Glenda Stowell
Object
Glenda Stowell
Object
Blacktown South
,
New South Wales
Message
To whom it may concern
I would like to use this opportunity to lodge my formal objection to the proposed Energy from Waste plant proposal. As a resident in the Blacktown area, and a mother of children who have suffered from asthma, I am deeply concerned about the location and the proposed management of this plant.
I understand that that the existing landfill sites within Sydney are reaching maximum capacity, however any alternative solutions need to be reviewed thoroughly in terms of their long term environmental and health impacts. Financial benefits should not be the leading factor for decision making.
I support the submission by Blacktown City Council, which opposes the construction of a large energy from waste incinerator at Eastern Creek.
Like Council, I believe there are still significant information shortfalls in the Environmental Impact Statement, including the source of the waste and the inability of the applicant to guarantee procedures and processes that satisfactorily demonstrate how all waste will be appropriately sorted, and burnt to minimise the health impact on local residents.
I also believe the current state environmental legislation will not provide the community with sufficient protection from its likely emissions.
Please do not make Western Sydney even more disadvantaged by these kind of proposals, when there are other locations and solutions for consideration.
I will follow the NSW government's reaction to the objections to the proposal with much interest, together with other local residents.
I would like to use this opportunity to lodge my formal objection to the proposed Energy from Waste plant proposal. As a resident in the Blacktown area, and a mother of children who have suffered from asthma, I am deeply concerned about the location and the proposed management of this plant.
I understand that that the existing landfill sites within Sydney are reaching maximum capacity, however any alternative solutions need to be reviewed thoroughly in terms of their long term environmental and health impacts. Financial benefits should not be the leading factor for decision making.
I support the submission by Blacktown City Council, which opposes the construction of a large energy from waste incinerator at Eastern Creek.
Like Council, I believe there are still significant information shortfalls in the Environmental Impact Statement, including the source of the waste and the inability of the applicant to guarantee procedures and processes that satisfactorily demonstrate how all waste will be appropriately sorted, and burnt to minimise the health impact on local residents.
I also believe the current state environmental legislation will not provide the community with sufficient protection from its likely emissions.
Please do not make Western Sydney even more disadvantaged by these kind of proposals, when there are other locations and solutions for consideration.
I will follow the NSW government's reaction to the objections to the proposal with much interest, together with other local residents.
Name Withheld
Object
Name Withheld
Object
Erskine Park
,
New South Wales
Message
I object to this application due to the negative impact on the health of the residents of Sydney.
The toxic emissions will be both in the air we breathe & also in the water we drink,thereby causing major health implications for millions of people for many generations to come. How can anyone think that this is acceptable?
Below are just a few of the disadvantages of Incineration of waste;
* The high cost of incineration plant has been a turnoff of for municipal authorities and is only now being addressed with the introduction of WTE plants. The need for huge waste to incinerate has led to abandonment of other plans for recycling and reuse of waste. Dioxins are produced in the treatment and is a cancer forming chemical. These are produced in the smoke stack. The plants require skilled personnel for operation and continuous maintenance.
* A disadvantage of waste incineration is that flue gases produced during this process contain residues that can pollute the environment. Also, the amount of energy produced by incineration can only serve a small town. Incinerated waste produces ash that contains toxins. If not handled properly, these toxins can lead to environmental problems when toxicity levels become high...
* Incineration facilities are expensive to build, operate, and maintain⁵. The high costs associated with this method of waste disposal may encourage waste generators to seek other alternatives for dealing with their waste. These facilities also require skilled staff to run and maintain them.
Smoke and ash emitted by the chimneys of incinerators include acid gases, nitrogen oxide, heavy metals, particulates, and dioxin, which is a carcinogen⁵,⁶. While incineration pollution control technology is evolving to reduce these pollutants, it has been found that even with controls in place, some remaining dioxin still enters the atmosphere⁷.
Some critics of incineration claim that incineration ultimately encourages more waste production because incinerators require large volumes of waste to keep the fires burning, and local authorities may opt for incineration over recycling and waste reduction programs⁵. It is has been estimated that recycling conserves 3-5 times more energy than Waste-to-Energy generates because the energy required to make products derived from recycled materials is significantly less than the energy used to produce them from virgin raw materials⁸.
In developing countries, waste incineration is likely not as practical as in developed countries, since a high proportion of waste in developing countries is composed of kitchen scraps. Such organic waste is composed of higher moisture content (40-70%) than waste in industrialized countries (20-40%), making it more difficult to burn³.
Do any of these sound like the way forward? NO! Do they sound like they are worth the risk to human life? NO!
The way forward will require a complete change in the way we think about rubbish & the way we take responsibility for our garbage.
THIS IS THE WAY FORWARD!
