Woodlawn Advanced Energy Recovery Centre

My name is Ashleigh Dukes. I have recently moved to Goulburn and I'm horrified to hear that there is an incinerator planned less that 40km from where I live. I absolutely object to Veolia’s proposed incinerator being built in Tarago.

Clean air is a right, not a privilege. The toxic fumes that this incinerator will spill into the surrounding farms, communities and cities is unacceptable. Our environment, families, children, health and futures deserve better than this.

We need to find better ways to deal with our
waste. This is not one of them.
When you have governments, agencies and scholars all stating that this is unsafe and unnecessary (Australian and New Zealand Journal of Public Health in 2020) ; (NSW government safety standards) ; (NSW govt. Energy from Waste Infrastructure Plan that waste incinerators impact human health) it is clear that moving ahead with this "energy recovery center" is negligible and will cause unnecessary and reckless harm.

I did not move from the overdevelopment of the outer suburbs of Sydney just to experience the same pollution here in Goulburn.
Please, have some compassion and good sense to stop this project.

Regards
Concerned resident.

This incinerator can't be approved. Think of the people that ĺive in the area, the toxins that will travel in the air. Drinking water, the agriculture and the health of our future population. I have kids what will happen to them. Just because a graph says that it will have safe levels would you feel safe. These plants are being shut down in other parts of the world. Why send Sydney rubbish to a rural agricultural area. It's not safe for Sydney it's not safe for Tarago. Veolia should use their 600 million dollars to implement a reduce recycle reuse management.
YOU MUST SAY NO TO THE INCINERATOR.

My name is Tamara Kenna and I live in Gundaroo. I beyond strongly object to Veolia’s proposed incinerator being built in Tarago; indeed, considering the current environmental crisis we all are facing, i consider it an incredibly offensive travesty that you would even consider building this facility in the first place. A waste incinerator poisons the environment, spewing toxic particulates which will accumulate for km's around. It will introduce toxins into the ecosystem, the plants and animals of which have already been devastated by multiple ecological disasters including fires and floods. This pollution includes toxic heavy metal particulates and persistent organic particulates, which will contaminate crops and the airways of children. The crops will damage health, with incinerator toxins causing cancer, developmental delays and respiratory impairment. After covid and the bushfires, I am highly disgusted you would consider adding MORE respiratory toxins to the air we breathe. Millions of tonnes of toxic waste ash will enter the environment, which once again - after the bushfires, I am utterly disgusted you would consider this as an option. This ash is classified as hazardous waste by the EPA. The damage this incinerator will do to the environment will not just last our lifetimes, but those of our children and grandchildren. Have we not trashed the future enough with our lack of climate action? Futhermore, VEOLIA has a dismal prior track record of complying with applied conditions, and this incinerator will contribute to climate change by emitting over 100 000 TONNES of greenhouse gases every year. Once again - reprehensible, especially considering the huge impact of climate change on the area in recent years from flooding and fire.

Precedence has been set in July 2018 when the NSW independant planning commission rejected the Eastern Creek waste incinerator in Sydney. They rejected this incinerator as not being in the public interest due to concerns on impact to air and water quality, as well as human health. They also rejected it due to insufficient evidence that pollution control technologies are fit for the job of managing emissions. Toxic waste incinerators have now been banned in Sydney due to the risk to human health, and they were banned by the NSW government. Once again, it is reprehensible that something considered too dangerous for Sydney is considered completely fine for Tarago and the surrounding areas. We are not second class citizens simply because we live in the country.

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 indeed anywhere in the Southern Tablelands. We are trying to heal our land and bodies, not destroy them.
Please do not undermine our efforts.
Thank you,
Tamara

A family member owns property nearby and does not want any toxic ash or fumes destroying the clean rural air.

1. My name is Bob Philipson and I live in Goulburn. I strongly object to Veolia’s proposed incinerator being built in Tarago and I am making this submission on behalf of Community Voice for Hume as its President.

