Woodlawn Advanced Energy Recovery Centre

Ms Sally Munk
NSW Department of Planning and Environment
Major Projects
Locked Bag 5022
Parramatta NSW 2124

28 November 2022

Dear Ms Munk

Please find attached a copy of No More Incinerators Inc submission objecting to Veolia’s proposal to build a waste incinerator on their Woodlawn bioreactor site.

Kind regards

Chris Hanson
No More Incinerators Inc
Matraville Precinct
www.nomoreincinerators.com
E: [email protected]

My name is Mary Besemeres and I live in O’Connor, ACT. I strongly object to Veolia’s proposed incinerator being built in Tarago.

Veolia’s toxic industrial waste incinerator will affect the air that my children breathe. They already have health challenges, with autism, anxiety, and asthma. They have a right to clean air.

It will affect the lungs of everyone else living within distance of Tarago.

The incinerator is toxic to our health and environment. The points below outline how. It is an unacceptable proposal.

Veolia’s incinerator proposal will emit toxic air pollution 24 hours a day, 365 days a year for 25 years, which will spread throughout the region from 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.

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

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.

This incinerator will impact the health of our children, grandchildren and their grandchildren through the accumulation of forever chemicals in the surrounding environment. It is an intergenerational burden and legacy which cannot be allowed to go ahead.

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”.

In 2019, academics from the Australian National University Medical School, the Public Health Association of Australia, and Council of Academic Public Health Institutions Australia completed a systematic review of the health impacts of waste incineration, which was published in the Australian and New Zealand Journal of Public Health in 2020 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 proposal has already caused significant detrimental negative impact to surrounding communities’ mental health by increasing anxiety and depression. This will only be increased if the project goes ahead as those living nearby continue to stress about when their health will start to show the impacts of the pollution from the facility, or having to stay indoors.

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.

Finally, Veolia's incinerator simply isn’t necessary.
At current volumes the existing Woodlawn landfill has a remaining useful life of 25 years. Implementation of the NSW Government’s circular economy policies will reduce volumes of residual waste, which will extend that life even longer. There is no need to divert one-third of waste received by Veolia in Tarago to an incinerator which will pollute the region when there is sufficient capacity already in their existing landfill which captures methane emissions to fuel/power generator that create and supply electricity to the grid.

To Whom it May Concern
My name is Deborah Smith and I frequently visit and stay in the region around Tarago, NSW.
I strongly object to Veolia’s proposed incinerator being built in Tarago.

I believe that Veolia’s toxic industrial waste incinerator will be bad for the communities health, poisoning the environment and will ruin the future of the region.
My objection is based on many reasons, the most significant being that it is Toxic to the health of the community surrounding it and the environment.
Veolia’s incinerator proposal will emit toxic air pollution 24 hours a day, 365 days a year for 25 years, which will spread throughout the region from Canberra to Goulburn, Braidwood, Bungendore, Murrumbateman, Gunning, Marulan, Yass and more.
Food contaminated by incinerator toxins can cause cancer, miscarriage, infant deaths, developmental delays, reproductive issues, heart disease and respiratory impairment.
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”.

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 must also be rejected - If they aren’t safe for Sydney then they aren’t safe for Tarago.

Finally, Veolia's incinerator simply isn’t necessary. At current volumes (which Veolia have stated they are not seeking to increase) the existing Woodlawn landfill has a remaining useful life of 25 years. Implementation of the NSW Government’s circular economy policies will reduce volumes of residual waste, which will extend that life even longer. There is no need to divert one-third of waste received by Veolia in Tarago to an incinerator which will pollute the region when there is sufficient capacity already in their existing landfill which captures methane emissions to fuel/power generator that create and supply electricity to the grid.

