Moorebank Waste Facility

I oppose the proposed Moorebank Waste Processing Project (Project Number 05 0157) at Lot 6 DP 1065574, Newbridge Road, Moorebank.

Please see attached for signed document outlining reasons for opposing this project.

My wife and I wish to object to the proposed building and construction of the Waste Recycling Facility at Moorebank (05_0157).

The main reason that we purchased a block of land in the Georger Fair Estate was to build our dream home and live in a peaceful and quiet community. The location also provides peace of mind that our children will grow up in a quality neighbourhood.

The construction of the proposed Waste Recycling Facility and day-to-day operation will see an increase in heavy vehicle traffic, industrial noise and dust. These three factors alone will significantly degrade the peace and quiet lifestyle that we are asspiring for.

Furthermore, we believe that property values in the immediate area (Georges Fair Estate) will fall to unacceptable levels if the proposed DA is approved.

Regards

David McLachlan

PLEASE SEE ATTACHED

Dear Sir/Madam,

When we first moved to Australia from Jakarta, Indonesia, we thought we wanted to give our two sons a better future; however, it turned out that what we have here is a lot less than what we used to have back then. Here, we have to work a lot harder for daily expenses, mortgage, bills, etc. It made us wonder what the point of travelling this far, leaving family and friends behind, leaving our comfortable lifestyle behind. We reached a point where we were thinking of going back.

One day, one of our friends from back home who have been migrating here for almost ten years said to us: "Lil, the ONE and ONLY thing we can give our kids here that we couldn't give back home is BLUE SKY." Yes, she is correct: Blue Sky. Blue Sky means cleaner air to breath; Blue Sky means clearer sky to see; Blue Sky means purer water to drink. These are simple things that we simply could not get in Indonesia which most Australian take for granted. These are simple things that keep us stronger surviving in Australia, thinking we ARE giving our sons a whole lot better future. Just these simple things.

And now, with your plan to build Recycling Plant close to our home, we feel we will be getting what we used to get back home. All the pollution, all the bad air quality, all the dust. Wonder what other environmentally bad things might happen as the effect of the Plant. We strongly oppose the development of the Recycling Plant close to residential area, anywhere in Australia, especially the one close to our home. Australia is a beautiful country with well planned development in every aspect of life, which is why we don't understand how this Recycling Plant was even planned, was even in the plan so close to residential area.

We understand that various tests were done to see the effect of the Plant; however, who could guarantee that it would not affect our wellbeing? Is this Recycling Plant really necessary in our area? I see Liverpool Council still has area that is more suitable for this Plant which is far away from residential area, why is this Plant not happening there? We are sure when you build the Plant in remote area, away from residential area, all of us (you and us) can save our energy and time debating this and we all can focus on making our Liverpool Council a better place to live.

Please, Sir and Madam, with your authorities and capacities, we are begging you on our knees to please put a stop to this plan so the Plant is not happening in our area.

Thank you.

Sincerely

Please see attached objection letter

As an OHS professional who gives advice regarding asbestos management planning to organisations as well as to businesses, I will normally advise them that working along the hierarchy risk of control in asbestos management is to consider elimination as the most effective risk control.

I will normally tell them that it is not worth taking the risk of living with asbestos exposure especially so that the fine minute fibres can be airborne.

A tiny particle of the fibre that can enter into the respiratory system of vulnerable group of people - infants, children and the elderly can bring about significant health consequences.

There are already scientific research studies on this. Exposure to asbestos dust is not limited to those working inside workplaces.

As asbestos dust is airborne depending on the direction of wind and the force of wind, the dust can travel with the wind and land on the residential area.

Georges Fair residential area lies west to north-west of the proposed Moorebank Recycling site.

You need the south-easterly wind to cause this.

The chances of this happening is significant as the area of Georges Fair lies on the slope of the Moorebank plateau facing east.

The chances of the airborne asbestos dust ending up inside the many homes is significant.

As a resident of Georges Fair, I am very concern of this happening to me.

I have to tell myself that if my advice to others that the best control is elimination, then the action of elimination control is to sell my property at Georges Fair and move away from this estate.

First of all, should I be doing that?

Secondly, is it fair that I pass on the hazard problem to the buyer of my property?

Do I owe to the buyer a duty of care?

Of course I will not sell.

So the solution to this is by applying elimination control action is not to approve Moorebank Recycling to proceed with the project.

Is it worth risking the health and lives of 4000 people staying in 1000 homes of an average of 4 occupants to a home at Georges Fair estate?

Cement recycling site operation and residential area less than 500 metres away are just NOT compatible.

Can we really believe that when the cement are collected for recycling will not contain asbestos fibres?

Hi Emma & Chris,

We refer to the NSW Government Planning & Infrastructure letter dated 25 February 2013 re the above Proposed Recycling Facility.

The above mentioned letter and the news of the Proposed Installation of a Recycling Facility has not only caught us with surprise but makes us feel guilty of making one of the worst decisions in our lives by having to build our "dream family home" at the New Georges Fair Estate in Moorebank.

We made a decision to build our family home at Moorebank back in April 2010 after learning about prospects of a family focused community and all the positive promotions about Georges Fair Estate at Moorebank through Investa Property that included:

- living a contemporary "green" lifestyle;

- assurance for protection of our investment with strict requirements around façade, landscaped gardens, strict fencing requirements, conditions of brick/paint color;

- promise to deliver lots of children's recreational areas; and

- above all, everytime we would walk into the Investa Property Sales Office and seek for status of the Proposed Marina, there is always positive response informing us that it is at planning phase and all looks very promising.

The point that we are making here is that above were some of the key reasons as to why we made a decision to build at Georges Fair and at NO stage during this process were we advised of a proposed recycling plant development literally next to the suburb.

If we had known about the subject Recycling Facility project back then, there is NO WAY we would have invested our time, effort money into building a family home and allow our children to grow in an environment which will be air polluted causing potential health hazard and filled with noise and ridiculous traffic conditions.

