Eastern Creek REP Throughput Increase

I object to the Eastern Creek REP Throughput Increase for the following reasons

1. Scope creep through multiple development modifications
This the 8th modification of a State Significant Development that was first approved more than ten years ago. I oppose a process by which a company gets iterative approval for multiple modifications over more than a decade. Through the process of these applications, the development becomes a substantially different one to originally approved. At the same time, negative impacts typically become cumulative while the number of residents exposed to these negative impacts grow. The negative impacts of this site on the quality of life and the health of communities around the landfill are unacceptable and would not be tolerated in some other areas of Sydney.

2. Impacts on amount of waste going to landfill are understated
The community has been told that approval of the application will not involve an increase in waste going to landfill. This is not correct. The Eastern Creek REP currently receives and processes up to 2 million tonnes per annum (Mtpa) of construction and demolition (C&D) waste and commercial and industrial (C&I) waste. Bingo are seeking approval to expand the throughput limit to receive an additional 950,000 tonnes at the Eastern Creek REP. The landfill is currently approved to accept 1 million tonnes per annum plus, in addition to that limit, any residue which comes down the chute out of the landfill. At best (and there is no clear data available to verify this), 85% of the waste that is delivered to the Recycling centres is reprocessed into road base and other products which means that the very large increase in the recycling limits will also increase the amount going into landfill by up to 62,500 tonnes per annum. There is no guarantee that the recycling rates will be 85% and no guarantee that further increases will not be approved in the future. Bingo has confirmed that approval will mean more material going into the landfill but has not presented this in a clear way to the community which has already been suffering serious problems caused by existing landfill operations.

3. Seriousness of odour problem hidden from assessors
The EIS is inadequate in its description of the odour problem both in the Community Consultation Engagement report and in the Air Quality reports. There were hundreds of complaints about odours in 2020 and many more in 2021. These odours continue to impact on some residents, most recently in early August 2022. The EIS fails to convey the distress and discomfort that has been caused by operations of this facility. It falsely states that temporary gas flares were effective in controlling odours in 2021. The consultants should be asked to update their report with a more accurate account of this issue. A permanent gas flare system has now been approved but given the record of water control on the site and the management of leachate, assurances that odours will no longer be an issue cannot be taken at face value.

4. Failure to disclose relevant information about Bingo’s compliance record
The EIS fails to disclose that Bingo is currently being prosecuted by the EPA for unlawful release of odours. It is unacceptable that the Department of Planning and Environment (DPE) would accept an application from a large profit-making company that failed to mention an ongoing prosecution for lack of compliance with existing regulations. DPE should reject an application to expand its operations in a major way from a company with such a poor compliance record.

5. Failure to account for climate change
The EIS air quality and other expert reports fail to consider the predicted impacts of climate change in their evaluation of likely future impacts on residents

6. Community Engagement Strategy hurried, poorly executed and inadequate
Bingo was required to complete a Community Engagement Strategy report. Tthe report provided by WSP does not provide an adequate account of the relationship between the community and the company. In fact, Bingo’s release over months of sickening odours that were originally denied by the company has left a deep bitterness in the local community towards the company, expressed in media coverage. Insufficient information was provided about the three new proposals, which were all covered in one fairly short PowerPoint. Up until the end of 2021, the company had no Community Engagement Strategy and adopted a policy of initially rejecting its responsibility for odours until there was so much evidence it could not continue to do so.

1. Development creep through multiple modifications

This is Modification 8 of a State Significant Development that was first approved more than ten years ago. We oppose a process by which a company gets iterative approval for many modifications over more than a decade. Through the process of these applications, the development becomes a substantially different one to that originally approved. At the same time, negative impacts typically become cumulative while the number of residents exposed to these negative impacts grow. The negative impacts of this site on the quality of life and the health of communities around the landfill are unacceptable and would not be tolerated in some other areas of Sydney.

2. Impacts on volumes going to landfill are understated

Residents have been told that approval of the application will not involve an increase in waste going to landfill. This is not correct. The Eastern Creek REP currently receives and processes up to 2 Million tonnes per annum (Mtpa) of construction and demolition (C&D) waste and commercial and industrial (C&I) waste. Bingo are seeking approval to expand the throughput limit to receive an additional 950,000 tonnes at the Eastern Creek REP. The landfill is currently approved to accept 1 million tonnes per annum plus, in addition to that limit, any residue which comes down the chute out of the landfill. At best (and there is no clear data available to verify this), 85% of the waste that is delivered to the Recycling centres is reprocessed into road base and other products which means that the very large increase in the recycling limits will also increase the amount going into landfill by up to 62,500 tonnes per annum. There is no guarantee that the recycling rates will be 85% and no guarantee that further increases will not be approved in the future. Bingo has confirmed that approval will mean more material going into the landfill but has not presented this in a clear way to the community which has already been suffering serious problems caused by existing landfill operations.

