State Significant Development
Moss Vale Plastics Recycling Facility
Wingecarribee Shire
Current Status: Determination
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- SEARs
- Prepare EIS
- Exhibition
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- Response to Submissions
- Assessment
- Recommendation
- Determination
Plasrefine is seeking approval for the construction and operation of a plastics recycling facility with the capacity to accept and process up to 120,000 tonnes of plastic waste per annum. The facility would also manufacture plastic fibers and resins
Attachments & Resources
Notice of Exhibition (2)
Request for SEARs (1)
SEARs (2)
EIS (14)
Response to Submissions (29)
Agency Advice (39)
Amendments (14)
Additional Information (10)
Recommendation (4)
Determination (2)
Approved Documents
There are no post approval documents available
Note: Only documents approved by the Department after November 2019 will be published above. Any documents approved before this time can be viewed on the Applicant's website.
Complaints
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There are no enforcements for this project.
Note: Only enforcements undertaken by the Department from March 2020 will be shown above.
Submissions
Name Withheld
Object
Name Withheld
Message
Roberto Bianco
Object
Roberto Bianco
Message
Attachments
Satstream (Australia) Pty Ltd
Object
Satstream (Australia) Pty Ltd
Message
Name Withheld
Object
Name Withheld
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Attachments
Name Withheld
Object
Name Withheld
Message
If the DP were to go ahead it would have catastrophic effects on the socioecological nature of the Wingecarribee Shire, and our Southern Highlands. There are infinite points of opposition to the DP, some of which I have included in the document attached. I have also included an image of the intended site. You will see how inappropriate a development of this nature and scale is, this close to residents, the town and the sensitivities of the ecological environment on the site, not to mention inadequate infrastructure to support the facility without severe detrimental effects to the immediate and wider community. This will have enormous detrimental effects on the Moss Vale, Burradoo and Bowral community as the plastic ‘sludge’ will be disposed at the Bowral waste facility which recently were served a huge fine for non compliance. The Bowral facility on Kiama street has residents in dismay due to pungent odours which will only worsen if extra plastic sludge which will contain animal proteins and can be highly volatile and putrid. The July / August South Westerly winds will blow emissions from the facility straight over Burradoo, Chev and Bowral.
Name Withheld
Object
Name Withheld
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Name Withheld
Object
Name Withheld
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I hasten to add that I do not have any issue with the relevance and importance to recycle plastic.
My objection relates to a number of factors relevant to The Southern Highlands:
1. The alarming volume and scale of heavy traffic entering and exiting The Southern Highlands (Berrima, Moss Vale, Bowral, Robertson and Mittagong) supplying recyclable plastic and chemicals then removing toxic waste and processed plastic- would have a significant impact on roads, noise, traffic and safety. 100 movements/day from 20 tonne heavy haulage trucks. It is a simple fact that trucks accessing the site from Wollongong, Sydney, Canberra (later Victoria) will take routes that are quickest. Planned/proposed routes through the SH will simply be ignored over time impinging on suburban roads and town routes.
2. Water usage and the strain put on the sewerage system in handling the sheer volume of water requirements. Indications by GHD that '80% of water will be harvested and recycled on site' are misleading and simply not true.
3. Proposed access to the site and related roads that need to be constructed require private land purchase. This has not yet been finalised so the road to the site is a serious issue which has many elememts to it. How could the proposal have progressed this far without this vital requirement still pending?!
4. A plant of this magnitude requires fire fighting resources on a scale not available in The Shire. Plastic recycling plants have a bad reputation internationally for being fire-prone. How will this be addressed?
5. Toxic chemicals and gasses are released in processing and heating/moulding plastic. The environmental and health issues associated with this where a plant of this size and magnitude abuts residential areas is of serious concern!
6. The Southern Highlands is well known throughout NSW as a pristine, beautiful location with magnificant vistas and unique wildlife. This is hardly the right location for a 7 hectare, 18m high facory facility which will not only be an eyesore, but produce toxic waste, noise, odours and high industrial scale traffic - while consuming and expending vasts amounts of water.
