Why Waste Waimate

A company going by the name of South Island Resource Recovery Limited (SIRRL) is proposing to build a Waste-to-Energy(W-t-E) incinerator in the heart of a pristine farming and food producing district in Waimate. The proposed site is 2.5km north of the small township of Glenavy adjacent to the majestic Waitaki River. The proposal is called Project Kea, you could be mistaken for thinking that this venture is about native bird conservation or as the company's name suggests, recycling, but unfortunately both of these titles are nothing more than a smoke screen to obscure the truth.

What Is W-t-E?

W-t-E is the process of burning municipal solid waste (MSW) to create steam which in turn powers a turbine to create electricity. SIRRL's proposal is to burn 365,000 tonnes p.a. of MSW and construction waste (CW) gathered from around the South Island to create 20-30 megawatts (MW) of electricity in the process. To put this amount into context, NZ generated 9,758MW of electricity in 2020.

Who Is SIRRL?

SIRRL is a 60% overseas-owned company made up of China Tianying (CNTY) 41%, Europe Zhongying (EUZY)19% and NZ company Renew Energy Limited (REL) 40%. Although EUZY is registered in Europe it is 100% owned by the controlling Chinese shareholder CNTY. A percentage of CNTY shareholder companies are owned by the Chinese government. SIRRL and REL director Paul Taylor was recently asked what the Chinese government's links to CNTY are and he said he didn't know: "They're a large public company, so I'm not sure whether they're linked" (North and South, 09/23, George Driver).

PR Spin

The company has hired a well-oiled public relations firm called Convergence to liaise with Waimate District Council and provide a Website that references how well W-t-E works in Europe. This Website highlights incentives that don't exist in little old Waimate, incentives like using the steam generated for central heating and W-t-E as an alternative to densely populated countries that don't have required space for landfill.

Green Washing

In addition to using the native parrot and naming itself to look like a recycling company, it also likes to cherry pick green looking add-ons from European plants that budget for three times as much as SIRRL's $350m budget. Embellishments like CO2 sequestering for use in neighbouring glasshouses (which in SIRRL's case don't yet exist), aggregate from ash recovery for use in roading and construction (when regulations in NZ don't allow this) and hydrogen production from excess electricity produced at the plant, when the company will be reliant on selling any modestly produced electricity onto the network in an attempt to make a profit.

Euro Washing

The Project Kea Website also does a pretty good job of Euro washing this proposal, by providing references to W-t-E in Europe, but does nothing to reference W-t-E practices in the country this proposal truly aligns with, China. The technology to be used is Chinese-owned, the company which will build the plant is Chinese-owned and the company which will own the controlling percentage and which will operate the Project Kea plant is again Chinese-owned. CNTY, which SIRRL claims has the technology and expertise to build and operate a plant that will outperform European Union standards, has yet to build a plant outside of Asia. No accessible data from any reference plant has been provided to substantiate the company's claims.

Resource Consent Applications Returned

Eight resource consents are required to build and operate this plant; the company lodged seven of these with Waimate District Council (WDC) and Environment Canterbury (ECan) in September 2022. These applications were returned for a "lack of fundamental information". SIRRL re-submitted in November 2022 just a few days before changes to the Resource Management Act (RMA) came into effect.

Changes that would require any application made after December 2, 2022 to have greenhouse gas emissions evaluated in any application. This application was also returned due to the lack of a site-specific Cultural Impact Assessment (CIA). SIRRL appealed that decision which resulted in an appointed commissioner ruling in the applicant's favour and stating that the application was complete without a CIA.

Ministerial Call-In

WDC and ECan have subsequently requested a Ministerial call-in of the application due to the national significance of the proposal. After taking on the Environmental Protection Authority's (EPA) advice, the Minister for the Environment has decided the application should be decided in the Environment Court.

