Cleanaway's Western Sydney Energy & Resource Recovery Centre

Please find my objections to this proposal in the attached submission

My concern is with the long turn unknown health affects of this project going ahead not convincing me that we have nothing to be concerned about, Minchinbury 2770 and surrounding areas are made up of many young families bringing up their children, we have many homes and schools within the fall out areas, with a mixer of aging people also.
I would prefer this project NOT to go ahead so close the residence around it.
We also will have the soot waste from the air fall on our clothing, Cars, Plants, Houses, Our animals drinking water also will be affected, Warragamba and Prospect Dam's water will also be affected by the fallout hence we then drink this water and God only knows what will happen from there.
My family and i have been residence for well over 25 years in Michinbury at our current address and choose not to leave the area, if feel it very unfair to build this waste facility so close to people young and old,
This council is holding the longer term out comes of this project within there hands,
I can only hope the people of our Blacktown Council are putting People before money and greed.
Our lives from babies to the elderly are in your hands, may this be taken into consideration through out the process,
This type of Waste develop complex should not be within such a close radios to any people, All Lives Matter,
I thank you of the opportunity to voice my opinion in regards to this project proposal.

After 9 months, Claenway have still not adequately/scientifically answered the following questions/comments:

1. When the plant is operating, when will the flue emissions be monitored?

2. What method will be used to monitor the emissions? That is, what chemical/instrumental procedures will be used?
3. What chemical species/compounds will be monitored?

4. Most importantly, what are ALL the chemicals making up the flue gases. The flue emissions will contain many more components/chemicals than the handful that Alex referred to for monitoring and that are discussed in the EIS. Contrary to Cleanaway's assertion, for health assessment purposes, chemicals cannot be grouped into dioxins/furans and other organics and groups of metals. If it is not known what the complete chemical profile of the emission gases is, it is not possible to assess or comment on the possible health effects of the emission. One cannot comment on something not known to even exist!
Similarly, a full profile of any and all metals contained in the flue emission must be known before any opinion can be made regarding the toxicity of the emissions. At the operating temperature of the combustion, many metals will become volatile and many metals will form volatile organometallic complexes/compounds. These chemicals must be known to assess their toxicities and possible health effects.
It is not acceptable to monitor a handful of chemicals and ASSUME that all the other chemicals being emitted have no health effects especially when what the other chemicals being emitted are NOT known. The toxicity/health effects of the emissions cannot be assessed when it is not known what what is being emitted.

In reply to my questions, Claeanway state:
"monitoring will be conducted for pollutants required by the EPA in compliance with the NSW Energy from Waste Policy Statement, including NOx, CO, particulates, TOC, HCl, NH3, Hg and SO2, as well as for auxiliary parameters including flow rate, temperature, pressure, moisture content, oxygen and CO2. Real-time emission data from the Continuous Equipment Monitoring System (CEMS) will be available to the EPA, and provided regularly online to the public. For pollutants whose levels are too small to be detected, a periodic sampling and testing regime will be implemented. This would be the case for heavy metals (As, Cd, Co, Cr, Cu, Mn, Ni, Pb, Sb, TI, V), Nitrous Oxide, dioxins and furans."
There will be MANY more chemicals emitted from the flue than the handful than will be monitored real time and the health effects of these additional chemicals will not be know for possible years to come. It can not be ASSUMED that "the case for heavy metals (As, Cd, Co, Cr, Cu, Mn, Ni, Pb, Sb, TI, V), Nitrous Oxide, dioxins and furans--are too small to be detected."

It is also important to note that the BAT (Best Available Technology that Cleanaway refer to does not make any reference to the health effects of the effluents, it does NOT comment or address as the the health effects of the chemicals being emitted by the process. BAT only refers to the best available technology not to the health effects of the technology.
There will be very many chemicals emitted from the flue that cannot be monitored in-line, cannot be monitored real-time, including metals, organics and organometalics, and the health effects of these chemicals will not be know until after their effects.
This project is "asbestos mining", silicon processing" in the the making.
I strongly oppose the establishment of a waste-to-energy incinerator in Western Sydney as its effects on community health has not been established. The flu emissions MAY have very serious acute and chronic health effects on the community and therefore the project is an unacceptable community health risk.

