Warragamba Dam Raising

To whom it may concern,
I very much oppose the raising of the Warragamba Dam wall for the following reasons.
Thousands of hectares of National Park, which include some Threatened Ecological Communities, especially Grassy Box Woodland, unique eucalyptus species diversity acknowledged as having Outstanding Universal Value under the area’s World Heritage listing and habitat for endangered and critically endangered species including the Critically Endangered Regent Honeyeater and Sydney’s last Emu population, would be flooded.
Kilometres of wilderness rivers, including the Kowmung River, which was declared a ‘Wild River’ and protected for its pristine condition under the National Parks and Wildlife Act 1974, would also be flooded.
Thousands of identified cultural heritage sites would also be flooded by the proposed raising of the dam wall.
This proposed destruction of all that is precious to so many is tantamount to terrorism.
And that alternative options to raising the dam wall were not even considered in the EIS is just terrible.
Yours sincerely,

See Attached

Insanity is doing the same thing over and over again and expecting different results!
Please refer to my submission lodged previously.

Attachment B was too large and has been uploaded in smaller files
Attachment A to F and submission doc 1 2 and 3 and submission 221021 are attachment B

Please find submission attached

I oppose the project, based on:
• Damage to the World Heritage Area, upstream of the dam (impacting World Heritage Values, Environmental and Indigenous Heritage)
• Inadequate considerations and recognition of alternatives, that provide equivalent levels of flood mitigation for Western Sydney

The project is cost-ineffective and entails spending a very large (and likely to blow-out) amount of public money to provide limited benefit to primarily private assets. Whilst reducing flood severity in some areas, the project would increase flood duration over a substantial area, and would worsen flood severity upstream of the Warragamba/Nepean confluence once flood waters begin to be released from the dam.

A better method would be to buy-out the most flood-affected properties; improve flood-affected critical infrastructure it is more resilient; stop building on the floodplain; and fund large-scale catchment remediation in the Wollondilly, Cox's and Nepean catchments. There is great potential to reduce flood volumes and peaks through strategic revegetation, erosion control, stormwater detention in urban and industrial areas, better use of farm dams for storage and flood mitigation, and the use of artificial wetlands. Existing large storages can readily be better managed to provide a degree of flood mitigation rather than just maximising water storage.

The proposed use of on-park biodiversity credit discharge is problematic and objectionable. The argument makes it clear, by default, that the NPWS is under-resourced and not doing all that is should to maximise biodiversity conservation on its estate. The proponent seeks to backfill that deficiency by funding work that is arguably core business of the NPWS. The proponent's case largely hinges on the concept of what is an is not core business in park management for biodiversity. In many cases, this distinction isn't scientific but economic. The underfunding of the NPWS should not be used as the basis on which the proponent would discharge biodiversity credit obligations through doing what the NPWS should be resourced to do in any case.

The proposed purchase of land for addition to the NPWS estate is only valid where such lands were at risk from processes that would otherwise significantly degrade or destroy the values for which the land would be bought. In many instances, land proposed for addition to NPWS estate is not so threatened by the lack of conservation management that it can be considered at-risk enough to warrant being used as an offset. The situation is also fraught in that the State is the proponent of the higher dam yet also the consent authority for activities that can and do destroy or degrade biodiversity values elsewhere. Conceivably, the State could approve clearing of a native forest for a plantation or a mine, then determine that the area actually warrants purchase as an offset for the higher dam. The State could then argue that the purchase is a legitimate offset because without the purchase, the values of that land would be degraded or destroyed, yet that might only happen because of the approval to destroy those values given by the same State. Any such acquisitions would need to be independently assessed to determine whether the values are really threatened or if the State, through its actions or inactions, is the cause of those threats. A situation where an acquisition might be legitimate could be where existing use rights such as livestock grazing are the threat to key values, and the purchase would extinguish those rights.

Irrespective of how well biodiversity offsets might be able to operate, they do not consider Aboriginal cultural heritage values in which it seems unlikely that one area of 'country' can be destroyed if another area is reserved.

