Warragamba Dam Raising

The EIS provides only a rudimentary discussion of alternatives to raising the dam wall in order to achieve the desired objective of the Hawkesbury Nepean Valley Flood Risk Management Strategy of reducing flood risk to life, property and social amenity from regional floods in the valley. Previous studies have identified alternative mitigation measures to manage flood risk that achieve similar outcomes without the massive detrimental effects on areas of the Blue Mountains National Park and the Blue Mountains World Heritage Area including numerous indigenous cultural heritage sites and threatened and endangered flora and fauna. Further, the discussion of the assessment of alternatives notes "Alternatives such as major new or upgraded regional roads, buyback of dwellings or disallowing new dwellings do not change flood depths and extents." Recall from earlier in the EIS that the objective of the project is not change flood depths or extents - it is to reduce flood risk to life, property and social amenity. While a raise dam will achieve some of the objectives, so too do other alternatives. Buyback of properties below the 1:100 or 1:500 AEP flood levels will reduce flood risk to life and property. Coupled with improved flood evacuation routes for properties above these level, risk to life can be suitably managed without the massive adverse impacts associated with dam wall raising. I call on the NSW Government through the planning department to abandon the plan to raise the dam wall and instead pursue other options or combinations of options that have far less dire consequences for our natural environment.
As a bushwalker who has visited the pristine Kowmung River in the past I am particularly concerned about the impacts of days of inundation on the river system and its beautiful but fragile banks that would occur post raising of the dam. As one of only 6 declared wild rivers in all of NSW, it seems bizarre to me that the same government charged with protecting this river can at the same time propose a scheme that will at best result in significant degradation of its value as a wild river or at worst significantly and permanently impact on a large stretch of this river.
Given the above I strongly urge the NSW to reconsider this approach to management of large floods in this area and further consider the alternative less destructive options.

I have been bushwalking in the Blue Mountains for the last 60 years.

I oppose raising the Dam wall, as it will seriously impact on substantial sections of a pristine National Park and create permanent damage to the Blue Mountains wilderness areas, particularly the Kowmung River, one of the last untouched rivers in NSW.

My additional reasons are:
. Systematic failures of the EIS
. The engineering firm (SMEC Engineering) who undertook the environmental and cultural assessments for the project have an established history abusing Indigenous rights, recently being barred from the world bank.
. Severe fires during the summer of 2019/20 devastated 81% of Blue Mountains Heritage Area. No post-bushfire field surveys have been undertaken.
. Only 27% of the impact area was assessed for Aboriginal Cultural Heritage.
. Threatened species surveys are substantially less than guideline requirements. Where field surveys were not adequately completed, expert reports were not obtained.
. No modelling of the stated flood and economic benefits of the dam wall raising are outlined in the EIS.
. The integrity of the environmental assessment is fundamentally flawed, and cannot be accepted as a basis for further decision-making by the Minister for Planning.
. World Heritage and cultural sites are under attack
. The Blue Mountains World Heritage area is not just a world class National Park, in 2000 it was inscribed on UNESCO’s prestigious World Heritage list in recognition of the Blue Mountains Outstanding Universal value for the whole of mankind. Raising the Warragamba dam wall and consequent damage to natural and cultural values would be a clear breach of these undertakings and Australia’s obligations under the World Heritage Convention. 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. This includes:

. The Kowmung River - declared a ‘Wild River’, protected for its pristine condition under the National Parks and Wildlife Act 1974;
. Unique eucalyptus species diversity recognised as having Outstanding Universal Value under the area’s World Heritage listing such as the Camden White Gum;
. A number of 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.
. Australia’s obligations under the World Heritage Convention mean it is critical for the Blue Mountains World Heritage site to be managed to protect its ecological integrity and authenticity. Any damage within its boundaries is completely unacceptable and inconsistent with World Heritage management principles.

. Gundungurra Traditional Owners have not given Free, Prior and Informed Consent for the Dam proposal to proceed.

Over 1541 identified cultural heritage sites would be inundated by the Dam proposal.
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.
Alternatives to raising Warragamba Dam wall
There are many 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.
Alternative options were not comprehensively assessed in the EIS. Any assessment of alternatives does not take into account the economic benefits that would offset the initial cost of implementation.
On average, 45% of floodwaters are derived from areas outside of the upstream Warragamba Dam catchment. This means that no matter how high the dam wall is constructed, it will not be able to prevent flooding in the Hawkesbury-Nepean Valley downstream.

I have connection to the blue blue mountains and an affinity for the remnant wildlife there, as well as it's cultural and social significance. I oppose this dam raising proposal. The EIS conducted by SMEC engineering has not adequately assessed ecological or cultural impacts.

ThwGThe Traditional Owners have not given Free, Prior and Informed Consent for the Dam proposal to proceed.

I believe the EIS should be conducted again with appropriate consultation, care and due diligence.

I was formerly a resident of Sydney and enjoyed walking in the Southern Blue Mountains, including Kowmung country in my youth. I strongly feel people should be able to continue to enjoy this area, in addition to knowing that its World Heritage Values continue to be protected.
In my opinion the EIS prepared for this project is fatally flawed, particularly in relation to Aboriginal Cultural Heritage impacts, threatened species surveys and modelling of the impacts.
Destruction of the areas proposed to be inundated would be in breach of Australia's commitments to protect its World Heritage Areas. The unique wildlife, biodiversity and geodiversity of these sites must not be degraded and destroyed by the proposal.
There are a number of alternatives which could protect existing downstream communities – these have not been adequately assessed. Because a large portion of the potential floodwaters originate from outside the upstream Warragamba catchment, the proposed raising of the dam wall will not prevent some downstream flooding.
I completely reject the proposal as formulated and request that the NSW Government find alternative means of avoiding the flooding of downstream properties, including the resumption of properties most severely at risk and the enforcement of planning controls which would alleviate the problems.
Save the Blue Mountains National Park and World Heritage Area!