I have a number of serious concerns about the waste incinerator, WI, proceeding, as described on the EIS. These are:-

a. Given the highly toxic by product from burning MSW, Veolia needs a strong record of compliance with regulations and be able to demonstrate competence in the operation of similar or the same facilities. The latest incident, a very serious toxic waste spill into Crisps Creek as reported in the Goulburn Post of 9th November 2022 points add to an already poor history of waste facility management. The recent closure of Veolia’s Horsley Park Waste Management Facility after the NSW Environment Protection Authority (EPA) found fragments of asbestos scattered across the top of the landfill and on roads, is another matter of concern.
b. Veolia must be open and honest in the purpose of the incinerator for the sake of the public and likewise in directing its staff, to avoid confusion that could lead to serious mishaps. This is not the case as the operation of the incinerator is consistently described in the Executive Summaries of at least the EIS appendices O&Q, as converting waste to energy and not waste recovery. It is also described as “Clean” energy when its carbon emissions are at least as bad as coal. Indeed a spokesperson for the waste industry in Europe in respect of emissions produced from power generation stated:- “ it is unfair to compare its carbon emissions directly with those of plants whose main function is to generate power. “The primary reason why we exist is for waste treatment, not energy production,” said Agnė Razgaitytė, a spokeswoman for the Confederation of European Waste-to-Energy Plants, or CEWEP, an industry group. “So it’s not exactly comparable in the same way.”
c. The EIS claims that the operation of the waste incinerator supports the Circular Economy is at odds with the NSW Circular Economy Policy Statement (2019) in that it does not reduce waste or maximise the use of NSW’s valuable resources, and does not contribute to innovation, growth and job creation. Indeed the waste incinerator
d. Veolia In calculating impact of greenhouse gases in support of the claim that overall emissions will be reduced by the waste incinerator, over and above a reduction in methane emissions from the landfill and bioreactor, by burning 1/3rd of all putrescent waste, but its comparison is against coal-fired electricity generation that is being rapidly replaced by energy from solar and wind, batteries and hydro and has a lower level of carbon emission than coal.
e. Can Veolia, in the operation of the waste incinerator, guaranty that hazardous waste, such as asbestos, is not present in the feedstock. The incinerator does not operate at the temperature required to safely burn asbestos. The closure of Horsley Park waste facility is an example of Veolia failing to keep hazardous waste out of circulation.
NSW Circular Economy Policy Statement

The NSW Government has developed a Circular Economy Policy to deliver positive economic, social and environmental outcomes. The circular economy is about changing the way we produce, assemble, sell and use products to minimise waste and to reduce our environmental impact. The circular economy can also be great for business; by maximising the use of our valuable resources, and by contributing to innovation, growth and job creation. Moving to a circular economy will provide long-term economic, social, and environmental benefits for NSW. This transition will generate jobs, increase the robustness of the economy, increase the accessibility of goods, maximise the value of resources, and reduce waste.

Testing the EIS Against the NSWCEPS Outcomes

• Positive economic outcomes:- there is no measurable beneficial economic outcome from the WI, in particular compared to alternative methods of treating the waste, such as recycling plastic or turning organic waste in compost, as is already done in Goulburn Mulwaree. In fact the WI diminishes local economic outcomes given that the it has the potential to impact farming and is unlikely to attract investment in truly circular business opportunities. It represents a disincentive given its inherently toxic character and poor history of waste management. It is likely to entrench Goulburn Mulwaree’s reputation as being Sydney’s waste dump
• Social outcomes:- As evidenced by the Veolia citizen support group no longer functioning and considerable social concern about the WI and its toxic waste, in particular, there is no obvious social benefit and will almost certainly drive current residents away from the area and is likely to further reduce property values. Further Veolia’s consistent failure to address the odour from the landfill shows that Veolia has limited concern for the social impact of its operation
• Environmental outcomes:-as already stated above, there are direct risks to the environment through the production of toxic waste and emissions and the risks of accidents that would release a toxic materials, due to Veolia’s poor management record. This risk was apparent in its loss of its WI licence in Italy, due to poor management practices. Also the level of CO2 emissions from the WI, will not lead to a reduction of emissions, compared to the production of power from renewable energy, a fact acknowledged by the waste incinerator industry in Europe. See quote in 1.b. above
• Changing the way we produce, assemble, sell and use products to minimise waste and to reduce our environmental impact. The WI will have no direct positive impact on these objectives
• Maximising the use of our valuable resources, whilst this is a claim, it is not quantified in the EIS
• Contributing to innovation, growth and job creation. There is no discernible level of innovation in the WI, rather by its nature it represents a disincentive to the development of investment in circular economy. In respect of job creation, after construction, there will be some 30 jobs
• In terms of waste reduction, by the nature of its operation, as the WI requires a consistent supply of feedstock for the duration of its operation, including plastic, there is no incentive for the affected Councils to promote the reduction or recycling of waste.
• On all counts the burning of waste provides very poor support for the circular economy.