The Longneck Lagoon study is of limited value but shows that significantly flood-affected CPW is degraded by that process. Whilst increased weed diversity and cover is a concern along with reduced native flora cover and diversity, the large amount of suspended debris also poses a significant risk of high intensity canopy fire that could be very damaging. It seems ironic, at least, that the NSW Government invests in CPW conservation and promotes its protection, yet is here proposing a dam that would increase the duration of flooding of some ares of CPW (including in this NPWS reserve) and that this would degrade the affected areas.

The project generates more harms than benefits, and at great economic cost. The proposed offsetting of biodiversity values is problematic, even with the relatively precautionary assumptions that are used. The method fails to consider the irreplaceability of some values, and assumes that a mix of acquisitions, on-park management, and payments to the BCT will cover all credit obligations. I don't consider this to be sound from an ecological perspective, and it remains ethically dubious. There are some ecological values that would be lost to inundation and that cannot be offset through any of the proposed options, noting that payment to the BCT assumes that it would be able to purchase land/credits for those values at some stage. In some cases, it cannot do this because there are no such sites available for purchase as acquisitions or a source of credits. To have any credibility, the offsetting plan would need to fully disclose its obligations and its methods to genuinely offset them. I'm confident that some values cannot be offset, or at least not credibly.

To whom it may concern,
I do NOT agree that the Warragamba Dam Wall should be raised for the following reasons: More than half of floodwaters originate from areas outside of the upstream Warragamba Dam catchment--the Grose River and the Nepean River, so that regardless of how high the dam wall is constructed, it will not be able to prevent flooding in the Hawkesbury-Nepean Valley downstream.
The report seems to downplay the destruction of World Heritage and National Parks within the Greater Blue Mountains World Heritage Area which would be inundated by the Dam project.
Has the report paid any regarded to the concerns of Traditional Owners, including important information about sacred sites that would be flooded?
There must be better flood plan control, and better flood evacuation routes and warning established.
I request the Department seeks advice from the Aboriginal community and also listens to the people whose lives will be affected should this Warragamba Dam plan cause even more flooding.
Yours sincerely,

Objection to Proposed Raising Warragamba Dam

Guntawang Catholic Youth Centres Incorporated (Guntawang) is a not-for-profit incorporated association which owns property as an in-holding within Blue Mountains National Park. The property is called Kiaramba and is located on Scott’s Main Range some 12Km South of Mt Cookem. Property identifiers are Lots 1, 20 and 37 DP 757070.

Guntawang (and its antecedents) has occupied this site since 1943. The site provides a facility for people to use and enjoy Blue Mountains National Park. One of the buildings on the site remains open at all times providing free accommodation for visitors and walkers on the corridor through the Special Areas.

We wish to raise objections to the proposed raising of the wall of Warragamba dam for the following reasons,
1. The increase of the high water level will result in a change to the boundary of the Schedule 1, restricted access area which will affect our property.
2. The increase of the high water level will affect the popular North-South walking route through the corridor from the Megalong Valley to Nattai.

We would appreciate please return advice regarding decisions about changes to the boundaries of the Warragamba Special Area and any affect it may have on our property.

We also request please advice of proposed changes to the walking corridor as a result of the raising of the dam wall and subsequent changes to the high water level.


Regards,



Paul Wilcock
Secretary,
Guntawang Catholic Youth Centres Inc.
Reg. No. Y10264-07
ABN 56 382 262 923
M: 0427 106 107
E: [email protected]