3. Seriousness of odour problem hidden from assessors

The EIS is inadequate in its description of the odour problem both in the Community Consultation Engagement report and in the Air Quality reports. There were hundreds of complaints about odours in 2020 and many more in 2021. These odours continue to impact on some residents, most recently in early August 2022. The EIS fails to convey the distress and discomfort that has been caused by operations of this facility. It falsely states that temporary gas flares were effective in controlling odours in 2021. The consultants should be asked to update their report with a more accurate account of this issue. A permanent gas flare system has now been approved but given the record of water control on the site and the management of leachate, assurances that odours will no longer be an issue cannot be taken at face value.

4. Failure to disclose relevant information about Bingo’s compliance record

The EIS fails to disclose that Bingo is currently being prosecuted by the EPA for unlawful release of odours. CEM considers it unacceptable that the Department of Planning and Environment (DPE) would accept an application from a large profit-making company that failed to mention an ongoing prosecution for lack of compliance with existing regulations. DPE should reject an application to expand its operations in a major way from a company with such a poor compliance record.

5. Failure to account for climate change

The EIS air quality and other expert reports fail to consider the predicted impacts of climate change in their evaluation of likely future impacts on residents. NSW including Western Sydney has experienced two rain events this year that once would have been considered to be ‘one in one hundred year’ events. We cannot in this submission review all the relevant climate science and predictions. However, there is a wide body of research which points to the link between extreme weather and climate change. Extreme weather events include rain events, flooding, heat, bushfires and other fires, drought and dust. All of these have occurred in the last three years and yet none have been discussed in the EIS. All of these forms of extreme weather are predicted to get worse and are expected to impact on the Western Sydney area. The company has already blamed recent odours on intense rain events. It would be reckless to approve such a major expansion without considering the impacts of climate change. The NSW government itself has stressed the importance of climate change adaption. These priorities should be built into the methodology of the EIS.

6. Predictions which do not take climate change and extreme weather into account are unreliable.

In April 20, a fire broke out on the Bingo site. The cause of the fire was never established but Bingo blamed it on the very dry weather that had been causing some smaller fires in Western Sydney at the time. This fire spewed ash onto nearby residential streets. Complaints were laid about this impact but community groups were never able to find out either the air monitoring results at the site or the cause of the fire. With increasing likelihood of extreme weather, these sort of incidents are likely to increase and cause extreme anxiety and a potentially increased risk of physical harm to the nearby community.

7. Community Engagement Strategy rushed, poorly executed and inadequately described

Bingo was required to complete a Community Engagement Strategy report. Unfortunately, the report provided by WSP does not provide an adequate account of the relationship between the community and the company. In fact, Bingo’s release over months of sickening odours that were originally denied by the company has left a deep bitterness in the local community towards the company, expressed in media coverage. The company’s habit of denying it was the source of odours unless the evidence was overwhelming means that this company has demonstrated a lack of good faith and has earned public distrust. Many residents believe their health and quality of life is collateral damage in this process.

The community engagement process for this application did nothing to improve this situation. Many residents did not receive the initial leaflet, which in any case provided only short notice for a response. The local MP Edmund Attalla intervened and more leaflets were distributed. The public Powerpoint presentations to residents’ meetings did not improve community participation. Not enough time was allocated to get through the presentation material, leaving insufficient time for questions, let alone discussion. Not all questions, including some asked by CEM members, were answered by the company. When many residents did not receive notification, two more sessions were scheduled. But by then many residents had received feedback that the sessions were not helpful. Live links to relevant project application information were not at first available and were not easy to identify on the NSW Planning website. Three projects were covered in the consultation. Overall, the presentation strategy was more akin to an information session than a consultation. The lack of attendance at the seminars cannot be passed off as lack of interest. This is the same community that had filed hundreds of complaints with the EPA during 2021. Some residents have been required to spend hours documenting their experiences for the Bingo presentation. The community deserves to be treated with more dignity than provided for in a formulaic ‘tick box’ presentation.

Insufficient information was provided about the three new proposals, which were all covered in one fairly short Powerpoint. Up until the end of 2021, the company had no Community Engagement Strategy and adopted a policy of initially rejecting its responsibility for odours until there was so much evidence it could not continue to do so. In mid-2021, the NSW EPA required Bingo Industries to develop a Community Engagement Strategy. Bingo submitted a draft that was sent back for more development work. This occurred during the months leading up to this application.