Identification and measurement of circular assets and risks for the finance and investment sector in the transition to a circular economy. see https://www.uts.edu.au/sites/default/files/2022-04/NSW-Circular-Finance-Investment-Rapid-Review-2022.pdf

In assessing the value of the Incinerator to the circular economy, in addition to the NSW Circular Economy Policy, it is worth understanding how it rates as an asset and risk to the investment sector in the transition to a circular economy as that could affect the ability of Veolia to obtain finance for its operation, especially as the supply of plastic decreases due the push for more recycling

Support for Circular Economy in the EIS
The Veolia EIS has some 31 references to the circular economy. The majority state that the waste incinerator supports the circular economy by extending the life of the landfill, generating low carbon energy and the extraction of resources, the former is challenged in the introduction of this submission and the latter is not quantified. The closest that the EIS comes to aligning with the policy statement above would seem to be the following:-
from page 30 of the EIS -Under this (Waste and Sustainable Materials Strategy 2041 focus area the NSW Government will “strategically plan for critical waste infrastructure, working closely with local governments and industry, with a focus on co-locating businesses in precincts that support circular economy and clean technology activities” (p.19).

Why The Waste Incinerator Challenges The Circular Economy
By its very nature, the waste incinerator (WI), produces highly toxic waste that itself cannot be recycled and does not further the cause of the circular economy.

The WI is a disincentive to the recycling of plastic as the WI requires a large quantity of plastic to provide the fuel for the incinerator. The State Government will be required to enter into an undertaking with Veolia for the supply of that plastic. The technology to recycle plastic to the point where it can be reconstituted. That technology is already available overseas. The lack of plastic feedstock represents a financial risk to the State Government if the plastic is not available.

Availability of Plastic Feedstock
The State Government has already banned the sale of single use plastic bags, single use plastics related to food, such as cutlery, cups, bowls, plates, straws and take-away containers. This will reduce the feedstock for incinerators. The elimination of plastic waste from supply chains in Australia is meant to occur by 2025, an event that will further reduce plastic feedstock.

The Federal Government is investing $250 million into new and upgraded recycling infrastructure through the RMF (Resource Management Fund?). The Fund will see over $1 billion of investment in recycling infrastructure, with contributions from the states and territories and industry. The above seems likely to reduce the supply of waste plastics further.

Further to the above the Federal Environment Minister announced on 15th November 2022 that all plastic was to be recycled as of 2040. This is further risk to the supply of plastic to Veolia.

The Impact On Local Economy of Veolia Investment in WI, will be to build an asset and not a business that could expand over a period. Also it is not clear as to how much of that investment will be made in Goulburn Mulwaree.

I object to this development. How can anyone think that this toxic incinerator be safe. Your tank water thatwe drink fruit and vegetables that we grow but most of all it's my grand kids that will be effected from the harmful toxins furans fly ash and everything else that comes from incinerator.
There must be another way recycle reduce re use is the answer it needs to be implemented we need to be educated. I SAY NO TO THIS PROPOSAL.

