SIRRL Fast-Track Application.
Robust Process?
On May 1, 2024, South Island Resource Recovery Limited (SIRRL) submitted an application for fast-track approval. Although the name of the applicant has been redacted, it is understood that SIRRL director Kevin Robert Stratful submitted the application. Fast-Track Ministers Bishop and Jones said the following in an October 6, 2024 media release; “The projects have been selected through a thorough and robust process which included an open application process run by Ministry for the Environment, analysis by officials, an independent assessment and recommendations process by an independent Advisory Group, and final decisions by Cabinet.”
On December 16, 2024, the government released the applications of the 149 projects included on the fast-track list, finally providing an opportunity to assess the government’s benchmark.
Economics versus Environmental and Human Health Concerns.
The application appears to be heavily weighted toward economic justification for the plant, with a large part of it focused on SIRRL’s economic report that accompanied its resource consent applications to Waimate District Council and ECan in November 2022. At the same time, the application is influenced by the so-called economic benefits; environmental and human health concerns have been largely ignored, with very little information about these concerns.
No Waste Source Provided.
Although the application states that the plant intends to burn 365,000 tonnes of waste annually, it fails to state where it will be sourced. This is a critical piece of this proposal that is completely missing. Why is that?
SIRRL constantly tell us that “NZ is in the midst of a waste crisis” and that waste-to-energy is needed to address this problem. The company claims more than enough waste is available in the South Island of New Zealand to fuel this plant. However, SIRRL’s calculations have been contested by waste management companies and the Ministry for the Environment (MfE). If the availability of waste is in question, then so is the validity of this proposal.
Overseas waste-to-energy plants have been built to overcapacity, meaning that available waste levels are insufficient to fuel these plants. One such example is the Amager Bakke plant in Copenhagen. At the commissioning stage of the development, it was flagged that the proposed plant was much larger than required and that waste would likely need to be imported to fuel the plant and keep it economically viable. Subsequently, a much smaller model was recommended. However, ministerial interference resulted in the original size being approved with conditions put in place: the plant operators do not import waste to fuel the plant and do not burn biogenic material. These conditions were later removed so that the plant could remain economically viable. The plant now imports vast amounts of recyclable material from Europe to fuel the plant.
Energy Claims.
The applicant states in its application that this facility’s primary function is energy generation, with a projected output of 30MW. However, the company has previously stated that the plant’s primary function is waste disposal, with energy recovery as a secondary function. The applicant also states that the energy generated will be 63% renewable. The company’s resource consent applications show how they reached the 63% figure. MfE again showed this calculation to be incorrect. The company has disingenuously claimed non-combustibles such as glass, concrete, and rubble as renewable energy sources. They also claim vast amounts of recyclable and compostable material in their calculations, knowing that current and future waste minimisation policies and regulations will significantly reduce those materials from the waste stream. WWW has done some calculations showing that removing non-combustible and recyclable/compostable material would reduce that 63% down to around 23% and likely further as soft plastics become more recyclable.
Fanciful Greenwashing.
SIRRL’s application states it will supply external energy for dairy plants to offset their CO2 emissions, supply energy for aquaculture, provide food-grade CO2 conversion, heat glass houses, and export excess electricity to the national and local grid for electricity resilience. They also claim in their resource consent application that they will use excess electricity to produce hydrogen. Then, there are energy-intensive internal processes like the plasma furnace. Just who do they think they are kidding? They will not generate enough electricity to power Oceania dairy’s 30MW boiler, let alone anything else.
Cultural Impact Assessment.
The fast-track application requires the submitter to answer the following question: Has there been an assessment of any effects of the activity on the exercise of a protected customary right? The applicant responded: “Yes, an assessment of cultural impacts has been undertaken within the planning report attached to the resource consent application. No customary rights exist.”
SIRRL included a cultural impact assessment report (CIA) gleaned from a totally unrelated proposal by nearby dairy plant Oceania Dairy to discharge wastewater into the ocean as part of its resource consent application. Local and regional councils deemed the CIA unsatisfactory and requested that the company undertake a site-specific CIA.
Applicant Falsely claims Time Restraints Due to RMA.
