Woodlawn Advanced Energy Recovery Centre SUB-51904479 - Woodlawn ARC: SSD-21184278

The proposal by the French company Veolia to operate a waste incinerator at Tarago NSW endangers Australians, as did the earlier French nuclear bomb tests in the Pacific Ocean. Scientific research demonstrates health-damaging residual waste and pollution are inherently generated from waste incineration facilities such as that proposed by Veolia for Tarago. Similar proposals by the same French company have been dismissed recently by the ACT and NSW Governments after thorough investigation.

Not only would Veolia's proposed waste incinerator at Tarago be negative because of its impact on the health of people in the Tarago district, it would also not be an effective nor efficient means of energy production as claimed be Veolia. That company has great 'greenwashing' credentials, as the residents of the Tarago district have witnessed over the years with Veolia's dumping of Sydney's waste in the Woodlawn open-cut mine site. 'Energy from waste' is more greenwashing propaganda by Veolia in promoting waste incineration. Even the proposed facility's title, 'Advanced Energy Recovery Centre' is garbage.
I doubt the NSW Government, and its responsible top bureaucrats, will survive should they agree to Veolia's 'evil' waste incinerator at Tarago.

I live in Goulburn NSW & I have been doing some research on waste to energy incinerators. What I have found doing a small search is Very Alarming. There's a growing backlash over incinerating garbage in Europe.
1) The big paradox 
Across Europe, Waste to Energy incineration is promoted, by some, as an alternative to landfilling for the treatment of waste. According to Eurostat, in the 10 years running up to 2016, the amount of waste incinerated increased by 30% [1]. The data also reveals that in the last 10 years CO2 emissions from incinerators have doubled. In 2017, over 40Mt of fossil CO2 was released by WTE incinerators in the EU 28 countries [2].
The CO2 emitted per tonne of waste incinerated depends on the composition of the waste. Eurostat statistics show that the majority of the increase in waste incinerated comes from so-called residual municipal solid waste (MSW) which produces significant amounts of CO2. 
Each tonne of MSW incinerated typically releases between 0.7 and 1.7 tonnes of CO2 [3]. This includes emissions of both fossil CO2 (e.g. from burning plastics) and biogenic CO2 (e.g. from burning wood, paper and food). Although biogenic CO2 is directly released into the atmosphere making a significant contribution to climate change, only the CO2 emissions from fossil sources will be considered for the purposes of a global analysis – an important loophole in GHG emissions accountability. 
On top of this, evidence indicates that more than half of what is currently being incinerated could have been recycled or composted [4], suggesting that much of Europe’s WTE incineration capacity is being used to burn valuable resources that could have had a better environmental outcome. WTE incineration is proving to be a barrier to improving recycling rates and it creates a need to replace these resources at a high environmental cost, and that cost is not included in the Eurostat figures.
2)Shouldn’t we just stop incinerating waste?
The carbon intensity of European incinerators is a significant (540gr CO2/kWh)[4], around twice the concentration of CO2 emissions derived from the average EU electricity grid (296gr CO2/kWh) [5] and significantly greater than the energy produced through conventional fossil fuel sources such as gas. 
Since these infrastructures are meant to last for about 20-30 years, continued use of incineration is simply delaying a much needed, and urgent, transition to less carbon-intensive power generation infrastructures such as wind and solar renewable energy whilst also undermining the move to lower-carbon options for waste management, including the re-design of products to increase recyclability and longevity.
It would be environmentally irresponsible to continue to promote Waste to Energy infrastructures that are already largely outperformed by the EU average and even worse, by conventional fossil fuel energy generation such as gas. For countries across the world to best meet their obligations under the Paris Agreement, it’s clear that decarbonisation must happen across all sectors. Specifically, that means that they should call for a phase out of incineration practices, to be replaced with genuinely climate-positive waste management ones, and for those countries not yet hooked on waste incineration,
3) The youngest of Dutch incinerators: Reststoffen Energie Centrale

