Cleanaway's Western Sydney Energy & Resource Recovery Centre

To Whom It May Concern,
I don't want a waste incinerator built at Eastern Creek.
I moved to Minchinbury in 1989 and started a family with my wife. We have 3 children and a grandchild on the way.
I am furious that Cleanaway wants to build an incinerator in my community. Western Sydney already has to deal with an ambient air pollution levels that often exceed the accepted health standards set by the National Environment Protection for Ambient Air, to which the NSW Government is a signatory. You would have to then ask why is the community yet again being put through the stress of having to fight another proposed waste incinerator being built in such an environment. Surely the NSW Government should be doing everything in it’s power to improve the existing air quality standards in Western Sydney, and to not even allow the consideration of a facility that has proven overseas to increase pollution levels.
Cleanaway is a massive company, and who clearly wants to make lots more money, but it should not be at the expense of whole communities. Recently I have read and watched several reports on the TV, radio, and in the newspapers, about Cleanaway’s business practices when they were found by the NSW EPA to have breached set health, safety and environmental standards. When 26 out of 27 of Cleanaway’s NSW sites were found to be in breach of the set standards there is clearly a history of a company behaving as if they are above the law. For this reason such a company should never have ownership, or control, of such a facility.
From where I live I will be directly affected by the proposed facility because I live within 5km’s of it, and with winds predominantly coming from the south west, I will also regularly be downwind of it.
As well as having a direct impact on the community’s health, there will also be a massive increase in truck numbers needed to bring the waste to feed the incinerator on our already congested roads. This will also increase air pollution levels, and will be even worse if Western Sydney is to be burdened with 2 waste incinerators !
If such a facility must be built, and I definitely don’t think they should, then don't allow it to be built anywhere near people. Another reason I say this is because authorities in Europe are now acknowledging that incinerators cause pollution, and the follow on health problems associated with them. The massive health impact has subsequently had in turn an equally massive financial impact, that by far exceeds any paltry benefits that this industry purports to having. So much so that the EU are removing subsidies to them, and have begun to tax them. They have come to realise that waste incineration is a toxic industry that has had a detrimental affect on communities world wide.
In light of this I ask you why then would you still want to build a waste incinerator in NSW, let alone here in a densely populated area of Sydney ?
I say no to the incinerator and ask you to do the same.

I have significant concerns about the impact on air quality, the environment and the community from the proposed project. The project EIS is a complex document that is difficult for average community members to digest and analyse. More consultation, especially involving air quality impacts, should be done with the community.

There is inadequate information on how the project will function under increasing heat. In the next 50 years Western Sydney may see one in seven days reach over 35 degrees celsius. Will the proposed facilities function in that heat? How will it impact pollution? Will it increase the urban heat island effect that exists in Western Sydney?

Regarding air quality - the information on particulate matter in the EIS suggests that an increase in dangerous pollution is not an important risk because of the high levels of existing particulate pollution. It is not adequate to say that because a problem exists, the impact of this project is negated. There is no evidence that there is a safe level of pm 2.5 pollution.
The reasoning behind the Air quality and Health risk assessment appears to be that given residents are already exposed to air quality that does not meet national standards, a further increase is of no concern. My understanding is that the annual average PM 2.5 is assessed to potentially increased by 1.9 ug/m3. This is not a small increase. It is an increase of nearly 25 % of the national standard. Even on top of the 2015 levels, this would put the area around the proposed facility above not only Australian levels but also WHO levels. On top of the 2019 levels, the PM 2.5 levels would be 75% above national standards.

Each 1 ug/m3 of PM 2.5 has significant increased health risks.

“Long-term exposure to PM2.5 was associated with total, non-accidental, cardiovascular, and respiratory mortality in Queensland, Australia, where PM2.5 levels were measured well below the WHO air quality standard.”

“For each 1 μg/m3 increase in annual PM2.5, we found a 2.02% (95% CI 1.41%–2.63%; p < 0.01) increase in total mortality. Higher effect estimates were observed in Brisbane than those in Queensland for all types of mortality.”

(https://journals.plos.org/plosmedicine/article?id=10.1371/journal.pmed.1003141)

I am a resident of Lalor Park in the Blacktown area and I object to the Cleanaway's Western Sydney Energy and Resource Recovery Centre as it will increase the toxic pollution in our area which will be harmful to everyone. It puts the community in too much risk. It will reduce our air quality and put everyone's health at risk which none of us want. It will also cause a bad odour in the area.

I also do not trust Cleanaway as they have a bad health record and we do not want anyone like that in this area.