"Recycling and waste reduction must be considered as our first line of defense to reduce our overall waste stream, and this also must include composting our organic waste instead of throwing it away. When we think about it, there truly is no "away," as all waste must go somewhere. Many of the materials that are thrown away have the potential to be used to produce new items, and not reusing these materials is a large waste of resources"
Not creating more problems by burning our rubbish & increasing pollution & illness!
Please also take the time to read through this report
www.ntn.org.au/wp/wp-content/uploads/2014/06/NTN-waste-to-energy-incineration-report-2013..pdf
The toxic emissions will be both in the air we breathe & also in the water we drink,thereby causing major health implications for millions of people for many generations to come. How can anyone think that this is acceptable?
Below are just a few of the disadvantages of Incineration of waste;
* The high cost of incineration plant has been a turnoff of for municipal authorities and is only now being addressed with the introduction of WTE plants. The need for huge waste to incinerate has led to abandonment of other plans for recycling and reuse of waste. Dioxins are produced in the treatment and is a cancer forming chemical. These are produced in the smoke stack. The plants require skilled personnel for operation and continuous maintenance.
* A disadvantage of waste incineration is that flue gases produced during this process contain residues that can pollute the environment. Also, the amount of energy produced by incineration can only serve a small town. Incinerated waste produces ash that contains toxins. If not handled properly, these toxins can lead to environmental problems when toxicity levels become high...
* Incineration facilities are expensive to build, operate, and maintain⁵. The high costs associated with this method of waste disposal may encourage waste generators to seek other alternatives for dealing with their waste. These facilities also require skilled staff to run and maintain them.
Smoke and ash emitted by the chimneys of incinerators include acid gases, nitrogen oxide, heavy metals, particulates, and dioxin, which is a carcinogen⁵,⁶. While incineration pollution control technology is evolving to reduce these pollutants, it has been found that even with controls in place, some remaining dioxin still enters the atmosphere⁷.
Some critics of incineration claim that incineration ultimately encourages more waste production because incinerators require large volumes of waste to keep the fires burning, and local authorities may opt for incineration over recycling and waste reduction programs⁵. It is has been estimated that recycling conserves 3-5 times more energy than Waste-to-Energy generates because the energy required to make products derived from recycled materials is significantly less than the energy used to produce them from virgin raw materials⁸.
In developing countries, waste incineration is likely not as practical as in developed countries, since a high proportion of waste in developing countries is composed of kitchen scraps. Such organic waste is composed of higher moisture content (40-70%) than waste in industrialized countries (20-40%), making it more difficult to burn³.
Do any of these sound like the way forward? NO! Do they sound like they are worth the risk to human life? NO!
The way forward will require a complete change in the way we think about rubbish & the way we take responsibility for our garbage.
THIS IS THE WAY FORWARD!
"Recycling and waste reduction must be considered as our first line of defense to reduce our overall waste stream, and this also must include composting our organic waste instead of throwing it away. When we think about it, there truly is no "away," as all waste must go somewhere. Many of the materials that are thrown away have the potential to be used to produce new items, and not reusing these materials is a large waste of resources"
Not creating more problems by burning our rubbish & increasing pollution & illness!
Please also take the time to read through this report
www.ntn.org.au/wp/wp-content/uploads/2014/06/NTN-waste-to-energy-incineration-report-2013..pdf
Name Withheld
Object
Name Withheld
Object
Minchinbury
,
New South Wales
Message
I object to this facility. I am 12 years old and live very close to it. I know many people in this area who have asthma and other lung problems, including myself and when this waste fills up the community, we will regret allowing it to go ahead. I am a child who deserves to lead a healthy life and I should not have this threatened. I have been learning about human rights at school and the right to a healthy life is a basic human right. This facility will stop my rights. I have also been learning about alternative forms of energy and there are so many other safer alternatives such as solar and wind power. This form of energy has too many negative consequences. Do not allow it it to ahead. It's not fair on me and my friends. We can't just move away, we are too young to be able to afford to do that.
Name Withheld
Object
Name Withheld
Object
Minchinbury
,
New South Wales
Message
I object to this proposal for many reasons. Firstly, I cannot afford to move anywhere else and am required for family reasons to reside in MInchinbury. I already have reduced lung capacity and would not like to be located so close to an incinerator spewing out toxic emissions. I also have my family to consider; my children and grandchildren live in Minchinbury, too. I don't want them to be exposed to harmful emissions, particularly my grandchild who suffers from a chronic medical condition. I witnessed first hand the same owners of this proposal breach their development conditions with the waste facility. There was construction at night, and even during Easter public holidays. Coincidently, as soon as the grand opening occurred, the noises ceased. Coincidence, I think not. They CANNOT be trusted to keep the health and safety of surrounding residents as a priority. I have read many reports on this, including the glossy propaganda I found in my letterbox and was horrified to read the report provided by the company was flawed. Statistics were completely wrong in regards to the level of toxins found in breast milk. How could they get it so wrong and how can anything else published by this company be trusted? There is simply not enough good news surrounding this type of facility and as such, it should not go ahead in such close proximity to residential areas, let alone anywhere. I strongly object to this proposal.