This is rebirthing of a very similar proposal by Dial-a-Dump that was thoroughly rejected by the Independent Planning Commission in 2018 because of its dire health impacts. This is the same proposal. It uses the same publicity phrases. Its promotion materials have same arguments etc. This proposal application should have even not been accepted for submission in the first place.
It is a waste incinerator that is deceptively and misleadingly termed as energy from waste facility. Such facilities are not economically viable as energy projects. Their economic feasibility entirely rests with the incineration of waste aspect.
This waste incinerator with non-stop truck movements will generate extreme amounts of heat, noise and toxic pollution (dioxins, air particles, complex hydrocarbons,......) that will devastate peace, health and property values of the dense urban population living right next to this facility. The EIS fails to consider the following:

1. Commutative health effects of combined pollution from existing and proposed facilities have not been considered. Often the combined impact is much more than the arithmetic sum of the two. The EIS fails to consider the existing air quality conditions and pollution from from existing waste facilities in the area.
The area has severe air pollution load already from numerous industrial estates with their diesel trucks and from motorways’ traffic. The area also has poor air drainage/flushing characteristics. The polluted air tends to hang on the area and is not easily blown away.

2. The residents in this area have been experiencing severe stench from existing waste facilities for several years. Relevant authorities have not been able to resolve that. That indicates poor enforcement abilities of the Authorities.
Institutional capacity of EPA to monitor pollution from incinerators (similar facilities) has not been discussed. This is concerning because EPA has not been able to detect the sources of leaks (marked by strong widespread stench) in the area.

3. The proposed incinerator will burn hundreds of thousands of tons of waste at very high temperatures. That will generate huge amounts of heat in an area that is already experiencing extreme heat in summer. With close to 50C temperature this was the hottest place on earth during the last (2019-20) summer. The impact of additional heat on the local climate has not been discussed.

4. Social impact of falling property prices in the adjoining urban areas. Tens of thousands of people live right next to the proposed incinerator site.

5. The need for such a large and polluting industrial waste incinerator surrounded by urban population of which there is no precedence in Australia.
Such facilities are being phased out in Europe. No new waste incinerators have been built in the USA for over two decades due to their health concerns.

6. Impact on Prospect Reservoir (source of water supply for the whole of Sydney) which is very close. Dioxins discharged from the facility will get added to that water. Current water treatment does not remove such chemicals.

Refer attached email submission

There is already too much traffic in the area of the proposed incinerator, it is much too close to suburban homes. When BHP opened at Rooty Hill everyone was told it would be non toxic, however many people developed breathing problems and things such as asthma when it commenced production.
I believe waste disposal should not be in suburban areas as the roads get ruined by waste trucks, Toxic fumes are created By the extra traffic as well as the incinerator chimneys stacks. It doesn’t matter that we are told how clean it will be it never is.
NSW has plenty of land that doesn’t impact housing areas so waste disposal should be done outside towns. Much waste can be used in landfill or recycled and doing it outside Greater Sydney area could create employment in semi rural areas.
The surrounding roads to the proposed incinerator Are already overcrowded. The only people to benefit will be clean away whose profits will be boosted. I would rather we protect our environment not destroy it with garbage disposal. The housing prices will be impacted in an already depressed housing market.
I say NO to Cleanaway’s proposal which they have tried to get passed by Government while we were all focussed on Covid impacting health and economy. Why has it been kept so quiet until recently. Another Liberal Government covering things up until the last minute.
The proposals from Cleanaway keep coming despite the population of Sydney not wanting things approved. Our land and environment are far more important than their profits. There is already foul odours coming from the local tip, scavenging Ibis fouling local areas and screeching in their nightly quest for trees to roost in at night. Bird lice in their wake. We don’t need another waste disposal facility so close to the tip.