I also do not want my kids/grandkids being poisoned by this for the next 30+ years

Ellen Whippy-Lal

To whom it may concern,

I have been a resident in Erskine Park for the past 7 years, in that time we have seen the pollution get worse and worse, we smell the garbage tips everyday, we do not need to have the air we breathe further compromised by the construction of this cleanaway incinerator or any other incinerator for that matter. Western Sydney and moreover this area already has the worst air quality in Sydney, allowing this incinerator is a death warrant to anyone living here.
We have a right to be able to breathe air and not get sick, it is up to you to keep our lungs clear, devoid of the toxic rubbish this incinerator would spew out. I plead with you to make the correct decision and not allow this abomination to go ahead.
Afew key points to not build any incinerators are;

* Waste incinerators have re-branded themselves as ‘green’ energy suppliers. The reality is that burning waste is the dirtiest form of energy generation both in toxic emissions and climate change gases. Waste burning facilities produce far more carbon dioxide per unit of energy generated than coal, oil or gas fired power stations. In addition to producing larger quantities of greenhouse gas per energy unit than coal, incinerators also destroy the ‘resources’ in waste that could be recovered if the discarded material in waste were recycled or reused. Much of the waste material burned in incinerators is based on petrochemicals. These include plastic bottles, bags, packaging and even electronic waste. Petrochemicals are fossil fuels and burning plastics derived from fossil fuels does not create ‘green’ energy – it is simply burning fossil fuels in another form.

* Independent studies have reported that waste management systems that use recycling, re-use, composting and anaerobic digestion generate many more jobs and far outstrip the few positions required to run an incinerator. In general terms waste incinerators are expensive, computer controlled, largely automated technology that only require a small workforce to operate. Conversely waste management systems based around recycling, re-use and ‘cool technologies’ have a high employment generation potential and flow-on effects throughout the community and economy. Installing a waste incinerator means that communities forego employment opportunities while squandering valuable resources.

* Waste incinerators produce large amounts of toxic air pollution that impact on the environment and human health. These emissions include highly toxic and carcinogenic persistent organic pollutants such as dioxins and furans (PCDD and PCDF), hexachlorobenzene (HCB), PCBs and brominated persistent organic pollutants.

So incinerators have been shown to make the environment toxic, Produces more toxic gases per energy unit than all other power stations and will create less Jobs. This is a lose,lose,lose,lose,lose,lose etc, proposal. Please put it where it belongs, in the bin!!! (then don't burn it..... recycle it).

I object the project for the following reasons:
Research studies prove the dangers of particulates, released by incinerators.
It is also now established that incinerators produce high quantities of ultra-fine particulates, there is no technology available to capture these 0.01PM which are invisible to the naked eye and are proven to cause a range of heath problems.
There are 15 schools near the site proposed incinerator.
Cleanaway reference facility breached Environmental licence in first week of operation .
Cleanaway site is to close to our water supply.
I used to work in at Clinical Waste an incinerator in Silverwater and I was diagnosed with non- Hodgkin lymphoma I had to undergo chemotherapy. I have been given a second chance in live and I have the responsibility to avoid people from been exposed to waste incinerator emissions and dave lifes.
Thanks for taking the time and reading my objection.
Kind regards
Sofia Jackson

I wish to object to Cleanaway's proposal for an Energy and Resource Recovery Centre.
There has not been sufficient time to review the entire EIS. For this reason, my submission is focussed on the air quality, health and climate issues.
I am concerned that the EIS not include an up-to-date risk assessment of climate change that includes material about specific impacts in Western Sydney. It is well below the standard that residents of NSW should be able to expect of assessments in 2020. The very few statements about climate included in the report are very brief and overly general. Indeed, the Todorski AQ report do not include any specific information about scientific research that shows there will be an increased likelihood of bushfires and increasing high temperatures that will impact on the area. It ignores evidence that increasing temperatures have been linked to deteriorating air quality. air quality. All of this is available through basic searches of research literature.
https://www.abc.net.au/news/2020-10-19/western-sydney-schools-at-risk-of-heat-danger-this-summer/12779666?nw=0

The selection of the year 2015 for the base line assessment is not sufficiently justified, especially given DPI results were available for 2019.

The report does not sufficiently explain or convey the risks to residents of increasing emissions of particulate matter in the vicinity of the facility. This assessment should be reviewed. There is a reference to local air quality monitoring that was done in 2019 to 2020 but I could not find it. It is possible that I missed it. Has this been included? if not, why not? I do know that any 2019 monitoring would have shown daily particulate matter results that were well above the 2015 baseline data. The evidence of poor air quality especially in Western Sydney cannot be ignored as there is evidence that the conditions of last Summer may recur in the future.

“All predicted impacts associated with all emissions from the proposal are within the applicable in-stack limits and ground level criteria, apart from cumulative ground level PM2.5 and PM10 concentrations, due to the existing background levels which already exceed the criteria (as 19030934A_WSERRC_AQ_200910_HiRes_Clean.docx occurs across much of NSW). However, the predicted proposal contribution to ambient PM2.5 and PM10 concentrations is small and would not result in any discernible or measurable impact.” ( Conclusion of Todorski report in EIS)

I do not believe that this statement is justified in the light of recent research on the impacts of particulate matter. in a situation in which air quality is already not meeting national standards, how can you justify exposed the residents to increased impacts? Surely far more discussion and justification is needed.

