Make a submission about the EIS
Make a submission about the EIS
What is this about?
The NSW Government has recently released its Environmental Impact Statement (EIS) for the Warragamba Dam wall raising and is asking the public to make submissions on the proposal.
The NSW Government wants to raise the Warragamba Dam wall so developers can build more houses on western Sydney floodplains. Upstream inundation caused by the dam wall raising would cause irreversible damage to threatened species, wild rivers, and risks the Blue Mountains World Heritage Listing itself.
How do I make a submission?
- To make a submission using the planning department’s website you need to create an online account with the Department of Planning.
However, we recommend making a written submission if you can. Doing so makes your submission more likely to be read and considered by the Planning Minister.
- Enclosed with this submission guide you will find a reply-paid envelope addressed to the NSW Planning Department and a blank sheet of paper. Once you have finished writing your submission on the blank sheet of paper, insert it into the enclosed reply-paid envelope and place it in your nearest post box before 9 November 2021. It does not need a stamp.
What should I say in my submission?
Your submission can be long, short, or any length you like! The most important thing is that your submission is in your own words. Include your full name, address and On the reverse side of this page we have outlined some facts and arguments you may like to draw upon in your submission.
It is helpful for your submission to follow the general ‘P.F.P’ structure. That is:
Personal: What is your connection to the issue? Have you been bushwalking in the Blue Mountains? Do you live in Western Sydney and are affected by floodplain development?
Facts: What are the facts that you see as relevant for the Minister to consider when making his decision to raise the dam wall or not?
- Position: Do you oppose the dam? If so, explain why.
Systematic failures of the EIS
- The NSW Government is both the proponent and the approval authority for the dam project, giving rise to a conflict of interest that has not been adequately addressed through a transparent, independent assessment process.
- 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.
- A staff member employed by WaterNSW was seconded by SMEC Engineering as the accredited offsetting assessor for the Dam project, creating a direct conflict of interest.
- 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 and Public Spaces.
Destruction of World Heritage
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.
- Any proposed offsets to mitigate the detrimental impacts and loss of these species will be ineffective given the threatened ecological communities and species that are underrepresented outside of the impacted region.
- The offset strategy proposed in the EIS excludes up to 1224 hectares of wilderness due to the application of a minimised upstream impact area. This represents a significant area not accounted for in offset cost calculations, including the majority of the Regent Honeyeater population’s breeding habitat.
Destruction of cultural heritage
- 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.
- When SMEC Engineering held their first consultation meeting about the project in 2018, Traditional Owners were given just four days’ warning by SMEC of the consultation meeting held three-hours away from the Blue Mountains.
- 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.