Here are the reasons why we "object to the Proposed Materials Recycling Facility":

- We were promised of a contemporary lifestyle living : will the polluted air quality from the Recycling Facility provide us this lifestyle; will daily torture of 325 trucks running on our roads literally 10 to 15 meters away from our Home provide for this promised lifestyle.

- Property value protection : how can we foresee this being maintained long term, who would in their right frame of mind would want to buy a Property for over $900K (this is how much it cost us to build) next to a Recycling Facility.

- Recreational areas for children : Indeed our suburb has lots of parks and playing area for our children, BUT if the Recycling Facility is installed, the air quality and traffic will no longer present safe environment for our children to use these recreational facility.

- Proposed marina construction : if the Recycling facility is allowed, it is obvious that this project will be called off and it will have significant impact on the value of our property and we were regularly reminded about the prospect of a Marina being built in the area.

For the safety and healthy livelihood of our children we submit to the NSW Planning & Infrastructure to reject the proposal for construction of Recycling Facility at Moorebank. Clearly as discussed above, this is NOT what we were promised when we bought our block of land only 3 years ago.

We object because Moorebank is now a heavily population density suburb and it is NOT a suitable location for construction of a Recycling Facility.

Furthermore, there is also an apparent collusion between Investa Property Group and Moorebank Recyclers and this proposal only surfaced after Investa Property is in it's final stages of development. This should to be investigated. If there was an existing proposal with the Council or NSW State Government for construction of this facility, then Investa Property had a duty of care to advise it's potential owners prior to the sale/purchase transaction.

Kind regards,

Runesh Roy
10 Christiansen Boulevard, Georges Fair Estate, Moorebank 2170
Mobile : 0423 826 591
Tel: +61 2 9335 3331

Please see attached our signed objection to the Moorebank Building Waste Processing Plant.

Currently building a new home at Lot 4330 Speare St, Georges Fair.

My submission is to OBJECT to the approval of the recycling facility proposed.

Please find my rejection letter enclosed as a PDF.

Regards

See attached PDF below

Please refer to the attached letter

Hi,

My partner and I are in the process of building our dream home at George's Fair, Moorebank and it is heartbreaking news for us to hear about the proposed recycling facility by Moorebank Recyclers.
We have put all our life savings, time and mental health into our project home, hoping that it would all be worth it in the end but instead more stress and anguish have been bestowed on us due to the proposed recycling facility.
After many countless days and sleepless nights with decisions after decisions, we chose George's Fair to start our lives and future together - hoping to raise our children in a new development area and thought this area would be the perfect location as it was right in the middle in both directions from both our families.
Please don't turn Moorebank into a complete industrial area. There is already enough heavy traffic on Newbridge Rd, not to mention the M5 traffic congestion as well as Moorebank Intermodal - what would become of this suburb?
I am not only concern about the traffic but more concern about the health, pollution, noise and smell. Please don't let George's Fair and nearby residents be affected by this for the rest of their lives. We want to be able to live and let live not close doors and windows to stop, dust, noise and pollution into our homes and lives. We will never be able to see the light of day again if this proposal was to go ahead.
My partner and I wouldn't have stop for one sec to even consider George's Fair had we known about this proposal. This is unfair for us and the hundreds of residents and future residents of George's Fair. It is unfair because we don't have the money to back away from this now. It is unfair because we are helpless and powerless. If you can make a difference and have the power, please be our saviour of George's Fair and give us a fair go.

Thankyou.

This is unacceptable. Since the opening of Brickmakers Drive it has been subjected to a higher volume of traffic than ever expected and if approved, this new facility will attract one extremely large truck every Seventy (70) seconds. Once residential development is complete, small children which are playing will be only meters away from these trucks. Appendix 9, 3.2.1(b) of environmental documents shows - 'Blue Box Open Forest and Ironbark Open Forest are examples of Castlereagh Ironbark Forest of NPWS (2002b) and Tozer (2003). Castlereagh Ironbark Forest is an endangered ecological community listed on the TSC Act as Cooks River-Castlereagh Ironbark Forest'. additionally 3.2.2(a) shows - 'Large trees providing roosting area for birds of prey. During the field survey a Peregrine Falcon (Falco peregrinus) was detected in one of the Muggas in the Ironbark Forest and a
White-bellied Sea-eagle (Haliaeetus leucogaster) in a Cabbage Gum in the River-flat Forest'. The construction of this facility would only destroy the Flora and drive away Fauna. With the current recycling plant, slight but notable smell exists. With the creation of a larger recycling plant it is completely obvious that smells will increase, gain strength and travel further as would dust particles and noise. These are only a couple of extracts and it is unbelievable that Council would even contemplate approving such a large facility so close to a residential area whilst also using compact residential access roads. Considering the Australian populations growing cases of allergies and allergy awareness this recycling plant would only spell disaster not only for the plant owner, but also for residents Flora, Fauna and the Council. Money should not be the key to approvals. If we knew of this development we would not have purchased in this area. In addition i believe that Brickmakers drive should be restricted to vehicles Three (3) tonne and under.

OPPOSITION TO MOOREBANK BUILDING WASTE PROCESSING PLANT

I oppose the proposed Moorebank Waste Processing Project (Project Number 05 0157) at Lot 6 DP 1065574, Newbridge Road, Moorebank.

1. I oppose the building waste processing plant because the proposed development is far too close to existing and proposed residential homes. The proposed development is just 250 metres from the Georges Fair housing estate. Trucks using the proposed facility will travel even closer to residential homes. Trucks will likely short cut through Georges Fair, passing parks and local residents, using roads not designed for massive trucks.


2. I oppose the building waste processing plant because of the known risks from inevitable silica dust, asbestos and toxins. At the community consultation meeting held on 31/5/2011 at New Brighton Golf Club, the representatives of the developer refused to comment on whether asbestos would be processed at the facility and whether toxins would be released. It is well known that inhalable silica dust causes lung cancer and silicosis (`Occupational Exposure to Silica and Lung Cancer', Cancer Epidemiology, Biomarkers and Prevention Journal, Volume 19, 2010). There is no known cure for silicosis (`A Brief Review of Silicosis in the US', Environ Health Insights, Volume 4, East Carolina University, 2010). The building materials proposed to be crushed at the plant inherently contain very high silica content. The developer plans to install sweepers "where trucks and people will travel" and that there are "unsealed areas" in the development. Their own documentation refers to "likely dust from the recycling facility" (pg 3, developer's information distributed on 31/5/2011 at New Brighton Golf Club). This is an unacceptable health risk for local residents.