8. Inadequate noise assessments

The noise assessment is not up-to-date and therefore underestimates current noise levels. According to residents, noise has been increasing in the area, particularly at night. In 2022, there have been more complaints to the EPA by ‘sensitive receivers’ about increased levels of noise, particularly in the evening. No authority has satisfactorily explained the source of the noise but in terms of an assessment of the proposal this does not matter. The construction and 24-hour operations of the waste facility and the increased truck traffic can only increase noise, which is already a problem.

9. Inadequate air quality assessment

The air quality EIS (Appendix K) states that the project will cause a small increase in the PM 2.5 annual average, but it already exceeds the national standard of 8 µg/m3 of PM2.5. We do not agree that even a small increase in annual average PM 2.5 is acceptable when the annual average in the area is already tending to exceed the national standard. Nearby residential areas are already exposed to increasing traffic on motorways and increasing industrial activity. Extensive scientific research has shown that there is no safe level of PM 2.5, which is linked to increased risks of heart disease, cancer, premature birth, and can impact lung and brain development. There is also evidence that it may be linked to diabetes, depression in adolescents and dementia. It has also been demonstrated that risks increase as levels of PM 2.5 increase. It is not fair that an area which is already more exposed to health risks than many other areas of Sydney should be further exposed to more risk, even if that risk is not predicted to be high.

Appendix K – Air Quality Impacts has several predicted concentrations of PM10, PM

No more favours for these proponents anymore please. I stay with my daughter often and every time I stay their I get sick and can’t breathe, the smells are so bad. You all have neglected us over money

It is unbelievable that the Government can allow these shifty proponents to build waste or waste handling facility so close to a residential area creating health problems instead of shutting them down or relocating them. They have never abided by the law. Minchinbury is such a beautiful community. So sad these greedy guys are ruining it. No expansion. Shut them down . Residents were there first

I object this project as a community member living within 5km of the waste facility, I have made multiple odour reports from 2021 up until present day and do not feel safe at the thought of their operations expanding when there seems to be issues with the current operations. I hold concerns for the odours present whenever we have the right wind direction, but also the fines for asbestos being uncovered in the facility more than once. They do not have my confidence and therefore I do not feel safe if they were able to operate on an even larger scale.

I STRONGLY OBJECT to this propOsal.
The current operations of this business are unethical and unsafe. They have a terrible track record of compliance with EPA regulations and have received many fines for their unsafe practices.
The increase the operations of this business would be at the expense of locals health and safety.

It has repeatedly shown the local community that it can not correctly and effectively dispose of the amount waste that it currently processes so an increase in volume would
Be disastrous.

For this I OBJECT to this proposal.

I regularly go to my niece’s house and can smell really bad egg smells and banging noises we know is from Bingo. This company should be shut down not expanded

I’m objecting to this project, the facility already has a terrible record of compliance with EPA licence conditions. Most recently they’ve been fined for exposed asbestos and expelling contaminated air (leechate). Adding extra waste to this facility will just perpetuate the problems.

I should also mention that their last licence change allowed extended working hours. This has caused excessive noise (loud metallic banging) throughout the night.

This business and facility should not be rewarded it’s an increased licence. This is telling them that they can continue to do the wrong thing and instead of being penalised they get rewarded with a higher income. All at the expense of local residents.

The facility is so close to homes and schools and they’re socially irresponsible.

At what point do the NSW planning authority and EPA start to utilise their powers to prevent this behaviour and protect the communities?

The roadways around the facility are already overly congested. We can’t handle any more excessively large vehicles in these roads. Wallgrove road has recently been ruined with the heavy vehicles already on it. Added trucks will cause more and more damage.

With increased waste will come increased pollution. This will have adverse effects on our children, who already cannot enjoy outdoor play when the wind blows the stench from the facility towards our Minchinbury house.
Increasing waste therefore increases health problems (asthma for example) which then increases pressure on the health system in western Sydney which is already under pressure.

For the above reasons I OBJECT to this proposal. In fact I ask that the planning authority and the EPA to take more action against the proponent for their ongoing breaches.

I suffer with asthma which has become increasingly worse with all the Hydrogen sulphide toxic releases that experts have confirmed has been coming from Bingo. Why are they allowed to apply for an expansion when we are having so many issues with them?

Alice Tai objects to the proposal

See the submission for further details

Please see attached.