The project is directly linked ( by Veolia’s own documentation) to the production of dioxins among other harmful byproducts which are scientifically proven (by domestic and international scientific studies) to pose an unacceptable risk to human health. It has not been adequately proven by Veolia that these harmful byproducts will not pose;
- an unacceptable risk of contamination to residential drinking water ( the regional area has a significant number of residents entirely reliant upon rain water or ground water for drinking water) .
- an unacceptable risk to contamination of locally grown food including, but not limited to, meat, eggs, vegetables, nuts and fruit.
- an unacceptable risk to air quality for thousands of local residents.
This project was found to be unacceptable (based on an unacceptable risk to human health) when proposed to be located in a western Sydney suburb. That same risk applies to this location in Tarago. The lives of local residence in and around Tarago should not be deemed to be of a lesser value than those in the city. The UNITED NATIONS Declaration of Human Rights is very clear and states that “Everyone is entitled to all the rights and freedoms set forth in this Declaration, without distinction of any kind” this includes discrimination based on residential location. Australia is a signatory to that declaration.
Veolia/Woodlawn has operated a waste facility near Tarago for some time. During that time it have failed to adequately address the ongoing concerns of residents, some tens of kilometers away, regarding pungent and intoxicating odors. Earlier this year Canberra media reported that Veolia admitted to breaching environmental guidelines at its Woodlawn facility . This record makes a statement about the type of operator Veolia is and will be and the risk posed to the community by this proposal.
Further, this proposal will have a substantial impact on the wear and tear of local roads which are already under significant pressure with local Councils finding maintenance funding increasingly difficult.
The proposed location poses a real risk to pristine rural countryside, livelihoods and human health.
It should be opposed as is consistent with the opposition to its predecessor in western Sydney.

My name is M****** and I live in Quilaigo. I strongly object to Veolia’s proposed incinerator being built in Tarago.
I am a second generation farmer in the area and the threat of pollution impacting on my families numerous land holdings and food production on these holdings deeply concerns me. The incinerator will create numerous toxic pollutants and these will be released into our air. But hey thats ok! we are only a small number of people compared to the large populations of Eastern creek and other suburbs where these incinerators have already been banned by the NSW Government.
we alraedy know of Veolias track record with its putrid odour regularly occuring. despite its promises that this would never happen and when it DID happen that it WOULD be rectified. i live approx 15kms from the tip as the crow flies and i can smell the odour. Not to mention the lead contamation caused by the railway siding in tarago and the subsequent health issues for the families along that railway corridor. Also they paln to bury the hazardous fly ash waste and the pit sealants only have a lifespan of 25 years, further adding to the pollutants currently seeping into our water table from the waste.at the tip.
These type of incinerators are currently being decommissioned in Europe. why do we as a country continue to lag 25 years behind in technology rather than being a leader?
I am also a real estate agent in the region and have experienced first hand the effect on purchasers desire to live in the area due to the odour emitted from Veolia. A huge smoke stack will only further exacerbate this and decrease land values exponentially not only in Tarago but surrounding localities aswell.

This proposal is highly inappropriate for the local environmental and human communities. Having grown up in Bungendore and spending the majority of my time off in the area this is deeply concerning.

Burning rubbish and emitting it into the environment is antithetical to any sense of community or ecology.

No to polluting water. No go polluting land. No to pollution air.

I have little confidence that we won’t turn around in 10-100 years time and say what a bad idea incineration was. Yes, there are protocols and restrictions in place using current scientific understandings but that does not mean we know everything we need to know. Think of asbestos, formaldehyde, mercury, and so on - scientists gave those the a-okay until further knowledge and understanding led us to understand the harmful effects. Other countries who were using this waste to energy concept have started moving away from it. I don’t want the risk of the toxic air pollution in our community.

The incinerator impact on surrounding towns is unacceptable. The plumes can have adverse effect on health and environment with most of the impact long term and unknown. There is no good reason for it to be located in this area to foot the bill of sydney waste and is unfair to these affect towns NSW towns and Canberra. I do not want my property value affected by this approval. I do not want my family to suffer unknown harm and penalties from this poor decision. Benefits do not outweigh this risks here. Strongly object to this approval

The incinerator is far reaching to surrounding green towns. The plumes can have adverse effect on health and environment with most of the impact long term and unknown. Do not want this facility to be approved and tested on my family and neighbours. There is no good reason for it to be located in this area to foot the bill of sydney waste and is unfair to these affect towns NSW towns and Canberra. Benefits do not outweigh this risks here. Strongly object to this approval

