Woodlawn Advanced Energy Recovery Centre

I object to the proposed incinerator for the following reasons:
- the incinerator will release toxic gasses that pose a major health hazard to residents in a large surrounding area.
- the incinerator will add to greenhouse gasses and exacerbate global warming. Burning waste is not recycling; if waste is produced then burying it and capturing the methane emissions (as Veolia is currently doing) is a much better option.
- the focus of any project dealing with waste should be on reducing the waste coming out of Sydney instead of burning it.
- if the incinerator is not safe to build in Sydney, then it is not safe to build near the residents of Tarago and surrounding areas.
- the project does not have support from the broad community surrounding the proposed site. Veolia's track record in operating its current projects in the location shows that it does not have a social licence to build the incinerator.
The proposed incinerator should not be approved.

I strongly object to the proposed incinerator in the Canberra - Goulburn area by Veolia. I live in this area, and run a food producing primary producer business.
(1) The threat: airborne pollutants will be spread by wind widely in the Canberra - Goulburn area, including to those two cities! Meteorological data mapping proves this. Pollutants include PFASS, same as polluted groundwater around Australian airports!
(2) The threat: pollutants will be spread in groundwater.
(3) The threat: Veolia has already been found guilty of failures in pollutant management, resulting in leakage outside of their existing facility in the area.
(4) The threat: Veolia, a French company, is no longer legally permitted to build this type of proposed incinerator in Europe due to major safety risks. Why would Australia allow this in 2022?
(5) Threat to public safety: airborne pollutants will enter the rainwater (the main human drinking water source for residents in this area outside of towns) and groundwater (the main drinking water source for the towns). Any home grown food (backyard vege garden, eggs from Chooks, sheep, cattle, etc) will also absorb the contaminants. The longer humans drink and eat this contaminated food and water, the more toxins will be built up (bio magnification) in people living in the area.
(6) threat to public safety: breathing in the pollutants.
(7) threat to food production: any food (grains, meat, milk, fruit, vegetables, wine, honey, mead etc) grown in the area will be contaminated. Contamination levels will increase over time.

So, the NSW Government and Veolia want to poison the people living in the Canberra - Goulburn area, and poison the food grown in this area as well. How can this be happening? Why was this not stopped already?

Hi my name is Ben Howarth and I live in the Tarago Village. I have lived here for 42 Years and I strongly object to Veolia’s Proposed Incinerator to be built near Tarago at the Woodlawn precinct.
We have had so many smelly days from the Bio reactor that it is not funny. We were promised that it would not smell and that it would be controlled. I fell that there have been far too many days of smelling from the bioreactor which is a breach of Veolia’s Contract. If they are going to build an Industrial Waste Incinerator what’s to say that this isn’t going to do the same and cover Tarago and surrounding area with toxic contaminants that are not good for the environment but also contaminate our water sources. As Tarago does not have town water and rely on our roof’s for collecting our only source of water, you can’t tell me that an incinerator isn’t going to cover our roof’s with contaminates, which in turn will be ingested by us the people of Tarago. This is only one aspect for which it should not be built.
There are more families moving into the area to get away from the cities and their toxic environments. There are a lot of families that grow their own fruit and vegetables, these will also be contaminated.
Even the New South Wales Government acknowledges in it’s own Energy from waste Infrastructure Plan that waste incinerators impact human health stating that “People 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”. Surely this is enough to stop this thing alone. We are talking about human health. If Sydney doesn’t want it neither do we.
This is also set to destroy our family business as a school bus operator as what family would move into this area and send their kids to the local school or pre-school, and not to mention the closing of the local school and pre-school if it goes ahead. Our business has been proudly servicing the area for the last 46 years. I hope to buy the business off my parents and continue that tradition and service for many years to come.
These are only a few of my grievances there are many more but I will leave with these few last facts.
1. The NSW Energy from Waste Policy states that incinerator proposals are only valid where “community acceptance to operate such a process has been obtained”. There is no community acceptance for a facility in Tarago or anywhere in the Southern Tablelands.

