Woodlawn Advanced Energy Recovery Centre

I have a number of concerns relating to this project in summary they are:
1. Inadequate or flawed modelling.
2. Transport of waste via road and its impacts.
3. Potential for toxins to enter the surrounding environment.
4. Lack of information regarding contingency plans and future site remediation.
5. That waste to energy is not a renewable source of energy generation.
6. Waste of a resource that could be valuable in the future.
7. It’s inconsistent with the National Waste Policy and the principles of ecologically sustainable development.

I have attached a detailed response.

I live in the Canberra region as well as owning property in southern NSW. I wish to express my objection to the building in Tarago of Veolia’s proposed incinerator.
I believe that Veolia’s toxic industrial waste incinerator will pose risks to the health and well-being of people and animals in regional NSW as well as Canberra. It will affect economic livelihoods as well as human and animal health and environmental systems.

Other reasons for my objection are:

• It contradicts NSW Government’s circular economy policies which should be encouraging reduction of waste rather than simply burning it;
• The accumulation of toxic waste products in the environment adds to the burden on our children and grandchildren of climate change impacts, pollution, poor development and unsustainable agricultural practices;
• Public health experts, in peer-reviewed studies and from the NSW Government’s own agencies, warn that waste incineration poses significant risks surrounding populations;
• Methane from landfill can be used to generate power which is a more sustainable and lower emission form of waste disposal;
• After climate-induced disasters like the 2019-20 Black Summer bushfires, which traumatised many people in our region, the last thing we need is a new source of CO2, air pollution and toxic ash;
• The track record of the company concerned does not inspire confidence that it will respect the rights and look after the interests of the local community in which it operates. As a for-profit company, they are by definition motivated by profit and not concern for the long-term interests of people, land and livelihoods.
• It is the role of Government to protect the long-term interests of the community and this should be the overriding consideration in deciding this issue.

Please find attached my objection to this proposal.

See attached.

I object to the project and provide the attached PDF incorporating my reasons.

I object to this proposal, because
- harmful and toxic gases released to the atmosphere impact the health of thousands of residents in Canberra, Queanbeyan and numerous other towns and villages.
- the existing Woodlawn facility has a remaining useful span in excess of 25 years
- incineration releases several 100,000 tonnes of greenhouse gases into the atmosphere, which contradicts the NSW Governments commitment to net 0 by 2030.

To Whom It May Concern,

RE: WOODLAWN ADVANCED ENERGY RECOVERY CENTRE – SSD-21184278

I am writing today as a natural person. I reside in the Goulburn Mulwaree Council region and today I fight strongly to object to Veolia’s proposed incinerator being built in Tarago.

I strongly believe that Veolia’s HIGHLY toxic industrial waste incinerator will cause absolute devastation to our region. This proposed development will poison our environment, cause havoc on our agriculture industry, this will cause significant negative impact on our property values, not to mention the damage this will cause to COMMUNITY HEALTH. Whilst it may not be an immediate risk BUT there are risks to me, to my family, to my future children, the future generations to come. Looks at the likes of Asbestos and look at the devastation it has caused. YOU CAN CHOOSE TO STOP THIS DEVELOPMENT!

There are so many reasons for my objection. I have listed them below:

Health and Environment

• The proposed Veolia’s incinerator will emit toxic air pollution 24 hours a day, 365 days a year for 25 years. This which will spread throughout regions of Canberra to Goulburn, Braidwood, Bungendore, Murrumbateman, Gunning, Marulan, Yass and more.

• Pollution from the proposed incinerator will includes acid gases, toxic heavy metal particulates (mercury, lead cadmium) and persistent organic particulates (dioxins, furans, PCBs, PFAS). Particulate pollution can lead to decreased lung function, cardiac disease and death. In addition to polluting the air, dioxins and furans will accumulate in the surrounding environment over time in soil and water and are absorbed by plants, crops and animals. This incinerator will impact the health of our future generations through the accumulation of forever chemicals in the surround environment. It is an intergenerational burden and legacy which cannot go ahead!

• Food contaminated by incinerator toxins can cause cancer, miscarriage, infant deaths, developmental delays, reproductive issues, heart disease and respiratory impairment. This is a GRAVE concern to me as we are planning on having a family.

• The NSW Government acknowledges in its own Energy from Waste Infrastructure Plan that waste incinerators impact human health stating “Populations can still experience health impacts when emissions are below the national standards, and for some common air pollutants, there is no safe threshold of impact”.
• Academics from the Australian National University Medical School, the Public Health Association of Australia, and Council of Academic Public Health Institutions Australia in 2019 completed a systematic review of the health impacts of waste incineration, which was published in the Australian and New Zealand Journal of Public Health and referenced by the NSW Government Chief Scientist and Engineer in his report to the NSW Minister for Environment that same year. This report concluded that “there is insufficient evidence to conclude that any incinerator is safe” and in particular “contamination of food and ingestion of pollutants is a significant risk pathway for both nearby and distant residents”.

