BIOENERGY AUSTRALIA SUBMISSION

Energy from Waste policy for Queensland

August 2019

The purpose of this submission from Bioenergy Australia is to support the role of Energy from Waste (EfW) in the transition to a circular economy in Queensland. About Bioenergy Australia

Bioenergy Australia is the National Industry association, committed to accelerating Australia’s bio economy.

Our mission is to foster the bioenergy sector to generate jobs, secure investment, maximise the value of local resources, minimise waste and environmental impact, and develop and promote national bioenergy expertise into international markets.

Bioenergy Australia’s objectives are to:

Advocate - With our members, we anticipate and develop leading positions on issues of concern to the advancement and growth of bioenergy in Australia.

Campaign - We raise the profile of the industry within the media and broader community to achieve a greater level of understanding about bioenergy and the vital role it must play to achieve carbon neutrality by 2050.

Inform - We publish reports, webinars and articles to help our members keep ahead of industry trends and opportunities. We also manage the Biomass Producer website, an AgriFutures Australia resource showcasing Australian bioenergy projects, expertise, and identifying opportunities for primary producers.

Connect - We facilitate knowledge exchange and networking for members through task-specific meetings, our Annual Conference, and Webinars. We link investors with emerging businesses; researchers with technology developers; government with innovators. We also administer Australia's participation in IEA Bioenergy. Our Industry groups bring together specialists in specific fields.

Contact: Bioenergy Australia (Forum) Pty Ltd

ABN 14 155 856 821 Renewables Innovation Hub

19/23 Moore street, Turner ACT 2612 Phone: 0439 555 764

Email: shahana@bioenergyaustralia.org.au

Why EfW?

As mentioned in the discussion paper, EfW technologies are an attractive option to treat non-recyclable waste streams not only due to the challenges associated with landfill availability and related greenhouse gas emissions, but also their potential contribution to sustainable baseload power generation, heat recovery, metals and aggregates recycling, as well as regional development and jobs.

The conversion of waste streams into energy delivers economic benefit to resources that would generally be considered as end‑of‑life products and promotes a circular economy approach to using the available resources for their highest order use, in accordance with the waste hierarchy.

The potential utilization of a broad range of waste streams provides the opportunity to create new industries. For instance, technologies are constantly under development to optimise the conversion of waste into fuels. Similarly, there are a range of technologies that can be employed to form bioproducts. Chemicals such as ethanol and butanol can be produced through fermentation processes, while other common chemicals such as ammonia and methanol can be produced through higher temperature processes including gasification.

EfW technologies

As highlighted in Table 2, the scope of the term Energy from Waste is broad, encompassing a range of thermal, biological and chemical processes. These include mature technologies, including combustion for heat and power, anaerobic digestion to generate biogas, and emerging technologies, such as those based on conversion of mixed sugars derived from waste into biofuels, fast pyrolysis, hydrothermal liquefaction (HTL) and gasification. These technologies allow waste to be converted to other energy products, such as gas or liquid fuels, waxes, residual products such as bitumen, feedstocks to make new chemicals and plastics, and hydrogen (which is rapidly emerging as an energy vector in power, transport, and industrial sectors).

As part of the Energy from Waste technologies included in Table 2, Bioenergy Australia invites the Queensland Government to consider the following recommendations regarding Energy from Waste options.

Biological technologies

The potential of biodegradable waste coupled with anaerobic digestion processing in a biogas plant is seen in Milan. Since 2014, the city has almost reached 100% collection of food and organic waste, providing an average of 120 000 tonnes of biodegradable waste per year. At full capacity (12.8 MW thermal), the city biogas plant should produce some 35 880 MWh of electricity a year, enough to supply 24 000 people, and yield 14 400 tonnes of fertiliser1.

Biogas upgrading increases the flexibility of anaerobic digestion applications. Biomethane (biogas with the CO2 and other impurities removed) can be injected into the gas grid to provide a source of ‘renewable natural gas’. Furthermore, biogas can be further processed to produce renewable hydrogen, which is expected to increase in demand as a means of decarbonising power, transport, and industrial sectors.

Anaerobic digestion is also mature in Australia, albeit not as widely used as in European countries like Germany.

Since Solid Fuel Production should technically fall under a separate category (Mechanical technologies), we suggest the heading for this section to be changed to “Mechanical/biological technologies”.

Bioenergy Australia suggests the inclusion of Microbial Fuel Cell: oxidation of biodegradable organic matter in the presence of either bacteria or enzyme (output: power).