A search of the DPI site reveals that the annual average of PM 2.5 was 11.9 ug/m3 in 2019. This sudden increase from previous years was largely due to bushfires. However the overall yearly results do show a tendency towards increasing levels that continue to be above the national standard. The choice of 2015 as the baseline year cannot be justified in these circumstances and has impacted on all the likely results. At the very least, predictions of worsening air quality should be taken into account through modelling different scenarios. This idea that this facility should be placed in an area where air quality tends to be worse than some other areas of Sydney raises serious questions of equity. In fact, the 2019 PM 2.5 readings may be closer to future readings than the 2015 monitoring results.

The reasoning behind the Air quality and Health risk assessment appears to be that given residents are already exposed to air quality that does not meet national standards, a further increase is of no concern. My understanding is that the annual average PM 2.5 is assessed to potentially increased by 1.9 ug/m3. This is not a small increase. It is an increase of nearly 25 % of the national standard. Even on top of the 2015 levels, this would put the area around the proposed facility well above Australian standards. On top of the 2019 levels, the PM 2.5 levels would be 75% above national standards. This is not acceptable.

Each 1 ug/m3 of PM 2.5 has significant increased health risks. Why is this not considered? A Queensland study found:

“Long-term exposure to PM2.5 was associated with total, non-accidental, cardiovascular, and respiratory mortality in Queensland, Australia, where PM2.5 levels were measured well below the WHO air quality standard.”

“For each 1 μg/m3 increase in annual PM2.5, we found a 2.02% (95% CI 1.41%–2.63%; p < 0.01) increase in total mortality. Higher effect estimates were observed in Brisbane than those in Queensland for all types of mortality.”

(https://journals.plos.org/plosmedicine/article?id=10.1371/journal.pmed.1003141)

While there may be uncertainties in the research, there is amply research evidence that no level of PM 2.5 level is safe but also that increased levels increase health risks. Once again, why is there no serious discussions of these issues in this EIS?

I raise these concerns because I have become increasingly concerned about unacknowledged risks to community health as a result of a disconnection between the predicted ambient levels in the WestConnex Air quality assessments and the actual results of WestConnex's own monitoring. Research in St Peters has shown that contrary to EIS assertions about background levels that claimed the yearly averages and maximum daily averages would either meet or be only narrowly above national goals, monitoring over three years shows levels higher than that. I would be happy to further more research into this issue to DPI asssessment teams. When this has been raised at the M8 Community Consultative Air quality Committee, residents have been told that this is of no concern to the project. I realise that this is not of immediate relevance to this project proposal, but I am concerned that an even worse under estimation of particulate matter levels may be occurring in this Cleanaway EIS.

I am concerned that the construction impacts in this report are once again dismissed as manageable. I draw the assessors attention to publicly available WestConnex reports showing scores of daily exceedances in St Peters in 2019. If the team does not have access to these reports, please let me know so that I can forward them to the department.

I have two additional points.

1. A little over a month is not sufficient for concerned community members to process, seek advice and respond to this EIS. A serious independent assessment is needed by experts who understand up to date health research on air quality and other issues.
2. At page 975 of the report, I found an unexpected statement.

“Following our recent meetings and negotiations with Blacktown City Council, Cleanaway and Macquarie Capital are pleased to advise that should the project be granted planning approval to proceed, the project offers to enter into a Voluntary Planning Agreement (VPA), based on the terms attached.”

Blacktown Council are known to have opposed the Dial a Dump New Generation facility I am concerned that Cleanaway might have sought to lessen likely opposition from Blacktown Council with financial considerations. It is well known that Council are struggling with finances. While I understand that this may not be a factor in assessment, i am very concerned that this has not been publicised to residents in the local area for discussion. Best practice in the area of VPAs has found that the community should be involved in their development. Again, I can supply more information about this legal research if necessary.

Thanks for considering this submission and please me if more references are need to justify these arguments.

No one was spoken to about this project in Minchinbury or surrounding suburbs. It has been rejected once, why can’t they project owners see no one wants it in western Sydney! People’s health are at risk. Not only to those living in the 5km zone but I’m surrounds. We don’t get impacted by bushfires but we get the smoke big time! I rather that all year over the smell and risk that would come from this. Animals lives are also at risk. Not only those living in the surrounding areas but a whole zoo as well! What a way to impact their health by polluting them.

I wholeheartedly object to Cleanway turning my local area into a 'sacrifice zone'. I live in Minchinbury and would be directly harmed by the proposed incinerator. I do not wish to be involuntarily exposed to toxic air pollutants such as dioxins or hexachlorobenezene, nor would I consent to exposure to toxic ashes produced by organic pollutants.

I would strongly encourage the NSW government to put the genuine interests of it's residents before profit motives and quick fixes.

To whom it may concern,

I wish to object strongly to this proposal for an incinerator based in Western Sydney. Waste incineration has been shown to be toxic for the environment and local communities- rather than reducing waste at its source, they burn it to generate relatively little energy and significant levels of air pollution; why on earth should we risk building such infrastructure so close to homes and schools, much less at all?