I live near that facility, always suffering from the noise and egg smells so why they asking for permission to increase their premises and operation.
Bingo has never protected the environment or people including their workers. Please do not approve

Sweltering Cities is a NGO that works directly with communities impacted by extreme heat to advocate for more liveable and sustainable cities. We work closely with communities across Western Sydney who are concerned about rising temperatures and the health impacts of extreme heat. Heatwaves are our deadliest environmental disaster and kill more people than all other environmental disasters combined. Urban Heat Islands, such as much of Western Sydney, can be up to 10° hotter than other parts of the city. Urban Heat Islands are created in areas with few trees, lots of dark surfaces and concrete. Because Western Sydney already feels significant environmental and health impacts from extreme heat we believe it is essential that all major developments reduce urban heat rather than exacerbate it. We believe that the Eastern Creek REP Throughput Increase will exacerbate the Urban Heat Island effect, and that the project's impact on local temperatures has not been adequately investigated. Climate change will increase temperatures in Western Sydney and in a matter of decades the location of this project may experience weeks of extreme temperatures a year. This project is not appropriate for our changing climate and the future environmental disaster risks projected for Western Sydney. We therefore oppose the project.

This waste facility has continuously endangered my life and the life of my baby girls and family!!! We live with disgusting air pollution that is NOT ACCEPTABLE!!!! The expansion will only lead to further negative impacts for the community of Minchinbury!!!!!! Close this place down not expand!!!

I object to the proposal, as I understand that it is not supported my many local residents who face a number of negative environmental impacts with the current site.

Here we go again.....year after year the fighting the same thing. Our need to live a simple life while greed threatens us in making billions for someone who is already very affluent.

What can we say more that we have not already said in our previous submissions in the face of this utter greed to further pollute Sydney and especially those living nearby, our homes and our air? Is there nothing that this proprietor will stop at in his desire make more money while causing major health problems within the community and wildlife by constantly polluting our air and our waters? We simply wish to live with health while others try to destroy this for money.

This is a NEVERENDING BATTLE WE MUST LIVE with; the threat of a well known unethical proprietor and his greed to expand further to pollute our air, waterways with every proposal he makes. We have been fighting the battle of greed vs our health and environment!

First it is the 100m tall chimney stacks burning highly toxic waste right in our backyard and now expanding it. His incessant need to become wealthier the whole of Sydney must suffer with their health. You have so far received every health assessment and report due to his previous applications to expand one way or another.

The history of the proprietor proves that he cannot be trusted to adhere to health emission levels or guidelines as he has proven to be highly untrustworthy while stockpiling massive amounts of asbestos, placing a pollution pipeline into Alexandria Waters and more. This facility will not only be taking in waste from Sydney but, it will go further to pollute the whole of the state (air, soil and water) by bringing in waste from other cities and states. Even considering opening the door to such a facility is abuse of power, utterly inconsiderate of human and animal health and life and putting monetary value above human life. This is an outrageously dangerous concept to even consider, especially in the middle of a highly populated city and so close to everything highly populated area, schools, parks, wildlife, even Sydney Zoo. The suburbs nearby are already suffering from the sewage stench that is emanating throughout their homes every day and night. This is just the thing we need to add to our already stench riddled homes everyday.

Just this year in January 2022 Dial a Dump was fined a mere $15,000 for uncovered asbestos. The $15,000 fine was issued after EPA officers identified uncovered fragments of asbestos waste at Eastern Creek landfill site during a routine odour inspection.

https://www.epa.nsw.gov.au/news/media-releases/2022/epamedia220121-dial-a-dump-fined-for-uncovered-asbestos-waste-on-landfill

The environmental health breaches go all the way back to 2002. From Stockpiling of 170,000-cubic-metre stockpiles of waste contaminated with asbestos to 1300 cubic metres of asbestos-contaminated soil levelled and spread across a property in Marulan, belonging to Mr Malouf's mother-in-law, Kathleen Hopkins's company, Kathkin Pty Ltd, as trustee for his five children.

Records show he bought the Alexandria Landfill site from Sydney City Council in 2000 and created a recycling facility. In 2002 he was issued with four clean-up notices after the OEH received complaints relating to odours. Inspectors found landfill leachate was causing the stench. Another clean-up notice was issued after failed attempts to fix the problem and complaints increased.