As a resident of the Blue Mountains and an avid bush walker who has explored many parts of the World Heritage Area (WHA), I am concerned by the proposal to raise Warragamba Dam. Threatened ecological communities and cultural heritage sites will be damaged and endangered species, such as the Regent Honeyeater, will lose habitat from inundation from the dam. Destroying parts of the WHA will also breach Australia’s obligations under the World Heritage Convention. What’s the point of National Park or World Heritage listing if it doesn’t protect the area from deliberate damage?

The WHA has been detrimentally impacted from the 2019/20 fires. The EIS has not adequately surveyed the impacts of the raised dam height, and particularly in post-fire conditions. The EIS also does not adequately explain why a 10.3m rather than a 14m increase in inundation level was used.

The floodplain will still flood even if the dam is raised as nearly half the floodwaters come in from rivers downstream of the dam. It is negligent to continue development on the floodplain and putting more people in harm’s way. There are other options to mitigate the risk of flooding and these should be further explored.

I do not believe the dam wall should be raised. The benefits do not outweigh the damage to our priceless natural heritage. From a personal viewpoint, I will be devastated that the lower reaches of the Kowmung River will be flooded and destroyed. Thank you for the opportunity to comment.

Dear Sirs/Mesdames
I am strongly opposed to the proposal for raising the Warragamba Dam wall for many reasons.

1. The EIS is severely flawed

• The engineering firm (SMEC Engineering) who undertook the environmental and cultural assessments for the project have an established history abusing Indigenous rights, recently being barred from the world bank. 

• Severe fires during the summer of 2019/20 devastated 81% of Blue Mountains Heritage Area. No post-bushfire field surveys have been undertaken. 

• Only 27% of the impact area was assessed for Aboriginal Cultural Heritage.

• Threatened species surveys are substantially less than guideline requirements. Where field surveys were not adequately completed, expert reports were not obtained.  

• No modelling of the stated flood and economic benefits of the dam wall raising are outlined in the EIS.

• The integrity of the environmental assessment is fundamentally flawed, and therefore cannot be accepted as a basis for further decision-making by the Minister for Planning.

2. World Heritage and cultural sites under attack

The Blue Mountains World Heritage area is not just a world class National Park, in 2000 it was inscribed on UNESCO’s prestigious World Heritage list in recognition of the Blue Mountains Outstanding Universal value for the whole of mankind. Raising the Warragamba dam wall and consequent damage to natural and cultural values would be a clear breach of these undertakings and Australia’s obligations under the World Heritage Convention. 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. This includes:

• The Kowmung River - declared a ‘Wild River’, protected for its pristine condition under the National Parks and Wildlife Act 1974; 

• Unique eucalyptus species diversity recognised as having Outstanding Universal Value under the area’s World Heritage listing such as the Camden White Gum; 

• A number of 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.

Australia’s obligations under the World Heritage Convention mean it is critical for the Blue Mountains World Heritage site to be managed to protect its ecological integrity and authenticity. Any damage within its boundaries is completely unacceptable and inconsistent with World Heritage management principles.

We have a responsibility to uphold our obligations to the World Heritage Convention as well as to our own management of National Parks.

3. Gundungurra Traditional Owners have not given Free, Prior and Informed Consent for the Dam proposal to proceed. 

• Over 1541 identified cultural heritage sites would be inundated by the Dam proposal.

• 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.

4. Alternatives to raising Warragamba Dam wall

• There are many 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.  

• Alternative options were not comprehensively assessed in the EIS. Any assessment of alternatives does not take into account the economic benefits that would offset the initial cost of implementation.

• On average, 45% of floodwaters are derived from areas outside of the upstream Warragamba Dam catchment. This means that no matter how high the dam wall is constructed, it will not be able to prevent flooding in the Hawkesbury-Nepean Valley downstream. Hence any new developments will only be putting more people in harms way at times of flooding. 


I therefore urge you to reject the recommendations of the EIS and reject the proposal to raise the dam wall.

I am very concerned to hear that this project would impact so negatively on the Regent Honeyeater, which is already classified as critically endangered. Please reconsider.

I am writing to voice my strong opposition to the raising of Warragamba Dam due to the project’s unacceptable potential impacts on the environment and cultural heritage including to the Blue Mountains World Heritage Area.
An example is the potential significant impacts to contemporary breeding habitat for the Regent Honeyeater that “cannot be avoided or minimised.Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority. The destruction or degradation of a contemporary breeding site for Regent Honeyeaters would have dire consequences for the species as a whole and is incongruous with the Federal and NSW Governments investment into the recovery program, including the Regent Honeyeater Captive Breeding and Release program.
I support the recommendations of the Interim Report of the Select Committee on the Proposal to raise the Warragamba Dam wall for full consideration of alternatives including a more thorough Aboriginal cultural heritage assessment.