 
• The proposed incinerator will exceed NSW government safety standards for air emissions during start-up, shut-down and many other ‘non-standard’ operating conditions. Veolia’s overseas incinerators often exceed safety standards and Veolia has a track record locally for failing to comply with license conditions at their existing Woodlawn facility.

• The proposal will create 2.2million tonnes of toxic waste ash, including 380,000 tonnes of air pollution control residue (fly ash) which is classified as hazardous waste by the Environmental Protection Authority (EPA). All of this will be dumped on site, risking further contamination of soil and groundwater as well as the Sydney water catchment. Veolia’s track record of polluting local groundwaters (recognised by EPA prevention notice in October 2022) proves they cannot
be trusted to safely manage such toxic outputs.

Climate Change

I do not agree that this waste incineration can be classified as renewable energy generation, nor that it will reduce greenhouse emissions or reliance on fossil fuels. Unlike wind and solar generated power, waste doesn’t come from infinite natural processes. It is sourced from finite resources – minerals, fossil fuels and forests that are cut down at an unsustainable rate. Plastic is a petroleum by-product. Burning it is the same as burning fossil fuel and produces similar emissions.

Veolia’s proposed incinerator will contribute to climate change by emitting 140,000 tonnes of greenhouse gases (CO2) each year. To approve the project is inconsistent with the NSW government commitment to Net 0 emissions by 2030.

Incinerator Proposal - Sydney

In July 2018, the Eastern Creek waste incinerator in Sydney was rejected by the NSW Independent Planning Commission as not being in the public interest. The reasons included concerns about safety, insufficient evidence that the pollution control technologies would be capable of managing emissions, concern about the relationship between air quality impacts and water quality impacts, the possibility of adverse environmental outcomes and concern about site suitability and human health impacts. Since then, the NSW Government has banned toxic waste incinerators in Sydney due to the risk to human health. The risks have not changed since that decision back in 2018 – this project in Tarago must also be rejected. Human lives in Australia are equals. If the project is safe, why was the incinerator proposal in Sydney rejected?

No social license

The NSW Energy from Waste Policy states that incinerator proposals are only valid where “community acceptance to operate such a process has been obtained”. Our community DOES NOT accept for a facility of this and any other nature in Tarago or anywhere in Southern Tablelands AND Australia!

Veolia has proven over the last 15 years and time again that they do not play by the rules, they are failing to operate their existing facility within license conditions, have received multiple infringements, failed to inform the community of pollution to the environment, and attempted to withhold information from the community under freedom of information processes.
 
The town has suffered impacts from the Woodlawn site for almost 45 years. The first 20 years from zinc, lead and copper mining undertaken on site, and the last 15 years from Veolia breaching its license conditions through impacting the surrounding region with unbearable odour impacts. The local town is also living with significant lead contamination in and surrounding the rail corridor, including local residences, which has directly impacted the long-term health of the community and young residents, due to long standing impacts from the previous Woodlawn mine.

With Veolia’s track record proving time and time again they break the rules, hide information from the community and pollute the environment. We as a community CANNOT place our health, our future generation’s health in their hands.

I want to ask the assessing team this – put yourself in our situation. Would you, your family ie children, grandchildren want to be breathing something that is deemed too dangerous for the residents of Sydney? Breathing the toxic fumes day in day out, 24 hours a day, 365 days a year for 25 years? Given Tarago and its surround towns and Local Government Areas are surrounded by prime agricultural land, would you want to consume food grown in the these region, what about drinking the wine produced in the region or go swimming where these chemicals can be released in your bodies?

In summary Veolia doesn’t care about our community and it’s all about profiteering! The incinerator will cause catastrophic issues for us and our future generations. What will life be like for our future generations to come? Will there be a world for them to live in?

I stand with my family, my friends, my community in strongly OBJECTING this proposed incinerator development.

