Woodlawn Advanced Energy Recovery Centre

Submission against the Veolia waste to energy incinerator at Tarago NSW
I write to register an objection to the proposed waste to energy incinerator at Tarago NSW. My objection is based on the toxic emissions of various kinds that this technology. What is being billed as a renewable source of energy does not fit the renewable energy criteria.
The process will produce a high level of particulates which would be damaging to the atmosphere and subsequently to the health of people in the region. I have been involved in the climate action arena for many years. One of the best books that I have read detailing the harmful impacts of fossil fuels is Client Earth by James Thornton and Martin Goodman (2017). The book included significant information on air pollution in general and particulates in particular (excuse the pun). Thus, when I have read that the waste to energy incinerator will increase the levels of particulates to extremely dangerous levels, this alone would lead me to oppose it.
There are of course other problems with this technology. Statistics are available of the emissions that will be produced each year. These are alarming but most significantly, various governments have been convinced enough to rule against the use of this technology: the NSW Government having banned the incinerators for Sydney and the ACT Government having banned them in the Territory.
It is undoubted that Australia and the world have a problem with waste. I wish there were better technology to deal with it. Governments need to be proactive and fund scientific research and development. We cannot solve problems with harmful solutions.

I live at Lower Boro. I object to the proposal because:
1. of the long term public health and environmental impacts the incinerator will have on water catchment areas, catchment areas that supply water to capital cities and many regional towns.
2. of the ongoing mental and social anxiety caused to people who are forced to have this structure in their area, or after-effects of incineration in their area.
3. the amount of pollution caused by transporting the material to Tarago significantly adds to the projects carbon footprint.

thank you.

I live in north-west Belconnen, ACT.

I strongly object because:

1. I have multiple chemical sensitivity (MCS) and any amount of pollution is a health hazard for me, and I’m not the only one suffering from this.

2. I buy chemical-free/organic, fresh local produce from market gardens and farms all around Canberra (which is essential for healthy minds and bodies and essential for me to manage my health condition).

3. If manufacturing waste is being reduced, then why do we need to incinerate it? What is the government doing about waste in manufacturing - if we are working on that then why do we need this incinerator?

4. We could persuade China to reduce the packaging in their export goods, or use corn starch to produce packaging, or stop using so much packaging.

5. In Iran in 2003, people were dying suddenly from heart disease, or brain cancer, because of pollution. I want neither.

6. There are already too many people suffering from respiratory ailments. Precipitating causes such as ash, however fine the particles, need to be reduced.

7. What evidence, over how many generations, do you have that there is no harm to:
1. Humans, 2. Flora or 3. Fauna from this kind of incinerator?

8. Look at the track record of Veolia – the pollution of groundwater and soil. We will therefore have reduced flora and fauna to maintain a healthy ecosystem.

9. Return to laundering (gowns, masks etc.) and autoclaving hospital equipment (including dressing packs). See the reduction of waste before your eyes and rejoice!

I strongly object to Veolia’s proposed incinerator being built in Tarago.

I believe that Veolia’s toxic industrial waste incinerator will be extremely dangerous to my and my family’s health, and those of my friends and neighbours health.
• There are many reasons for my objection, first and foremost is the fallout from the plume of debris that is plotted to fall over where I live.
With the expected plume fallout range, it will mean that the area where I live will be covered by the toxic pollution generated by the proposed incinerator, including acid gases, toxic heavy metal particulates (mercury, lead cadmium) and persistent organic particulates (dioxins, furans, PCBs, PFAS). I understand that 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. In the villate where I live we all rely on tank water. We do not have mains water, so we can expect to have our drinking water contaminated should this incinerator go ahead.

• If incinerators aren’t safe for Sydney, then they aren’t safe for Tarago.
I am aware that 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, with some of the reasons being sighted including 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!

• No social licence
I understand that 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. This can also be seen as a social licence.

