Woodlawn Advanced Energy Recovery Centre

I object to Veolia's proposed incinerator at Tarago. I do not believe sufficient community consultation has occurred on the advantages/disadvantages of this system nor is there a clear need for it. I believe that the existing landfill facility has sufficient capacity to accommodate waste and that waste can be used more sustainably for power generation than burning it.

Nor have I seen sufficient data to explain how a facility that burns waste continually does not create harmful pollution which may spread across the region. Previous studies, such as that published in the 2022 Australian and New Zealand Journal of Public Health indicate that facilities such as this do create harmful pollution which could pollute the surrounding area.

Therefore, given the lack of consultation and dearth of evidence available to allay these concerns, I strongly object to the development of a waste incinerator.

I object to this project for the following reasons:

1. Potential serious impacts on human and animal health both in the immediate vicinity of the proposed site and areas downstream and those possibly affected by airborne particulate matter. – There is too little detail relating to the waste to be incinerated and too great a risk of dangerous substances being released and accumulating in the environment.

2. Potential effects on sustainable agricultural food and fibre production. – It is possible that if this proposal was to be allowed there could come a time in the future that restraints were placed on the production of food in the surrounding areas due to concerns about emissions or the accumulation of toxins (either real or perceived).

3. Potential devaluing of adjoining land due to the operations of the proposed facility and the real or perceived effects of emissions and waste transportation issues.

4. The unnecessary transportation of enormous quantities of waste from the point of generation to another community. – If the facility is as safe as it is claimed, there is no reason not to locate it in the area where the waste is produced and avoid the need for costly transportation and the accompanying damage to infrastructure (ie roads)

5. A completely inadequate EIS – The EIS in its present form makes sweeping assumptions that any emissions can be safely managed without providing detailed evidence of how this will occur. Further, the EIS appears to be based on “best case” assumptions and ignores the possibility of “worst case” scenarios. The EIS also does not address adequately the collection of base line data or ongoing monitoring.

6. The proposed use of “second rate” technologies. – Any serious proposal would include the very latest and best technologies for the scrubbing and capture of potentially dangerous substances.

7. The complete lack of indemnities for surrounding landholders. – If this proposal is as safe as it is suggested, the company should include indemnities for potentially affected landholders which would cover future potential health impacts (both human and animal), environmental impacts (including soil health, ecosystem health and water quality) and economic impacts to agricultural enterprises.

I am a resident of Lake George due east of the proposed incinerator. Our prevailing winds in summer come from the east and the pollution emitted will be deposited on us. This is a rural area we do not have town water, all of our drinking water is collected from our rooftops and stored in rainwater tanks. I have seen the analysis in the EIS which suggests there will be minimal impact on drinking water, however I note that they do not address PFAS in any significant ways other than noting it is likely to be present in waste burnt and is difficult to monitor. There is a lack of consideration of the cumulative impacts of contaminants building up in sediments accumulating in rainwater tanks.
I am making this submission to lodge my objection as an affected resident. The waste incinerator is unnecessary and unwanted. It is disappointing that Sydney's waste problems are being shifted to another area.

Objection Lodged on Behalf of Queanbeyan-Palerang Regional Council

Nassif Abi-Khattar
252 The Lookdown Road, Bungonia, NSW, 2580
Epsom Park
Phone: 02-96355180
Mobile: 0431 237 423
[email protected]
Saturday 3rd of December 2022

Please see attached, objection, No to the waste incinerator, regards, Nassif Abi-Khattar

Please find my objection.


--
Anne Wiggan
"MIZPAH" 33 King St .Bungonia 2580
(02) 4844 4228 0408 666 196
https://www.facebook.com/Bungonia-Heritage-and-Conservation-576073996193548/

Hello,

Please find attached my objection to the Tarago Waste Incinerator at Tarago (Woodlawn ARC: SSD-21184278)

I have not made any political donations in the last two years.

I acknowledge and accept the Department's disclaimer and declaration.

Andrew Martin
433 Marked Tree Road
Gundaroo NSW 2620

21 November 2022

Department of Planning and Environment,
Locked Bag 5022,
Parramatta NSW 2124

Dear Sir/madam,

Woodlawn Advanced Energy Recovery Centre
Application Number: SSD-21184278
Assessment Type: State Significant Development
Development Type: Electricity Generation - Other
Local Government Area: Goulburn Mulwaree

I refer to the proposal above and as such submit my formal response to same.