Name Withheld
Object
Name Withheld
Object
Erskine Park
,
New South Wales
Message
I object once again to this proposal, this time in its amended form.
I will begin with my original reasons below, which haven't changed.
*As one of the people living in close proximity to this proposed waste facility, I want to say how disappointed I am that it is even being considered. I can't imagine that the people involved in this venture would feel the same if it was near their homes & families. We have such a huge amount of land in this country that there is no need to have something like this is such close proximity to densely populated family suburbs. You have also done nothing to make the reports that you have had done & linked to, easier for normal people to understand, so I guess you are hoping that most wont wade through the enormous amount of reading material & or will just give up. Even if this is the case & they don't put in a submission in objection to this, it doesn't mean that they don't deserve to live a healthy long life & have their families breathe in clean air every day, not this filth 24 hours a day 7 days a week. Seriously, WHAT ARE YOU THINKING? I have read most of the attachments & resources provided but believe that they have been skewed towards what you want the end result to be. Have not enough mistakes been made with people's lives & health? There were times when we thought many things were safe with the limited knowledge & resources we had available but people have paid with their lives because of someone's greed & lack of care of their fellow human beings situation. Please care that many many people's lives, loved ones & quality of life will be affected by this. Once it's done, it's too late. Cancer cases in our society are raging ahead with no way of slowing it down. Let's err on the side of caution this time
Please do not make this mistake that so many of us will have to live with.
& now to add my 2017 reasons;
* Reduced air quality & toxic particles in the air we breathe, causing more health problems than we accurately foresee. Some of the particles will be so small that there is no technology for measuring them but you will certainly be able to breathe them in.
* We, in Western Sydney, already have the worst air quality & the highest number of respiratory problems/diseases in Sydney. We have days where the EPA warns people with respiratory problems to stay inside. Imagine what 2 or more of the world's largest incinerators, operating 24 hours a day, 7 days a week would do to our health.
* Pollution of Prospect Reservoir - Prospect rReservoir is a major catchment for Sydney's drinking water & is only a few kms from the site of these incinerators. Who in their right mind would think that this is a smart move or even acceptable?
* The proponent has a long list & history of EPA breaches & we believe that he/they cannot be trusted to do the right thing by the community or the environment.
* The areas most drastically affected by this, are also the ones that are densely populated residential areas, full of young families, schools, kindies, sporting fields, aged care facilities. We already have too many tips, waste transfer stations, etc. in close proximity to us. Our health cannot take any more. WE MATTER TOO!
* Incinerators & their technology are being phased out in Europe - This is NOT the way forward, nor is it clean or green! Lets not find out years down the track that we have made another huge environmental mistake, like they have, but one that they are unfortunately stuck with because of the long contracts they are locked into.
* It will also be in the middle of a major industrial area, where thousands of people spend their working lives.
* The Incinerators will be visible from Erskine Park which will immediately affect property values. We shouldn't lose our health & money, for them to make more.
* These types of waste management solutions have been rejected in Australia for many, many years. They weren't right then & they are not right now & never will be. This is a money making venture, pure & simple, not an environmentally responsible one. What we need is education & reduction of garbage & a totally new way of thinking about this, not an outdated version that no one in the world think is a good idea anymore. Unfortunately there is no way to make money from education & reduction, so new ideas will never be put forward by this company until they will bring big profit too.
To help you understand the lack of care the company has for anyone but themselves, I would like you to know a couple of the "alternative truths" (lies) & flippant remarks that were made at a meeting with them recently:
Yes, peoples health will be affected but 1 in 2 die of cancer anyway.
"There are no discernible health risks", This is not to say it is safe, because they have admitted there are health risks. What they are actually meaning is, that any disease you may get, wont be able to attributed to their company & or this project specifically.
Whilst residents were speaking at the Erskine Park meeting there was eye rolling, whispering behind hands, ridiculing & giggling, by the next Generation panel, whilst also interrupting & trying to put the residents off what they were saying.
They have outright lied about;
* being able to measure particles that are too small for any machine invented.
*Greenpeace approving of waste to energy incinerators, the quote was
"Greenpeace are all for incineration, they get angry when we don't burn enough"
* In a human health assessment, Next Generation stated that breast milk only contains 0.04% fat. It is actually 4%, meaning they miscalculated how much contamination infants would ingest....they state the fraction of contaminate ingested from milk is 0.9%...
When it is actually 90%....
How will this affect babies?
These are just a few of the lies that have been told by this company to try to get their project passed, regardless of the negative impact it will have on millions & millions of people. These people/this company have proved, now & in the past, that they are not to be trusted & will do anything to make more money. This is why we cannot trust them with people's health & our environment.