I believe Social license is made up of three components:
o Legitimacy – do they play by the rules?
o Credibility – do they provide honest information?
o Trust – can the community be confident that they will do what they say?

From my readings of the current proposal and objections against it I see that Veolia have spent over 15 years failing to operate their existing Woodlawn facility within licence 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.

Veolia’s track record speaks fr itself, and shows they break the rules, hide information from the community and pollute the environment, with no regard to the mental and physical harm it imparts to the Tarago community. With the incinerator Veolia’s impact will reach much further than Tarago, spreading throughout the region from Canberra to Goulburn, Braidwood, Bungendore, Murrumbateman, Sutton, Gundaroo, Gunning, Marulan, Yass and more.
Veolia should be held accountable for the running of their existing facility in Tarago before they should be given permission and a licence to operate any new facility, not just in Tarago but in NSW.

I live in Wamboin. I strongly object to the proposed incinerator being built in Tarago. The reasons for my objection is that being downwind of it will ruin the quality of the air over here. I believe removing one of the main benefits of living here may impact property prices. I'm also worried that the waste pollution in the air from the incinerator will worsen my asthma and may impact older residents in the area.

Briefly:
1. the world is going green and in the process of educing the burning of coal, fossil fuels or anything to reduce green house effect. There is no evidence that burning/incineration of wastes is better than burning coal and/or fossil fuels. Further more ,incineration or burning of wastes: (such as plastic materials such as polyurethane, polypropylene, rubbers, woods, electronic board, medical and hospital accessories such as medical tubings, industry wastes, office wastes, retail wastes, to name a few to add to your imagination on what will be included in the wastes for burning) out of thousand of unrecoverable, non recyclable materials, will certainly generate toxic chemicals and gases that are known to be carcinogenic which are detrimental to human and live stocks. These carcinogenic by products (gases and ashes) not only affect immediate regions around the incinerator site, but also reaching easily to wider regions stretching all the way to more populated regionals and will certainly reach as far as Sydney, Canberra, Cooma and beyond, depending on the wind direction and seasons.

2. This Development Application should be referred to the Federation, ACT and VIC Department of Environment and Energy for independent assessments by different departments to ensure compliance with the EPAs as the emissions have the potential to cross borders contaminating air and water. In addition, this Development Application should also be referred to National, State and Territory Energy and Chemical Safety authorities as the impacts are far out reaching and not confined to just NSW regions

3. The efficiency of trucking millions of wastes from Sydney to the Woodlawn site to be burnt or a better word, incinerated should also be assessed for efficiency as trucking is one of the most inefficient form of transport as trucking emits green house gases.

4. Odour - this is noticeable problem especially on still morning. Veolia has acknowledged that they have been having problem with odour in the last few years and has yet to fix the problem. One of the Veolia media releases about management of odour problem is that Veolia will "monitor the weather and wind" or words to that effect. What that statement can be interpreted as Veolia has no solution to the odour problem, releasing of odour gases will be depending on weather and wind and hopefully the strong wind and weather will dilute the odour to an insignificant level to the immediate communities. Odour gases are detectable, what about the odourless carcinogenic gases? The Communities including National, State and Territory governments should be concerned about this, as pollutants, any pollutants, whether they are gases or particulars - odour or odourless; should not be allowed, particularly it is evidenced that some of the gases and particulars are carcinogenic and; some have health consequences that are not yet known currently.
Further, as Veolia cannot fix the odour problem prior to full operation, what hope do we have that Veolia will fix the problem after obtaining the Development Application

5. Overseas studies have all indicated that generating power from incinerators are outdated technology and they are slowly phasing them out. Incinerators remind the remanent of outdated technology. To build an incinerating power station in 2022 is absurd. Call it an "Advanced Energy Recovery Centre" does not hide the fact that it is a power station that burns waste or "rubbish" that cannot be recycled. What is worst than burning Coal is that no one know what is in that waste or "rubbish". Without knowing the contents of the waste, how the authorities determine what are the composition of the gases and particulars emitted into the environment.

