Woodlawn Advanced Energy Recovery Centre

The Conservation Council ACT Region opposes Veolia’s proposed Woodlawn Advanced Energy Recovery Centre near Tarago, NSW, regardless of where it might be located. The key reasons for opposition are:
- Incinerating materials is inconsistent with the waste management hierarchy and the principles of a circular economy;
- Incineration would create air and solid pollution, impacting biodiversity and human health;
- Incineration is not a clean source of energy consistent with addressing climate change; and
- The community does not support the proposal.

As a resident, Landowner and Business owner in Tarago NSW I STRONGLY OBJECT to the Woodlawn Advanced Energy Recovery Centre.

My family and I live and work 14km east of the Woodlawn eco precinct, with prevailing winds predominantly coming from the west this puts my family and livelihood directly in line with pollutants from this site.

With the current Eco Precinct, Veolia have a savage history of neglecting and operating outside of regulated standards. This is evident by repeated notices issues by the EPA due to odour, water contamination and contaminated roadways / railways. In all instances Veolia have brushed this off and put in short term remedies that soon revert to their old habits. Whilst Veolia claim this technology is safe I have absolutely no faith in them to operate it withing safe operating standards and causing long term harm to our community and young families.

Not only does this pose a risk to our family’s health is also poses a great threat to our local farmland and local water ways. Tarago and surrounding areas have a large agricultural community that are vital to providing safe locally grown food through Australian supermarkets. Tarago is also part of the Sydney water catchment with a lot of our land having harsh restrictions placed to ensure the safety of Sydney’s water supply so why should the be an exception.

With the plans for an incinerator found "not in public interest" for Eastern Creek in 2018 why does this make Tarago a suitable location, are Sydney residence more valuable or more important than your rural residence?

I am writing to object to the Tarago incinerator proposal. I have been a viticulturist and resident in the region for over 10 years and am deeply concerned about the risk this proposal poses to the Canberra Wine Industry which is a significant regional employer and contributor to the local economy primarily through tourism.

After reviewing Veolia’s Environmental Impact Statement (EIS) I note that they make no mention of the wine or grape growing industry. This glaring omission calls into question the entire EIS - how can we be certain that the true impacts on residents as well as local agricultural industries have been comprehensively assessed if this impact was not recognised?

With no information in the EIS, the local wine industry approached the Australian Wine Research Institute (AWRI) for an assessment of the risks posed by this facility. The attached report is unequivocal in assessing the facility as high risk and states “it is considered not advisable to build the ARC at the site proposed by Veolia and it is therefore suggested that an alternative site be sought.”

The AWRI points out a number of issues that were not examined by Veoia in its EIS. Specifically the potential for several of the chemical compounds that will be released by the facility to accumulate in the soil and revolatilise during summer. This will pose a great risk to our grape harvest as grapes absorb these chemicals and the resulting wine can be tainted by them at a sensory level much lower than a health and safety level. This was illustrated by our loss of the crop in 2020 from bushfires over 150km away - the levels were not of a health concern but the wine was undrinkable due to the smokey/ashtray characters.

When I review the EIS I do not believe that Veolia has adequately factored in the risk of long-term accumulation in the soil - if these chemicals have the potential to revolatise during summer than potentially they could build up to levels much greater than predicted by Veolia as they seem to have focused only on what the incinerator is emitting at a point in time. This makes me concerns about my and my family’s future health. I draw your attention to a couple of key points from the attached AWRI report:

- Using data provided in the Woodlawn ARC EIS, two separate approaches were used to estimate the amount of chlorophenols that could potentially be emitted by the Woodlawn ARC each year. In both estimations, the amount of CPs that could potentially be emitted was more than double the amount required to taint all the wine produced by Australia in the 2021-22 period

- An easterly wind direction would direct emissions from the ARC straight towards the Canberra District viticultural region. There is likely to be higher occurrence of easterly winds, and lower wind speed, during summer months, when grapes are ripening.

- Accumulation of 2,4,6-trichlorophenol (TCP), one of the chlorophenols in MSW incinerator flue gas emissions, in vineyard soil introduces the possibility of its biotransformation to one of the most potent food taint compounds known: 2,4,6-trichloroanisole (TCA). Volatilisation of TCA from vineyard soil during summer introduces the risk of aerial contamination of grapes with this compound.


I trust that these points will cause you to reject the proposal by Veolia as the risks to human health and local industries are too great. The Canberra Wine Industry is world-renowned and an Australian tourism asset - to destroy it by the installation of this facility would be heart-breaking to both Australia, small businesses and rural residents.

