21st November 2022

Dear NSW Planning,

My name is Simon Clough and I live in a small village on the Far North Coast of NSW called Iluka. I am writing to object in the strongest terms to Veolia’s incinerator proposal.

You may wonder why I’m bothering to object to a proposal over 1,000kms away. Our communities are threatened by a similar incinerator being proposed for Casino. I believe it is important for all communities that are threatened by this insidious proposal to stand together.

I would like to list my objections to Veolia’s proposal:

• The incinerator proposed will emit toxic air pollution continuously for 25 years. This pollution is very damaging to human and animal health as well as the environment.

Food contaminated by incinerator toxins can cause cancer, miscarriage, infant deaths, developmental delays, reproductive issues, heart disease and of course respiratory problems.

ANU scientists concluded “there is insufficient evidence to conclude that any incinerator is safe” and in particular “contamination of food and ingestion of pollutants is a significant risk pathway for both nearby and distant residents”.

• Veolia's incinerator isn’t needed the existing Woodlawn landfill has a remaining useful life of 25 years. The proposal is also completely at odds with the Government’s circular economy policies.

• The economic impact of the proposal is in direct conflict with alternative development and growth in the local area. Maintenance of successful local agricultural businesses, along with increased growth in rural- residential developments expected over the next 10-20 years will sustainably increase the size and diversity of the local community,


• Veolia’s waste incineration is not recycling, contributes to climate change and is essentially “green washing”. The incinerator will contribute to climate change by emitting 140,000 tonnes of greenhouse gases (CO2) each year. To approve the project is inconsistent with the NSW government commitment to Net 0 emissions by 2030.


• In July 2018, the Eastern Creek waste incinerator in Sydney was rejected by the NSW Independent Planning Commission as not being in the public interest. The reasons included concerns about safety.

If this type of incinerator is unsafe for Sydney it is unsafe anywhere, especially when the cumulative impacts are considered.

Sincerely,

Simon Clough

My name is Kathleen Godfrey and I live in Goulburn. I strongly object to Veolia’s proposed incinerator being built in Tarago.
I believe that Veolia’s toxic industrial waste incinerator is not something that should be built near farming properties, surrounding towns as well as the city of Canberra with a population of 455,000. Why does the Government think that it is ok to build it in our region when in 2018 the Eastern Creek waste incinerator was rejected by the NSW Independent Planning Commission as not being in the public interest.
Some of the reasons for that decision were as follows:
1. insufficient evidence that the pollution control technologies would be capable of managing emissions
2. concern about the relationship between air quality impacts and water quality impacts
3. the possibility of adverse environmental outcomes, and concern about site suitability and human health impacts
Since then, the NSW Government has banned toxic waste incinerators in Sydney due to the risk to human health. The risks have not changed since that decision back in 2018 – this project must also be rejected for the same reasoning. If they aren’t safe for Sydney then they aren’t safe for Tarago. I have children and grandchildren living in Canberra and children living at Tarago, I am extremely concerned about their health in the impact this incinerator will have on them in the future and the environment they live in.
Please, I beg you, do not allow this incinerator to go ahead.

Objection to the Woodlawn Advanced Energy Recovery Centre

The proposal of the Woodlawn Advanced Energy Recovery Centre (ARC) exemplifies the inequality between metropolitan and regional areas through the significant risk it poses to human health. If this proposal is accepted by the NSW Planning Authority, the ARC will threaten drinking water quality and agriculture in an area which relies on rainwater as one of its main sources of potable water for drinking, bathing, preparing food, and growing crops. Furthermore, the proposal to operate such a facility does not align with the NSW Government's commitment to Net Zero Emissions by 2050, and prevents the community from taking steps to live sustainably. Hence, the Woodlawn Advanced Energy Recovery Centre should not be permitted.