2. Social license is made up of three components:
o Legitimacy – do they play by the rules? Definitely Not
o Credibility – do they provide honest information? NO
o Trust – can the community be confident that they will do what they say? Definitely Not

3. Veolia have spent over 15 years failing to operate their existing Woodlawn 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.

4. Veolia’s track record shows they break the rules, hide information from the community and pollute the environment.
I hope that this enough for the NSW Government to put a stop to this project.
Regards
Ben Howarth.

I currently live in the area that the proposal is for, and have lived here since 1994. I strongly object to Veolia's proposed incinerator being built in Tarago. I believe that if this was to go through it would cause large issues for myself, my family, the local community and the natural environment.
There are many reasons to object to this proposal but i'll select a few:
- The fact that waste incineration is not recycling and goes against the fight of climate change.
- It being toxic to people, animals and the land. Many people rely on rain water and the land for food. If this was to go ahead you would be accepting to poison people. It has been shown that these toxins do cause all sorts of medical issues.
- this same proposal was recently declined at Eastern Creek NSW being unsafe. An incinerator being unsafe for Sydney should definitely make it unsafe for us.
I really hope that this is looked at with an open heart and mind with the outcome to deny it. I'm both scared and angry that this would even be proposed.

My name is Paige Davis and I strongly object to the proposed waste incinerator in Tarago.
I have detailed some of my objections in the attached document.
Issues I have covered include:
A) The risk to human Health
B) Personal impacts
C) The proposal undermines the basic human rights of the community
D) The existing, untreated historical lead contamination in Tarago
E) The repeated, unrectified, and ongoing licence breaches at Veolia’s existing facility in Tarago
F) The previous IPC decision in 2018 that ruled against a waste incinerator in Sydney.
G) The requirement for Veolia to establish a Loss and Damage Fund prior to the toxic waste incinerator being built should this ridiculous proposal be approved.

I live in Gundaroo and I strongly object to Veolia’s proposed incinerator being built in Tarago.
My stance is based on previous university level education surrounding human biochemistry specifically.
I believe that Veolia’s toxic industrial waste incinerator will be detrimental to the health effects of the surrounding communities, through unintended air and food pollution.
The proposed municipal/commercial/industrial waste incineration will create a large amount of pollution in the forms of toxic heavy metal particulates and persistent organic particulates including dioxins, furans, PCBs and PFAS. These pollutants have been shown in various studies to cause decreased lung function, cardiac disease, and even cause death. These pollutants accumulate overtime and increase the toxicity of the surrounding soil and natural water sources. In turn the local plants, crops and animals will absorb the pollutants and cause a significant risk pathway for both nearby and distant residents. The proposed incinerator has the capacity to negatively affect our children, grandchildren, and their grandchildren.
I strongly recommend the proposed incinerator application for Tarago to be discontinued.

It is not a case of "not in my backyard". It is a case of not in anyones backyard.
This project does not stack up as a viable long term option towards net zero emissions. Waste to energy incinerators hinder the transition to a circular economy. Better alternatives are available - anaerobic digestion, gasification of combustible waste and recycling all offer greater reductions in greenhouse gas emissions. Waste incineration is a barrier to achieving transformational change in regards to how we produce and consume goods and services. Waste incineration incentivises "business as usual" approach. Indeed, it will encourage the use of plastics so as to keep the incinerator burning at full capacity. It is a quick fix solution that does not address the problem of waste, but rather leaves a trail of human health and environmental tragedy in its wake.
We are certified organic farmers in the area that will be contaminated by the toxic emissions. We strive to produce the healthiest food we can - this incinerator puts our livelihood and our health at risk.
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 – if it's not safe for Sydney, it is not safe for Tarago and the surrounding districts. The operator of the current waste management site Veolia, have not operated the Woodlawn facility within the license conditions for 15 years. They have received multiple infringements, have attempted to withhold information from the community and failed to inform the community of pollution to the environment. Apart from the whole concept of an incinerator being a backward step, how can the government think that Veolia will operate the facility in the best possible manner given their track record both here in Australia and overseas?
The problem of waste is not solved by an incinerator - it merely changes form. It becomes acid gases, toxic heavy metal particulates (mercury, lead cadmium) and persistent organic particulates (dioxins, furans, PCBs, PFAS). It will produce 2.2million tonnes of toxic waste ash, including 380,000 tonnes of air pollution control residue (fly ash). This is classified as hazardous waste by the Environmental Protection Authority (EPA). The proposal is to dump all of this at the site - risking soil and groundwater contamination. Sydney's waste may indeed be returned to them in the form of contaminated water. Again, Veolia's record of polluting local ground water (recognised by EPA prevention notice in October 2022) shows that they are not capable, nor do they care, of managing such a facility.
I strongly object to this proposal due to the reasons outlined above. It points to a government totally out of touch with anything happening outside of the Sydney basin and is a backward step environmentally.