3. I oppose the building waste processing plant because of the lack of studies in a non-industrial setting of inevitable exposure to respirable silica dust of nearby residents, particularly infants, the elderly and those with pre-existing health conditions. A lot has been said in the literature about exposure limits, necessary safety gear, etc. of the grownup employees working for only around 40 hours a week in such plants but information is lacking about the unprotected residents, especially infants, growing children and elderly, exposed 24/7 to such carcinogenic environments. NSW government's own website (http://www.environment.nsw.gov.au/soe/soe2009/chapter4/chp_4.1.htm#fig4.11 ) has the following to say: "Those particularly susceptible to the health impacts of air pollution are the very young (because they are generally more active outdoors and their lungs are still developing), the elderly and those with pre-existing health conditions." Additionally, since infants breathe by mouth, thus bypassing the natural filtering mechanism of nose, they are at a much higher risk.


4. I oppose the building waste processing plant because of the known increased toxicity of freshly fractured silica that will be released from the plant than aged crystalline silica dust found elsewhere.

5. I oppose the building waste processing plant because of the potential for flooding. The proposed development is in an area that floods. In the event of a flood, unsafe building materials and material stockpiles may cause an environmental disaster throughout Moorebank and the entire Georges River Basin.

6. I oppose the building waste processing plant because the NSW Government has indicated there will be "a return of local planning powers to local communities" (`NSW govt scraps 3A planning provision', SMH, 4/4/2011). The local community is opposed to this development. Councillors of the Liverpool City Council have voted unanimously against this development (Minutes, Liverpool City Council meeting, 15/6/2011).

7. I oppose the building waste processing plant because the proposed development is incompatible with the current and planned residential and recreational uses of the area. The proposed concrete processing facility is just 250 metres from the Georges Fair housing estate, with a high proportion of residents having young families. The area is zoned E2 Environmental Conservation. It should not be used for a concrete processing plant. In close proximity are schools, parklands, the Georges River itself, cycleways, a proposed waterside marina, a library and a golf club. The land is more suitable for recreational facilities or a reserve. Even the owners of the Benedict Recycling plant at Moorebank (which borders the proposed facility) have accepted that the area is no longer suitable for a building waste processing plant and have started to shut down their operations to create their own housing estate and marina.

8. I oppose the building waste processing plant because of increased traffic. The developer states the proposed facility will result in an extra 324 truck movements a day, which is "very low and will have no impact on the arterial road network" (developer's information distributed on 31/5/2011 at New Brighton Golf Club). Increased traffic will have a significant impact on arterial roads including Nuwarra Road, Newbridge Road and Governor Macquarie Drive. There is already significant traffic in the area which will be made worse by the `Intermodal', which will cause an extra 1.5 million truck movements in the first year. Truck movements will primarily be in peak hours, further impacting on already high congestion. The residents of Moorebank and other areas should not experience any additional noise, pollution and congestion from this proposed facility, given the likelihood of the `Intermodal'.

9. I oppose the building waste processing plant because of the negative impact on land values. Residents of the Moorebank precinct in particular have spent significant amounts of money on land and homes. The proposed development will have a severe impact on land values and residents will not be compensated.

10. I oppose the building waste processing plant because there was a lack of community consultation at a meeting held by representatives of the developers on 31/5/2011. The organisers did not notify a significant number of local residents and future residents about the meeting. The organisers refused to answer questions from local residents on health risks. The organisers did not allow time to note down and respond to residents' concerns.

11. I oppose the building waste processing plant because it is dangerous to residents for a concrete processing plant to be located in this area of metropolitan Sydney. There are pre-existing waste processing plants operated by Benedict Recycling and Smorgan Steel Recycling at Chipping Norton. Benedict Recycling is planning to build another plant at Heathcote. There is no need for so many waste processing plants in such close proximity to each other.

12. I oppose the building waste processing plant because of the misleading information provided by Moorebank Recyclers in their application showing their panhandle as the access route for their trucks to New Bridge Road whereas RTA has already refused this access. The environmental assessment is meaningless without taking correct route into account to assess the impact on the nearby residents and environment. The to and fro movement of 324 trucks per day will create huge dust clouds if one goes by what their trucks were shown to do in a recent ACA report on Channel 9 titled "Housing dream shattered".

13. I oppose the building waste processing plant because of the misleading information provided by Moorebank Recyclers in their application claiming their "model to predict dust concentrations in the region and at nearest sensitive receptors" whereas the nearest sensitive locations are actually much closer than those used in their model, i.e., Georges Fair residences just across the Brickmakers Drive.

14. I oppose the building waste processing plant because the model used by Moorebank Recyclers for Air Quality Assessment is based on pollution data obtained during 2005 whereas government's own website (mentioned above in 3) says: "Emissions from the commercial and domestic sectors are growing, increasing their relative contribution to overall emissions." In view of this the modeling should be based on recent data and not some old convenient data.

15. I oppose the building waste processing plant because the model used by Moorebank Recyclers for Air Quality Assessment is based on meteorological data obtained from Bankstown Airport which is kilometers away but still "considered to be representative of conditions experienced at the project site" despite "Terrain around the site consists of gentle hills, bounding the Georges River (see Figure 2)". These types of gross assumptions are risky to be made when it comes to public health and safety especially when DECCW requirements clearly state that "Data must be representative of the area in which emissions are modeled".

16. I oppose the building waste processing plant because Moorebank Recyclers already admit in their Air Quality Assessment that "Assessment of cumulative 24-hour average PM10 air quality impacts is often complicated as there may be many occasions when background concentrations are already above the 24-hour average air quality criteria". The pollution levels have further increased since this data was obtained and will most likely keep increasing due to proposed Intermodal. Therefore, the pollution levels cannot be allowed to increase any further risking thousands of innocent lives.

