The Perrottet government will have to rework large parts of the environmental impact statement for its proposal to raise the Warragamba dam wall, according to officials responsible for assessing the project.
New South Wales environment officials have told the government its analysis, published in September, has failed to properly assess or justify impacts to the Greater Blue Mountains world heritage area that would be caused by the $1.6bn plan to raise the wall by up to 17 metres.
In responses published by the department of planning, industry and environment, Heritage NSW and the department’s environment, energy and science division (EES) both offered significant criticisms of the project.
The environment division’s response identified numerous problems with the assessment including that an evaluation of the project’s impact on world heritage values had been based on “incorrect assumptions”.
Officials wrote that the assessment of the WaterNSW project also incorrectly excluded Aboriginal heritage from the world heritage values of the area and there was a risk that sites of high cultural value had not been identified.
“EES does not consider the impacts of the project on the natural and cultural values of the national parks estate and Greater Blue Mountains World Heritage Area have been adequately assessed or justified,” Dean Knudson, the deputy secretary of biodiversity, conservation and science wrote in the 88-page response.
Among their concerns, environment officials wrote that the assessment’s conclusion that the project would have minimal impact on threatened species was “not supported by the data or evidence”.
The EIS also had not addressed requests from the World Heritage Committee that the government fully consider all potential impacts to the outstanding universal values of the area, including Aboriginal cultural values, or whether raising the wall would exacerbate bushfire risk and threaten the recovery of species and habitat.
Environment officials highlighted inadequate surveys of threatened species habitat and wrote the assessment of aquatic ecology had failed to identify that raising the dam wall would result in inundation of about 284km of rivers and streams during floods.
They said while WaterNSW had correctly identified the process for sourcing environmental offsets for the project, it had failed to identify the actual location of proposed offsets or whether the offsets requirements could even be met.
In a separate response, Heritage NSW wrote the assessment underestimated the area’s cultural significance. It said the impact to Aboriginal cultural heritage values would be significant.
Heritage NSW’s executive director Sam Kidman wrote that the “presence and clear expression of dreaming stories and songlines in the archaeological record of the Burragorang Valley” was unique and could not be offset, even if similar sites were identified.
The response states that clear concerns raised by the Aboriginal community had not been addressed “and there has not been a concerted effort to redesign or appropriately mitigate the impacts”.
The department has published 2,088 public submissions responding to the EIS. An analysis it commissioned of 2,067 responses found 1,931 were opposed to the project.
Of those objections, the most frequently raised concerns were about impacts on biodiversity (raised in 80% of submissions), the world heritage area (50% of submissions) and cultural heritage sites (47% of submissions).
The NSW ministerial reshuffle last month means the new infrastructure minister, Rob Stokes, has joint carriage of the dam project with Stuart Ayres, the minister for western Sydney.
A final decision, though, would still sit with the government as a whole, a spokesperson for Stokes said.
Harry Burkitt, of the Colong Foundation for Wilderness, said the responses from government agencies demonstrated “the farcical nature of the entire EIS process” and the “complete failure of due diligence”.
“For the past four years, minister Stuart Ayres and his departments, WaterNSW and Infrastructure NSW, have attempted to force the NSW government into supporting the raising of the Warragamba dam wall. Their attempts have now comprehensively failed,” he said.
Kazan Brown is a Gundungurra woman whose great-great-great-grandfather, John Joseph Riley, owned land at Burnt Flat, which is in the inundation zone.
She said the written advice of both environment officials and Heritage NSW reiterated “everything we’ve said from the start”.
“The consultation [from WaterNSW] was useless, it wasn’t real,” she said.
“What they did was they came and told us what they were going to do and they went and did it and didn’t care what we had to say.
“All along we have said the cultural surveys and assessments had not been properly done.”
A letter from the department asks WaterNSW to make several changes, including conducting a more comprehensive survey of Aboriginal cultural heritage values and of likely impacts to the world heritage area.
It also asks WaterNSW to detail the proposed offsets for all damage the project would cause.
A spokesperson for WaterNSW said: “WaterNSW will now review the submissions received during the public exhibition and address the issues raised in a submissions report to the Department of Planning and Environment”.
Comment was sought from the minister for western Sydney, Stuart Ayres.