In summary the location for a facility of this size and purpose should not be located adjacent to residential areas in the SH.
Regards
Rachel Russell
Object
Rachel Russell
Message
555 Penrose Road
Penrose NSW 2579
APPLICATION No. SSD-9409987
I OBJECT to the Plasrefine proposal.
I oppose the Plasrefine development. I am concerned this proposal has even been allowed to reach planning stage, when it has not been demonstrated that GHD has resolved issues of access to the site. There is currently no evidence GHD has agreement with the relevant landowners who reside at 77 Beaconsfield Rd, 13-17 Lackey Rd, the Garvin Institute, or Wingecarribee Shire Council (WSC) that would enable GHD to presume they would be able to utilise Braddon Road. WSC has categorically stated to GHD that Beaconsfield Road is unsuitable as an access road for industrial use: GHD do not have permission to use this road, despite public comment that they will use it if they cannot gain access through Braddon Road.
On the basis of the failure of GHD to transparently and accountably follow NSW Department of Planning, Industry and Environment (DPIE) Secretaries Environmental Assessment Requirements (SEAR) procedure with their failure to secure site access prior to advancement of the project, I would ask that this proposal be rejected immediately rather than allowed to progress. The community have been forced to deal with a vexatious and what could be seen as aggressive proposal. The Plasrefine proposal has placed them under an unacceptable degree of duress and upset with the thought they could have heavy industry within such a close proximity to their homes (some of them life-long), and has the further potential to threaten their health and safety should an accident occur. Consequently even as a proposal it is causing significant harm to their well-being.
Further, if a Chinese shelf company such as GHD, with no other investments in Australia, is prepared to cut corners and only pretend to tick critical boxes in the application for development, this does not demonstrate the integrity required to be granted permission to run a high-risk operation of this scale.
This concern is validated when research shows that one of the key parties involved, a Beijing-based businessman Lyu Yalin, owns companies that have faced censure from Beijing’s Environmental and Ecological Bureau. A number of close neighbours have only recently been informed, not by the company but by letterboxing on behalf of the community fighting this. GHD has demonstrated a lack of transparency by changing the proposal and figures relating to the development on a number of occasions without notice, so requiring constant community vigilance.
The WSC Development Control Plan (DCP) specifically zones this land as general industrial (IN1) in our 2010 LEP. Also on this site is a Conservation Zone (C4). It is set within the boundary of the township. The general industrial zoning only allows for light industrial activity. The reason for this involves proximity to residential areas, whereas the scope of the Plasrefine proposal is Heavy Industry. Therefore this proposal does not meet respectful standards for approval. While it is acknowledged in a general sense that a Development Control Plan (DCP) can be viewed by the State Government as a guideline only, it is important to note that WSC has consistently applied our DCP. This lack of consideration and respect for the needs and aspirations of the local community is a further mark against the character of this company, particularly when it is seeking our public monies to pursue its development.
Proximity to residential areas also raises issues of pollution emanating from the facility. For example, there is nothing in the EIS which would assure any resident nearby that noxious odours which arise from the transport of rubbish with food scraps are adequately contained within a shed with roller doors which open multiple times each day. The potential of bright light pollution into the residential area has similarly not been addressed, despite this being a requirement of the SEARS to address this issue.
This site does not have the infrastructure to support this development. The roads in this area are poorly constructed, and WSC has publicly stated they are not suitable for frequent heavy truck movements. The traffic assessment was completed during a period of the COVID pandemic and so is not a true and accurate reflection of normal conditions. Further, trucks carrying waste from the site were not included in GHD’s calculations. The capacity of WSC sewerage treatment plants to manage a projected 15,000 litres per day of waste water is not assured, and also raises issues about contamination of micro plastics into the landscape, environment, and Sydney’s water supply.
It is quite clearly not the right site for such a development, and not the right company. With so many critical infrastructure issues, practicalities, and community health and safety issues not adequately addressed, one can only assess this proposal to be a sloppily prepared justification for a thought bubble as to how to best access Australian public money to make a quick buck. The Plasrefine proposal by GHD needs to be rejected outright.