Please DO NOT ruin this community with this poisonous, unnecessary incinerator.
Yours sincerely Deborah Smith

See Attachment

The area for the proposed incinerator is surrounded by hundreds of agricultural landowners. All of which will be affected by this incinerator depending on which way the wind blows on a given day. The toxins will find there way into the livestock, by inhalation, and by eating the fodder grown for them, the dams for livestock will also be contaminated, along with the ground water , and bores.This contamination of water and fodder will also affect wildlife. Then there is the drinking water of the human population. Are the owners of the incinerator going to take responsibility for contaminated drinking water causing health problems both physical and mental for the human population.? Violia have shown they are NOT responsible operators as they have breached of licence conditions at Woodlawn in the past and have recently admitted to contamination of ground water.
Australian and New Zealand Journal of Public Health has concluded in their studies,' there is no safe incinerator" they also state contamination of food and ingestion of pollutants is a significant risk.
The incinerator will also exceed NSW Government safety standards for emissions especially during start up, shut down procedures. How can this company not comply with NSW Government safety standards and be allowed to operate within such close proximity to families and livestock?

I don't agree the incinerator is renewable energy. It is burning waste , which is polluting the environment. Waste reduction needs to begin at home and in the shops. Waste disposal should also be carried out in the exact region it was created. Yes I believe sending Sydney's waste to regional NSW should not happen . Sydney people should take care of their own waste no matter what it is. It is also not 'green ' as you are using trains an trucks to take it to the incinerator, both using NON GREEN energy to travel a great distance to then burn it polluting another communities environment. All these actions, transport and burning of the waste contribute to climate change, something we were supposed to be avoiding. The pollutants of adding to climate change will directly affect very large area, including Canberra Yass, Bungendore, Gunning Braidwood Goulburn, Marulan and Bungonia.
The health impacts are an unknown quantity, and it is not , or will not be known for many years, then it is too late to make it better, because you can never make it right. Advice from the NSW government Public Health Journal should be followed, there is a reason the report has said incinerators are not safe! They are not safe for humans animals or the environment.
The project also conflicts with the local council rural residential future development, if this project is allowed to go ahead it will kill off future development in the council area, thus reducing property values.
This project was deemed NOT SAFE for Sydney in 2018. Technology has not improved in the time since, so it is still NOT SAFE for ANY community.
Tarago has a problem from ground water contamination already from this company, past mining also has caused long term contamination from lead, why do they need air pollutants to add to their already contaminated environment?
If it is not safe to do in your back yard then don't do it in someone else's backyard. If your don't want it in your backyard then don't put it in someone else's.
Violia have proved to the community they cannot be trusted, with multiple infringements impacting the community negatively in the past 15 yrs. Burn the waste In Sydney and stop using regional areas as a dumping ground for your own rubbish. Educate your residents about THEIR WASTE and how THEY CREATE it. Then, go on and educate them on how their waste has to be disposed of in their back yard! If that process has an impact on them they may change their ways, but stop inflicting regional areas with problems created by the metropolis.

I am living in the fallout area that would be impacted by the implementation of this Recovery Centre. I also have immediate family members living very close to the actual proposed Recovery Centre site and also family members living in the Canberra region who would be exposed to the fallout from this facility. I have seen the impact statement associated with this type of Recovery Centre and I am very concerned for the health of the residents in our region and my family members and of course for myself personally. My concerns also includes the impact on animals, farms and regional produce of the area if this Recovery Centre was to go ahead.

On reading this project's history and seeing that this type of Recovery Centre has been rejected previously, it would seem that our region was selected from a political perspective - "less voter impact" and with total disregard for the impact on the environment, the people and our region.

Be assured that peoples health and well being must be put ahead of any perceived short term political gains that the implementation of this type of facility might seem to offer.

I am making this submission to formally object the implementation of this Recovery Centre. I ask that this project not be allowed to go ahead.

My name is Michael Church and I live with my family on a farm at Covan Creek Road, Lake Bathurst.
We are 7.55km from the Veolia site.
I strongly object to Veolia’s proposed incinerator being built in Tarago. Or anywhere else for that matter.

I believe that Veolia’s toxic industrial waste incinerator will rain down toxic material on our home and poison my family and livestock, pollute our fields and rainwater and eventually destroy our ground water supply.

