It’s time everyone. We need you to make your voices heard. Make a submission to stop the Te Awamutu Incinerator.

 

WHAT TO DO:

• Read through the details and write down your key points

• When you are ready go to the Submission page* (see below for form guidance)

• Ensure you make your submission by Wednesday, 18 December at 5.00 pm.

 

KEY ISSUES TO RAISE IN YOUR SUBMISSION

We strongly encourage you to read more about the proposal and to make comments that reflect your own views. Here is some guidance on key issues.

• Climate and energy:

• • New Zealand’s obligations to the global environment will be impacted by the estimated greenhouse gas (GHG) emissions from the proposed incinerator. The Ministry for the Environment’s initial view is that the estimated GHG emissions for the proposal are between 145 kt and 165 kt p/a of CO2, and that this is significant at a national and international level. (see the EPA advice to the Minister, pp6-7)
  • The feedstock of this facility is primarily plastics and other fossil fuel-based products. It is not renewable energy.
  • Along with the feedstock this incinerator would use millions of litres of diesel every year to “co-fire” the plant to keep it hot enough.
  • It would be more energy efficient, and less polluting (as a result of the chlorine-based additives in many plastics), to directly burn the fossil fossils for energy. “Waste-to-energy” is just an industry term to hide what this incinerator really is: burning toxic rubbish in a residential neighbourhood.
  • Current emissions from waste are also entirely the methane from biograding organic materials in landfill. Across the country there are extensive policy and programme solutions to address organic waste to landfill now underway. Waste is somewhere we can eliminate emissions altogether, but not if we build incinerators.

 

• Air, land and water contamination

• • The incinerator would burn 166,525 tonnes of waste a year equalling 456 tonnes a day emitting ultra fine particles into the air – PM10 and PM2.5 – which are major sources of air pollution.

• • The incinerator would burn 3 million tyres plus mixed plastics, household rubbish and “flock” (the leftovers from scrap metal process including metals, foam, rubber and plastics) emitting dioxins and furans, sulphur dioxide, carbon monoxide, mercury, nitrogen dioxide and hydrogen chloride in an area immediately next to houses, schools, medical facilities and food businesses.
  • The incinerator would create 23 tonnes of toxic ash per day. This consists of 21 tonnes of bottom ash and  2 tonnes of fly ash, both of which are highly toxic, laden with heavy metals and dioxins, and require landfilling, potentially in a hazardous waste landfill.
  • Overseas, waste incinerators have contaminated land and water downwind for many kilometres. In France, health authorities have issued warnings to millions of residents not to eat eggs from domestic coops in the Île de France region due to high levels of contamination “by persistent organic pollutants [POPs]” such as dioxins, furans, polychlorinated biphenyls and per- and polyfluoroalkyl substances (known as PFAS or forever chemicals). Tests by the ToxicoWatch Foundation in 2022 found very high levels of dioxins in domestic backyard chicken coops near the largest waste incinerator in Europe, located in Paris. Authorities have now carried out their own research in 25 farms and confirmed their initial warning. Similar findings of contaminated land have been recorded in China where waste incinerators are common.
  • The incinerator would use large quantities of water, producing 200kg/hr of contaminated ash treatment water which would be sent to landfill, and 2.65t/hr of general waste water. Some water would be discharged into the Mangapiko Stream, further threatening the health of the stream and the Waikato River of which it is a tributary.

• Human health impacts

  • Dioxins are released by the incinerator everyday. These are highly toxic and cause serious health problems, including infertility, learning disabilities, endometriosis, sexual reproductive disorders, birth defects, damage to the immune system and cancer. In fact, according to the World Health Organization, the most toxic forms of dioxin are considered to be the most carcinogenic (cancer causing) substances known to science. Even a very tiny quantity of dioxins can be dangerous. There is no safe level of dioxin exposure.
  • Persistent noise, odour and dust from the burning of tyres and plastic waste.

• • Thousands of tonnes of PM10 & PM2.5 released into the air. PM refers to “Particulate Matter” and the number refers to the size of the particle, with 10 being 10 microns, and 2.5 being 2.5 micros. As it is very small PM2.5 is particularly dangerous because it can reach deep into the alveoli of the lung. At risk are elderly, children, those with respiratory, cardio-pulmonary, bronchitis, asthma and other lung and heart conditions.

 

• Likelihood of Fire, Flooding & Explosion

• • The proposed incinerator site is subject to ‘severe flooding risk’ and proposed earthworks could make flooding of the surrounding houses significantly worse.
  • The Insurance Council of NZ has strongly urged the government to stop allowing building on floodplains due to the inevitable flooding brought on by climate change (“Building in flood-prone locations needs to stop, insurer IAG says”, published August 17, 2022).

• • In 2023, a massive fire exploded at a waste incinerator in Doral, Florida (just outside Miami) and burned for 2 weeks because firefighters could not get it under control. The facility burned to the ground, severely contaminating the entire surrounding community. Te Awamutu is served by a volunteer fire department, and the region does not have the capacity to address a significant fire or explosion. 

• Waste minimisation

• • The goal of New Zealand’s national waste strategy looks for ways to recover value from waste without increasing emissions. This proposal does not fit with this waste strategy.
  • Incinerators ‘lock in’ the production of waste because the capital costs are so high, and the requirements for waste ‘feedstock’ are constant that they must maintain supply, often locking-in local councils into waste contracts that are directly contrary to waste minimisation goals.
  • Several studies have shown that overseas waste-to-energy incinerators burn mostly recyclable or compostable waste. In New Zealand, council analyses of the average household rubbish bag repeatedly reveal that most of what we throw out is recyclable or compostable. Incinerating materials that can be recycled or composted violates the waste hierarchy, is energy inefficient, and represents a loss of resources and a massive opportunity-cost.

READ MORE

• You can read full details of the application on the Environmental Protection Agency website.
• In particular, we recommend reading the EPA advice to the Minister which outlines why the application was called in under the RMA to a Board of Inquiry.
• Read our website
  • About waste incineration including fact sheets and links to articles
  • About the Te Awamutu project and history specifically

 

NOTES ON THE ONLINE SUBMISSION FORM:

*This submission form has several key questions at the start:

1. My position is: Choose “I oppose the applications (or specific parts)”
2. I seek the following decision from the Board of Inquiry: Choose “Decline the applications”
3. Do you wish to be heard in support of your submission? If you want to give an oral submission then tick “yes”. This usually can be done remotely. You can change your mind later if you decide not to give an oral submission.
4. Trade Competition: Choose “I would not gain an advantage in trade competition through this submission”