Marianne Barker
Object
Marianne Barker
Message
I will definitely be spreading spread the word and do what I can to conscientiously object to such a ill-conceived proposal.
Anna Phillips
Object
Anna Phillips
Message
If Plasrefine is approved we can say goodbye to our future as a tourist destination. If they are allowed in more will follow as the land is there and just waiting for the next big business.
I totally agree that we need to recycle & repurpose plastic but the bottom line is This Is Not The Right Site. Thanks Anna
Will Mathews
Object
Will Mathews
Message
1. Environmental concerns.
a. Airborne volatile organic compound emissions leading to increased incidence of cancer (confirmed link with employees and nearby residents in a number of equivalent facilities internationally), also suspected association of said volatiles with Autism Spectrum Disorders and ADHD.
b. Inability of these facilities to contain plastic particles including microparticles within the facility boundaries leading to irreversible contamination of adjacent waterways (within the Sydney catchment area).
c. Inability of these facilities to contain refuse - gross material leading to increases in litter.
2. Traffic. The increased volume of large trucks in Moss Vale and surrounding areas will have a significantly negative impact on traffic flows and costs of road maintenance. Inadequate access and major ongoing disruption to an already congested town.
3. Company and company officers are not fit and proper persons. Controlling individual has previously been charged with breaches of environmental laws in relation to the operation of similar facilities in China - country of origin.
4. Incorrect Zoning. The proposed location utilises Zoning established by a previous Council, many members of which were Councillors in the Wingecarribee Shire Council recently sacked by the NSW State Government for dysfunction and incompetence. The Zoning in this area should be reviewed as it is now incompatible with residential land releases in nearby areas.
The location is within the town boundaries and is too close to residential areas, schools, critical waterways and farmland.
Will Mathews
4 Suttor Rd Moss Vale
Name Withheld
Object
Name Withheld
Message
Susan Winning
Object
Susan Winning
Message
It is inappropriate to build a plastic recycling facility for Canberra, Sydney and Wollongong’s plastic waste in a regional area which does not have the infrastructure to support it. Our suburban roads are designed for light trucks and cars, not the 50+ huge trucks which will be using the roads in and out 24/7.
The proposed site for Plasrefine is inappropriate because of it’s proximity to the centre of Moss Vale. It is within 100 metres of homes and two schools as well as a childcare centre. The latter two are of concern because of safety issues resulting from the increase in traffic near young children.
The facility will result in an increase in significant air pollution for the Southern Highlands, noise and impact visually on a beautiful location.
I strongly object to this facility being built in the current proposed location.
Kevin Brooks
Object
Kevin Brooks
Message
o Research studies show local populations living close to these facilities suffer from serious health conditions, respiratory diseases, skin rashes and eye disorders, not to mention the potential cancers caused by plastic resin compounds.
o There is no doubt that this kind of waste industry is highly toxic to the local community and the environment due to Airborne Volatile Organic Compounds emitted during the process of turning plastic waste into flakes and pellets and products.
o Plasrefine Pty Ltd is a company registered in Australia, with 100% Chinese interests.
o The Factory is proposed to be located within 150m of homes.
o The site has 2 incompatible zones, Environmental Living and an under sized General Industrial portion.
o The site has highly sensitive environmental areas (Koala Habitat), and a category 2 riparian waterway that flows directly into the Wingecarribee River, the Drinking water Catchment!
o 5 acres (2 x 10,000sqms) of buildings in a highly visible area.
o Is close to 2 schools and an Early Childhood Centre.
o Proposed to function 24 hours a day 7 days a week.
o estimated 160-200 heavy vehicle truck movements and 280 light vehicle movements per day using the local residential Moss Vale road Network, (Light vehicles over 3 shifts in the 24 hour period).
o Trucks to deliver waste Mon-Fri 7am-6pm, causing more gridlock on our already choked roads.
o Proposed to take 120,000 tonne per year of dirty plastic waste from Sydney / Canberra / Wollongong.
o Wash / heat / shred / pellet and melt then make more plastic products, greenwashed by the term RECYCLING.
o Proposing to use 20,000L of our drinking water every day to wash plastic waste.
o Proposing to pump 10,000L of contaminated water into our already overloaded sewage system.
o Prevailing westerly winds will potentially blow smell and dust and Micro Plastics over Burradoo and Bowral.
o Will directly impact the highly sensitive Garvan site where a road extension will be forced.
o Will directly impact home prices in Moss Vale.