On multiple grounds, this proposal fails to stack up. Not only does not eliminate landfill (and can burn plastics and recyclables), but it poses a very real threat to Sydney's precious water catchments and drinking water! Cleanaway's own EIS confirms sediment may have the potential to impact Environment, Reedy Creek & Eastern Creek, while run-off from hard-standing areas will be directed to the bioretention basin - promoting contamination to soil and vegetation by heavy metals and toxic chemicals. As a result, the Hawkesbury-Nepean river system, (an important natural asset and one of the largest coastal river catchments) will be at real risk- unthinkable given that it is the main source of drinking water for over 4.5 million people (some 70 percent of the NSW population). Its waters also support agricultural and horticultural industries that generate more than $1 billion annually, including $259 million of irrigated agriculture which supplies much of Sydney’s fresh food.

As if that was not alarming enough, Cleanaway’s EIS shows that Dioxins will not be continuously monitored. Given that exposure to dioxins can cause cancer and infiltrate the very food chain of a local area, I have significant concerns for the safety of this and future generations.

Finally, Sydney is a C40 City and should be leading the way on renewable energy projects to reduce climate changing emissions like C02 and improve the health of communities. The Cleanaway incinerator will emit more C02 than coal and gas as well as dangerous emissions such as dioxins that are cancer causing. Approving an incinerator flies in the face of that commitment.

We should be looking towards clean air, renewable energy and more sustainable management of council waste; not this toxic "waste to energy" scheme. For the future of Western Sydney and the children who will have to grow up under the shadow of these structures and their pollution, I implore you to put a stop to the development and send a message that the health and wellbeing of this community is worth something.

I object to this project. I feel angry that our community has been fighting this for so long now (and won) but it seems Cleanaway just keep throwing money at it. I feel this is starting to look like a financial issue rather than a safety issue. These incinerators should not be anywhere near residential areas. I’m in Minchinbury very close to the proposed site and I’m very concerned about the health impacts this will have on my family with 3 of us already suffering from asthma. Cleanaway claim they consulted the community yet it is clear from our community FB page nobody was consulted! The government should be putting people’s health before any financial gains. Please please please don’t let this go ahead.

The burning of petrochemicals is simply more burning of more fossil fuels, not a green energy source. Waste burning facilities have been shows to emit more greenhouse gases per energy unit than other condemned energy sources like coal, oil, and gas fired power stations whilst misappropriate otherwise recyclable resources which may be in the discarded waste. Evidently, I believe resources should be properly funnelled into the development of sound long-term sustainable technology, energy sources, and waste management systems. I strongly object to this unjustifiable development project.

I object to the proposal for an Energy from Waste incinerator in the Sydney basin region and as a refuse removal service due to the inefficiency of the activity.
Incineration is not an improvement on landfill and proves to be significantly hazardous to human health and an environmental disaster with particulate matter significantly increasing in the air when there is an incinerator active. The NSW EPA states that incineration is not an improvement on landfill.
Environmental authorities along with the Department of Planning and Development confirm the human dangers from incineration as a result of increased air pollution for nearby residents and those further afield.
It is reported that lung cancer rates are higher for Western Sydney and the addition of increased air pollution from an incinerator will have a deleterious effect for the community as well as those living outside the immediate vicinity as air is pushed downstream.
It is important to note that a past request for EfW incinerator in the Eastern Creek area was rejected by the Independent Planning Commission based on it not being in the public interest at the time, as well as in the future, noting the polluting factors of the future Western Sydney Airport reducing the air quality as an additional factor.
Overseas research also considers that any urban design must include polluting factor policy as part of their planning implementation to reduce the environmental and health burden and impact.
References:
<https://www.ipcn.nsw.gov.au/resources/pac/media/files/pac/projects/2018/04/eastern-creek-energy-from-waste-facility-ssd-6236/department-of-planning-and-environment-meetings/20180412--dpe-presentation--efw--final.pdf>
<https://www.wentwest.com.au/content/documents/phn/needs-assessment/WSPHN_PHCA.pdf>
<https://www.ipcn.nsw.gov.au/resources/pac/media/files/pac/projects/2018/04/eastern-creek-energy-from-waste-facility-ssd-6236/determination/statement-of-reasons.pdf>
<https://www.who.int/en/news-room/fact-sheets/detail/ambient-(outdoor)-air-quality-and-health>
Barrera V, Calzolai G, Chiari M, Lucarelli F, Nava S, Giannoni M et al. 2015, ‘Study of air pollution in the proximity of a waste incinerator’
Kim Y, Kim J & Lee S 2011, ‘Burden of disease attributable to air pollutants from municipal solid waste incinerators in Seoul, Korea: a source-specific approach for environmental burden of disease’
Endjambi K W, Ameh O S, Kgabi N, Maposa I & Hamatui N 2016, ‘Particulate matter concentrations in the vicinity of an incinerator’

I have moved to St Clair in the past 6 months with my partner, we choose St Clair as it is the perfect location for us to raise our future family. With nature reserves, local sports fields and minimal traffic and industrial activity we believe this was the right choice.