OIO Approval Required

SIRRL released a media statement in April 2022 stating it had purchased the required 15 hectares of land near Glenavy/Waimate subject to resource consent and Overseas Investment Office (OIO) approval (Stuff, 28/04/22, Yashas Srinivasa). The company lodged an application with the OIO to acquire the 15 hectares of sensitive land for the proposed incinerator in March 2023.

SIRRL, which was registered with the NZ Companies Register in March 2021, also applied for approval from the OIO in March 2023 to acquire sensitive business assets because the company is over 25% overseas owned. The total investment of $350m exceeds the $100m OIO threshold; this also requires that the company seeks OIO approval. An OIO recommendation was expected to be forwarded onto Government ministers in late November 2023, and the understanding is that a decision will be made by the appointed Minister.

Resource Recovery, Or Resource Destruction?

The burning of 365,000 tonnes of waste annually will require the use and destruction of 2.5 million litres of fresh water DAILY. A large percentage of this water will be turned into water vapour and released into the atmosphere as a greenhouse gas. The process of waste incineration will also require the use of numerous bulk substances in an attempt to mitigate toxic emissions.

Dangerous Emissions

Despite emission control technology being employed at the plant, numerous toxins which include cadmium, mercury, lead, furans and dioxins will still be released, by way of emissions from the stack and toxic residue ash destined for landfill. Although the company claims emissions will be real time monitored, this only accounts for gases and does not cover dioxins/furans and heavy metals; these toxins will be sample gathered and lab tested every three months initially, extending out to six monthly, and will not take into account the bioaccumulation on ground and surface areas.

There is also no record of whether the results of lab testing will be independently verified or made accessible to the public. Samples taken from hens' eggs, dairy cows and soil samples in the vicinity of W-t-E plants in Europe have in the past found high levels of heavy metals and dioxins (Science Direct).

Particulates

The below information on particulates has been sourced from a 71-page medical report completed by the British Society For Ecological Medicine, titled "The Health Effects Of Waste Incineration".

Particulates are tiny particles in the air classified by size. PM10's have a diameter of less than ten microns, whereas fine particulates (PM2.5s) are less than 2.5 microns. Ultra fine particulates (PM0.1s) are less than 0.1 microns. Baghouse filters commonly used in incineration plants effectively act like a sieve, allowing the smallest particles to get through while blocking the less dangerous larger particulates. Only 5-30% of all PM2.5s will be removed by these filters and virtually none of the PM0.1s.

Studies have shown that toxic metals accumulate on the smallest particulates and that 95% of polycyclic aromatic hydrocarbons (PAHs) are associated with fine particulates (PM3 and below). PAHs are toxic and carcinogenic, and it has been estimated that they increase the risk of lung cancer by 7.8 times. The last sentence contained in the report reads: "We recommend that no future waste incinerators be built".

WHO, Dioxins

The World Health Organisation (WHO) describes dioxins as belonging to the so-called "dirty dozen"- a group of dangerous chemicals known as persistent organic pollutants (POPs). They also describe dioxins as highly toxic and can cause reproductive problems, damage the immune system, interfere with hormones and also cause cancer. Once dioxins enter the body, they last a long time because of their chemical stability and their ability to be absorbed by fat tissue, where they are stored in the body.

Their half-life in the body is estimated to be seven to 11 years. In the environment dioxins tend to accumulate in the food chain. The higher an animal is in the food chain, the higher the concentration of dioxins. The site of this proposed plant is about 2.5km from Genavy township and school. Prevailing north easterly winds will carry any emissions directly over the school.

Burning Plastics

The waste burnt will contain huge amounts of plastic. SIRRL has said that it will not burn recyclable material but has not provided any plausible method for achieving this as there will be no sorting facility at the plant. Plastics have a high calorific value (CV) i.e., they release a large amount of energy when burnt. Igniss.com provides a calorific value table that shows plastics at around 35 megajoules per kg or 41 for PVC, compared to paper at 13.5 and dry wood 14.4. Coal has a CV of 15-27 depending on grade.