Christopher Tetley
Object
Christopher Tetley
Message
CONSULTATION. GHD representing Plasrefine have been misleading to our community from the get go. They have continually altered plans on the run during the consultation process. Some plans (traffic) have/are wrong. Statements regarding their consultation process & agreements with WSC (LOCAL COUNCIL) are blatant lies. This was made clear at a community meeting held by WSC on the 17/3/22 where council confirmed there has been only 3 face to face meeting with GHD, NOT several & council confirmed @ no time have council said they support this proposal. As GHD & Plasrefine representatives have claimed.
MAJOR IMPACTS. 1.SAFETY. Proposal has the potential to impact local residents,childrens bus routes,day care centre with anticipated heavy vehicle haulage through residential streets.
2. ENVIRONMENTAL. Visual- The shear size of this thing. Some 6 hectares in size, 5 storeys in height, to receive 100000 tonnes of waste by road through residential streets. NOISE- 24 HR operation, 3 kms from town centre of Moss Vale & only 250mts from local housing. 3. Water & Air Quality- development risks contamination of local water catchments & risk potable drinking water. 4.SOCIAL IMPACTS- No social impact study has been instigated despite requests from WSC or affected groups. 5.FIRE RISKS- The shear size & type of developent would require, in case of fire a response that could not be adequatley met by local authorities as was the case in the building fire in our adjacent town of Bowral. I could write oh so much more but not really being computer savvy i'm giving myself a headache. Thankyou for reading my submission. Regards Christopher Tetley , on behalf of my family who have been residents of Moss Vale for 60yrs .
Name Withheld
Object
Name Withheld
Message
Instead it will create heavy vehicle road damage, traffic congestion, influx of out of district road users at times when local commuter volumes are already at capacity. The employment opportunities do not meet the high growth sectors that young people are training for in the local education centers and small businesses. The project will impede the growth of of local tourism, farm to plate boutiques experiences, and day trippers dining that have developed naturally in Moss Vale. The council should be supporting local initiatives that follow the successful growth path demonstrated in existing entrepreneurship which capitalises on natural attractions, bespoke home-wares, arts crafts and clothing shopping niche opportunities leveraging the unique assets of small town living with proximity to Sydney.
I am appalled at the waste of council resources for this project when there should be focus on enabling local creative business ideas to thrive and grow. If this project goes ahead then The council does not understand what value the community places on local innovation. We give local ideas for new small business start ups our complete support. The proposed plant is not a priority and detracts from the business offering that we have worked hard to establish.
Lynette Desmond
Object
Lynette Desmond
Message
The transport routes for the trucks that will service the facility 24 hours a day 7 days a week are going to be residential streets that are ill equipped to handle that increased traffic and there are schools , a preschool and churches and no guttering on these streets.
Noise and air pollution will be significant for all the residents of Moss vale and surrounds. There is no modelling to ensure that this is within safe limits.
They plan on using 46,300 L of water per day and pump 16,300 L of polluted waste into our sewerage system- we are part of the Sydney water catchment and our water and sewage cannot cope with this.
This plant is to be the biggest in Australia and will badly affect the southern Highlands, which relies on tourism and agriculture. Moss Vale is not the correct location.
The technology to process recycled plastic is still being worked out, CSIRO have set up research into how to use the recycled plastic and this company appear to be making things up as they go without the expertise to do the work properly.
The proposal is inadequately assessed and will adversely affect the region and produce a profit to the Chinese investor.
This is the wrong site and the cost to the surrounding areas is too great to consider this project
Noel Davis
Object
Noel Davis
Message
Ultimately, the location of this factory in suburban Moss Vale will not be allowed to proceed and work undertaken to allow it to be there will be a waste of public money.