see attachment

To whom it may concern,
I wish to state that I oppose the Warragamba Dam wall raising. I have previously stated my preference against it and has not changed since.
The Environmental Impact Statement is bias, and FAILS to address concerns raised in previous reviews:
1. The report has all but dismissed the concerns raised in 2,500 community and government agency submissions to the initial EIS in 2021, and in some cases expert submissions were not even addressed
2. The report has announced NSW Government intention's to ignore the advice of the UNESCO World Heritage Committee by changing the boundaries of the Blue Mountains National Park World Heritage Area.
3. The serious concerns held by Sydney Water and Health NSW about the effects the dam project would have on Sydney's drinking water quality have been dismissed in the report.
4. The report has attempted to downplay the destruction of World Heritage and National Parks. An estimated 65 kilometres of wilderness rivers, and 5,700 hectares of National Parks, 1,300 hectares of which is within the Greater Blue Mountains World Heritage Area, would be inundated by the Dam project.
5. The report has again disregarded the concerns of Traditional Owners, not including important information about sacred sites that would be flooded.
6. Over 1541 identified cultural heritage sites would be inundated by the Dam proposal.
7. The Aboriginal Cultural Heritage Assessment Report has been severely and repeatedly criticised by both the Australian Department of Environment and the International Council on Monuments and Sites (ICOMOS) for not appropriately assessing cultural heritage in meaningful consultation with Gundungurra community members.
8. There are alternative options to raising the Warragamba Dam wall that would protect existing floodplain communities. A combined approach of multiple options has been recommended as the most cost-effective means of flood risk mitigation.
9. Alternative options were not assessed in the EIS. No Any assessment of alternatives does not take into account the economic benefits that would offset the initial cost of implementation.
10. 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.
The above points laid out shows how little the revised report has changed. It shows lack of concern for the environment, the wildlife, the community, government bodies, scientists and public health.
All for creating a pathway to MORE irresponsible poor private developments that destroy our small remaining natural wonders.
I can't for the life of me support the wall raise. The natural environment is not 'owned' by anyone to do as they please. It is first and foremost exist for our unique wildlife, protect the air we breathe, water we drink and land we live on.
Yours sincerely,

see attachment

To whom it may concern,
My wife, I and all of our friends oppose the raising of the Warragamba dam wall as this will lead to severe damage to the World Heritage area and destroy Aborigine cultural sites that are important to them. This will also lead to the building of more houses on the flood plain where the overflow from the dam is but one factor that results in flooding. The proposal is a ban aid solution and ALL factors leading to flooding need to be addressed and the outflow from the dam is not the only cause of flooding.
Yours sincerely,

To whom it may concern.
I strongly oppose the raising of the Warragamba Dam. I am a resident of the Blue Mountains and have spent many years protecting the values of the Greater Blue Mountains World Heritage Area through voluntary and professional bush regeneration activities.
I do not accept that the raising of the wall will solve the flooding issue in the Hawkesbury-Nepean valley, and am concerned that the recent report does not adequately address the implications of the destruction of World Heritage and National Parks. The irreversible effects of flooding the Kowmung Wild River, the inundation of Aboriginal Cultural llHeritage and detrimental effects on threatened plant and animal species is completely unacceptable.
I am shocked at the disregard for the concerns of the Aboriginal Traditional Owners, the Gundungurra people, that sacred sites would be flooded. The lack of meaningful consultation with the Traditional Owners and the plan to destroy cultural heritage is extremely disappointing and suggests a complete disregard for the living culture of the Gundungurra and their Cultural heritage.
I believe there are alternatives to protect existing communities on the floodplain other than raising the wall, and am concerned that these do not appear to have been assessed.
Yours sincerely,

To whom it may concern,
I oppose the raising of Warragamba Dam.
The most recent report has basically ignored the vast community opposition to this project. It is ignoring the advice of the UNESCO World Heritage Committee, and the serious concerns held by Sydney Water and Health NSW about the effects on Sydney's drinking water quality.
The environmental impacts of this project are unacceptable. We need to protect biodiversity in such important areas as the Kowmung River and the Greater Blue Mountains World Heritage Area.
Furthermore, the report is disregarding the concerns of Traditional Owners, with the fact that over 1542 identified cultural heritage sites would be inundated by the Dam proposal. To forge ahead with this knowledge, and flawed assessment processes, is not only disrespectful, but violent.
My family has walked and camped in these threatened wild areas over many years. We have a strong personal connection and are devastated to see this beautiful, wild area threatened by the proposed raising of the Warragamba Dam wall.
I understand the need to protect people living on the floodplain below Warragamba Dam but believe that there are alternative options which do not involve the destruction of wild areas and areas of importance to the indigenous people of the area. Even the NSW Government's scientific committee has spoken against the dam raising. It is time to listen to the science, stop this proposal, and protect our World Heritage areas for perpetuity.

Yours sincerely,

To whom it may concern,
I hereby lodge my submission to the Warragamba Dam Raising Project. I would also like to state my opposition to this project.

I object to the report as it has again disregarded the concerns of Traditional Owners. Important information about sacred sites that would be flooded have not been included. Once again, the culture of the First Nation people has been rated as insignificant.

Over 1541 identified cultural heritage sites would be inundated by the Dam proposal. This is a significant loss and should not just be ignored by the New South Wales government.