Lack of regulatory review of monitoring data will put human and environmental health at risk, especially when assessing toxic compounds from improperly managed waste incinerators. This project can not be supported because there is insufficient regulatory overview of monitoring data within NSW. The NSW EPA does not assess the information in POEO Licences for accuracy. In the last 2 years I found 17 simple errors in the monitoring reports submitted for the Bingo Landfill (POEO Licence 13426) and the Alexandria Landfill (POEO Licence 4627). The EPA Specialist usually ignore information concerning errors in reporting.
The comments below are based on the content in Appendix O.
Woodlawn Mechanical Biological Treatment (MBT) Facility – extracts the organic content from a portion of the municipal solid waste (MSW) for use in tailings dam remediation. Page ES1. Is this material the same as Mixed Waste Organic Outputs (MWOO) which was determined by the EPA to be toxic and not useful as a soil amendment in 2019? Why would it be approved to rehabilitate tailings (mining waste material) dam remediation if it is toxic.
Waste is processed at the MBT Facility to extract recyclable materials and to produce an organic output from the organic fraction. The material is matured on site. Stage 1 of the MBT facility commenced operations in 2017 and is able to process up to 144,000 tpa of MSW and 40,000 tpa of green waste. Isn’t this green waste MWOO? How are they permitted to use this toxic material. Pg 7.
It is ridiculous to include the peak PM2.5 concentrations recorded on a day heavily influenced by bushfire emissions (1 January 2020) on the graphs of the expected additional particulates to be generated by the proposed project. It ruins the scale comparison for actual normal PM levels. Pg 130. Why would EMM even consider adding an anomaly to this graph?
It is not clear to me how adding the ARC emissions to the current condition will lower PM2.5 from 0.44 to 0.34 µg/m3. Will the ARC remove existing emissions? How is this possible? Pg 130

My name is Sophie Robertson and I live in Gungahlin in Canberra. I strongly object to Veolia’s proposed incinerator being built in Tarago.
 
I believe that Veolia’s toxic industrial waste incinerator will be extremely harmful to our environment in many ways.

Veolia’s incinerator proposal will emit toxic air pollution for 24 hours a day, 365 days a year for 25 years. This is catastrophic! Not to mention the acid gasses, toxic heavy metal particulates (mercury, lead cadmium) and persistent organic particulates (dioxins, furans, PCBs, PFAS). These have severe health risks to people as well as the environment.

This air pollution will spread throughout the region from Canberra to Goulburn, Braidwood, Bungendore, Murrumbateman, Gunning, Marulan, Yass and more. Waste incineration is not recycling and contributes to climate change. This is not in line with Albanese’s goal to be carbon neutral by 2050.

The NSW Energy from Waste Policy states that incinerator proposals are only valid where “community acceptance to operate such a process has been obtained”. There is no community acceptance for a facility in Tarago or anywhere in the Southern Tablelands.

If it’s not safe to burn Sydney’s landfill in Sydney, then why is it any safer in Tarago? Think before you act and don’t be selfish when it comes to the safety of our people and the environment we live in.

KEEP YOUR TRASH OFF OUR DOORSTEP

Please see my submission on what follows the incinerator.

Please see my attached comments on LVIA

I don’t want Sydney’s rubbish being burnt in our beautiful region and causing unknown irreparable damage to our local environment, farms and precious surrounding wilderness. I have 3 children and I don’t want their futures ruined because of these money making projects for some rich people in the city. It’s insulting that you think you can unload & burn your waste in our country towns polluting them with forever chemicals ruining our farms and our precious national parks!!!!! I am truly disgusted that this would even be considered particularly after one was rejected in the vicinity of Sydney due to the danger it posed. Why is it ok to put one here, destroying our region when it wasn’t it ok in Sydney? It’s not ok. This just shows me how little the NSW government and the corporations that donate to it, think of our country towns & its people. I completely reject and object to this terrible waste incinerator!!! Stop destroying our environment for profit!!!!

