Moss Vale Plastics Recycling Facility

The proposed development by Plasrefine Pty Ltd on riparian land within Sydney’s water catchment is an unacceptable risk heightened by the variability and extremes of climate change.

Plasrefine has been unable to demonstrate the operational experience to manage a waste facility of the scale proposed under Australian regulatory requirements.

What measures would Plasrefine Pty Ltd be required to undertake to ensure the sustainable management of site riparian zones through construction and operation?

Would the monitoring and preservation of the site riparian zones be incorporated into Plasrefine's operational licence and supported by independent water quality test results?

As a clinical psychologist, I support children, adolescents and families within the Wingecarribee region. Environmental anxiety and concerns have a significant mental health impact on both individuals and communities Despite the nominal purpose of the proposed facility being recycling, the EIS raises additional concerns including:
- Exposing the community to microplastics, which have known health and environmental impacts.
- Dust and particulate emissions.
- Use of greater than 46,000: of water per day to wash plastic waste (partially sourced from town potable water).
- Release of over 16,000L of contaminated water into the sewerage system.

I am concerned by the lack of Social Impact Statement (despite repeated requests from residents and Wingecarribee Shire Council) given the high likelihood of negative impact on the emotional health and social wellbeing of the community including:
-The close proximity of this facility to residential areas (within 150 meters of its closest residential neighbour).
- Significant noise and light pollution, which is inevitable given the scale of the proposed facility which will be in operation 24/7.
- The potential for sleep disturbances for local residents due to project amenity noise (which has an enormous impact of physical and emotional wellbeing).
- The vastly increased traffic volume (largely consisting of large trucks) will need to move through residential areas in order to reach the facility.
- The potential for negative impact on property values for residents who live in close proximity to the facility.
- The potential for negative impact on local businesses such as tourism and wineries.

I have spoken to many local residents who are impacted by the proposed facility and have seen their distress, both due to the proposal but also due to their experiences with GHD. These experiences have been shaped by GHD’s approach to consultation which has actively created barriers to community participation, avoided clear and transparent communication, and minimised the emotional impact of this proposal on residents.

I strongly oppose this proposed facility being built in it's current location. It is clearly not the right site.

The location of the proposed Plastic Recycling Facility is totally unsuitable. It is within 200 metres of residences and most importantly, it is 700 METERS FROM A CHILD CARE CENTRE!!! Plastic recycling causes toxic waste. The children will be breathing the waste all day. Is this what the NSW Government has in mind for children of NSW?
The proposal indicates that the toxins and residues are to be washed away - into a waterway that feeds directly into the Wingecarribee River. This will affect the health of the population of the Sth Highlands, and also recreation.
Furthermore, when there are prevailing westerly winds, the airborne emissions will travel widely throughout the Sth Highlands.

I STRONGLY object to this proposal.

This project will significantly impact where we reside and impact the community around us. We already live on a busy road that will become increasingly worse if this project goes ahead. There is to date, no detail of the required construction for the proposed access road from Lackey Road which makes you wonder, amongst other decisions in this project, how this can be accurately costed and has it actually been planned!? Then there are the traffic issues related to this, the excess noise from the multitude of large trucks and ofcoarse the impact these types of vehicles have on our already pot hole filled, narrow streets.
The impact this project will have on water and air quality is another great concern the whole community has. The Highlands is a place of lush, green pastures and fresh air and fresh water creeks. There will be odour from plastic waste bales, storage, processing, wastewater facility and toxic residues. Currently no modelling has occurred to assess the emissions this will expel which is of great concern. The water usage is in excess of 46,300L everyday coming from a combination of rainwater harvesting and potable town water, absolutely not ok in a location that has in most recent times suffered through drought and dreadful bushfires, not to mention a current 150,000L water storage tops which will last what 3 days.
Overall, there are so many ways this project impacts on this beautiful community that you would honestly need an essay space to list them all. We strongly object, we understand that we need a recycling plant somewhere but this is absolutely not the right place. Somebody with common sense and half a brain needs to come up with an alternative in a state that is vast and has a multitude of other locations that would be more appropriate. Please let common sense prevail.

