I have family living in Moss Vale, and on my numerous visits to the town I have come to really appreciate the beauty and tranquility of the area. I have recently been made aware of the proposed plastic recycling development by the community group "Moss Vale Matters" which has deep concerns about the project, and I am moved to add my voice to their objections against it. In particular: the proposed plant appears to be excessively large, although I have not been able to view a layout, and unsuitable for its location in a predominantly residential area: I believe the number of trucks visiting the plant daily through the neighbourhood will be intolerable and unsafe for Residents, especially as I cannot see any details about planned infrastructure; and I am concerned about the likely noise, air and particle pollution that will result and impact Residents. I fully endorse the more detailed objections voiced by "Moss Vale Matters"!

I am writing to object to the project of the Moss Vale Plastics Recycling Facility. My first objection to this project is to the use of Beaconsfield Rd Moss Vale by a number of trucks Monday to Friday, 7 am to 6 pm. At the moment Heavy Vehicles only make up 0.9% of the use in the street. The increase in a quiet suburban street of trucks will limit the quality of life and environment for those living in Beaconsfield Rd. It will also make it dangerous for the young families that live in this area, plus there will be a substantial increase in noise and dust from this many trucks driving up and down the road. Beaconsfield Rd has not been built for heavy vehicles and does not have curb and guttering for most of the street, this street will deteriorate very quickly. Technical report 6 refers to the plastic recycling facility using Braddon Road. The thought that they will be using a road that is not even began, "paper road" Braddon Road is a problem, how many years before this road will be in use. There seems to be a lot of this development dependant on roads that are in the planning stage only, that will take a number of years before being built eg the Moss Vale by pass and Braddon Road.
I also have a concern about a company from another country that has no track record for care of the environment, country and business, especially when the plastics recycling facility close to an important water way the Wingecarribee River and ponds. There is also an increase risk of sedimentation and runoff into waterways not including risk of waste water from the facility.
During construction the traffic and noise and dust will have a large impact upon the community around Beaconsfield Rd quality of life and closer to the site. There is a child care centre in this are that will be very much impacted, not to mention the primary schools that are the end of the road with traffic, plus the quality of life for those living in the area will be impacted.
I also have concerns about the air pollution and smell coming from this facility as it is being built in a residential area. Only the very end of the street has agriculture.
I object very strongly to this project being built on Beaconsfield Rd Moss Vale because of the negative impact it will have on residents.

Whilst I understand that the DA submitted by MIKSHAM PTY LTD ( Application number 19/1525 ) for 74 – 76 Beaconsfield Rd , Moss Vale was for a substantially less impactful application I feel it important to highlight the reasons for refusal as these conditions do not seem to be able to be met by the current proposal by Plasrefine Pty Ltd for the same site.
If this proposal had been submitted to Wingecarribee Shire Council rather than it being a SSD it would not have been able to meet these criteria and been refused on the same grounds as it simply is not as suitable site for such a development.

In regards to DA submitted for this site by MISKSHAM PTY LTD to subdivide 74-76 Beaconsfield Rd for subdivision into 2 lots (refusal sent 9/7/2019 on the following grounds):

SCHEDULE 1 REASONS FOR REFUSAL
1. Lot 11 DP 1084421 is not connected to Council's sewer infrastructure. Council is not satisfied that the development can effectively and safely dispose of wastewater to meet the demands generated by the proposed development. Accordingly, Council is not satisfied that the development can comply with the Moss Vale Enterprise Corridor Development Control Plan 2012 which seeks to ensure the orderly development of the Enterprise Corridor.

2. The lot 11 DP 1084421 is not connected to stormwater infrastructure. Lot 11 DP 1084421 is flood prone 9 in part ) , traversed by watercourses and is degraded. The Council is not satisfied that the development can effectively manage stormwater and achieve a neutral or beneficial effect on water quality in accordance with :
a) State Environmental Planning Policy (Sydney Drinking Water Catchment) 2011
b) Clause 1 .2 of the Wingecarribee Local Environmental Plan 2010 to " protect and enhance waterways, riparian land and water quality in the drinking water catchments of Wingecarribee".
c) Clause 7.5 of the Wingecarribee Local Environmental Plan 2010 which has the objectives to " maintain the hydrological functions of riparian land waterways and aquifers, including: (a) protecting water quality, and (b) protecting natural water flows, and (c) protecting stability of the bed and banks of waterways, and (d) protecting groundwater systems. "
d) The aims of Moss Vale Enterprise Corridor Development Control Plan 2012 to which seeks to ensure the orderly and proper development of the Enterprise Corridor;
e) The controls set out at Section 3.2 of the Moss Vale Enterprise Corridor Development Control Plan 2012 to comply with Council's engineering specifications
3. The controls set out in Part 4 'Flood prone land and stormwater management' of the Moss Vale Enterprise Corridor Development Control Plan 2012