I have previously objected to these incinerators and my reasons have not changed. Given the high incidence of Asthma along with other health concerns in our population we cannot have any organisation burning toxic wastes, plastics and other land fill.
The proposed incinerator is close to schools , homes and businesses that will suffer if this is to go ahead.
It is a known fact that breathing in these fumes causes cancer and these incinerators have been banned in so many other countries.
CLEANAWAY have confirmed they will be burning plastics in their incinerator. Burning plastics derived from fossil fuels does not create “green” energy - it is simply burning fossil fuels in another form and is therefore in breach of The Renewable Energy (Electricity) Act 2000.
Cleanaways EIS, says: "Most plastic received will form part of the fuel for the EfW process."

Waste-to-energy incineration is also a source of mercury emissions. The increased mercury levels have been recorded in fish living in the reservoirs for hydroelectricity. The adverse effects of mercury exposure on human health have been indicated in a number of studies, and there seems to be no ‘zero effect’ exposure level. As a result, the mitigation of mercury emissions is gaining more and more attention. The danger of mercury pollution drew widespread attention after the cause of the Minamata disease (Ekino et al., 2007) was identified as a severe case of mercury poisoning. Mercury compounds are generally more toxic than the compounds of other nonradioactive heavy elements (Pushie et al., 2014). Mercury can easily vaporise in combustion processes and be released into the atmosphere as mercury vapours. Moreover, combustion temperatures are usually high enough to decompose mercury compounds and release Hg0 vapour (metallic Mercury).
Elemental mercury has a very low solubility in water, which makes it challenging to remove elemental mercury by commonly used methods for flue-gas cleaning. Human exposure to metallic mercury takes place mostly by swallowing contaminated foods or drinks or breathing in mercury vapours. When ingested, only a very small amount of metallic mercury (less than 0.01% of the dose) is absorbed through the gastrointestinal tract (Da Broi et al., 2017). Inhaling of mercury vapours is much more dangerous as mercury enters the bloodstream through the lungs. The density of saturated mercury vapour strongly depends on the temperature. Charvat. P ‘et.al., 2020, ‘An overview of mercury emissions in the energy industry - A step to mercury footprint assessment’, Journal of Cleaner Production, ScienceDirect, Volume 267, No 122087

Please do not allow this slow poisoning of Blacktown residents to go ahead.

Another reason to ban Cleanaway's Incinerator is it is too close to our water supply. The drinking water pipeline is right next door, and Prospect Reservoir is only 1.7km . We do not want contaminate our water supply.
There are a hundred thousand more reasons to object to this incinerator but I do not have any more time to waste telling you NO to this incinerator. Like the last 2 incinerator proposals we DO NOT want to have one.
Thanks
Regards
Alison

I object to the Cleanaway Western Sydney Energy Centre on the following grounds: The community already faces compromised air quality and this incinerator can only add to this .Im already told that during winter there is sometimes more pollution from firewood during than car pollution! An incinerator may make people think that waste is out of sight out of mind but our are quality is being affected by so any things . We don't need to add to the cumulative effects.
I’m reliably informed that there are safer ways to manage residual waste, such as Material Recovery Biological Treatment facilities, Anaerobic Digestion facility, non combustion technologies like Gas phase chemical reduction that could become part of a sustainable renewable hydrogen economy.
It wild be much better to recycle more of our waste effectively and aim for reducing he amount of ‘waste’ in the first place. This linear approach to waste management that releases ghgs to the atmosphere, is the reason why the EU has withdrawn any subsidies for this industry and has classified it a climate threat. Even the Australian Public Health Association warns that there are a range of adverse health impacts associated with incinerators. NSW has a long history of rejecting incinerators.
Please look at the many alternatives to this project and think of our air quality
Mark Selmes
Mount RAe Rd , Taralga

I object to this incinerator proposal. Cleanaway does not call it an incinerator, but that's what it is. Incinerators are not the way forward for waste management in the 21st century. I support recycling as the way forward for our city's waste management, and do not support incinerators which pump toxic fumes into the air we breathe.