Submission in Objection to the Plasrefine Proposal # SUB-39480484

I object strenuously to the proposed Plasrefire Plastic Recycling Facility in Moss Vale as follows:

The EIS is full of technical errors, inconsistencies and does not address many areas of concern such as occupational safety and hazard at the plastic melting stage, emergency measures in the event of a factory fire. There are no details of plastic sludge disposal, protection of Riparian zone . The EIS does not meet the required standards and the level of details expected of an EIS for such scale SSD. On these points alone, I posit that the proposed development cannot be considered seriously by any authority based on the submitted EIS.

Here's some more in depth analysis of this deeply flawed proposal. Based on the requirements of the SEPP 33 the proposed development is potentially hazardous in nature as it involves plastics and polymers for reprocessing. While the plastic products prior to recycling or final products may not be hazardous and toxic there are some stages in the reprocessing of each of those plastics are hazardous and toxic as discussed below.

Section 7.5.1 of the EIS lists six types of plastics and polymers which will be crushed (powder will be in the), melted at a high temperature and molded into new plastic products. Nowhere in the EIS does the proponent show how this will be done. The Material Safety Data Sheet (MSD) indicates that two of plastic types proposed for recycling are potentially explosive in the powder form. Other byproducts like plastic sludge is deadly to the environment (water, wildlife, humans, soil) and cannot be disposed of just anywhere like in Bowral waste facility as GHD report suggests.

In figure 12.4 and 12.5, the Noise Contour is modelled on the way to avoid residential suburbs. There is no natural barrier or any other barrier, so obviously that contour on both maps is to be intentionally modified. Instead of identified hazard zones, the LES stated as the potential cumulative hazard (page 284):
· Noise and vibration - 1.6 km radius surrounding the proposed plastic and reprocessing facility site,
· Air Quality and odour – 1.2 radius surrounding the proposed plastic and reprocessing facility site,
· Landscape and visual – 2 km 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.
There are significant residential areas within the Moss Vale and the surrounding rural residences as well as Early Childhood Learning Centre and other facilities will be significantly compromised by the above hazards if the proposed plant is approved.

The proposed development is not suitable use under the State Environmental Planning Policy 2011 No 511 and includes the Chapter 6B of the Occupational Health and Safety Regulation 2001 for the following reasons. 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.
· Directly adjoining Primary Production Small Lots area.
· Less than 1 km from Early Childhood Learning Centre.
· There are a number of archaeological sites including Aboriginal Sites of heritage values.
· There are only local roads and no any major thoroughfare easy accessible.

In summary, the EIS does not address adequately any possible hazard:
· 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.

In addition, the design details included in the Plasrefine EIS regarding proposed plant and equipment and processing flow sheets are entirely inadequate and therefore insufficient to allow an informed submission on most aspects of the project. The EIS makes a number of assumptions about the likely delivery routes and the sort of vehicles that would be involved. However, the feed materials would be processed off-site by third parties and they would be using transport providers independent of the Proponent, thereby making it impossible for the Proponent to make good any promises made in their application.

The proponent proposes to manage the air quality issue by installing “fast opening and closing” roller doors on the plant to minimise the escape of any toxic substances. This ludicrous solution is unmanageable with so many trucks arriving throughout the day and night. The opening and closing of these doors would delay the delivery of materials, cause a back up of trucks with nowhere to wait other than the narrow suburban streets thereby creating noise and exhaust emission pollution as well as a significant traffic hazard.

The proposed access route to the facility requires private land acquisition on a number of adjacent properties and there is no guarantee that this will actually occur. It would be highly disruptive to the neighbours involved and may well incur considerable extra costs for the already cash strapped Wingecarribee Shire Council and its ratepayers.

