How LINZ/OIO Approved the SIRRL Waste-to-Energy Proposal – And Why It Raises Serious National-Interest Concerns
Overview
This page summarises the key findings of the Independent Review of the SIRRL Overseas Investment Consent, drawing exclusively on evidence contained within:
- SIRRL Independent Review Report (2025)
- Associated supporting documents provided under the Official Information Act (financial, technical, ministerial briefing, and agency correspondence released to the public).
It outlines how SIRRL’s waste-to-energy (WtE) proposal was assessed and approved under the Overseas Investment Act 2005—and why the approval process raises significant concerns for national-interest protection, environmental integrity, and public confidence in the Overseas Investment regime.
What Is SIRRL and “Project Kea”?
South Island Resource Recovery Limited (SIRRL) was formed in 2021 to develop a large-scale, foreign-owned waste-to-energy incinerator in the Waimate District. According to the documents:
SIRRL_Independent_Review_Report
- The plant would process 365,000 tonnes of waste per year,
- Cost approximately $350 million,
- Require $108 million of the $350 million total for imported plant and equipment components
- Be majority foreign-owned (CNTY + EUZY = 60%),
- Generate around 30 MW of electricity,
- Produce 110,000 tonnes of residual ash every year,
- Attempt to recover 160,000 tonnes of aggregate (a physically impossible figure discussed later).
Repeated WtE Attempts Across NZ
The same promoters previously attempted WtE plants in Hokitika, Westport, and Waimate, each abandoned after technical, financial, or regulatory barriers were exposed.
Despite this track record, SIRRL gained unusually elevated access to New Zealand’s investment and infrastructure pathways, including:
- OIO call-in as a National Interest case,
- Placement into Fast-Track Approvals processes,
- Public ministerial engagement.
How the OIO Consent Was Processed
Lodgement and Acceptance Issues
SIRRL lodged its application on 13 April 2023, but LINZ did not accept it for processing until 5 May 2023.
A 22-day non-acceptance period typically indicates missing or non-compliant information. The Review shows the initial lodgement did not include the “significant business assets” component, despite foreign ownership and capital expenditure clearly triggering it.
A neutral regulator would normally require a complete application before formal submission, yet the evidence suggests LINZ facilitated post-lodgement repair, effectively coaching SIRRL.
National Interest Call-In
LINZ escalated the case under section 208 of the Overseas Investment Act, recognising:
- The scale of foreign ownership,
- The strategic nature of waste infrastructure,
- Potential negative effects on competition and regional resilience,
- Significant environmental and climate considerations.
The Two Key LINZ Reports – And Their Contradictions
Two internal reports were produced for ministerial decision-making:
National Interest Report (NIR) – Cautious, Risk-Focused
The NIR highlights serious risks, including:
- Potential closure of major South Island landfills (“some or all”),
- Reduced competition and system resilience,
- Increased national dependence on a single foreign-owned facility,
- Risk of future Crown exposure if the project fails,
- Misalignment with NZ’s waste-minimisation policies and circular-economy strategy
Recommendation Report (RR) – Benefit-Focused
Final ministerial advice largely accepted SIRRL’s benefit claims, stating the “Benefit to New Zealand Test is met” while downplaying or omitting several serious concerns documented in the NIR.
The Independent Review notes that ministers were effectively provided two conflicting conclusions produced simultaneously by the same agency.
Key Findings of the Independent Review
Capital Expenditure – “Benefits” Built on Unchecked Assumptions
LINZ accepted SIRRL’s projected $242 million domestic spend, despite:
- The project being entirely dependent on CNTY capital,
- CNTY’s high global debt exposure,
- Banks unwilling to finance WtE without sovereign guarantees,
- No independent financial due diligence being carried out.
The NIR acknowledges risks of landfill closures, market destabilisation, and potential bailouts, yet these negative economic impacts were never quantified or compared against the claimed expenditure benefits.
Job Creation – Claimed Gains, Ignored Losses
SIRRL supplied multiple contradictory job figures (76, 90, 100, 108 FTE). LINZ adopted “around 100” for benefit calculation.
Evidence instead shows:
- The three main South Island landfills employ around ~110 workers,
- NIR states SIRRL may cause closure of “some or all” of these facilities,
- Recycling is far more labour-intensive than incineration, resulting in more jobs
- Therefore, net job losses—not gains—should have been expected.
Any realistic analysis would have shown regional job displacement outweighing any gains at the incinerator site.
Technology and Environmental Alignment – Ministry Concerns Ignored
MfE’s formal technical advice (cited in the documents) states that municipal solid waste incineration:
- Likely to have negative climate impacts,
- Is misaligned with circular-economy goals,
- Requires continuous waste generation (a “lock-in effect”),
- Produces toxic ash unsuitable for agricultural reuse,
- Lacks an established regulatory emissions framework in NZ.
Despite MfE stating that “current government policy does not support technology reliant on the production of waste”, LINZ still treated the introduction of WtE incineration technology as a positive national “benefit”.
Productivity Claims – Several Are Physically Impossible
The Review identifies several critically flawed or impossible claims accepted by LINZ:
4.4.1 Aggregate Recovery
SIRRL claims 160,000 tonnes of aggregate recovered from 110,000 tonnes of ash—a clear physical impossibility.
4.4.2 Metal Recovery
Metal-recovery figures exceeded resource-consent documentation by ~45%.
4.4.3 Energy Output
The plant’s claimed 30 MW net electricity generation is inconsistent with turbine specifications, steam parasitic loads, and international WtE performance norms.
4.4.4 Diesel Supplementation
Independent engineering review notes the plant would require significant diesel supplementation to maintain temperatures—not addressed in SIRRL’s economic or emissions modelling.
LINZ accepted all productivity claims at face value.
Exclusion of Key Agencies – Especially MBI
MfE’s advice recommended MBIE involvement, given the proposal’s significant:
- Energy-sector impacts,
- Grid-integration issues,
- Employment claims,
- Economic implications.
OIA responses show no evidence MBIE was ever consulted.
This omission removes an essential economic and energy-sector check required for a credible national-interest assessment.
Transparency Problems – Why Important Information Never Reached the Public
LINZ released only the Recommendation Report publicly.
The more cautious National Interest Report was not made available, despite:
- Already being released under OIA,
- Containing critical information about risks,
- Containing nothing that could not be lawfully redacted and published.
This selective publication created an information imbalance, giving SIRRL’s narrative visibility while keeping LINZ’s internal cautions effectively hidden.
Why This Case Matters Nationally
The SIRRL decision raises broader national-interest and governance concerns:
- Unchecked benefits can pass as evidence, even when inconsistent or impossible.
- Negative impacts (job losses, landfill closures, competition effects) can be overlooked.
- Expert ministry advice can be sidelined without explanation.
- Foreign ownership of critical waste infrastructure can be approved without complete scrutiny of operational history or financial resilience.
- Key reports can remain unpublished, limiting public oversight.
- Large, high-risk infrastructure projects can be advanced despite poor alignment with NZ waste policy.
The case exposes weaknesses within NZ’s Overseas Investment decision framework—especially regarding complex infrastructure, environmental impacts, and foreign control of essential services.
Conclusion
Based solely on the publicly available documents:
- SIRRL’s WtE proposal contains major technical, financial and environmental inconsistencies.
- LINZ adopted SIRRL’s benefit claims without independently verifying basic calculations.
- Risks identified by government agencies were not properly integrated into the final ministerial advice.
- Critical information (the NIR) was not published alongside the supportive Recommendation Report.
- The final consent appears to have been granted on an imbalanced and incomplete evidential foundation