The Aboriginal Cultural Heritage Assessment Report has been severely and repeatedly criticised by both the Australian Department of Environment and the International Council on Monuments and Sites (ICOMOS) for not appropriately assessing cultural heritage in meaningful consultation with Gundungurra community members. This needs to be reassessed.

I bushwalk extensively in the Greater Blue Mountains National Park World Heritage Area. Each visit provides new astonishment at it’s natural beauty. I return feeling refreshed and revived after a visit to the mountains. The New South Wales Government has no right to destroy any part of this World Heritage Area and the First Nation cultural sites found within.

Thank you for this opportunity to comment.

For the only planet we have.
Yours sincerely,

To whom it may concern,
I live in the upper Blue Mountains, and I’m deeply concerned about the NSW Government’s proposal to increase the height of the Warragamba Dam wall and the resulting environmental and economic impact that will have on the Greater Blue Mountains World Heritage Area.
I would like to respond to the Preferred Infrastructure report in the following way:
• If the Greater Blue Mountains World Heritage Area has seven layers of legislative protection, how can the government disregard these protections?
• By ignoring the advice of the UNESCO World Heritage Committee and changing the boundaries of the Blue Mountains National Park World Heritage Area, businesses throughout the Blue Mountains will be severely impacted. The region relies heavily on the tourism generated by the Blue Mountains National Park.
• The concerns raised by Sydney Water and Health NSW regarding the impact on Sydney’s drinking water quality during the construction and following the raising of the wall height have not been properly considered
• The report has disregarded the fact that the raising of the dam wall will inundate over 65 kilometres of wilderness rivers, 5,700 hectares of National Parks and 1,300 hectares of the Greater Blue Mountains World Heritage Area. The report has dismissed the environmental impact and consequences of this project.
• Flood Strategy, adopted by the NSW Government in June 2016, identified nine outcomes. Alternatives to raising the dam wall in order to mitigate damage in Western Sydney due to flooding such as building and improving flood evacuation roads, lowering the current supply level of the current dam, acquisition of properties on the lower flood plain and reducing floodplain development have not been considered. A combination of these alternatives would be a more cost-efficient approach.
• A 2017 Infrastructure NSW report on the Hawkesbury-Nepean valley flood risk management strategy states that the NSW Government intends to allow an additional 134,000 new residents to live on the Hawkesbury-Nepean floodplain. Development on floodplains should cease, especially as we have already witnessed the devastation to property and lives during recent severe flood events.
• An estimated 45% of floodwaters come 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.
• Raising the dam wall will flood habitat for the critically endangered Regent Honeyeater, Koala colonies and Sydney’s last Emu population.
• Warnings raised by expert ecologists state temporary inundation would cause permanent damage to the environment. These ecosystems are meant to be under water for a couple of weeks. These ecosystems may never recover. In addition, the cost of offsets required to pay for this permanent damage, will exceed government estimations, further adding to the cost of this project.
• The Black Summer fires of 2019/2020 destroyed 81% of the Blue Mountains Heritage Area. No post bushfire field surveys for threatened species have been undertaken to assess the damage inflicted by these fires.
• Over 1541 identified Indigenous cultural heritage sites would be inundated by raising the dam wall. The Aboriginal Cultural Heritage Assessment Report has not appropriately assessed cultural heritage in meaningful consultation with Gundungurra community members.
• Raising the dam wall would cause irreversible damage to natural and cultural values which would be a clear breach of Australia’s obligations under the World Heritage Convention.
I oppose the raising of the dam wall for the following reasons:
• After much work and dedication, the Greater Blue Mountains National Park received World Heritage Listing in 2000 and this listing will be at risk if the NSW Government goes ahead with this proposal. According to information provided on the NSW Department of Planning, Industry and Environment website, the listing was given in recognition of the area’s significant natural values. This website also states that the Greater Blue Mountains Area is one of the largest and most intact tracts of protected bushland in Australia. The raising of the dam wall would inundate and destroy vast areas of this protected bushland.
• The raising of the dam wall will not prevent flooding in low lying areas of Western Sydney. A 2015 NSW State Emergency Service report on the Hawkesbury Nepean Flood Plan states that an average of 45% of floodwaters originate from catchment areas that are not upstream of Warragamba Dam. How can we consider doing so much environmental damage by raising the wall when this action will not prevent flooding?
• Why is the government considering allowing more people to live on the floodplain if we know that major flood events will occur? It appears as though this decision is influenced more by economic considerations rather than public safety and protection of the environment.
• Why does nature always take second place to economic interests? The Regent Honeyeater is a critically endangered bird. An estimated 30,000 koalas were lost in the Black Summer fires of 2019/2020. I’m appalled that the NSW Government would consider inflicting more damage on the environment, the fauna and flora of the protected Greater Blue Mountains World Heritage Area for a proposal that will not stop flooding.
• The disregard for the Indigenous cultural heritage sites that will be inundated by raising the dam wall is extremely disappointing. It is disrespectful to our First Nations People.
• If this proposal goes ahead, it will further damage Australia’s international reputation in regard to our handling of environmental and Indigenous cultural issues.
• If this proposal goes ahead, future generations will not have the opportunity to experience the beauty of this wildness. What legacy are we leaving behind? What problems are we creating for future generations?

