Response to Revised Draft EIS – Proposed Non-Recyclables Plastic to Fuel Facility, Hume

Inquiry Panel Secretariat, Foy Inquiry Panel

Introduction

While Tuggeranong Community Council (TCC) recognises the value of converting waste into useful products and the introduction of new recycling technologies, in appropriate locations, the ACT government needs to ensure that such a facility is safe, non-polluting and offers significant benefits over residual risks posed to nearby residents or the many workers in the industrial precinct of Hume itself, throughout all of any agreed lease period for the site.

Annex A is a detailed assessment by the TCC of the revised Environment Impact Study (EIS) submitted by The Foy Group.  It requests certain clarifications by the Government and makes certain recommendations to the Government in respect of the proposal and the EIS.  It has been prepared after committee members of the TCC Attended the public forums held on 6 and 7March 2017 by the independent review panel, appointed by the Government.

Annex B is a copy of the TCC submission made in October 2016 and is included for completeness and to avoid repetition of relevant information.  Except for where concerns expressed therein may have been since clarified by the revised EIS, the content of that submission still stands.

Comments

After review of the EIS and attendance at public forum sessions, the TCC wishes to express the following concerns about the proposed facility at Hume, as summarised from Annex A (in no particular order of priority):

• Should the Foy proposal be approved, the TCC recommends that storage capacity be reduced to a minimum.
• There needs to be adequate safeguards in place to prevent over exploitation of the site to the detriment of Hume workers and local residents.
• Should the Foy proposal be approved, the TCC recommends that the Government conduct regular, independent inspections of facility processing and various records of operations, as a quality assurance and public safety measure.
• The TCC requests clarification as to the volume of feedstock from the ACT and asks what will happen to any waste residue.
• The TCC requests clarification as to the volume of diesel the ACT Government has agreed or intends to buy from the facility.
• The TCC recommends that the energy equation for the system as a whole be determined before any Government decision.
• The TCC recommends that the pollution equation for the system as a whole be determined before any Government decision.
• The TCC requests clarification as to whether excessive pollution from this facility would comply with ACT Government legislation in place or current policies and takes into account the inversion layer in the Tuggeranong area.
• The TCC requests that the Government advise details of the lease agreement agreed to.
• The TCC recommends that the proposal for the facility to be allowed in Hume be rejected on the grounds alone that the proposed facility is essentially experimental.
• The TCC recommends that, before any decision, the Government insist upon Foy producing a business case as well as satisfying the requirements of an EIS.
• The TCC recommends that, before any decision, the Government insist upon The Foy Group producing adequate bank guarantees and insurance policies for the duration of the lease period.
• The TCC recommends that the Government insist on independent validation of the Ausplume model for the Hume site and the Tuggeranong Valley in general.
• TCC considers that the economic benefit of the project is insufficient to outweigh the potential risks posed by this facility.
• The TCC recommends that the Government show good faith and allow public access and reaction to the Panel’s report before any decision is taken.
• The TCC is not yet convinced that collectively the mitigated risks of the myriad risks involved are acceptable.
• The TCC has welcomed the advent of the Panel and looks forward to seeing its conclusions and recommendations to the Government.
• TCC concludes that the Foy proposal offers very minimal benefits to Tuggeranong and the ACT but raises concerns about possible significant risk to workers in Hume and to local residents.

Summary

There are too many important questions yet to be answered.

Given that the technology for the proposed facility is not proven, at least in Australia, and refused already by NSW EPA, The Foy Group proposal has to be categorised at best as experimental.  If The Foy Group were genuine in its intent to not cause any ill effects on people or the environment, it should have sought a totally safe site and, if proved successful, it would have a solid basis for development of like facilities in other areas.  Given the perceived risks involved, there is no valid reason why this heavy-industrial facility should be located in Hume or anywhere near residential areas.

In spite of assurances that may be made, the TCC considers that the project offers only considerable and unacceptable risk with negligible benefits to Tuggeranong residents.  The TCC therefore does not endorse the revised EIS or agree to the project proceeding at Hume.

Glenys Patulny
President, Tuggeranong Community Council

Canberra, 15 March 2017

Annexes: A and B. [Prepared by M. R. Flint, ADip (Elec Eng); MSc (Logistics), Treasurer, TCC]