Moss Vale Plastics Recycling Facility

To Whom It May Concern,

Please find attached my objection to the Moss Vale Plastics Recycling Facility, Project ID SSD-9409987.

Yours faithfully,

Marie Davison

See attachment

To Whom it May Concern,

As set out in the EIS, Plasrefine Recycling Pty Ltd proposes to work with PET, HDPE, LDPE, PVC, PP and PS.

Plasrefine does not provide any information, MSDS, reports or data which sets out the toxicity of the various plastic types that they propose to use. In particular Plasrefine’s documents are silent as to the toxicity of PET, HDPE, LDPE, PVC, PP and PS specifically when heated.

Plasrefine’s documents do not set out any specific plastic material melt temperature data, for each type of plastic they intend to work with (example of such a table attached and marked A), they provide a generic up to heating point indicator.

Plasrefine’s documents do not provide any thermogravimetric analysis setting out the temperature at which volatile organic contents are released from the material upon heating (separate to any cold state data).

Plasrefine’s documents do not provide any data as to the precise levels of VOC that may be released, notwithstanding the proposed ventilation plans.

Separate to obvious traffic and congestion concerns, the airborne toxins that may potentially be released from the proposed plant, inside the plant itself and out into the environment, may cause respiratory conditions. Further, some additives to plastics may be carcinogenic; for example:

1. Styrene’s various forms and makeup in particular include “R20 harmful by inhalation”, “R36/38 irritating to eyes, respiratory system and skin”, “R45 may cause cancer”. (Attached and marked B extracts from April 1999 National Occupational Health and Safety Commission, List of Designated Hazardous Substances)

2. Polypropylene (PP) may contain a form of ethylene, which depending upon its chemical makeup and what occurs to the product during heating includes “R20 harmful by inhalation”, “R45 may cause cancer,“R46 may cause heritable genetic damage”. (Attached and marked B extracts from April 1999 National Occupational Health and Safety Commission, List of Designated Hazardous Substances).

As a consequence it is imperative to know what is the precise chemical makeup, including CAS numbers as a minimum, of each of the plastics that are proposed to be heated and as at the point of heating.

In light of the above I object to the proposed project.

While I can see the benefits of such a facility, I very strongly object to the proposed location. The roads that will be used to access the area are totally unsuitable for the traffic that will come with this project. I am very concerned for the safety of my three stepchildren, and indeed all of the children, who live in this area. It would not take long at all for an injury or fatality to occur, given the number of trucks that will be on residential streets.

I am not saying no to having this is the Southern Highlands, I am saying no to this location.

I write to voice my strong objection to the proposed Moss Vale Plastics Recycling Facility.

I am a resident of Moss Vale, and live here with my husband and our two young children, Oscar and Sam. They both attend the Southern Highlands Early Childhood Centre which is situated just several hundred metres down the road from the proposed site. To be honest, it is astounding to me that this location could even be considered for such industry. There is nothing more important to me than my children's health and safety. And this proposed project puts those at risk.

The increase in traffic through a primarily residential area through both the construction and operation of the factory will undoubtedly increase the risk of traffic incidents in the surrounding area. Stories of young children being injured or even killed in and around daycare car parks are already too frequent - adding hundreds of vehicles to Beaconsfield Road increases the risk of incident considerably - especially when you consider there are no footpaths on these roads.

Perhaps even more concerning: the evidence on the toxicity and dangers of plastics - particularly as it relates to the endocrine systems of young children (especially boys) and pregnant women has been building steadily over the last decade and is well documented in peer-reviewed scientific research - how then do you justify the heating of such compounds and products within a light breeze's trajectory of a day care? Noting especially that the Highlands and notoriously windy, so even the smallest amount of pollution released outside the factory walls will be carried far beyond its boundaries.

I understand the need to build a strong recycling industry in Australia - however, given the great expanse of NSW, surely there are countless locations that also boast adequate proximity to major cities, but pose far less risk to communities and local economies? The Southern Highlands is renowned for its natural environment, and the potential for regenerative economic growth - focused on regenerative agriculture, eco-tourism, food and wine and community events - in the coming decades is huge. Putting a high risk, highly toxic factory within growing communities seems completely at odds with the potential and brand of the Southern Highlands.

