and consider their wisdom and knowledge fundamental to a sustainable future for my children and grandchildren. They have explained comprehensively (backed by planetary health research) that raising the Warragamba Dam will destroy the habitat of the Regent Honey Eater, Koalas, and the last wild Emu population in Greater Sydney. Indeed it will cause irreversible damage to threatened species, wild rivers and risk the World Heritage listing of the Blue Mountains. This area has already lost an area the size of Wales, UK in the last bushfires that devastated the ecosystem of the Blue Mountains.
Given the evidence of recent floods and historical records it is inexplicable why houses are being built on a known flood plain. A raised dam wall will not prevent local flash flooding which, as the climate continues to change, is becoming more prevalent.
Enough has been done to remove natural ecosystems that are essential not only to Earth Care but People Care without the voice of our children and future generations who will inherit an unhealthy and depleted plant. We need to take every step to reverse this trend not accelerate it.

To whom it may concern,
I feel that placing a dam here would be a huge dissapointment. These lands are both special and sacred and it shouldn't be altered by things such as dams as they cover up land that can ever be accessed again. I am a gundungurra woman and really value the natural state of our lands and the preservation of them and all that it holds.
Yours sincerely,
sharon Robbie

Submission – Warragamba Dam Raising Project – SSI-8441
I object to the proposal to raise the Warragamba Dam wall for the reasons outlined below.
I have not made a reportable political donation in the past two years.
I accept the Department’s submissions and disclaimer declaration.
My reasons for objecting to this proposal are as follows:
I am worried that many valuable artefacts will be washed away and sites of significance destroyed and made inaccessible. In addition a beautiful area of Country will be drowned and lost. In addition to specific artefacts and sites of significance, there is the loss of the experience of being on and connecting with this pristine Country if it is subject to flooding in this way.
The history contained in this place is precious and ancient. The Opera House is precious and it would never be traded for water management arrangements, so why are Aboriginal sites of significance considered expendable that are so much more ancient and irreplaceable. I respect that progress is necessary but at what cost? Does so much history need to be wiped out to achieve these ends? It is important to recognise that much has already been lost in previous developments and considerations of this loss need to be put in the context of a long history of Aboriginal sites being sacrificed in this area for development. It cannot be assessed only in terms of the loss associated with this particular proposal. That is a distorted way of assessing it.
Beyond the loss of tangible and intangible cultural value and the sense of grief and loss associated with that, is the message it will send of Aboriginal values of being lesser importance than European values. It sends a strong message of disregard and that little has changed from past practices that the government now claims it is sorry for. The bottom line is that if it was ancient European artefacts at risk of destruction this would be a different conversation. The message is that Aboriginal people are still not equal to non-Aboriginal people in this country.
With regard to minimising the harm or compensating for it - While some smaller objects can be removed, shelters and other sites of significance will just be destroyed. Although there are examples in other places of scar trees being relocated, this is not always feasible. Also in this instance we are talking about such a large area and so many artefacts. I cannot see how protection is really possible in a meaningful way.
The government has asked about compensation as an alternative to protection. But in my view it is not possible to compensate for the irreplaceable. It cannot be assigned a measurable value. There is no suitable compensation for this kind of loss. The only solution is to find a different way to manage the water.
I understand that there has been a suggestion that by raising the wall this may protect artefacts and sites of significance from flood damage downstream. I cannot engage with this theoretical question. I do not trust this assertion. And when the flooding happens downstream anyway, then it will be too late. So I cannot endorse this trade-off.
I lodge this submission in the hope that it will not only be read but really be heard. Although things are improving, the fact remains that Aboriginal people are treated as second class citizens in this country in many ways. The value placed on their cultural heritage and relationship to Country when it is an obstacle to development is one of many areas where this double standard is keenly felt and clearly still applies. There is a general sense that these processes are somewhat tick-box and that the government will just do what it wants to do and in line with European rather than Aboriginal values and priorities. The government needs to actively demonstrate that it is giving the views of the Aboriginal community equal weight in these kinds of consultations.