For something to burn without an auxiliary fuel it requires a CV of at least 14.4 (the equivalent of dry wood). MSW has a CV of 7-16mj/kg before recycling has taken place, the variables are the result of organic material and moisture content, the higher the moisture content the more auxiliary fuel required for efficient combustion. In SIRRL's case the auxiliary fuel to be used is diesel.

From this we can see that burning plastic will provide more energy which results in more electricity and more profit, so it's in SIRRL's best interest to burn plastics and lessen the need for expensive diesel consumption. There are numerous examples of companies throughout NZ thinking outside the box and recycling otherwise non- recyclable plastics into recyclable materials, for instance Futurepost which turns soft plastics into fence posts and garden beds. If SIRRL or any other MSW W-t-E company was to be granted a consent to burn this and other reusable materials, it would effectively kill future initiatives like that of Futurepost.

Target Small Towns

The NZ arm of SIRRL, Renew Energy, has previously attempted to build a W-t-E plant in Westport. This became untenable after the then Buller Mayor, Gary Howard, accompanied REL directors on a trip to China to view a CNTY W-t-E plant, and while there signed operational deals with the Chinese without his Council's knowledge (Stuff, 04/04/19, Joanne Carroll).

In 2018 Renew Energy managed to acquire a $350,000 feasibility grant from the Government to investigate the viability of a W-t-E plant, however this was retracted after Government ministers learned that REL director/shareholder and founder, Gerard Gallagher, was being investigated by the State Services Commission for his part as a public servant working in the former Christchurch Earthquake Recovery Authority (CERA). (Stuff, 28/02/18). Mr Gallagher would later be charged by the Serious Fraud Office (SFO) and found guilty on three charges of corrupt use of official information.

REL then moved on to Hokitika to yet another eagerly awaiting Mayor, but again failed to impress locals after an Official Information Act (OIA) request provided material that showed another REL director, Kevin Stratful, had used his work emails while working as a ratepayer funded West Coast Economic Development consultant to promote the W-t-E proposal that he had a personal interest in. It was also made public from this OIA material that Mr Stratful had tried to coach councils on how to avoid OIA requests (Stuff, 14/11/19).

Why Waimate?

The targeting of small under-resourced towns continued with the announcement in September 2021 (Stuff, 15/09/21) that Waimate with yet another overly zealous Mayor was chosen as the ideal location (albeit at least third choice) for a W-t-E plant. This media announcement included a supporting statement from Waimate Mayor Craig Rowley.

He said it was an exciting proposal which could create many benefits for the district. "This would include new employment opportunities and is yet another example of the district's appeal to commercial operators. This initiative has yet to go through the required consenting process, but we know the growth these major enterprises can create-and that's a big positive for the Waimate District".

Yet another OIA request provided emails that showed that SIRRL's public relations representatives, as well as asking for a supporting statement from the Mayor, also asked Waimate District Council for a list of the town's key influencers in yet another attempt to garner support for their proposal. There is the question of why build this plant so far away from the population base, waste source and infrastructure required to support it. If most of the waste is coming from Christchurch, wouldn't it be logistically better suited nearer Christchurch?

Or maybe Waimate was seen as a sleepy little back water unlikely to put up much of a fight? It would seem that having backing from small town mayors has more bearing on the siting of these proposals than the actual working logistics. Similar W-t-E proposals have recently popped up in more small towns around NZ including Feilding, and Te Awamutu as companies try last ditch attempts to get in on the tail end of a dying industry.

Community Condemns Waste-to-Poisons Plant

After first releasing the proposal publicly in September 2021 the company has used a Website providing misleading and false information to help sell its concept to the Waimate community. Convergence asked WDC staff to plug the Website and direct any locals wanting more information about the proposal to the site. The information contained in this Website was essentially all locals had to learn more about this venture as numerous attempts to get the company to return to Waimate with more information were ignored.