3. Braddon Road is nominated as the point of vehicular access for both of the proposed lots. Access from Braddon Road to the land zoned lNl 'General Industrial;' would generate, by reason of future vehicle movements, a significant adverse impact on the residential amenity and safety of Moss Vale residents living to the south of the application site. The proposal therefore does not accord with the Wingecarribee Local Environmental Plan with regard to :
a) It’s aim to "provide opportunities for development and land use activities that...make an effective contribution towards the economic wellbeing of the community in a socially and environmentally responsible manner'
b) the objective of the lN 1 'General lndustrial' zone "to minimise any adverse effect of industry on other land uses"

I ask that these reasons be taken into account by the DPIE and thorough investigation be done as to the inadequacies, discrepancies and the vast amounts assumed information due to lack of detail in the EIS presented by GHD on behalf of Plasrefine be thoroughly examined .

Moss Vale Plastics Recycling Facility , Project ID SSD-9409987

Access to and site safety during and after construction with the use of local roads:
Beaconsfield Rd and Lytton Road are narrow and have no pedestrian footpaths Therefore residents need to walk on the roads.

The proposed semi trailer route for the proposed Plasrefine site has a childcare centre on Beaconsfield Road and is within vicinity of 2 schools.

If the Plasrefine application is approved the deterioration of local roads because of increased use along with the offset developer contributions would make Wingecarribee council ratepayers responsible for upgrades and ongoing costs.

The proposed site for the Plasrefine buildings is only a matter of metres from Australian Bio Resources (the Garvan Institute). The Garvan Institute's valuable work may be greatly impacted by the noise and vibration from very heavy vehicles entering and exiting Plasrefine if their application is approved.

• The Unsuitability of Beaconsfield Rd for heavy vehicles will ensure further problems for a narrow and not very well surfaced road with no safe pedestrian areas to crumble into a extremely bad state.

There's also the aspect of local residents using Beaconsfield Road being placed in dangerous situations with trucks that are by far too large to be on such a narrow road. Beaconsfield Rd, whether used only during the construction period or always, will put local residents, including school students relying on school buses, at far greater risk of being involved in a motor vehicle accident than is currently the situation.

• The fact that proposed factory site is located within 150 metres to 200 metres from homes off Beaconsfield Road is extremely concerning considering the unacceptable noise generated from traffic for and the proposed operation of the recycling and production plant if it is approved. The impacts it would have on nearby sensitive residential occupied spaces would be life changing in a very negative way.

Noise and vibration from an industry operating 24 hours per day, 7 days per week for 44 weeks each year will have dreadful consequences on the health of residents closest to the Plasrefine plant if approved.

The above along with the known toxicity of plastic recycling and plastic re-purposing factories through their daily operations on the lives and the health of nearby residents is well documented by various scientific groups and individuals in multiple types of publications.

A plastic recycling and plastics manufacturing plant is an extremely poor choice to have close to residential areas.

Furthermore, the proposed Plasrefine complex if approved would be situated less than 3 kilometres from the Moss Vale CBD and denser housing areas. There's massive potential for so much plastics pollution, particularly micro plastics and plastic pellets, to invade every aspect of the population of Moss Vale's residents lives including the interior of their homes and businesses.

• The proposed site Plasrefine have purchased has two zones which are not compatible with each other, Conservation (C4) and  General Industrial (IN1) which is 7.7 hectares of the land.

The type of industry Plasrefine are wanting to build on the site appears to be at odds with the Conservation (C4) zone. With C4 zoning aimed at being for very specific usage, which appears to exclude industrial usage, the size of the buildings and the type of industry such as Plasrefine are considering on the land are at odds with C4 Environmental Living standards thereby cancelling any protection of specific environmental qualities of the land zoned C4 if the Plasrefine plant is application is approved.
Sensitive natural environments such as riparian land would at high risk of becoming polluted by plastic pellets and plastic dust.

• Moss Vale lacks of much of the infrastructure required to support an extremely large operation such as that as proposed by Plasrefine.

Our roads are already under far too much pressure from the growing local traffic from new residential properties. The strain is seen not only in the quantity of traffic but from the effects that traffic increases are having on our local roads with numerous pot holes and the rapid increase of road edges breaking due to the often narrow roads within Moss Vale. A huge influx of semi trailers using these streets will cause far more damage.

In the advent of a fire in the proposed Plasrefine complex it would require units from Campbelltown and Camden, which are a minimum of 55 minutes and 58 minutes away from the site in Beaconsfield Rd, Moss Vale.

In the advent of a chemical spill into a nearby water course which is part of Sydney's water supply the nearest large facilities to deal with chemical spills would also be from Campbelltown or Camden.