I have raised matters of concern surrounding waste incineration for my community many times.

It is clear to me that the vast majority of the people in my electorate do not support the proposal of waste incineration.

The small village of Tarago is situated approximately 40 kilometres south of Goulburn with a population of approximately 510. The Veolia eco-precinct is located outside of the village of Tarago.

The system which Veolia operates on currently receives the municipal solid waste of Sydney sent to two transfer terminals; where it is sorted and loaded for transport by rail to Crisps Creek; and then by truck to the Woodlawn site – which it is presently used as landfill.

The ‘ARC’, a $600m waste-to-energy project, proposes an additional step once this waste is delivered to Tarago. Burning 380,000 tonnes of rubbish to generate steam and electricity to the tune of 39MW the equivalent of power to 50,000 homes annually.

Trains and trucks of rubbish are being hauled through the city, past our national parks, through prime agricultural lands and taken to Tarago.

It appears the electorate of Goulburn is an attractive dumping ground for Sydney’s waste due to its close proximity.

The inference that this is a waste to energy project appears somewhat misleading, why are we using resources to transport the waste, to an area to incinerate and then generate power, which then must again be returned to the city? That’s because this isn’t about energy production, it is waste incineration.

Of particular concern to me is the risk to human health.
From the website of the proponent: The energy-from-waste process is well regulated and proven to be safe.
I refer to the expert advice from the NSW Chief Scientist and Engineer, Mr Hugh Durrant White, whereby he advises.
Exposure to particulate matter (PM) can be linked to increased mortality, hospitalisations and respiratory disease. A large body of scientific evidence supports this. AAQ monitoring of airshed quality in NSW and internationally measures both PM10 and PM2.5. AAQ data are used in large scale population health studies to understand better the health impacts of particulates overall as well as specific health impacts associated with coarse and fine particles. Understanding health impacts of UFP is a major area of research internationally. However, there is incomplete information about the development, size distribution and composition of UFP, and challenges remain in our ability to accurately and separately monitor these particles.
And this.
Currently, there is no means of assessing the impact that a single source of emissions (e.g. a specific plant) will have on an individual. (Ref.1)

During a recent community meeting representatives of the proponent advised that there have been no soil studies undertaken of surrounding prime agricultural land.
The Chief Scientist advises that The Human Health Risk Assessment (HHRA) should consider food as an exposure pathway.
We know that one of the main contaminates of concern are Dioxins. Dioxins are found throughout the world, they accumulate in the food chain, mainly in the fatty tissue of animals. Mercury is also a toxic heavy metal and incineration has been known to produce high levels of this pollutant.
Across NSW regional plans have been adopted to provide a blueprint for growth until 2036, recognising the need for the state's best agricultural land to be preserved. The NSW Government has guidelines in place to ensure the potential impact of projects on prime agricultural land is properly assessed during the planning approvals process, protecting our food bowl.
Biophysical Strategic Agricultural Land (BSAL) is land with high quality soil and water resources capable of sustaining high levels of productivity. BSAL plays a critical role sustaining the State’s $12 billion agricultural industry.
A total of 2.8 million hectares of BSAL has been identified and mapped at a regional scale across the State.
Tarago has a mapped area of BSAL. (Ref.2)
When conducting A Human Health Risk Assessment, it is imperative to address environmental hazards of concern and evaluating how likely it is that the environment might be impacted as a result of exposure to one or more environmental stressors, such as chemicals, in this case persistent organic pollution (POP).
A recent study by ToxcioWatch of incinerators in three countries – Spain, Czechia, and Lithuania, identified high levels of persistent organic pollution (POP) contamination in the surrounding areas of waste incineration facilities, it also found that contamination levels posed a ‘significant risk to the environment and to the health of people nearby’.
Analysis of vegetation, pine needles, and mosses also shows high levels of dioxins, the report states, adding that ‘people living in the vicinity of incinerators could be harmed’ if they eat vegetables grown in contaminated soil. (Ref.3)
In NSW, Government policy provides a framework by which a project that proposes to recover energy from the thermal treatment of waste (energy recovery facility) only occurs where it delivers positive outcomes for human health and the environment.
Proponents who seek to operate energy recovery facilities must comply with the 2015 NSW Energy from Waste Policy Statement, to protect the community and ensure best use is made of waste materials.
I am unconvinced that enough studies have been undertaken to prove there are no risks associated with EFW projects to human life and agriculture and as such I am opposing the Woodlawn Advanced Energy Recovery Centre proposal alongside my community.
Yours sincerely,