Apart from the property 'Jooriland' listed, there are no local or otherwise heritage sites in the upstream (affected) area listed. The area listed as 'World Heritage' has as stated, many aboriginal sites and artifacts but also many non-Aboriginal/European sites such as; Wollondilly Hotel and race track, 2 school and 1 part school sites including the grave of a school teacher (1870's), many house site remains, Wollondilly Shire Council roads, bridge and culverts, tobacco kiln remains and much more. Bearing in mind that, prior to the construction of Warragamba Dam, most of these foreshore areas were cleared (check early aerial photographs). The remaining foreshore areas that would be affected such as the rest of the Wollondilly and Nattai arms of Lake Burragorang and Tonalli, Little River, Lacys and Greenwattle Creek and the Cox arm of the dam all have many, including a grave of a boy (Taylor) drowned in the Nattai River 1870 and placed well above any flood line (until possibly now) with his parents house remains not far away, the only still standing sandstone house remains on the foreshore, remains of a steam powered saw mill with the boiler still intact and several vehicles etc etc non-Aboriginal/ European sites including Aboriginal family house site remains on two reserves (one of which, as far as known was not revoked). Has the SEAR done this on purpose to downgrade the heritage importance of this upstream area? Or has NPWS neglected to add them to their Section 170 Register (as they were well known and recorded prior to the land being transferred from the Water Board to NPWS)?
The Burragorang families that gave up their lands, not by choice, for Sydney's water supply and the water quality protection of it should have their history and heritage acknowledged and recorded.
In NSW early Colonial period, the Government of the day realized that building on the flood plains of the Nepean, Hawkesbury (and others throughout the state) was not a good idea due to huge loss of property and life and gave instructions such as "settlers should build homes on high lands as a precaution against losses from floods". These instructions can be found within the Colonial Secretary's Letters at NSW State Archives. Perhaps modern Governments (Councils and State) could and should learn from our past.

I strongly oppose the proposal to raise Warragamba Dam due to the project’s unacceptable potential impacts on the environment including to the Blue Mountains World Heritage Area and threatened species.

The Regent Honeyeater is listed as Critically Endangered at both a state and federal level, with as few as 350 individuals remaining in the wild.  Modelling by BirdLife Australia suggested that up to 50% of contemporary Regent Honeyeater foraging and breeding habitat was burnt in the 2019/20 bushfires. Protecting remaining unburnt breeding habitat is of the highest conservation priority.

The destruction or degradation of a contemporary breeding site for Regent Honeyeaters would have dire consequences for the species as a whole.

Let's stop destroying the habitats of the native animals we still have left.

Subject - Submission – Warragamba Dam Raising Project – SSI-8441;
Name: Sandra Harlor
Address: 12 Twelfth St Warragamba 2752
Email: [email protected]
Phone: 0415 458 462
I am happy to have any of my details or statements included in this submission published.
I have made no political donations to any organisation, entity or individual at any time and have no affiliation with any political party or entity involved in this project.
Signed,
Sandra Harlor NSW Justice of the Peace - 252921
Subject - Submission – Warragamba Dam Raising Project – SSI-8441;
I am writing this submission to strongly object to the Warragamba Dam Raising Project proposal on a number of grounds.
The Warragamba Dam Raising project is not in the best interests of anyone but developers who have plans to make billions developing areas currently listed as flood plain.
Raising the Warragamba Dam Wall will not protect of the areas stated in the document from an MPF. It may, in fact put more lives at risk as, even though the insurance council has withdrawn its support for the project, many people will be lulled into a false sense of safety and build on those flood plains if the project goes ahead.
The 2020 floods made it clear that flood waters come from a myriad of rivers and creeks, not just the Warragamba Dam release, and poor planning in the past has created the risk.
As stated in the document climate change will and already has changed the dynamic and the only responsible action should be to use the 3.5 billion dollars listed as the cost of the project to buy back the most endangered areas of developed land and radically identify and improve flood evacuation routes.
Many others have commented extensively of the destruction of a World Heritage area and the impacts it will have on indigenous culture. Many sites have not even been properly identified in the current study. Much more intensive work needs to be carried out.
I am a long-time resident of Warragamba and have lived through both previous attempts at solving the flood risk problem. Each time being told that this time you had it right and that these changes/improvements would be it. That it would all be fixed and the problem handled.
Each time the original integrity of the Dam was impacted. Blasting, excavating, drilling, removing footings and replacing them with……….. Now you’re going to do it all again.
Warragamba Dam was built as a water storage dam NOT a flood mitigation dam. The engineers who designed it chose a very specific site to suit the very specific engineering design they had formulated. And now you use computer simulations to suppose that these engineers who took hundreds of hours and hundreds of core rock samples to test their hypothesis, and throw that all out the window to almost double the intended capacity and ability for this Dam to withstand these pressures even for an alleged short time.
One question – “if this is safe and in the best interests of Greater Sydney WHY wasn’t it built to the currently proposed specifications in the first place simply for water storage?”
From the perspective of a resident who will be impacted physically, socially, personally and healthwise over the 5 or more years of construction. I have a number of concerns:
• Contrary to what the document has stated in tables that have compiled information from both public meetings and apparent personal observations, as well as an outdated census, to state that the village of Warragamba is stagnant and of a lower socio-economic population. New businesses are coming in and existing are being sold and expanded. Warragamba has an aging population along with an increasing number of young families. The Covid pandemic has caused people to adjust their priorities but the working population currently differs very little from that of Silverdale. As a community development officer at the local community centre I see a significant share of the population on a regular basis and base this observation on my work.

• Warragamba Dam is in and of itself a significant heritage icon in the local area, for NSW, state and even nationally. The valve house building, the hydro-electric power station and the gantry crane are also an historical part of this community. The intention is to remove discard all of these features.

• The proposal states that -while there will be set working hours - 7am to 6pm - five days per week and 8am to 1pm Saturdays - it is quite feasible that works will be carried out outside of these times particularly in hot weather and when concrete is being mixed/poured. So night-time and weekend works over extended periods that can greatly impact local residents are predicted.

• Noise from the site day and night at times can impact both physical and mental health. The document states clearly that they cannot comment on that until the project is up and running and noise becomes a problem???


