To: Chief Executives and Elected Members of Horizons Regional Council and Manawatu District Council
Feilding Against Incineration - Don’t Burn Our Future!
CBARA
We urge Horizons Regional Council to decline the discharge to air resource consent application lodged by Bio Plant Manawatū to build a waste-to-energy pyrolysis facility in Feilding, Aotearoa New Zealand.
Failing that, we urge the Manawatū District Council to call an urgent public forum on the issue fully disclosing the environmental, social, economic and cultural impacts.
We request that:
1. That the Horizons Regional Council publicly notify the discharge to air resource consent application lodged by Bio Plant Manawatū so that Feilding and the wider community have the opportunity for input. This is required under section 95A of the Resource Management Act 1991 as the adverse environmental effects are likely to be 'more than minor'.
2. Horizons Regional Council requires that the consenting process extends beyond emissions to air to also include discharge to land and water - because we know that toxicants will be produced in the processes being described by Bio Plant Manawatū and potentially released into our waterways and soils.
3. Horizons Regional Council identifies the lack of alignment of the resource consent application with their One plan policy, 3-8, 3-9 and 3-10 on waste management.
4. Manawatū District Council identifies the lack of alignment with their Waste Management and Minimisation Plan, and statutory responsibilities outlined in their Environmental Stocktake.
5. Horizons Regional Council and the Manawatū District Council obtain a public health expert assessment of the proposed pyrolysis plant before it is given consent to proceed.
Failing that, we urge the Manawatū District Council to call an urgent public forum on the issue fully disclosing the environmental, social, economic and cultural impacts.
We request that:
1. That the Horizons Regional Council publicly notify the discharge to air resource consent application lodged by Bio Plant Manawatū so that Feilding and the wider community have the opportunity for input. This is required under section 95A of the Resource Management Act 1991 as the adverse environmental effects are likely to be 'more than minor'.
2. Horizons Regional Council requires that the consenting process extends beyond emissions to air to also include discharge to land and water - because we know that toxicants will be produced in the processes being described by Bio Plant Manawatū and potentially released into our waterways and soils.
3. Horizons Regional Council identifies the lack of alignment of the resource consent application with their One plan policy, 3-8, 3-9 and 3-10 on waste management.
4. Manawatū District Council identifies the lack of alignment with their Waste Management and Minimisation Plan, and statutory responsibilities outlined in their Environmental Stocktake.
5. Horizons Regional Council and the Manawatū District Council obtain a public health expert assessment of the proposed pyrolysis plant before it is given consent to proceed.
Why is this important?
PYROLYSIS IS A FORM OF INCINERATION
The EU classifies pyrolysis as a type of incineration because it involves the thermal treatment or combustion of waste, and many of the resultant pollutants and emissions are all similar across the different waste-to-energy technologies. The EU's Directive on Industrial Emissions provides the following definition (Article 3 (40)):
“‘waste incineration plant’ means any stationary or mobile technical unit and equipment dedicated to the thermal treatment of waste, with or without recovery of the combustion heat generated, through the incineration by oxidation of waste as well as other thermal treatment processes, such as pyrolysis, gasification or plasma process, if the substances resulting from the treatment are subsequently incinerated.”
The Feilding pyrolysis facility fits within this definition.
INCINERATORS POLLUTE OUR AIR, LAND AND WATER
While it is true that today’s incinerators are cleaner than older models, they’re still not perfect. Modern incinerators still release toxic chemicals that include dioxins, mercury and cadmium – substances that cause cancer, nerve damage and birth defects. Anyone living downwind from an incinerator is in danger of breathing in these dangerous chemicals and suffering the health consequences, like respiratory issues [1].
Toxins in the form of dioxins and furans and other toxic chemicals formed by the process of pyrolysis can leach into soil and groundwater and accumulate in food chains.
Waste pyrolysis facilities produce outputs in the form of gas, oil, air emissions, liquid effluent and solid char that are all highly contaminated with toxic substances. All of these outputs require substantial treatment to be able to be used safely, and some components of the treatment facilities (e.g. filters, scrubbers) become extremely toxic and require disposal at special hazardous waste landfills. The oil produced from pyrolysis is particularly toxic when plastics are used as feedstocks and can contain bromine, zinc, calcium, chlorine, and sulphur making the oil produced by pyrolysis significantly more environmentally polluting than other engine fuel [2].