Wendy Tuckerman MP,
Member for Goulburn
Minister for Local Government











Ref.1 https://www.chiefscientist.nsw.gov.au/__data/assets/pdf_file/0019/357400/FINAL-Report_EFW-with-additional-advice.pdf
Ref.2 strategic_agricultural_land_map_-_sheet_sta_035.pdf
Ref.3 https://resource.co/article/zwe-finds-surroundings-waste-incinerators-are-highly-contaminated

Letter received by post

I strongly object to Veolia’s proposed incinerator being built in Tarago. My concerns include:
-Detrimental impacts to air and water quality in the surrounding population centres e.g. Canberra, Goulburn, Braidwood, Bungendore, and particularly Tarago. These areas are all experiencing extraordinary growth, with many people moving here seeking a cleaner environment. If toxicity isn't an issue, why transport waste 100s km, it is more efficient to retain Sydney's waste in Sydney for processing.
-The pollution from these types of incinerators have led to heart and lung disease. It is also likely that pollutants such as dioxins will accumulate in the environment over time and impact on our soil and water, impacting crops and animals. Numerous studies have suggested these types of operations are not safe and result in food contamination and health risks to residents. Is the NSW Government ready to endanger the health of residents and impact on both productive land and the natural environment (which is already in dire straits due to climate change and poor management).
-It is likely that the proposed incinerator will contribute to climate change by emitting 140,000 tonnes of CO2/year. To approve the project is inconsistent with the NSW government commitment to Net 0 emissions by 2030.
-Roads in this area are becoming increasingly dangerous. Trucks and vehicles as associated with Veolia's current operations are already damaging our roads at their current present. The trucks in particular can drive quite dangerously, often needing to encroach on the wrong side of the road (usually due to excessive speed and the narrowness of the roads). An increase in activity at Veolia will only worsen the situation.
-There has been very limited community consultation from Veolia. I have received considerable information from those objecting to the proposal (volunteers with little financial support), while absolutely nothing from Veolia. I live approximately 10kms from the proposed incinerator, some engagement would have been welcomed.
-Employment is strong in the area, businesses are already struggling to find and retain staff. This proposal will add to these difficulties. Housing is also an issue in the area - how will accommodation be provided to new workers?
Thanks for considering my objection.

On behalf of Neighbours of Winfarthing Inc. I am objecting to this development for the following reasons.
1. As Public Interest is a legitimate factor when deciding a SSD application, it is obvious that there are many individuals, community organisations, religious leaders and the Goulburn Mulwaree Council are opposed to this development. This indicates that it isn't in the Public Interest.
2. The proponents claim the development will meet guidelines and will be safe. Those opposing the development claim it will not be safe. Both cannot be right. So, who do we believe?
The proponents who stand to make a huge amount of money or the locals who want to protect their health, environment and lifestyle?
If we take the opponents path nothing can go wrong. If the proposal goes ahead it will only be a matter of time until something goes wrong and the locals health, environment and lifestyle will be compromised.
3. Veolia has repeatedly shown they cannot manage their current facility without getting it wrong (odour and contaminants) and being penalised.
How then can we trust them to manage this highly technical operation without something going wrong which would negatively affect the locals?
4. If the development is safe as claimed, why isn't it situated in Sydney which is the source of the waste? Is it because there will only be thousands of people who will be affected as opposed to millions if in Sydney?
Does this make us second class citizens compared to those in Sydney? Or is it because we have a small voice politically?
5. The Goulburn Mulwaree LGA should not become the Industrial Suburb of Sydney and gain a negative reputation. We already have, in the Southern Tablelands actual and proposed wind farms, solar farms, quarries, waste dumps, all for the benefit of Sydney. We have a clean, healthy and vast areas of pristine environment which attracts a large number of people to work and live here. This reputation will be trashed by this development.
6. Living some 40 km north east of the proposed development, our prevailing winds are from the south west for much of the year. This puts us directly in line for any toxic pollutants expelled from the development, contaminating our tank drinking water, gardens, environment and animals. That possibility shouldn't be allowed to occur.
7. If Veolia with all it's resources is unable in some 18 months to produce their EIS without the 50 plus gaps, errors and inconsistencies as noted in the Goulburn Mulwaree Council submission, they have shown they are not fit to run a facility like this. If they can't get this right what hope have they got to be able to get this development right?
8. The likelihood of something going wrong should be sufficient to stop this development from being approved.

