ASBG is concerned the EfW Regulation is far broader than it needs to be, capturing a wide variety of waste processes which it deems are Energy from Waste (EfW).
Of concern is that all fuels even containing small portion of waste derived fuel are captured. If captured there are two types of EfW processes: those generating electricity or heat for export, and those using the energy internally. The first is limited to only selected sites within NSW, The latter is not permitted if the site is replacing natural gas or LPG with a waste derived fuel.
Other concerns is the poor definitions under thermal treatment of:
- Waste derived fuel in terms of blended fuels, e.g. petroleum based with waste derived fuel. It seems a trace of waste in for example a diesel, would render the mix captured and subject to the EfW Reg. restrictions.
- Minimum operating temperatures are needed or even mechanical shredding etc. could be captured as these occur above ambient temperatures - a statement used by EPA in past. ASBG recommended at least 200oC and with higher temperatures for different process types.
- A minimum change in chemical composition e.g. >10% or higher which permits small changes in composition, such as browning reactions in wood, from being captured.
- Thermal treatment of biosolids is exempt, but does this mean sites using for energy extraction as an RDF are exempt from the EfW Regulation?
Advanced Recycling (Chemical processes turning waste plastic into hydrocarbon streams) is specifically captured and also required to remake 75% of its plastic inputs in to plastic. This requirement is fundamentally flawed as it will greatly limit Advanced Recycling in NSW. ASBG recommended that Advanced Recycling be preferably left out of the EfW Reg. altogether. If not then the focus should be on restricting it to generating at least 10% non-fuel hydrocarbons, giving it a reasonable chance of more plants being developed in NSW. If not then most plastic which could have been utilised in these processes would either end up being landfilled or burnt as RDF.
Lastly the requirement that RDF, PEF etc cannot replace natural gas or LPG seems to based on limiting Greenhouse Gas Emissions (GHG). However, if the RDF used contains a threshold amount of biomass which is renewable, this position will generate more GHGs not less. ASBG recommended adjusting the EfW to recognise the renewable content in the RDF being used and permit its use if there is a net GHG reduction over the current fuel it replaces.
 ASBG's Submission on the Draft Thermal Energy from Waste Regulation 2022 | 1117 kB |