The environment and health impacts are enormous and far reaching for generations. Hence, more intense scrutiny by various and relevant National, State and Territory authorities is required as the impacts are far reaching in distance and in expertises, from environment, industry, chemical, health, water, air and meteorology.

Hi, my name is Glen Harris, I live in the village of Tarago. I soundly object to Veolia’s proposed incinerator being built in our village of Tarago. I am of the firm belief that Veolia’s toxic industrial waste incinerator does not equal positive action towards climate change.

As a nation we are striving ultimately towards net Zero emissions. The date may move around depending on the government of the day however approving new projects that will increase and not decrease carbon emissions should be off all political agendas.
Veolia already operates an advanced recovery facility at the site with multiple community health and well being concerns that have never been properly addressed. These are not actioned by the NSW Government entities that give licence to their operation, nor a full and proper reparation received from Veolia themselves.

The fact that they have chosen to apply for this in a location with significantly less residents than greater Sydney speaks to how it would be received by the greater population of NSW. If there was no issues and it was environmentally friendly and alright to operate around people, livestock and nature then why can it not be built closer to the main source of the waste? The simple answer is that with a population of millions instead of hundreds the objects would have been too great and they would not have been able to build this facility.

The economic benefit of this proposal to the local area will be minimal if any at all. Instead with overwhelmed local governments and contracts for infrastructure maintenance well outdated the local area will go backwards instead of forwards. The only economic benefit is to Veolia’s bottom line. What happens if all the claims of environmental impact from Veolia are proven to be untrue and locals land and property values plummet? Veolia will not be held responsible. Let alone the local business and livelihoods that will need to be uprooted and relocated at a great loss to the individual, not the multinational corporation.

Within the purview of this proposal they need approval from the local area to proceed. So in closing I am strongly not approving its proposal and have not spoken to a single resident of Tarago, Goulburn, Bungendore and the surrounding areas that does support it.
Kind regards,
Glen Harris

My name is David Wind.
I strongly object to Veola's proposed incinerator being built in Tarago.
I believe the toxic gases and ash it will produce will poison our drinking water which is collected from the roofs of our houses,it will also pollute the soil and pasture which our livestock graze on which will in turn contaminate the food we eat.
It will contribute to climate change as burning plastic and bio waste can no way be less harmful than burning coal or any other fossil fuel.
This project would not be viable without government subsidy's I suggest the government use our taxes for safer more worthwhile purposes.
Regards
Dave Wind

My name is Adam Burns and I live in Collector (NSW). I am writing this as I strongly object to Veolia’s proposed incinerator being built in Tarago (NSW).

I believe that Veolia’s toxic industrial waste incinerator will negatively impact my family’s health, impact my property re-sale value and make Collector a less desirable transit stop for visitors (thus impacting local business).

As a local resident I implore you to scrap the incinerator. I will feel extremely let down by all involved if you do not listen to the people.

Regards,
Adam Burns

I strongly disagree with this project as Tarago NSW is already used as a dumping ground for Sydney Rubbish.
I moved to Tarago over 12 years ago and since moving here we have put up with Rubbish Smell from the mine at Woodlawn and i feel more rubbish coming to our town will only increase the level of smell and pollutants put locally into our region.
Also the amount of trucks using our roads is just going to increase destroying our roads and leaving drip trails all over the road that smell for days from the rubbish contained within the containers on the trucks.
* Stop spoiling our country town i moved here for the fresh air not to live next to a tip/incinerator.
I fear for my kids and there health.
The Cole Family

I object to the proposed development. Attached is my full submission.