Out of the 13 waste incinerators currently in operation in the Netherlands, the Reststoffen Energie
Centrale (REC) is the most recent one. The so-called waste–to-energy plant is located in Harlingen,
bordering the UNESCO Wadden Sea coastline in the North of the Netherlands. When it was built in
2011, it was proudly announced by the Dutch Ministry of Economic Affairs as ‘a state of the art’
installation, the best in Western Europe. However, long-term testing revealed the plant emits dioxin,
furans and toxic pollutants far beyond the limits set by EU laws.
Initially, in order to deliver energy to the nearby salt industry plant, the REC incinerator was only
supposed to burn Frisian household waste. However, nowadays the waste input comes from
everywhere in the Netherlands. Besides household waste, the REC waste input includes also
industrial waste, digestate1 and sewage sludge. Chemical analyses to check the waste input were
first undertaken at the start in 2011. It is debatable whether this installation with a post combustion
temperature of 8500 Celsius is actually capable of combusting the chemical complexity of current
‘household’ and industrial waste.
4)Environmental biomarkers and toxic eggs
In 2013, a study by ToxicoWatch found high concentration of dioxins and furans2 in eggs of backyard
chickens in the surroundings of the REC incinerator3 4. Eggs of backyard chickens are sensitive
environmental biomarkers for persistent organic pollutants (POPs) like dioxins5. All eggs of backyard
chickens in Harlingen, sampled within a radius of 2 km from the REC incinerator, showed a much
higher concentration of dioxine than allowed by the EU6. Notably, the concentration exceeded 1.7
BEQ/gram fat (Bioanalytical EQuivalent)7, and the 2.5 picogram TEQ/gram fat8 limit set by EU law.
1 Digestate is the material remaining after the anaerobic digestion of a biodegradable feedstock. 2 Polychlorinated dibenzo-p-dioxins and dibenzofurans, PCDD/Fs. 3Arkenbout, A, 2014. Biomonitoring of dioxins/dl-PCBs in the north of the Netherlands; eggs of backyard chickens, cow and goat
milk and soil as indicators of pollution. Organohalogen Compd. 76, 1407–1410 4 Arkenbout, A, Esbensen KH, 2017. Biomonitoring and source tracking of dioxins in the Netherlands, Eighth World Conference On
Sampling and Blending / Perth, Wa, 9–11 May 2017, 117-124 5 Witteveen en Bos, Dioxine emissie oktober 2015 – Verspreidingsberekeningen, 2015, rapport LW217-12/16-002.590 6 See n=6, Figure 1 black spot
7 The values are expressed in Figure 1 in BEQ because analyses are performed with the bioassay of DR CALUX. 8 TEQ stands for Toxic EQuivalent, picogram is a millionth of a millionth of a gram or 10-12 gram
5) Hidden emissions
One of the reason why the REC incinerator exceeds the dioxins permit levels is the use of bypasses
during transient phases, which means that the incinerator emits without filtering (Figure 4). In the
technical literature this is known as a ‘filter bypass mode’, ‘abatement bypass’ or ‘dump stacks’. The
bypass mode is structurally programmed whenever elevated dust emissions occur. Although the
plant management had recently promised to stop using bypasses, data don’t confirm this has
actually happened.
these are just some serious problems, please read the attached studies

I write to strongly object to Veolia’s proposed incinerator being built in Tarago, as outlined in my attachment.
In summary:
-- Burning waste produces biproducts which are incredibly dangerous for long term health and environmental impacts. There is much evidence to support this position, indeed, there is insufficient evidence to conclude any incinerator is safe.
-- The cost benefit return of burning such waste produces a negligible amount of electricity compared to the energy input for burning. Indeed, the equivalent burn by a conventional power station produces far more electricity.
-- Material amounts of carbon are released as part of the process which are not effectively captured through the burn.
-- The goal of burning waste is to effectively remove it. Other methods exist to do so, without the same environmental or health impacts.
-- Veolia has a record of poor management at Woodlawn
In closing, if an incinerator is not permitted in Sydney, why should the same be allowed to be built at Tarago?

Date: 5.12.22
To Whom It May Concern:
This letter is written to formally object to Veolia’s intention to build a waste incinerator at Woodlawn. Application No: SSD-21184278 – “Woodlawn Advanced Energy Recovery Centre”