The proposed plant site is remote from existing infrastructure for the supply of power, water and sewerage, and the existing infrastructure is inherently inadequate for the site’s needs. This would require considerable Council outlays at the Wingecarribee ratepayers’ expense with doubtful offsetting benefits. This issue should have been highlighted by more comprehensive engagement with the Wingecarribee Shire Council and the provision of a Social Impact Study at the outset.

Finally, the scale of the proposed development is overwhelmingly inappropriate for this location at 17 metres high and 120 metres long. The whole plant covers 38,000 square metres of total floor space (the size of around 6 average soccer fields) and that doesn’t include concrete driveways or parking areas. The impact of this large structure is further exacerbated by the significant slope of the land to the northeast. This presents totally unacceptable views of bulk and scale.

I am extremely concerned about the imminent construction of the Plasrefine facility. The Southern Highlands has long been an unspoiled piece of rural paradise just under 2 hours from Sydney. We have a thriving economy and tourist trade, all of which would be spoilt by this plant.
As with Hume Coal, there is a real need for transparency from companies looking to build facilities in the area that do not benefit the local community, its health, or the biodiversity of the area.
My main concerns are;
1. Visual Impact on the beautiful town of Moss Vale – From the information I have read the size and scale of the project is enormous. A 6ha complex at over 5 storeys! How can this be anything but a big ugly factory in a rural landscape? The current plans do not address how the scale and bulk of this building will alleviate the visual intrusion on the locals.
The residents on Beaconsfield road will no doubt have their property prices affected and that end of Moss Vale will become an industrial wasteland.
The plans show a total lack of green space/landscaped areas compared to the size of the complex.

2. Road Congestion – The highlands is already suffering from an influx of people to the area and there seems to be very little regard to how future traffic flow will be managed.
The traffic assessment that was carried out was pre-covid and would not take into account this increased migration.
We already have issues with potholes, degraded roads, and roads that are too narrow. The increase in truck and vehicle activity would negatively impact these existing roads, not to mention the added noise, requiring significant upgrades.
Multiple roads will need to be upgraded to sustain the increased traffic that will be generated. Whilst Plasrefine appears to promote any such road works as upgrades for the community’s benefit, these upgrades are necessitated purely for the private purpose of the project. The works are simply a consequence of the traffic-related noise and safety impacts that will eventuate if the project is approved.

3. Water and Air Quality – I feel that not enough information has been given regarding the odours that will be emitted from the plant and how they will be addressed. Having lived near the Cement works in Berrima the prevailing wind can carry the most revolting and acrid smells. This in turn affects people’s quiet enjoyment of their properties, causing them undue stress.
There will be toxic residues and toxins in plastic dust that are extremely harmful to good health and the environment. I don’t feel these have been adequately addressed as there is currently no way to know the level of these emissions, as no machinery has been specified.
The proposed site is located in the Sydney Water Catchment area.

In closing, I don’t feel that the project would in any way benefit the Highlands or its residents. A more suitable site must be found.

I am writing this submission in objection to the proposed Plasrefine facility which will be located at 74-76 Beaconsfield Rd, Moss Vale 2577 - SSD-9409987.

The EIS report identifies that there will be 40-50 trucks per day delivering and removing plastics in addition to 60 light vehicles that will also enter and exit the site. In the EIS report and during the community sessions it was outlined that there would be approx. 5 trucks per hour coming into the Plasrefine site. In a best-case scenario this would mean 1 truck every 12 minutes would enter the site or broken down even further, it would mean that there is a truck either entering or existing the site every six minutes. Essentially there will be a constant flow of trucks entering and exiting the site.

Undoubtably, the arrival and departure of trucks for the Plasrefine site will heavily depend on traffic conditions. When there are delays in trucks arriving on site, this will create a back log of trucks causing congestion. In the community meeting it was outlined that trucks could park on site if there are delays however it is unclear as to how many trucks could safely wait on site and whether or not this would spill out onto the road which would cause further congestion for local residents.