I am writing to strongly object to the proposed development and any proposed waste incinerator in the Southern Tablelands or NSW. I am a key community leader in the Southern Tablelands as the Rector of St Nicholas Anglican Church Goulburn and the Archdeacon of Goulburn and the Southern Tablelands. This proposal does not have my support nor does it have the support of the Christian community I lead. I am deeply saddened that this proposal is even being considered by the NSW government.
I would like to make the following points regarding this proposal:
* I believe this proposal brings an unacceptably high risk of harm to the health and wellbeing of the people of this region. Even if a waste incinerator is run perfectly there will be emissions of known toxic chemicals into the atmosphere that will collect and build up in the ground over time. There will also be toxins concentrated in our waterways and water supply (and also the water supply of Sydney and Canberra). There will also be the potential for emissions of chemicals that we don’t presently know are toxins and aren’t even monitoring at the moment but that in the future we find are dangerous toxins. It would be sad to find a PFAS style disaster in the Southern Tablelands or anywhere in NSW in 25 or 50 years time due to waste incineration. This could be the case even if the plant is run perfectly.
* I am also concerned that the plant will not be run perfectly. The history of Australia is filled with industrial accidents bringing contamination from facilities that everyone thought was safe. Machines fail, those who operate them make mistakes and safety protocols are forgotten or ignored. It has happened here in Australia on a number of occasions. The possibility of an industrial accident that causes significant damage to people’s health and well-being in this district is present and significant. The only way to have certainty that there will not be an industrial accident is to not have the facility. Whilst ever this facility exists the residents of the Southern Tablelands, the ACT and Sydney will be living under a cloud of fear about what might happen.
* I don't believe that the proposal has seen anywhere near appropriate community consultation nor has it received anything like community support. As a community leader I have met a good number that still do not know about it. Others don’t know how to navigate the submissions process thereby reducing the number of submissions. In my experience the vast majority of those who do know about it are appalled at this proposed development. In my opinion, the community categorically does not support it and actually rejects it.
* Any proposal to burn rubbish on an industrial scale is in my opinion an abuse of State Significant Development legislation. This legislation should be there for developments that individual councils may oppose but will be for the common good of all who live in the state. It’s there for things like hospitals, freeways and airports. This proposal or any like it is not for the common good. Indeed, it runs counter to the common good. This is unnecessary infrastructure that has the potential to harm health and even take lives. Thus, I believe the use of State Significant Development status for this proposal is immoral and undermines trust in the NSW government.
* The people of the Southern Tablelands and surrounding areas that will be affected by this proposed development deserve to have their say on it. Unless there is a plebiscite that asks people if they would like an industrial scale waste incinerator burning hundreds of thousands of tons of Sydney's rubbish in their area that is passed by a majority of the Southern Tablelands and other affected areas, then I would not consider any decision to approve any waste incinerator by the NSW government on this proposal to be a morally legitimate decision.

I object to this development in the strongest possible terms. In my opinion, it should not be approved in any way, shape or form. No attached conditions will redeem it and adequately safeguard the health and wellbeing of the people of the Southern Tablelands. It should be rejected completely and utterly with no further review.

This project is destructive with long term consequences to the environment and needs to be stopped.

My name is Bianca Pavlic and I live in Wamboin NSW. I strongly object to Veolia’s proposed incinerator being built in Tarago.

I believe that Veolia’s toxic industrial waste incinerator will have a major impact on my health and environment.

As an asthmatic I feel this will create additional health hazards and concerns. I don’t believe they can burn waste without creating harmful toxic substances in the air.

I have been in living in Wamboin for the past 25 years (all of my life), I have seen my parents create a valuable productive farm which supplies to many of the locals with organic produce. This will significantly impacted the production of chemically free produce. I one day wish to continue the farming business however cannot see a future with the proposed incinerator!

Thanks

The EPA will play a decisive role in the assessment of the Woodlawn Waste Incinerator.

Their draft Policy Statement was on exhibition for comment from March 31, 2021 until April 30, 2021. The final version of the Policy Statement was released in June 2021.