We, as a society, continue to put profit before people & whilst I dont know how to turn this around, I ask you, the decision makers, to help make this a fair playing field for all.
Everyone has value, not just the rich, who just seem to want to get richer & never have enough.
I work hard to have a home & my loved ones mean the world to me and I shouldnt have to fear losing them to illness or my home's worth. I shouldnt have to feel that I cant grow some veggies in the garden because of the invisible toxins they will be coated in or that I can't go for a walk each day because of the toxic particles that I will be sucking in.
There are millions of hard working people, living honest simple lives that deserve better than this company has in mind for them. We are not asking to be millionaires like them, or own multi million dollar yachts like them or own mansions in Vaucluse like them, just some clean air & water... not too much to ask is it? Apparently Next Generation thinks it is, or more likely is the fact that they haven't given the "poor people" a thought at all.
The job you have, has an enormous responsibility to this generation & many generations to come, please do the right thing by them & reject this application & others like it, that will destroy people's health & ruin lives.
I will begin with my original reasons below, which haven't changed.
*As one of the people living in close proximity to this proposed waste facility, I want to say how disappointed I am that it is even being considered. I can't imagine that the people involved in this venture would feel the same if it was near their homes & families. We have such a huge amount of land in this country that there is no need to have something like this is such close proximity to densely populated family suburbs. You have also done nothing to make the reports that you have had done & linked to, easier for normal people to understand, so I guess you are hoping that most wont wade through the enormous amount of reading material & or will just give up. Even if this is the case & they don't put in a submission in objection to this, it doesn't mean that they don't deserve to live a healthy long life & have their families breathe in clean air every day, not this filth 24 hours a day 7 days a week. Seriously, WHAT ARE YOU THINKING? I have read most of the attachments & resources provided but believe that they have been skewed towards what you want the end result to be. Have not enough mistakes been made with people's lives & health? There were times when we thought many things were safe with the limited knowledge & resources we had available but people have paid with their lives because of someone's greed & lack of care of their fellow human beings situation. Please care that many many people's lives, loved ones & quality of life will be affected by this. Once it's done, it's too late. Cancer cases in our society are raging ahead with no way of slowing it down. Let's err on the side of caution this time
Please do not make this mistake that so many of us will have to live with.
& now to add my 2017 reasons;
* Reduced air quality & toxic particles in the air we breathe, causing more health problems than we accurately foresee. Some of the particles will be so small that there is no technology for measuring them but you will certainly be able to breathe them in.
* We, in Western Sydney, already have the worst air quality & the highest number of respiratory problems/diseases in Sydney. We have days where the EPA warns people with respiratory problems to stay inside. Imagine what 2 or more of the world's largest incinerators, operating 24 hours a day, 7 days a week would do to our health.
* Pollution of Prospect Reservoir - Prospect rReservoir is a major catchment for Sydney's drinking water & is only a few kms from the site of these incinerators. Who in their right mind would think that this is a smart move or even acceptable?
* The proponent has a long list & history of EPA breaches & we believe that he/they cannot be trusted to do the right thing by the community or the environment.
* The areas most drastically affected by this, are also the ones that are densely populated residential areas, full of young families, schools, kindies, sporting fields, aged care facilities. We already have too many tips, waste transfer stations, etc. in close proximity to us. Our health cannot take any more. WE MATTER TOO!
* Incinerators & their technology are being phased out in Europe - This is NOT the way forward, nor is it clean or green! Lets not find out years down the track that we have made another huge environmental mistake, like they have, but one that they are unfortunately stuck with because of the long contracts they are locked into.
* It will also be in the middle of a major industrial area, where thousands of people spend their working lives.
* The Incinerators will be visible from Erskine Park which will immediately affect property values. We shouldn't lose our health & money, for them to make more.
* These types of waste management solutions have been rejected in Australia for many, many years. They weren't right then & they are not right now & never will be. This is a money making venture, pure & simple, not an environmentally responsible one. What we need is education & reduction of garbage & a totally new way of thinking about this, not an outdated version that no one in the world think is a good idea anymore. Unfortunately there is no way to make money from education & reduction, so new ideas will never be put forward by this company until they will bring big profit too.
To help you understand the lack of care the company has for anyone but themselves, I would like you to know a couple of the "alternative truths" (lies) & flippant remarks that were made at a meeting with them recently:
Yes, peoples health will be affected but 1 in 2 die of cancer anyway.
"There are no discernible health risks", This is not to say it is safe, because they have admitted there are health risks. What they are actually meaning is, that any disease you may get, wont be able to attributed to their company & or this project specifically.
Whilst residents were speaking at the Erskine Park meeting there was eye rolling, whispering behind hands, ridiculing & giggling, by the next Generation panel, whilst also interrupting & trying to put the residents off what they were saying.
They have outright lied about;
* being able to measure particles that are too small for any machine invented.