I could go on at length at the many ways in which this proposal is problematic, and I'm sure many others will highlight the myriad concerns. But in closing I come back to my opening sentiment. Plastics are highly toxic, particularly to young children and pregnant women. The proposed site is less than a kilometre from a childcare centre with 20 staff (all young women), and 70 children, five years and under. My children are among them, and this proposal terrifies me. It is simply not a safe location for such industry, and it feels completely at odds with the Premier's stated priorities around customer-centricity, community and environment.

Kind regards,
Nathalie Swainston

I am a resident and rate payer of Moss Vale and the Wingecarribee Shire with a young family.
I strongly object to the proposed development and am highly concerned regarding:
- first and foremost, the effect that the pollution will have on my baby and future children
- the pollution such a factory will bring to the pristine Southern Highlands including; air quality and odours, water pollution directly to a Sydney drinking water catchment, flooding and further waterway/stormwater pollution
- toxic residues and toxins in plastic dusts, emissions on westerlies and that emissions are currently modelled, emissions being carried to other towns and villages in the Southern Highlands
- the increase of heavy vehicle traffic on our local roads that are already severely inadequate, and road noise arising from this same issue
- the ambiguities and lack of straight answers for the community from the ownership group and community engagement group GHD of the proposed factory and no meaningful community consultation
- the company is owned by Chinese nationals which have no prior experience in operating a plastics recycling facility, let alone to this scale
- inconsistent information from the proponents regarding employment at the proposed development which remains unclear for providing jobs to local employees
- the disruptions and adverse impacts to the neighbouring Garvan’s Institute which provides critical medical and scientific services
- impacts on the booming Moss Vale property market
- the visual impact of the proposal on local residents and adverse impact to the landscape character
- the effect on category 2 riparian wetlands that flows directly to the Wingecarribee River (a Sydney drinking water catchment)
- exponential water use by the proposed facility
- EIS:- Figure 12.4 and 12.5 Noise Contour is modelled on the way to avoid residential suburbs. The contour has been intentionally modified as there is no natural or other barrier currently in situ.
- Occupational health and safety hazards such as hazards at the plastics melting stage, no emergency measures in the event of a factory fire, no details of plastic sludge disposal
- The proposed development is located:
· Less than 2 km from the Town Centre of Moss Vale.
· Less than 1 km from the residential suburbs of Moss Vale
· Less than 200 m to the first residences
- There is:
· No buffer zone for air quality and odour
· No buffer zone for noise and vibration
· No buffer zone for fire hazard
· No plan for evacuation in case of any accident including surrounding residences as well as future employees.
The EIS is comprised of technical errors and inconsistencies, and does not address many areas of concern raised by the community such as occupational safety an The EIS does not meet the required standards and the level of details expected of an EIS for such a scale of state significant development. The proposed development cannot be seriously considered by any authority based on the submitted EIS.

In addition to the EIS, the LES stated as the potential cumulative hazard (page 284):
· Noise and vibration - 1.6km radius surrounding the proposed plastic and reprocessing facility site
· Air Quality and odour – 1.2km radius surrounding the proposed plastic and reprocessing facility site
· Landscape and visual – 2km radius surrounding the proposed plastic and reprocessing facility site
· Aboriginal and cultural heritage – 10 km radius surrounding the proposed plastic and reprocessing facility site
· Biodiversity – 10 km radius surrounding the proposed plastic and reprocessing facility site.

I strongly object

There are far too many questions and doubts about this proposed development for it to proceed to the next stage unless there is much more scrutiny.

Based on reading the proposal, those questions and doubts include the following in summary:

SITE ACCESS AND UNSUITABILITY OF DEVELOPMENT SCALE

Road network not suitable and infrastructure lacking
Height and scale of development is out of keeping with area and will impact visually from a distance

TRANSPORT ISSUES
Volume of projected traffic is excessive for road system and nearby residents
24/7 operation gives no respite from noise and traffic movements
Traffic movements will impact other areas aside from development site

ENVIRONMENTAL ISSUES
Emissions of all types from site are not well documented
Prevailing winds from south will disperse odour or toxic content into Bong Bong Common, river and bike track
Water catchment risks not addressed adequately
Recent floods have shown resetting of flood plains are needed

INFORMATION LACKING & TECHNOLOGY QUESTIONS
Many questions have not be answered with objective third party investigation

LACK OF COORDINATION WITH AN INDUSTRY AND GOVERNMENT APPROACH
This seems to be a project that is no longer allowed in China so the solution is to establish it in Australia but where is the evidence that this technology and waste management solution is actually state-of-the-art or is what the future requires. Will implementing a lesser standard operation make other future solutions less economic.

