Environment Protection Act 1970 Section 20B Conference Report

Application: Development of a waste-to-energy facility at 70 Ordish Road, Dandenong South Applicant: Great Southern Waste Technologies Pty Ltd

Produced for

Conference Date: Tuesday 3rd March 2020 Conference Chair: Jennifer Lilburn

Declaration Limitations of Use I am the Chairperson appointed under Section 20B of the This report has been prepared for EPA Victoria’s consideration as Environment Protection Act 1970 to preside over a consultation part of its assessment of the Works Approval Application by Great conference relating to a Works Approval Application by Great Southern Waste Technologies Pty Ltd. The author has included Southern Waste Technologies Pty Ltd for the construction of a new reflections and recommendations that represent an impartial, non- abattoir at 70 Ordish Road, Dandenong South. I hereby submit my expert view, based on the comments made by community members report to the Environment Protection Authority as required under at the Section 20B Conference held in Dandenong on 3 March 2020. the provisions of the Act. Considerable effort has been made to ensure that the report accurately reflects the discussions that took place at the 20B Conference. However, the feedback by its nature is subjective and not always consistent. It cannot necessarily be construed to be an accurate reflection of the weight of broader community or Jennifer Lilburn stakeholder opinion. No formal statistical analysis of data has been Director Kismet Forward undertaken. March 2020 No responsibility or liability can be taken for errors or omissions, or in respect of any use of or reliance upon this report by any third party. Acronyms and abbreviations used in this document

Great Southern Waste Technologies Pty Applicant Ltd CALD Culturally and Linguistically Diverse EPA Environment Protection Authority Victoria

EU European Union Great Southern Waste Technologies Pty GSWT Ltd the Conference The Section 20B Conference Photographs in this report were taken by Kylie Cirak and Jen Lilburn UN United Nations of the subject site and during the Conference VCAT Victorian Civil and Administrative Tribunal WTE Waste to energy

Table of Contents Executive Summary ...... 4 1. Introduction and background ...... 5 1.1 Summary of the application ...... 5 1.2 Timelines and submissions ...... 6 1.3 The Section 20B Conference ...... 6 1.4 Invitations and participation ...... 7 1.5 Conference format ...... 7 1.6 This report...... 8 2. What we heard: Issues and Concerns ...... 9 2.1 Theme A: Environmental Concerns (water, land, waste) ...... 9 2.2 Theme B: Air quality, dust, odour, noise ...... 18 2.3 Theme C: Human health concerns ...... 27 2.4 Theme D: Concerns about the location of the facility and road/traffic impacts ...... 35 2.5 Theme E: Other Concerns ...... 42 2.6 Other Input ...... 49 3. Final comments by participants ...... 52 4. Conclusions ...... 54 4.1 Chair’s reflections and conclusions ...... 54 4.2 Recommendations ...... 55 Appendix: Conference Agenda ...... 59

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Executive Summary Many participants and submitters are concerned about the waste which will be processed. There is anxiety regarding the incorrect Great Southern Waste Technologies Pty Ltd (the Applicant) has sorting of domestic waste, the risks involved in secondary sorting, submitted a works approval application to EPA for approval for a and the consequences of the incineration of toxic materials leading waste to energy facility at 70 Ordish Road, Dandenong South. to toxic emissions. rd A community conference, held on 3 March 2020 in Dandenong, EPA Victoria and the Applicant have critical roles to play in was conducted under Section 20B of the Environment Protection Act acknowledging concerns and working with community members to 1970. The conference provided an opportunity for 95 community transparently and thoroughly explain how any potential impacts will members to raise and discuss issues, opinions and concerns about be negated. the proposal. Key points raised by those attending have been documented in this report. The comments, concerns and opportunities expressed by Conference attendees have led to the development of The location of the proposed waste to energy facility is a primary recommendations for EPA Victoria as detailed in Section 4 of this focus for many participants. The proximity to residential areas, report. Although the City of Greater Dandenong only attended the community facilities and business is a cause of great anxiety 20B conference in an observer capacity, many of the issues raised especially the potential impacts on human health. There is a relate to the planning permit. As such suggestions for the City of common belief that there is a legally enforceable 1.5 km separation Greater Dandenong are also included. zone - clarification of this separation zone is essential to increase community understanding and potentially allay fears. The overarching recommendations are that There is concern that the cumulative effect is unknown and that the • due consideration is given by EPA Victoria to the potential impacts of this proposed facility should not be looked at in recommendations and suggestions contained in Section 4.2 isolation but in the context of the local industry and its current of this report, and impacts. • feedback is provided to submitters and conference participants regarding the outcome of each recommendation There is a distrust of the proposed technology and a perception that and suggestion. both the EPA and the Applicant are inexperienced with this technology and are not equipped to adequately manage and monitor the facility. There is also a belief that other countries are moving away from waste to energy and that it is a retrograde step for Australia to consider it when cleaner, more efficient energy generation methods are available.

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1. Introduction and background 1.1 Summary of the application Great Southern Waste Technologies Pty Ltd (the Applicant) is proposing to develop a waste to energy facility at 70 Ordish Road, Dandenong South. The facility would process 100,000 tonnes of municipal solid waste and commercial and industrial waste per year. The plant is designed to deliver approximately 7.9 MW of electricity to the grid per year. According to the application, this will result in a greenhouse gas emissions net benefit of 142,800 tonnes of carbon dioxide equivalent per year as compared to landfilling. The proposed facility will utilise gasification technology developed by Energos Technology AS. This technology has been chosen based on: • its long-term performance against strict European emission limits • its reliable long-term performance • a suite of operational reference plants in Europe. The proposal is scheduled as A08 (waste to energy) and K01 (Power station.1

1 https://engage.vic.gov.au/epa-works-approvals/GSWT

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1.2 Timelines and submissions 1.3 The Section 20B Conference The Works Approval application was received by EPA on 23 October The Section 20B Conference (‘the Conference’) was held on Tuesday 2019. On 27 November 2019 EPA advertised the Works Approval in 3 March 2020 6-9pm at the Dandenong Civic Centre in Dandenong. metropolitan and local newspapers and accepted public submissions The purpose of the conference was: until 8 January 2020. • For EPA to gain a better understanding of community concerns 79 submissions were received by EPA Victoria including a petition and issues that need to be considered; with 1454 objection signatures, and a petition with 280 local • To inform the public about the Works Approval application, the resident objection signatures. assessment processes and its current status; All submissions to the EPA can be viewed at • To identify potential resolutions for issues relating to the https://engage.vic.gov.au/epa-works-approvals/GSWT application; and • For the community to raise any additional matters relevant to On 11 February 2020 EPA issued a notice under section 22 of the EPA’s assessment. Environment Protection Act 1970, requesting the Applicant to provide additional information.2 The Conference was chaired by independent facilitator Jennifer Lilburn of Kismet Forward.

Under section 20B(4) of the Environment Protection Act 1970, ‘The Authority shall take into consideration the discussions and resolutions of any conference under this section and the recommendation of any person presiding at that conference.’

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1.4 Invitations and participation 1.5 Conference format The conference was advertised on the Engage Victoria website A copy of the agenda is provided as an Appendix. (engage.vic.gov.au) and invitations were sent to all people who had The Conference was opened by Richard Marks (Director Regulatory lodged a submission to EPA. Standards, Assessments and Permissioning) EPA Victoria, who 95 community members attended the conference including local acknowledged Country, welcomed everyone and thanked them for community members as well as representatives from South Eastern their attendance. Facilitator Jen Lilburn then ran through the format Environmental Group, representatives from the offices of Martin for the meeting. Paluka MP and another State Member of Parliament, a media This was followed by three short presentations: representative from Star New Group and staff and councillors from the City of Greater Dandenong. • Richard Hook (Senior Project Manager - Approvals) outlined the EPA Works Approval process; 15 representatives of EPA were present to explain the Works Approval assessment process and the submissions received, and to • Lukas McVey, National Manager Waste, SMEC, on behalf of assist with recording of feedback. Representatives of the proponent Great Southern Waste Technologies, who briefly outlined the were also present to explain the proposal and to hear community development proposal, and feedback firsthand. • Andrew Halliday (Senior Project Manager) gave an overview of the issue themes and submission analysis. A list of questions from conference participants, and feedback from All presentations are available at https://engage.vic.gov.au/epa- a community member who was unable to attend the conference, works-approvals/GSWT . were provided to facilitator. The questions and feedback have been recorded in this report in 2.6 Other Input. EPA Victoria then provided a summary of the issues and concerns that were raised through the 79 submissions regarding the proposal. These were used as a basis for discussion at the Conference and were categorised into five themes: Theme A: Environmental Concerns Theme B: Air quality, dust, odour, noise Theme C: Human Health Theme D: Location and Traffic Theme E: Other

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Themes A, B and C are relevant to the EPA’s scope and the Works opportunity for members of the audience to state/restate questions Approval process, whilst Theme D is relevant to the City of Greater and concerns. Dandenong’s planning process. Theme E is a combination of issues relevant to both processes.

There were 14 tables of participants, each hosted by a 1.6 This report representative from the EPA or Kismet Forward. For each theme participants were asked if they were concerned, satisfied or felt The key output of the Conference is this report documenting the key neutrally about the issues for that theme. They were then asked to issues, opinions and concerns of conference participants, along with join a table which focused on their chosen attitude to the theme. possible solutions to issues raised. The vast majority of participants were very concerned about all The brief for the 20B Conference Chair highlighted that the themes, hence there was limited movement between tables. Conference Report should: The themes were addressed over 5 discussion rounds. For each 15- • Provide an independent perspective of the Conference; minute round, participants worked through the following questions: • Highlight issues raised during the Conference; 1. Are you very concerned/satisfied about the proposal in relation • Identify issues that were resolved; and to this theme? OR somewhat concerned/satisfied? Why? • Make recommendations about aspects that the Chair deems 2. Is there anything that could be added to the summary of issues as requiring scrutiny by EPA as it decides on the application. for this theme? Has anything been missed? 3. Of the issues listed, what are the more significant? Why? EPA Victoria staff will consider this report in the course of their assessments of Great Southern Waste Technologies’ application. 4. Are there any actions or further information could help reduce community concerns about this theme? It is highlighted that the author of this report neither agrees nor disagrees with the comments made at the conference by Participants used issues summaries, derived from submissions to the community members or the Applicant, and the comments included EPA, to inform their discussions. These summaries are included in in this report are made without endorsement or judgement of them this report in grey boxes. or their veracity but as a record of the comments made at the After the discussion rounds, there was a plenary session in which conference. table hosts summarised the key themes and messages that had It is NOT within the scope of this report or the author to recommend come through the discussions. This was followed by a final whether the application should be approved or rejected.