*Greenpeace approving of waste to energy incinerators, the quote was
"Greenpeace are all for incineration, they get angry when we don't burn enough"
* In a human health assessment, Next Generation stated that breast milk only contains 0.04% fat. It is actually 4%, meaning they miscalculated how much contamination infants would ingest....they state the fraction of contaminate ingested from milk is 0.9%...
When it is actually 90%....
How will this affect babies?
These are just a few of the lies that have been told by this company to try to get their project passed, regardless of the negative impact it will have on millions & millions of people. These people/this company have proved, now & in the past, that they are not to be trusted & will do anything to make more money. This is why we cannot trust them with people's health & our environment.
We, as a society, continue to put profit before people & whilst I dont know how to turn this around, I ask you, the decision makers, to help make this a fair playing field for all.
Everyone has value, not just the rich, who just seem to want to get richer & never have enough.
I work hard to have a home & my loved ones mean the world to me and I shouldnt have to fear losing them to illness or my home's worth. I shouldnt have to feel that I cant grow some veggies in the garden because of the invisible toxins they will be coated in or that I can't go for a walk each day because of the toxic particles that I will be sucking in.
There are millions of hard working people, living honest simple lives that deserve better than this company has in mind for them. We are not asking to be millionaires like them, or own multi million dollar yachts like them or own mansions in Vaucluse like them, just some clean air & water... not too much to ask is it? Apparently Next Generation thinks it is, or more likely is the fact that they haven't given the "poor people" a thought at all.
The job you have, has an enormous responsibility to this generation & many generations to come, please do the right thing by them & reject this application & others like it, that will destroy people's health & ruin lives.
Max Y
Object
Max Y
Object
Minchinbury
,
New South Wales
Message
I support the submission by Blacktown City Council, which opposes the construction of a large energy from waste incinerator at Eastern Creek.
Like Council, I believe there are still significant information shortfalls in the Environmental Impact Statement, including the source of the waste and the inability of the applicant to guarantee procedures and processes that satisfactorily demonstrate how all waste will be appropriately sorted.
I also believe the current state environmental legislation will not provide the community with sufficient protection from its likely emissions.
Phil Bradley
Object
Phil Bradley
Object
Winston Hills
,
New South Wales
Message
Supplementary Submission Objecting to the proposed Energy from Waste [Incinerator] Facility at Eastern Creek - by Phil Bradley (BEng-Civil, Grad Dip Ed Tech)
1. Ecologically Endangered Cumberland Plain Woodland and Eucalyptus River-Flat Forest
Approximately 0.3 ha of Cumberland Plain Woodland and 3 ha of Eucalyptus River-flat forest are proposed to be cleared for the development. These are endangered ecological communities supposedly protected under the Threatened Species Conservation Act. Eight habitat trees within the proposal footprint will be cleared. 
Many vulnerable and endangered animals live in this area land clearing will further threaten these animals. These areas should be protected.
2. Cancer Clusters caused by Incinerators
There is a lot of international evidence of a significantly increased risk of cancer and resultant deaths within 10 kilometres or more of industrial incinerators. This risk ini such a highly populated region is totally unacceptable.
The references below to dioxin emissions, their inadequate assessment and health risks are further reason for concern about increased cancer rates arising from the proposed Incinerator.
3. Serious Concerns Arising From the Environmental Risk Sciences Pty Ltd (enRiskS) Review of the Human Health Risk Assessment (HHRA) (provided as Appendix O of a revised EIS for the proposed Energy from Waste [Incinerator] Facility, Eastern Creek.)
This review was commissioned by the NSW EPA to the EIS report prepared by Fichtner Consulting Engineers Limited on behalf of The Next Generation NSW Pty Ltd. In particular, I draw attention to the following sections of this review, which raise serious concerns sufficient to have the Incinerator proposal rejected.
"3.6 Section 6 - IRAP Model Assumptions and Inputs
.........
Air
It is assumed that the air quality modelling undertaken in Appendix L of this EIS would be relevant for use in determining vapour phase and particle phase concentrations to feed into the IRAP model. The report does not definitively state that this is what was done nor does it include a table listing the values determined in Appendix L that were used in this assessment.........
This would all need to be checked to be confident that the results are acceptable. It should be clarified which approach was adopted and it would be preferred that the modelling from Appendix L of the EIS was used if this has not occurred.
People
....... Body weight for children is higher than recommended by Australian authorities (correct value would result in higher risk estimates so it is not conservative). They should have been adjusted to those recommended in Australian guidance.
Intake of produce should have been adjusted for Australian recommendations.