We don't want an incinerator spewing god knows what into our area.
They ship Sydney's garbage out of their region to a site they've never even heard of that boasts about generating electricity all the while I have to cart our garbage to a local refuse center once a month because we don't have a curbside service and pay our electricity bill while suffering the impacts of the current bio reactor.
How can you trust the Veolia telling you this thing will be fine when they cant even contain their current projects negative impacts?
In the EIS, Veolia claims the conditions will be no worse than what they currently are, at minimum we smell odor once a week, some times we have periods where we smell odors multiple times a day for multiple days at a time, waking us up at night, causing nausea and headaches, if that is anything to go by, it is not good enough!
The EIS states Veolia door knocked all local residents in May 2022, I work from home full time, this is unequivocally false.
If they lie about speaking to residents what else are they lying about?
Veolia does no service to our town other than pollute our air and this is before you consider the proposed incinerator.
We collect rainwater for drinking in this community. Who is responsible when the pollutants settle on our rooftops, in our gutters and rainwater tanks?
Who is responsible when our livestock, ecosystem, soil and crops are impacted by the pollutants?
Countries all over the world including areas of Europe have banned this type of project, what makes this an acceptable project here?
Why should we have to suffer it out here in our town where we make a conscious effort to produce less waste and take actions to produce our own power via renewable options?
I wholeheartedly disagree with this project, Sydney siders don't want one in their region, we don't want one in ours.
If Veolia want to build an incinerator they can go back to France and build it there.

I am a Canberra resident concerned that a waste incineration plant is proposed to deal with municipal waste when this technology is outdated and dangerous.

I am worried for my family and the elderly who like me fear that the fine particulates ash plume that this proposal would generate will damage our health and the health of our children for years to come. Canberra residents are likely to be in the fallout of the toxic plume. Some fallout will enter our drinking water catchments and spoil our clean air.

I do not trust Veolia to operate the facility safely when they have a history of poor environmental compliance.

I strongly object to this proposal that uses faulty technology which only increases carbon emission damage to the atmosphere. This proposal uses technology that has been banned overseas and the NSW Department of Planning and Environment should reject the technology and refuse this proposal. This facility would bring unacceptable risk to the environment, the community and to the NSW Government itself.

Objection to WtE Tarago

I strongly object to Veolia’s proposed incinerator being built in Tarago NSW.
My family owns, lives, and manages a farm at Lake Bathurst, which is approximately 10km from the proposed incinerator site at Woodlawn. We have a mixed farming operation, running sheep, cattle, broadacre crops for grain and forage and a hay business, supplying locally and into the Southern Highlands. There are currently 3 full time employees and several casual employees throughout the year. Both sides of my family (husbands & mine) have been farming since early settlement of Australia and we are extremely proud to be in the Agricultural industry. Our families have worked extremely hard over many years to allow us to both be able to farm today and the thought that there is a possibility that this is being taken away due to an incinerator being built in our local community is terrifying.
There are several reasons why I object to the incinerator proposal:
1. I believe if it is not safe for Sydney residents then how is it safe for us? The NSW government acknowledges in its own Energy from Waste Infrastructure Plan that waste incinerators impact human health stating “Populations can still experience health impacts when emissions are below the national standards, and for some common air pollutants, there is no safe threshold”. I don’t understand why our lives and health are not considered as important as those in Sydney.
2. We have recently had our first daughter and I am extremely concerned about the side effects the pollution from the incinerator will have on her ability to have a family in the future. The toxins that are produced will drop on our farm, our roof and my children will be eating, drinking and playing in potentially contaminated food, water & soil.
3. The proposal will create 2.2 million tonnes of toxic waste ash, including 380,000 tonnes of air pollution control residue (fly ash). This is classified as hazardous waste by the EPA and Veolia are proposing to dump it on site. This will risk further contamination of water and soil (of which the water is in the Sydney catchment). We do not trust Veolia as they have a terrible track record which has been recognized by a recent prevention notice in October 2022 by the EPA. How can we trust them to manage this proposal safely?
4. This entire process from learning about the proposal to finally having the EIS to read, digest and then object has been extremely tough on my mental health along with my families. The last 6 weeks have taken my priorities away from my daughter and my work so that I can focus on spreading awareness of this proposal. I can’t imagine what will happen if it were to go ahead. The further stress and pressure that it would put on my family would be immense.
5. After reading the EIS the language used has not been convincing or direct. The words such as “expected” & “may” do not fill me with hope that it is safe for us. Imagine if we were told to run into someone firing bullets and that we don’t “expect” you to get hit and killed.
6. We have been told that our produce is safe and there will be no effect on it, well what happens when the meat standards tighten? And what is considered safe today is no longer? Our businesses and livelihoods will be destroyed.

Again, I reiterate my first dot point. If the NSW Government acknowledges that building an incinerator in Sydney is not safe for its residents then how the hell is it safe for my husband, my daughter and me.

I object to Veolia's proposal. Please see attached document.

As a local resident of Tarago, I object to the proposal for the Woodlawn Advanced Energy Recovery Centre (the proposal). Whilst I understand that the facility could bring economic and social benefits to the area through improvements to local infrastructure, I am not confident in Veolia’s ability to manage environmental and community impacts based on current performance.