17. I oppose the building waste processing plant because Moorebank Recyclers proposal is denying the opportunity to the future residents closest to the proposed site who are yet to complete their construction and start living there.

18. I oppose the building waste processing plant because we might be creating another James Hardy situation considering the similarities of health effects of asbestos and respirable silica dust. 30 years ago it was considered perfectly fine to work with asbestos without any protection. Even at that time plenty of medical break-through were occurring. Yet, nobody banned asbestos back then. It was only years later that the real danger of working with asbestos was known. Unfortunately, for some people it was too late. However, the dangers about exposure to silica are already well known and perhaps in future we may find that it is even more dangerous than we ever knew. Despite knowing this, if this development were to go head, it not only would be an environmental and health catastrophe but it would also be a moral catastrophe where future generations may not look at this event kindly. It is unclear why despite having recently looked at the James Hardy debacle we are trying to create another James Hardie? Why are the poor people who have nowhere to go be subjected to this silica dust 24/7?

19. I oppose the building waste processing plant because I am aware of significant scientific literature which clearly states that methods often used to control dust, such as watering or screening by trees, is most ineffective when it comes to the extremely fine particles of respirable silica dust, which is an integral part of air and will follow it everywhetre.

As a community member, having bought the property in Georges Fair, I OPPOSE the building waste processing plant. I call on councillors, the NSW Parliament, the Minister for Planning, the Planning Assessment Commission, the NSW Department of Planning and Infrastructure and the Premier of NSW to REJECT this proposal.

OPPOSITION TO MOOREBANK BUILDING WASTE PROCESSING PLANT

I oppose the proposed Moorebank Waste Processing Project (Project Number 05 0157) at Lot 6 DP 1065574, Newbridge Road, Moorebank.

1. I oppose the building waste processing plant because the proposed development is far too close to existing and proposed residential homes. The proposed development is just 250 metres from the Georges Fair housing estate. Trucks using the proposed facility will travel even closer to residential homes. Trucks will likely short cut through Georges Fair, passing parks and local residents, using roads not designed for massive trucks.


2. I oppose the building waste processing plant because of the known risks from inevitable silica dust, asbestos and toxins. At the community consultation meeting held on 31/5/2011 at New Brighton Golf Club, the representatives of the developer refused to comment on whether asbestos would be processed at the facility and whether toxins would be released. It is well known that inhalable silica dust causes lung cancer and silicosis (`Occupational Exposure to Silica and Lung Cancer', Cancer Epidemiology, Biomarkers and Prevention Journal, Volume 19, 2010). There is no known cure for silicosis (`A Brief Review of Silicosis in the US', Environ Health Insights, Volume 4, East Carolina University, 2010). The building materials proposed to be crushed at the plant inherently contain very high silica content. The developer plans to install sweepers "where trucks and people will travel" and that there are "unsealed areas" in the development. Their own documentation refers to "likely dust from the recycling facility" (pg 3, developer's information distributed on 31/5/2011 at New Brighton Golf Club). This is an unacceptable health risk for local residents.


3. I oppose the building waste processing plant because of the lack of studies in a non-industrial setting of inevitable exposure to respirable silica dust of nearby residents, particularly infants, the elderly and those with pre-existing health conditions. A lot has been said in the literature about exposure limits, necessary safety gear, etc. of the grownup employees working for only around 40 hours a week in such plants but information is lacking about the unprotected residents, especially infants, growing children and elderly, exposed 24/7 to such carcinogenic environments. NSW government's own website (http://www.environment.nsw.gov.au/soe/soe2009/chapter4/chp_4.1.htm#fig4.11 ) has the following to say: "Those particularly susceptible to the health impacts of air pollution are the very young (because they are generally more active outdoors and their lungs are still developing), the elderly and those with pre-existing health conditions." Additionally, since infants breathe by mouth, thus bypassing the natural filtering mechanism of nose, they are at a much higher risk.


4. I oppose the building waste processing plant because of the known increased toxicity of freshly fractured silica that will be released from the plant than aged crystalline silica dust found elsewhere.

5. I oppose the building waste processing plant because of the potential for flooding. The proposed development is in an area that floods. In the event of a flood, unsafe building materials and material stockpiles may cause an environmental disaster throughout Moorebank and the entire Georges River Basin.

6. I oppose the building waste processing plant because the NSW Government has indicated there will be "a return of local planning powers to local communities" (`NSW govt scraps 3A planning provision', SMH, 4/4/2011). The local community is opposed to this development. Councillors of the Liverpool City Council have voted unanimously against this development (Minutes, Liverpool City Council meeting, 15/6/2011).

7. I oppose the building waste processing plant because the proposed development is incompatible with the current and planned residential and recreational uses of the area. The proposed concrete processing facility is just 250 metres from the Georges Fair housing estate, with a high proportion of residents having young families. The area is zoned E2 Environmental Conservation. It should not be used for a concrete processing plant. In close proximity are schools, parklands, the Georges River itself, cycleways, a proposed waterside marina, a library and a golf club. The land is more suitable for recreational facilities or a reserve. Even the owners of the Benedict Recycling plant at Moorebank (which borders the proposed facility) have accepted that the area is no longer suitable for a building waste processing plant and have started to shut down their operations to create their own housing estate and marina.

8. I oppose the building waste processing plant because of increased traffic. The developer states the proposed facility will result in an extra 324 truck movements a day, which is "very low and will have no impact on the arterial road network" (developer's information distributed on 31/5/2011 at New Brighton Golf Club). Increased traffic will have a significant impact on arterial roads including Nuwarra Road, Newbridge Road and Governor Macquarie Drive. There is already significant traffic in the area which will be made worse by the `Intermodal', which will cause an extra 1.5 million truck movements in the first year. Truck movements will primarily be in peak hours, further impacting on already high congestion. The residents of Moorebank and other areas should not experience any additional noise, pollution and congestion from this proposed facility, given the likelihood of the `Intermodal'.