Woodlawn Advanced Energy Recovery Centre SUB-51904479 - Woodlawn ARC: SSD-21184278

The proposal by the French company Veolia to operate a waste incinerator at Tarago NSW endangers Australians, as did the earlier French nuclear bomb tests in the Pacific Ocean. Scientific research demonstrates health-damaging residual waste and pollution are inherently generated from waste incineration facilities such as that proposed by Veolia for Tarago. Similar proposals by the same French company have been dismissed recently by the ACT and NSW Governments after thorough investigation.

Not only would Veolia's proposed waste incinerator at Tarago be negative because of its impact on the health of people in the Tarago district, it would also not be an effective nor efficient means of energy production as claimed be Veolia. That company has great 'greenwashing' credentials, as the residents of the Tarago district have witnessed over the years with Veolia's dumping of Sydney's waste in the Woodlawn open-cut mine site. 'Energy from waste' is more greenwashing propaganda by Veolia in promoting waste incineration. Even the proposed facility's title, 'Advanced Energy Recovery Centre' is garbage.
I doubt the NSW Government, and its responsible top bureaucrats, will survive should they agree to Veolia's 'evil' waste incinerator at Tarago.

See attachment

I live in Goulburn NSW & I have been doing some research on waste to energy incinerators. What I have found doing a small search is Very Alarming. There's a growing backlash over incinerating garbage in Europe.
1) The big paradox 
Across Europe, Waste to Energy incineration is promoted, by some, as an alternative to landfilling for the treatment of waste. According to Eurostat, in the 10 years running up to 2016, the amount of waste incinerated increased by 30% [1]. The data also reveals that in the last 10 years CO2 emissions from incinerators have doubled. In 2017, over 40Mt of fossil CO2 was released by WTE incinerators in the EU 28 countries [2].
The CO2 emitted per tonne of waste incinerated depends on the composition of the waste. Eurostat statistics show that the majority of the increase in waste incinerated comes from so-called residual municipal solid waste (MSW) which produces significant amounts of CO2. 
Each tonne of MSW incinerated typically releases between 0.7 and 1.7 tonnes of CO2 [3]. This includes emissions of both fossil CO2 (e.g. from burning plastics) and biogenic CO2 (e.g. from burning wood, paper and food). Although biogenic CO2 is directly released into the atmosphere making a significant contribution to climate change, only the CO2 emissions from fossil sources will be considered for the purposes of a global analysis – an important loophole in GHG emissions accountability. 
On top of this, evidence indicates that more than half of what is currently being incinerated could have been recycled or composted [4], suggesting that much of Europe’s WTE incineration capacity is being used to burn valuable resources that could have had a better environmental outcome. WTE incineration is proving to be a barrier to improving recycling rates and it creates a need to replace these resources at a high environmental cost, and that cost is not included in the Eurostat figures.
2)Shouldn’t we just stop incinerating waste?
The carbon intensity of European incinerators is a significant (540gr CO2/kWh)[4], around twice the concentration of CO2 emissions derived from the average EU electricity grid (296gr CO2/kWh) [5] and significantly greater than the energy produced through conventional fossil fuel sources such as gas. 
Since these infrastructures are meant to last for about 20-30 years, continued use of incineration is simply delaying a much needed, and urgent, transition to less carbon-intensive power generation infrastructures such as wind and solar renewable energy whilst also undermining the move to lower-carbon options for waste management, including the re-design of products to increase recyclability and longevity.
It would be environmentally irresponsible to continue to promote Waste to Energy infrastructures that are already largely outperformed by the EU average and even worse, by conventional fossil fuel energy generation such as gas. For countries across the world to best meet their obligations under the Paris Agreement, it’s clear that decarbonisation must happen across all sectors. Specifically, that means that they should call for a phase out of incineration practices, to be replaced with genuinely climate-positive waste management ones, and for those countries not yet hooked on waste incineration,
3) The youngest of Dutch incinerators: Reststoffen Energie Centrale