I also forgot to write with my initial submission...
Veolia has not make significant efforts to connect with our community.
I coordinate a local group in my area and in contacting them about our specific group actions, I had enquired if they knew about the incinerator. Many people who I have spoken to over the past few months have not been aware of the waste incinerator being proposed (Advanced Energy Recovery Centre, is spin, it burns waste, which is plastics etc...).
It is concerning that so many in our community are not aware of the Incinerator project.
A lot has happened locally over the past few years with Floods, Fires, COVID, Cost of Living, New High Schools, and more (many of these events are continuous and on top of each other)... people need specific connections with infrastructure that will affect them into the future. If they don't know about it they can't sign up for Veolia's newsletters, they can't make submissions here. Veolia has not held an information session in my locality, yet we can get wind from where the proposed incinerator is being built. Of the events they have organised (I get their emails as I looked it up when I read about it in the newspaper, not everyone reads the local newspaper) the notification of events is too short and the days and times are only one option and they don't work with our schedule (which we can't change). So we could not attend. I have been doing a lot of reading about waste incinerators that are operational, it isn't something our country should be investing in. We should be looking more at recycling and reducing instead of burning waste.
What will happen if there is a breech or accident? Veolia have already had a number of incidents with their current operations, it is concerning that they want to expand operations further when what they are currently doing is not 100% safe (https://www.canberratimes.com.au/story/7964580/toxic-waste-spill-blunder-revealed-as-company-spruiks-rubbish-burning-plan/).

I would have liked to addressed the AERC further but due to time constraints I have not been able to address all of my concerns. I have attached my objection to this project.

I have lived near Tarago for 26 years and it is worrying that my community is planning to take step backwards in regards to the environment. Avoidable air pollution is not acceptable in this day and age, especially in a rural community that is so loved and appreciated.

We have lived in Tarago for the last 13 years on our 105 acre property . We have run cattle on the place for most of that time .
We have 3 dams and the cattle are grass fed . We do have regular visits from our Grandchildren from Sydney . We do experience unpleasant odour from the Veolia / Woodlawn bioreactor from time to time , depends on the wind !
We are totally apposed to the garbage incinerator near Lake George .The potential pollution from this incinerator could harm the whole environment in Tarago , people and animals . I believe the incinerator will exceed the NSW Government safety standards for air emissions and the ACT Government banned these incinerators for health and environmental reasons !
Re Cattle production - the NSW Chief Scientist states "new incinerators should be located away from areas of food production" and "food grown near an incinerator should be avoided " !
Food contaminated by incinerator toxins can cause cancer, miscarriage , Infant deaths , heart disease and respiratory impairment.
For the health of our family and friends , please stop this development
Regards
Jamie & Gina Stanistreet
Tarago NSW 2580

Major concerns over the Air Quality produced from the proposed Woodlawn ARC during operations and especially during time of maintenance/repairs when Air Quality will be compromised and not monitored.
Please consider the relocation of this Project.

Following a review of the Environmental Impact Statement (EIS) prepared by EMM for Veolia Environmental Services (Australia) the following key concerns have been identified that relate to the operation of the proposed Woodlawn Advanced Recovery Centre.
Groundwater impact assessment:
EIS Appendix U Groundwater impact assessment (EMM) states Veolia has adopted several leading practices to produce a project design that avoids and minimises impacts to water assets, however it is unclear what these leading practices are as the mitigation measures identified as no more than business as usual.
The assessment reviews the Willeroo borefields as a potential source of operational water. The report includes a field assessment which determines:
• A pumping rate of 9.7 L/s for up to 14 days continuous pumping is estimated to be the safe yield for GW042931 - Bore 3 (operating in isolation of other production bores). The pumping test analysis indicates that the current pumping rate of approximately 15 L/s is not sustainable, as after approximately 16 hours groundwater level is predicted to reach the pump intake;
• safe yield of 15 L/s cannot be maintained long term and hence only the early drawdown data was used to predict the safe yield of this production bore
• The predicted drawdown following 25 years of cyclic operation of the borefield (at 600 ML/yr) is shown in Figure 8.4. The water table drawdown is predicted to extend the width of the deep aquifer palaeochannel. Potential drawdown impacts at third party bores, which are a minimum 750 m away, are highly unlikely as pumping is not expected to be continuous for the 25 year period.
The assessment fails to outline the alternate source of water as a result of not achieving the 15L/s from the Willeroo borefields that is required during operation. If the water supply is not available or volumes are not sufficient, what is the impact on operations at the facility or where will this shortfall in water be supplied from.
What is the impact on groundwater dependent ecosystems from the continual drawdown of groundwater? This impact has not been assessed sufficiently.
The Groundwater Assessment identifies during drought conditions the facility will require a significant increase in groundwater use. The cumulative impact of this increase in groundwater use has not been assessed and consideration of local users has not been discussed, other than to state Veolia has a Licence and proposes to use the water with no regard to local or environmental constraints.