.......,,,
Assumptions in regard to breast milk used in the assessment are listed in Section 6.4.2 as:
- Exposure duration of infant to breast milk = 1 year
- Proportion of ingested dioxin that is stored in fat = 0.9% XXX
- Proportion of mother's weight that is stored in fat = 0.3%
- Fraction of fat in breast milk = 0.04% XXX
- Fraction of ingested contaminant that is absorbed = 0.9% XXX
- Half-life of dioxins in adults = 2,555 days XXX
- Ingestion rate of breast milk = 0.688 kg/day XXX
There has been an error in how these assumptions have been listed (or the values used are not correct). For example, the fraction of fat in breast milk is 4% (or a fraction of 0.04) not 0.04% and the fraction of ingested contaminant absorbed by the child from the milk is 90% (or 0.9 fraction) not 0.9%. Also, according to the National Dioxins Program risk assessment, the ingestion rate of breast milk assumed for Australia is 0.75 kg/day and the half-life of dioxins is assumed to be more than 4,000 days (National Dioxins Program 2005).
A complete assessment of the calculations undertaken in the model and the impact of the assumed values for each parameter compared to the values recommended in Australia has not been undertaken but could be if required.
[In my opinion, this complete (re)assessment suggested by Environment Risk Sciences Pty Ltd must be undertaken and is likely to provide further evidence to ensure this Incinerator development is rejected!
Dioxins are of course highly toxic and carcenogenic!]
Section 6.6 and Tables 6.4 and 6.5 outline how the emission rates for each chemical were determined. The emission rates are based on the emission limits in the stack, however, they are based on European requirements for stack limits not those listed in the POEO Clean Air Regulation which is what the facility must comply with here. A quick check of some of the Group 6 requirements for scheduled premises indicate that some of the levels assumed in this assessment may be too high for a facility in NSW. The assessment should be redone using the relevant NSW limits as the starting point for estimating emissions (NSW Government 2010).
3.7 Section 7 - Risk Characterisation
Section 7 discusses the results of the risk assessment and estimates risk. Given the many issues discussed above, a detailed assessment of this section has not been undertaken. Matters that have been identified in a short review include:
- Slight changes in estimated risks between the original version and this more recent version - presumably this is due to changes in the air quality modelling but it is not possible to determine why these changes have occurred. For dioxins in breast milk the risk estimates at the point of maximum impact for resident and farmer have been reversed - it is not clear which is correct.
- Annualised risk estimates for cancer - the only place annualised risk estimates are used in NSW is the land use safety planning guidance where it is used to establish limits on fatality and injury risk estimates for fire, explosion and other safety incidents. It is not appropriate nor is it compliant with any guidance about assessing risk for cancer in Australia. The lifetime risk estimate is the only relevant parameter to use in assessing whether cancer risk at the facility is acceptable. As a result, the cancer risk estimated for the farmer at the point of maximum impact is not acceptable for this facility and the cancer risks estimated for residents at the point of maximum impact and in the surrounding suburbs are within 2-10 fold of the acceptable value. Such a small margin of safety might require additional pollution control measures be considered.
.........
3.8 Section 8 - Conclusions
Given the issues already outlined the conclusions cannot be accepted until the risk assessment is revised in accordance with Australian guidance.
This Environmental Risk Sciences report is more than sufficient on its own to reject the Incinerator development!
I also support the submission by Blacktown City Council
Council's Submission opposes the construction of this waste incinerator at Eastern Creek.
Like Council, I believe there are still significant information shortfalls in the Environmental Impact Statement, including the source of the waste and the inability of the applicant to guarantee procedures and processes that satisfactorily demonstrate how all waste will be appropriately sorted. Incinerator waste is admitted by the proponent to be continually changing, so therefore the chemical nature of the incinerator emissions will change also, making opportunities for people to avoid adverse health effects from these emissions very limited. I also believe the current state environmental legislation will not provide the community with sufficient protection from its likely emissions.
The proponent has failed to guarantee that their predictions of low emissions are valid and achievable.
The incinerator proposal fails to comply with the area's zoning requirements and is therefore prohibited.
It will have a significant impact on critically endangered ecological communities.
Furthermore the location and design of the Energy from Waste plant fails to encourage a high standard of development.
1. Ecologically Endangered Cumberland Plain Woodland and Eucalyptus River-Flat Forest
Approximately 0.3 ha of Cumberland Plain Woodland and 3 ha of Eucalyptus River-flat forest are proposed to be cleared for the development. These are endangered ecological communities supposedly protected under the Threatened Species Conservation Act. Eight habitat trees within the proposal footprint will be cleared. 
Many vulnerable and endangered animals live in this area land clearing will further threaten these animals. These areas should be protected.
2. Cancer Clusters caused by Incinerators
There is a lot of international evidence of a significantly increased risk of cancer and resultant deaths within 10 kilometres or more of industrial incinerators. This risk ini such a highly populated region is totally unacceptable.
The references below to dioxin emissions, their inadequate assessment and health risks are further reason for concern about increased cancer rates arising from the proposed Incinerator.