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2. What we heard: Issues and Concerns 2.1 Theme A: Environmental Concerns (water, land, waste)

Priority issues about this theme3 Conference participants were asked to indicate the issues of most concern for this theme. This feedback has been consolidated and the most frequently prioritised issues and concerns were: • Cumulative impacts of the proposed facility with the current impacts of existing facilities • Impact on Dandenong Creek • Other concerns about water quality impacts and risks • Type of waste being processed including how it is handled and stored • Lack of EPA knowledge/experience with this technology

Summary of submission feedback EPA provided a summary of community issues and concerns about this theme, as per the grey box below. These had been raised via community submissions before the Conference and were used as a basis for discussion.

3 There were 95 community participants distributed across fourteen tables. Tables Priority issues have been identified as those where four or more tables identified had varying numbers of participants, from 2-17 (most had 6-8 participants). an issue as very concerning.

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A1. Concerns re water or land contamination and environment 8. Concern that the 160-metre distance to Dandenong Creek may not be enough to prevent pollution from the proposed facility, 1. Water quality impacts and risks vehicle movements, or windblown rubbish 2. Medium risks to air, soil, water and land contamination are

“accepted” in the risk assessment A2. Concerns re waste disposal, litter 3. Release of toxic chemicals to water (Dandenong Creek) and soil causing irreversible harm to all living beings 1. Rubbish falling off trucks/vehicles and being blown by the wind in 4. Risk of ground/aquifer contamination, including the introduction many different directions of dioxins, “one of the most dangerous pollutants known to 2. Disposal of ashes in landfill and environmental impact from heavy mankind” metals caused by this 5. Risk of aquifer contamination via in-vessel incineration has not 3. Waste will be dumped in the open and that this will accumulate been considered in the risk assessment biological and chemical hazards 6. Long-term contamination of local groundwater and rivers flowing into the eastern treatment plant and the potential contamination 4. Support for great initiatives of reducing the waste and changing of recycled water supplies to residents of Keysborough, the way these are disposed of and made use of, but concern that Somerfield and surrounding areas, or flows into the bay the proposal will create pollution and emissions 7. Risk to native wildlife in local and wider areas - including migratory 5. There will be toxic waste left over birds like the sharp-tailed sandpiper, the red-necked stint fly, Latham's Snipe and the black-winged stilt as well as many native species like the superb fairy-wren, magpie-lark, red wattlebird, white-plumed honeyeater the black swan, pacific black duck, the blue-billed duck, and the grey and chestnut teal

Summary of discussion at 20B Conference Why are you concerned about the proposal in relation to this Feedback from Conference participants is also shown below. Some theme? points that were raised during the discussion rounds have been 59 people were recorded as being very concerned about the moved to more appropriate themes; duplicated or similar points proposal in relation to environmental concerns, and 9 were have been consolidated. somewhat concerned. The following summarises the key reason for their concern. (3 people identified as being ‘neutral’ about this

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theme, but there was no feedback attributed to them.) • Pollution to house and water via streams – concerned about flowers and vegetables. Cumulative impacts • Storage of municipal sorted waste can affect surface water and Five tables raised concerns regarding the cumulative impacts of the groundwater. proposed facility with the current impacts of existing facilities. • It could poison watercourses and land for a long time. • They say that air emissions will be quite minimal, but it is still a • Adequacy of surface water and groundwater monitoring. risk. It is the accumulation of all emissions from everywhere that is the risk – have the cumulative effects been tested? EPA’s lack of experience • Need to look at facilities in the vicinity as a whole, not just this Three tables raised the concern that the EPA does not have specific proposal. experience in assessing and monitoring a waste-to-energy facility of this kind.

Impact on Dandenong Creek The potential negative impacts on Dandenong Creek were raised by Other water/ land concerns five tables. • Carcinogenic dioxins will soak into the land – what is the plan for monitoring and containment? • There has been limited/no assessment of the impact on Dandenong Creek during different weather. • Risk of leachate into the soil. • No assessment of release of pollutants to the creek when ashes • Impacts on wildlife, pets (inc horses), insects (pollinators), and are being handled. on farms and market gardens. • Proximity to Dandenong Creek – pollution from trade waste in • Long-term contamination of the land and groundwater will stormwater drains. affect the next generation. • Zero contamination from waste is not a ‘not significant’ concern. Other concerns about water quality impact and risks • How impacts to water, land and waste will be monitored – too Four tables were more generally concerned about the potential many uncertainties, monitoring software can be manipulated. contamination of water. • Emission control is being done by software – can be • Melbourne Water East Treatment Plant is nearby – concern manipulated. about the birds and wildlife there. • Consideration and preservation of local parks. • Water contamination, water courses used by local kids and schools.

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• Why would the applicant/EPA allow anything like this to be built • Waste storage and disposal of fly ash/bottom ash. near a waterway? • Testing of the ash before its disposal.

Type of waste being processed Transportation concerns Participants at five tables raised issues about the type of waste • Windblown litter from trucks during transport. being processed and the impacts of the processing. There is • Safety of contaminated waste while it is being transported. particular concern about people sorting waste incorrectly and the • Risks of transporting waste that can’t be processed at the risk inherent in relying on secondary sorting. facility. • In Australia people put incorrect waste in the bin (eg batteries, paint). It will go to the facility and be emitted to air or water and land via road fly ash. It will be toxic. Other concerns raised during this theme • Other countries are more specific with what waste goes to the Concerns about technology/other countries moving away from facility. technology • We don’t know or have control over what is being incinerated. • New technology in Australia is not proven here – concerns • The applicant proposed that glass would be incinerated which is around business familiarity with the technology. silicone and this hasn’t been incinerated for decades. • 3rd or 4th generation technology means nothing. • Unclear where things that can’t be processed will be stored. • Other countries are moving away from this technology – why • Class A contaminated waste can only go to one site. would we embrace it? • The amount of contaminated waste going to the right landfill. • Articles on incinerators in other countries are not good. • Storage of the municipal sorted waste on the site before burning. Location • Why always in populated areas? There are the same issues in Ash West Melbourne. Always in working-class areas. Concerns about storage and transport of ash were raised at five • There are vast areas that aren’t near people/Not against the tables. proposal but move it 12-15 kilometres from people. • The proximity of residents to the current industrial zone • Use of ash in construction, road building because of harmful residual chemicals. particularly Keysborough South which is close to Dandenong South. • Control of ash (ie release to atmosphere).

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• The separation distance is too small. Is there anything that could be added to the summary of issues for this theme? Miscellaneous Need to assess the current state of the area • Articles on incinerators in other countries are not good. • Existing data of water quality for Dandenong. • EPA should ask for financial assurance for the waste and site • Is the land contaminated already? Need to have a baseline decommissioning. before doing something. • EPA should assess over the entire lifecycle of the project including remediation and demolition/dismantling of the site. Comparison with other facilities • Lack of benefit compared to the risk to the community. • What is different from this proposal to a similar NSW proposal? • Big tank for storage – if it is guaranteed safe forever than that is Why was it rejected by the NSW government? fine, but leachate could escape. • First plant being built in Victoria – where is the experience to run • Time=$. There will be shortcuts. it? Need an example to prove that they can run it properly and • Renewables should be favoured over burning waste energy – the not have any issues. government is pushing alternative energy sources. Add historical data from a similar project that has run over 70 • Every second day in the media there is an article about EPA not years. monitoring. • I was not informed by anybody about the proposal. Other issues • Lots of waste stockpiled – fire risk • Any contaminants might stick to the ground and impact on people, especially children at kindergartens. • The volume of water that becomes waste is an issue. • It is taking something that isn’t hazardous and making it hazardous. • Will encourage people to be more wasteful.

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Of the issues listed, which are most significant? Why?

Issue (as per grey box on pg 10) Number Comments of tables A1.4 (ground / aquifer contamination) 6 Dioxins will spread through the water. Control systems only as good as the monitoring – how much attention will this part of the plant get? A1.2 (risks to air, soil, water and land 4 What is classed as acceptable? contamination are “accepted” in the risk An acceptable level is still pollution that wasn’t there before. assessment) 20,000 tonnes of ash – where does it go? ‘Accepted’ not appropriate, we want no risk. ALL issues are significant 3 A1.6 (Long-term contamination of local 3 Health and intergenerational impacts. groundwater and rivers) A1.3 (Release of toxic chemicals to 3 Where is the waste stored? Believe there will be a build-up of waste that may leak Dandenong Creek) into the creek. A2.1 (Rubbish falling off trucks) 2 Trucks leak – concerns about transport. A1.1 (Water quality impacts and risks) 2 More time for kids to be exposed. A2.5 (There will be toxic waste leftover) 1 What happens to leftover waste? How long would clean uptake if the site closed? A1.7 (Risk to native wildlife) 2 Need to include pollinators. A1.8 1 We have just got the bay back into good shape. We are risking polluting it again. It is too close to the creek.

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Other issues noted as significant • Council fining/penalties for people putting in wrong waste. • Location for waste storage and treatment. • Alternative location. Information relating to similar facilities • Statistics from independent bodies on how well this technology has worked in other countries. If the proposal was to proceed, what actions or further information could help reduce community concerns about this • Statistics on pollution and health impacts from other plants. theme? • How long has the technology been around – statistics to show this plant’s technology? Monitoring and reporting

• Long-term monitoring of water in Dandenong Creek. More information about operations • Long-term assessment of the effect on birds. • Tell us what is going to happen to the waste. • Ongoing monitoring /Transparency of monitoring and reporting • Explanation of what the applicant does to ensure pollution does /Independent monitoring. not leave the site. • Monitoring of the environment • Access to information about ongoing activities. • Will there be a third party comparing any monitoring of the • Understanding where the waste is going and the impact on plant? those communities – can’t be a separate process. • Information and detailed explanation regarding risk assessment and ongoing monitoring and management. Other actions or information • Define ‘acceptable’ and who decided ‘acceptable’ and what it is • We require best practice outside of biased parties who have based on. already approved such facilities. • Need a clearer presentation of risk mitigation. • Move it away from people. • More information needed around ash disposal and management. Outstanding Questions • Open access to reporting data. Waste Management Improved waste sorting measures • What is done with the separated contaminated waste? • Council improving waste collection and sorting. • The rubbish that will be stored in the facility – will it generate toxic liquid? What is the treatment? Where is it going? Will it get buried?