I very strongly object to Veolia's proposal to build an incinerator in Tarago. I am a Bungendore resident and feel that our area will be seriously impacted by pollution from this enviromentally disastrous proposal.
The benefits for the residents of the large area that will be affected by the toxic waste are zero but the negative impacts on health and wellbeing are enormous.
Why is it considered ok to build this toxic incinerator in Tarago when they are banned in Sydney ?
The amount of power produced will be miniscule compared to the massive amount of pollution produced.
How can this toxic greenhouse gas producing disaster be justified when the government is supposed to be aiming for zero emissions ?
In closing I repeat my objection to this shortsighted, disastrous,toxic proposal.

Please see the attached submission.

The project poses serious health risks for nearby residents and put dangerous toxins into human food chain. My family has a property that produces honey, vegetables and eggs. Their family with young children and their farm will be adversely affected by having this project so close to their home.

My name is Madeleine McGrath and I live in Murrumbateman. I strongly object to Veolia’s proposed incinerator being built in Tarago.

I believe that Veolia’s toxic industrial waste incinerator will severely impact the local environment and cause significant pollution. I believe I have a right, as someone who will be directly impacted, to object to the building of an incinerator. The project was deemed unsafe to be built near Sydney, yet the people it will impact here don’t seem to matter, and do not have a say, and I think that’s incredibly wrong. My concern is that the pollution will severely effect air and water quality, and will poison the environment with acidic gases, toxic metal particles such as mercury and lead, and dioxins. The persistent organic particulates have proven to decrease lung function, and contribute to cardiac diseases and even death. The waste that is going into the incinerator is deemed toxic and too harmful to burn “near populated areas” but you fail to see the capital of Australia, numerous small towns, and all the local wildlife as population. Veolia has proven to be completely negligent of safely managing toxic waste, due to their pollution recognised In the EPA prevention notice in October 2022. It was clearly started by the NSW government that the waste being expelled from this incinerator will have “no safe threshold of impact” due to the nature of the toxic waste. It is highly likely that my local town will experience significant impact, including contamination of the local produce and adverse health of the residence. At what point do human lives not matter? The project will permanently harm peoples health, lifestyle, and the environment and it will severely contribute to the already worrying problem of Climate Change. This Incinerator will contribute heavily to climate change by emitting 140,000 tonnes of C02 each year. This does not line up with Australia’s net 0 emissions by 2030 commitment. The recent State of Environment Report clearly states that the environment isn’t good, and its only getting worse. The damage this waste incinerator will output could be irreversible and kill people. Another Climate change concern is that Incinerators and other similar waste management projects are proven to reduce the amount of waste that gets recycled, and end up burning recyclable materials and polluting the air instead of giving them a 2nd life. It is an incredibly lazy, short sighted, selfish, risky, and dangerous method to get rid of sydneys trash and dump it directly into the environment and bodies of all the living things near it. The NSW Energy from Waste Policy states that incinerator proposals are only valid where “community acceptance to operate such a process has been obtained”. There is no community acceptance for a facility in Tarago or anywhere in the Southern Tablelands. Veolia’s track record shows they break the rules, hide information from the community and pollute the environment.
This project shouldn’t have even been an option and the clear disregard for the planet and human lives is disgusting.

I object to Veolia’s proposal to put a waste incinerator in our region. As a local I have spent the last 48years of my life doing my best to live a sustainable life. I have been very conscious of the seriousness of climate change which has been at the forefront of many scientists’ forecasts since the eighties. But politicians and big industries have chosen to ignore these warning until now, when it is too late to repair the damage.

I have placed a conservation order on my property and also over my last property, which sit within a 15km radius from the Woodlawn facility. The conservation orders cover 260 acres in total. These are registered over the titles on these properties and cannot be reversed. The reason for these titles is because most of the flora here is endangered as is the fauna.