I would like to provide more detail and if given an extension wil detail.my objections on environmental and health concerns as well as the lack of legislative regulation and monitoring of this industry in New South Wales

As a group we object to this incinerator proposal.
Incinerators are not the way forward for waste management in the 21st century. We see a sustainable, local recycling industry as the way forward for our city's waste management, and do not support incinerators which pump toxic fumes into the air we breathe.
And the hazardous solid waste has no clear, specific regulatedcsolution to its ongoing storage.
As a group we would like an extension for providing a more detailed submission given the significant documentation.provided and the large number of concerns it raises

At no time was there any type of consultation with residents in regard to this proposal. As a resident that would be affected by emissions I object to this project.

Please refer to the attached letter of submission on the project

See email submission attached

To the review committee:

I am writing to express my opposition to a proposed waste incinerator in Western Sydney. As a parent who lives in and whose children attend school in Western Sydney, I do not want the multitude of pollutants and toxic ash from incinerators polluting the air my family lives in. With their lower thresholds for health impacts, children's environmental health protection must inform and direct our policies in regards to air quality.

While it is sometimes claimed that modern incinerators do not pose a significant risk, Zero Waste Australia summarises on their website, "most modern waste incinerators are still significant sources of hazardous air toxics emissions that are difficult to control. Some of the pollutants such as mercury, dioxins and polycyclic aromatic hydrocarbons (PAHs) can travel great distances and contribute to contamination on a global level as well as contaminating local soil and produce. Less persistent pollutants such as acid gases, nitrogen oxides (NOx), sulphur oxides (SOx) can still be highly toxic and impact on public health at a local and regional level around individual incinerators." They also outline that, "While tighter air quality standards have forced waste incinerators to increase pollution controls (especially for dioxins) they continue to be responsible for discharges of a large range of atmospheric pollutants and dioxin release incidents. The improvements to air emissions have also led to a much higher level of contamination of incinerator residues such as ash which must still be sent to landfill."

The 2019 report in the Australian and New Zealand Journal of public health, "The Health impacts of waste incineration: a systematic review", reported that, "A range of adverse health effects were identified, including significant associations with some neoplasia, congenital anomalies, infant deaths and miscarriage".

A report, "Hidden emissions: A story from the Netherlands" from Zero Waste Europe reports on Toxico Watch research monitoring the Harlingen incinerator in The Netherlands, built in 2011 and touted as "state of the art" and conforming to best environmental practice. "In 2013, a study by ToxicoWatch found high concentration of dioxins and furans in eggs of backyard chickens in the surroundings of the REC incinerator. Eggs of backyard chickens are sensitive environmental biomarkers for persistent organic pollutants (POPs) like dioxins. All eggs of backyard chickens in Harlingen, sampled within a radius of 2 km from the REC incinerator, showed a much higher concentration of dioxine than allowed by the EU. Notably, the concentration exceeded 1.7 BEQ/gram fat (Bioanalytical EQuivalent), and the 2.5 picogram TEQ/gram fat limit set by EU law. This means that potentially highly toxic dioxins exceed the maximum limit for consumption of eggs in the environment of Harlingen. A subsequent national survey found 50% of the backyard chicken eggs in the Netherlands were below the maximum limit for dioxins in eggs. However, around the incinerator (Figure 1) all eggs are exceeding the limit for dioxins of 2.5 picogram TEQ/gram fat".

This report goes on to explain, "Long-term sampling is not mandatory for waste incineration facilities, that mostly rely on pre-announced short-term sampling of 6-8 hours twice a year. After the alarming findings of dioxins in eggs of backyard chickens in the ToxicoWatch study, the local government decided, for the first time in the Netherlands, to perform long-term sampling of flue gases in the REC with the AMESA technique, which stands for Adsorption MEthod for SAmpling of dioxins. When short- and long-term sampling are carried out in the same period, remarkable differences become visible (Table 1). The results show that short-term sampling seriously underestimates actual dioxin emission levels by factors of 460 - > 1290 (Table 1)."