• The proposed laydown area for fly ash, aggregate and other components for concrete batching is less than a kilometre from Warragamba’s major sporting fields, recreation areas and swimming pool. The dust and possible carcinogens will impact the recreation, social, physical and mental health of all of those, both local and non local people who use/access these fields for community sport, for recreation, for exercise and relaxation.

• Warragamba Public School, Warragamba Preschool, Warradale Early Learning Centre, Warragamba’s Teddy Bear Cottage Childcare service and Warradale Wigwam OOSH service also operate within a two-kilometre radius of this “laydown area”. The potential noise and dust implications for these services has not even been mentioned or have been dismissed as inconsequential. The residents of Warragamba and Silverdale have the right to expect that sending their children to school or daycare, or having them participate in local sport at their local grounds will not have a negative ongoing effect on their lives physically or emotionally. Please note that the document does not even take into account the four Childcare services operating in the Warragamba township.

• There is mention of blasting in the document but no mention on how the possible impacts / property damage to residences situated in the probable impact areas will be assessed or repaired.

• The document states that there may be as many as 208 truck movements per day (or night) during the construction period but there is no mention of what will be done by the proponent to ensure the integrity of the local roads for the safety of all road users over the 5 years or more of construction. Apart from one temporary set of traffic lights there is no mention of how the increased risks of major traffic accidents and fatalities will be addressed or any attempts minimise the risks.

• The document discusses the influx of around 500 workers for the construction period. Historically very few of these workers come from the local areas as companies, contractors and sub-contractors have their own teams in place and generally a small number of casual positions pop up on a random basis. There is no mention of an increased police presence in the area to monitor traffic incidents and any possible increase in the local crime rate.

• The other issue historically, is that with an influx of workers is an increase in the crime rate. For what ever reasons over the previous two dam extension construction periods crimes like robbery, burglary, vehicle theft and theft from vehicles, as well as alcohol related incidents increased.

• As per the document many local businesses don’t believe that the influx of workers with counter the loss to business from tourists not able to visit the Dam.
I raised my four children in this community during the last two attempts to flood proof Greater Sydney and I observed and endured the impacts these apparently unsuccessful attempts created for this community. One of my daughters suffered quite major asthma over that time, along with many others. Our kids did not go out unaccompanied because of the number of ‘strangers’ randomly appearing around the township and the increased number of speeding vehicles.
During each previous construction periods promises – commitments – enticements were made to this community but for the most part very few of these commitments came to fruition.
I have records from the previous Community Liaison Committee clearly stating a commitment to “look after local roads” which, in actuality, meant that they would leave them as they found them – potholes and all.
The records also show that because a major tourist attraction to Warragamba (Warragamba Disabled Playground) was demolished to facilitate the extension of Production Avenue as an alternate access to the Dam, a commitment was made “to rebuild a bigger and better inclusive facility” as a part of the construction process. This was another of the discarded commitments to this community. Dust was constant, noise was excessive and communication with the community was poor. Many complaints were ignored, dismissed without due process or covered up.
I strongly believe that efforts to increase the height/capacity of Warragamba Dam will not floodproof Greater Sydney and may well cause the flood time and therefore damage to be greater by extending the length of time some areas are impacted.
The funds proposed for this proposal should be directed at buying up those properties in the highest risk areas and to identifying and improving evacuation routes.
No amount of dam raising will ensure that many of the areas downstream of Warragamba Dam will be safe from flooding when much of the floodwater comes from rivers including the Grose and Nepean Rivers, Eastern Creek and run-off from huge areas of the Blue Mountains and Greater Sydney itself which filters into the Sydney Basin and ultimately the river system.
You just can’t build on a flood plain and not expect to be flooded.
There has to be another way!!!

Re: Objection to the Proposal to Raise the Warragamba Dam Wall

To Whom it May Concern,

Reasons for objection:

1) Possibility for Hydraulic Uplifting

In 1928 the San Francis Dam collapsed. It was built between 1924-26 by the City of Los Angeles Bureau of Waterworks. The structure was a concrete gravity arch type, and it catastrophically failed near midnight on March 12/13, 1928, in its second year of operation. This created a flood, which was 42 meters (140feet) above the streambed. This wave travelled at first faster. Five minutes later it had travelled 2.4km (7300feet), travelling 29 km/hour.
The flood waters reached the ocean 5:30 AM approximately 84 km distance away (52 miles).
The official death toll was 432 people.

One of the possible reasons for this dam to collapse was so called hydraulic uplifting. The St Francis Dam, which was designed to be 56 meters high, was twice heightened by 3 meters – altogether 6 meters to be 62meters high. When considering the uplifting, 10% increase in dam height is critical.
Uplifting happens when the water pressure increases in the base area, and the base cannot cope with this increased pressure, but gives in.
Another possible reason was the breach of the abutment, which means that the side of the dam connected to the rock wall next to it gave in.

2) The Auxiliary Spillway has weakened the Warragamba Dam structurally

The Warragamba Dam is a concrete gravity dam. When it was built in 1960, it’s height was 142 meters. Since then it has been raised by 5 meters. If the Warragamba Dam is raised another 15 meters, it will be 100 meters higher than the St Francis Dam was. In 2006 one concrete block was removed from the Warragamba Dam, in order to access water from the deeper level. The Auxiliary Spillway was finished in 2009.

The Auxiliary Spillway itself is a safety concern, because when it was built,
1/3 of the Dam height of the rock was removed from the eastern side of the Dam. To my understanding the Auxiliary Spillway is twice as wide as the Warragamba Dam itself. This Auxiliary Spillway has been filled with earth, and concrete blocks have been used to cover it. It is very common that these earth filled spillways collapse.