Additionally, there is no assurance as to how trucks will be managed to ensure that they do use the prescribed route as outlined in the EIS report. If there are delays with trucks (which there ultimately will be) what will prevent a truck from utilising a quicker route, driving through residential areas, to arrive or depart the Plasrefine site? Further who will ensure that the trucks are using the prescribed route and what are the consequences for the truck drivers and Plasrefine if the prescribed route is not used?

In the community sessions held, it was outlined that although the site will operate 24/7 the last truck must leave the site at 6:00pm. It was outlined that trucks are only allowed to enter and exit the site between the hours of 7am-6pm. It is unclear what measures will be put in place to ensure this occurs and what avenue residents have to raise concerns should trucks enter or exit the site outside of the prescribed times. Again, delays are inevitable and further information needs to be provided as to how the trucks will be managed.

I believe that this is not an appropriate site for this factor. It is too close to the Moss Vale township. The residential road are not suitable for the volume of vehicles that would be travelling on them. A large number of people would be greatly impacted by such an industrial. As we live on one of the roads that would carry these vehicles it would be of great concern to our safety too.

As a Moss Vale community member whose family has been in the area since the first settlement, I strongly oppose the use of the site at Beaconsfield Road Moss Vale for a Plasrefine site. The reasons I object are because:
1. Beaconsfield Road and the surrounding roads are not suitable for heavy vehicles
2. Uncertain and unsuitable access arrangements for the anticipated vehicle movements and the unacceptable noise impacts it poses for nearby residences
3. The factory is proposed to be located within 150m - 200m from homes, off Beaconsfield Road
4. This is not 3kms North of Moss Vale, as stated by Plasrefine, but within the town boundary
5. Narrow access along Beaconsfield Rd with no Pedestrian access. The residents need to walk on the road – no footpaths (Beaconsfield and Lytton rds)
6. Childcare Centre on Beaconsfield Rd and within vicinity of 2 schools
7. 24hr operation, 7 days per week for 44 weeks per year and 8 weeks for maintenance
8. Only metres from Australian Bio Resources (the Garvan Institute)
9. 150 metres from closest resident
10. Deterioration of local roads due to increased use and offset developer contributions therefore council / ratepayers become responsible for upgrade and ongoing costs.
11. There will be a proposed 38,638 square metres of buildings over 5 storeys (18 m) in height
12. No detailed plans, architectural drawings and diagrams of the factory complexes, only basic concept plans
13. The industrial zoning of the land appears to be relied on as the sole reason/ justification for maintaining building envelopes of uncharacteristic bulk and scale despite the numerous adverse impacts this design then has on the environment, neighbouring properties and the amenity of the landscape
14. Odour from plastic waste bales, storage, processing, wastewater facility and toxic residues, plastic dust. Emissions are currently modelled do not specify what machinery will be involved
15. waterway that flows directly into the Wingecarribee River, the location of SYDNEY Drinking Water Catchment!
16. Proposing to use 46,300L of water every day to wash plastic waste sourced from a combination of rainwater harvesting and potable town water.
17. Only 150,000L of water in storage = 3 days supply
18. Proposing to pump 16,300L of contaminated water a day into our already overloaded sewage system.

These are only some of the many reasons that the majority of local residents are against the site on Beaconsfield Road being utilised by Plasrefine.

Moss Vale Plastics Recycling Facility - Submission ( SUB - 39463101)

Plastic recycling facilities are needed throughout the state to manage this important resource, and should be located within areas which are compatible with the operations, close to the source , and which can accommodate and minise the negative impacts resulting from their operations.