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• Have seen asbestos and non-sorted items in waste facilities – • Will the company put the continuous emission monitoring what are the assurances that toxic items won’t get burnt? results live on the company website? • How will the manual waste sorting be done safely? • Are they looking at accumulative impact within the 10 km x 10 • What are the safeguards for all the harmful contaminants that km impact area or just the impacts of the new facility? are separated so they are not burned? • What has been done to test what the current environment is for the local community? Water • How will it be monitored? • What is the process of treating water? • How will the facility affect the tertiary treating of water at the Concerns about the technology eastern treatment plant ie will ash or other contaminants or • Information – is this facility used widely across other countries? toxic chemicals affect the water treatment plant? Is it safe? Is it proven technology? How long has it been used for • Where will cleaning waters go? and operated safely? Has it been widely used? • How can you guarantee the level of emissions when this Monitoring technology is in Australia for the first time? • What is the external monitoring process of the internal sorting • Are there similar factories around the world – how do they work, process? do they have problems, how have they been dealt with? • EPA reporting and inspection – no response from pollution reports – how can the community be assured? Long-term impacts • Plants are known to have fires and leaks? What are the • How long do impacts last? We do not know the monitoring processes and what are the plans for intergenerational effect, look at Agent Orange. leaks/hazards/fires etc? Who is responsible? Who is doing the If there are long-term health impacts, how and who deals with monitoring? these impacts on the community as well as any legacy for water • What are the standards being used to measure the facility? and land?

• Stockholm convention standards being used by EPA are inadequate – are these the only standards the EPA uses? Or Ash what are the other standards? • Will the ash be contained to the facility? • The EPA is introducing new more stringent laws in July – why do • Plan or process for management of fly ash? this assessment now?

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What happens with the ash after it is sorted? Will it be Other Questions appropriately dealt with? • What are the emergency management plans? • What kind of data is used to compare the current environment Operations and Management to the impacted environment? • What is the back-up plan for if an emergency/accident/problem • Emissions in rainy conditions – what effects on the local happens? environment? • Bushfires have already impacted air quality – what if there is an • Who is responsible for doing the risk assessment and approval? industrial fire? • Why do we need this facility? • How self-sufficient is the facility in terms of water coming and • What is the life of the plant? going from the site – will it balance and will it affect • groundwater? What is acceptable to the community regarding further impact? • Why is it acceptable in this area but not others? We are already • What are the operating controls/bad weather plans? in an industrial area and already being impacted. • What happens to discharge in a liquid state? Where does that • go? We already have odour issues – will this add to them? • Is there enough provision and capacity at Lyndhurst? • Will there be any containment of rainwater?

• How will the community be informed in an emergency?

Transportation • 100 trucks every day. Freeway is near a high-density residential area, what if things fall off the trucks? • Truck waste transport safety – how is safety maintained? How is fire prevented? How is the risk and impact of truck waste, fire pollution to the environment understood and controlled during transport or liquid waste? How can we be sure containment measure will work?

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2.2 Theme B: Air quality, dust, odour, noise

Priority issues about this theme4 Conference participants were asked to indicate the issues of most concern for this theme. This feedback has been consolidated and the most frequently prioritised issues and concerns were: • How the facility would be monitored and by whom, and how the community will be able to access this data • The proposed location and its proximity to residences, businesses and community facilities • The proposed technology and the belief that other countries are moving away from technology • Odour including the existing odour in the area and the failure to resolve concerns about it

Summary of submission feedback EPA provided a summary of community issues and concerns about this theme, as per the grey box below. These had been raised via community submissions before the Conference and were used as a basis for discussion.

4 There were 95 community participants distributed across fourteen tables. Tables Priority issues have been identified as those where four or more tables identified had varying numbers of participants, from 2-17 (most had 6-8 participants). an issue as very concerning.

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B. Air quality, dust, odour, noise 13. Existing odour impacts that residents are complaining about, 1. Air quality has deteriorated over the last 10 years including chemical smells 2. Increased air quality impacts by adding to existing emissions 14. Odour will be worse than existing levels because of the proposed from nearby landfill and industrial facilities facility 3. Safeguards in place to capture and reduce hazardous gas 15. Odour from the stench of waste emissions 16. Children vomiting from existing odour impacts 4. Air quality impacts on families and their neighbours. 17. Responses to odour complaints from Council 5. Toxic air quality causing irreversible harm to all living beings. 18. Existing odour impacts force children to stay inside 6. Effects on the environment from possible air pollution 19. The second and third most common winds from SSE and SE will 7. The air quality will become so bad it will not be suitable for frequently blow odour and emissions to the residential area and residents to live there anymore schools 8. City of Dandenong Council and the EPA are not resourced 20. Existing odour, which is ‘absolutely disgusting’ enough to detect, prove or clean up pollution. 21. Existing odour prevents the opening of windows to have fresh 9. Risk to human health and local farming and chicken and egg air, to go running, to comfortably breathe. production from potential air pollution, including dioxins 22. Increased noise from increases in truck traffic in the morning 10. Whether the proposal is environment-friendly, given it burns and afternoon of each day. materials including plastics, and produces chemical emissions 23. Increased noise impacts on people in their homes in nearby 11. Risk Assessment has a risk management strategy to ‘Accept’ the areas. ‘Medium’ risks from air quality. Concern that the residual risks 24. Noise will devalue the property owned by residents and that no are not acceptable. one will want to come and live here. 12. The effectiveness of pollution control technologies in removing 25. Neighbours are worried about future air quality and noise levels. pollutants, including those which are persistent and 26. Noise levels are not acceptable for the local residents. bioaccumulative; which resist breakdown in the environment and are concentrated in the food chain.

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Summary of discussion at 20B Conference • No effective monitoring of current situation about odour. Feedback from Conference participants is also shown below. Some points that were raised during the discussion rounds have been Location moved to more appropriate themes; duplicated or similar points Five tables raised concerns regarding the proximity of the proposed have been consolidated. facility to residences, businesses, schools and other community facilities. Why are you concerned about the proposal in relation to this theme? • Proximity to people. 76 people were recorded as being very concerned about the • Proximity to schools - Haileybury, KCC, Lighthouse College and proposal in relation to environmental concerns, and 6 were many schools will be affected by odour and noise somewhat concerned. The following summarises the key reason for • Will this proposal impede construction of the new school and their concern. primary school? • Separation distance ‘EPA publication 1518’. Distance is less than recommended. Monitoring and reporting • Proximity to other businesses, particularly food manufacturing Participants at ten tables raised issues about how and by whom the eg egg farm. facility would be monitored and how the community could access the results. • People moving away because of impacts like odours and air emissions. • EPA can’t monitor some of the emissions. • Existing regulation – buffer zone 1.5 kilometres (Victorian • If emissions exceed standards there will be no consequences to Planning Provisions) to childcare centre and Mt Hira College. the applicant. • There is land in other places. This is too close to children, • Monitoring needs to occur close to the site. schools, residents. The government is putting cost above people. • Air quality monitoring site is not in an ideal to pick up maximum Human health is more important. emissions / Concern that EPA air monitoring station located in • Too close to neighbouring properties – will they be affected by Diamond and Alphington are not representative of local dust fall out and how will they manage the issues. conditions. • Good idea to turn waste into energy but not near people. • Should meet the most stringent EU guidelines and levels. • Too reliant on modelling and justification basis for the modelling absent at this time.

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Concerns about technology/other countries moving away from • Smell -won’t be able to go out of the house at night and walk in technology a pleasant environment Participants from four tables raised concerns about the use of technology that is either too old or too new and untested. Dioxins Participants were also concerned about Australia adopting • Dioxins: very harmful, accumulate in people, cause technology which has been rejected by other countries. cancer/health harm • Other countries (e.g. USA) are phasing out of waste to energy • How will the public be provided with enough information about incinerators/this technology is actually on the decline monitoring and impacts, including dioxins – real-time • If other areas have said no, why is this area of to say yes? monitoring. Can’t monitor dioxins. New technology needs historical data from Europe – can we trust the data for the Australian situation Air Quality

• Emissions: Mercury, S02, C02, Dioxins /will emit 28 times more Odour dioxins than coal-fired power stations Four tables were concerned about potential odour. There was a • Odourless impacts that we don’t know about, that cause long- common sentiment that there is an existing odour problem that has term health impacts. not been addressed or resolved by the EPA and this has led to • Need fresh air to breathe – can’t get rid of toxins. distrust that any new odours will be monitored and mitigated. • Furans. • The odour will drive people away from community – only poor • CO2 emissions will be a lot greater than expected and can’t people will end up living there. reach the claimed standard. • Accumulative effect – new odours adding to current odour • Cancer-causing toxins. problems/ Existing strong odour for last 1-2 years, many EPA • Air quality has deteriorated over the last 5 years. South reports but not much progress, don’t trust monitoring system/ Keysborough -trucks coming in contribute to air quality and Already experience odour from Clayton South, this is closer, will odour. it make things worse?

• EPA can’t even locate some of current odour Ash • In China where a more advanced waste to energy facility exists, • Ash impacting gardens and laundry and garden including fruits nearby residents can smell the odour within a kilometre of the and vegetables. facility and it has caused illness. • Dust from fly ash in transportation.

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Impacts of transport • Noise from burning rubbish. • Noise from the trucks transporting waste/ Concerned about • Accumulated noise noise from trucks- how many trucks will be operating 24/7? • Trucks driving to plant generating odour, noise and congestion. Fire More danger to health. • Fire risk. • Big trucks can move a lot of waste • Fire brigade resources to control risk. • Trucks stir up dust. • Air pollution from increased truck movements. Other issues • Have been through this in Taiwan. Other Issues • EPA does not have world’s best practice in terms of air quality • General concern about lack of information about how these levels and legislation. types of facilities operate. • United Nations has stated there should be no more creation of • Stockpiled waste – air and odour impacts. some pollutants yet Australia is approving some of them. • The long-term effect on all living things. • Impact on children at school – seven years of continuous • Not a natural thing to do. exposure. • Dust – asbestos was airborne. Workers at the new facility will • No continuous measurement. have it on clothing when they leave work. • I don’t accept that the further you go from the facility in the • Concern that there is no reference plant operation. 10kilometre radius the less the impact. • Concern that the fundamental business model is not economic. • As we are converting 30% renewables, coal will go down, this • Concern that the process is incineration. will become a dirtier way of converting to energy than renewables.

• Compensation for health impacts from air pollution. Is there anything that could be added to the summary of issues • Fixing up existing odours before approving the new operation. for this theme? • Contingency planning. Noise • Noise will be continuous – all day and night there will be traffic noise. And if they don’t do it continuously there will be stockpiling which will bring other issues.

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Of the issues listed, which are most significant? Why? Issue (as per grey box on Number Comments pg 19) of tables B1,2,13,15,16, 18,20,21 14 Because it will directly affect the quality of life. (Air quality has Children need to go outside – can’t let them deteriorated, chemical Concern that based on prior area performance that it will be an issue for this period. smells, disgusting, can’t Cumulative effects critical – already grossly inadequate limits. Mental health and wellbeing affected, economy breathe, increased impacts affected due to impacts on the medical system. by adding to existing, Existing odour – this will make it even worse children vomiting from It’s children’s health – they are more susceptible than adults existing, can’t go outside) ALL issues are significant 4 All are of equal concern – they will experience impacts every day as they are residents. They moved to Melbourne as it is the best, most liveable city in the world, they did not move here to be polluted by this proposal. B5 (Toxic air quality 4 Toxic air quality. causing irreversible harm) Animal life and families. Cumulative effects critical – already grossly inadequate limits. Concern that odour is related to toxic chemicals. Concern that current performance is an indication of future performance. Health concerns more information available. B19 (SSE and SE winds will 3 Dioxins – pets/children also impacted. frequently blow odour and Concern because individuals live in that area emissions to the Ash will fly away with the wind into populated areas. residential area and schools) B3 (Safeguards in place) 2 Will the filter and technology be fail-safe to ensure no breakdowns or problems Make it safe for the kids B8 (City of Dandenong 2 Resourcing - EPA still can’t determine where the odour is in this area after more than a year. So is EPA resourced Council and the EPA are enough to monitor this? Is the technology good enough to monitor this? not resourced enough) Don’t want to end up with legacy issues.