3) The pressure from the extra concrete to the base & abutment rocks can weaken the surrounding rock formations

If the Warragamba Dam would be lifted another 15 meters, it would mean, that 20 meters would have been added to its original height 142 meters. Considering that 10% is a critical height for uplifting to happen, it is quite possible that the Warragamba Dam would collapse, because too much pressure is put onto the base area.
The proposal is to use a massive amount of concrete (1,5 million tons) to cover the whole Warragamba Dam, including the Spillway (EIS Ch.5 p.21). This is a quite concerning proposal, and can cause too much stress to the base rock and abutment rocks.

When the Warragamba Dam was built a thorough geological examination was performed to investigate the rock formation in the foundations. Similar investigation was done to dam abutments (side rocks).
The geologists investigated the base and abutment rocks for Warragamba Dam, by drilling holes to the rock. Some of those holes were 300 meters deep. That way they were able to conduct geological examinations of the surrounding rock formations.
It is impossible to concuct “extensive investigation of the dam foundations”, after the dam has been built. Even if a laboratory has tested this proposed new structure, they have not been able to investigate, how the surrounding rock formations would cope, if this new structure is causing more pressure towards them. A huge concern is also the structural alterations made on dams right side rock and abutment, when the Auxiliary Spillway was built. This work has weakend the right abutment area of the dam.

4) Possible Catastrophical Failure (PMF)

When the Warragamba Dam was built 3 million tons of concrete was used. Now it has been proposed to add 1,5 million tons of concrete on top of the Warragamba Dam and the Auxiliary Spillway. The weight of the proposed concrete topping of existing Warragamba Dam would give more weight to the Dam and its foundations. It is possible, that the base rock will crack because it is not calculated to carry all that concrete. And if the side rock on abutments, especially on already weakened eastern side (the Auxiliary Spillway side) fails, the Warragamba Dam can have a catastrofical failure (PMF), which causes a huge inland zunami, maybe 50 meters or more in height in Penrith. This zunami wave will reach Penrith in 20 -30 minutes, and it will be higher in Penrith, than Richmond – Windsor area, where it is 26.7meters high (EIS Ch 15 p.92).

PMF= a hypothetical flood or combination of floods, which represent an extreme scenario and is highly unlikely to occur in nature (EIS Ch 15 p.92)

People in Wallacia, Penrith, especially in Emu Plains and Jamisontown, even in Penrith centre, have nowhere to escape if Warragamba Dam fails catastrophically. Wallacia residents will be inundated in 5 minutes. Penrith City Council has stated in their submission, that it will take 15 hours to evacuate people from flood affected areas. There is no time for evacuation, if the Warragamba Dam will catastrophically collapse. People will loose their lives, their homes will be destroyed, a huge damage to infrastructure will happen, and there will be extensive amount of human suffering in affected communities.

In EIS Chapter 16 p.9. Table 16-4 are listed all of critical infrastructure by type affected if the dam collapses. One of them is airport, which is the Badgery’s Creek Airport, which is built at the moment, and should be finished by 2026 . Wallacia, which will be hit with 60 to 70 meter inland zunami wave if the Warragamba Dam catastrophically fails, is situated 5 km from the Warragamba Dam. The Badgerys Creek Airport is situated approximately 5 km from Wallacia, 10 km from the Warragamba Dam.
There are 9 railway stations, which are listed as critical infrastructure. One of them is St Marys, which will be the major transport centre serving the Badgery’s Creek airport, and its customers. (EIS Chapter 16 p.9. Table 16-4)

5) In summary the Warragamba Dam Raising project would not fullfill the
following objectives in priority order: (EIS Ch. 15 p. 6)

• Maintain the structural integrity of the dam, because by putting more weight to the dam can cause a catastrophic failure
• Minimise risk of life, because Penrith, especially people living in Wallacia, Emu Plains, and Jamisontown do not have time to escape, in case of dam failure.
• Maintain Sydney’s water supply, because if we loose the Warragamba Dam in case of a catastrophical structural failure, we loose 80% of the Sydney’s water supply. The water desalination provides 15% of Sydney’s needs at the moment.
• Minimise downstream impact of flooding to properties, because we loose over 30 000 properties, if Warragamba Dam fails. (EIS Ch. 15 p. 105)
• Minimise environmental impact, because we loose our sewer plant in Penrith, and everything becomes contaminated.
• Minimise social impact, because communities are broken down, and people will basically loose everything.

Considering the structural safety aspects, which might be affected by the project,
the changes in flood levels in Wallacia, Penrith and Windsor are insignificant due to the project to raise the Warragamba Dam. (EIS Ch.15. pp. 89-91, Tables 15-22, 15-23,15-24)

Could you please reconsider you proposal to increase the height of the Warragamba Dam, and consider reducing the dam capacity instead.

Sincerely
Pirjo Laukka 11th of October 2021

Objection to raising the Warragamba Dam Wall
I am horrified to think that raising the dam wall is even being considered. I love the Blue Mountains area and have walked in from Mittagong, Nattai, the lower parts of the Blue Mountains, as well as from Wenworth Falls to Mt Victoria. I have also walked the Six Foot Track from Katoomba to Jenolan Caves. Much of this area is World Heritage and justly so.

There is so few large areas of intact bushland left in Australia that to even contemplate damaging this World Heritage areas is incomprehensible.

This proposal is not even essential to the well being of Sydney’s residents. Floods will occur again with or without this raised wall due to the number of tributaries and the constriction of the valley downstream. The best way to ameliorate the impact of flooding is simply not to build on the floodplain. The floodplain is well mapped and easily avoided.