Now Veolia comes along and threatens to destroy this all!!!
Shame on you. The futures of todays children will suffer the consequences of your actions.

I object to the New South Wales Government allowing this proposal to happen, it is a disgrace to think that you would even entertain such a poorly managed company to build an Incinerator anywhere in Australia. We are only custodians of the beautiful earth and should be protecting it for our children and our children’s children for seven generations.

I do not want my drinking water exposed to the toxins that will be generated and airborne by this incinerator, no amount of filtering will stop a nanoparticles getting into the atmosphere. This company can’t even stop the smell they currently create from reaching the entire region, how can they be trusted to control, fumes, steam and diesel burning from their generators. It is not good enough. The particulates, dioxins and heavy metals will end up in our rain water tanks and over 25 years end up concentrated in our drinking water.

This is not just a problem for the Goulburn council but for all councils, and class action is what you will be looking at if this for any ridiculous and unacceptable reason goes ahead. I object to this proposal and it should never be allowed anywhere in Australia.

I moved to Tarago with my wife a little over 11 years ago. We chose Tarago because the surrounding area was beautiful, provided a reasonable commute to Canberra and Goulburn, and gave us a clean, rural lifestyle for our children who came soon afterwards. We’ve worked hard to make this our forever home, a place to raise our kids who can run around free and healthy outside in the fresh air and space.

But all of this – the home that I’ve built with my family – is at risk thanks to Veolia’s proposal to build an industrial waste incinerator.

The Veolia EIS and glossy brochures call it an “Advanced Recovery Centre” and that it will produce clean renewable energy using the world’s best practice technology. This is all corporate spin and blatant green washing.

There is nothing clean about this proposal. It will poison our agriculture, our flora, fauna and rivers, the water we drink from our water tanks, our people, my family, my children.

While there are so many reasons why this project should not proceed, I provide the below key issues to support my objection:
• The NSW Government acknowledges the harm that waste incinerators cause to health – their own Energy from Waste Infrastructure Plan 2021 states “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”.

• A 2019 systematic review conducted by the ANU Medial School, Public Health Association of Australia and Council of Academic Public Health Institutions Australia published in the Australian and New Zealand Journal of Public Health (Tait et al 2020) clearly concluded “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”.

• While the NSW Chief Scientist and Engineer selectively left out the main conclusion from the above report in his report to the Minister for Environment in 2020, he still highlighted the risk to food production. The Tarago and surrounding area consists of prime agricultural land. Permitting a waste incinerator to be built here will threaten this multi-million dollar industry, and risk harming not just locals but those in the city who consume the meat and produce of this region.

• Toxins from incinerator emissions include acid gases, toxic heavy metal particulates (mercury, lead, cadmium) and persistent organic particulates (dioxins, furans, PCBs, PFAS). These will pollute our air, water tanks (when the pollution washes in from our roofs) and accumulate in the surrounding environment negatively impacting the health of our children, grandchildren and their grandchildren. This is an intergenerational burden which cannot be allowed to happen.

• While no level of emissions from a waste incinerator are safe for the surrounding community, Veolia has failed to even demonstrate they would be able to achieve NSW emission limits. State policy requires that they provide evidence from an existing reference facility using the same technology and waste feedstock to clearly demonstrate the proposal’s ability to meet regulatory requirements. Their own consultants admit in EIS Appendix L(i) – Woodlawn ARC BAT Assessment that “potential reference plants are not currently available to benchmark against all the requirements of the NSW EfW Policy as the requirements on energy recovery facilities are different in other regions; notably, the Technical Requirements for emissions standards”. So that means there is no conclusive evident that they would even meet NSW emission standards meaning the proposal must immediately be rejected.

• Tarago has been living with 15 years of Veolia breaching its licence conditions, polluting the environment, failing to genuinely communicate, and actively gaslighting community members who provide feedback or complaints. Hundreds of odour complaints are made every year, the EPA issues fines and prevention notices, yet nothing changes – Veolia is able to operate with impunity, negatively impacting the community while being rewarded with approvals for ever increasing volumes of waste to their Woodlawn Bioreactor landfill. Veolia is a bad neighbour and they have lost their social license to operate the existing facility. There is absolutely no community acceptance or social license to operate the proposed waste incinerator.