The proposed location of this facility poses potential risks to the closely located residential area, to the community of Moss Vale and to the broader community of Southern Highlands.
The operations of the proposed facility project heavy truck movements at a volume which are highly incompatible with the current road infrastructure of the area, proximity to preschool, schools, and the village centre of Moss Vale. Recently Wingecarribee Local Council has been heavily criticised for its failure to provide and plan for adequate road infrastructure to match increased population growth in this area, and the town bypass has been in discussion for many years. The proposal to add the projected volume of heavy truck movements on to local streets would degrade and cost the community economically, socially and environmentally; apart from general safety issues.

I urge authorities and the proponent to resite this facility to an area more compatible with its operation- nearer the existing recycling centre in Moss Vale which buffers some impacts to local residences, may be an option. However until road infrastructure is upgraded in the local area such a facility should not proceed, and definitely not the on promise of road improvements to follow. Local communities should not bear the burden of poor planning decisions.

There are also questions about impact to water and air quality. And whilst the proponent may demonstrate compliance in this application - there is a well documented littany of failures in the regulatory process in NSW with little consequence to offenders. Understandably the public is cautious, and we are now at a time when biosystems are so fragile surely the precautionary principle needs to be adopted, and such a significant project should only be approved with an independent and stringent monitoring regime in place.
As acknowledged, plastic recycling is essential, responsible and potentially profitable. With such a significant project - recycling a large proportion of the state's waste - site compatibility, minimising impacts and access to the site surely need to be examined as determining factors. Just because land is zoned as appropriate - does not ensure it is fit for purpose.

I Object to the proposed Plastics factory - citing the following reasons.

Location of proposed site, there are residential properties / houses within 200-300 metres, it is within 1 to 2 kilometres of the suburbs and CBD of the township of Moss Vale. Far too close for any factory of this type. Why - The rural surroundings will be irreversibly damaged to an unlimited degree regarding Air pollution / run off / unacceptable noise levels due to an estimated 200 trucks per day transiting the area and township of Moss Vale.

The Dynamics of Moss Vale, its residents / sense of community / Rural outlook / it's Tourism and growth potential all will be damaged beyond repair if this Plastics Factory is established. It will then open up to further factory / industrial development of the area - thereby destroying rural / cultural / natural / Aboriginal Historical features of the landscape of Moss Vale.

I refute the diligence of the EIS Statement that was presented. I have absolutely no confidence or assurance that all health concerns have been addressed, regarding Pollution (Air - escaping from the factory wind conditions towards residents / risk mitigation - suppression etc.) (200 Trucks producing Air / Noise / Road Damage / increased CO2 Diesel fumes pollution spreading through-out Moss Vale residences.
No plans listed for the safety of surrounding residences in any major emergency event. One very real issue is a Factory Fire (Highest risk as per recent events with other recycling factories, such as :

"Capital Valley Plastics in Blaenavon, Torfaen WALES UK. 04 Sept 2021"
Results of this fire are best described in an article from "The Fire Protection E Newswire"

I pharaphrase the following. "While there were no reported injuries in the blaze, the impact on the local community and environment was significant with local road closures, residents being forced to close windows and doors due to harmful smoke, and a number of measures employed to minimise the impact of pollution to the local environment. One month later, what remained of the roughly 3,000m2 building was demolished and will be disposed of. The event developed high volumes of smoke and contained harmful contaminants. Furthermore, fire water run-off needed to be monitored by the relevant agency and there is the environmental impact of disposing of the damaged properties and the costs, resources and materials required to repair and rebuild them."

There are No listed Communication Methods or Evacuation plans for Moss Vale residents in the event of a major emergency. ?? No plans listed - no WHS plan for outside of the Factory.

I also have concerns about the Foreign Company Ownership due to Current Geo Political Issues, and the Local Un-Invested Integrity issue of both the Company / Owner and Australian based PR Representation Company. There is no local vested interest i.e. all involved live no where near this region. Therefore no personal impact for them - as a result they have No local interest or care / regard for the area at all.

No specifics mentioned of where the work force will come from, no local involvement therefore little or no Local Financial & Employment benefit at all.