The size of the proposed Plasrefine complex buildings being at 38,638 square metres of buildings and over 5 storeys (18 m) in height is not within the visual context of the area zoned industrial nor the very close by residential area, as well as any other part of Moss Vale.

The proposal does not give  a reasonable balance between landscaped areas and buildings thereby failing to
minimise the visual aspect of the size of the buildings on the surrounding landscape. There's no contour plan available in the Plasrefine proposal either. It is extremely difficult to gauge a decent idea from much of the proposal but nevertheless the bulk size of the buildings is inappropriate for the proposed site.

If approved the Plasrefine plant will be by far the largest building and therefore becoming a visual blight on the landscape.

With no detailed plans, architectural drawings or diagrams of the proposed complex available one can only use the basic concept plans that do not even have a reference of scale on them to try to evaluate exactly how Plasrefine are planning to lay out the various floors and what types of precautionary measures will be in place to reduce the risk of micro plastics and chemicals escaping during the entry of vehicles and people or through vents, etc. It's very disconcerting not knowing  where, if at all, any precautionary measures would be placed. Having been told at a local community meeting that the complex would a have fast opening and closing roller door hasn't been sufficient information in regards to safety measures along with the lack of information in the basic complex plans.

The lack of information regarding emissions from the proposal on how noxious gases from chemicals to be used on-site by Plasrefine if the application is approved is also disconcerting. There has been almost no information available to the residents of Moss Vale as to how it is envisaged that Plasrefine will not be creating unnecessary air pollution as well as water pollution.

Thank you for your time reading my submission.

The PlasRefine project proposed for Moss Vale is a service NSW and Australia needs, but the proposed location is wrong.
The project proposes to place a major chemical waste transformation plant on the same land division as environmental open space, and adjacent to living areas, as well as a pre-school on Beaconsfield Road.

1. The latest population forecast for the Southern Highlands indicates that from 51,000 occupants today, population will rise to 65,000 by 2045, a 25% increase. The existing infrastructure of the Highlands overall, and Moss Vale-Berrima in particular, is ill-suited to the possible addition of high volumes of articulated trucks 24 hours a day. Some estimates have stated that primary delivery traffic movements could exceed 120 a day. Given the current condition of multiple single carrageway low volume roads in the area which trucks would be required to use from the Hume motorway, already in poor condition and involving multiple roundabouts, significant infrastructure risk would fall to ratepayers and council which cannot even maintain roads already.

2. More than 100,000 tonnes of waste from Sydney, Canberra and Wollongong will be trucked to this proposed plastic recycling plant in Moss Vale. Because Australia has reportedly accumulated a stockpile of 1.3million tonnes of plastic since Asian companies stopped taking our plastic waste, demand for processing services will rise rapidly and force expansion that has not, to date, been publicly detailed in sufficient degree to quantify further ingress on local resources and infrastructure. If the reported movements are indeed 60 semi-trailers a day and the plant processes 100,000 tonnes annually, that suggests truck loads of just 5.35 tonnes per truck. Either there will be only 15 trucks a day carrying the more likely 25 tonnes, or there is actually a plan to process 400,000 to 500,000 tonnes per annum, with the consequential increased emissions well beyond the public scope so far revealed.

3. The project is a "state significant" project removing Wingecarribee Shire Council from the decision process, despite its objection to the chosen site for reasons of concern about stormwater, road infrastructure and impact on traffic delays in Moss Vale, adjacency to residential areas and emissions across the shire into residential and agricultural and horticultural land. Indeed, in the plan for Shire population expansion the location of this plant could well fit a dormitory expansion of Moss Vale residential sites, not immediately likely to be part of the flood plain or river overflow area.

4. The plant will run 24 hours a day, 7 days a week. It is located south west of the residential areas of much of Moss Vale, Burradoo and Bowral directly, and on the days when easterly winds are blowing, Berrima and New Berrima. Without stringent environmental emissions controls and filtering (currently not specified as being required because it is not classed as a chemical plant (which it is!) significant risk of gases and toxic emissions of mixed plastics is possible, without, seemingly any public reporting obligations or control mechanisms in the event of pollution control breakdown. As regards risk assessment of the initial and mooted expanded facility, in failure conditions or chemical fire, there has been no public disclosure by the company PlasRefine of worst-case outcomes, let alone day-to-day operations. Such omission is reprehensible.

5. As mentioned in the opening to this submission, the proposed site in the Industrial Park is 250 metres from residential properties, with further approved housing opposite the Preschool about to be constructed in March 2022. The prevailing winds in this area are south westerly. In winter average wind speeds for over more than 45 days exceed 45-50km steady winds, with peak winds now frequently exceeding 85kms/hour from June to October. The rate of contamination in such conditions, across some 35,000 shire residents' homes, is unspecified in any public document and would need to be addressed fully to ensure adequate understanding of air quality changes to which residents and livestock would be exposed.

