Lynn submitted an appeal to the Public Environmental Review of the East Rockingham Waste to Energy Facility. The text and attached appeal below outline continuing concerns with the project. The seven issues identified and recommendations made incorporate concerns heard from the community.
Office of the Appeals Convenor
Level 22 Forrest Centre
221 St George's Terrace
PERTH WA 6000
via email email@example.com
PER APPEAL: NEW ENERGY EAST ROCKINGHAM WASTE TO ENERGY FACILITY
Dear Ms Faulkner
A number of constituents and stakeholders have communicated their ongoing concerns to my office with regard to the New Energy (NE) Waste to Energy (WTE) Facility proposed for construction in East Rockingham and recommended for approval by EPA. I submit an appeal against the EPA’s recommendation and recommend that approval not be granted for reasons outlined below.
1. In the EPA PER document, NE states that:
“The gasifiers installed by Entech have typically dealt with difficult to treat wastes such as clinical or bio-hazardous materials. These waste streams are often very heterogeneous in terms of physical, chemical and calorific composition. Despite this, the Entech gasifiers have a history of successful operational compliance with design standards. As a consequence, New Energy has a high degree of confidence that the East Rockingham facility will operate reliably and efficiently given that the waste received at the site will be sorted and processed to produce a more uniform product.”
I am of the view that the above statement does not justify New Energy’s ‘high degree of confidence’ given the lack of accompanying data with regards to Perth’s specific waste stream. It is unclear as to whether New Energy has commissioned a specific study of Perth’s municipal waste stream.
2. On page 25 of NE’s response to PER submissions the proponent states that:
“The proposed plant site has never been used for nickel production or other industrial activities. As a consequence, no contaminated sites investigation is proposed.”
In other areas of NE’s PER response the company cites ‘background’ emissions and contamination levels from adjacent industry as being primarily responsible for environmentally adverse data and as having an impact on future contamination data. Given the proximity of several sources of significant industrial air and ground contamination to the proposed site, the EPA’s precautionary principle would appear to stipulate that even a greenfields site be thoroughly assessed prior to use.
Recommendation: that the EPA require New Energy to conduct a contaminated sites investigation of the proposed WTE site and reassess environmental approval in the event of adverse findings.
3. On page 27 of NE’s response to PER submissions the proponent states that:
“The largest gasifier vessel constructed by Entech is a 14 MWt plant. The current plant scales the gasifier vessels up by only 28.6%. The increase in throughput is then achieved by using 4 gasifier modules in parallel to achieve a combined capacity of 72 MWt. New Energy is confident that this approach to scaling of the facility can be achieved efficiently and effectively.”
In effect, the State has embraced as a waste solution an untested gasification model of unprecedented size. NE’s projected emissions, noise, and shutdown safety data, although stated to be conservatively modelled, is therefore only theoretical in nature. As the proposed plant sits within 2.5km of a residential area this set of ‘unknowns’ is extremely troubling to many residents and to myself.
Recommendation: That the proposal be rejected due to the plant’s untested nature and potentially hazardous proximity to residential areas should the proponents’ modelling prove inaccurate.
4. “The New Energy proposal has been developed in response to the lack of a solution (other than landfill) for handling residual wastes produced by existing waste treatment plants in Perth. The operators of existing waste treatment facilities (including Instant Waste Management Pty Ltd, Southern Metropolitan Regional Council and other Metropolitan Regional Councils have stated publicly that they are seeking a solution for the high calorific value residual waste streams that are currently landfilled because no viable option exists for recycling them. Whilst the Zero Waste Model is a desirable goal, it is simply not practical to implement now or in the foreseeable future. Operators in the waste management industry in Western Australia are of the view that WtE will be an essential part of reducing the State’s reliance on landfill as the primary means of waste disposal.”
In other words, there is zero commitment to Zero Waste from New Energy. This is a failure of waste policy at a wider level and perhaps outside the scope of this Review’s terms of reference, however I would note that metropolitan areas larger than Perth, such as the City of San Francisco, are working towards Zero Waste with great success and without recourse to gasification or incineration.
New Energy’s stated attitude to Zero Waste is out of step with best practice in waste management and suggests a company motivated primarily by waste-for-profit rather than any real commitment to eliminating waste. If granted responsibility for such a large proportion of the Perth MWS, the city is effectively locked into an anachronistic, energy-intensive, and harmful model of waste management for 25 years. The strategic impact of approving the WTE facility in the face of practical and sustainable non-gasification alternatives should be taken into account in the final approvals process.
Recommendation: That the long-term strategic waste management impact of WTE be rigorously assessed in comparison to proven alternative models of waste management as part of the EPA’s final approvals process.
5. On page 30-31 of the PER document, NE clarifies a prior statement indicating The Hon. Roger Cook MLA’s support for the project (following an objection by Mr Cook as included in the document). However, NE’s response to another submitter’s comment on this matter (p26) continues to imply Mr Cook’s support for the project. It is troubling that NE continues to attempt to portray Mr Cook’s quite unequivocal concerns with regards to the project, in an overly positive if not outright deceptive manner.
6. There is an ongoing lack of acknowledgement of potential cumulative impact with Phoenix Energy’s proposed incinerator, although NE does state that plume crossover would be ‘unlikely’ under normal wind patterns. The failure to assess cumulative impacts from industrial proposals is an ongoing one on the part of State regulators.
Recommendation: That the EPA conduct an assessment of likely cumulative emissions from the NE and Phoenix Energy facilities and take this into account in their final assessment.
7. On page 66 of NE’s response to PER submissions the proponent states that:
“Diesel use and emissions have not been specifically considered as the transport of waste would occur whether the waste was going to the proposed facility or a landfill site. There is no reference to diesel emissions on page 44 of the PER. As mentioned previously, NEC did not assess the CO2 contribution from transport of waste as transport would be required if the waste was directed to landfill, as is currently the case. It is arguable that there will be a net saving in transport emission as landfills are becoming more remote from the Perth CBD.” P 66
This is in response to a submission regarding diesel particulates, not CO2/e emissions. Particulate issues are not addressed. However, it is noted that the projected increase in road traffic is minor (0.38%).
Recommendation: That NE be required to address the issue of diesel particulate contamination and undertake modelling to assess its potential onsite impact.
Hon Lynn MacLaren MLC
Member for South Metropolitan Region
1 July 2014