• The Tarago area is already surrounded with state significant projects including the Woodlawn Bioreactor, Woodlawn Bioenergy Plan, Woodlawn Mechanical and Biological Treatment (MBT) facility, Woodlawn Develop Mine (zinc & copper), Woodlawn Wind Farm, Woodlawn Solar Farm, Capital I and II Wind Farms, Capital Solar Farm, Collector Wind Farm and numerous other smaller, but still large scale quarry developments. As noted in the EIS, there are also an additional seven state significant projects in the pipeline. Tarago and surrounds are already suffering multiple negative impacts from these major projects from pollution to offensive odour, housing stress to unsafe roads from truck movements. This proposed incinerator would constitute an unacceptable cumulative impact to the local community and must not be approved.

• This project will provide no additional capacity for processing of NSW waste over the next 25 years (the life of the project). Veolia’s existing Bioreactor landfill can accept current waste volumes until 2047 and as they do not intend on raising their intake levels of waste from Sydney this will provide no waste management benefit to NSW and is simply pointless. It must be rejected on the basis it provides no additional capacity or benefit to NSW’s waste management.

• The proposal is bad for the environment and increase global warming – based on the figures in the EIS, it will generate an additional 85,777 tonnes of CO2 greenhouse gases each year on top of all the other toxic emissions that will pollute the surrounding community. The claims Veolia make that the energy generated would result in fewer emissions than a coal-fired power station are false and irrelevant. There are no coal-fired power stations in NSW that would reduce power production due to this project. Similarly Veolia’s claims in the EIS that incinerating waste is more environmentally friendly than landfill because it would prevent harmful methane emissions is false and deliberately misleading. The waste to be burned in this project would be diverted from their existing Bioreactor landfill at Woodlawn which captures the methane emissions and uses them to generate power in the BioEnergy plan preventing their release into the atmosphere.

• This project would actively work against moves to a circular economy – something the NSW Government has committed to achieving by 2040 (10 years before the proposed decommissioning of the incinerator). Waste incinerators discourage recycling by locking councils into long-term contracts forcing them to maintain volumes of waste rather than reduce, increase recycling and invest in innovative and more environmentally sound management. They take waste and convert it into toxic pollution and large volumes of hazardous ash which would be buried in the ground contaminating our soil and environment.

The health, wellbeing and environment of Tarago and surrounding communities is just as important as the people of Sydney who have been protected from the harms of these facilities, yet produce the rubbish it proposes to burn.

This project will decimate our town – those who can afford will move, those who can’t will stay and suffer, and the town will be locked into a toxic future. The growth and positive community outcomes the proponents claim are a total furphy – this will kill the town of Tarago!

The NSW Government and Independent Planning Commission must reject this proposal in its entirety, just like it did for the similarly toxic Eastern Creek Energy from Waste application in 2018.

Twenty five years ago, we bought 100 acres to escape the pollution and noise of the city. With a number of family healthy issues we chose to live off grid, close to Canberra and a train line. Yet slowly our little community is being polluted. First Veolia carts all the food rubbish and shoves it in a hole and it stinks! I love sleeping at night with windows open for fresh air… now I often have to close them because I don’t smell fresh country air but rotting rubbish. How much more will we be affected by a toxic incinerator? It seems unfair that those of us who have chosen to live simply and remotely to enjoy fresh country air have to put up with other peoples waste in our backyard! If someone you didn’t know crept into your personal backyard and dumped tonnes of smelly waste would you think that’s fair and civilised? We have unique wildlife, flora and fauna… we have unique businesses…. we have unique individuals … should all those be in jeopardy due to unhealthy toxic incineration? I would have thought we learnt a lot of lessons from our recent seasons from bushfires… we need to preserve our countryside at all costs!
Don’t let Veolia wreck our community anymore!

As a long time resident who lives off the land and drinks the water from our roof, I object to the thought of anything that is going to polute the atmosphere. My wife and I fear the detrimental health effects associated with the said incinerator. Please reconsider the environmental effects to ourselves and our flora and fauna.