Name Withheld
Object
Name Withheld
Message
Please also see my attached document which discusses my objections in more detail, and includes scientific references. Here I will summarise the most important points:
The report omits important information about the impacts on human health from volatile organic compounds (VOCs) and other airborne emissions, and presents insufficient detail about how Plasrefine would manage emissions. The report only assessed 3 individual VOCs (benzene, toluene and styrene), but there are many more VOCs and other noxious compounds that can be released when plastic is melted, some of which are carcinogenic or neurotoxic; a few are associated specifically with waste plastic. The report does not mention these problematic substances, or assess their impacts on the health of the community, or on Plasrefine’s own employees.
The report relies on the stated assumption that the plastics being heated will include only polyethylene (PE), polypropylene (PP) and polyethylene terephthalate (PET). The EIS states, however, that the facility will also process acrylonitrile butadiene styrene (ABS), and up to 20,000 tonnes of polyvinyl chloride (PVC) per year. Both of these plastics should have been included in the report’s assessment of air quality impacts, particularly PVC which will represent around one sixth of all plastics processed at the facility and will therefore contribute significantly to its emissions.
The toxic emissions from heating PVC include hydrogen chloride, vinyl chloride (a known carcinogen), and dioxins, which are “among the worst materials for human health impacts." The exclusion of PVC from the report casts doubt on the validity of GHD’s claims that airborne emissions from the Plasrefine facility will be “low” or benign.
Studies of plastic recycling processes and facilities elsewhere in the world have documented impacts on human health and wellbeing as a result of airborne emissions. The impacts on people living near other plastic recycling facilities included respiratory and skin problems, increased cancer risk, and reduced quality of life as a result of unpleasant odours. Impacts were sometimes experienced by residents more than a kilometre away, but were most severe for those closest to plastic recycling facilities. The EIS does not address these human health issues, nor are those studies included in its reference list.
The report does not provide information about the efficiency of the proposed systems for treating air emissions within Plasrefine’s facility, and does not state what percentage of emissions these systems would capture. This is an important detail, since it will determine the amount of airborne pollutants released into the surrounding environment. Without this information, how can it be confidently stated that emissions will be “low”?
At previous community presentations, GHD stated that Plasrefine would use “common techniques that are able to capture 99% of emissions”. Even if this is true, it still amounts to a large impact on air quality. Effectively it means that untreated emissions from 1% of the 120,000 tonnes of plastic to be processed each year (around 1200 tonnes per year, or more than 3 tonnes per day) will be vented straight to the surrounding neighbourhood. If some ordinary citizen was to melt down 3 tonnes of plastic per day in their backyard, with no protection for the neighbours, it seems highly unlikely that would be considered acceptable anywhere close to a residential area.
A failure or inadequacy of the airborne emissions treatment systems, or unusually large emissions if a fire impacts on the facility, could create serious off-site risks or offence to people, property or the environment due to the toxic nature of the substances involved in melting and burning plastics. A build up of these toxic substances in the nearby environment over time could also represent a significant hazard. Therefore, I would suggest this proposal falls into the category of potentially hazardous or offensive development and should be assessed under SEPP 33.
The list of “sensitive receptors” in section 4.1 of the report omits the many people in the general community >500 m from the proposed facility who are vulnerable to impacts from VOCs and other airborne emissions. These include young children, the elderly, and people with respiratory issues such as asthma, or other health issues.
The meteorological data presented in section 4 shows the prevailing winds blow mostly from the North/Northeast in spring and summer, directing emissions straight towards Moss Vale’s central residential and business areas for around half the year. Spring is also the time when high wind speeds occur most frequently, further increasing the likelihood of airborne emissions impacting on the town. Moss Vale is a growing community with several housing developments under way, so these airborne emissions could impact on an increasingly large number of people.
It is not clear whether there are effective barriers to air movement between the processing areas where emissions will be generated and the unloading area where trucks will drive in. If air can flow freely between these areas (as appears to be the case from the diagrams of the buildings’ internal layout) then what will prevent untreated emissions escaping whenever the roller doors open to allow trucks in and out?
