In September 2021, the NSW Environment Protection Authority (NSW EPA) released the Energy from Waste Infrastructure Plan alongside the Guide to the NSW Energy from Waste framework that complements both the NSW Waste and Sustainability Materials Strategy 2041 (the Waste Strategy) and the NSW Energy from Waste Policy Statement (Revised in June 2021).
The NSW EPA acknowledges that waste-to-energy (W2E, WtE or WfE) facilities are necessary where “they deliver positive outcomes for the community and the environment”. The regulator highlighted that the strategy is valued when it is used to manage residual waste and “not as an alternative to waste reduction or recycling”.
The Infrastructure Plan establishes regions where energy from waste facilities are expected to “best address the state’s waste management needs until 2041, and where it maximises efficiencies for waste innovation, management and energy recovery”.
What is residual waste and why is it important?
Residual waste is waste that is not viable for reuse, separation, recycling or reprocessing due to practical or economic reasons. Residual waste may only be ‘recovered’ by means of combustion and advanced thermal technology such as the ones employed at some energy from waste plants.
Where waste-to-energy facilities or other alternatives disposal options are not readily available it is highly likely that residual waste will make it to landfills. Diversion of residual waste from landfill is critical but only if it is to a use with a lesser environmental impact.
Waste-to-Energy facilities and their impacts on the community
We have previously covered the Pros and Cons of Air Quality of Waste-to-Energy. WtE can be preferable to disposal of waste in a landfill. WtE provides the ability to:
• reduce carbon emissions that may be otherwise produced by other modes of disposal, and
• to generate electricity.
The potential impact of WtE on air quality can be minimised through implementation of best practice design and emissions control, siting and diligent management and operation.
Zoning and Waste-to-Energy
The main changes in the Energy from Waste Infrastructure Plan 2041 are related to the location of the new facilities in specified regions including Special Activation Precincts (SAPs).
We have previously addressed the benefits of strategic planning by means of implementing zones or regions for specific industrial purposes. By carefully identifying areas for industrial uses taking into account key factors such as climate, meteorology, terrain and land-use as well as infrastructure and economic considerations, long-term planning conflicts can be avoided. Once identified, industrial zones can be subjected to coordinated development that takes into account the cumulative effects of industry on air quality and allows for efficient and shared use of infrastructure (e.g., a shared air quality monitoring network and airshed model). Zoning can also prevent encroachment by establishing a buffer zone between industrial emitters and sensitive land-uses. In some circumstances, the buffer zone can accommodate insensitive land-uses.
There are likely to be many issues that need to be considered before a site or zone is determined to be suitable for WtE from an air quality perspective:
- The availability of waste that is suitable for WtE and potential contaminants within that waste
- The proximity of sensitive receptors and populated areas within the region
- Risks of encroachment of sensitive uses
- Depending on waste constituents, the best practice emission controls that will be necessary to mitigate emissions and residual risks to air quality
- Emission controls to minimise odorous releases
- The capacity and lifespan of landfills where waste will be generated
- The need or otherwise to transport waste from metropolitan areas to regional areas for them to processed
- Greenhouse gases generated by the facility and potential reductions relative to business as usual
- Community perception of air quality risks and issues of equity – a common concern is that a region is being used as a dumping ground for someone else’s waste.
What can we expect after the publication of the NSW Energy from Waste Infrastructure Plan
First, we expect a more streamlined process for evaluation of applications for new waste from energy facilities within the pre-established regions. The Guide to the NSW Energy from Waste Framework establishes technical requirements relating to air emissions, human health risk assessment, waste feedstock, plant technology, waste treatment and disposal, amongst others.
Energy from Waste Infrastructure Plan sets out the following Energy from Waste Priority Infrastructure Areas:
- West Lithgow Precinct
- Parkes Special Activation Precinct
- Richmond Valley Regional Jobs Precinct
- Southern Goulburn Mulwaree Precinct.
There are exceptions where WtE might still be allowed to operate in NSW outside of these regions should they comply with planning and environmental legislation and policies. Facilities thermally treating preestablished lower risk eligible waste fuels including biomass and residues are excluded from the location limitations.
Second, it is unclear how the proposals currently known to the NSW Government will be dealt with. The Guide to the NSW Energy from Waste Framework establishes seven stages for the evaluation of a Major Project in NSW and it is yet to be seen what will transpire in terms of projects that had not reached the final determination stage.
We expect that WtE projects that are approved will have strict licence conditions including emission limits for a large suite of air pollutants, continuous and periodic emissions monitoring and detailed data collection and reporting requirements. You can read more about monitoring as part of licence conditions here.
How can Katestone help?
Katestone has had extensive experience in the air quality impact assessment and management of odours associated with waste-to-energy facilities. Our team has assisted clients at every stage of the process including the feasibility and preliminary design phase through approvals to operations.
Our highly experienced air quality and odour impact assessments and odour management plans help clients implement state-of-the-art emission control strategies. Katestone has extensive experience in dealing with air quality issues for industrial emitters within Australia and overseas. In particular, we have been involved with issues such as site suitability and selection studies, air quality, odour and health risk assessments of waste to energy facilities, tall stack dispersion, stochastic emissions for coal fired plants, aircraft safety and vertical plume velocities and the interactions of various types of cooling towers both in producing aerodynamic changes, and the consequences for stack plume performance.
Katestone has also assisted a growing number of clients from a range of industries with amendments to licence conditions through analysis of monitoring data, review of manufacturer’s specifications and literature review of Australian and international emission regulations.