This incinerator that is going to consume 380000 tonnes of Sydney’s rubbish per year for the next 30 years.
It will bury 3000000 tonnes of contaminated fly ash on site that will eventually, without fail, leak into the ground water and another 50000 tonnes of hazardous, toxic ash that will be stored somewhere.
It will pump out harmful air emissions such as: acid gases, toxic heavy metal particulates (mercury, lead, cadmium) and persistent organic particulates (dioxins, furans, PCBs, PFAS). These emissions will travel for at least 100km.
Veolia has admitted the incinerator will exceed the NSW Government safety standards for air emissions.
As a State Significant Project, it will essentially be exempt from being controlled by the EPA. A licence to pollute, as Veolia has done with the odor from their garbage landfill site for the past 14 years.
If this project gains approval now, at some stage in the future in 30 or more years, people will say in horror “who’s idea was this?”

I am nine years old and live in Tarago. I object to this project because of the threat there is to mine, and future generations if the Tarago Incinerator goes ahead.
For starters, I have twenty- four beloved chickens and I can’t imagine my life without them. If the Incinerator goes ahead, it will poison their water and food, therefore poisoning their eggs.
Same with all the rest of the animals we use for meat, for example: cows and sheep- because they will be eating the grass and drinking the water that will be poisoned, which means we will be eating poisoned food products.
But also, the incinerator will not only affect the animals, but it will also affect the children as well. I love all my friends at Tarago Public school. Even now, Tarago is still having problems with lead poisoning in the water. But with only toxic air to breath and toxic water to drink, who knows what effect it will have on the children? To me, what I think Veolia is tying to say is that profit comes before all the people in my town. But let me tell you something. IT DOESN’T.
Another thing is that the Tarago Incinerator is an intergenerational warfare, my mum explained it to me. It’s when one generation (usually the older one) does stuff that suits them, but has bad effects on my generation. The Tarago Incinerator is a great example, because most people in this room will be dead in twenty- five years, when the Toxic effects of the incinerator start to show. But guess who will still be around? My generation and future ones. At the older generation doesn’t have to die by being poisoned by the incinerator! But my generation and our generation will have to wear the effects of that. Do you think that’s fair? Because all the people who made that decision for us had a nice peaceful life and will never have to worry about all the things my generation will have to worry about.
The things that will happen are: cancer, brain diseases, lung diseases, birth defects, miscarriages and more.
Would you want that dwelling in your mind for your whole life? And hoping it doesn’t happen to your children? If you don’t want that to happen to yourself, then why let another generation deal with it?
Please, stand firm to Veolia and the NSW government and protect my generation and future ones. Or we’ll be the one having to clean up the mess you’ve made.

My name is Kit, and I am 11 years old. I live in Tarago and have been here my whole life. I love it here. I enjoy all of the wildlife, trees, and the weather. Here is why I object to the proposed Veolia Tarago incinerator.

I object to the proposed Veolia Tarago incinerator because it will contaminate all of Tarago with pollutants. It will harm children and future generations with toxic pollutants and contaminate the land.

Veolia claims that the smoke coming out of the smokestack will be harmless, but it is found to pollute areas nearby with pollutants and cause birth defects, brain cancer, and miscarriage. You would not be able to eat any animals like beef, chicken, lamb, or pork produced in the area. It will contaminate any animal in Tarago. The same rules apply to the by-products of those animals like milk or eggs.

You also could not eat any plants grown in the area, like mushrooms or strawberries. Veolia’s proposed incinerator would be burning garbage 24/7/365 for 25 years!

Tank water will also be contaminated which would be a hugely big problem for houses in and around Tarago, since they all run off tank water. Tarago has no town water system, so people collect water off their roofs and into a water tank. The pollutants that come out of the smokestack will settle onto resident’s house roofs and wash contaminated water into their water tanks. People will use that water for everything from doing laundry, to drinking a glass of water, from washing the dishes, to having a shower. All that water would be contaminated.

It will not only affect things on the ground, but it will also poison the air. We would go outside and breathe in that polluted air that will also cause the diseases listed above. If an incinerator were so safe, then why couldn’t you just put one in the city where all the rubbish is coming from so you would not have to transport everything to another town far away? The effects of the pollution will also be intergenerational and future generations will have to try and clean up the mess that past generations have made.