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Issue (as per grey box on Number Comments pg 19) of tables B12 (effectiveness of 2 Long-term health impacts. pollution control technologies) B4,7 (Air quality will 2 Air quality impact on local families and children. become so bad it will not Schools and childcare all within 1.5 km. be suitable for residents, families) B10 (Burning plastics etc) 1 Concern around burning plastic releasing CO2 and other emissions be counter to what should be done to reduce air quality impacts. B11 (risk management 1 Don’t believe ‘medium’ risks are acceptable. strategy to ‘Accept’ the ‘Medium’ risks) B22 (noise from increases 1 Concern about morning and afternoon noise. in truck traffic)

Other significant issues If the proposal was to proceed, what actions or further • Fire risk and resources. information could help reduce community concerns about this • Property value. theme? Monitoring, reporting and enforcement • Continuous measurement linked into community facilities – not by the business or by EPA. Need third-party, real-time, transparent monitoring e.g. on an app • Constant air monitoring data published online – not by the facility but published by EPA and Council or on an app. Not just

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normal air quality parameters such as dust, we want data on a • EPA to clarify whether existing manufacturing eg food processing specific type of emission from the facility. will be contaminated. • Make it a condition of the licence that after they exceed a limit • Delay consideration until REA Laverton plan is built. of 10 hours per annum they should be made to close down for • Testing before the operation. the remainder of the year. • Insufficient scope of parameters of other contaminants (heavy • Monitoring of changeover time of emissions impact as they modelling, lead, arsenic). move from organics to combustible. • Independent monitoring/ Independent assessments to answer issue numbers B8, 11 and 12/ Evidence to prove independent Outstanding Questions assessments are independent. Monitoring • Scope of modelling is inadequate – needs to set out model • How will it be monitored? inputs. • How can the air emission data can be trusted? Can it be faked • We want to see all of the results, not just summaries. A more like car emission testing? Eg Volvo comprehensive report • How different are our air quality regulations to Europe? • Don’t know what toxicants are being released – how can you Other actions or information guarantee that it is safe for the community to live nearby? • Solve existing odour issue – then trust EPA can do work properly. • Does the plant stop automatically if emissions standards are • Move to a safe distance – at least 10 kilometres from residential reached? areas. • What is the air pollution calculation based on? Is that based on • Thorough emergency and contingency plans in case there are 50% organics burn? Because that is likely to go down over time failures in controls/ Communication with the community about because the council is taking care of more organic waste. Means fail-safes in place that will protect health if something bad more combustible waste as a percentage, emissions change over happens at the plant. time – how will we know when and how that has changed? • Should include all of the EU standards. • What treatment will be done to prevent or defect or destroy • Should include carbon filter/polish filter in air quality process dioxins? between the fan and the stack. • Air emissions from burning plastics. How will they determine • More information in general about how these facilities operate. different incineration levels for different wastes? • EPA to clarify buffer distance.

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• Will this push Dandenong South over the limit with emissions down if the air quality was bad from other sources/for other considering so much industry is already there? Eg the Denmark reasons? case with exceedance of the Kyoto protocol. • Will there be a filter post-process to ensure no pollution? Is it Other questions proven, how will it be monitored and will it ensure pollution 1. Have they assessed current community health? does not come out? 2. Should we be supporting a relatively unclean energy source? • Concerns about ash floating In What levels of noise and air 3. Not sure of noise impact when operating. Will it affect sleep? pollution can be expected? How bad will it be? 4. Why is this location chosen? Because of the project first? Or because the land was bought first? Emergency Plans 5. What benefit does the applicant get from this proposed • What is the contingency plan for trucks with waste when the facility? Eg financial or environmental? plant is shut down for standby and maintenance periods? 6. What other areas are identified as waste to energy hubs? • Back-up emergency plans for accidents/impacts/problems – Where would they go? what will they do to improve air quality? 7. Where is the rubbish coming from? • Emergency response plans: transparent, data triggers – when 8. What other alternative technologies are there? does it become an emergency? 9. How is community valued in all of this? 10. Fly ash – how will it affect closest residents – is there Operations and management evidence that fly ash is bad for asthmatics? • What are the hours of operation?

• What is the life of the plant? Could this become an unclean plant? • Does the plant have to run at 100% to reduce emissions? What happens when not operating at optimum? Will that increase emissions? • How will dust be mitigated? • Bushfires – Victoria and Melbourne had poor air quality. A facility like this can only exacerbate the air quality situation in the area, especially in bushfire season. Would the plant close

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2.3 Theme C: Human health concerns

Priority issues about this theme5 Conference participants were asked to indicate the issues of most concern for this theme. This feedback has been consolidated and the most frequently prioritised issues and concerns were: • Location of the proposed facility and its proximity to residential areas. • The impact on the health of vulnerable groups such as children and the elderly. • Long-term health impacts. • Comparison sites, both the negative health impacts on nearby communities reported about facilities in China and the different environments at sites making comparisons invalid.

Summary of submission feedback EPA provided a summary of community issues and concerns about this theme, as per the grey box below. These had been raised via community submissions before the Conference and were used as a basis for discussion.

5 There were 95 community participants distributed across fourteen tables. Tables Priority issues have been identified as those where four or more tables identified had varying numbers of participants, from 2-17 (most had 6-8 participants). an issue as very concerning.

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C. Human Health Concerns 9. There could be a plant malfunction, toxic gas could escape and 1. Close to residential areas and schools. Potential human health potentially kill people nearby, without enough warning for effects from emissions of combustion gases, dust, odour. people to evacuate. Suggestion that the technology should be built and trialled long- 10. Control measures are unlikely to mitigate all the risks and that term in country areas without residents and schools, to ensure health effects are significant it's safe for the public and environment. 11. It would affect the environment we are raising our vulnerable 2. The ability to compare health impacts between Melbourne and children, by-products of the energy plant may affect our Norway due to differences in allergy triggers from air emissions children's health. 3. Impacts on young people and children 12. Developing diseases, asthma or cancers from nearby residents 4. The health of the high number of young families and children at 13. Whether the health of children was considered in the proposal. home and school 14. Being able to live healthily if the air quality worsens because of 5. Health impacts of dioxins and furans emissions to air and land. the facility 6. The pollution will badly damage people’s health. 15. The health impact on human development and young people, as 7. My kids’ health is in danger. well as older people 8. Kids, adults and elderly people will get sick from toxic gas. 16. People will be unable to avoid air quality impacts 17. A new school is opening and increasing numbers of young people moving to the area that will be impacted

Summary of Discussion at 20B Conference around the proximity to residents and community facilities such as schools and aged care facilities. There was also concern about the Why are you concerned about the proposal in relation to this potential need for many residents to leave the area if the proposal theme? went ahead. 72 people stated that they were very concerned about the proposal • in relation to this theme and 1 person was somewhat concerned. Nearest residential property is 600m away, school is 1.4 km – The following summarises the key reason for their concern. too close to residents who are concerned about impacts to health. Location • Many schools and kindergartens close by / New primary school Participants at ten tables raised concerns about the location of the in Keysborough, existing primary school and a childcare facility proposed facility and its impact on human health. Concerns centred nearby

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• ARCARE (aged care facility) nearby – concerned about the ageing Unknown long-term health impacts population especially for those cultures who take care of the Five tables were particularly concerned about potential long-term elderly. health impacts and the inability to know what they are and how they • Residents will have no choice but to move/ many residents will could affect people. leave the area. • Dioxins accumulate in bodies no matter how it is controlled. • The facility should be more remote/ At a minimum it should be • Not sure about future illnesses this might create – unknown located 20km from any residence effects on health. Air emissions to local businesses and potentially contaminating • The facility will run for more than 25 years 24/7, so what about food production long-term health impacts that are unknown like tv towers causing cancer from radiation. Impact on health of vulnerable groups – children and the elderly • We don’t know what the long-term impacts of poor air quality Seven tables were concerned about the health impact on more are. Even low levels of toxicity can cause cognitive impacts in a vulnerable community members such as children and elderly short-term situation. We need to think about short-term and people. These community demographics were considered to be long-term impacts. especially sensitive to pollutants and associated health impacts. • What we say is fine now might not be fine in ten years eg • Lyndhurst baby born with a deformity – could happen here. asbestos. • Children’s health – this is high on the agenda now / Health • Psychology – mental health anxiety. concerns for younger generations – will cause serious illness. • Longevity study. • Dust impacts to lung health in particular for children who will have long-term exposure to this and therefore long-term Concerns about comparison sites impacts on health. Participants at four tables were concerned about the comparisons • Levels are tested against adults, not against kids. with similar facilities especially as data from overseas facilities has • Young people are susceptible to dust and benzenes. indicated negative health impacts on residents near waste to energy What are the standards are around health impacts for children? plants. Concerns were also raised about the comparisons as being potentially invalid due to differences in climate and other factors. • Norway does not have bushfires – we are not comparing apples with apples. PM2 being released in the air causing sickness and asthma in the nearby community – has been seen in bushfires.

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• The Melbourne weather is different from Norway. It is hot here • Operating temperature – if not operated properly dioxins would – can create more emissions. affect humans. • The comparison with existing facilities only looked at the good case studies – need to also look at the bad case studies, for Cumulative impact example, China where there is evidence of associated illness. • Need to consider not just the plant but all the trucks and • Concern about health impacts from a facility that was built in associated work. It is a compounding impact on air quality and China – rates of cancer to people aged over 70. 40% of this therefore human health. demographic was diagnosed with cancer • Concern that individual assessment doesn’t consider the cumulative effect of all local industry. Concern about impacts on lung health • Concern about air quality impacting on breathing issues like Any impact on human health is unacceptable asthma • Need data to prove zero impact eg C1 sensitivity uses. • Respiratory issues – with already toxic air, especially in summer, • A small change or impact on health is still an impact and we this is adding to air quality issues. shouldn’t have to accept it. • No evidence to suggest there are no detrimental health risks. Concern about worker health • Some of the by-products can be benzenes, dioxins, furans of • Staff working there need six and twelve-monthly health testing which there is no safe limit. to see the cumulative impact. • Level of dioxin emissions should be zero. • Workers in the surrounding industrial area will be at high risk of health impacts. Concerns with EPA assessments and regulations • EPA dioxin emission levels are not appropriate because of the Outdated technology ongoing effect of certain emissions. • Technology is outdated; there is new technology available that is • EPA’s assessments don’t adequately cover human health. vastly superior. • Health assessment is based on EU rules but it will not operate

under EU rules. Dioxins • We require a health check if the plant is run within EPA licences • Dioxins and furans may be released and make people sick. for ace waste – not like full EU standards.