Fifteen months after first announcing its proposal, SIRRL lodged a resource consent application which provided the true intention of this company, to truck municipal solid waste and construction waste from around the South Island (mainly Christchurch) to Waimate, incinerate it and then truck the remaining 100,000 tonnes of residual ash produced annually to landfill. This will require 134 heavy truck and trailer movements daily. Local community groups, including a group of five doctors, have publicly condemned the proposal, calling it a "waste to poisons plant" and, along with an opposition group called Why Waste Waimate, have for the last 18 months asked SIRRL to provide more information about the proposal.

Jobs

Waimate is also promised jobs, the company says 100 and then inflates that out to 300 with the addition of neighbouring glasshouses; glasshouses which will be reliant on someone else to build if they eventuate at all. Just where are these employees going to come from? And how is the company going to accommodate them? Our Mayor who, up until recently, was giddy with enthusiasm at the prospect of Waimate becoming known as "Rubbish Town" has recently said we don't need more jobs. Local dairy factories were built with the same promises, jobs for locals, when the reality is they need to bus workers in from neighbouring districts to fill positions, while those workers pay rates and spend their wages elsewhere.

Budget

The company has provided a $350 million budget for Project Kea, this budget was provided two and a half years ago and despite significant inflation and admission in March 2023 by director Paul Taylor that the budget is "probably unrealistic" they have failed to provide any alternative budget. Similar sized plants in Europe budget for twice to three times as much. In an April 10, 2023 Stuff article Paul Taylor was quoted as saying "what we're proposing here is a Rolls-Royce compared to many plants in Europe".

In 2009 Chinese motor company Geely released the Geely GE car. Rolls Royce motor company saw the GE as an obvious rip off of the Rolls Royce Phantom. The Geely GE budgeted for $US44,000 compared to the $US365,000 of the Rolls Royce Phantom. Was the quality of the Chinese model that of the Rolls Royce? Of course not. One cannot help but draw comparison to SIRRL stating it will provide the "best of the best", the "Rolls-Royce" of incineration plants for a fraction of the budget of European plants.

Flood Risk

The proposed site is 50% bordered by open water channels and the entire site is within a flood zone, this was evident when most of the site was recently under significant amounts of flood water due to heavy rain. Locals have reported seeing the site and adjacent area flooded numerous times over the last 30 years.

Fire Risk

Resource consent applications made by SIRRL state that the company will store in excess of 40,000 tonnes of waste onsite at any one time, with a further 7,000-tonne bunker capacity inside the plant. This waste storage poses a huge fire risk. There is no way of controlling what enters the waste destined for Project Kea. The current waste stream contains numerous hazardous and flammable materials including lithium batteries, which are known to frequently cause rubbish collection trucks to catch fire.

A recent fire at a W-t-E plant in Florida in the US burnt for three weeks. Locals had to be evacuated for threat of exposure to toxic emissions. There are numerous examples of such fires breaking out at W-t-E plants globally. Waimate or Glenavy volunteer fire services would be unlikely have the resources needed to deal with such a blaze and the likelihood is any fire would burn itself out and create a huge environmental disaster that the region would struggle to fully recover from.

Climate Changing Emissions

Diesel generators will be used to provide an auxiliary fuel source for the plant, to fire the plant up from cold start and to keep the plant's incinerator above the required 850 degrees Celsius. That's why SIRRL's resource consent includes provisions to store 100,000 litres of diesel onsite. Also factor in the extra 134 truck movements daily carting waste from all around the South Island, and carting the residue ash to landfill, that's a lot of diesel required to make a rather insignificant amount of dirty electricity.

Waste incineration creates climate changing greenhouse gas (GHG) emissions, these GHG emissions are not limited to carbon dioxide (CO2), they also include nitrous oxides (N20), oxides of nitrogen (NOx), and ammonia (NH3). SIRRL has stated that gas emissions exiting the stack will be as follows; 63.5% nitrogen, 21.8% water vapour, 7.5% carbon dioxide and 7.2% oxygen, so 92.8% of what will be exiting from Project Kea's stack will be climate altering, perhaps this is why the company rushed the lodgement of its resource consent application in an attempt to avoid RMA changes that would require that its application has GHG emissions taken into account?