The Feilding pyrolysis plant will produce a by-product of 2.5 tonnes of solid ‘char’ per day. This extremely toxic material will need to be dumped in special hazardous waste landfills. It is in no way, shape or form the same as ‘bio-char’ which can be used as an agricultural soil amendment and it is highly misleading of Bio Plant to call this toxic by-product ‘bio-char’ [3].
Incinerator toxins falling back to land are regularly washed into waterways where they combine with leachate from hazardous waste landfills. These contaminants poison aquatic life as they flow through our streams and rivers into our harbours and eventually into our oceans. These toxins have the potential to enter our food chain at every stage of their journey to the sea.
Environmental impact
- Up to 70 tonnes of rubbish will be burnt in Feilding each day.
- Incinerators release greenhouse gases - for each tonne of waste burnt, up to 1.2 tonnes of CO2 is produced. While pyrolysis does not burn waste directly, it produces gas and liquid fuels which will be subsequently burnt and will release similar levels of CO2.
- It is claimed that the pyrolysis process will be ‘CO2 neutral’ and produce ‘renewable energy.’ This is completely false – the key ingredient will be plastics which are made from oil, a non-renewable resource. The synthetic gas and diesel that will be produced are also less efficient and more polluting than regular fossil fuels.
Effects on the Feilding community
- The health and well-being of residents - exposure to cancer-causing dioxins released into the air and potential odour nuisance.
- Manawatū District Council locked into a long term and expensive contract.
- Feilding is locked into producing rubbish to fulfil this contract instead of moving towards a sustainable circular economy and zero waste.
- Endangering the wider community by increasing impacts of climate change and taking Aotearoa New Zealand further away from the Climate Change targets it needs to achieve.
- Feilding could become a dumping ground for waste from other areas of NZ and possibly the Pacific.
- May adversely affect land-values of neighbouring properties.
- Employment - Bio Plant will employ very few people compared with ambitious zero waste programmes and initiatives such as reuse, repair, recycling and composting - which create as many as 200x more jobs than landfills and incinerators [4].
- Incinerators are being shut down around the world - Europe closed its last pyrolysis plant in Germany (Burgau plant) in 2015 due to climate and safety considerations [5]. Other plants are failing due to technical/engineering issues. In February two further plants in the UK alone closed due to technical failure.
- There is no facility like this anywhere in NZ (and very few overseas). This is brand new technology and any consenting needs to be extremely rigorous. Feilding does not wish to be a guinea pig for this unproven technology.
- We are very concerned that the proposed site for the Feilding pyrolysis facility is subject to a Treaty Claim. By failing to consult with Mana Whenua before offering this land to Bio Plant for a pyrolysis facility, Manawatū District Council are contradicting their goal of partnership with Mana Whenua.
Incinerators destroy the progress we have already made. While we accept that waste is a problem, we know that incinerators are not the answer. Here in Aotearoa New Zealand, we can address our waste issues in regenerative ways that preserve rather than destroy valuable resources, prevent pollution, produce sustainable and innovative products and material systems, create jobs, and invigorate a zero waste circular economy.
To help achieve this goal, we hope you will join us in opposing the Feilding pyrolysis facility proposal.
The EU classifies pyrolysis as a type of incineration because it involves the thermal treatment or combustion of waste, and many of the resultant pollutants and emissions are all similar across the different waste-to-energy technologies. The EU's Directive on Industrial Emissions provides the following definition (Article 3 (40)):
“‘waste incineration plant’ means any stationary or mobile technical unit and equipment dedicated to the thermal treatment of waste, with or without recovery of the combustion heat generated, through the incineration by oxidation of waste as well as other thermal treatment processes, such as pyrolysis, gasification or plasma process, if the substances resulting from the treatment are subsequently incinerated.”
The Feilding pyrolysis facility fits within this definition.
INCINERATORS POLLUTE OUR AIR, LAND AND WATER
While it is true that today’s incinerators are cleaner than older models, they’re still not perfect. Modern incinerators still release toxic chemicals that include dioxins, mercury and cadmium – substances that cause cancer, nerve damage and birth defects. Anyone living downwind from an incinerator is in danger of breathing in these dangerous chemicals and suffering the health consequences, like respiratory issues [1].