Veolia is already not a good neighbour. My whole life, I have continually smelt the stench coming from the Veolia bioreactor. I continually smelt the smell when I was at Tarago Public School, and I still smell it all the time. Whenever other residents and I can smell the bioreactor’s stench, they are breeching their licence conditions. That means that they regularly breech their licence conditions.

Veolia’s trucks have also been leaking bin juice out of the back of their trucks onto the roads that they drive on. Residents have continually complained after seeing the bin juice leak out of the trucks and have captured it on video.

In conclusion, I completely object to the Tarago incinerator that has been proposed by Veolia. It will poison food, animals, plants, humans, water, and air. The proposed incinerator will be disastrous and impact future generations for decades to come if we do not stop it going ahead.

Air Politian from the stack output ,ash and fine Dust
Extra heavy traffic which will destroy our main roads
Water pollution into crisp creek which has already happen
Crisp creek run into Malware ponds which eventually into Sydney water catchment
The rail intermodal is on the banks of crisp creek
Tarago has a large quantity of workers that commute to Canberra every day via the Bungendore road
Our property valuations would drop drastically
I have been a resident of Tarago for 58 years we have been told a lot of lies over the years
such as the Oduor we have had to put up with during the years.
The new waste incinerator should be located away from rural residential area such as Tarago

There would be more trucks on the road and the road is not up to stranded as it is.
we have odor already
leaking of trucks on the road

My name is Kathleen Godfrey and I live in Goulburn. I strongly object to Veolia’s proposed incinerator being built in Tarago.
I believe that Veolia’s toxic industrial waste incinerator is not something that should be built near farming properties, surrounding towns as well as the city of Canberra with a population of 455,000. Why does the Government think that it is ok to build it in our region when in 2018 the Eastern Creek waste incinerator was rejected by the NSW Independent Planning Commission as not being in the public interest.
Some of the reasons for that decision were as follows:
1. insufficient evidence that the pollution control technologies would be capable of managing emissions
2. concern about the relationship between air quality impacts and water quality impacts
3. 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 must also be rejected for the same reasoning. If they aren’t safe for Sydney then they aren’t safe for Tarago. I have children and grandchildren living in Canberra and children living at Tarago, I am extremely concerned about their health in the impact this incinerator will have on them in the future and the environment they live in.
Please, I beg you, do not allow this incinerator to go ahead.

This project should not be approved. Veolia breach their licence frequently now, so what happens when they breach their licence to this harmful toxic polluting heap of infrastructure. It will be to late, the damage to the environment agriculture the people and the communities surrounding this area will be unsafe. The health of the future generations will never recovery from the furans dioxins and fly ash. The agriculture will be affected the Sydney water catchment which we drink will be filled with harmful and deadly posions. You must say NO TO THE TARAGO INCINERATOR.

Collector 2581 - I do not want the planned building of the Incinerators to be build in Tarago to go ahead . It will cause bad health issues to myself , family , pets and the all the wild life that live in the area ,which we all in joy . Please do not build it in my area .

My name is Hannah Davey and I am a resident of Goulburn. I am writing this as I strongly object to Veolia's proposed incinerator being built in Tarago. Below is a discussion of my major concerns with the proposed waste incinerator.

Veolia’s proposed incinerator has detrimental consequences for Tarago, the surrounding areas and even Sydney as it is toxic to both our health and environment. The pollution from this incinerator (2.2 million tonnes of contaminated ash) will negatively impact air quality, water quality, agriculture and health in the area. This is because it will include acid gases, toxic heavy metal particulates and persistent organic particulates. This large amount and composition of this pollution classifies it as hazardous waste by the Environmental Protection Authority. This waste will be absorbed into soil and water and consumed by plants, crops and animals. Thus negatively impacting the agricultural industry in the area and people who consume the food from this area may be susceptible to cancer, miscarriage, infant deaths, developmental delays, reproductive issues, heart disease and respiratory impairment.