9. I oppose the building waste processing plant because of the negative impact on land values. Residents of the Moorebank precinct in particular have spent significant amounts of money on land and homes. The proposed development will have a severe impact on land values and residents will not be compensated.

10. I oppose the building waste processing plant because there was a lack of community consultation at a meeting held by representatives of the developers on 31/5/2011. The organisers did not notify a significant number of local residents and future residents about the meeting. The organisers refused to answer questions from local residents on health risks. The organisers did not allow time to note down and respond to residents' concerns.

11. I oppose the building waste processing plant because it is dangerous to residents for a concrete processing plant to be located in this area of metropolitan Sydney. There are pre-existing waste processing plants operated by Benedict Recycling and Smorgan Steel Recycling at Chipping Norton. Benedict Recycling is planning to build another plant at Heathcote. There is no need for so many waste processing plants in such close proximity to each other.

12. I oppose the building waste processing plant because of the misleading information provided by Moorebank Recyclers in their application showing their panhandle as the access route for their trucks to New Bridge Road whereas RTA has already refused this access. The environmental assessment is meaningless without taking correct route into account to assess the impact on the nearby residents and environment. The to and fro movement of 324 trucks per day will create huge dust clouds if one goes by what their trucks were shown to do in a recent ACA report on Channel 9 titled "Housing dream shattered".

13. I oppose the building waste processing plant because of the misleading information provided by Moorebank Recyclers in their application claiming their "model to predict dust concentrations in the region and at nearest sensitive receptors" whereas the nearest sensitive locations are actually much closer than those used in their model, i.e., Georges Fair residences just across the Brickmakers Drive.

14. I oppose the building waste processing plant because the model used by Moorebank Recyclers for Air Quality Assessment is based on pollution data obtained during 2005 whereas government's own website (mentioned above in 3) says: "Emissions from the commercial and domestic sectors are growing, increasing their relative contribution to overall emissions." In view of this the modeling should be based on recent data and not some old convenient data.

15. I oppose the building waste processing plant because the model used by Moorebank Recyclers for Air Quality Assessment is based on meteorological data obtained from Bankstown Airport which is kilometers away but still "considered to be representative of conditions experienced at the project site" despite "Terrain around the site consists of gentle hills, bounding the Georges River (see Figure 2)". These types of gross assumptions are risky to be made when it comes to public health and safety especially when DECCW requirements clearly state that "Data must be representative of the area in which emissions are modeled".

16. I oppose the building waste processing plant because Moorebank Recyclers already admit in their Air Quality Assessment that "Assessment of cumulative 24-hour average PM10 air quality impacts is often complicated as there may be many occasions when background concentrations are already above the 24-hour average air quality criteria". The pollution levels have further increased since this data was obtained and will most likely keep increasing due to proposed Intermodal. Therefore, the pollution levels cannot be allowed to increase any further risking thousands of innocent lives.

17. I oppose the building waste processing plant because Moorebank Recyclers proposal is denying the opportunity to the future residents closest to the proposed site who are yet to complete their construction and start living there.

18. I oppose the building waste processing plant because we might be creating another James Hardy situation considering the similarities of health effects of asbestos and respirable silica dust. 30 years ago it was considered perfectly fine to work with asbestos without any protection. Even at that time plenty of medical break-through were occurring. Yet, nobody banned asbestos back then. It was only years later that the real danger of working with asbestos was known. Unfortunately, for some people it was too late. However, the dangers about exposure to silica are already well known and perhaps in future we may find that it is even more dangerous than we ever knew. Despite knowing this, if this development were to go head, it not only would be an environmental and health catastrophe but it would also be a moral catastrophe where future generations may not look at this event kindly. It is unclear why despite having recently looked at the James Hardy debacle we are trying to create another James Hardie? Why are the poor people who have nowhere to go be subjected to this silica dust 24/7?

19. I oppose the building waste processing plant because I am aware of significant scientific literature which clearly states that methods often used to control dust, such as watering or screening by trees, is most ineffective when it comes to the extremely fine particles of respirable silica dust, which is an integral part of air and will follow it everywhetre.

As a community member, having bought the property in Georges Fair, I OPPOSE the building waste processing plant. I call on councillors, the NSW Parliament, the Minister for Planning, the Planning Assessment Commission, the NSW Department of Planning and Infrastructure and the Premier of NSW to REJECT this proposal.

OPPOSITION TO MOOREBANK BUILDING WASTE PROCESSING PLANT

I oppose the proposed Moorebank Waste Processing Project (Project Number 05 0157) at Lot 6 DP 1065574, Newbridge Road, Moorebank.

1. I oppose the building waste processing plant because the proposed development is far too close to existing and proposed residential homes. The proposed development is just 250 metres from the Georges Fair housing estate. Trucks using the proposed facility will travel even closer to residential homes. Trucks will likely short cut through Georges Fair, passing parks and local residents, using roads not designed for massive trucks.


2. I oppose the building waste processing plant because of the known risks from inevitable silica dust, asbestos and toxins. At the community consultation meeting held on 31/5/2011 at New Brighton Golf Club, the representatives of the developer refused to comment on whether asbestos would be processed at the facility and whether toxins would be released. It is well known that inhalable silica dust causes lung cancer and silicosis (`Occupational Exposure to Silica and Lung Cancer', Cancer Epidemiology, Biomarkers and Prevention Journal, Volume 19, 2010). There is no known cure for silicosis (`A Brief Review of Silicosis in the US', Environ Health Insights, Volume 4, East Carolina University, 2010). The building materials proposed to be crushed at the plant inherently contain very high silica content. The developer plans to install sweepers "where trucks and people will travel" and that there are "unsealed areas" in the development. Their own documentation refers to "likely dust from the recycling facility" (pg 3, developer's information distributed on 31/5/2011 at New Brighton Golf Club). This is an unacceptable health risk for local residents.