Extra drinking water for Sydney (not yet proposed) should come from desalination, not dams.

Although extremely lengthy the EIS is woefully inadequate and biased. As a member of Birdlife Australia, I am aware of the importance of this valley for the critically endangered (at both NSW and Commonwealth level) Regent Honeyeater. That the NSW would contemplate damaging this habitat is appalling. It is no wonder that Australian Government is considered a “global Pariah” on biodiversity protection (SMH 11/10/2021).

However one looks at the EIS it is inadequate. No post fire assessment, totally inadequate assessment for Aboriginal Cultural Heritage, no modelling of economic benefits or flood benefits, totally inadequate threatened species surveys. This is a World Heritage site - i.e., of importance to the whole world and the State Government treats it as site that can be trashed because of very dubious infra structure. I gather that 5700 hectares of National Park will be damaged as well as 65 km of wilderness rivers. No voter will be happy with this.

We are obliged to manage this area for its ecological integrity and authenticity, and I expect the State government to carry out its obligations to the world.

Yours
Faithfully
Robin Buchanan

Submission – Warragamba Dam Raising Project – SSI-8441 – Dr Melanie Crane - Northmead

I don’t mind what information is published, and I would like to OBJECT to the proposal please.

Please see below for The basis of my objection;

- we live on a remnant bush line, and visit the blue mt regularly, as one of the last true robust wilderness areas near Sydney

- as someone who spends time in nature, I see the damage caused when time is not taken to properly assess the environmental impacts. Our natural world is a delicate and complex interconnected web, and interruptions to upstream creek flows, aquatic, and non-aquatic plants and animals needs detailed assessment to understand the full impacts......

It is my understanding that


- No post-bushfire field surveys have been undertaken.
- Threatened species surveys are substantially less than guideline requirements.
Where field surveys were not adequately completed, expert reports were not obtained.

- No modelling of the stated flood and economic benefits of the dam wall raising are outlined in the EIS.

This is very very concerning to us given the proposal involves flooding 65km of the kowmung river, and 6000 hectares of remnant bushland in the world heritage area.

Please please take the time to do a full EIS covering the points above - everyday we watch more bushland clearance around us, and see animals and plants under pressure from other human impacts such as climate change. Birds die in trees around us on a hot summer day presently..., this didn’t used to happen.....

I fear for our futures unless we start making each decision properly - not just for more quick economic housing development......

Yours sincerely

Dr Melanie Crane (Public Health Research fellow)

I strongly object to the proposed increase in height for Warragamba Dam, for the following reasons.

I believe that the disadvantages outweigh the possible advantages.

1.The disadvantages are clear as far as the wildlife that exists in the area of flood. Specifically this action threatens the regent honeyeater, a bird that has only 300 members left in Australia. With so much of its habitat already destroyed by housing development in South Easter Australia, this action is likely to lead to extinction of this once common bird. I (Sue) have spent much time in the Nepean basin and the sight and sounds of this bird were familiar in our walks around our family home.
2. Impact on Aboriginal Cultural heritage. Over 1200 significant cultural sites have been documented. As the wider Australian community are starting to recognize and value the importance of Indigenous cultural heritage and their contribution to our understanding of our way of life and future custodianship of this ancient land, it is NOT the time to destroy it. The harm done to Aboriginal Australians, already a disadvantaged population, by these destructive actions perpetuate the lack of respect in consultation and transactions.
I have made no political donations at all in the past 2 years.
Sincerely.
Dr Sue Outram

At a time when international negotiations are forging ahead to create protection and restoration of the world's natural and cultural resources, the NSW Government is planning to inundate the Kowmung River and the already threatened animal and plant species in the Warragamba and our National Park. Raising of the dam wall will not stop flooding of the Hawkesbury floodplains as half of its flood waters come from outside of the upstream Warragamba Dam area.
After the appalling decision, by whichever Government was in power at the time, to allow the development of the floodplains, it is time to explore alternative measures to protect the existing households and businesses in the area. Consultation with engineering experts in those countries with similar infrastructure problems i.e. The Netherlands, UK, would be a step in the right direction, however, I am sure Australia also has such up to date expertise.
Raising of the dam wall and the large expansion of water it will collect would also drastically change the climate in the Blue Mountains as well as the Greater Sydney Area. A larger evaporation area means potentially more rainfall and in a normal or wet season it would mean more flood water, including that from the other sources, onto the Hawkesbury Plains.
The development of lakes and water canals on the Plains would attract wildlife. It would give opportunities to develop green areas for the enjoyment of residents and tourists while channelling water into larger river ways. This could also develop opportunities for water storage. Taxpayers would prefer such a scheme with the similar costs as those envisioned for raising the dam wall. Taxpayers would also expect new DEVELOPERS to pay for such water control, either the wall construction or canals.
The disrespect shown to the traditional owners of the cultural heritage area by not being consulted by SMEC Engineering or given the opportunity to assess the Dam proposal is against all legal or moral laws. They were not consulted in the 1950's on the flooding of their land in the Burragorang Valley to make way for the Warragamba Dam. It is time to right the wrongs that have been made by shonky engineering companies or State governments involving our First Australians.
To ignore and negate the granting of UNESCO's prestigious World Heritage list in recognition of the Blue Mountains Outstanding Universal value for the WHOLE of mankind would be, yet another, embarrassment to our international standing. It is not just about the Three Sisters and Scenic World, it is about our unique and diverse natural and cultural history.
Yes, I am very much against the raising of the Warragamba Dam wall. Please explore the more beneficial and fairer alternatives.