The reasons behind our objection include:
1. Veolia have a long history of polluting our community and failing to control odor from the waste management facility that is currently in place. Well over 200 incidents reported to EPA in the past year alone. Their most recent offence at the end of November resulted in a local waterway being polluted. At no point was our community alerted to this until news broke via the media. When we have to deal with odor, we are not able to hang our washing out, nor is it pleasant to be outside. The reality is, Veolia struggles to maintain pollution from the waste facility they have had in place for a number of years now. How are they going to manage with 2 facilities going at once? The truth is they won’t be and it will be the community that pays the price.
2. It was decided that it was not safe to build such a facility in Sydney. Our community is yet to hear as to why our lives are more expendable than those who live in Sydney.
3. Such a facility has never been operated in a rural location where the local community relies on tank water. Considering the amount of work that went into cleaning and sanitizing our tanks and water supply following the 2019/2020 bushfires, this is a valid concern that needs to be addressed. Micro-particles entering our water supply is inevitable, yet Veolia behave as this problem does not exist.
4. Placing this facility in a rural location will impact upon crops, stock and food production as a whole. Entire livelihoods will be destroyed by this health hazard of a project going ahead. No one will want to eat products grown and produced within range of a waste incinerator, nor will anyone invest in wool contaminated by micro-particles. Even on a smaller scale, those of us who grow our own produce for our families will be left eating contaminated produce. This is not acceptable.
5. The presence of the waste management facility in its current format has impacted our community enough as it is in regards to housing prices. As it stands, those who choose to sell must do so with regard to avoiding days where odor may be detected. “Do you smell the tip?” is commonly asked by those looking to move into the area. The presence of the incinerator will destroy any chance we had of selling at market price, if we’re able to sell at all.
6. Veolia have been very reluctant to share the extent of the impact of the incinerator, despite ongoing pressure from our community to do so. Tracking models show the plume from the incinerator will reach as far as Canberra. Veolia quickly changes the topic when this is raised. Our community has done our best to educate and warn those in harms way in town but there only so much we can do without Veolia being forthcoming with real information and facts. If the truth of the impact was known by Canberra and the surrounding rural communities, Veolia would be facing a much more intense backlash. So instead they say silent.
7. Veolia have violated residents rights to peace and privacy by sending around company reps in order to “address any concerns about the project.” These reps ignored “No entry” signs and trespassed onto numerous properties in order to achieve “community consultation.” The truth is, this consultation was uninvited and unwanted but continued despite individuals making it clear the rep’s only option was to leave properties immediately and that their presence was unwelcome in our community. When asked why they were trespassing, the response from the reps was “Veolia sent us.” Whilst we understand Veolia is obligated to consult with us, under no circumstances are they allowed to trespass or access our properties without consent.
8. Veolia is refusing to acknowledge any accountability and need for compensation or support in regards to the consequences the community will face if this project goes ahead. Veolia denies any responsibility for testing our water supply, cleaning our tanks or having water trucked in. They refuse to accept the need for greenhouses both on personal and commercial scales in order to protect crops and food supplies from contamination. They refuse to acknowledge the impact the project will have on our housing prices or provide market value compensation to those of us who wish to sell up and move away from the area in order to protect our health. Veolia is in clear denial about the extent of the impact this project will have on the surrounding communities.
9. Veolia have a long history of giving multiple responses to the same question, avoiding questions completely, changing the minutes of meetings and gas lighting those who challenge them. At a recent community meeting, a member of our community was removed from the meeting after they tried to hold Veolia accountable and commit to supporting the community they are destroying. As it stands, the final 3 members or the community consultation group resigned from their positions as a result of Veolia’s ongoing unethical behaviour.

We were told we wouldn’t be impacted by the current waste management facility yet we are regularly dealing with odor. Veolia’s welcome in our community is wearing thin. We cannot go back on agreeing to the original facility but we are fighting with everything we have to object to and prevent Veolia expanding their facilities. Their history proves they cannot be trusted and we will not allow them to continue to decimate our livelihoods, community and the environment that surrounds us.

We formally and passionately object to the Veolia’s incinerator project. We confirm that we have no political donations in need of declaration and accept the department’s disclaimer and declaration.
Sincerely,
Rhi Sugars

There have been recent breeches by Veolia at Woodlawn with admissions of toxic spills over a number of years that the Tarago community was unaware of. I find it difficult to trust the new project being monitored correctly with the past track record. If the project was to go ahead it is condoning past breeches and letting them get away with it. The fines are not enough for the breeches. A clear NO message to any future projects is the only way to keep the company accountable for looking after the environment for us, our children and our children's children.
The air is very clear here and that is one of the reasons I moved from Sydney to the country. The Tarago area in particular is not a suitable area for the centre to be built. We do not have mains water supply and rely on water tanks that directly collect rainwater for drinking as all other residents here. This is a farming area with many commercial farms and small farms producing organic products.
The infrastructure around Tarago with roads in and out are not suitable and are in a constant state of disrepair due to heavy trucks moving out from Canberra through Bungendore to Woodlawn. The roads are not wide enough and are dangerous as the trucks with the rubbish in do not slow down that causes cars to need to move to the left into sides of roads that have large ridges, pot holes in the middle that damages car wheels and hubs and puts lives in danger. The rain has also exasperated the road situation. The roads are not suitable for the increased large construction trucks needed to build the facility.
Burning the rubbish may be seen as getting rid of the rubbish reducing the size of the rubbish to the eye but there is always cause and effect. The rubbish turns into toxic air when burned that has to be purified but is it coming out as fresh air? No to the risks both known and unknown of living near a facility that will contaminate the air.