Veolia has a track record of polluting local groundwaters and thus there is a high probability that they will not be able to safely manage the toxic outputs and as a result the Sydney water catchment will likely be impacted. Thus the incinerator will also negatively impact the health of those living in Sydney through the negatively affected water quality.

Furthermore I believe that if this waste incinerator is not deemed safe for Sydney, it is not safe anywhere. In July 2018, the Eastern creek waste incinerator in Sydney was rejected by the NSW Independent Planning Commission because of 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. 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 in 2018. Therefore this project must also be rejected as if they aren’t safe for Sydney then they aren’t safe for Tarago.

Therefore, the proposed waste incinerator should not be built, it will cause no good only harm for the regions from Canberra to Goulburn, Braidwood, Bungendore, Murrumbateman, Gunning, Marulan, Yass and even Sydney.

I object, on behalf of my family and close neighbours on
Lake George Escarpment,
to the Woodlawn ARC for the following reasons:

Burning waste will produce toxic and harmful products which can contaminate the air, environment and groundwater.
Any toxic or harmful emissions will reach us and will have health effects and odour impact as any easterly air flow is forced up due to the terrain and passes in a concentrated way directly over our residences. We know this because we have been able to smell the site from 21kms away.
We cannot fully consider the proposal as acceptable until all assessments have been made especially to human health.
Flue gas treatment systems are not 100% effective at removing harmful emissions.
The heat and emissions will contribute to climate change.
Capturing and burning methane from landfill has positive benefits of reducing the contribution to climate change and of producing electricity.
Burning will encourage more products to be discarded rather than separated and recycled.
Harmful and non-natural materials will be included in the input waste stream to add to toxic output.
The original proposal was to fill the mining hole and rehabilitate the site not to burn rubbish.
There is no majority local community acceptance or trust of Veolia’s actions.
There will be limited economic benefits to the local community.
Property values will be negatively impacted.
Although staff will have to be brought in to operate the incinerator, Veolia will not be demonstrating that it is harmless by having all such staff living next to it.