But, it seems he is exculpated from it all because it is his "rogue employees and waste transporters" who are to blame. WOW!!! Even if that were to be true, this is evidence that his system is not managed or controlled effectively, demonstrating bad waste management practices, bad control and audit safety management and overall bad management of the whole organisation. If this site cannot be controlled and have not been controlled for 20 years how can a bigger facility provide the community with any assurance that these practices will be upheld at the highest standard safety and environmental standards at all times??? How can this organisation assure anyone that these past "problems" will not happen again, even though it only happened again last year in 2021, while Bingo is the owner of the facility.

https://www.forbesadvocate.com.au/story/941985/pollution-trail-to-megadump/

The owner of Dial a Dump sold all of his assets, to break the disconnect and disassociate himself and his rule breaching history by selling the whole business to the new owner of the site Bingo. Have a look here and see who sits on the board of Bingo. In short, NOTHING HAS CHANGED. The same sneaky and unethical management. It is just a change of brand who donates big money to the Liberal Party.
https://www.bingoindustries.com.au/sustainability/governance/board-and-management

In the light of all this, would the proprietor like to smell sewage in his home every day and night?

If anyone were to think of considering approval of this facility one must consider this question: Would I like to live right next door (literally) to such a facility and have your home filled sewage stench every day morning and night that you cannot even open your windows, let alone to health issues in years to come from such an untrusted management? THINK AND CONSULT YOUR CONSCIENCE BEFORE YOU APPROVE!!!

Confidential

Earlier today I made a confidential submission. However I inadvertently made a number of typos that could be read to given the wrong position. I have now corrected the content that follows below. Consequently the previous submission should be destroyed, and instead this is the correct copy:

PLEASE WITHHOLD THIS CONFIDENTIAL SUBMISSION

I object to the proposal.

I have worked for more than twenty years in senior roles for consulting firms within the property industry. I also continue to have an interest in urban planning and environmental matters. This includes regularly travelling to Western Sydney, specifically to the Eastern Creek - Penrith area. My comments follow:

- The EIS relies on old data that is not sufficiently nuanced and fails to disclose the facility's history of breaches, some of which have had major implications for local residents;

- I have witnessed some breaches; for example on Sunday 5 June 2022 (a winter's day), I visited the site in response to residents’ concerns. On this occasion I was able to able to enter the site, which I note was unmanned despite trucks entering the site with waste material. Moreover, the weigh bridge was closed, despite trucks entering and delivering waste material - ie without what appeared to be the appropriate recording of material. Moreover, odours from the site were apparent, both on the premises , and away from the site; e.g further along Kangaroo Avenue and Honeycomb Drive. Given it was a relatively cold day with a low grade breeze, I assume the situation could be far worse, particularly during summer. On this occasion, it was also apparent that there was no security or management at or around the entry point to the site, and what appeared to be poor management practices, with goods dumped at the eastern end of the site. In short it didn’t appear the site was, and seemed to be operating professionally. Viewing the site on that day, from a high vantage point that overlooks the void, it also appeared that gases were arising;

- On other occasions, I have observed strong odours (stench) from my car despite recycling the air, as well as from Minchenbury;

- I have recently read CEM’s independent report, and concur with a number of their observations; in particular the absence of reliable data, and concerns about the quality of reporting;

- It appears the applicant’s report has given little weight to climate change, and the likely increase in ground and air temperatures over the coming decades in the west as a result of Western Sydney’s densification and the escalation of the temperatures locally as a consequence of the introduction of Western Sydney Airport and with the urban island heat impact;

While I believe that consent approval should not be granted for this proposal, the data should nonetheless be independently verified for the purpose of reviewing the relevant consent conditions and verifying relevant benchmarks for consent provisions. This is particularly relevant given the passage of time, since the first consent approval was granted.

On behalf of Dexus, this Submission has sought to inform objections and provide recommendations to the DPE about the subject SSD Application.

Dexus objects to the Proposal on the following grounds:

• Further investigation into potential impacts on traffic in the vicinity of the Site, including increased heavy vehicle movements during construction and intensified operation of the Site, the condition of existing road surfaces, and any required intersection upgrades is required.

• Further consideration should be given to the proposed Stage 2 works not being commenced until after the Honeycomb Road and/or Archibald Road extensions take place, so as to alleviate potential traffic impacts in the area surrounding the Site.

• The site is located in close proximity to sensitive receivers associated with employment generating uses. As such, there will be potential impacts of emissions and odour on the health of the general public due to the proposed works.

• The proposed throughput increase will not promote ongoing economic benefits to the local community. It is considered that given the potential for traffic impacts, poor air quality and odour events, poor visual amenity and socio-economic outcomes, the Proposal could have a detrimental impact on the property value of the surrounding employment generating uses.

I object to this project. We do not want an increase of landfill at this site. Odours will be terrible and air quality will worsen. Houses and Schools nearby will be impacted and peoples health will deteriorate. Who even knows what toxic wastes will be dumped leaking into the environment.climate change has not been factored in along with many other considerations. Please stop this project from going ahead.
Thank
You
Yours sincerely
A concerned western Sydney resident