I object to the project on the grounds of the unsuitability of the site:
The impact on and use of groundwater during production. There are sites already for industrial use of recycled water!
Air pollution - air quality. In the midst of Moss Vale village - residential, schools, farming.
Why are we selling out once more to overseas investors? Another ferry/train debacle? Needs to be an Australian operation - creating jobs and profits for our economy.
Traffic - large vehicular traffic on backroads.
Surely this needs to be a more remote site.

I do not support this project. The proposed site is unacceptable for this type of industrial use. It is adjacent to homes and day care centers. Toxic fumes will blow towards homes and residential areas. The vehicular route in and out will add an unwelcome level of commercial use adding noise pollution. It will detract from the visual appeal of the agricultural land.

Items of objection/requests for information contained in the accompanying submission

I hold great concerns about the project and it's location.
These include:
impact on environment particularly as we are a catchment area - including noise, gasses and pollution
proximity to conservation areas
position inside town boundary
proximity to houses (within 150m) and child care facility
impact of noise and pollution on community
access to the site and increases in traffic in town already overwhelmed by local traffic - unsuitability of Beaconsfield rd access
lack of local infrastructure to support the project
toxicity of waste
waste disposal
size of the project
operations of the factory and impact of this on town's residents including lighting and trucking 24 hours a day and noise this will create

In addition there are no plans, scale drawings only excessive size of factory in relation to site and no balance in design or consideration for rural aspect and landscapes areas.

The use of resources is also concerning including the proposed use 46,300L of water every day when local water storage is only 150,00L
Pumping of 16,300L of contaminated water a day into sewage system.

In addition the plans are at odds with the community and would have social impacts including on our sense of community, rural way of life, tourism, access and use of facilities and infrastructure in our towns. As well as impact on wellbeing, health and personal property.

This is not a suitable location for this project and there has been little communication and consultation with our community who would like to preserve the rural lifestyle for which our townships are known

To whom it may concern,

I write to strongly object to the proposed Moss Vale Plastics Recycling Facility – Plasrefine. Although I am not opposed to recycling of materials, I believe the proposed site for this facility is not appropriate for a number of reasons.

The site is in close proximity to the residential area of Moss Vale. The facility will reduce the visual amenity of this area and potentially poses a risk of air, water, and noise pollution to nearby residents. This will also decrease land value and quality of life for the surrounding residents. There is considerable opposition to this project in not only the Moss Vale community, but Southern Highlands community as a whole.

The site is bordered by two riparian zones and will require modification to at least one of these zones for construction of the facility and treatment of waste water. A Development Application in 2019 (DA 19/1525) for a two-lot subdivision of the site was rejected citing that the land is flood prone. The site is also part of the Sydney Water catchment and the potential for surface water and ground water contamination should not be discounted.

The 2019 Development Application (DA 19/1525) was also rejected on the grounds that there would be significant adverse impact on residential amenity and safety with the construction of Braddon Road. The Plasrefine proposal favours Braddon Road as the preferred access option. This road requires the purchase of properties including part of the Australian BioResources (ABR) site owned by The Garvan Institute for Medical Research.

The current entrance to the driveway for ABR is not in a suitable site for heavy traffic as there is a significant rise to the North of the entrance on Lackey Road. Vehicles travelling South on Lackey Road from Collins Road may be at risk of colliding with vehicles waiting to turn right into Braddon Road. As an employee of ABR this is a great safety concern for myself and my colleagues.

Given the volume of traffic suggested in the EIS for the Plasrefine site, the suitability of Lackey Road is also questionable. During high rainfall events, such as those witnessed earlier this month, Lackey Road becomes flooded. Areas of Collins Road and Douglas Road also become flooded. This not only restricts traffic flow, it results in significant damage to the road surfaces. Such damage will only be worse with increased traffic along these roads, posing a further safety risk to the community. The cost of maintaining these roads will increase at rate-payers expense.