Regarding the proposed Veolia Woodlawn Advanced Energy Recovery Centre
I am objecting to the above proposal on the following grounds
1. The proposal is described as an “Advanced Energy Recovery Centre”, when it is in fact a waste incinerator which produces a relatively small amount of electrical power. I will expand on this point and show it is not accurately described.
2. The proposal is said to support the move to a “circular economy”, when in reality the burning of waste is not a long term solution and is likely to present an obstacle to the process of creating a circular economy involving the reuse and recycling of waste material.
3. There is only a vague reference to training in the EIS. The competence of the staff is of paramount importance as nearly all industrial incidents have at least part of their root cause the lack of competence of employees and inadequate management systems.
Section 1
The proposal is described as an “Advanced Energy Recovery Centre” when in reality it is an incinerator whose main purpose is to extend the life of the landfill facility by diverting around 1/3 of the waste which originated in Sydney to be burnt instead of landfill. The project is designed to thermally treat up to 380,000 tpa of residual solid waste and in return generate approximately 30MW of electrical energy. The project also claims that the export of electricity to the grid is considered to be a “GHG” offset. The project is said to save around 252,022t CO2 Eq GHG emissions per annum by incinerating waste and generating electricity in the ARC. The project is said to produce 71,828t CO2 Eq emissions and the argument is advanced that this only 0.01% of national emissions and 0.05% of NSW emissions. They state that GHG emissions intensity of electricity generated by the project is 0.64 Kg CO2 per KWh, and this lower than the NSW grid value of 0.85 kg CO2 per KWh. Using these figures for a full year I calculate 168,192 tonnes of carbon are released to the atmosphere by the ARC.
NB. Wind energy produces around 0.011 Kg of CO2 per KWh. So for 30MW we would have only 2,890 tonnes of carbon released, a factor of 1/58!
NB. NSW government is committed to a 50% reduction in emissions by 2030 and the largest coal mine in NSW will close by 2030 (source NSW Climate and Energy Action); indeed the Eraring coal fired power station (2800 MW) is also due to close in 2025.(source Chris Briggs University of Technology Sydney). Hence its not relevant to use coal fired generation as a comparison for this project, and as the projected life of the ARC is 25 years clearly this plant will be highly inefficient compared with the latest renewable power sources coming on line within a decade. This is in my opinion misrepresentation.
Furthermore there is some confusion in the rating of the electrical generator: parts of the appendix state 240,000 MWh, while the design output is 28.42 MW (not 30 MW). Appendix R on life cycle analysis states that “ Accounting for parasitic loss, the exportable electricity is expected to be up to 219,830 MWh, using this figure the power actually available to export is a maximum of 25.1 MW (based on a 24/365 year).
- Allowing for maintenance and annual shutdowns what is the likely lower figure?
Appendix R states that the proposed residual MSW and C&I waste based electricity production system has lower environmental impact than electricity production from coal, and biomass for all impact categories. They also state that the ARC will produce electricity with a lower environmental impact than natural gas except with regard to acidification.
The Appendix R makes the statement that there is avoidance of biogenic methane arising from the decomposition of MSW and C&I waste as this is diverted from landfill to the ARC.
- Is this the 6.12E+02 Kg CO2 equivalent referred to in table 10?
The Appendix R states that the annual savings are up to 395,034 tonnes CO2 eq.
- Is this correct or is the amount the lower value of 252,022t CO2 Eq GHG emissions per annum?
Section 2
In ES6 Evaluation of the project the statement is made that the “project meets the objective of the NSW Government to provide an ERF to serve Sydney by the NSW Waste and Sustainable Materials Strategy 2041 (DPIE 2021a) and will support the circular economy and the waste hierarchy by diverting some 380,000 tpa to landfill”. I disagree with this assertion for a number of reasons, which I will enumerate now.
1. According to the US EPA (epa.gov/recyclingstrategy/what-circular-economy) a circular economy is important because it is part of the strategy for slowing climate change. Clearly burning waste and adding CO2 eq emissions is not compatible with actions taken to mitigate the negative effects of climate change. The US EPA also makes the point that when a circular economy is properly designed and applied in a thoughtful and inclusive manner it has the potential to protect the environment, improve economics and elevate social justice. The community of Tarago and surrounding area are not being treated fairly with regard to social justice in the proposal for this incinerator, euphemistically described as a Waste to Energy Plant. The US EPA state that the aim of the circular economy is “Safe jobs and healthy communities are the goals”. The release of toxic material into the atmosphere poses a physical threat to the health of the community by inhalation or ingesting through contaminated food. Suspecting that the air, water or food grown locally is contaminated could have an impact on mental health in the area,
2. The NSW Government has published the NSW Waste and Sustainable Materials Strategy 2041 Stage 1 plan 2021-2027 in June 2021 which outlines how over the next SIX years they intend to move the state to a circular economy. The strategy is linked to the NSW Net Zero Plan Stage 1 2020-2030. The intention behind this legislation being to reduce waste and emissions. Accompanying this legislation is the NSW Plastics Action Plan which has been developed to address all stages of plastics life cycle.

- As plastic waste is considered to be part of the incinerator feedstock surely if the circular economy approach is to be deemed successful in the next decade we should be aiming for a greatly reduced tonnage of plastic waste going to waste?

Indeed, the NSW Plastics Action Plan states that there should be an accelerated transition to better plastic products and a ban on plastics which are problematic or unnecessary. As previously stated the EIS states that incinerating waste supports the circular economy, as I have shown this is not the case because the need for incinerator feedstock will be a disincentive to reprocessing and recycling waste. See Zero Waste Europe: The hidden costs of incineration: the case of Madeira and Azores Case Study January 2019 https://zerowasteeurope.eu/downloads/the-hidden-costs-of- incineration-the-case-of-madeira-and-azores/ This case study found that recycling of domestic waste was almost non-existent as the local council struggled to meet the demands for feedstock of the incinerator. Also https://www.wastedive.com/news/wheelabrator-baltimore-lawsuit-contract-dispute/552762/ where the waste handling company is suing Baltimore County USA for $32 million for failing to fulfil the contract for the supply of suitable waste.