Chemical technologies

Bioenergy Australia recommends the inclusion of the following technologies:

Esterification: reaction of a triglyceride (fat/oil) with alcohol in the presence of a catalyst (output: biodiesel).

Hydrodeoxygenation (hydrogenolysis): reaction of a triglyceride (fat/oil) with hydrogen in the presence of a catalyst (output: renewable diesel).

Hydrothermal liquefaction (HTL) is also able to chemically recycle plastics back to the feedstocks from which they came, enabling the production of new plastics from the light fraction of the hydro carbons in the “Plasticrude” produced.

1 https://ec.europa.eu/environment/waste/waste-to-energy.pdf (p8)

Thermal technologies

- List of Residues of Advanced thermal treatment should include “bottom ash/slag” as gasification systems produce bottom ash as residues (some gasification technologies produce a glassy slag).

- Level of maturity of advanced thermal treatment is acknowledged to be maturing as some advanced thermal treatment systems are mature and some are still in the developing/commercialising stages, i.e. whole tyre pyrolysis plants, plasma assisted gasification.

Role of EfW in the waste hierarchy

Q1. Do you agree that energy should be extracted from residual waste materials rather than disposing of those materials to landfill, if there are no other available alternatives for reusing or recycling the waste materials?

Yes, we completely agree. Once the point is reached where no more recyclable materials can be economically or environmentally sustainably extracted from residual waste, Bioenergy Australia supports EfW as a preferable solution to landfilling for this residual waste.

Consideration should be given to defining the term “residual waste” in this context, as recently addressed by the WA EPA.2 This is discussed further in our response to Q4.

Risk based EfW Framework

Principle 1: A risk- based approach will be used to guide and manage the development of EfW infrastructure.

Three-pathway risk-based approach that safeguards human and environmental health, whilst creating opportunities for greater resource recovery and innovation.

Pathway 1: Technologies established and operating in Queensland

Pathway 1 recognises established EfW technologies currently operating in Queensland with known risks. It supports efficient approvals and regulation under existing processes to maximise the environmental, economic and social benefits which these technologies can generate for Queensland. The Queensland EfW policy will highlight the role that these technologies play within the state’s broader resource recovery agenda without creating additional regulatory burden or barriers to project development.

2 WA Environmental Protection Authority, Ministerial Statement https://www.epa.wa.gov.au/sites/default/files/EPA_Report/Report%20and%20Recommendations%20-%20WTE%20Residual%20Waste%20-%2017%20October%202018_0.pdf accessed 22 August 2019

Pathway 2: Operationally viable and mature technologies

Pathway 2 will help Queensland take advantage of mature EfW technologies that have been proven in other jurisdictions. Mature technology refers to technology with a proven track record that can reliably and commercially operate on given waste feedstocks. This pathway will give regulators and communities confidence that technologies which are new to Queensland will be safe and reliable. A clear and rigorous policy for bringing EfW technologies into Queensland will allow proponents of mature and well-proven technologies to navigate the approvals process confidently and efficiently, while deterring inappropriate or risky projects. Provision of detailed operational data is key to this pathway because the performance of EfW technologies varies significantly with size, and feedstock composition. Under Pathway 2, proponents would have to provide decision makers with appropriate and accurate performance data from a fully operational reference facility to assess the potential environmental and human health risks of the proposed facility.

Pathway 3: Development and demonstration of emerging technologies

Pathway 3 will support innovation and entrepreneurship in Queensland in a safe and transparent way. The Queensland government actively supports research, development and commercialisation of new technologies through programs like the Queensland Biofutures Roadmap, and this work will be complemented by the Queensland EfW Policy. Pathway 3 will allow Queensland to take the lead in establishing new EfW technologies which tackle challenging feedstocks, unlock high-value resources or develop new technologies to suit our regional centres.

Q2. Does the proposed three-pathway framework for EfW technologies provide an appropriate, risk-based approach? What additional or alternative characteristics of EfW proposals should be considered?

Bioenergy Australia supports the proposed three-pathway framework for EfW technologies and has the following suggestions:

- It is important to clearly define technology characteristics of pathways by distinguishing differences among them.

- There is no consistency between the first sentence and the third sentence in first column of Table 5. The first paragraph refers to “Technology readiness level 6-7”, while the third paragraph explicitly refers to “Technology readiness level 7-9”. It is recommended to remove or rewrite the first sentence.

- As defined for pathway 2, the following sentence should be added to Technology characteristics of pathway 3: “Data from the design and modelling alone is not acceptable to demonstrate operational performance”.