A paper titled "Emissions From Waste Incineration" written by Bernt Johnke provides the following formula for CO2 output from W-t-E, 1 Mg of municipal waste in MSW incinerators is associated with the production/release of about 0.7 to 1.2 Mg of carbon dioxide (CO2 output). Applying this formula to SIRRL's intended incineration of 365,000 tonnes of waste annually will produce up to 438,000 tonnes of CO2 p.a.

Better Alternative To Landfill?

SIRRL has been comparing its proposal as a better alternative to landfill, however in doing so it has repeatedly used historic landfilling practices for comparison. Fox River on the West Coast of the South Island is one such example it likes to provide. Fox River was a tip that predated the Resource Management Act's (RMA) inception in 1991. Prior to the forming of the RMA there were very few regulations around the landfilling of waste in NZ. Using such landfills as a comparison is misleading at best. Past councils, in their wisdom, provided tips near watercourses and coastal areas; this unfortunately means we now inherit numerous historic landfills around NZ at risk of exposure from weather events.

Project Kea will do nothing to change that. Is SIRRL going to open up all the historic landfills in the South Island and incinerate the contents? The answer is no, as this simply is not viable, the moisture content of waste already landfilled would be such that it would not provide the calorific value required to burn efficiently. Add in the logistics of uncovering, removing and transporting that material to site would make the idea uneconomical.

SIRRL also likes to reference climate affecting methane gas produced by landfill, and claim that its W-t-E proposal is a better option, however, again it is using outdated landfilling practices to draw comparison. The biogenic methane produced in landfill results from organic material breaking down in the waste. Future Government regulations will ensure that green waste will be separated from MSW, therefore removing the methane producing content.

Also, modern landfills like Kate Valley in North Canterbury which currently accepts most of Canterbury's waste, utilise methane capture technology to produce electricity and somewhat mitigate atmospheric methane release. In making its comparisons, SIRRL needs to stop using misleading comparisons to outdated waste disposal examples like Fox River that have no relevance to modern landfilling practices.

Landfilling Ash

The company refuses to say where it will landfill the resulting ash produced by Project Kea, maybe it doesn't yet have a landfill willing to accept it? However, it has provided distance values in its resource consent application that suggests Kate Valley landfill in North Canterbury. SIRRL has constantly tried to sell itself as a better alternative to landfill, which answers why it has kept its true intention of landfilling the ash out of the public eye. I quote SIRRL director Paul Taylor: "We simply can't continue to bury our mounting rubbish problem in the ground for our children to deal with". Mr Taylor's argument loses all credibility when the thing he is arguing against is required as a major part of his company's intended operation.

Waste

The company also claims it has contracts in place to acquire most of the 365,000 tonnes of waste required each year. This flies in the face of what experts in NZ waste management say. The waste stream in NZ is already spoken for, councils have contracts in place with well-established waste management companies. Many councils like that of Christchurch City have shareholdings in landfills which bring a return on their investment, so are unlikely to provide waste to an incineration plant.

The two largest waste management companies in NZ, Waste Management NZ and Envirowaste have both stated in a North & South magazine article that they will not support a W-t-E plant. So, if the majority of the waste created in the South Island is already spoken for, then where is the waste going to come from?

Import Waste?

As mentioned earlier, REL the NZ shareholding company behind SIRRL has had previous attempts at building a W-t-E plant on the West Coast. Westport was its first port of call. When asked "why Westport?"", the then managing director, David McGregor, said: "Because it was near a PORT for the importation of waste from the Pacific Islands and Australia". So, is SIRRL going to import waste for incineration? Maybe. The company is prepared to cart waste from all around the South Island, so why not further afield? SIRRL is after all 60% overseas owned. Importing waste would only add to the ludicrous nature of this proposal.

Provide Neighbouring Industries With Energy

The company has also said it will provide neighbouring industries currently using coal fired boilers with energy to offset their carbon emissions. However the only neighbouring industry is Oceania Dairy factory about one km north of the proposed site. SIRRL has confirmed that it does not have any agreement in place with Oceania.