The development of the incinerator will jeopardize this for our families future in St Clair. We don't want to live in a suburb that will be right next to this facility, this is essentially condemning our family to suffering future health issues and death as a a result of this project.

Cleanaway & Macquarie Capital both have a history of operating outside the law. Both proponents have contravened environment protection legislation making their corporations an unfit person under the Act. Below lists some of their EPA violations. This is why our community has no faith in them building and operating an incinerator near our homes. Cleanaway (Over 35 EPA violations) and Macquarie Cleanaway can’t be trusted to keep our air quality clean.

On the 2nd September 2009 at the Wagerup Refinery (owned by Cleanaway) an employee, Paul Herbert Fry, fell through one of the open manholes to his death. Transpacific breached the OHS Act by its failure to take all reasonably practicable steps to protect the health and safety at work of its employees. There was a court case, pursuant to cl 4 of Pt 1 of Sch 2 of the OHS Act the respondent was convicted and paid a $170,500 penalty to the Commonwealth of Australia.

29/03/2001 - Cleanaway (previously known as) Transpacific EPA Order
Allowed waste to be stored outside of concrete bunded areas at the site in breach of a licence condition. Also received waste from interstate, for the purpose of treatment by incineration, when the waste was physically unsuitable for incineration.

Macquarie Capital (Group) are Cleanaway’ Joint Venture Partner. They are being investigated overseas for financial misconduct and should not be allowed to be a property developer in Australia.

Macquarie group is currently being investigated for massive tax fraud in 2018, across several European countries over long periods. Macquarie's internal documents, reviewed by a collaboration between 17 European media, show that Macquarie continued to make money available for speculation and fraud with dividend tax after their legal advisers expressed concern.

Top executives of Macquarie Group were among 30 staff likely to be classified as “suspects” as part of a German tax investigation over a 2011 deal. Macquarie Group chief executive Nicholas Moore and his successor, Shemara Wikramanayake, were involved in approving deals that are now at the centre of an investigation by German prosecutors into an alleged tax fraud scandal.

The proposal to build the Cleanaway & Macquarie Capital Incinerator at Eastern Creek, is a recipe for disaster. The public health claims made by proponents at their citizen panel are challenged by the experiences of communities around the world where these incinerators are already operating.

A 2020 Study “The Health Impacts of Waste Incineration: A Systematic Review in Austraia” states; A range of adverse health effects were identified, including significant associations with some neoplasia, congenital anomalies, infant deaths and miscarriage, but not for other diseases. Ingestion was the dominant exposure pathway for the public.

There is an increased risk of out-of-hospital cardiac arrest (OHCA) even from short-term exposure to low concentrations of fine particulate matter PM2.5, such as that produced by Incinerators. This current 2020 nationwide study in Japan, chosen for its superior monitoring, population density and relative air quality, is believed to be by far the largest of its kind. It provides comprehensive evidence of the relationship between PM2.5 and cardiac arrests, using a sample three times larger than all previous research combined and demonstrating the impacts on groups such as the elderly

Two large American studies confirm that Waste to Energy Incinerators increase particulates therefore increasing the risk to health. The studies proved that fine (PM2.5) particulate air pollution causes increases in all-cause mortality, cardiovascular mortality and mortality from lung cancer, after adjustment for other factors. A more recent, well-designed study of morbidity and mortality in postmenopausal women has confirmed this, showing a 76% increase in cardiovascular and 83% increase in cerebrovascular mortality in women exposed to higher levels of fine particulates. These fine particulates are primarily produced by combustion processes and are emitted in large quantities by incinerators.

The study “Public health impacts associated with incinerators – a compilation” results support the hypothesis of a statistically significant higher risk, among men and women alike, of dying from all cancers in towns situated near incinerators and hazardous waste treatment plants, and specifically, a higher excess risk in respect of tumors of the stomach, liver, pleura, kidney, and ovary. Furthermore, this is one of the first studies to analyze the risk of dying of cancer related with specific industrial activities in this sector at a national level, and to highlight the excess risk observed in the vicinity of incinerators and installations. https://zerowasteoz.org.au/wp-content/uploads/2017/12/Public-health-impacts-associated-with-incinerators.pdf

How can you in good faith allow for a waste to energy incinerator to be built by Cleanway & Macquarie Capital when they have had many violations, breaches and fines throughout there time operating as well as the many scientific studies that outline the adverse health affects to the communities that live in the vicinity of these facilities?

Myself and the rest of my household are against the proposed development of the Cleanaway Incinerator. We find the provided information regarding environmental impact to be lacking. Previous attempts to construct this style of incinerator have faced strong community opposition. It is clear that people do not want this project to be approved. Some quick research into waste-to-energy incinerators shows that the filtration process is far from perfect and can produce long lasting detrimental health issues. This submission should not be approved. Quality of life should be considered above financial benefit. There are many other methods of clean energy production that should be explored in the place of this proposal.