The prime focus of Koala Action Inc. is the koala, however, members are equally concerned about all native wildlife and the habitat upon which they depend. This includes birds, as they form crucial components of the same ecosystem that koalas use. The Regent Honeyeaters is just such a bird. KAI's opposition is related to the unacceptable potential impacts on the natural environment including the Blue Mountains World Heritage area and threatened species. The draft EIS concludes that the project poses significant impacts to the contemporary breeding habitat for the Regent Honeyeater that cannot be ameliorated. This species is listed as 'Critically Endangered' at a state and federal level with approximately 350 individuals remaining in the wild. Modelling undertaken by Birdlife Australia suggested that up to 50% of this species foraging and breeding habitat was destroyed by the 2019/20 bushfires. Retaining/protecting remaining unburnt habit is of the highest conservation priority. There are only a small number of breeding sites remaining for this species and during the assessment of the project only 21 Regent Honeyeaters including active nests were recorded in the affected area. Any breeding habitat must be considered critical for the survival of the species under the National Recovery Plan. This document states "it is essential that the highest level of protection is provided to these areas and that enhancement and protection measures target these productive sites". The destruction or degradation of these sites will have dire consequences for the species as a whole. In fact, destroying their essential habitat is incongruous with the money, time and effort already invested by the Federal and NSW government to bring about their recovery. IT IS UNACCEPTABLE AND INCONSISTENT WITH THE NATIONAL RECOVERY PLAN FOR ANY AVOIDABLE LOSS OR DEGRADATION OF BREEDING HABITAT TO OCCUR. Members of Koala Action Inc. strongly oppose the Project's offset strategy. Offsets are rarely an appropriate response to proposed biodiversity loss and especially for critical habitat for the survival of a species. This is particularly the case for the breeding habitat for the Critically Endangered Regent Honeyeater. There is no evidence to suggest that breeding habitat for this species can be successfully offset. Any offsets would be highly unlikely to provide direct benefits for both the locally affected population and the species as a whole. In addition, I have consulted with members of Queensland Koala Crusaders Inc, for whom I am the Policy Coordinator and Moreton Bay Koala Rescue Inc. All three groups are volunteer not for profit incorporated associations designated as charities. KAI, MBKR and QKC number over 400 members , all of whom, do not support the Warragamba Dam Raising Proposal. It is our earnest hope that all levels of government use peer reviewed good science to make the best decision for the species and that would be not to go ahead with this inappropriate proposal.

Reasons for in Principle Support of the Proposal.
[A]. Raising the Wall Should Stop Warragamba Feeding
Small H-N Floods.
Flooding in the Hawkesbury-Nepean River [H-N] system will occur without any water being discharged from Warragamba Dam. This flooding is caused by high rainfall in the Nepean catchment and the water bypasses Warragamba.
History has shown that flooding from the Nepean catchment occurs quickly and can be above 9.0 metres at Windsor, which is enough to cut most evacuation routes on the flood plain.
With climate change, and by 2090, these floods could be as high as 11.5 metres at Windsor [my estimate]. The catchment is close to the Illawarra escarpment and on occasions can be subjected to much higher rainfall than the Warragamba River catchment, except for rain that falls on the Eastern Blue Mountains escarpment. Climate change may increase this orographic type rainfall.
The February 2020 flood was 9.2 metres at Windsor with no water coming from Warragamba. Rainfall at Robertson NSW was 395mm in one day and the water reached Windsor in 24 hours. Because Warragamba was at a low level, all the inflow from the catchment, more than 1000 GL was contained. Adding 1000 GL of FMZ would fully contain this type of inflow without any discharge into a flooded H-N. The flood however, could have been much higher if more rain had fallen on the Grose catchment. It could have been a 1:10 flood at Windsor, and with climate change a 1:20 flood by 2090 [my estimate].
The 2020 flood was unique in recent times, not just because no water came from Warragamba, but because it also showed clearly without being masked by Warragamba water, what the Nepean catchment’s flow contribution could be to a normal H-N flood.
Conclusion 1.
The 2020 flood rose rapidly and cut the evacuation routes on the flood plain. This will happen again regardless of what is done at Warragamba, and will remain forever at least a 1:15 flood threat. This is type of flooding, which cuts access roads on the H-N flood plain, is not fully analyzed or discussed in the EIS. However, it is important to prevent Warragamba water adding to this type of flood.

[B]. Main Effect of Raising the Wall.
Warragamba inflows during the 1961 and 1978 floods exceeded 1500 GL [my figure based on published reports] over 4 days, and the release of this water was the main cause for 1:20 to 1:100 flooding in the H-N. Assuming the February 2020 flow rate could approximate the Nepean catchment component of a 1961 or 1978 type flood, this flow caused the river at Windsor to stay above 5.5 metres for 4 days [in February 2020]. Assuming a 1500 GL inflow into the dam, a raised Warragamba would hold back 1000 GL [if at FSL to start], but there would be an uncontrolled discharge of 500 GL, which would take place during the same 4-day period of the maximum dam inflow and at the same time the downstream H-N flood is peaking. This will increase the flood height at Windsor from 9.2 metres [February 2020] to maybe 12.2 metres [my estimate], equivalent to a 1:10 to 1:20 flood.
If one of the aims of the project is to protect the H-N valley from a 1:20 to 1:100 flood, the FMZ needs to be at least 1500 GL. This requires the main spillway project height to be increased from 12.0 to 17.0 metres [my estimate].
Conclusion 2.
Instead of waiting [before 2090] to raise the main spillway from 12.0 to 15.0 metres because of climate change, do it now, but make it 17.0 metres.
[C]. ‘Piggy Back’.
The idea of ‘piggy back’ discharges which are planned to begin as soon as a H-N flood peaks, and to mirror the normal river draining process is a positive for reducing the time the World Heritage Area is submerged and also restores the FMZ as soon as possible. If a 100 GL per day outflow from the dam can cause a 5.5 metre flood at Windsor [EIS Table 15-29], it is clear that a discharge of 100 GL per day into a falling flood level is not going to happen, if bridges and flood plain roads are to be opened. Consequently, it is going to take more than 10 days to restore the 1000 GL FMZ, during which time another rain event could occur. The ‘piggy back’ action will prolong flood levels and add to the misery of people using the flood plain. If there is anyway the proposed ‘piggy back’ process time frame can be reduced, or modified, it will be a positive for the H-N valley and the World Heritage Area. However, there does not appear to be an easy answer to this problem.