Toxins in the form of dioxins and furans and other toxic chemicals formed by the process of pyrolysis can leach into soil and groundwater and accumulate in food chains.
Waste pyrolysis facilities produce outputs in the form of gas, oil, air emissions, liquid effluent and solid char that are all highly contaminated with toxic substances. All of these outputs require substantial treatment to be able to be used safely, and some components of the treatment facilities (e.g. filters, scrubbers) become extremely toxic and require disposal at special hazardous waste landfills. The oil produced from pyrolysis is particularly toxic when plastics are used as feedstocks and can contain bromine, zinc, calcium, chlorine, and sulphur making the oil produced by pyrolysis significantly more environmentally polluting than other engine fuel [2].
The Feilding pyrolysis plant will produce a by-product of 2.5 tonnes of solid ‘char’ per day. This extremely toxic material will need to be dumped in special hazardous waste landfills. It is in no way, shape or form the same as ‘bio-char’ which can be used as an agricultural soil amendment and it is highly misleading of Bio Plant to call this toxic by-product ‘bio-char’ [3].
Incinerator toxins falling back to land are regularly washed into waterways where they combine with leachate from hazardous waste landfills. These contaminants poison aquatic life as they flow through our streams and rivers into our harbours and eventually into our oceans. These toxins have the potential to enter our food chain at every stage of their journey to the sea.
Environmental impact
- Up to 70 tonnes of rubbish will be burnt in Feilding each day.
- Incinerators release greenhouse gases - for each tonne of waste burnt, up to 1.2 tonnes of CO2 is produced. While pyrolysis does not burn waste directly, it produces gas and liquid fuels which will be subsequently burnt and will release similar levels of CO2.
- It is claimed that the pyrolysis process will be ‘CO2 neutral’ and produce ‘renewable energy.’ This is completely false – the key ingredient will be plastics which are made from oil, a non-renewable resource. The synthetic gas and diesel that will be produced are also less efficient and more polluting than regular fossil fuels.
Effects on the Feilding community
- The health and well-being of residents - exposure to cancer-causing dioxins released into the air and potential odour nuisance.
- Manawatū District Council locked into a long term and expensive contract.
- Feilding is locked into producing rubbish to fulfil this contract instead of moving towards a sustainable circular economy and zero waste.
- Endangering the wider community by increasing impacts of climate change and taking Aotearoa New Zealand further away from the Climate Change targets it needs to achieve.
- Feilding could become a dumping ground for waste from other areas of NZ and possibly the Pacific.
- May adversely affect land-values of neighbouring properties.
- Employment - Bio Plant will employ very few people compared with ambitious zero waste programmes and initiatives such as reuse, repair, recycling and composting - which create as many as 200x more jobs than landfills and incinerators [4].
- Incinerators are being shut down around the world - Europe closed its last pyrolysis plant in Germany (Burgau plant) in 2015 due to climate and safety considerations [5]. Other plants are failing due to technical/engineering issues. In February two further plants in the UK alone closed due to technical failure.
- There is no facility like this anywhere in NZ (and very few overseas). This is brand new technology and any consenting needs to be extremely rigorous. Feilding does not wish to be a guinea pig for this unproven technology.
- We are very concerned that the proposed site for the Feilding pyrolysis facility is subject to a Treaty Claim. By failing to consult with Mana Whenua before offering this land to Bio Plant for a pyrolysis facility, Manawatū District Council are contradicting their goal of partnership with Mana Whenua.
Incinerators destroy the progress we have already made. While we accept that waste is a problem, we know that incinerators are not the answer. Here in Aotearoa New Zealand, we can address our waste issues in regenerative ways that preserve rather than destroy valuable resources, prevent pollution, produce sustainable and innovative products and material systems, create jobs, and invigorate a zero waste circular economy.
To help achieve this goal, we hope you will join us in opposing the Feilding pyrolysis facility proposal.
How it will be delivered
References:
1. https://www.nrdc.org/experts/daniel-rosenberg/burned-why-waste-incineration-harmful
2. https://www.no-burn.org/wp-content/uploads/2022/01/PTF_A-losing-proposition_Jan-12-2022.pdf
3. Rollinson, A.N., Oladejo, M.S., 'Patented blunderings', awareness, and self-sustainability claims in the pyrolysis energy from waste sector.