I object to this proposal .
The community consultations were not in line with best practice . The proponent cleanaway suggests they contacted over 3000 residents and none opposed . Due to covid 19 - the usual methods of engagement/ consultation were not as active or as effective . Residents who are within 15 km are not aware , and have no time to make submissions once they found out via their local council . Residents who live further away , but whose air quality would be affected such as kings Langley , we’re also not aware of this proposal due to covid 19 preventing normal
Methods of engagement for consultation- such as. A stand at park Lea markets , with people who couldn’t even answer my questions as to what technology was going to be used ? ( that was pre covid ) and just gave me a flashy PR style brochure .
I reject this proposal based on Insufficient community consultation and awareness of This proposal . The proposal
Is also complex and the state government and council should do thorough investigations on the health and economic impacts and release these for public viewing so that the public can make a
Balanced and unbiased choice .

I also reject This proposal and any bias Blacktown council May have in their submissions . They have a proposed financial gain , if the project is to go ahead through collecting royalties based on volume through the weighbridge . This bias and potential financial gain should be stated and considered as an influencing factor in their submissions

Please see attached objection as I was unable to use this box.

I am a local resident in my mid-twenties, living in St Clair towards the Roper Rd M4 exit. I have grown up in this suburb and more recently chosen to settle here with my partner. I am extremely disappointed at the prospect of opening an new incinerator in Sydney, let alone one so close to my home. I am worried about my community's health and how this contributes to carbon emissions which will affect my life and the life of my niblings and the younger generation immensely. We should be building circular economies, better recycling facilities and renewable energy facilities instead of this literal pile of burning waste. The reluctance by the government to act according to the science, and thus, in our best interests, is making me more anxious about the future and more reluctant to have children.

Building this incinerator will pose multiple health/environmental risks including but not limited to:
1. Increased Cancer Risk and Respiratory Problems
Many studies, old and new, show that communities all around the world, living close to incinerators, even modern facilities, suffer higher rates of cancer and respiratory problems (e.g. http://tinyurl.com/y7dteo). The recently released Paris Appeal Memorandum, supported by the European Standing Committee of Doctors (representing 2 million doctors), urged a moratorium on building any new incinerators (www.artac.info/static.php?op=MemorandumParisAppeal.txt&npds=1).
A recent study by The Small Area Health Statistics Unit has revealed and area in Dundee, Scotland, near a waste incinerator has one of Europe's largest cancer clusters. There were 81 more cases of non-Hodgkin's lymphoma than average and evidence of clustering for myeloid leukemia, around the incinerator. https://www.whatdotheyknow.com/request/matters_relating_to_the_incinera

2. Fine particulates in our air
L M Brown and his colleagues have pointed out that “long-term exposure to even low concentrations of fine particles may be associated with reduced life expectancy” [Brown L.M., Collings N., Harrison R.M., Maynard A.D. and Maynard R.L. Ultrafine particles in the atmosphere: introduction. Philosophical Transactions of the Royal Society of London A 358 (2000) 2563-2565].

3. Increased mercury levels
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

Additionally, the company hoping to build the 'Energy & Resource Recovery Centre' has continuously reaffirmed their inability and reluctance to behave in safe manner, as highlighted with the following EPA violations:
1. 4. June 2010 – Transpacific (Cleanaway) fined for supplying false information – whiting-out emission test results (the subject of the above breach) in its annual return for its oil recycling facility to NSW EPA
2. June 2006 - Transpacific (Cleanaway) Conviction for wastewater discharge from sewer into Dry Creek wetlands in SA. Charge: Material environmental harm, section 80(2), EP Act 1993. ERD Court. Guilty plea. Convicted and fined a total of $15,000 plus $650 prosecution costs awarded and $120 victims of crime levy.
3. 2011 - Transpacific (Cleanaway) were fined $110,000 after an employee was exposed to hazardous chemicals
4. 2011 - Transpacific (Cleanaway) have a history of not protecting their workers’ health and safety. In 2011 Transpacific (Cleanaway) were fined $363,000 after a fatal accident in Perth breaching federal work health and safety laws. The penalty is the largest against an employer as a result of a single court proceeding by Comcare. It is also the first time multiple breaches of Commonwealth work health and safety laws have been found against an employer in regard to an ongoing risk to health and safety.
5. 29/03/2001 - Cleanaway (previously known as) Transpacific EPA Order
Allowed waste to be stored outside of concrete bunded areas at the site in breach of a licence condition. Also received waste from interstate, for the purpose of treatment by incineration, when the waste was physically unsuitable for incineration.

Please reconsider if this is the best step forward. I wholeheartedly object to this project.