3. I oppose the building waste processing plant because of the lack of studies in a non-industrial setting of inevitable exposure to respirable silica dust of nearby residents, particularly infants, the elderly and those with pre-existing health conditions. A lot has been said in the literature about exposure limits, necessary safety gear, etc. of the grownup employees working for only around 40 hours a week in such plants but information is lacking about the unprotected residents, especially infants, growing children and elderly, exposed 24/7 to such carcinogenic environments. NSW government's own website (http://www.environment.nsw.gov.au/soe/soe2009/chapter4/chp_4.1.htm#fig4.11 ) has the following to say: "Those particularly susceptible to the health impacts of air pollution are the very young (because they are generally more active outdoors and their lungs are still developing), the elderly and those with pre-existing health conditions." Additionally, since infants breathe by mouth, thus bypassing the natural filtering mechanism of nose, they are at a much higher risk.


4. I oppose the building waste processing plant because of the known increased toxicity of freshly fractured silica that will be released from the plant than aged crystalline silica dust found elsewhere.

5. I oppose the building waste processing plant because of the potential for flooding. The proposed development is in an area that floods. In the event of a flood, unsafe building materials and material stockpiles may cause an environmental disaster throughout Moorebank and the entire Georges River Basin.

6. I oppose the building waste processing plant because the NSW Government has indicated there will be "a return of local planning powers to local communities" (`NSW govt scraps 3A planning provision', SMH, 4/4/2011). The local community is opposed to this development. Councillors of the Liverpool City Council have voted unanimously against this development (Minutes, Liverpool City Council meeting, 15/6/2011).

7. I oppose the building waste processing plant because the proposed development is incompatible with the current and planned residential and recreational uses of the area. The proposed concrete processing facility is just 250 metres from the Georges Fair housing estate, with a high proportion of residents having young families. The area is zoned E2 Environmental Conservation. It should not be used for a concrete processing plant. In close proximity are schools, parklands, the Georges River itself, cycleways, a proposed waterside marina, a library and a golf club. The land is more suitable for recreational facilities or a reserve. Even the owners of the Benedict Recycling plant at Moorebank (which borders the proposed facility) have accepted that the area is no longer suitable for a building waste processing plant and have started to shut down their operations to create their own housing estate and marina.

8. I oppose the building waste processing plant because of increased traffic. The developer states the proposed facility will result in an extra 324 truck movements a day, which is "very low and will have no impact on the arterial road network" (developer's information distributed on 31/5/2011 at New Brighton Golf Club). Increased traffic will have a significant impact on arterial roads including Nuwarra Road, Newbridge Road and Governor Macquarie Drive. There is already significant traffic in the area which will be made worse by the `Intermodal', which will cause an extra 1.5 million truck movements in the first year. Truck movements will primarily be in peak hours, further impacting on already high congestion. The residents of Moorebank and other areas should not experience any additional noise, pollution and congestion from this proposed facility, given the likelihood of the `Intermodal'.

9. I oppose the building waste processing plant because of the negative impact on land values. Residents of the Moorebank precinct in particular have spent significant amounts of money on land and homes. The proposed development will have a severe impact on land values and residents will not be compensated.

10. I oppose the building waste processing plant because there was a lack of community consultation at a meeting held by representatives of the developers on 31/5/2011. The organisers did not notify a significant number of local residents and future residents about the meeting. The organisers refused to answer questions from local residents on health risks. The organisers did not allow time to note down and respond to residents' concerns.

11. I oppose the building waste processing plant because it is dangerous to residents for a concrete processing plant to be located in this area of metropolitan Sydney. There are pre-existing waste processing plants operated by Benedict Recycling and Smorgan Steel Recycling at Chipping Norton. Benedict Recycling is planning to build another plant at Heathcote. There is no need for so many waste processing plants in such close proximity to each other.

12. I oppose the building waste processing plant because of the misleading information provided by Moorebank Recyclers in their application showing their panhandle as the access route for their trucks to New Bridge Road whereas RTA has already refused this access. The environmental assessment is meaningless without taking correct route into account to assess the impact on the nearby residents and environment. The to and fro movement of 324 trucks per day will create huge dust clouds if one goes by what their trucks were shown to do in a recent ACA report on Channel 9 titled "Housing dream shattered".

13. I oppose the building waste processing plant because of the misleading information provided by Moorebank Recyclers in their application claiming their "model to predict dust concentrations in the region and at nearest sensitive receptors" whereas the nearest sensitive locations are actually much closer than those used in their model, i.e., Georges Fair residences just across the Brickmakers Drive.

14. I oppose the building waste processing plant because the model used by Moorebank Recyclers for Air Quality Assessment is based on pollution data obtained during 2005 whereas government's own website (mentioned above in 3) says: "Emissions from the commercial and domestic sectors are growing, increasing their relative contribution to overall emissions." In view of this the modeling should be based on recent data and not some old convenient data.

15. I oppose the building waste processing plant because the model used by Moorebank Recyclers for Air Quality Assessment is based on meteorological data obtained from Bankstown Airport which is kilometers away but still "considered to be representative of conditions experienced at the project site" despite "Terrain around the site consists of gentle hills, bounding the Georges River (see Figure 2)". These types of gross assumptions are risky to be made when it comes to public health and safety especially when DECCW requirements clearly state that "Data must be representative of the area in which emissions are modeled".

16. I oppose the building waste processing plant because Moorebank Recyclers already admit in their Air Quality Assessment that "Assessment of cumulative 24-hour average PM10 air quality impacts is often complicated as there may be many occasions when background concentrations are already above the 24-hour average air quality criteria". The pollution levels have further increased since this data was obtained and will most likely keep increasing due to proposed Intermodal. Therefore, the pollution levels cannot be allowed to increase any further risking thousands of innocent lives.

17. I oppose the building waste processing plant because Moorebank Recyclers proposal is denying the opportunity to the future residents closest to the proposed site who are yet to complete their construction and start living there.