Air Quality Impact Assessment:
The EIS Appendix O Air Quality assessment confirms that under all three scenarios modelled, the local air quality will be adversely impacted due to an increase in emissions (excluding as a result of a bushfire). The assessment referenced a similar project in the UK using only one year of data from 2017 and showed where non-conformance against NSW EPA criteria would occur due to incorrect feedstock inputs. The assessment determines this to be an anomaly and an error, however, what engineering controls have been designed into the Woodlawn system to eliminate such issues occurring. While real-time monitoring will detect any exceedance, the air quality will be impacted as a result of the emissions entering the atmosphere and the real-time monitoring is reactive rather than a pro-active measure and does not prevent incidents from occurring.

Capability of Veolia to meet NSW EPA criteria and comply with DPE SDD conditions of approval:

Veolia has failed consistently to comply with both of its Environment Protection Licences (EPL) (No. 11455 CRISPS CREEK INTERMODAL FACILITY; and No. 11436 WOODLAWN LANDFILL) relevant to the operation of the Woodlawn facility on an ongoing basis and every year since 2017 and 2016 respectively.

In addition to non – compliances with EPL conditions, the EPA issued Veolia with a S. 96 Prevention Notice on 26 October 2022 as a consequence of not managing leachate water. The impact of this has the potential to result in groundwater and surface water contamination of off-site sources located at Crisps Creek and Lake Bathurst.

This Prevention Notice issued by EPA demonstrates that Veolia is not managing the environmental aspects of the site in a competent manner. The EIS Appendix V – Surface Water Impact Assessment states all water will be contained on site due to the level of contaminants (e.g. acid mine drainage etc) with no off-site discharge required, therefore no offsite impacts proposed. This statement is not consistent with the actual operational activities occurring on site currently.

In addition to the Veolia operations at Woodlawn, more widely, Veolia demonstrates ineffective systems to manage governance and environmental requirements. This is demonstrated through Veolia agreeing to an enforceable undertaking and agreeing to pay $590,000 as a result of its Horsely Park Waste Management Facility not managing asbestos appropriately (https://www.epa.nsw.gov.au/news/media-releases/2022/epamedia221007-$590000-financial-undertaking-secured-after-asbestos-find)

This demonstrates that while criteria and controls can be required for the operation of the Woodlawn facility, including the provision of monitoring data, it appears unlikely that Veolia will meet these requirements and the local community and environment will be impacted.

Woodlawn incinerator will impact the air I breathe and the land I live on. Veolia have a poor record of controlling the escape of pollutants. If incinerators are safe then burn the rubbish at the source- Sydney. If it is not safe in Sydney it is not safe here. Kurnell is a more appropriate site, it has polluted industrial sites, proximity to the rubbish and prevailing offshore winds. Our community will not accept you dumping your rubbish on us.

I am extremely concerned about the proposed Veolia incinerator planned for Tarago. I live in Canberra and I am concerned about the toxic gases and particulates that will be belched into the air, 24/7 for the next 25 years if this gets the green light. They will not only be in the air, but will also end up in the soil and water, leading to unwanted, toxic impacts for agriculture across the surrounding region. This level of toxic ash pollution will also impact people’s health. We DO NOT WANT THIS INCINERATOR in our region!!!

Canberra, and the surrounding region, is known for its clean air, vineyards, truffle farms and sheep properties. I strongly OBJECT to the imposition of such an incinerator on our region.

Think outside the square and come up with a proper environmentally-friendly solution to Sydney’s waste. Don’t just burn it and cause the Canberra region to be significantly damaged.