Europe is sometimes mentioned as a wide user of incineration, however, in the 2017 European Commission report, “Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions" titled “The role of waste-to-energy in the circular economy”, we see that "the waste hierarchy also broadly reflects the preferred environmental option from a climate perspective: disposal, in landfills or through incineration with little or no energy recovery, is usually the least favourable option for reducing greenhouse gas (GHG) emissions; conversely, waste prevention, reuse and recycling have the highest potential to reduce GHG emissions." For member states overly reliant on incineration of municipal waste, the report states that "such high rates of incineration are inconsistent with more ambitious recycling targets", and recommends "introducing or increasing incineration taxes, especially for processes with low energy recovery while ensuring they are paired with higher landfill taxes; phasing out support schemes for waste incineration and, where appropriate, redirecting support to higher-ranking processes in the waste hierarchy; and introducing a moratorium on new facilities and decommissioning older and less efficient ones."

The Nordic Council of Ministers has conducted an "Analysis of Nordic regulatory framework and its effect on waste prevention and recycling in the region" with the executive summary recommending "The clearest area of required change will be a significant shift away from incineration (and in Iceland, landfilling) towards recycling".

While energy production via waste incineration is sometimes claimed to be a "green" energy solution, the report, "Plastic and Climate: The Hidden Costs of a Plastic Planet" from the Center for International Environmental Law, reports that "one Mt of plastic burned results in 0.9 Mt of net CO2e emissions, even after taking into account the electricity generated by the combustion process. On average, one Mt of plastic packaging contains 79 percent combustible carbon content, which would release 790 kg of carbon, or about 2.9 Mt of CO2, into the atmosphere" and that "incineration of plastic packaging waste will still result in 0.9 Mt of CO2e emissions, even when two Mt of CO2e can be offset by energy recovery". The Global Alliance of Incinerator Alternatives (GAIA) summarises, "The research clearly shows that burning plastic in incinerators creates the most CO2 emissions among any plastic waste management method. Waste incineration, also referred to as Waste-to-Energy, is the primary source of GHG emissions from plastic waste management, even after considering the electricity that can be generated during the process." Incineration isn't the solution to our waste that we are looking for.

The solution is to pursue Zero Waste policies, strategies that enable a true circular economy rather than the wasteful and harmful impacts of waste incinerators, and ensure we have a good and healthy country for our children to grow up in.

A waste incinerator for Western Sydney has already been rejected previously. The risk to the community posed by harmful pollutants remains, as does the environmental impact of directing waste away from recycling, reuse and compost into a high-carbon emitting process.

Thank you.

It should be stopped and lessons have to be learned from other countries that had same situation and costed them huge.

I have attached a letter outlining my objections.

Please do not start a new project which creates more air pollution- toxic particles, not just greenhouse gases. Please do not start a new project which produces toxic residues. Please do not start a project which necessitates the continued consumption of resources and the concomitant production of waste. Please do promote reduced consumption of resources, reduced production of waste material, and increased recycling.

As a local resident I strongly object to this proposal. We moved to Horsley Park in 2014 as our family all suffer asthma and allergies, and medical professionals suggested that the rural residential atmosphere was better for our health. Since moving here, we have had the airport approved, and now could be also impacted by this proposed facility. The current Veolia facility at Wallgrove Rd Horsley Park, covering 30 hectares of land currently receives up to 430,000 tonnes of waste per annum and emits very strong pungent odours every afternoon and evening, already impact the aesthetics of our rural community. This new facility in the same vicinity will exacerbate this further.

As we already have a large waste management facility in the area, surely it would be better from an environmental, health and traffic point of view to plan such a the new waste management facility & incinerator for an area that does not already have such a facility. There are many locations on the outskirts of Sydney that could accommodate this, reducing the concentration of traffic, pollution and environmental hazards within our region. The nearby Prospect Reservoir and Western Sydney Parklands are areas of major concern, as air or water based pollutants from the proposed facility could greatly impact these two extremely important Western Sydney assets.

There are many local families that would be severely impacted by the doubling up of waste management facilities within our region. Please reconsider this decision and prevent Cleanaway building this facility in our local area, which already houses the Veolia facility.

I object to this project due to the health and economic impact it will have on the residents of Eastern Creek and surrounding suburbs.
Western Sydney already shoulders more than their fair share of environmental harms related to pollution, contamination, toxic waste and heavy industry.