Submission: Wollert Waste to Energy Incinerator

On Sunday night we sent off our 16 page detailed submission in to the EPA Victoria engagement for the Cleanaway Development licence for the Melbourne Energy Recovery Centre (MERC) Incinerator proposal, with 3 hours to spare. There are more points we would have liked to have included, but in the end we were defeated by the volume of information in the Development licence proposal and the need to research and build up science based arguments to the proposal.

We note the Planning Minister denied an Environment Effects Statement, despite the Basel Convention clearly stating that hazardous waste incinerators should have environment Impact Assessment done for each location.

We note Whittlesea Council is operating under Administrators so local residents have no elected Councillors to debate planning issues and represent them to the State Government.

We note the EPA Victoria is both underfunded and under resources to actually ensure Cleanaway is compliant if the project is approved.

We note the flaws in the EPA Consultation process.

We note the record of Cleanaway, from just a cursory google search for the last few years. We question whether Cleanaway is a fit and proper organisation to run a complex Waste to Energy Plant that has potential for causing substantial environment and health risks in the Northern Suburbs:

Executive Summary

While our essential concern is the need to reduce greenhouse gas emissions to address the climate emergency, we have related interest in reducing air pollution to improve health, and general environmental protection in embracing sustainable solutions and moving to a circular economy in minimising waste.

Cleanaway intends to operate the Melbourne Energy Recovery Centre (MERC) Waste to Energy
Plant for 30 or more years. We do not believe the applicant has demonstrated the project will
contribute to meeting the legislated Victorian climate targets of net zero by 2045, but will
substantially add to the state’s emissions.

Cleanaway has not demonstrated that this plant is at the very end of a waste processing hierarchy, and considered the possibility to do further waste stream separation and recycling.

After separation of waste into recycling streams, pre-sorted landfill with bio-stabilisation provides the best option for Australia’s residual waste in terms of climate, air quality and public health costs as part of a circular economy.

We argue that the development licence for Cleanaway should not be approved in our submission and that the EPA should deny the development licence.

We also comment on the Planning process and the minister’s decision to deny an Environment
Effects Statement, and the consultation process.

We note part of Cleanaway’s CEO Mark Schubert vision for the Melbourne Energy Recovery Centre (MERC) is “feeding waste CO₂ to ‘protected cropping’ in closed hydroponic and greenhouse crops.”

Yet the Cleanaway licence argues that air pollution to the surrounding area, which includes residential areas and agricultural production, will be minimal.

We also note the statements by Marcos A. Orellana, UN Special Rapporteur on Toxics and Human Rights, who visited Australia from 28 August to 8 September 2023. In his End of Mission Statement released 8 September one of the areas he highlighted was Waste Incineration, and he also noted Air quality standards in Australia are less protective than in other member countries of the Organization for Economic Cooperation and Development (OECD).

“Waste incineration is the end of the line for fossil fuels. It reflects a linear process that is incompatible with a circular economy. Incineration imposes heavy health and other costs on local communities, and it is a significant source of greenhouse gases. It has been reported that even the most modern incinerators produce dioxins, furans and toxic ash.”

Climate Action Merri-bek gives our thanks to the Anti-Toxic Waste Alliance and Environmental
Justice Australia for permission to use their submission to the EPA consultation on the Prospect Hill International Pty Ltd as a resource to inform this submission.

References

APRIL 7, 2024, Community meets and hears speakers on Wollert Incinerator project. Submissions needed https://climateactionmerribek.org/2024/04/07/community-meets-and-hears-speakers-on-wollert-incinerator-project-submissions-needed/

FEBRUARY 20, 2024, Consultation on Wollert Waste to Energy Incinerator Plant https://climateactionmerribek.org/2024/02/20/consultation-on-wollert-waste-to-energy-plant/

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