I am concerned that the proposal will create air pollution, including dioxins, which can spread through the wind. I live in Wollongong where we had a SWERF (solid waste energy recycling facility) which heated waste through pyrolysis but released dangerous levels of dioxins. Even if at low concentrations these toxin bioaccumulate, so have the potential to concentrate in the food train and be stored in animal tissue. Over time this can lead to hazardous concentrations that can impact heath.
I am also concerned that the process will generate heavily contaminated ash. The NSW upper house inquiry into coal ash shows that industrial ash is a costly liability in terms of management costs and environmental and human health risk. Furthermore, any scrubbers on the smoke stack only work as long as they are maintained. I am concerned that during maintenance periods there will unsafe exceedances of hazardous material.
I would like to see NSW develop a circular economy where the calorific material is preserved and utilised. 44 council’s across NSW have rolled out FOGO (Food Organics and Garden Organics) services which have municipal-scale composting systems to create A-grade commercial compost for use in a range of applications in landscaping and agriculture. This way most of the carbon is sequestered in the soil, improving its water holding capacity. By comparison a waste incinerator makes poor use of the organic material. I am concerned that many of the councils and municipal waste collection contractors that seek to supply this proposed facility do not have best practice FOGO services. I am concerned that instead of investing in FOGO services, this project will enable munipalities with current AWT systems to continue to generate highly contaminated Mixed Waste Organic Outputs.
Furthermore, using plastics as incinerator feedstock is against the waste hierarchy which seeks to maximise environmental and economic benefits through the circular economy. Plastics should be recycled and remanufactured for reuse, saving virgin materials.
As an energy from waste facility with a capacity to thermally process up to 500,000 tonnes per annum of residual waste from Municipal Solid Waste and Commercial and Industrial waste streams, it will undermine the viability of recycling and innovation.
Australian supermarkets have just started the implementation of the Australian Packaging Label which improves consumer understanding of what is recyclable, and enables better recycling compliance. This is the time when recycling supply chains should be getting better than ever, and the proposed incinerator puts all that at risk.
I am also concerned that this proposal will lock Council’s into crippling contracts where the incentive for waste reduction, waste avoidance and recycling maximisation is lost. The proposal has high capital costs and will rely heavily on public funding.
I have visited the Global Renewables facility next door, and that project failed to live up to it’s design claims. The maintenance costs of the electricity generation equipment where too great to be financially viable. I am concerned that this will be the case with this latest proposal.

There is no safe thresh hold for fine particulate pollutants . The thresh holds that are recommended by the EPA for all pollutants . Particulate and gaseous VOC , NO2 and Sulphur dioxides safety thresh holds accepted in Australia are not worlds best practice . The air pollution level in Western Sydney from motor vehicles , industry and energy generation is already at levels that harm human health.
Western Sydney has a higher incidence of individuals with elevated weight and type 2 diabetes than the rest of Sydney . The link of fine particulate pollution and incidence of diabetes , heart and lung disease , small for gestational babies is well established .
There is is no guarantee that the feed stock for the incinerator is not going to be toxic . If this is the endpoint for solid waste that cannot be dealt with otherwise. How do they keep out Cadmium , mercury from old thermometers , radioactive material for old smoke alarms , pesticides, asbestos , old sump oils full of metals .
Harm reduction is not the dilution of toxins and spreading it over a larger area.
Energy generation from cleaner sources are now more cheaply available . Waste management is an expensive complex issue . The solutions should also take into account the precautionary principle . That if there is the risk of harm to the community . You protect the community .