The Woodlawn ARC, if approved, will create harmful levels of pollution in the drinking water supply of local communities, which poses a significant risk to human health and will create an economic burden for residents. As many Goulburn-Mulwaree, Yass Valley and Queanbeyan-Palerang residents rely on rainwater as their main source of water for drinking, growing and preparing food, and bathing, it is vital that this water is of an acceptable standard in order to protect their health. In relation to rainwater, the NSW Health Department states that “the water should be free from […] harmful levels of chemicals,” (NSW Health, 2022). The potential for the Woodlawn ARC to release chemicals and other harmful pollutants into the air threatens access to safe water, in areas which have no access to public water supply, and may be forced to resort to water filtration systems, buying bottled water or importing water from safer sources. All these options are highly expensive and negatively impact the environment through the excess packaging waste they create and the energy used to obtain them, such as fuel emissions from trucking water to properties. They are also all costs that individuals will need to absorb, likely with limited support from government. Therefore, because many residents in this region have no public water facilities, unlike their counterparts in Sydney, where much of the waste the Woodlawn ARC will process originates, they will unjustly suffer the health, economic and environmental effects of this project.

The health risks posed by the Woodlawn ARC are serious and suggest that residents of the surrounding area are expendable, in comparison to those who live in metropolitan areas such as Sydney where similar waste management projects have been rejected. The chemicals released in the process of waste incineration can have significant impacts on health, and have been linked to cancers, infant death and miscarriage, and congenital anomalies. While newer waste incineration technologies may have a reduced impact, studies into their effects are inconclusive and a cautionary response has been recommended until adequate time has passed for any adverse effects to emerge (Tait et al., 2019). Therefore, the Woodlawn ARC proposal cannot be supported, as it poses too great a potential hazard, especially when there are other methods available to process waste. According to the NSW Government Net Zero Plan Stage 1, “Innovation needs to be part of any plan to reach net zero emissions by 2050,” (Department of Planning, Industry and Environment, 2020). Using an incinerator to manage waste is not an innovative technology, and has been used to the detriment of the environment and health for decades. Sydney’s waste should not be transported to the regions, because it allows the problem of safe waste management to move to the back of the minds of Sydneysiders, and to the forefront of poor regional health outcomes and inequality. The fair and equal consideration of all NSW residents should be of the highest priority for the NSW Government, thus approving the Woodlawn ARC cannot occur as it is in direct opposition to achieving this.

The development of the Woodlawn ARC will limit and discourage sustainable practices at all levels of society; from state government to the individual; and will not contribute to reaching net zero emissions by 2050. An investment in this facility will encourage limited action from individuals or councils to reduce overall landfill inputs, as it poses as a solution to waste management. It may also impede investment in closed loop initiatives such as innovative recycling programs. The ARC justifies its plans to incinerate waste by collecting the energy produced. However, the Net Zero Plan Stage 1 states that “when combined with firming technologies, such as gas, batteries and pumped hydro, renewables are now the cheapest forms of new, reliable electricity generation” (Department of Planning, Industry and Environment, 2020). There is hence no purpose in pursuing such a technology which burns non-renewable resources; the proposed operation of the ARC could be compared to burning fossil fuels to create energy. Given “The NSW Government’s fourth priority is to play a leading role itself, by bringing sustainable goods, services and practices into the market and maximising the environmental value of the assets it oversees,” (Department of Planning, Industry and Environment, 2020) the government cannot support this proposal. Seeing out the lifespan of the existing landfill management facility at Tarago and investing in successful, sustainable technologies such as diversion of organic waste from landfill to make compost and supporting research into recycling will make a far greater positive impact on the environment. These strategies could be used in combination to effectively manage Sydney’s waste safely. The Woodlawn ARC is not an acceptable answer to the issue of waste management in NSW when we have such options available.


The proposal to construct the Woodlawn Advanced Energy Recovery Centre cannot be approved by the NSW Planning Authority. This project poses too significant a threat to the lives of residents in the Goulburn-Mulwaree, Yass Valley, Queanbeyan-Palerang and surrounding regions. Its potential to negatively impact drinking water, and consequently health in the area will perpetuate regional inequality and cause significant health and financial harm to the residents. Allowing the ARC to operate implies that NSW’s rural and regional residents are less important than those who live in metropolitan areas, and that the risks to their health and wellbeing are inconsequential. Furthermore, the approval of such an archaic form of waste management technology will discourage investment in technologies and strategies that will minimise waste and close loops, instead providing a band-aid solution and obstruction to achieving the Net Zero Plan by 2050. The Woodlawn ARC simply cannot be permitted.