The potential fire risk of the facility is also a great concern. The EIS states that the site is not subject to bushfires. This does not account for the possibility of grass fires and the devastation they too can cause. There are countless examples of fires in recycling facilities and whilst there will be no stockpiles of flammable materials outside of the Plasrefine buildings, should a fire occur within, it will be very difficult to control.

The risks posed by construction and operation of the Plasrefine facility to the neighbouring Australian BioResources facility should not be discounted. The NSW Government contributed a significant amount of money to building the Garvan-owned facility. Should there be impacts on the breeding abilities and health status of the mice at ABR this money will have been wasted. Millions of dollars in research grants will also be at risk should there be an adverse impact on the ABR facility. Will Plasrefine provide some form of indemnity to The Garvan Institute? How will the 50+ employees of ABR be compensated for their loss of income and job security?

Finally, I have serious concerns about the capacity of the Plasrefine proponents to operate the facility safely. The proponents have no prior experience in constructing and operating a plastics recycling facility and it is not clear where they have drawn their expertise from in developing this proposed use for the site. Should there be issues with the facility where does the accountability lie? Will it be up to the residents of Moss Vale to lodge complaints about noise, water and air pollution? How will Plasrefine be held to account for ensuring that their activities do not impact on local residents, neighbouring businesses, and the environment? Who will monitor traffic flow and numbers to ensure that Plasrefine are complying with the conditions of approval of the project?

Please consider my objections in the review of the EIS and subsequent decision on the future of the project. Put simply, this is not the right site for a plastics recycling facility.

Regards


Joanne Dodd

M. Sus. Ag.
Grad. Dip. Ecology & Management
Grad. Dip. Ed.
B. Ag. Sc.

The project will create pollution over the entire town, the prevailing westerly winds will blow towards the main town.
It is too close to residential land.
Too many movements of trucks.

This heavy industry proposal is out of character to the Southern Highlands, located in an inappropriate residential area within Sydney water catchment. Made by a company with no local knowledge by a company who's main benefactors live in China. Moss Vale residents strongly object to the proposal.

I am writing this submission to object to the construction and operation of the plastics recycling facility (Plasrefine) which is proposed to be located on 74-76 Beaconsfield Rd, Moss Vale NSW 2577 SD-9409987.

With an additional 40-50 trucks every day, not including an additional 60 light vehicles as well as any other trucks required to transport sludge and other plastic waste, there will without a doubt be additional pressure on the local roads, impacting traffic and leading to further congestion in and around Moss Vale.

It was outlined during the community sessions that the average load of trucks transporting the plastic will be 20,000 tonnes. Although the specific type of truck used was not outlined, I am concerned that the increase of these heavy vehicles on local roads will lead to an increase in risk of accidents on our local roads especially due to the inadequate existing road infrastructure and pedestrian pathways. It was only this year that a cyclist was killed on Mereworth Road at Berrima (approx. 10 min away from the site).

The noise generated from the increase in trucks on the Moss Vale roads cannot be underestimated. Consideration must be given to the current rural ambience and general quietness of Moss Vale. This site is located in and amongst residential area, the noise from the movement of the trucks will be disruptive and constant at minimum from the hours of 7am – 6pm.

The Traffic Impact Assessment undertaken in Dec 2020 was during covid and prior to many people relocating from Sydney city to Moss Vale. The timing of this Impact Assessment would not adequately consider current traffic conditions and movements on Moss Vale roads. An updated Traffic Impact Assessment should be undertaken to comprehensively understand the impact of the additional trucks and light vehicles on Moss Vale roads.

I object to this project in the current location based on the following factors: There is totally insufficient road access to the site without using narrow residential roads. These roads have school children and young families on them all day without even have a footpath. The damage to these roads with the volume of articulated lorry's on them will be significant, the potential for accident, injury or worse is greatly increased by this proposal. There will be considerable noise and light pollution from the site which is just ridiculous to plan to have something running 24/7 being accessed through entirely residential roads and next to residences. There is vastly insufficient detail around the contaminants being released into the waterways and atmosphere in a residential setting with families., schools and daycares. I think it is wholly ridiculous in state as big as NSW that an application is even being entertained when it is so close to waterways, residential and commerce. There must be a better location.