- Presumably there would be some contractual obligation for customers to supply sufficient suitable waste and failure to do so would result in sizeable financial compensation?
Section 3
The issue of training of staff at the ARC is only briefly mentioned i.e
“It is considered that the Veolia’s ARC project will provide long-term livelihood benefits from ongoing and increased employment, community investment and involvement, and training and apprenticeship opportunities.”
Employee competence is of paramount importance in the operation of any industrial plant and associated equipment. Competence can be defined as “possessing the skills and underpinning knowledge to carry out the duties required by their employment, safely, effectively and efficiently”. The various tasks and duties to run the plant properly should be defined within Standard Operating Procedures (SOP) for each part of the plant and these must in turn be used to define the competencies of the employees to operate that plant or item of equipment. Errors of judgement and other Human Factors which can lead to serious incidents are almost always due to poor training and ineffective management systems. Whenever a new procedure is introduced involving a change in the SOP then it is essential that this is the subject of a properly executed change management procedure which ensures all employees are aware of the changes made and it is properly documented.
- What is Veolia doing about ensuring Human Factors is properly addressed and that staff will receive regular refresher training and reassessment of competencies?

There are many tragic examples of incidents which can be shown to have as their root cause human error or human factors.

- Will Veolia instigate a rigorous root cause analysis of all “near miss incidents” as well as accidents? Will these be transparent and available to the public? Will all Lost Time injuries be posted publicly?

As the famous quality management guru Dr W Edwards Deming stated in his 14 Points for Management, No8 “Drive out fear, so that everyone may work effectively for the company”. An example of an explosion and fire in an incineration plant can be found on the French government site ARIA No 45433 02/07/2014 in Clermont-Ferrand. Another example of Human Factors is that of a fire and explosion at a fuel storage depot at Buncefield, England 11/12/2005, when operators relied on the readings on their monitoring equipment although experience and observation should have warned them there was a problem. Forty people were injured. www.hse.gov.uk/comah/buncefield/

At its meeting on 24 November 2022 Yass Valley Council resolved to object to the Woodlawn Advanced Recovery Centre Tarago, Waste to Energy (incinerator) affirming the following:
• Council maintains its strong objection to the proposal in support of the surrounding region’s communities
• Council restates its call for an urgent review of the State Government’s Energy from Waste Infrastructure Plan before specific proposals are determined

I am a member of the Tarago Community. I have been living locally for several years. I have had to put up with the stench from the bioreactor for the entire time that I have lived here. Veolia are not good neighbours and have repeatedly lied to the community and refused to comply with their licence conditions.
There are many reasons that I object to the proposed incinerator, I have listed some of them below:
This incinerator will impact the health of our children, grandchildren and their grandchildren through the accumulation of forever chemicals in the surrounding environment. It is an intergenerational burden and legacy which cannot be allowed to go ahead.
The proposal has already caused significant detrimental negative impact to surrounding communities’ mental health by increasing anxiety and depression. This will only be increased if the project goes ahead as those living nearby continue to stress about when their health will start to show the impacts of the pollution from the facility, or having to stay indoors.
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.
I note that in 2018 the NSW Planning Department refused an incinerator in Sydney. All of the reasons that were stated as to why that incinerator was not appropriate apply equally if not more to the proposed incinerator in Tarago. Tarago and surrounds are environmentally sensitive areas and the locals rely on tank water for their everyday lives. If an incinerator isnt safe enough for Sydney its not safe enough for Tarago.

I am a Tarago local and I have lived here for over twenty years. I strongly object to the proposed incinerator for the following reasons:
Food contaminated by incinerator toxins can cause cancer, miscarriage, infant deaths, developmental delays, reproductive issues, heart disease and respiratory impairment.
Veolia’s incinerator proposal will emit toxic air pollution 24 hours a day, 365 days a year for 25 years, which will spread throughout the region from Canberra to Goulburn, Braidwood, Bungendore, Murrumbateman, Gunning, Marulan, Yass and more.
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.
This incinerator will impact the health of our children, grandchildren and their grandchildren through the accumulation of forever chemicals in the surrounding environment. It is an intergenerational burden and legacy which cannot be allowed to go ahead.