3. Serious Concerns Arising From the Environmental Risk Sciences Pty Ltd (enRiskS) Review of the Human Health Risk Assessment (HHRA) (provided as Appendix O of a revised EIS for the proposed Energy from Waste [Incinerator] Facility, Eastern Creek.)
This review was commissioned by the NSW EPA to the EIS report prepared by Fichtner Consulting Engineers Limited on behalf of The Next Generation NSW Pty Ltd. In particular, I draw attention to the following sections of this review, which raise serious concerns sufficient to have the Incinerator proposal rejected.
"3.6 Section 6 - IRAP Model Assumptions and Inputs
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Air
It is assumed that the air quality modelling undertaken in Appendix L of this EIS would be relevant for use in determining vapour phase and particle phase concentrations to feed into the IRAP model. The report does not definitively state that this is what was done nor does it include a table listing the values determined in Appendix L that were used in this assessment.........
This would all need to be checked to be confident that the results are acceptable. It should be clarified which approach was adopted and it would be preferred that the modelling from Appendix L of the EIS was used if this has not occurred.
People
....... Body weight for children is higher than recommended by Australian authorities (correct value would result in higher risk estimates so it is not conservative). They should have been adjusted to those recommended in Australian guidance.
Intake of produce should have been adjusted for Australian recommendations.
.......,,,
Assumptions in regard to breast milk used in the assessment are listed in Section 6.4.2 as:
- Exposure duration of infant to breast milk = 1 year
- Proportion of ingested dioxin that is stored in fat = 0.9% XXX
- Proportion of mother's weight that is stored in fat = 0.3%
- Fraction of fat in breast milk = 0.04% XXX
- Fraction of ingested contaminant that is absorbed = 0.9% XXX
- Half-life of dioxins in adults = 2,555 days XXX
- Ingestion rate of breast milk = 0.688 kg/day XXX
There has been an error in how these assumptions have been listed (or the values used are not correct). For example, the fraction of fat in breast milk is 4% (or a fraction of 0.04) not 0.04% and the fraction of ingested contaminant absorbed by the child from the milk is 90% (or 0.9 fraction) not 0.9%. Also, according to the National Dioxins Program risk assessment, the ingestion rate of breast milk assumed for Australia is 0.75 kg/day and the half-life of dioxins is assumed to be more than 4,000 days (National Dioxins Program 2005).
A complete assessment of the calculations undertaken in the model and the impact of the assumed values for each parameter compared to the values recommended in Australia has not been undertaken but could be if required.
[In my opinion, this complete (re)assessment suggested by Environment Risk Sciences Pty Ltd must be undertaken and is likely to provide further evidence to ensure this Incinerator development is rejected!
Dioxins are of course highly toxic and carcenogenic!]
Section 6.6 and Tables 6.4 and 6.5 outline how the emission rates for each chemical were determined. The emission rates are based on the emission limits in the stack, however, they are based on European requirements for stack limits not those listed in the POEO Clean Air Regulation which is what the facility must comply with here. A quick check of some of the Group 6 requirements for scheduled premises indicate that some of the levels assumed in this assessment may be too high for a facility in NSW. The assessment should be redone using the relevant NSW limits as the starting point for estimating emissions (NSW Government 2010).
3.7 Section 7 - Risk Characterisation
Section 7 discusses the results of the risk assessment and estimates risk. Given the many issues discussed above, a detailed assessment of this section has not been undertaken. Matters that have been identified in a short review include:
- Slight changes in estimated risks between the original version and this more recent version - presumably this is due to changes in the air quality modelling but it is not possible to determine why these changes have occurred. For dioxins in breast milk the risk estimates at the point of maximum impact for resident and farmer have been reversed - it is not clear which is correct.
- Annualised risk estimates for cancer - the only place annualised risk estimates are used in NSW is the land use safety planning guidance where it is used to establish limits on fatality and injury risk estimates for fire, explosion and other safety incidents. It is not appropriate nor is it compliant with any guidance about assessing risk for cancer in Australia. The lifetime risk estimate is the only relevant parameter to use in assessing whether cancer risk at the facility is acceptable. As a result, the cancer risk estimated for the farmer at the point of maximum impact is not acceptable for this facility and the cancer risks estimated for residents at the point of maximum impact and in the surrounding suburbs are within 2-10 fold of the acceptable value. Such a small margin of safety might require additional pollution control measures be considered.
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3.8 Section 8 - Conclusions
Given the issues already outlined the conclusions cannot be accepted until the risk assessment is revised in accordance with Australian guidance.
This Environmental Risk Sciences report is more than sufficient on its own to reject the Incinerator development!
I also support the submission by Blacktown City Council
Council's Submission opposes the construction of this waste incinerator at Eastern Creek.