- The five-year time requirement for Pathway 2 could limit Queensland being an early adopter of new technology.

- The pathways should also address issues of how technology scale increases are considered and technology improvements.

Q3. How should a proposal or technology type transition from Pathway 3 (demonstration) to Pathway 2?

Whenever a technology is meeting the characteristics nominated for pathway 2, the transition from pathway 3 to pathway 2 should be granted.

That said, when developing new technologies, there are a number of steps required between the initial concept and completion of the final production plant. These steps include the development of

the commercial process, optimization of the process, scale-up from the bench to a pilot plant, and from the pilot plant to commercial prototype or to the full-scale process. While the ultimate goal is to go directly from process optimization to full scale plant, the pilot plant is generally a necessary step. Reasons for this critical step include: understanding the potential waste streams, examination of macro-processes, process interactions, process variations, process controls, development of standard operating procedures, hazard and risk management etc. The information developed at the pilot plant scale allows for a better understanding of the overall process including side processes and managing process upsets. Therefore, this step helps to build the information base so that the technology can be permitted and safely implemented.

It should also be noted that many of the pathway technologies are being developed or have been developed offshore and are being demonstrated at either pilot or full scale. As much as possible technology pathways should be assessed with a global view and not just a local view, even if modestly different pathways or substrates are being trialled and/or deployed offshore.

Finally, we invite the Queensland Government to use the Bioenergy Project Assessment Tool and the Bioenergy Project Development Timeline as part of the assessment process. These were developed by Bioenergy Australia in collaboration with Foresight Group, Clean Energy Finance Corporation and ARENA to assist with the assessments regarding project viability and opportunities. These tools provide a framework for project developers to self-assess and track the status of their project, and provide guidance on the factors investors will consider.

Safe Guarding the Waste Hierarchy

Principle 2: The Queensland Government must consistently apply the waste hierarchy. Regulation and policy must ensure that energy recovery does not undermine recycling, and that disposal does not undermine appropriate energy recovery.

Principle 3: Energy recovery is only appropriate for residual wastes which it is not practically or economically viable to recycle.

Principle 4: The composition of residual waste will change over time as recycling improves and Qld transitions to a circular economy. EfW facilities must be designed to accommodate this change.

Q4. What role should facility operators, collection contractors and local councils be expected to play in ensuring that only appropriate residual waste is accepted for energy recovery?

Facility operators, collection contractors and local councils should play a key role in facilitating source separation for all waste generators.

Councils play an active role in waste management by providing waste disposal and recycling services. They also regulate the waste disposal of individuals and organisations in the municipality. In addition to providing waste services and regulation, councils should provide advice and education to assist and encourage people to dispose/recycle their waste responsibly and promote correct behaviour, appropriate to the technology and infrastructure mix available in a particular region.

Councils also make and enforce local laws to control the disposal of waste in their areas, but it is the State Government’s responsibility to set the policy and to regulate the acceptance criteria for the waste facilities.

Waste producers are expected to dispose and recycle their waste responsibly, but they should be

provided with an appropriately wide range of waste bins in order to allow effective separation at source, where separate collection and drop-off arrangements can be cost-effectively integrated into waste management arrangements.

It is relevant to note that in October 2018, the WA EPA defined “Residual Waste” in the context of thermal energy recovery from waste as follows:

‘Waste that remains after the application of a best practice source separation process and recycling systems, consistent with the waste hierarchy as described in section 5 of the Waste Avoidance and Resource Recovery Act 2007 (WARR Act), and the Waste Strategy approved or revised from time to time under the WARR Act.’

This is consistent with the general principles of the Waste Hierarchy, in the sense that “residual waste” as defined above, would typically be destined for landfill.

Environmental approvals issued for thermal EfW facilities in WA have included requirements around waste acceptance monitoring and management. It is therefore suggested that regulatory approvals and licensing conditions be developed to reinforce ongoing adherence to the principle of only utilising residual waste in thermal EfW facilities.

The above would not be applicable for biological EfW technologies but may be relevant to mechanical technologies applied to fuel production processes (such as RDF).

Q5. What should the requirements be for safeguarding current and future resource recovery? Does the solution involve segregation, pre-processing or both?

Bioenergy Australia encourages waste segregation and endorses the principle that non-recyclable waste should be used for energy. When source segregation is properly undertaken and waste generators are appropriately aligned and educated, processing can be minimised or completely avoided for certain waste streams.

