This is 350 Aotearoa’s submission on the proposed Te Awamutu waste incineration plant.
You can read more about waste incineration here:
https://350.org.nz/why-is-waste-to-energy-incineration-a-bad-idea-for-aotearoa/
Background: 350 Aotearoa is the New Zealand arm of the international climate movement 350.org which aims to unite the world around climate change solutions. We coordinate local campaigns by providing education, practical tools, and support for community leadership. Our campaigns challenge the cultural acceptance of fossil fuels and encourage tangible change in New Zealand towards an equitable zero-carbon economy. You can find a recent blog post on waste-to energy here.
1. We oppose the introduction of a new methodology for waste disposal in Aotearoa that comes with significant potential for environmental harm. Waste to energy is not an appropriate fit for Aotearoa New Zealand. Recent research undertaken on the Aotearoa context clearly shows that for mixed municipal waste applications, waste to energy technologies have higher carbon emissions than disposing of these materials to landfill1.
2. The applicant notes that the infrastructure is intended to process combustible components of municipal solid waste and other waste – the feedstock identified as the most harmful in the above report. In places where waste to energy applications have been commonplace, such as the European Union, authorities are increasingly moving away from these as they realise that it is a carbon-intensive process that undermines genuine efforts to reduce emissions, and as their organic feedstocks deplete and they are forced to move towards unsuitable municipal feedstocks that increase emissions as compared to landfilling2.
3. To be clear: for all of the materials listed on page 18 of this application as being handled by this infrastructure (flock, end of life tyres, municipal solid waste and plastic), emissions are increased by handling these materials through incineration or waste-to-energy as compared to landfill.
4. We fundamentally disagree with the applicant’s assertion that waste to energy has the “potential to dramatically improve the waste management landscape” (pg 16). Aotearoa’s waste sector already reports high efficiencies in landfill gas capture, and both disposal tonnages and their associated emissions are trending downwards. This is accredited by the Ministry for the Environment to a range of regulatory changes made since 2004 for the management of greenhouse gas emissions from landfill, including:
- requiring municipal landfills to meet resource consent conditions under the Resource Management Act 1991
- requiring large municipal landfills to operate landfill gas capture systems (LFG) according to the National Environmental Standards for Air Quality (2004) under the Resource Management Act 1991
- providing direction and guidance to local governments and the waste sector through the New Zealand Waste Strategy and its revision in 2010
- developing the Solid Waste Analysis Protocol to set up a consistent waste classification system, sampling regimes and survey procedures for the estimation of solid waste composition
- implementing a waste disposal levy for waste sent to class 1-4 landfills and enabling regulations to establish product stewardship requirements under the Waste Minimisation Act 2008.
5. Introducing and entrenching a new, more harmful way of managing waste puts at risk the progress we are making towards our emissions targets in the waste sector. The waste sector plays a key role in the second emissions reduction plan, delivering up to 30 per cent of overall abatement above that achieved by the Emissions Trading Scheme.
6. The applicant notes that recyclable material will be delivered to the site for processing, including tyres (pg 18). This undermines the Governments’ recent announcement of a tyre product stewardship scheme, designed to keep the materials used to produce tyres in circulation and reduce the environmental impact of their disposal. Any materials that are able to be recycled should be – they should not be burnt for one time use as fuel, to never be beneficial again.
7. The applicant further notes that “non-recyclable materials” (including wood) will be loaded into enclosed waste bins within the site, and generally sent to landfill (pg 20). This, again, contradicts the Government’s commitment to divert organic materials away from landfill, including through increasing the availability of resource recovery infrastructure for these materials, such as those produced by construction and demolition3.
8. We find the conclusions of the applicant in relation to odour unfeasible. The applicant contends that raw material will be presorted to eliminate putrescible material and will have no odour. This, however, is not supported by recent experiences in Bromley, Christchurch, relating to odour from a local composting plant. An intensive odour survey undertaken by the city council showed that many of the respondents (34 percent) believed the smell that they were experiencing came from the waste transfer/refuse station or dump, as opposed to the local composting plant (28 percent). 38 percent of all residents in the study area identified a “compost” odour, but 30 percent identified the odour as “rubbish” more generally. This suggests that perceptible odours are still present to the human nose from standard rubbish services, not just those that handle putrescibles4.
9. Additionally, without additional information about how sorting will be undertaken to remove putrescibles, and with knowledge of high contamination rates in waste services across the country, it is difficult to believe that there will be “no significant odour that requires control” (page 31).
10. Te Awamutu is highlighted by the Waikato Regional Council as an area featuring a strong characteristic of employment and income deprivation – one of the overall most deprived areas in the Waikato region5. It is vital that high quality, resilient and long term jobs are the focus of economic development in such places. We can not continue to perpetuate the environmental injustices of introducing high-polluting, environmentally harmful practices and infrastructure into areas of deprivation in the alleged name of delivering jobs.
11. In 2019, the Ministry for the Environment identified that transforming our waste and resource recovery infrastructure would have a positive effect on the overall workforce, with studies showing that for every five jobs in landfilling (and thus transposed to other disposal methodologies, such as waste to energy), 15 – 20 jobs could be created in resource recovery6. Eunomia (for Waikato Regional Council) also highlight that job opportunities are more numerous in recycling and organic waste treatments than for disposal infrastructure7.
12. Claims of additional benefits of energy resilience (pg 36) rely on being assured that there is a consistent and ongoing feedstock source of waste for the facility to process. The international experience shows us that this is not the case – and that in many global applications, operators have been forced to resort to importing waste to keep their infrastructure operating.
13. This type of infrastructure relies on the continued production of waste – something that is out of step with this Government’s commitment to continuing to reduce waste. WasteMinz have noted that waste to energy applications do not generally have the capacity to downsize or delay production as waste is reduced through action further up the waste hierarchy – simply put, waste to energy entrenches a reliance on waste production8.
14. At 350 Aotearoa, we know that we need a fossil fuel free future, and that requires us to move away from a reliance on coal and natural gas for powering our country. This transition is already underway through projects such as Electrify New Zealand, and through more appropriate projects currently seeking consents such as wind farms, geothermal technology and large scale solar farms. Additionally, we note that anaerobic digestion applications of waste to energy, which handle only organic waste, are able to be used to produce energy (such as the EcoGas plant in Reporoa, which powers a co-located greenhouse for a produce company).
15. It is disingenuous and short sighted for the applicant to claim that waste to energy is a solution to help Aotearoa move away from coal and gas reliance. The World Energy Council (referenced by Zero Waste Network Aotearoa) have found that burning waste produces as little as ten percent of the energy of coal, and seven percent the energy of natural gas, while producing many times the pollution9. The Energy Justice Network estimates that CO2 is released by waste to energy incineration plants at a rate 1.65 times that of coal power plants10. In 2023, it was further estimated that the 57 incinerators in operation across the United Kingdom emitted more than seven million tonnes of fossil-based carbon dioxide in the previous year alone11.
16. The applicants insistence that greenhouse gas emissions impacts are to be considered separately to the Resource Management Act (pg 30) suggests that they, too, know the environmental damage they are proposing to impose on Aotearoa through the introduction of this infrastructure. It is vital that we do not open the floodgates to technology that has globally proven to be an emissions and waste reduction failure, and that will locally put at risk the successes of both the waste sector and the Government in reducing our emissions.
17. In conclusion, 350 Aotearoa strongly opposes this application in any form.