Yours sincerely,

To whom it may concern,
I am against the raising of the dam wall. My principal reasons are:
a) The raised water level will flood and kill important habitat for a variety of threatened fauna, in particular the critically endangered Regent Honeyeater.
b) The raising of the dam wall will cover and destroy a large amount of indigenous sites, many of which have been poorly documented.
c) Is a ploy for more housing development on floodplains downstream of the Warragamba Dam wall. With increasing flood events predicted as a result of climate change such development will result in the tax payer having to fund rescue of people in these areas and likely buy back of properties in the future as seen elsewhere.
Yours sincerely,

To whom it may concern,
I oppose the raising of the dam wall.
• The report has again disregarded the concerns of Traditional Owners, not including important information about sacred sites that would be flooded.
• An estimated 65 kilometres of wilderness rivers, and 5,700 hectares of National Parks, 1,300 hectares of which is within the Greater Blue Mountains World Heritage Area, would be inundated by the Dam project.
• Almost half of the floodwaters come from areas outside of the upstream Warragamba Dam catchment--namely the Nepean River and the Grose River. 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.
• There needs to be improved Flood Plan Development control, and flood evacuation routes established.
• I hope the Department will listen to the people and seek advice from the Aboriginal community.
Yours sincerely,

To whom it may concern,
I object to the raising of the Warragamba Dam Wall, on the basis that the logic of raising the wall to prevent future flooding is fundamentally flawed, and also due to the further loss of habitat surrounding the dam and loss of access to national park areas surrounding the dam by virtue of entension of the dam exclusion area.
For most of my adult life I have bushwalked, canyoned and caved throughout the Kanangra Boyd National Park/Wilderness Area and neighbouring Blue Mountains National Park. I have witnessed the loss of accessible national park through both the Kanangra Boyd Wilderness Area declaration, gating and locking accessible trails which serve no purpose but to keep people out so that the lack of weed and pest control is less obsesrved, and NPWS can reduce expenditure.
In more recent times, the Warrgamabe Dam exclusion zone has been extended to the crest of the Great Dividing Range on the Range Trail by acquisition of the Limeburners Flats and further restriction of access to the area.
Raising the the dam wall will increase the top water level and further extend the exclusion zone with loss of accessible national park and bush areas for public use. It will also further daage and detroy the habitat and environment between the existing high water level and the proposed new high water level.
And still, the floods down stream will not be prevented. Some may be reduced or controlled adequately, but there will always be pressure to increase the average stroage capacity of the dam to maximise Sydney's water supply. This reduces the ability of the dam to prevent floods downstreams as freeboard capacity is reduced.
Given the current situation where 3 consecutive la ninas have occurred, it is not possibloe to raise the dam wall enough to prevent spilling and subsequent downsteam flooding.
Preference should be given to buy back of affected residential properties, relocation of residents to non-flood prone areas, rezoning of the flood zones to less affected industries/uses to undo the damage done by previous greedy developers and the polititians that allowed these areas to be zoned residential. It was a mistake and the mistake itself needs to be corrected!
Raising the dam wall is a political stunt to increase the water supply capacity for Sydney. It is not a solution to flooding on the Hawkesbury Nepean flood plains.
Yours sincerely,