New South Wales
I Object to this proposal and ask that DPE recommend against approval.
1. The project has not been sufficiently justified which is a requirement of the SEARS. Those responsible for this application should have been expected to engage with and detail the main interactions between the EPA and the licence holders for both the recycling plant and the landfill. These two licences are connected as the facility has a chute which delivers residue to the landfill. The justification for the proposal is given in a few sentences which is quite shocking when one considers the impacts that the operations of the site have been having on the nearby community. We are told that there are spare 'state of the art' recycling facilities available and that the existing approval limits for inputs to the Waste Recycling Facility will be reached in a few years. Why did the company build facilities so far in excess of what was provided for by approved limits? This very much sounds like a company that has risked spending money on building facilities and then relying on the DPE to approve them.
2.There is not enough information about what residue will go into the landfill from the Waste Facility. This is the residue that cannot be recycled into road base and other products. What is in the residue? How do we know what the proportion of recycled material will actually be? This company has now been taken over by Macquarie Group and is even less transparent than previously. There is insufficient information supplied about this. The landfill has only been approved to take C&D and other forms of non-organic waste and yet it has been giving off an enormous amount of hydrogen sulphide and methane. These levels would not normally be expected with a non-putrescible landfill that does not accept organic waste. Indeed, this is presumably why the landfill was previously not expected to have a gas system. Given the distressing impacts that this facility has had on the quality of life and health of residents in recent years, there is insufficient economic or other justification for this project provided. Commonwealth and State governments do support recycling but will this facility itself encourage unnecessary development of roads, rather than public transport? Will it create a demand for feedstock to produce road base that is not necessarily in the best interests of community planning? These issues should be considered in the proposal's 'justification'. The basic information that is provided is more of a statement than a reasoned justification.
3. The Noise assessment states concludes that sleep will not be disturbed by the project. In fact, Minchinbury residents are finding that their sleep is disturbed in the early morning hours in 2022. I am aware that the EPA may have received some complaints. It may be that these have not been sourced back to Bingo but nor have the complaints been satisfactorily resolved. I find the noise assessment unduly optimistic and out of touch in its conclusions. It would seem unlikely that increased night truck movements less than 500 metres from some residences will not create further disruption.
4. The air quality study did not pay sufficient attention to the high temperatures, high PM 2.5 levels, dust and fires that occurred in 2019/2022. Such extreme weather is predicted to occur more frequently in the future and should be considered in any professional EIS in the 21st century. Rather than expanding this facility so close to where thousands of people live, the DPE should consider whether this landfill and recycling facilities should be given a limited life.
The EIS consideration of water management on the site is not sufficiently detailed, particularly in the light of two years of heavy rain events that are also predicted to be more frequent in the future. Bingo has blamed recent odour problems on these rain events so why is this issue not dealt with more comprehensively in the EIS future predictions?
4. The proposal fails to meet SEARS requirement because there is no adequate detailed description of the site. Even a basic fulfilment of the SEARS requirement for a description of the site would mean that the ownership of the site would correctly be described. In 2021 Bingo Industries was taken over by Macquarie Group Infrastructure which now is responsible for the management of the site.
5. There is a failure to engage with the SEARS which requires a consideration of the suitability of the site including its environmental impacts on nearby communities. Hundreds of complaints about odours emanating in breach of the site licence have led to a prosecution of Bingo Industries that is currently before the courts. The EIS is dishonest in its reassurance that the odours are effectively being managed and will be resolved by a permanent gas flare system. The temporary gas flare system was supposed to be effective too but failed. One resident has made 53 complaints to the EPA. 28 complaints in the period between September 2019 and July 2021 and 25 complaints were made after +the installation of gas flares. It is untrue to say the odours have been effectively managed. Even today, odours are worrying residents of Minchinbury including near the school. The EPA clearly believes that residents’ complaints are credible as it is using them to prosecute Bingo. On one occasion during the last year, Bingo was caught be the EPA dealing with leachate without appropriate controls in place. Given the poor management of water and leachate on the site, how can one be sure that the flare system will work? Why should a corporation that has behaved in this way be given the benefit of the doubt?
More up-to-date research on the impact of hydrogen sulphide should have been included in the EIS
6. As I write this, Minchinbury residents are experiencing odours. No one knows where the one EPA monitor is based but I question whether it has been placed where residents mostly intensely experience odours. I have personally spoken to at least 10 residents that have experienced skin rashes, breathing difficulties and anxiety because of the odours. This is part of the history of the site and should have been treated with more seriousness by the EIS consultants. More up to date research on Hydrogen Sulphide should have been considered in this EIS. A study on landfill on those living within 5 km health found a strong association between Hydrogen Sulphide (rotten egg gas) and deaths caused by lung cancer, as well as deaths and hospitalizations for respiratory diseases. The results were especially prominent in children. Respiratory symptoms were detected among residents living close to waste sites. These were linked to inhalation exposure to endotoxin, microorganisms, and aerosols from waste
collection and land filling.
https://www.sciencedaily.com/releases/2016/05/160524211817.htm?fbclid=IwAR0wb97hu507o_ifHVGs3Ci7T05hEHShAVF90WtahcwVIWUEMRhWmOsyiko. Such research is lacking in Australia but at the very least this 2016 study should stimulated more investigation into health complaints by residents near the Bingo landfill site.
Minchinbury is within 1 km of the Bingo, Rooty Hill South, 3km, Erskine Park is within 1.5 kmand St Clair 3.5 km. There are schools and hospitals within these areas.
7. I attended a Community Engagement Session. It was not adequate. There was not enough time to ask questions and I have never received satisfactory answers to my questions. Three projects were rolled into one PowerPoint and the company representatives took up most of the talking time. Th PowerPoint was much more about sending a message to the community than listening to the community. The links to the DPE applications were not easy to access. Overall the Community Engagement Strategy ( which was non- existent until late in 2021) was more about 'snowing' and overwhelming the community than it was about genuine consultation. This so called consultation process reinforced the poor relationship between Bingo and its nearby community.
8. During my research on this issue, I have spoken to workers at Eastern Creek. They have told me that they have also experienced overwhelming odours. Why have they not been considered more carefully in the EIS?
9. This week Environmental scientist Charlie Pierce notified the EPA about monitoring problems at the site. It is very concerning that there are gaps in the monitoring of the site. The EPA has constantly struggled to adequately regulate this site.
10.Residents have written submissions that will provide more detail of their experience with odours. I ask that DPE takes these submissions seriously and provides a public hearing that will allow the community to publicly express how badly Bingo Industries has impacted on their lives. Bingo’s approach was to initially deny that it was the source of the odours. Once the NSW EPA had clearly identified the site as the source of the odours, they resorted to minimising the impact. The truth is that the company has not been able to control the odours as of 10/8/2022.
11. Do not approve the project by trying to make the unconscionable acceptable by imposing conditions. Bingo has shown by its previous conduct that it will not comply with conditions in a timely way. ( For example. conditions imposed on an earlier modification to extend the limits for landfill and hours of operation in April 2020 were no completed on time.)
12. This article describes some of the events which a detailed historical account of the site ( as required by the SEARS) should have included. https://www.wendybacon.com/2021/EPA-warned-Bingo-of-rain-danger-and-an-unexplained-fire
13. This article explains Bingo's unsatisfactory conduct earlier in 2022. These are not the actions of a responsible corporate citizen. Bingo must not be rewarded by approving an expansion of activities.