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Other issues • International companies compensate people who live near these • Waste acceptance is crucial to controlling emissions and plants. There is an issue if they compensate. potential health impacts – there may be more severe health risks than anticipated if the waste differs eg contamination in waste. Mental health impacts • Concern about the accuracy of the assumption made in • Mental health considerations are not considered. modelling. • Psychological impacts of being near the plant. • Cancer clusters are a concern. • The proposal is NOT to use full EU design and construction and Cumulative effects operation rules. • Human health concern isn’t confined to those living nearby. For • Concern as to lack of published research into health effects on example, our bushfire smoke affects South America. The people who live close by. decision is not just for this council area – it is state-wide. • State Government is giving it a 20-year life span. The money will • Concern that the proposed emissions increase the existing override human health. emissions – concern the combined emissions could be over the • We need a baseline study of our current community and its threshold. health. Other issues • The potential impact on medical systems. • All integrated – everything affects health. • Environmental hormones mimic signalling, chemicals in the body. • Traffic increase will increase the risk of an accident. • Asthma – pre-existing issues. Need clean air. • Animal health- what about these? (Pets, chickens, wildlife) Is there anything that could be added to the summary of issues • No specific organisation to deal with SOLVING reported for this theme? problems – air quality and health. Information relating to similar facilities • Food chain concerns. • Data collected from other countries is not transparent – can we • Burning is only speeding up the process. trust it? We should use Australian data. • It is right by the cycling trail – inhalation is increased because • Specific concerns due to impacts already seen in China – both air they are exercising. quality and health. • Disposal of toxic waste via filters and scrubbers – existing toxic waste facility already provokes concern.

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• Due to odour and air impacts, people will stay inside – issues to • Animal droppings from birds that have ingested fly ash are health from not being active. potentially harmful to humans who come in contact with it. • We’re basing technology on the minimal information we have • Built dream house – very difficult to move. now – there is no evidence to say this will be fine in the future. • Monitoring equipment to force compliance. • Concerns about fly ash impacting local wildlife and flora.

Of the issues listed, which are most significant? Why? Issue (as per grey box on Number of Comments pg 28) tables C1 (Close to residents 4 Should be put in non-populated areas – there is so much space in Australia. and schools) Too close to residences and new schools and community shops In general respiratory health concerns – lack of understanding of impacts, not confident in the assumptions made. C5 (Dioxins and furans) 4 This is the air we breathe in every day – it will impact the quality of life. We know dioxins and furans are DNA altering. This is leading to mutations in the body eg cancer which equals death. What study will they do to prove otherwise? Dioxins are poisonous to human health. ALL issues are significant 3 Everything is significant – everything goes back to health! Everything is important – human health and good quality of life. C6 (health impacts, esp. 3 We know dioxins and furans are DNA altering. This is leading to mutations in the body eg cancer children, elderly) which equals death. What study will they do to prove otherwise? Affected immune systems are susceptible. C9 (Toxic gas if plant 2 How can we be sure that the plant will stop if there is a malfunction? malfunctions) C12 (Would result in 2 Long-term effects that may not be easily identified in the immediate to short term disease, asthma, cancer) The greatest concern is about the potential for cancer or other significant health impacts due to what has been experienced in areas in China.

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If the proposal was to proceed, what actions or further Other actions or information information could help reduce community concerns about this • Database of cancer/current health. theme? • Mitigate waste so it doesn’t have to be built. Change Location • The Government guarantees in writing that human health won’t • Choose another location – we are prepared to pay more council be affected. If you allow this to proceed this is a guarantee. rates for waste than have to move to another suburb or away • Residents will leave the area if the facility is implemented. They from the community, far away from people. don’t know how dangerous the impacts will be to their health so • Locate the facility further away from houses and schools. they would rather leave the area to be on the safer side. • Upgraded filters to capture more toxins not just the proposed Monitoring filters. Improved systems and technology beyond what is • Aggregated data in a local government area at frequent time proposed. points eg 12 month period and compare year on year. Include primary care and hospital data. Outstanding Questions • Independent study to show no significant impacts. Location • Monitoring results. • Why build a news suburb and schools and then put this plant • Time-based evidence ie cumulative emissions over time. near them? • Proximity to residential areas – schools, aged care facilities. Improved information What evidence is there to show a safe buffer? • Clearer information around health impacts and what the safe • Why should this facility be planned near humans when there levels are. could be alternatives? • A better translation of the science and technical terms into everyday language easy for the community to understand. Transparency and Consultation • Will all information be transparently provided to the public if Information relating to similar facilities there are any incidents or problems around human health? • Other example sites and health impacts experienced there. • Were all affected parties adequately notified of this proposal • Case studies from other countries where similar facilities have and consultations available to the public so that they can have been running for a long time even if run with older technology. an opportunity to voice their concerns? Including aged care

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facilities, schools and preschools. • If there are health impacts discovered, what will happen to the licence? What will they do if anyone gets sick because of it? Information relating to similar facilities • Any research or data to support the long-term health effects of • What sort of communities surround other waste to energy this proposal? facilities? Are these communities able to raise concerns? • Does the government have a contingency if there are • Do the existing plants face any problems like impacts to human unexpected human health impacts? health or the environment? • How can they promise community no harm to human health? • Have any workplace accidents happened at existing plants? • Will there be baseline measures done at a population level of • What have other facilities based their data on? How far away conditions like asthma, chronic lung conditions so we can see from residences are the other eight plants built around the changes over time? Who will monitor and report? How will world? residents know?

Monitoring, Reporting and Compliance Other Questions • How will this be tracked? • How can cause and effect be established? • What kind of data is used to judge the effects on human health? • Public perception will drive people away – how can we prevent this? Emissions • More information needed about this facility – is it safe? • The proximity of the facility to residential areas. Will the gases • Has there been consultation done with local businesses who will be toxic? Will it affect our immune systems? be immediately impacted? • By-products of burning – more toxic than nuclear waste – where • What are hours of operation? Have school hours been is it going? considered? • Carcinogenic material burning – will it be safe to breathe? • Where is the accountability? In 20 years are sick people able to • Will there be peak emission periods? Is it a continuous emissions come back at the EPA and the applicant? period? • How much energy used to burn compared to the electricity generated? Human Health Impacts • How are the EPA threshold values for air pollution determined • Mental health – am I doing the right thing by my child? for different types of people within the community? Old, young, thin, obese, chronic health issues etc

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2.4 Theme D: Concerns about the location of the facility and road/traffic impacts

Priority issues about this theme6 Conference participants were asked to indicate the issues of most concern for this theme. This feedback has been consolidated and the most frequently prioritised issues and concerns were: • Proximity to residences, schools, aged care facilities. • A common belief that there is a legal 1.5 km buffer zone which this proposal would be breaching. • Increased traffic unsuitable for a residential area.

Summary of submission feedback EPA provided a summary of community issues and concerns about this theme, as per the grey box below. These had been raised via community submissions before the Conference and were used as a basis for discussion.

6 There were 95 community participants distributed across fourteen tables. Tables Priority issues have been identified as those where four or more tables identified had varying numbers of participants, from 2-17 (most had 6-8 participants). an issue as very concerning.

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D1. Concerns regarding location or separation distance 11. Proximity to the existing South East Green Wedge (and an area 1. It is so close to a densely populated residential area. specifically designated for agricultural activity) 2. Nearby areas have been marked for high-density development 12. The potential impact on residential community health will be with more residential buildings (houses, townhouses and outweighed by any energy generated in the future. apartments) being built along with childcare centres and 13. The location is too close to homes and people, but support for schools the need for the technology or facility in another location 3. It is close to a newly built community, mainly young families. 14. Local residents are being ignored in their concerns about how 4. The nearby community is large and growing quickly - more than close the plant is 7000 families in Keysborough in 2016. Somerfield also growing. 15. The VCAT planning decision and whether EPA decision affects 5. The childcare, primary schools and colleges are so close, all 16. Residential planning and development activities showed no sign within 5km. of a WTE plant being planned nearby 6. The location for this facility is only 1.4 km from the closest residents and school (Mt. Hira college) and there are 2 primary D2 Concerns regarding road and traffic impacts schools, 2 colleges, 3 kindergartens and 1 maternal and child 1. Traffic impacts in school hours at Greens Rd and Chapel Rd, with health centre are within 5 km radius from this location, over 280 new townhouses being built, a new school and increased truck local residents have signed a petition to stop this happening. traffic. 7. People had no idea about the proposal before deciding to move 2. A significantly increased risk of traffic accidents, noise and to the area. odour. 8. The technology will have health impacts from air emissions and 3. Leaks, spills, or fire from trucking of waste and the hazard to that the technology should be trialled to demonstrate safety in children at nearby school. a country area with no residents 4. Traffic noise. 9. Suggestion to move this plan to a remote area with fewer 5. Traffic congestion getting worse than it is now. people living there. 10. Inter-generational equity

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Summary of Discussion at 20B Conference • Surrounding population density is increasing and will increase even more. Why are you concerned about the proposal in relation to this theme? • Why build new schools and homes and then put this next to it? • The proposal might stop the development of the area. The 77 people noted that they were very concerned about the proposal facility might turn off developers and people might move out in relation to this theme. One person was neutral, and one was satisfied with this theme. The following summarises the key reason • House prices will drop for those who were concerned. • 10 km emissions zone impacts a lot of people as it is a highly concentrated area. Why not select an area that is less

concentrated with people? Proximity to schools and aged care facilities Six tables raised concerns regarding the proximity of the facility to Buffer zone schools and aged care facilities and the associated risks of the There was a common belief that there is a legal obligation for any impacts on vulnerable community members. industrial facility to be located outside a 1.5 km buffer zone. • Potential risk to children and elderly • There is a school within 1.4 km which is inside the 1.5 km zone • Very concerned that the closest school is 1.1 km away and many • Everything is within 1.5 km buffer distance more within 5km. • Why was the land zoned for this use when it is within 1.5 • Incineration facilities should have a 10 km buffer to minimise the kilometres of a school? impact on human health – see research paper https://doi.org/10.3390/pr7100676 Yong et al. Sustainable Impacts on residents who have moved to the area Waste to Energy Development in Malaysia: Appraisal of • Moved in and spent a lot of money not knowing this would Emissions. happen