The effectiveness of the proposed methods will be to separate the different kinds of plastic, and the consequences if plastics become inadvertently mixed and are melted at inappropriate temperatures at a result, should have been discussed in the EIS.
It is not clear at what temperature the extrusion process in Building 1 will occur, although this temperature will significantly affect the level of toxic emissions produced at this stage of the process. The extrusion process in Building 2, where plastics are reformed, will be done at “less than 280˚ C”. This is not particularly comforting, since many plastics emit harmful substances at much lower temperatures than this. A more precise range of treatment temperatures should be provided for each type of plastic in order to realistically assess the emissions.
Table 7.4 gives insufficient information about how Plasrefine will assess and monitor VOCs and other noxious emissions. There is no information as to how, by whom, how often, and what specific kind of emissions will be monitored. These are important details, since a failure of the emissions capture systems could result in unacceptable impacts on the nearby community if this failure is not detected quickly.
The proponent does not appear to have run a similar facility before, so their ability to run the plant safely and successfully is unknown.
The EIS involves transporting plastics a long distance from their point of origin in the cities, creating a large carbon footprint.
The proposed facility is much larger than other similar facilities in Australia, and accordingly could have much larger impacts on the community and local environment.
As climate change intensifies over the next few decades, extreme weather events will increasingly disrupt transport to and from Moss Vale. The haulage route between Wollongong and Moss Vale is particularly problematic, even though it is a smaller distance than the route to Sydney.
Many of these problems could be mitigated by having two or three smaller facilities located closer to the outskirts of Sydney, Canberra and/or Wollongong (although still at sufficient distance from residential areas to protect human health).
The local roads in the Moss Vale area do not seem adequate for the increased heavy traffic. All of the three local access roads to the proposed site appear to have significant problems associated with their use. It seems likely that construction of the new access road will be delayed or even prevented altogether due to land acquisition issues, causing unacceptable impacts on Beaconsfield Road, and/or a significant reduction in the quantity of plastic waste the facility can receive.
The proposed site has previously been described by Wingecarribee Council as “flood prone” land. In 2019 a development application to subdivide the site was refused by council on this basis. Recent flooding events in NSW have demonstrated that the unexpected is happening more frequently, and many existing flood maps may need to be reassessed.
The need to move a watercourse to build the facility is a red flag. This cannot be done without having serious impacts on the ecology of the creek.
I am also concerned about the proposal’s potential impacts on tourism, which is a large source of revenue for the Southern Highlands. Why would anyone want to go on holiday near a huge plastic recycling factory that may smell bad, make them cough or itch, or cause them to develop cancer?
While recycling plastics is certainly desirable and necessary, it needs to be done in a way that will protect people and the environment. If the local community cannot be guaranteed protection from noxious airborne emissions and other impacts, then using the precautionary principle, the Plasrefine facility should be located much further away from residential areas.
Attachments
Name Withheld
Object
Name Withheld
Message
- Heavy vehicle trucks 11 hrs a day 7 days a week continually passing residential housing only 10-15 meters from roadway (Beaconsfield ' Lackey and Lytleton Rds).
-How far will this continual noise penetrate into the surrounding suburban area. Peoples lives impacted by the relentless noise. Their sanctuary from the stresses of daily life and work taken away from them.
-The safety issue of heavy vehicle transport sharing residential roads with school children ,aged from 5 years up , with no footpaths forcing them to walk on the edge of the road. Some of these roads can barely accommodate two passing passenger vehicles let alone these monster trucks. This is a potential tragedy waiting to happen. These residential roads should be completely off limits to Heavy vehicle usage and the Recycling company should not proceed with any works until another access rd is constructed.
-water usage by the processing plant and dependence on town water are a real concern, especially during times of drought.
-contamination and volumes of water being discharged into the sewerage system.
-Air pollution ,what toxic chemicals are going to be released into the air by this process. What are the safe limits and who will monitor these pollutants . What action will be taken for non compliance.
Conclusion- This is not the right site