18. I oppose the building waste processing plant because we might be creating another James Hardy situation considering the similarities of health effects of asbestos and respirable silica dust. 30 years ago it was considered perfectly fine to work with asbestos without any protection. Even at that time plenty of medical break-through were occurring. Yet, nobody banned asbestos back then. It was only years later that the real danger of working with asbestos was known. Unfortunately, for some people it was too late. However, the dangers about exposure to silica are already well known and perhaps in future we may find that it is even more dangerous than we ever knew. Despite knowing this, if this development were to go head, it not only would be an environmental and health catastrophe but it would also be a moral catastrophe where future generations may not look at this event kindly. It is unclear why despite having recently looked at the James Hardy debacle we are trying to create another James Hardie? Why are the poor people who have nowhere to go be subjected to this silica dust 24/7?

19. I oppose the building waste processing plant because I am aware of significant scientific literature which clearly states that methods often used to control dust, such as watering or screening by trees, is most ineffective when it comes to the extremely fine particles of respirable silica dust, which is an integral part of air and will follow it everywhere.

As a community member, who would soon be living in Georges Fair, I OPPOSE the building waste processing plant. I call on councillors, the NSW Parliament, the Minister for Planning, the Planning Assessment Commission, the NSW Department of Planning and Infrastructure and the Premier of NSW to REJECT this proposal.

Paul Phillips
65 Bradbury St
Moorebank, NSW 2170

RE: Objection to Proposal 05_0157 Moorebank Recyclers

I wish to submit my objection to the above proposal, based on the below.

Director General's Requirements
The DGRs were issued in July 2006, almost 7 years ago, surely they must be re-issued taking into account up to date information, such as the 1000+ homes planned (and existing) for the neighbouring properties (Benedict and Georges Fair/old Boral).
With the preliminary EA also dated in 2006, it does not sufficiently take into account the residential growth in the area, with the close proximity to the proposed site.
Part 3A of the planning code has been scrapped, why is this ridiculous development being allowed ot be submitted and assessed under an out of date, scrapped government legislation?
Figure 2 of prelim EA does not adequately show residential growth from when aerial photo was taken 7 years ago - hundreds of additional families are living within 200m of the proposed site, they have not sufficiently looked at this
PEA refers to existing Boral site, and future residential, residential has been in place for over 5 years, this goes to show how out of date the information is (7 years)
PEA refers to LEP dated 1997, forgetting that this was updated in 2008, 5 years ago, and 2 years after the out dated EA was initially prepared

Site Access
In the Director General's requirements, it is said that the proponent must have site access approval before submitting this request. The site access documentation and land owners consent attached with the submission are out of date, as council rescinded land owners consent in a memo to Moorebank Recyclers, dated June 2011. The Proponent's other `option' for site access is also not agreed, as the proponent is in court proceedings with the council regarding the establishment of an easement across two separate lots under council control. The date of these proceedings is for the end of May 2013, with a decision expected by late 2013, early 2014. I do not see how this submission could have gone ahead without the DGR's being fulfilled. There is also a proposal with RMS currently (submitted Nov 2012) to make the entire length of Brickmaker's Dr (from Newbridge to Nuwarra) a 5t load limit.
With their designs for site access, they are forgetting that Benedicts will be building a bridge between their own site and Brickmakers drive through/over lot 309, and the courts have denied MR access to use to that road/bridge as their site access.
By building the proposed access road earthworks, they will remove 3500m3 of flood water storage from within a flood plain, when residential homes are right next door, that's clever.

Traffic/Trucks
The data in the EA traffic report is severely flawed, they have not sufficiently taken into account the growth of the Georges Fair residential estate, nor the proposed Georges Cove Marina development, and associated residential development. The no left turn signage, and associated concrete barriers designed to stop trucks turning left onto brickmakers dr from the access road will not be in place, as this access road/bridge is being built as part of the Georges Cove development (development of the current Benedict's site), and these traffic adjusters are not part of this. Regardless if they were in place, trucks already drive over existing concrete barriers etc on Brickmakers Dr, so why wouldn't the proponents trucks do this also as a shortcut to the M5
The EA continually says they will be accepting trucks from 6am, with crushing to start at 7, but all there traffic data refers to trucks timings starting at 7am and finishing at 6? What time would these trucks be queuing up from, idling noisily alongside existing housing to get access to the site?
The estimated number of truck movements per day is also flawed, as it is based on 10 year old data regarding the estimated amount of recycling that will be done on site, and the estimate of how this will be handled., what happens when they decide it is more efficient to run double the trucks with smaller loads, that would drastically change the use of an already busy road & intersection, especially during peak hours.
Their traffic data must be flawed, any local person can tell you that the local main roads and intersections are not performing satisfactorily during the peak times, with Brickmakers drive backing up for approx 1.2km when trying to get onto Nuwarra Rd in the afternoon peak (from 400pm onwards), and between 8-9 am, when trying to turn onto Newbridge Rd from Brickmakers Drive, there is substantial traffic bank up, taking upwards of 10-15 min to travel 200m to the intersection.
An additional estimated 324 trucks per day will not help this situation in the slightest, but make it much worse, in the EA, they also say that they will increase heavy vehicle movements on the local roads on weekdays from 1 every 2 minutes, to 1 every minute, effectively doubling the trucks on the local roads, driving past people's homes, using their noisy air brakes to slow down for intersections.
The table showing estimated truck movements for each hour of the day is at odds with earlier in the report. In the earlier sections, they say there will be around 19 in and out during 8-9 am, here they say 7.52 and 21 in and out between 4-5, here they say 4.18- more flawed data. They also still neglect the trucks entering before 7am to drop off loads.
This table does not add up to 324 truck movements per day, so can we assume the other app 250 truck movements will be between 6-7 am and 5-6 pm???
They also claim here that their trucks would be distributed to Nuwarra Rd (directly along Brickmakers Dr perhaps?
They have estimated the number of daily truck movements based on 2003 data, which is hopelessly out of date
They are proposing only 16 vehicle spaces, how will this work when thy have two water trucks, a number of service vehicles and a fuel truck? Surely they can't expect their staff (20 of which could be assumed to be onsite at any one time), to park kilometres away and walk to work?