The applicant, SIRRL, initially lodged their resource consent applications with Waimate District Council and Environment Canterbury to construct and operate a waste-to-energy plant near Waimate in 2022. However, this statement seems to contradict the following claim made by Stratful,
“In total, from the first lodgement of the resource consent applications to now, it has taken 3 years. It is likely to take a further 18 months for the Environment Court to hear and decide on the applications. Appeals to the High Court are then possible. The Fast Track process has the potential to create both project certainty and will reduce the resource consent process time by 18 months which currently sits with the Environment Court.”
The incorrect statement above has been provided to give the impression that the standard RMA processing is causing time delays with SIRRL’s application. However, this is untrue. Since lodging their 2nd resource consent in November 2022 and receiving RFIs by ECan and WDC a few months later, the authorities have been waiting for SIRRL to lodge a water take consent, a fundamental part of the overall resource consent. So, if time restraints are an issue, why has SIRRL not taken action for the last 2 years? They also publicly committed to Waimate in September 2021, stating they would lodge resource consents by the end of 2021. It didn’t happen for a further year. This clearly shows any time restraints for this project have been due to the applicant’s inability to deliver on deadlines, not RMA failings.
Application Riddled With Inconsistencies and Mistakes.
- The applicant’s job figures, a crucial aspect of its application, are marred by inconsistencies. It states, “Project Kea will employ 108 FTE, of which 43 roles are specialist positions in Waimate alone”. The subsequent section states, “Operation of the facility is estimated to support a total of 165 FTE jobs per year across Waimate, Timaru and Waitaki. Of the 165 jobs, 108 are estimated to be located in Waimate and 57 spread across Timaru and Waitaki.
- The application refers to SIRRL’s commissioned Air Quality report, which was completed by Andrew Curtis from PDP when it was, in fact, completed by PDP’s Tara Hutchins.
- The application states the plant will create 100,000 tonnes of bottom/grate ash and 20,000 tonnes of fly ash annually. However, the company’s resource consent applications provide figures of 80,000 plus 20,000 tonnes per annum.
- The applicant’s statement that “the energy generated by the plant bypasses the national grid, so any disruption to the national network will not affect the local market” Reveals a significant misunderstanding. This shows a poor understanding of how any electricity generated by the plant will be exported.
Applicant Makes False Declaration
Section 9 of the application asked the applicant to provide a summary of all compliance and/or enforcement actions taken against the applicant by any entity with enforcement powers under the Acts referred to in the Bill and the outcome of those actions. The applicant provides the following: “There have been no compliance and/or enforcement actions taken against the applicant by any entity with enforcement powers under the Acts referred to in the Bill”.
In 2019, Renew Energy Limited (REL), more on REL HERE, was served an abatement notice by Environment Canterbury (ECan) to remove illegally stored waste from a location in Canterbury. While REL eventually removed the bales from the site, another company working closely with REL called ERP Group, more on ERP HERE, continued baling waste and illegally storing it at several locations around Christchurch, again leading to ECan enforcement action. ERP eventually went into receivership, and the owner absconded the country, leaving his landlords with a $3 million clean-up bill. While SIRRL and REL managing director Paul Taylor claim ERP’s part had nothing to do with SIRRL, REL is the 40% NZ shareholder of SIRRL. REL has been working closely with ERP since illegally storing waste in 2019. Insolvency papers show that REL owned the baling plant ERP was using, with ERP owner Michael Corcoran claiming the waste being baled and stored was destined for a proposed SIRRL waste-to-energy plant in Waimate.
When ECan served ERP Group with abatement notices to remove the waste, Paul Taylor tried to secure a heads of agreement between ERP and Timaru District Council to transport and store the illegally stockpiled Christchurch waste to Redruth Landfill. This shows how closely ERP Group and Renew Energy were working together.
It is concerning that none of this information was disclosed in SIRRL’s fast-track application, despite Renew Energy’s 40% shareholding in SIRRL.
This failure to disclose important information about its track record shows the dishonest nature of this company and, once again, the government’s lack of due diligence regarding REL’s long and well-documented history of dishonest and illegal behaviour.
Conclusion
So, while we are being told that the process for fast-track inclusion was “Robust,” this application highlights just how low the government has set the bar. It would seem they are rather eager to accept any application, no matter how contradictory, misleading, or false. It is also clear that the proponents behind these proposals are not screened, nor are their declarations.
This project’s inclusion in the fast-track list brings into question the government’s credibility and its processes for screening applicants.