A 2001 report to the European Commission, Waste Management Options and Climate Change, evaluates the gross greenhouse gas emissions of various waste management processes and provides net values for various waste management options from recycling to disposal. The study has shown that overall, source segregation of MSW followed by recycling or composting gives the lowest net flux of greenhouse gases, compared with other options for the treatment of unsegregated MSW.

Q6. Should the Queensland Government ban specific materials from landfill, or from both landfill and EfW facilities?

In accordance with the waste hierarchy, waste should be recovered for its highest order use wherever it is economically feasible to do so. As an example, organic wastes should be diverted from landfill and utilised in bioenergy facilities to maximise energy production (electricity and/or direct use gas), produce bio-fertilisers and to eliminate methane emissions. Accordingly, appropriately supportive policies enabling cost-effective beneficial use of digestate residue from anaerobic digestion would also be required. Future efforts should minimise the disposal of waste to landfill by diverting organic waste to bioenergy plants. Accordingly, Bioenergy Australia does not support the ongoing landfilling of organic waste and encourages waste managers, being councils or industries, to divert organics to facilities able to recycle nutrients and extract the gas more efficiently.

Studies have shown that the increased deployment of EfW compared to landfill can reduce greenhouse gas emissions. This is because when organic material is placed into a landfill, bacteria breaks it down to produce methane. Some of this methane can be captured in well-operated landfills however, it is often difficult to fully contain. Any methane that is released into the environment is 25 times more potent as a greenhouse gas than carbon dioxide and therefore, reducing methane emissions from landfill is one of the focus areas for meeting our international commitments to reduce greenhouse gases. In Germany and Sweden, a landfill ban on unstabilised biodegradable municipal wastes was implemented several years ago and is proving to be effective in reducing reliance on landfill. In Finland, a ban on placing organic waste in landfills came into effect in 2016. At least half of the community’s waste must now be recycled or biologically processed. Belgium, Denmark, Netherlands and Switzerland have achieved “zero waste to landfill” with only 1% of municipal waste going to landfill with development and integration of organics processing and energy from waste infrastructure.

Alongside landfill bans, complementary policy settings and establishment of relevant infrastructure would be required to process and recover those materials (e.g. organics). Accordingly, Bioenergy Australia acknowledges that a food waste reduction program and social marketing/education campaigns should be accompanied by creating opportunities for households and businesses to utilise organic waste recovery options. Ideally, this would come once a genuine commitment to providing a home/business organics program is put in place, noting that arrangements may vary significantly across different council areas and regions.

Promoting Genuine Energy Recovery

Principle 5: To be considered genuine energy recovery, thermal EfW facilities much meet a minimum energy efficiency threshold that is consistent with international best practice.

Q7. Should thermal EfW processes be required to meet the European R1 Criteria? Why/why not?

Thermal EfW process should be required to meet the European R1 criteria in order to achieve the high

level of energy recovery standardized by the European Commission.

It is important to be noted that “R1-formula” is not an expression of efficiency, but a performance

indicator for the level of recovery of energy from waste in plant using modern combustion-based

waste-to-energy technology. It is a crucial factor to understand that R1 Formula as used in Europe

includes not only the total electricity produced from EfW plant and total energy input to the EfW

system by waste streams, but also the following energy generation and use components:

1) Energy input by imported energy to the plant operation (i.e. fuel-oil, gas for start-up and

shut down process)

2) Energy from heat (steam and hot water) generation delivered to third parties (i.e. steam

supply for near-by industries and district heating system)

3) Energy from heat (steam and hot water) generation for use within the EfW system (i.e.

steam driven turbo pumps for boiler water, backflow as steam; heating purposes of

buildings/instruments/silos, backflow as condensate; demineralization with condensate

as boiler water input)

According to the European Commission’s document, “Directive 200/98/EC on Waste”, EfW facilities

(installed after 2008) dedicated to the processing of municipal solid waste (MSW) only must have an

R1 factor equal to or above 0.65. We agree that for EfW facilities intended to be installed and operated

in Queensland meeting the European R1 criteria is necessary in order to achieve the international

benchmark level of energy recovery standardised by the European Commission.

However, in the discussion paper the following sentence is found “the R1 criteria is equivalent to

converting approximately 25% of the energy generated from the waste into electricity only” (p. 17).

It seems that this statement has been adapted from “NSW Energy from Waste Policy Statement by

NSW EPA”. This 25% value has been derived from the EU R1 formula without considering energy

generation and usages (item 1-3 listed above). This approach makes thermal efficiency criteria

significantly higher than the EU standard, to the point where EU best practice would not be able to be

deployed in QLD.