[D]. Auxiliary Spillway Design.
The new auxiliary spillway is a positive design change and will remove the threat to the H-N valley that has been present ever since the existing ‘fuse plug’ spillway was commissioned in 2002.

I am objecting because of the significant impact this project would have on the future survival of the Regent Honeyeater. Whilst it is only this one species I am focusing on, and I do understand we can't stop all future projects because they impact on various species, I am urging you to rethink on how you do something whenever it is possible so that we get both: new resources for humans without extinction of other species. Just because it is currently the cheapest option doesn't make it the best option, especially for the long term future of our precious planet (including us). "Worry about the pennies and the pounds will take care of themselves." ie Worry about each individual species and the whole ecosystem will survive. Australia is yet to tap into the major tourist industries that exist in Europe and the UK etc. based on birdwatching. A special bird like the Regent Honeyeater has the potential to bring in many 'twitchers' from overseas once travel resumes after the COVID-19 pandemic. Add in a few more rare birds across the country (eg the Black-breasted Button Quail in Toowoomba's Redwood Park, etc) and you could create a major tourist drawcard for all of Australia. The Regent Honeyeater is a valuable resource and we should all be doing all we can to preserve it.

I object to the raising on the dam wall because of the flood impact on the world heritage area, biodiversity and aboriginal heritage. Furthermore in a warming world in which flood severity is projected to increase, increasing the dam wall should not be used as a reason to facilitate urban development on the flood plain. Residential zoning should be more careful to take into account flood constraints, enabling preventative protection against flood risk. The water holding capacity of the existing dam should be better managed for flood mitigation. There is great potential for improved water conservation through fixing the leaks within the distribution network, increased water recycling, as well as improved pollution control within the Sydney-Illawarra catchment Special Areas to protect and improve water quality, particularly from underground mining. According to Dr Chas Keys, former Deputy Commissioner of the NSW State Emergency Service 'the raising of the dam wall will reduce the threat of flooding for
the lesser, more frequent floods in these areas but will according to the government’s own investigations achieve little mitigation in the bigger events. The raising of the (Warragamba) dam is beguiling. It makes a kind of popular sense but it is not necessarily highly productive of mitigation, especially in rare genuinely big floods which will be the most consequential. The pressing need, I think, is to stop the problem of community flood vulnerability from getting worse. We should focus on restricting development in this valley. We should focus on building more evacuation routes and we are going to have to do that even if the dam is raised. We should focus
on lowering the full supply level of the dam to create flood storage capacity. We should focus on buying back the worst affected properties '
See: https://www.parliament.nsw.gov.au/lcdocs/inquiries/2535/Interim%20Report%20No%201%20-%20Select%20Committee%20on%20the%20Proposal%20to%20Raise%20the%20Warragamba%20Dam%20Wall.pdf

I find it appalling that developer lobbyists such as Urban Taskforce continue to lobby for the raising of the dam wall.
See: http://createsend.com/t/r-77C43C5B666732922540EF23F30FEDED.
Urban Taskforce implies that raising the dam wall will facilitate increased housing approvals which will lead to increased housing affordability, a claim that must be tested for veracity. Indeed building approvals in NSW are at an all time high and yet house prices continue to rise at alarming rates. Housing prices are being pushed high by investment. Greenfields developments on flood plains does not lead to decreases in house prices - all it does is exacerbate the flood risks and the bridge infrastructure costs.
See: theurbandeveloper.com/articles/nsw-building-approvals-hit-33yr-high-homebuilder

In terms of biodiversity I am concerned that the up-valley flood impacts will destroy habitat of the Regent Honeyeater. As Birds Australia have stated "The destruction and degradation of breeding habitat for Regent Honeyeaters is incongruous with the time and money that the Federal and NSW Governments have invested into the recovery program, including the Regent Honeyeater Captive Breeding and Release program."

Of course, if raising the dam wall leads to increased down-stream development, as Dr Keys has highlighted creates the central concern was that this reduction in smaller “Levee Paradox” whereby flood mitigation of frequent smaller floods can drive a push for development on floodplains increasing overall risk. "Dr Keys provided an example of the levee paradox in effect in Brisbane, Queensland, following the upgrade of Wivenhoe Dam to a flood mitigation dam following the devastating 1974 floods
and the subsequent flood event in 2011. The effect of reducing the flood risk was increased development on the Brisbane River floodplain and despite the 2011 flood peaking 1 metre below the 1974 height the number of inundated houses was much greater. The 1 metre reduction in flood height was attributed to the operation of Wivenhoe Dam as a mitigation dam but the additional damage was as a direct result of more people living in flood prone areas that were considered at less risk."
(also from the NSW Upper House inquiry, linked above).
This can thereby increase downstream ecological destruction due to urban development on previous natural eco-systems of diverse agricultural lands.