• Built a life here – disappointed and shocked. We are not young Proximity to residential areas people and moving is hard. Participants at five tables were concerned about the location of the • facility and its proximity to residential areas and the potential Mental torture to move somewhere else negative impacts on the local community. • This type of facility should be away from residents and other built-up areas even balancing the additional transport costs

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Poor planning • 300 vehicles entering the facility – concern about the trucks Participants at two tables blamed the current situation of adjacent driving through residential areas particularly given the expansion residential and industrial areas on previous poor planning by of the residential area. Council. • Trucks tracking dirt/waste and causing accidents like the issues • Concern over past decisions around poor planning and the related to the Clarke Road landfill. setting of a buffer zone and the decisions to allow residential • Mt Hira school is on the road that trucks have to go down. development close to an industrial area • Residents in new estates of Keysborough are close to the • Why are we, the community, being penalised for poor planning? proposed plant. There is already a lot of trucks that shouldn’t be • Urge EPA to influence Council planning process in single-lane roads that can barely fit cars. • Trucks are trying to avoid tolls – traffic congestion, volume, Choose a new location fumes and noise will increase • Majority of articles suggest 10 km buffer to residential areas. • Local roads – Ordish Road – can’t cope with additional trucks. • The location should be at a landfill site or a transfer facility Should have at least dual lane access. where the waste is stored and produced. • They have selected the site because the proponent owns the Other issues land rather than it being the best possible site. • There is not enough capacity in the plant to deal with current or future waste. • Should be much more aware of urban encroachment. • VCAT is prohibitive for community members to appeal due to costs. It takes away civil liberties to test your rights. It is not a Road/traffic impacts level playing field due to the costs and inability to present Concerns about traffic were raised at nine tables. Increased traffic scientific reports with expertise and credibility as you need the was seen as leading to increased accidents and increased pollution. scientific experts to present it. • Traffic management will be an issue. Council isn’t effectively • Loss of amenity -mental health. managing current traffic issues. • Majority of people would prefer the diesel fumes of transporting • Increased truck movements may block the road if the facility waste to a remote location over the proposed facility. can’t handle the increase. • Jobs at what price? More jobs created by recycling. • More traffic and trucks mean more accidents. • This facility is not appropriate given future development of the Dandenong South industrial estate.

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• Potential for pollution like fly ash to travel into neighbouring • Is this the best use of land? If it is I would prefer it to be properties. government-run because the government is more likely to be held to account.

Is there anything that could be added to the summary of issues Other issues for this theme? • Other countries will want to build this type of facility in Australia. Risks of fire It will set a precedent. • Concern about the fire risk in the facility which is surrounded by • VCAT and EPA not taking community concern into the decision. an area with existing high levels of waste and fire risk already. VCAT decision-makers don’t live in the local, affected • Concern about uncontrollable waste fires and the impact on the community. community. • Incineration in Guangzhou is the same and people complain about this. Complaints are censored by the government so we Use of Land don’t hear about it here. • Land utilisation – in Australia we have vast amounts of land so • Affect food processing in the area – Tip Top bakery, egg farms, why in a residential area? It is only for economic reasons, cheese. sacrificing our health for $.

Of the issues listed, which are most significant? Why?

Issue (as per grey box Number of tables Comments on pg 36) D1.1,1.2,1.3,1.4,1.5,1.6 6 Just too close on all fronts. Will affect daily living. (close to growing Uncertainty around the future welfare and value of property communities, young Historical planning decisions giving poor results give concern re future decisions. Feeling families, childcare, that Council isn’t being considerate in their decisions. schools) Inhibit development, house prices. Tradespeople and workers coming into areas are at risk because of toxins in the soil. Will they know about it?

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Issue (as per grey box Number of tables Comments on pg 36) D1.7 (lack of 2 People don’t know but they should. Not accessible to the community due to time and community language. knowledge) Does everyone know? Do the right people know? D1.12 (health impacts 2 No amount of money generated should come at a cost to human health. outweigh energy We did not have the opportunity to know about it and comment on it. generation) D1.9 (move it to a 2 remote location) ALL issues significant 2 D1.8 (needs to be 1 Availability of information. trialled to demonstrate safety) D1.11 (close to Green 1 Wedge)

If the proposal was to proceed, what actions or further • Help community visualise what 100,000 tonnes looks like in information could help reduce community concerns about this terms of impact on local traffic and roads. theme? Traffic Management Monitoring and Reporting • Traffic management plans – transparent, enforced. Something to • Government lifting its standards. Change regulation so can’t be show how trucks will not be going through the residential area. too close to communities. If regulation changes communities won’t have to keep defending. • Need clear numbers – how many trucks each day (and when)? How is this monitored and enforced? • Monitoring and transparent reporting – frequent.

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Other actions and information • Could any nearby factories or industrial facilities increase the • Move the plant to a site with fewer residents and better access. risks of this plant operating in this location? • Buffer zone – evidence that it is safe. • How many landfills and other garbage industries are around • Measurements of current conditions of this area. communities?

Outstanding Questions Consultation • Does VicRoads know about the facility? Traffic in local area and impacts on M3. • How close is the animal shelter to the facility and have they been informed? • Do surrounding factories know about the plant? What consultation as done?

Operations and management • Toxic and almost toxic waste – is this being delivered day or night? • How is the waste sealed/covered? This makes a big difference.

Monitoring, Reporting and Evaluation • How can we know where the odour is coming from and access this information openly? • Monitoring – Who? How? Reporting needs to be frequent and transparent

Other Questions • Sewerage and waste facility five kilometres down the road – why Can’t this go next to it?

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2.5 Theme E: Other Concerns Priority issues about this theme Due to the broad range of issues discussed during this theme, not all table hosts prioritised issues when recording participant comments. It is therefore not possible to define the priority issues.

Summary of submission feedback EPA provided a summary of community issues and concerns about this theme, as per the grey box below. These had been raised via community submissions before the Conference and were used as a basis for discussion.

E1. Concerns re climate change and greenhouse gases E2. Concerns re impact on society and economy 1. By “destroying resources rather than conserving them” there will 1. Destruction of economic development opportunities in the be significant and unnecessary lifecycle Greenhouse gas surrounding areas emissions. 2. Residents will move out and shops and schools will close 2. Global warming and pollution and whether producing energy by 3. The surrounding area will be less attractive to the public to live creating and releasing harmful and deadly contaminants is the and study way to go? 4. Impacts may force owner-occupier residents to move out 3. Gasification can reuse carbon emissions fails to mention the 5. Local crime rate will increase and the local business market will creation of additional greenhouse gases. decrease 4. Australia’s climate has changed dramatically, that recent 6. Council investments on the local community hub, parks, bushfires seriously affected air quality in Dandenong and playgrounds, and libraries will go waste if the proposal goes Keysborough areas and that the fire risk of waste storage in the ahead and people leave because of the impacts. proposed plant location will increase the risk to the public. 7. Council and the EPA are not resourced enough to detect pollution

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or enforce compliance. 9. How the resulting ashes will be treated, transported, stored and 8. Air quality impacts on local farming, including chicken and egg disposed production 10. The waste audit results were hidden as ‘commercial-in- confidence’ and not available E3. Concerns re property devaluation 11. The proposal needs to explore the reasons for opposition to 1. The proposal will impact house prices. similar overseas projects by residents 2. Not being able to afford to move away. 12. The application is at odds with the Council aim to “promote a 3. People who are disadvantaged and need to stay. healthy, active and safe community…” 4. The “possibility of our homes being ruined”. 13. Council cannot choose to promote health and at the same time 5. Property will be devalued due to traffic, noise pollution, health allow the risk of pollution. hazards and because no one will want to come to live here. 14. Management of GSWT by the EPA or Council to “meet best 6. The proposal wasn’t communicated before buying our property practice and mitigate impacts” (as per MWRRG [Metropolitan Waste Resource Recovery Group] Hub Plan Action point 5) is E4. Concerns re technology and regulation subjective and will in time become open to negotiation 1. The imported technology is experimental and that the risk is 15. Compliance to the Stockholm conventions, which requires unknown and uncertain. rigorous controls, has been proven to be entirely inadequate at a 2. The proposed facility is larger than European facilities local government and global level for this type of industry in the 3. There are no clear guidelines and assessment regulations for the past – especially for airborne or groundwater-based pollution gasification waste to energy technology in Australia. coming from private facilities. 4. The proposal cannot be protective of health and environment in 16. Lessons from mistakes in countries with an established WTE the location due to the current regulations in Australia. industry need to be considered 5. Waste to energy [WTE] is not a one and all solution for waste 17. At least a 10 km buffer zone from cities and residential areas is management needed to prevent health impacts caused by exposure to toxic 6. WTE does not solve the waste management crisis flue emissions that contain furan, dioxin, and other heavy metals 7. WTE will mean that improvements in recycling to minimise 18. The technology will have health impacts from air emissions and municipal solid waste will be impacted that the technology should be first trialled to demonstrate safety 8. Whether the trade-off of reducing one type of landfill waste for in a country area with no residents another and pumping toxic, persistent and bio-accumulative poisons into the air, ground and (potentially) water supplies, is E5. Concerns re other issues worth it. 1. The short notice (October 2019) of the proposal.

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2. People had no idea about the proposal before deciding to move 3. The safety of the proposal and the risks of dangerous accidents, to the area. fires or explosions

Summary of Discussion at 20B Conference Lack of experience of Applicant and EPA • If there is isn’t enough experience – EPA, government, the Why are you concerned about the proposal in relation to this applicant – and you put it next to a residential area then we theme? residents are just lab rats. Concerns with data • The business owner’s experience in the energy sector, • Data collected from China cannot be trusted because the specifically waste to energy. They don’t have any proven information is restricted. You can’t complain. People who live experience and have not implemented this technology before. there are suffering because of incineration. • Data transparency. Monitoring and Reporting and Compliance • There is not regulation and guidelines for this type of facility. Concerns about the benefit to the environment • The facility will burn more than 100,000 tonnes of waste per • Waste to energy is not a valid argument. It produces 28 times year and who will police. the dioxins, 2.5 times the CO2, 3.2 times the nitrous oxides, 6-14 • Best practises are not defined. times the mercury, and 6 times the lead compared to burning coal. • Danger from ash greater than putting waste in landfill. • • There are other cleaner ways to produce electricity. How long until EPA applies ALL the rules from Europe at incinerator plants • Landfills are available – don’t see the point. The reduction of waste to landfill from burning compared to normal compression • Potential for recyclables etc and industrial waste to be included in landfill is not a significant improvement. in the feedstock. • It’s backwards to return to burning – we need a circular • Not separating the recyclables. economy • This proposal is based on an overseas model with the • This is still not a clean form of energy. Greenhouse gases are still assumption that it will be replicated in every way. That is not significant. possible. Our grid, our infrastructure is different from that of Europe.

