Make a submission about the EIS
Make your submission
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.
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. 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 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 under attack
The Blue Mountains World Heritage area is not just a world class National Park, in 2000 it was inscribed on UNESCO’s World Heritage list in recognition of its 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.
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.
When must your submission be made by?
Your submission must reach the Department before the close of the exhibition period on midnight 19 December 2021.
How will your personal information be used by the Department when you make a submission?
- Your personal information may be published online, including:
- Your submission;
- Your name (unless you state that you want your name withheld);
- Your suburb; and
- Any political donations disclosure statement.
- The Department may publish any personal information you have included in your submission unless you tell it there is personal information you do not want us to publish. Do not include any personal information in your submission that you do not want published.
- By making a submission, you are acknowledging and accepting the Department’s disclaimer on submissions and accepting the submission declaration, which can be viewed here.
- For more information, view the Department's Privacy Statement.