From the final (and current) Policy Statement (Page 1)

Introduction
The Environment Protection Authority (EPA) recognises that the recovery of energy and resources from the thermal processing of waste has the potential, as part of an integrated waste management strategy, to deliver positive outcomes for the community and the environment. Energy from waste can be a valid pathway for residual waste where:
• further material recovery through reuse, reprocessing or recycling is not financially sustainable or technically achievable
• community acceptance to operate such a process has been obtained.
(bolding added)

The bolded sentence was also in the draft. I am unable to find the submissions to see whether any submitter wanted this changed.

As is normal, a number of agencies were asked by DPE for their input into the SEARs. The EPA’s input was extensive and detailed.

EPA input to SEARs relevant to this submission

RE: Veolia Environmental Services (Australia) Pty Ltd - Woodlawn Advanced Energy
Recovery Centre (SSD - 21184278)
I refer to your request for the Environment Protection Authority’s (EPA) requirements for the environmental assessment (EA) in regard to the above proposal received by EPA.

The EPA has considered the details of the proposal as provided by <DPE or applicant> and has identified the information it requires to issue its general terms of approval in Attachment A & B. In summary, the EPA's key information requirements for the proposal include an adequate assessment of:
1. Waste management, including waste feedstock and inputs, waste processing and controls and management of residual waste and by-products from the incineration process (such as ash);
2. The proposal's compliance with the NSW EPA's Energy from Waste Policy Statement; and
3. Air quality and human health risk. (bolding added)

DPE issued SEARs for the Woodlawn incinerator on July 2, 2021



SEARs from DPE relevant to this submission

Key Policies – including:
addressing the relevant provisions in, and consistency with, the following State and
international waste legislation and policy:
o NSW Energy from Waste Policy Statement (EPA, 2021)

We would then expect to find in the EIS a strong case showing community support and community acceptance of the proposal.

I’ve chosen a paragraph that I think is most relevant.
From the EIS (page ES16)

iv Community
The assessment recognises that some in the community have concerns about the project, and the impacts of current operations at the Eco Precinct. All of the issues raised have been addressed in the EIS. It is noted there is also support for the project and its economic benefits and contributions to the community. Veolia has and will continue its community engagement program throughout all phases of the project.

Very unconvincing.
This paragraph was written, I assume, by one or more of the EMM signatories to the EIS, more specifically David Snashall, Associate Director and/or Kate Cox, Associate Environmental Scientist. Remember, all EMM signatories to the EIS claimed that the EIS and all its Appendices does not contain information that is false or misleading
These two individuals gave a presentation to the Waste 2022 Conference 3-5 May 2022 entitled:
Energy from Waste in NSW – The long and winding road (sounds a bit insulting to EPA/DPE)
The last section of the last slide of EMM’s presentation is headed “Key challenges for proponents”
Challenge number 5 is “Resource Recovery Criteria” to which they comment:
“Efw Policy Statement is unclear which leads to different interpretations by bureaucrats”
Also sounds a bit insulting to EPA/DPE. (no mention of community acceptance to operate such a process has been obtained so this is unclear)

The last Challenge on the last slide of EMM’s presentation, number 7, is “Social licence (sic)” to which they comment:
“Gaining some measure of community acceptance”
Can the EPA or DPE shed any light on EMM’s interpretation of the Policy Statement?

There is no question that Veolia has some measure of community acceptance – employees for example.

I object to the proposal. "If it's too dangerous for Sydney, why should we have it?"

I strongly oppose this project. I am deeply concerned that the proposed site is so close to the ACT, where I live, and so close to regional communities like Tarago and Collector, where my friends and family live.

This will impact the air and water quality. We will be able to smell it. Breathe it. See it. It will pollute our ground water supplies. It will poison the land, our food, our bodies.

Food contaminated by incinerator toxins can cause cancer, miscarriages, developmental delays, reproductive issues, heart disease and respiratory impairment.

This proposal disregards human life. Makes regional areas responsible for Sydney’s waste. Will disproportionately affect women. Will ruin the region’s growth and future.

This project CANNOT go ahead.

