NPA SUBMISSION GUIDE – Submissions close 12 November 2021

How to make a submission

To make a submission, go to the NSW Planning Portal and click on ‘make a submission’. You’ll need to login or, if this is your first time at the site, fill in your contact details. We suggest considering the following points when making a submission.

Key Talking Points

A flawed project

  • WaterNSW, an agency of the NSW Government, has released an Environmental Impact Statement (EIS) proposing to raise the wall of the Warragamba Dam. Their justification for the project is that raising the dam wall is required to reduce the risk of future flooding to residents and businesses across Western Sydney. This is simply not the case.
  • The project rationale is deeply flawed, with nearly half the floodwaters that have historically impacted the floodplain coming from rivers outside the Warragamba catchment.  
  • Raising the dam wall will encourage further ill-advised development in vulnerable areas without providing any guarantee of future protection. 
  • What we need is better urban planning, not short-sighted fixes that will only encourage development in flood prone areas.

Intolerable environmental impacts

  • The World Heritage listed Blue Mountains National Parks have been given the highest possible international status and protection in recognition of the area’s extraordinary biodiversity and ecological integrity. 
  • The Commonwealth and NSW Governments made a commitment to future generations to protect the Greater Blue Mountains World Heritage Area forever.  This is the last place that any government should sacrifice to enable further expansion of floodplain development. 
  • Raising the Warragamba Dam wall will inflict terrible damage on the environmental and cultural values of the catchment.  It will decimate 5,700 hectares of National Parks, 1,300 hectares of World Heritage Area, more than 60 kilometres of wilderness rivers and thousands of Aboriginal sites and places of cultural significance.  The area that will be destroyed contains some of the best remaining grassy woodland ecosystem in NSW, complete with healthy populations of dingo, quoll, woodland birds and many other native species.
  • The rising water will drive threatened species into extinction, including NSW’s rarest bird, the Regent Honeyeater.
  • Australia is a signatory to the World Heritage Convention and required to do everything in its powers to protect the ecological integrity of the Greater Blue Mountains World Heritage Area.  This proposal falls far short of that obligation, and if the EIS is approved it will confirm our growing international reputation as environmental vandals. 
  • No consent has been obtained from the Gundungurra Traditional Owners for the work that will significantly impact their cultural heritage. 

Totally inadequate environmental impact assessment

  • The purpose of raising the dam wall is to hold water at a level up to 17 metres higher than the present dam.  Even if the water is only held at these elevated levels for a few months, the unavoidable reality is that the habitats, flora, fauna, cultural sites and soils within the inundation zone will be devastated. 
  • Despite the EIS having been in preparation for more than 5 years, the environmental and cultural surveys on which it relies are woefully inadequate.  The EIS relies upon biodiversity and cultural surveys conducted before the unprecedented wildfires of 2019/20, which burnt 81% of the Greater Blue Mountains.  Those fires changed the face of the Blue Mountains and drove many species to the brink of local extinction.  It is not sufficient to do a ‘desktop’ analysis of the impacts of the fires on the project area, a new survey is needed.  
  • The Commonwealth Department of Environment and the International Council on Monuments and Sites have both pointed out very serious failings in the assessment of the impact on the cultural heritage of the Gundungurra traditional owners.
  • The proposal relies upon the payment of biodiversity offsets to mitigate the irreparable environmental damage to the biodiversity of this unique and internationally significant area.  
  • Calculations based on the NSW Government’s own biodiversity laws and offsets trading scheme suggests that the total cost of biodiversity offsets will be around $2 billion. 
  • Shockingly, rather than disclose the true cost to NSW citizens and taxpayers, the EIS does not calculate the biodiversity offset liability for the project.   

The wrong time and the wrong place

  • NSW is still reeling from the 2019/20 mega-fires, record levels of land clearing and a species extinction crisis. If there is any time and any place where the protection of nature must be prioritised, surely it is in now in World Heritage listed National Parks?
  • Has the NSW Government learnt nothing from the desecration of Juunkan Gorge about the importance of protecting Aboriginal cultural heritage?
  • Aboriginal cultural heritage, National Parks, World Heritage and threatened species need protection, not destruction.

For more suggestions about submission points please visit GiveaDam and Birdlife at:

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