We have for years continued to fight against the Next Generations incinerator and now, unnecessarily we are tortured mentally and physically again by having to fight the Cleanaway incinerator. What I can't understand is why the Politicians who are all supposedly against this are not agreeing together on a Bill in Parliament. Even Gladys Berejiklian says she is against it.  I spoke to her on radio 2gb the day before the State elections on 22nd March 2019 and she promised an incinerator would never be built in Eastern Creek! Or was this just a big fat lie and vote gain tactic? Seems that there is some corruption, dirty deeds or money offers going by the big guns if we are the losers!
Cleanaway with their dirty track record, who have many fines and breaches to their name (some attached) is even making offers to Blacktown council in its EIS. This could easily sway results but it doesn't show that the the community want any toxic incinerators whether they live close to the proposed site or not.
The irreputeable marketing company financed by Cleanaway has manipulated answers in their favour. Questions can not be given comments and all are yes or no answers where yes is in favour of the incinerator and no is in favour of the incinerator. This is beyond laughable and definitely unreliable. They claim that 3000 people have been consulted. What a load of baloney. I am just over 1km from the proposed site and not 1 person in my street has been consulted and as far as the Minchinbury community Facebook pages and Rooty Hill noticeboards that cover thousands of residents neither has anyone else. So where are they getting their paid (bribe) unreliable data from? Department of Planning stated that one of the knockbacks in The Next Generations application was because of Public disinterest. This has not changed and will never change.
Department of Planning independent enquiry also knocked back TNG's application because of the vast amount of evidence available showing detrimental effects on health and the environment. We know these toxic monsters cause deformities,  premature births, respiratory problems, cancers and death. People in countries living close to incinerators all experience this. Please see attached.
Environmental Protection Agency cites health studies indicating that particles smaller than 2.5 micrometers (PM2.5) (and emitted from Incinerators) are “the major contributor to serious health problems like respiratory illness and premature mortality”
[http://www.crwi.org/textfiles/partem.htm]
What if there is a fire at the incinerator?
With it being so close to residential areas there is no escape. National Toxic Network has a record of many fires at these plants all over the world with many being fatal.
https://english.arnika.org/ipen-cee/waste-incinerators-accidents
We live in the Sydney basin. Worst location for anything really with Western Sydney having a high record of asthmatics.
"Asthma is now impacting approximately 2.7 million Australians or 11.2% of the population compared to 2.5 million or 10.8% in 2014/15."
https://asthma.org.au/about-us/media/asthma-incidence-on-the-rise/
"The strongest risk factors for developing asthma are a combination of genetic predisposition with environmental exposure to inhaled substances and particles that may provoke allergic reactions or irritate the airways", such as pollution,outdoor allergens, chemical irritants , air pollution and
strong odours to mention a few that would all be caused by incinerators.
https://www.aihw.gov.au/reports/chronic-respiratory-conditions/asthma/contents/asthma
Health experts and doctors also provided this information and concern at TNGs independent enquiry and earlier.
"The main barrier to the continued development of these plants is pollution. A US study from 2011 revealed that even when waste-burning facilities comply with the law, they still release many more harmful toxins — mercury, cadmium and lead — than coal plants. In Australia, environmental groups have been vocal critics of the plants, as have people who live near the proposed site"
Incinerators release more Carbon Dioxide than Coal, Oil and gas.
https://www.google.com/amp/s/www.createdigital.org.au/australia-waste-to-energy-options/amp/
Australia hasn't got the technology to monitor the air quality.   If this is given to companies to monitor themselves then you know it will all be rogue and dishonest.
In the summer of 2017 and2018,  temperatures in the western suburbs increased 10-12 degrees higher than the rest of Sydney.Air quality decreases during times of hot temperatures because the heat and sunlight essentially cook the air along with all the chemical compounds lingering within it. This chemical soup combines with the nitrogen oxide emissions present in the air, creating a “smog” of ground-level ozone gas. This makes breathing difficult for those who already have respiratory or heart problems and can also make healthy people more susceptible to respiratory infections
There would also be increased Pollution from additional Cars and Trucks causing ground level Ozone
We already have the worst air quality in Sydney. There are already days where the EPA warns people living in Sydney and predominantly Western Sydney with respiratory problems to stay inside. The Incinerator.
On the 23/02/17 between 15:00 and 17:00 St Marys (which is the closest monitoring station to the Incinerator site) reported Ozone levels exceeding national air quality standards.
*Exposure to fine particle pollution has been linked to a variety of health problems
including increased respiratory symptoms (e.g. irritation of the airways, coughing or
difficulty breathing), heart problems and premature death in people with heart or lung disease." http:www.environment.nsw.gov.au/topics/air/air-pollution/particles-as-pollution
• “May cause people with heart disease to experience symptoms like chest pain, and
shortness of breath. Particle pollution can aggravate existing respiratory diseases
such as asthma and chronic bronchitis”.
http://www.environment.nsw.gov.au/topics/air/air-pollution/indicators-we-monitor
These are all from Government agencies websites confirming health concerns.
The Proposal fails to meet many Government Policies.
The Proposal fails to meet the basic principles of The NSW Energy from Waste Policy Statement because they will bemass burning,  disposal outcomes won't be avoided
,Air quality and human health won't be protected, higher value resource recovery outcomes won't be maximized, scope isn't provided for industry innovation, Community acceptance to operate a process hasn't and won't be obtained
• This application fails to meet all of the basic principles of the NSW Energy from
Waste Policy Statement
The Proposal fails to meet the basic principles of The
Renewable Energy (Electricity) Act 2000
The Proposal fails to meet the basic principles of The European Human Rights Convention
• Waste to Energy Incinerators presently contravene basic human rights as stated by the United Nations Commission on Human Rights
• The foetus, infant and child are most at risk from incinerator emissions: their rights
are therefore being ignored and violated, which is not in keeping with the concept of
a just society. Nor is the present policy of locating incinerators in deprived areas
where their health effects will be maximal
The Proposal fails to meet the basic principles of The Stockholm Convention on Persistent Organic Pollutants, amongst many more Government Policies it won't ever meet.
The EPA,  Planning Departments, Politicians, interested parties etc must understand a few things; we are alot more knowledgeable about all the negativities that come from incinerators. We are stronger, fearless, determined and undermined because we will fight this to the end because allowing such a toxic monstrosity is nothing but sheer and deliberate genocide!
I have faith that this will be rejected,like TNG's incinerator as the evidence is there to show that the same principles exist with this application indicating the same risks, health problems, environmental problems,  community disinterest thus never being able to get a social License amongst other reasons. I do hope we the people will be listened to as this all spells catastrophe.