I live in Gungahlin, ACT (north north Canberra). I object to Veolia’s proposed incinerator being built in Tarago near Lake George and Collector NSW. This toxic industrial waste incinerator will completely ruin the local area’s growth prospects. People are finding affordable housing in the region and commuting to ACT or Goulburn to work. Now nobody will want to live there with the smell and the pollution. Also, these negative factors will impact Canberra. Why should regional areas have to deal with the waste from Sydney?

Being a resident of the Goulburn Mulwaree LGA, I am extremely concerned about the pollution that this project will put into our air and the health implications of this pollution. My children attend school near this project and we live in the direction of the main proposed air flow. The health affects, especially in the long term, that this may have, if this project is allowed to go through, is extremely concerning. If there are no health concerns, let the project be built in Sydney, as it is Sydney waste being disposed of. If it is too much of a health hazard for Sydney, we DO NOT want it here. Our area may not be as heavily populated but we are still people and our health is equally important and we have gone without a lot to live in an area where our air is clear and fresh. The damage that this level of pollution will do to our farming lands is unspeakable. This project must not be allowed to go ahead!!!

My name is Christine Bradey and I live at 14 Moray Pde Saratoga NSW 2251 and I am strongly opposed to the incinerator being allowed to proceed.
I am writing to add my objection in support of the people directly and indirectly debilitated by this incinerator.
I would like to know if the following impacts from this proposed incinerator have been addressed.

A lot of the affected properties do not have access to town water and rely solely on tank water for their drinking, bathing and washing. With the toxic ash falling in such a wide area on roofs, this ash, containing heavy metal, will be washed into the tanks with possible dire health consequences.

In Sydney you can only have tank water for use on gardens as it is known that the toxic fallout from industry, that accumulates on roofs, would be detrimental to people's health. Why is not the same consideration given to residents in the affected areas from this proposed development, when they rely solely on tank water for all needs.

This development does not take into account the detrimental effects of contamination this proposed development will have on farming, in such a wide catchment area.

There is no need for the diversion of some of the waste for incineration as the current site is currently using methane capture technology to generate electricity without polluting the air. The pollutants from this proposal will impact a vast area and cause untold damage to the lives of the residents. It is a highly inefficient method of power generation and appears to just be a way to try and solve a problem caused by the lack of proper recycling facilities in Sydney and surrounds.

Veolia also has a record of NOT doing the right thing when it comes to preventing pollution. Even the NSW government admits there is no real safe threshold and populations will be affected.

Waste incineration is NOT recycling and contributes to climate change. If a proposed incinerator for the Sydney region was rejected at eastern Creek, why is it acceptable to impose it upon a rural community without access to a reticulated water supply.

Also, as a retired real estate valuer working for the Valuer Generals and the State Valuation Office, specializing in rural valuations, the negative affects this proposed development will have on properties values in the area will be dramatic.

The residents in this affected area would have a good case for mounting a class action, if not only to stop this development if it proceeds, but also to claim compensation for loss in value of their properties and detrimental health effects to themselves.
There is so little land suitable for residential development in NSW contaminating such a large area would not help matters.

Thank you,
Christine Bradey
0402 804 803
14 Moray Parade
Saratoga NSW.

Veolia is couching burning waste in very rosy environmental terms and they are simply not true:

1 - The NSW government already admits this type of waste burning doesn't meet environmental pollution standards at certain critical operational times. Given how much the wind blows in the selected area (note wind turbines located nearby) there is NO safe way to operate this thing.

2 - The fly ash is a serious concern in terms of airborne pollution and as an employee of an organic certified composting business at Mulloon (Landtasia Organic Compost) - this proposal puts my employer's business and my employment AT RISK. We just had an EPA audit (and passed) but if this airborne pollution gets a green light, we won't pass soil and water quality metrics in a few years.

There is so much more I could say about this greenwashed project but I think the above points are compelling enough to demonstrate why I oppose this project.

I trust sanity will prevail.