Out of the 13 waste incinerators currently in operation in the Netherlands, the Reststoffen Energie
Centrale (REC) is the most recent one. The so-called waste–to-energy plant is located in Harlingen,
bordering the UNESCO Wadden Sea coastline in the North of the Netherlands. When it was built in
2011, it was proudly announced by the Dutch Ministry of Economic Affairs as ‘a state of the art’
installation, the best in Western Europe. However, long-term testing revealed the plant emits dioxin,
furans and toxic pollutants far beyond the limits set by EU laws.
Initially, in order to deliver energy to the nearby salt industry plant, the REC incinerator was only
supposed to burn Frisian household waste. However, nowadays the waste input comes from
everywhere in the Netherlands. Besides household waste, the REC waste input includes also
industrial waste, digestate1 and sewage sludge. Chemical analyses to check the waste input were
first undertaken at the start in 2011. It is debatable whether this installation with a post combustion
temperature of 8500 Celsius is actually capable of combusting the chemical complexity of current
‘household’ and industrial waste.
4)Environmental biomarkers and toxic eggs
In 2013, a study by ToxicoWatch found high concentration of dioxins and furans2 in eggs of backyard
chickens in the surroundings of the REC incinerator3 4. Eggs of backyard chickens are sensitive
environmental biomarkers for persistent organic pollutants (POPs) like dioxins5. 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 EU6. Notably, the concentration exceeded 1.7
BEQ/gram fat (Bioanalytical EQuivalent)7, and the 2.5 picogram TEQ/gram fat8 limit set by EU law.
1 Digestate is the material remaining after the anaerobic digestion of a biodegradable feedstock. 2 Polychlorinated dibenzo-p-dioxins and dibenzofurans, PCDD/Fs. 3Arkenbout, A, 2014. Biomonitoring of dioxins/dl-PCBs in the north of the Netherlands; eggs of backyard chickens, cow and goat
milk and soil as indicators of pollution. Organohalogen Compd. 76, 1407–1410 4 Arkenbout, A, Esbensen KH, 2017. Biomonitoring and source tracking of dioxins in the Netherlands, Eighth World Conference On
Sampling and Blending / Perth, Wa, 9–11 May 2017, 117-124 5 Witteveen en Bos, Dioxine emissie oktober 2015 – Verspreidingsberekeningen, 2015, rapport LW217-12/16-002.590 6 See n=6, Figure 1 black spot
7 The values are expressed in Figure 1 in BEQ because analyses are performed with the bioassay of DR CALUX. 8 TEQ stands for Toxic EQuivalent, picogram is a millionth of a millionth of a gram or 10-12 gram
5) Hidden emissions
One of the reason why the REC incinerator exceeds the dioxins permit levels is the use of bypasses
during transient phases, which means that the incinerator emits without filtering (Figure 4). In the
technical literature this is known as a ‘filter bypass mode’, ‘abatement bypass’ or ‘dump stacks’. The
bypass mode is structurally programmed whenever elevated dust emissions occur. Although the
plant management had recently promised to stop using bypasses, data don’t confirm this has
actually happened.
these are just some serious problems, please read the attached studies

I write to strongly object to Veolia’s proposed incinerator being built in Tarago, as outlined in my attachment.
In summary:
-- Burning waste produces biproducts which are incredibly dangerous for long term health and environmental impacts. There is much evidence to support this position, indeed, there is insufficient evidence to conclude any incinerator is safe.
-- The cost benefit return of burning such waste produces a negligible amount of electricity compared to the energy input for burning. Indeed, the equivalent burn by a conventional power station produces far more electricity.
-- Material amounts of carbon are released as part of the process which are not effectively captured through the burn.
-- The goal of burning waste is to effectively remove it. Other methods exist to do so, without the same environmental or health impacts.
-- Veolia has a record of poor management at Woodlawn
In closing, if an incinerator is not permitted in Sydney, why should the same be allowed to be built at Tarago?