The current waste facility has had numerous issues in relation to odour management and I feel like I am constantly making complaints. I am not convinced the new facility will be managed any better and it is frustrating that the facility will be predominantly benefitting Sydney (i.e. it is mostly Sydney’s waste) with Sydney receiving no repercussions of the impacts.


Many residents of the local area choose to live here due to the slower and more sustainable lifestyle, we are removed from the hustle and bustle of the city and are more conscious of waste. Most of us don’t have curb side collection and as a result try to minimise waste to landfill and reuse as much as possible. This is why it is so upsetting that a facility such as this could be approved as it goes against everything regional and remote towns are about. Sydney’s single use lifestyle is ending up in our backyard and we are paying the price.

I understand that the Goulburn/Mulwaree area has been identified as one of four priority areas in the EfW. Have the other three locations been explored to the same degree as this one? S3.1.4 of the EIS states that a buffer of 4km to the nearest residence is an advantage of this site, however Veolia cannot manage impacts currently within 10km (where I live) so not sure how that is an advantage. I suggest there may be other areas, closer to Sydney more suitable.

The specific issues I have are as follows:

1. Section 3.2 states “The Goulburn Mulwaree Local Strategic Planning Statement (Planning Statement) provides a 20-year vision for the future growth within the Goulburn Mulwaree LGA.” The proposal is taking waste predominantly from Sydney, it is not benefiting the local area nor contributing to waste management and efficiency within the Goulburn Mulwaree LGA, as a result, stating alignment with the planning statement is a stretch. The proposal is not about improving regional areas, it’s purely to solve a problem identified in Sydney and making sure the solution is far from there.

2. Section 3.2 Priority 5 – Primary Industry states “This project does not compromise the use of any agricultural land” However the contamination risk is based on a model only and whilst the impacts are stated to be negligible, the implications are largely unknown in an Australian context. There is also a perceived impact of contamination, the EIS does not talk to this in terms of impacts to agricultural land. Will Veolia foot the bill for perceived impacts and subsequent loss of revenue and reduced property prices?

3. Section 3.3 Outlines the criteria that the EfW infrastructure plan selects sites against and states it complies with them. Specifically, “compatible with environmental and climatic factors (air quality)” and “support secure and sustainable energy in locations that need it”. The current facility at Woodlawn has many demonstrated non compliances with odour levels as per their EPL, emissions from the proposal are said to be the same and no worse, therefore the proposal is not compatible with odour levels. As per the latter criteria, the requirement for sustainable energy has not been triggered by Gouldburn Mulwaree, the requirement has come from Sydney’s increased waste. If Sydney did not exist, the proposal would not be required so it is inappropriate to try and make this connection and state that the local area “needs’ the proposal.

4. Table 6.3 states “The proposed Woodlawn ARC will comply with the operating conditions set by the EPA in the environment protection license” This statement is false as the current Woodlawn facility does not currently comply to odour levels, so how will it suddenly comply?

5. Section 2.5.2 it states that the issues raised by neighbours in 2021 include current odour management and air quality yet in 2022 “eighbours” are still having these same issues in areas outside the mapped “impact” areas.

6. Section 8.1 talks about the adoption of an odour goal of 6ou in the 99th percentile due to the number of sensitive receivers in the immediate vicinity of the proposal. This number corresponds to a population of approximately 10 in the vicinity. As a resident located at least 10km from the site, who regularly experiences an odour, then sure we should be considered an affected receiver. It is unclear what is considered “immediate”? and it appears it is dependent on the outcome. Given this there would be more than 10 receivers affected and therefore the odour unit response has been incorrectly applied in this situation. It is recommended that a more stringent ou is adopted to accurately predict odour for the residents already experiencing odour. Table 8.4 used in the human health assessment notes 181 nearby receptors which would be closer to 3-2 ou, not 6ou. No operational mitigation measures have been identified and included to manage air quality and odour, what mitigation measures will be in place to manage air quality and what can the community expect when there are non-compliances.

Dear Madam/Sir
My name is Ned Dale and I am writing to oppose the proposed waste incinerator at Tarago.
I live in Canberra (Campbell) in the Australian Capital Territory.
I oppose the incinerator because it will spread toxic air pollution impacting the town of Tarago, and surrounding towns and Canberra, where I live.
I am also very concerned about the impact of the incinerator on the National Parks around Tarago including near Bungonia, home to much vulnerable flora and fauna as well as many popular bushwalking tracks. My grandmother fought to save Bungonia from mining in the 1970s. It would be very sad to see our natural heritage degrade as a result of an unnecessary incinerator.
Yours sincerely
Ned Dale