Thank you for the opportunity to provide written objection to this proposal - I object to this is the strongest way possible.
While I agree we need strategies to reduce our environmental footprint, do much better in terms of conservation and environmental management, there are so many more options available to us; and even if there weren’t, then we should change our ways and not even consider this.
While I know evidence presented suggests this is leading edge, and best practice, there is as much evidence that contradicts this position and should not be overlooked, ignored, or downplayed.
Those reviewing, and contemplating this proposal are in very trusted positions, and by design should be looking after the communities you represent, and should not be contemplating such terrible environmental initiatives rebadged as a good thing for the environment. It’s dishonest, and unethical.
While thinking more broadly about the promises associated with this initiative, I implore the decision makers to consider very carefully the fact the Veolia to-date has had significant issues with controlling the stench leaving the facility, which well and truly pre-dates the increased water in the environment over the last few years.
If they cannot be trusted to meet the terms and conditions of their current licence, are considerably and continually breaching their conditions, and are making a nuisance of themselves not only in the local community, but across the district due to their lack of compliance, which is correlated to the absolute stench, how can they be trusted to meet any new compliance or licences?
This is a terrible thing for a local farming community, think about where your food comes from as well. There will be long term impacts affecting generations to come if this goes forward. Think about your community, think about your children, and honestly review the evidence at hand.

See attached PDF

My name is Rhys, I'm from Collector NSW, and I totally oppose an Energy from Waste facility operating in Tarago and my region.

The key reasons for my opposition waste to energy incinerators in Tarago include:
• Waste to Energy incinerators have been deemed by the NSW Government as unsafe for Sydney residents, therefore they aren’t safe for Tarago and surrounding community residents.
• Installing a waste-to-energy incinerator in a region where residents have no access to treated drinking water and instead rely on water collected from roofs means their health is at even more at risk than Sydney residents because of waste incinerator emission pollutants settling on their roofs and accumulating in their water tanks.
• Veolia has stated in the EIS that they will not monitor groundwater or soil quality in any way – this means they cannot be trusted and are deliberately trying to avoid being held accountable for the irreversible accumulation of toxic pollutants in our region's soil and water.
• Veolia’s Continuous breaching of their odour responsibilities from their current operation at Woodlawn in Tarago and their recent contamination of the groundwater demonstrate they cannot be trusted to operate a waste-to-energy incinerator.
• Tarago is situated in a high wind area which is why there are multiple wind turbines. This means the toxic fly ash piles and emissions cannot be contained and will spread large distances throughout the region.

All energy from waste proposals within the NSW government’s 4 chosen locations are still required to comply with environmental and planning laws, including the Energy from Waste Policy Statement, which states: 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

All my family and friends do not accept Energy from Waste facilities operating in this community or this region. Members of my community and the region I have communicated with do not accept Energy from Waste facilities operating in this community or this region. And, based on the voted position of Goulburn Mulwaree council at the 21st of September 2021 Council meeting, Goulburn Mulwaree council also totally oppose waste to energy incineration facilities in the Goulburn Mulwaree Local Government Area.

I totally oppose the incineration of waste at any location because:
1) Burning waste is in direct opposition to a circular economy. Once the waste is burnt, all the materials that could be repurposed and recycled are gone forever.
2) A viable alternative to burning waste is the creation of a Circular Economy where materials are recovered and reused to reduce material going to, which is possible even for medical waste[1]. It is already widely practised throughout the EU.
3) A Circular Economy will provide huge economic and social benefits to the NSW and Australian Economies by creating permanent, skilled jobs and a healthier environment. The recent PricewaterhouseCoopers (PwC) study, “Building a More Circular Australia”[2] estimates that the cumulative economic benefit to NSW of moving to a circular economy through to 2040 would be $648 billion.2a
4) The health and environmental impacts from the incineration of waste, including cancers, reproductive dysfunction and congenital birth defects, are unacceptable. The recent research carried out in the EU demonstrates this.[3],[4]

REFERENCES
[1] Clinical clean up: finding ways to recycle medical waste
[2] PricewaterhouseCoopers, “Building a More Circular Australia”, 1a (table on page 12)
[3] HT Incineration-Hidden POPs Emissions-Arkenbout, Petrlik, 2019
[4] IPEN, Toxic Ash Poisons Our Food Chain, 2017, Section 9, Case Studies, Newcastle, UK (Byker Waste Incinerator)

I strongly object to the application of the Woodlawn Waste to Energy Incinerator for the following reasons.
The main reason is the impact to agriculture in the immediate surrounds and the flow on effects downstream and downwind. The incinerator will produce significant amounts of toxic organic pollutants that could contaminate water, soil, pastures and crops. This could lead to contaminated livestock and hence food that could make our farming enterprise unviable, if our stock are unable to be sold due to these contaminants. The negative impact to the land values surrounding the plant also should be considered.
If the plant is safe as claimed then there should be no need to transport the waste to Woodlawn where it is not produced and should be able to be kept where it was produced.