6. The scoping report estimates that 80 to 90% of water used at the plant for washing incoming plastics would be recycled on site in a waste-water treatment plant. There is no detailed data on the contents of holding pools, dam and water pipe construction for holding areas, filtration, risk assessment of water contamination or mitigation or the effect on groundwater and bores in the location.

7. 20,000 litres of water will be pumped from the Moss Vale water main each day, with 10-20% of that wastewater going back into the Moss Vale sewerage plant. NSW has, quite rightly, strict water particulate and chemical emissions concentrate regulations. PlasRefine has not publicly stated what emission levels could be under possible failure conditions, nor the mitigation and prevention steps they propose, nor the various chemical compositions of such outputs and parts per million.

8. The plant proposes the use of Braddon Road, which does not physically exist yet but appears on the 2019 sub-division plan. The connection to the Hume Motorway for Northbound and Southbound truck movements uses small narrow connection roads ill-suited to what will likely be over 94,900 total movements annually, involving semi-trailer trucks of 20 tonnes or more, many of which are likely to be articulated with noisy air brakes, turning into a plant proposed to be located just 250 metres from residences.

9. During operations there will reportedly be 260 traffic movements a day, including 60 return trips by semi-trailers. That's over 40,000 semi-trailers truck movements, using single carriageway connections not suited to the weights these semi-trailers will be carrying coming in and out.

10. The plant is reported to be beneficial to the local economy through employment opportunity. However, at public meetings, no guarantee of significant employment is quantified, given that many of the plant processes will be fully automated.

11. The classification of this factory has, it is understood, allowed the proposal to advance without the requirement for it to be regulated and monitored by the EPA. No development of this kind so close to residences and schools should be enabled without total oversight and monitoring by the EPA.

There is no doubt Australia desperately needs to improve its ability to recycle plastic. It also needs government policy to massively reduce plastic waste at source and introduce suitable environmental plastics-minimisation policy to reduce need in future years from the current almost logarithmic growth in plastic waste. The proposed plant risks emissions of microplastics which are known carcinogens and destructive of quality agricultural and horticultural land in proximity to source, as well as damaging to cattle and other livestock. With a Council which has declined to support this proposal for many of the reasons stated above, and a community of thousands of concerned Citizens already submitting several thousand signatories, it is unconscionable abdication of environmental responsibility to place this plant in a rural environment close to housing. The nature of what will go on in this plant means its definition as light industrial process rather than a chemical transformation factory (which it is) is flawed and the plant should be located where there is infrastructure, logistics and safety mitigation to deal with the inevitable breakdowns that could occur in emissions of gases, smell, noise and water contamination. With so many coal plants due to retire, locations where all these risks have been mitigated for decades, why are such sites not a much better candidate location for this chemical repurposing site, some of the waste products of which could be used as energy stores to complement the battery, wind and solar energy sources suggested for some of those sites.

It is the strongly-held view of this Wingecarribee ratepayer that PlasRefine and its associates should not be granted approval for this facility with the lack of adequate infrastructure, emission controls and risk mitigation currently submitted. It's the right idea for environmental waste management in a very wrong semi-rural location.

Sincerely,
John Swainston.

See attached letter objecting to proposed Plasrefine facility in Moss Vale.

Please find attached the document created by a group of people in response to the major community concerns expressed in the Southern Highlands.
We believe the only outcome is a refusal of the application. This is NOT THE RIGHT SITE.

The concept of the major used plastics processing facility is good, HOWEVER, the chosen site appears significantly UNSUITABLE due to the following factors:
a. Road access to the processing facility via suburban roads like Beaconsfield Rd is totally unsuitable for 120,000 tonnes of waste plastic per year, plus a similar weight of the products exported from the facility. Until the local access road replacing the currently unformed Braddon rd (and extensions) is completed, any construction traffic would use existing overloaded or residential roads . Also, until the separately proposed Moss Vale bypass road is constructed, many local roads will be used, including the already overloaded Berrima Road.
b. Atmospheric pollution from the stage 2 processing plant, in particular VOC and other chemicals from treating various plastics being blown into residential and other commercial cavities in the vicinity, including the sensitive Garvan facility immediately adjacent to the plastics processing site.
c. The potential for pollution of the local water table and streams noting the number of dams in the vicinity and the Sydney water collection basin.

Surely a more suitable site for such a facility would be much closer to the Hume Freeway where there are suitable exits and entries for the size of trucks involved and the volumes of such B2 vehicles each day, as well as much larger distances to residential and child minding/educational facilities.