An example differentiating between R1 criteria and 25% efficient based on electricity generation is an

example calculation found in Annex 5 of European commission’s document (Directive 2008/98/EC on

Waste). According to the EfW plant’s data in Annex 5, the R1 factor is calculated as 0.703—well above

the European standard. If energy generation and usages of item 1-3 listed above are excluded from

those data (as in the proposed scheme) the same EfW plant yields net efficiency of 21.1% which is less

than the required threshold defined by NSW EPA and adopted in the NSW EfW policy statement. This

means that an EfW plant which could be approved by the European standard might be non-compliant

with the draft EfW policy in the Queensland EfW discussion paper. This kind of restriction may

undermine successful deployment and establishment of future EfW infrastructure in Queensland.

We would prefer to use the R1 criteria as it has been adopted in Europe, and without stipulating a

minimum requirement of 25% net electricity output efficiency.

The R1 is therefore a good basis, but it is important to consider that Australia’s climate and population

distribution is significantly different to Europe and opportunities for utilisation of heat may not be as

plentiful. Accordingly, some flexibility may be needed in the short term to allow a better

understanding of how R1 would work in the Australian climate and whether it can be achieved in

Queensland.

Managing Potential Environmental Impact

Principle 6: Queensland should adopt international best practice standard and guidelines for managing the environmental impacts of EfW technologies.

Q8. Do you agree that the European BREF for Waste Incineration and BREF for Waste Treatment are appropriate guidance documents for Pathway 2 technologies? Why/why not?

Bioenergy Australia believes that BREF documents, developed under the IPPC Directive and the IED, are appropriate guidelines for Pathway 2 and potentially Pathway 1 technologies.

Similarly to the R1 criteria, further investigations on the applicability of BREF guidelines in our domestic context might be needed in order to avoid minor technicalities potentially preventing genuine and good projects proceeding in the Queensland.

Planning Approvals for EfW Facilities

Principle 7: Queensland needs a clear, consistent and well-informed assessment process for new waste technologies.

Q9. What aspects of the current planning and assessment framework do you think require clarification?

Bioenergy Australia believes that the current planning and assessment framework is generally clear and appropriate. Additional clarifications could be provided with regards to the assessment of the potential environmental impacts of complex and/or new waste management technologies associated with EfW proposals.

Q10. How can the planning process support effective community engagement?

Community engagement must occur at the beginning of a project using formal EIA processes, following a plan that is transparent, building trust and explaining complex issues in a way that is relevant to the public.

Q11. What role should the government play in assessing significant EfW proposals?

The State Government should play the same role in assessing all significant proposals, whether EfW or not. For instance, it should be responsible for the assessment of the following parameters:

- Potential location suitable for the EfW facility

- Existing infrastructure to support the EfW proposal

- Project’s contribution to the broader EfW industry

- Emissions management systems, protocols, infrastructure and commitments

- Conditioning approvals to include ongoing requirements around waste acceptance monitoring and management

Community Engagement

Principle 8: Proponents of EfW facilities must demonstrate that they have engaged appropriately and transparently with communities impacted by the proposed facilities.

Q12. Do you agree with the proposed stakeholder engagement principles and responsibilities? Is there anything you would add or change?

Bioenergy Australia agrees with the proposed stakeholder engagement principles and responsibilities.

The stakeholder engagement requirements should be based on a risk criterion that takes into account the technology, potential impact of the plant and number of potentially effected stakeholders.

Q13. How could proponents demonstrate that they have followed the proposed principles of engagement?

Proponents should be required to present the outcome of the consultation, highlighting key issues and potential solutions, proposed actions and/or commitments to address them.

Q14. Should proponents of EfW facilities be required to demonstrate that they have obtained a social licence to operate the proposed facility? How would this be demonstrated?

Similarly to the requirements for other projects potentially affecting the community, Bioenergy Australia supports the need to undertake appropriate public consultation in the early planning process of an EfW facility in order to address potential concerns on the project’s environmental, social and economic impact.

Demonstrating this has been achieved however, may be quite challenging and subjective, and it will not always be the case that a “social licence to operate the proposed facility” will be achieved, even after demonstrating full compliance with consultation requirements and securing all necessary regulatory approvals. Therefore, although we agree with the objective, demonstrating that a social licence to operate has been obtained will be very challenging, and may not be a realistic expectation in every case.

Thank you for the opportunity to provide this submission.

Yours sincerely

Shahana McKenzie, CEO Bioenergy Australia