I strongly object to building a waste-to-energy incinerator at the existing Woodlawn Bioreactor landfill site in the Goulburn Mulwaree NSW council region near Tarago. This incinerator will emit harmful toxic air pollution 24 hours a day, 365 days a year for 25 years into region of Canberra. Incinerating rubbish is not the answer. This incinerator will contribute to climate change and will impact the health of my children, grandchildren and their grandchildren through the accumulation of forever chemicals in the surrounding environment.

Given the fact I am having to write this NO submission is evidence enough the NSW Government is either corrupt or not fit for office. It beggars belief that whilst the rest of the world is banning these toxic incinerators the NSW Government is being conned by Veolia that it is a safe solution. If it is so safe as they want us to believe then why not build it in Sydney at the source of the rubbish rather than transport it by rail all the way to Tarago. Truth is everyone knows these are not safe and building it in or near Sydney would mean a guarantee political suicide at the next election. So some how it’s not safe for Sydney but it’s safe enough for Tarago. Sounds more like those country folk at Tarago and surrounds are being treated as collateral damage by the NSW Government.

I live 6km from the Woodlawn site. I will be able to see this monster when it is built. We have chickens, we have ducks, we have cattle, sheep and goats, we grow vegetable, have fruit trees and our drinking water is collected from our roof. Once this toxic incinerator is operational, we will no longer be able to use any of these. The chickens and eggs will be the first to pickup the toxins especially the dioxins. We will no longer be able to trust what we are eating from the garden and our drinking water will be totally compromised. It will only be a matter of time before we are pulled up for excessive residues with our sheep and cattle. I note that in Federal Parliament last week it was stated that every Australian is entitled to clean air. This definitely won’t allow for that.

Veolia current track record with the existing bioreactor is appalling. They have breached their environmental regulations on hundreds of occasions and have repeatedly gone out of their way to keep this from the local community. Recently it was discovered Veolia had contaminated the Tarago ground water; not once but repeatedly over the past 5 years. This is absolutely appalling and quiet frankly terrifying. The community was never made aware of this and it’s obvious they have done nothing to remediate the initial issue. Surely 5 years is more than sufficient to remediate the issue or better still sufficient grounds to halt the current operation. The bio reactor is small fry compared to the proposed incinerator. Breaches will be 1000x more damaging to the environment and community. Added to this it is clearly evident from their track record they will do everything in their power to not inform the local community when these breaches occur. Contrary to the current Veolia message the only thing they are interested in is making money and lots of it. The last thing they are concerned about is the local community and the local environment and farmlands. Based on their current poor track record how can we even start to think we can trust them with this incinerator given the stakes will be so much higher every time they stuff up; and it won’t be if the breach the regulations but when.

This proposal is also having a massive effect on my families mental health. My youngest daughter has developed significant anxiety over this proposal and if this was to proceed this will only get worse. We won’t be able to sell our farm when it is time to retire. Who on earth would want to buy a contaminated property within eyesight of this toxic facility. I am appalled that Veolia has the gaul to call us local’s who are objecting to this proposal NIMBY’s (Not In My Back Yard). Just shows how out-of-touch they are with the local community as we really stand for “Not In Anyone’s Back Yard”. There is no place anywhere for this.

This whole proposal goes against the directions of the rest of the world. Reduce emissions, recycle, reuse, reduce our rubbish footprint, develop new technologies. If this goes ahead all this will be put on hold for the life of the polluting incinerator as there is a minimum amount of rubbish contracted to run it so there will be zero incentive by the NSW Government to want to reduce Sydney’s volume of rubbish or even consider developing and implement new technologies and initiatives. In today’s society with so much focus now on climate change and our impact on the environment and word we live I find this whole proposal totally insulting and rather criminal.

I say No to this toxic incinerator.

Regards