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Climate Change and Greenhouse gases Lack of community engagement • It will feed into climate change and there is no definitive • It has not been advertised equitably and we have not been given evidence that it will mitigate it, only in comparison to landfill. appropriate choice making information. • Climate change concerns – may be a better solution overall for • People closest to plant need to be informed and consulted about Victoria but not for the local area. the impact of the plant and property values. • Climate change – Bureau of Meteorology says we will increase 4 • Engagement with the wider community and culturally and degrees in 80 years- we are sanctioning a carbon-producing linguistically diverse people. plant with a life of 30 years. There are alternatives such as • Translation of science into everyday language. burying, recycling that should be considered and are less carbon- • Lack of information to community – we feel purposefully out of producing. the loop. Not enough has been done to involve the community. • Choose climate over the economy. Can’t turn back climate, can • Council process is not clear. Will VCAT allow consultation? We adjust the economy don’t think so which means the community has potentially been locked out of half the process. Concerns re impact on society and economy • This is contradicting economy policy and is not encouraging better waste management. Is there anything that could be added to the summary of issues • If this gets approved some community members will move out for this theme? which is not good for Dandenong. Costs outweigh benefits • The reputation of the area – a facility like this has a negative • The benefit to the environment is much less than the damage impact on the local area. and cost to the community and human health. • The flow-on effect of people moving out is shops and schools • Right of business to make a profit is higher than the rights to be closing down. a community. • The cost of this plant costs more than the benefit they add to Concerns re property devaluation the environment. The concerns are more than they plan for the • People have spent a lot of money and put in effort to make their plant. home and area nice – this is a surprise. • The real aim of building the plant is not clear – for money or for • Impact on property value helping the environment. • There is no great economic advantage – there would be more jobs if the land was used in other ways.

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• Will the plant have enough waste to run in the future? • Heavy industry is in cheaper areas, it creates disadvantage, people have no choice but to live there. It increases the crime Climate change and greenhouse gases rate because people are under duress. It feeds into the cycle of • Climate change and rising sea levels. No mention of climate disadvantage. Why should our community bear the brunt of change’s direct impact on animals and disappearing species. everyone’s waste? There should be some sort of compensation. • Climate change impact on human communities. Islands in the • The area will lose its attractiveness if this proposal is approved. Pacific are disappearing and we are losing areas of Lakes • People will move out, loss of opportunities, growth of Entrance. Dandenong will slow down.

Concerns re Impact on society and economy

• People might stop investing; the community economy might collapse

Of the issues listed, which are most significant? Why? Issue (as per grey box on Number of Comments pg 42-43) tables E1.2 (impact on global 2 Will cause more bushfires. warming, pollution) Toxins in animals – will affect what we eat. E2.2 (costs of moving 2 We have built our home here in this community, don’t want to see it disintegrate. away) E4.1 (experimental, 2 The technology is new. Where is the evidence that it is safe? Why are they experimenting in unknown technology) a high-density area? E2 (impact on society) 1 Impacts on society. We can’t represent individual residents but EPA and VCAT go ahead and we are locked out of the courts. ALL issues are significant 1 E3 (property devaluation) 1 Personal financial impact and an uncertain future.

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Issue (as per grey box on Number of Comments pg 42-43) tables E4.2 (proposal larger 1 Why does it need to be bigger? More of all concerns. than in Europe) E4.9 (ash disposal) 1 It is unclear where ash is going and how it is managed. Historical planning decisions giving poor results give concern re future decisions. Feeling that Council isn’t being considerate in their decisions. E4.16 (consider lessons 1 Must make sure we learn from others’ mistakes from WTE in other countries) E5.2 (lack of community 1 Nobody knew about it and we feel Council and EPA process has been rushed. awareness) E2.7 (EPA, Council not 1 EPA and council don’t have enough autonomy to stand against the State Government. They resourced) need more autonomy.

If the proposal was to proceed, what actions or further • Types of waste being incinerated, including whether recyclables information could help reduce community concerns about this will be separated. theme? • Show community the State Government’s waste to energy • Buffer in location. policy. • What can be done to educate the public about the benefits of • Publication of ash processing and associated risks and controls. the facility? More education is required in the community to • More data needed around E4 (technology/regulation)– greater help ease concerns and this, in turn, will help prevent property evidence. prices from going down. • Use alternative energy sources. • The community to see clear guidelines and regulations for this type of facility.

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Outstanding Questions this cost in their modelling and risk management? Will they Consultation want compensation? Who pays? The taxpayer? • Does VicRoads know about the facility? Traffic in local area and • Why was the project was first approved by past EPA? impacts on M3. • How could residents do better garbage classification so that a • How close is the animal shelter to the facility and have they been better solution to waste to energy can be found? informed? • Do surrounding factories know about the plant? What consultation has been done? • Have indigenous and cultural heritage considerations been explored?

Technology • Is any other state considering this technology? We believe NSW rejected it. • Has GSWT operated one of these plants before? • Why is this plant considered if it is not the best available technology? • Europe and USA are moving away from waste to energy – why are we taking it on?

Other Questions • What is the income source? • Has Haileybury been informed? • Economics: Federal Government is not very progressive or competent when it comes to the environment. There is no price on carbon. What happens when a more progressive government puts a carbon scheme in place? Has the applicant considered

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2.6 Other Input In addition to the submissions and discussion recorded at the Conference, questions from community members and additional points were provided to the facilitator afterwards. There was also a community member who was unable to attend the conference who contacted the facilitator before the Conference. The questions and feedback (where not already included in this report) are recorded below.

Additional Questions submitted at 20B Conference • Which types of garbage are prepared for incineration? Have you detected the calorific value of this type of garbage? • Will you burn: • Kitchen waste and garden waste? (more environmentally responsible to compost it) • Industrial waste (metal, soil etc)? (low calorific value in other countries, government recycles some recyclable items first then landfills them but the calorific value is very low unless new energy will be purchased and put into the incineration to ensure 850 degrees bottom line temperature. Does not make much sense for the bottom line) • Hospital waste? High risk. In other countries, it is incinerated in a specific factory. • Waste incineration power plants require the average low-level heating value of incineration waste entering the furnace must reach above 5000kj/kg.

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• Different zone, different areas provide different rubbish – are we • What happens if GSWT bankrupts? Who is going to take over the aware of that? Are we going to treat different rubbish operation? Has the government got a backup plan? differently, even to purchase new fuel to maintain 850 degrees? • How to deal with slag and fly ash separately? Fly ash must enter • A garbage collection truck processes 5 tons of garbage every the hazardous waste landfill or be processed by a hazardous time and the daily garbage processing capacity is 1500 tons. waste treatment company qualified for ash treatment and it Then about 300 vehicles will enter and leave the incineration must not be mixed with ordinary domestic waste for landfill plant every day. In addition, the garbage pool will store garbage treatment. Normally it is handled by a third party company. for 5-7 days. How does the waste incineration plant control the • How will you deal with landfill leakage? Where is the water impact of odour diffusion, leakage on the surrounding residents going? Is it going to Dandenong Creek? and environment? • Is there a compensation plan for the surrounding residents? • Are deodorants used at and around the incineration site? Local residents sacrifice their health and house prices drop. • Is the production area of the incineration plant closed and • In the past, we have reported numerous times about the odd operating under negative pressure? smell in the neighbourhood. These issues are still existing and • Is there a real-time live monitoring system to monitor the pending and we have not received any confirmed resolutions. If effectiveness of exhaust gas treatment? this problem has not been resolved, how do we trust the EPA • Is the third-party monitoring team available already? Who are will be able to ensure the new technology, which is being they? implemented in this country for the first time, will be monitored • An experienced operation team is very important for the efficiently? incineration plant to run up to standard! Will a team with • Do we have alternatives other than incineration? existing experience be employed? Please provide the profile of • How is this company making a profit? Funding from the the operation team. government or residents? • Will the government set up a professional supervision team for • Safe buffer zone: www.theguardian.com/australia- the incineration plant? Will it be the EPA? Third-party? Will it news/2018/apr/11/western-sydney-waste-incinerator- include local resident representatives? department-nsw Call on the Government to back the Greens to • What is the strategy and what is the formula? ban such incinerators withing 15 kilometres of residential areas to secure clean air into the future. • Are you going to get a third-party organisation to approve it? • • What treatment method will be adopted for dioxin and other Why is council / EPA looking at this having no regard to the state toxics? What temperature will they use? and local Labour’s commitment to recycling?

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• It is Inefficient: Reduces the use of recycling and reusability of • My business is food production, just 1 kilometre from the site. energy contained in recyclables/plastics, 10x more expensive Many people are working within the industrial area who will be than similar-sized solar plants, Very few jobs created. impacted. Have businesses been informed? • Worried about the smell, ‘invisible pollutants’, the appearance of • It is Toxic. the big generator. I know of this technology in other countries, • Dioxins - We have a duty to eradicate dioxins not create but it is always away from residential areas. This is the first time them (Stockholm convention). it is being used in Australia, and it is untested in our unique • Mercury poisoning is a real issue. conditions – our weather, the number of allergies in our population. The modelling data doesn’t take into account the • CO2 - Denmark has found that its waste to energy individual sensitivities of people (ages, inherited conditions, incinerators released 2x the amount of CO2 than originally allergies). estimated – the reason why they have missed their Kyoto targets! • Ash Waste - Where will the fly ash/filters and bottom ash be stored? • Will EPA test fly and bottom ash before its disposed of? • It opens Council and EPA to a class action. • It’s expensive and can be more polluting than coal/gas per kW hr • Waste to energy is one of the most expensive ways to generate electricity.

• How many tonnes of SO2 and CO2 will be produced per kW hr of energy generated? • How will Council afford constant measurement and remediation? • What will happen if GSWT can’t afford remediation or goes bankrupt? EPA and Council would need to protect residents from this eventuality.

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3. Final comments by participants At the conclusion of the conference, table hosts were asked to summarise the key issues raised at their tables. These were: • Children and families living/working/going to school close to emissions. • Incremental change – new impacts adding to the current load. • The unknowns in people sorting their municipal waste. • Current development of residential areas. • Trust – current odour problem. • Dioxins and accumulation. • Long-term health impacts • This proposal has so many unknowns – the community will be like lab rats. • A lot more information is required – is it safe? Is it proven? • The cumulative effect of this proposal and other industry. • Location – why a highly-populated area? • Concerns about facilities in China. • Monitoring, reporting and evaluation – by whom? It must be independent and accessible. • Proximity especially air emissions and the creek. • EPA’s knowledge of this technology. • Technology not addressing best waste management needs. • The technology proposed is already old, not best practice. • EU standards should be used across all aspects, not cherry- picking the bits they want.