Like Council, I believe there are still significant information shortfalls in the Environmental Impact Statement, including the source of the waste and the inability of the applicant to guarantee procedures and processes that satisfactorily demonstrate how all waste will be appropriately sorted. Incinerator waste is admitted by the proponent to be continually changing, so therefore the chemical nature of the incinerator emissions will change also, making opportunities for people to avoid adverse health effects from these emissions very limited. I also believe the current state environmental legislation will not provide the community with sufficient protection from its likely emissions.
The proponent has failed to guarantee that their predictions of low emissions are valid and achievable.
The incinerator proposal fails to comply with the area's zoning requirements and is therefore prohibited.
It will have a significant impact on critically endangered ecological communities.
Furthermore the location and design of the Energy from Waste plant fails to encourage a high standard of development.
Name Withheld
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Mt druitt
,
New South Wales
Message
I am writing to lodge my firm opposition to the proposed construction of the TNG incinerator at Eastern Creek, and strongly urge the minister for planning (Anthony Roberts), to show common sense and reject the proposal. It is utter lunacy to build such a massive incinerator in the heart of a residential area, especially when the company has acknowledged it can not guarantee 100% that harmful pollutants will not be released into the environment. When dealing with people's lives, anything less than 100% safety is unacceptable...
The area is full of young families with little children, we can not condemn these children to potentially a future of sickness, when you have the power to prevent this. In addition it must be pointed out Western Sydney has the highest rate P.T.O. Rate of Vascular & Respiratory problems in the state. These problems will only be exacerbated by the incinerators emissions, and no doubt also by the 504 trucks a day, expected to deliver waste to the incinerator. Our roads are clogged as it is, how much worse will they become with these trucks.
In addition, the TNG, The New Generation incinerator is an ironic misnomer as best, for already in Europe these types of incinerators are being phased out.
Surely Australia is as advanced technologiically as Europe, so why is old technology now being introduced into Australia.
Finally i am personally tired of Western Sydney being a dumping ground with nuclear waste, an Airport with no curfew, and now an incinerator...
If the owner is so certain of the safety and need of such an incinerator, he can build it in his own backyard!.
Futhermore, if the owner has failed to meet Environmental Safety Standards now, before the incinerator is even constructed, what will he do once once it is actually constructed..
The old adage is very apt "PREVENTION IS BETTER THAN CURE"....
The area is full of young families with little children, we can not condemn these children to potentially a future of sickness, when you have the power to prevent this. In addition it must be pointed out Western Sydney has the highest rate P.T.O. Rate of Vascular & Respiratory problems in the state. These problems will only be exacerbated by the incinerators emissions, and no doubt also by the 504 trucks a day, expected to deliver waste to the incinerator. Our roads are clogged as it is, how much worse will they become with these trucks.
In addition, the TNG, The New Generation incinerator is an ironic misnomer as best, for already in Europe these types of incinerators are being phased out.
Surely Australia is as advanced technologiically as Europe, so why is old technology now being introduced into Australia.
Finally i am personally tired of Western Sydney being a dumping ground with nuclear waste, an Airport with no curfew, and now an incinerator...
If the owner is so certain of the safety and need of such an incinerator, he can build it in his own backyard!.
Futhermore, if the owner has failed to meet Environmental Safety Standards now, before the incinerator is even constructed, what will he do once once it is actually constructed..
The old adage is very apt "PREVENTION IS BETTER THAN CURE"....
Leslie Perez
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Leslie Perez
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St Clair
,
New South Wales
Message
As a resident of St Clair I am concerned about the smell, pollution and health problems associated with another landfill facility which will hold up to 300,000 tinned of waste and incinerate this. We are already in a basin which holds immense heat in the summer. I can only imagine the conditions will worsen with another landfill in the area. At times, the smell from the current landfill is so unbearable I am unable to open my windows. With a number of schools and recreational spaces in the area, I can hardly fathom that this - and the detrimental impact it will have in the members of our community - is being considered for approval. As a parent of a primary school aged child, I shudder to think of the smell he'll have to bear at school as another landfill fills our air with its wafting stench. Please listen to the members of the community who have clearly shown that we are against another landfill in such close proximity.
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44 buring cresent minchinbury n+
,
New South Wales
Message
to whom it may concern I oppose to building a Energy from
Waste Facility at Eastern Creek because I live opposite the site in a straight line about 1to half a kilometres away the burning from waste for the sake of it bad air dirty air burn to be done with will not give us any guaranty that it doesn't harm us my family go on daily walks with our dog and I have a organic garden which we eat daily from it we will be the losers if this goes ahead with it I SAY NO TO A EFW SITE
Waste Facility at Eastern Creek because I live opposite the site in a straight line about 1to half a kilometres away the burning from waste for the sake of it bad air dirty air burn to be done with will not give us any guaranty that it doesn't harm us my family go on daily walks with our dog and I have a organic garden which we eat daily from it we will be the losers if this goes ahead with it I SAY NO TO A EFW SITE