Dust Generation
The use of `misting sprinklers' to control dust released is ludicrous., dust will be flying off the trucks entering site, driving around site, off loads that are dumped onto stockpiles, off the stockpiles themselves, and when the material is processed. When house-sized chunks of concrete are broken up, outside of the sheds, toxic silica dust will freely enter the airstream from the prevalent E/NE winds, and be carried the short distance of 200m to existing homes, ready to be breathed in by parents, children & pets. When the sprinklers fail, or are turned off outside of operating hours (they will not be running 24/7 that is guaranteed), this toxic silica dust, along with who knows what else will be free to blow around the site, blow over existing homes, and also be carried off to land in the Georges River itself, already an ecological disaster, but one that is being worked on.
The proponent's existing recycling facility at Camellia is a great generator of dust, with similar dust reduction systems in use as proposed in Moorebank facility - nearby residents (350m) are having to wash/scrub their houses daily. They claim their neighbours have no issues, they are talking about the industrial neighbours, not the residential a short wind gust across the river.
Misty sprays will be used to ensure stockpiles form a crust to stop any dust being generated, what about when the particles are too fine to be stopped by misting sprays, or when the dust that is present clogs up the sprayers, I am quite sure that they will not be misting the outside of their stockpiles, where the wind will carry silicosis-causing cement dust particles, ready to infect my family's lungs
Spraying water on piles of dust will just cause the dust to fly off anyway, and if the wind is strong enough (and it is in this area), the wind will blow the misting water away from the stockpiles, taking the dust with it, carrying it for kilometres and depositing it across homes, environmentally sensitive land, shopping centres & schools.



Noise
Noise of excavators with rock breakers breaking apart concrete chunks is louder than Benedict's current noise (which EA models their noise off)
Proponent frequently makes note of existing Benedicts noise, yet easily forgets that Benedicts are relocating, and building residential & a marina (how easy is it to forget a proposed development when you are the only one who objected to it). They make use of existing Benedicts noise, claiming it will help to mask their own noise generated
Assessment of noise levels is incorrect, as they state homes are over 500m from the site, when homes will be within 200m of the site
Measurement of existing noise levels is taken between existing Benedicts site (east of proposed site) and Eloura Cres (west of GF residential), and they think the noise found here would be higher than GF residential from their own site, ridiculous
I highly doubt that a noisy, dusty concrete and building waste recycling facility will not have a detrimental effect to local endangered wildlife
Noise recordings taken in Feb & March 2007 are apparently considered still relevant, especially when there is an additional few hundred homes between the MR site and where noise recordings were taken
Predicted traffic volumes for brickmakers drive are used to play down MR site's noise generating, claiming that this traffic noise will basically drown out the MR site's noise, claiming that all cars will be travelling at 60km/h on a 50km/h speed limited road - more flawed data in the out of date EA.

Visual Impact
The EA states that the crushers are 12m (primary) and 10m (secondary) high, how does the proponent intend to house these crushers inside up to 10m high and 8m high colorbond sheds? Surely he doesn't intend to bend the rules of the universe to allow something taller than the shed be housed inside it?
What happens to the `negligible' visual impact when a bushfire roars through and burns out all of the greenbelt hiding the facility?
Under Visual Impact, proponent claims there is zero exposure of the land to existing residential, this is incorrect, as homes at the top of Bradbury Street can see the open area where the site is to be located, and the 6-storey unit blocks in construction on Nuwarra road would also have a great view of the surface of the site



Flooding Potential
The proponent says they will have a 10m wide wall of stockpiled material, of varying height, obviously this wall will not be in place for very long.
Flood waters can still enter site where the trucks enter
The EA says land is not suitable for building due to prior landfilling, how can it be suitable for buildings now (sheds, offices etc), and for heavy crushers etc?
The water runoff data throughout the EA is entirely contradictory, at some places saying all runoff will be captured in storage tanks, in other places saying that surface runoff will exit the site through openings in the `wall' surrounding the site, running into the Georges River, and allowing an easy entry point for possible `inland tsunami' floodwaters to enter the site, allowing all the toxic cement dust to flow freely through the waterways, causing unknown environmental havoc.
Parts of the EA say that they are going to be draining all surface runoff directly into the Georges river, that's a great idea for pollution, let's just allow concrete and asphalt dust directly into the environmentally challenged river.
Apparently, approved earthworks will protect the operational facilities from floodwaters, not the potentially toxic material stockpiles, which could wash away down river causing who knows what damage to the environment.
Water usage of 130kL daily, based on maximum used at existing facility - what they don't say is the huge amount of dust still generated at that existing facility and how the water misting sprays do nothing to stop it (Camellia facility, as seen on A Current Affair story March 2013)
Where they speak of `only fractionally more overflow events' (from water storage tanks) - they mean to say 25% more, which is not the small fraction they claim.

Air Quality
They specify that there are few winds from N/NE , with the most predominant being from the NW. This is incorrect, the majority of winds are from the E/NE, with Southerlies and other general directions also occurring less frequently. Dust generated on site WILL be easily blown the short 200m to residential homes with young children, causing untold numbers of health issues





In conclusion, I have nothing against recycling, and nothing against industry. My issue is with the placement of said industry, there is a place for everything, and smack bang between two residential communities of over 1000 homes is not the place for a concrete recycling facility. Perhaps the proponent would do better to acquire land far from residential, in an industrial precinct for his industrial facility.
The proponent paid $10,000 for this land 10-15 years ago, and is simply trying to put an out of place facility there, simply because he feels he can. I doubt if he would enjoy living 200m from one of his facilities.


Sincerely
Paul Phillips

Please find attached a submission setting out our objections to the Proposal 05-0157 as well as a judgment of the NSW Court of Appeal which underpins some of the key points we have made in our objection

It is just 1 hour 30 mins away from the dateline of putting in my objections. I have also attached objection letters from my neighbourhood who share my concern on the hazards especially health and safety that are related to Moorebank Recycling work if such work were to be approved. We are scared. We are angry. We are disillusioned with the whole system. We are cheated. We just feel lost. Please stop it. I am scared of being exposed to asbestos. Please understand us. Please help us.

Submision Documents attached