In Summary - The location for this type of Factory is completely wrong, it is not suited to the pristine Southern Highlands region / Landscape / rural location. Too high a risk of damaging Health issues as a result of this type of plastic fibres and resin recycling process. There are far better and safer locations with excellent access well away from populated locations, greatly reducing environmental and human health. I therefore submit my objection to the Plasrefine Plastic recycling factory being built in this area.

Submitted 22/03/2022

This plastics recycling facility cannot go ahead in the Southern Highlands. It will ruin our waterways and pollute our air. Our roads cannot handle the amount of truck traffic that will ensue. This facility won't create local jobs. It is an abomination and I beg for it to not go ahead. The EIS is full of inconsistencies and does not address many areas of concern such as emergency measures in case of a factory fire.

I have researched the effects of plastics on the human body for more than a decade, interviewing scientists, biologists and doctors on the subject around the world.
The idea that such a facility is being tabled so close to a community - a day care centre 700m away, no less, and residential density increasing exponentially this past few years with only more residents on the way, is frightening given the potential dangers to health of such a facility, no matter how well managed.

The endocrine disruptive properties of plastics are well known and documented in the scientific literature, and this disruption can occur via the air as well as via microplastic dust ingestion/respiration.

Such a facility should be much more remotely located to avoid danger to the community and I implore you to stop this planning proposal dead in its tracks for your safety and that of the people of the Southern Highlands, many of whom are my family members, including nephews, and children, specifically boys are affected by endocrine disruptive plastic components such as phthalates, to name one group of particularly harmful chemicals found in a wide range of plastics known to disrupt sperm production (2 such study examples and findings: https://pubmed.ncbi.nlm.nih.gov/27546318/#:~:text=The%20general%20exposure%20to%20endocrine,malformations%20of%20the%20genital%20tract. and https://pubmed.ncbi.nlm.nih.gov/18570050/ ). And many on microplastic effect on male fertility also https://pubmed.ncbi.nlm.nih.gov/33804513/

Thank you. While I applaud efforts for plastic recycling it must be done at a much safer distance from the heartland of the Moss Vale, Southern Highlands community.

Alex

25-27 Merrigang Street,

Bowral,

NSW 2576

March 21, 2022


To Wingecarribee Shire Council.

Dear Sirs,

Re Plascerefine proposal – Application Number SSD-9409987

We wish to object strenuously to the proposal to build this facility where it is currently proposed to do so. We base our objection on three grounds: -
- The scale of the proposal is completely in appropriate for the location where it is proposed to be located
- The closeness to the residential areas in unacceptable - people’s homes are way too near the proposed location of the plant
- finally, it seems to us that it would be a travesty to place this facility in such a beautiful area – it only suits the need of the developer and ignores the needs of the residents – there have got to be better options that balance mor appropriately the needs of all the stakeholders


Yours Sincerely,



Donal & Judith O’Dwyer

I'm the mother of two children and we live 2 km from the proposed site.
There are so many potentially hazardous risks associated with this site that it simply should not go ahead.
The airborne toxins released by the reprocessing of plastics and polymers are a massive health risk.
Plastic sludge from runoff cannot be easily disposed of at the Bowral waste facility as suggested in the (deeply flawed) GHD report.
There is no buffer from noise and vibration from the hundreds of trucks using our, already congested, roads twenty four hours a day seven days a week.
The site is less than 2km from the town centre of Moss Vale.
Less than 1 km from and Early Childhood Learning Centre.
Less than 2 km from primary schools.
Grossly inadequate community consultation:
In their EIS, GHD says that community engagement was fulfilled. This is absolutely NOT the case. I spoke to many residents living under a 2 km radius of the site and they had heard nothing about the proposal project until a local community group did a letterbox drop.
There has been a serious lack of engagement or transparency on the project from those behind.
For these reasons, and many more, the proposed Moss Vale site is completely unfit for a plant of this scale and purposes.
Thank you for your time and consideration.