Rail Siding

The company also states that it intends to build a rail siding and freight 50% of the waste via rail. However, SIRRL directors have confirmed that there is no agreement in place with KiwiRail. Why use rail? Local dairy factories Oceania and Fonterra both claimed as part of their resource consents that they would build rail sidings and use rail to offset road use. This never happened and is unlikely to happen at Project Kea. The prospect of an extra 134 heavy truck and trailer movements required for Project Kea is unpopular with locals, due to roads already in poor condition and the extra road congestion. How do you mitigate locals' concerns? Tell them you intend to use rail.

SIRRL's claim to build a rail siding at the proposed site requires it to build it on neighbouring land owned by MGI Irrigation. The MGI owned land sits between the main trunk railway line and the proposed Project Kea site. The land is used to carry water via an open channel for irrigation. SIRRL has provided a letter of support from MGI Irrigation as part of its resource consent application. This letter states that MGI will make the land in question available to SIRRL by way of a commercial lease.

Is it likely that SIRRL will build a very costly rail siding over the top of a currently open irrigation channel that runs the entire length of the site, on land it doesn't own? REL will be contracted to provide the waste for Project Kea, one of REL's current shareholders owns multiple trucking companies. This may also suggest that rail will unlikely play any part in any future Project Kea operations.

Company's Motives Questioned

So, Why Waste Waimate questions the intentions behind a 60% Chinese owned company wanting to acquire pristine farmland in a rural location, within a flood zone to build a waste incinerator hundreds of kilometres away from the waste source, and population base, without infrastructure to support it, when there are huge question marks over the waste availability and the economic viability of a W-t-E plant in NZ, with a budget that is proven to be well below what's required to provide best practice standards.

There is also the question of how this company believes it can make W-t-E work in this country when previous feasibility studies conducted in NZ by well-established W-t-E companies have concluded that the figures don't stack up. See BERL report "Waste to Energy - The Incineration Option".

Corruption

Add in the dubious history of the NZ company behind this proposal, Renew Energy Limited (REL). History which includes a former director being prosecuted and convicted by the Serious Fraud Office (SFO) on three counts of corrupt use of official information, who has continued to be paid by REL as an independent contractor until late 2022 (at the time of writing this, Gerard Gallagher is currently serving a 12 months home detention sentence).

OIA requested material also supplied emails that showed Gallagher had asked Council to legally threaten a journalist writing about the proposed plant, to get them "sorted out once and for all". Another REL director who was employed by the West Coast Regional Council used his work emails to promote a previous Waste to Energy proposal he had a personal interest in, and who also attempted to coach councils on how to avoid OIA requests. Add to that, the company unlawfully storing huge amounts of baled waste at a site near Christchurch while it tried to commission an incinerator plant (Stuff, 23/06/20).

REL has also had a close working relationship with a company called ERP Group which was recently placed into liquidation after it was disclosed that it was also unlawfully storing huge amounts of waste at sites around Christchurch for the proposed Waimate incinerator (Stuff, 28/05/22).

SIRRL's resource consent application states that REL will be responsible for acquiring and freighting the waste to Project Kea. REL describes itself on the Project Kea website as "a New Zealand company that provides sustainable and tangible solutions for waste destined for landfill in NZ". But the truth is this company has no experience at delivering what it claims it does and, in fact, history suggests that these guys are not good waste management operators.

This is a high risk, very little gain proposal, with 60% of any profits leaving the country, with 100% of the risk falling on the local community and environment. Why should Waimate have to shoulder the burden of the South Island's waste to provide jobs for neighbouring districts and become known as "the rubbish burning town" in the process? We should all be taking responsibility for what we consume and the waste it creates. We need to make better choices and think about what happens to the item we are purchasing when it has reached the end of its intended purpose, or when we no longer have a need for it. Can it be repurposed, reused or recycled or will it contribute to the need for residual waste disposal?