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• The Works Approval and Planning Permit process – community robust, defendable, and we will give full consideration to the not properly informed of these processes. Have they been community and ensure if approved that there are the purposefully rushed? appropriate controls to ensure that the operations of the plant • Engagement with the community has not been done well, meet the requirements at that time. At the licencing stage, there especially with the CALD community. may be new standards that the proponent will have to adhere to. Timing will not impact safeguards.) • Property values – people have just moved here and now they want to move out. • Will there be another opportunity for the community to question the responses received by the applicant? (EPA • More information about technologies in Europe – debate about the standards. response: See the Works Approvals Next Steps slide at https://engage.vic.gov.au/epa-works-approvals/GSWT EPA and • No trust that EPA can make sure it won’t generate emissions. GSWT Presentations.) • Overrides on modelling. • Journal articles indicate that there should be a 10km buffer zone • Scope of contaminants on modelling. for human health. According to EPA, this is third or fourth generation technology so all historical data should be irrelevant. Participants were then invited to state issues that were still of If it is so new it hasn’t been verified, why can’t they do it concern to them. Questions and comments not recorded as part of somewhere away from people? the table discussions are listed as follows: • It is illegal to build it in this location - it is only 1.5 km from the school. I have read two documents and I know it is illegal to build • Page 12 of the application talks about sensory receptors this within 1.5 km of a primary or high school and we have a including Mount Hira College. I have measured this and at some school already there. Why are we even here discussing this if it points it is only 1.2 km away. How is it being measured? Isn’t is illegal? this a concern? • How many times will EPA measure emissions? Will the applicant • In the context of the times when the Bureau of Meteorology is be given prior warnings? Will there be real-time monitoring of predicting an increase of 4 degrees, you need to consider emissions by the EPA and the general public? (EPA response: go whether you should approve another carbon-producing plant. to engage.vic.gov.au and look at Current Works Approvals and • Why is EPA assessing this now when there are new regulations look at past decisions for Australian Paper Waste to Energy7 and due in 2020. Is this being rushed through before the changes? Recovered Energy Australia8 to see examples of how we set (EPA response: There is no rush. EPA’s assessment will be conditions and how emissions are measured.)

7 https://engage.vic.gov.au/epa-works-approvals/australian-paper-wa 8 https://engage.vic.gov.au/epa-works-approvals/recovered-energy-australia

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• The legislation will change, data can be overridden or can even 4. Conclusions be false. Please consider the community’s concerns and prioritise them. Look at the bad case studies when doing 4.1 Chair’s reflections and conclusions comparisons, not just the good ones. The location of the proposed waste to energy facility is a primary focus for many participants who attended the section 20B Conference. The proximity to residential areas, schools, aged care facilities and local businesses is a cause of great anxiety. There is a common belief that there is a legally enforceable 1.5 km separation zone that must be kept between a facility of this nature and residential areas. Clarification of the separation distance is essential to increase community understanding and potentially allay fears. Concern about the possible impact on nearby residents generated great concern across all themes discussed. The potential impacts include negative effects on human health, particularly for vulnerable community demographics, and a broad economic impact on the community due to property devaluation and impacts on local businesses. (It is noted that this last point is not within EPA’s scope) Related to the above, a common concern expressed by participants was the existing odour in the area and its effect on the environment, human health and community. It was felt that the cumulative effect is unknown and that the potential impacts of this proposed facility should not be looked at in isolation but in the context of the local industry and its current impacts. A sentiment amongst many who opposed the facility was a distrust of the proposed technology. Suspicion ranged from the untested nature of the new technology, the negative impacts reported from other waste to energy facilities in China, and the inexperience of

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both the EPA and the Applicant to appropriately understand, endorsement or judgement of them or their veracity but as a record manage and monitor the potential impacts. There was also a belief of the comments made at the conference. that other countries are moving away from waste to energy and that

it is a retrograde step for Australia to consider it when cleaner, more efficient energy generation methods are available. I take this opportunity to thank participants of the Conference for the respectful manner in which they conducted themselves, despite Many participants and submitters were concerned about the waste their fears and concerns. which will be processed. There is anxiety regarding the incorrect sorting of domestic waste, the risks involved in secondary sorting, and the consequences of the incineration of poisonous materials 4.2 Recommendations leading to toxic emissions. EPA and the Applicant have critical roles to play in acknowledging The potential impact of increased traffic was also of concern to community concerns and working with community members to many. The residential nature of local roads was considered to be transparently and thoroughly explain how any potential impacts will both inappropriate and inadequate to cope with increased usage by be negated. heavy vehicles. There is the worry that there will be increased accidents, congestion and traffic-related noise and pollution in the Although the City of Greater Dandenong only attended the 20B residential areas. conference in an observer capacity, many of the issues raised relate to the planning permit. As such suggestions for the City of Greater It is acknowledged that the Applicant has endeavoured to alleviate Dandenong (and/or the decision-maker for the planning permit) to some of the community’s concerns through the development of five consider are also included. banners, which were displayed at the Conference and the earlier information session. They are also provided on the Engage Victoria The following recommendations and suggestions are made in website. While these posters demonstrate excellent intent and are response to community comments, concerns and opportunities that supported by helpful graphics, they are not written with the were expressed at the 20B Conference and/or in submissions. It is layperson in mind. The language is overly complex and characterised noted that some of the recommendations in this report may be by jargon that makes the posters inaccessible to general community included or implied in the Section 22 Notice to Supply Further members, especially those from CALD backgrounds. Information, issued by EPA Victoria to the Applicant on 11 February 2020. It is reiterated that as Independent Chair of the conference and author of this report, I neither agree nor disagree with the Adoption of the recommendations and suggestions will assist in comments made at the conference by community members or the alleviating community concerns and improving community Applicant and include the comments in this report without engagement and relations with regulators and the Applicant.

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Accordingly, my overarching recommendations are that winds etc.). Include relevant information from similar technology in operation overseas, and its potential • due consideration is given by EPA Victoria to the application in this location. recommendations and suggestions contained in this report, and 1.3. Further to Recommendations 1.1 and 1.2, consider the use of the Precautionary Principle where verifiable data • feedback is provided to submitters and conference regarding potential health and environmental impacts do participants regarding the outcome of each recommendation not exist. and suggestion. 1.4. Require the development of an Air Quality Management

and Monitoring Plan including regular publication of data in 1. Before the determination of the Works Approval a form that is easily understood and accessible by the Application, it is further recommended that the following layperson. The Plan should include the actions that Great actions be undertaken by EPA Victoria. It is also Southern Waste Technologies will take if emissions exceed recommended that a response to each of the actions is threshold limits. included in the EPA’s Works Approval Assessment Report, 1.5. Investigate, through EPA’s Environmental Public Health with a summary that is written in plain English and (if Unit, baseline health data and the potential health appropriate) translated in line with the requirements of implications of the Application, particularly the potential CALD community members: cumulative impacts given the existing local industry. 1.6. Clarify, publicise and explain the rationale for the acceptable 1.1. Verify, through expert assessment, the nature and extent of ‘separation distance’ for a facility of this nature in relation potential odour and other air emissions risks and the likely to residential areas and schools, with reference to relevant ability of GSWT to keep these within regulated limits, planning policy. including during abnormal conditions (e.g. plant breakdown, blackouts, fire, extreme winds etc.). Include relevant 1.7. Require the Applicant to clarify how this proposal is information from similar technology in operation overseas, consistent with the state government’s Circular Economy and its potential application in this location. Policy and the 2017 Climate Change Act and that it represents the best available technology. 1.2. Verify, through expert assessment, the nature and extent of risks associated with storage, treatment and disposal of 1.8. Require the Applicant to develop succinct, plain English fact process by-products and the likely ability of GSWT to keep sheets and translated in line with local CALD community these within regulated limits, including during abnormal conditions (e.g. plant breakdown, blackouts, fire, extreme

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requirements. These should describe the proposal9, necessary and appropriate technical experts to answer including answering outstanding questions as detailed in community questions clearly and succinctly. this report. Efforts should be made to ensure that the documents are not written from a public relations perspective or in complex scientific language, but are 2. Before the determination of the Planning Permit developed with the sole purpose of building community Application, the following are suggested for consideration understanding. In particular, the following should be by the decision-maker of the Planning Permit: explained: 2.1. Undertake a peer review of the Traffic Impact Assessment, 1.8.1. The rationale for proposing the development at this with particular consideration of location given the concerns that community members 2.1.1. Assessment of proposed traffic movements and have expressed, transport routes (and possible alternative routes), 1.8.2. An evidence-based explanation of potential air number of traffic movements during different times of emission and noise impacts and planned management day and days of the week, strategies10, 2.1.2. Analysis of likely traffic impacts (noise, odour and 1.8.3. A detailed explanation as to how feedstock will be congestion) on residents, and correctly sorted and the strategies employed to ensure 2.1.3. Necessary road safety measures (such as signage, that subsequent emissions are within EPA limits, road marking, slip lanes etc). 1.8.4. Strategies to ensure that local waterways11, neighbouring properties and groundwater are not 3. Should the Works Approval Application be approved, it is adversely impacted due to drainage or leaching, and further recommended that the following actions be 1.8.5. Emergency response strategies in the case of undertaken by EPA Victoria: abnormal conditions. 3.1. Require the development and ongoing implementation of a 1.9. Consider a further information session or question and answer process after the Requests for Information have Community Engagement and Complaints Response Plan as a been received from the Applicant and accepted by EPA. condition in the Works Approval and/or Licence. This session should include language translation where

9 10 11 As mentioned in Section 4.1, the Applicant has produced information banners; these could be rewritten in simple language to meet the requirements of Recommendations 1.8.2 and 1.8.3.

57 Great Southern Waste Technologies Approval Application for a Waste to Energy facility 20B Conference Report March 2020

3.2. Ensure that the Air Quality Management and Monitoring 6. Regardless of whether the Planning Permit Application is Plan (as detailed in Recommendation 1.4) is implemented in approved or rejected, it is further suggested that the accordance with any EPA Licence that is issued. following actions be undertaken by the decision-maker or 3.3. Following the issue of any EPA Licence to operate, ensure City of Greater Dandenong: that any breaches of air emissions or noise conditions are 6.1. Make the Planning Permit Assessment Report and enforced. attachments publicly available. 3.4. Actively promote the EPA’s role in managing compliance to local residents, including detail on how to register a complaint in the event of noncompliance. 3.5. Provide information to the community about the requirements post-closure of the Applicant to ensure that the site is remediated.

4. Should the Planning Permit Application be approved, it is further suggested that the following actions be undertaken by City of Greater Dandenong: 4.1. Require signage and any road modifications as deemed necessary by VicRoads. 4.2. Designate operating hours to reduce road safety impacts (as informed by the Traffic Impact Assessment).

5. Regardless of whether the Works Approval Application is approved or rejected, it is further recommended that the following actions be undertaken by EPA Victoria: 5.1. Make this report publicly available.

58 Great Southern Waste Technologies Approval Application for a Waste to Energy facility 20B Conference Report March 2020

Appendix: Conference Agenda