References

Department of Planning, Industry and Science, Department of Planning, Industry and Environment Net Zero Plan Stage 1: 2020–2030 (2020). State of New South Wales 2020. Retrieved November 23, 2022, from https://www.energy.nsw.gov.au/sites/default/files/2022-08/net-zero-plan-2020-2030-200057.pdf.

NSW Health. (2022, September 30). Rainwater Tanks. NSW Health Department. Retrieved December 1, 2022, from https://www.health.nsw.gov.au/environment/water/Pages/rainwater.aspx

Tait, P. W., Brew, J., Che, A., Costanzo, A., Danyluk, A., Davis, M., Khalaf, A., McMahon, K., Watson, A., Rowcliff, K., & Bowles, D. (2019). The health impacts of waste incineration: A systematic review. Australian and New Zealand Journal of Public Health, 44(1), 40–48. https://doi.org/10.1111/1753-6405.12939

The independent review conducted by the NSW Chief Scientist and Chief Engineer on the proposed NSW EPA energy from waste policy which will allow waste incinerators to discharge 7kg/hour of dust over our homes and into our water supply. I am not only concerned but mortified that this is even being considered forTarago and its surrounds. Why on earth would I support an incinerator or any operator plans to install where they are legally able to discharge more than 7 kg/hr of dust 24/7 over Tarago homes and the surrounding district?
Waste incinerators generate large amounts of highly toxic ash and other materials such as spent activated carbon which, despite what the waste to energy industry says, can’t be remediated and must be disposed of as hazardous waste. Currently any attempt at immobilising pollutants focuses only on heavy metal contamination and nothing is done to immobilise persistent organic pollutants such as dioxins and dioxin-like compounds. In addition, if undoped activated carbon is used to filter mercury from the discharge stream any mercury collected will not be retained and will leach out of the spent activated carbon. To effectively filter and absorb mercury from the discharge stream activated carbon doped with sulphur is required so that mercury sulphide is formed and is retained.
There are no requirements specifying how the immobilisation of heavy or bottom and fly, baghouse ash, spent activated carbon or other reagents should be carried out. Given the hazardous nature of the waste ash and other reagents this is essential to prevent toxic pollutants leaching into the environment prior to, and after disposal. Currently, proponents are only required to measure a very limited number of pollutants being emitted in stack gases under steady state plant conditions. Testing on modern waste incinerators currently operating in Europe has shown that this performance measure is deeply flawed as the highest concentrations of pollutants are emitted during start up, shut down or stack bypass events. It doesn’t surprise me that in other countries persistent organic pollutants are now being found in the environment, food chain and people from waste incinerators. So why should we believe for one minute that the incinerator proposed for Tarago will comply 24/7 with environmental orders? Veolia’s track record to date speaks for itself - they have a history of non-compliance while operating Woodlawn – who’s to say history wont repeat itself if the ARC is developed.
I do not support Veolia's proposal to build a waste-to-energy (WTE) incinerator near Tarago, in the NSW Southern Tablelands

My name is Sandra Gerber.I live in Croydon Sydney. I strongly object to Veolia's proposed incinerator being built in Tarago.
My daughter's young family live in Tarago. I am greatly concerned that Veolia's waste incinerator will have a detrimental affect on their health and well-being. They grow much of their own food and their water supply is collected in tanks. Both are highly vulnerable to toxic air pollution.
It is well-documented that Veolia has often failed to comply with licensed conditions. The Tarago community has absolutely no reason to believe this would change.
In 2018 the Eastern Creek incinerator in Sydney was rejected based on a list of public health and safety reasons. The proposed Tarago incinerator should also be rejected based on similar reasons. Surely the people of Tarago and its surrounds are as worthy as the population of Sydney for a safe and healthy living environment.

I have a concern for the people who live near it and how it may damage their health and the environment. As well as lowering the value of the land around the area

I object to this project as the area is subject to very frequent high winds ( as evidence by the number of wind turbine in the area), which would spread pollution and harmful substance far and wide, there is a number of farms and hobby farms in the area and it would affect property value. This kind of project was rejected for Sydney in 2018 so why propose it in our region