ANDREW CURTIS - PDP

SIRRL has included an air quality assessment report as part of its resource consent application. Tara Hutchins from Pattle Delamore Partners (PDP)  completed this report, which Andrew Curtis reviewed and approved.

 

 

The following is taken from Mr Curtis’s LinkedIn profile:

Andrew has more than 30 years of engineering experience and has specialised in air pollution for over 20 years. This experience has ranged from the assessment and correction of air pollution problems and the design of air pollution control equipment to preparing resource consent applications for a wide range of industries. He has also been involved in assessing application for regulatory bodies and he is often called upon to provide expert evidence at Board’s of Inquiry, the Environment Court and Council resource consent hearings. Curtis is also a qualified Hearings Commissioner, whose areas of experience include:
• Air Pollution Control
• Odour Control
• Atmospheric Dispersion Modelling
• Environmental Impact Assessment
• Air Pollution Equipment Specification
• Ambient Air monitoring
• Expert Evidence

 

SIRRL'S FIRST RESOURCE CONSENT APPLICATION

SIRRL first lodged a request for resource consent to construct and operate Project Kea in September 2022. This application included a 65-page air quality assessment report dated September 19, 2022, completed by PDP’s Tara Hutchins and reviewed and approved by Andrew Curtis. 

This resource consent application was returned by ECan and Waimate District Council for lack of ‘fundamental information, including the following:

detailed description of the proposed discharge to air:

  1. The contaminant identification process has inadequate detail; the contaminant
    properties evaluation stage is absent, the contaminant health or other impacts
    stage is absent, and there is no detail on the method proposed to assess the
    potential impacts of each contaminant and its suitability.
  2. The process description in Technical Report 1 does not address process matters
    relating to air emissions. As there are a range of sources within the process that
    will result in discharges into air, the process description and impacts must be fully
    outline all sources.
  3. There is inadequate information on the nature of contaminants and the
    relationships of these and the waste stream.

SIRRL RELODGE RESOURCE CONSENT APPLICATION

SIRRL relodged their resource consent application in late November 2022, with an updated 102-page Air Quality Assessment report dated 23 November 2022, prepared by PDP’s Tara Hutchins and reviewed and again approved by Andrew Curtis.

ECAN REQUEST FOR MORE INFORMATION

Since commencing the evaluation of SIRRL’s second application, ECan has requested more information from the applicant. This request included the following:

The Canterbury Regional Council (CRC) External Air Quality Expert has reviewed the application; the detailed assessment is attached in Appendix 1. The information required allows CRC and other relevant parties, including potential submitters, to better understand the proposed processes and their effects on Air Quality.

 

 

In summary, the following information is required: 

 

a. Please provide comprehensive justification of the guaranteed emission limits.
b. Please provide a detailed plant design, including the combustion chamber design.

suitability to the waste stream and impact on emissions.
Less plastic material (product stewardship/changing packaging mix, material bans,
increased recycling capability).
Changing make-up of construction waste as materials recovery is driven through
Building Act, RMA/NBA and WMA changes.
Please provide details (location, class of landfill) on the proposed disposal for bottom
ash and vitrified fly ash until markets are established for beneficial use.
Please provide evidence that an existing authorised disposal pathway exists for the bottom
ash and vitrified fly ash, e.g, evidence that the ash meets the waste acceptance criteria
at an authorised landfill.
Please provide examples and details of successful and beneficial use of fly ash and bottom
ash.
Please set out the contingency arrangements for the management of air pollution
control residues/fly ash if the vitrification process fails or is temporarily offline?
Please address the impact of reduced feedstock quantity on the operation of the facility.
Please advise where the targeted feedstocks are currently going and why there is a

need for something new?

 

The request also included an appendix by Dr Emily Wilton, who is peer-reviewing PDP’s Air Quality Assessment report. In the appendix, Dr Wilton stated that there is a lack of cohesion between the experts who prepared Technical Report 1, the Operational and Technical Overview report completed by Babbage Consultants, and Technical Report 5, the Air Quality Assessment report completed by Pattle Delamore Partners (PDP).

Dr Wilton went on to state that the inconsistencies between the two reports was problematic when providing an assessment.

 

FIELDING WTE PROPOSAL BY BIO PLANT

 A Fielding waste to energy proposal by Bio Plant Manawatu Ltd also initially had the support of Andrew Curtis and included a report he co-authored on air discharge; that support was later withdrawn by Curtis due to “unreliable data.” (See Stuff article dated January 18, 2023, titled ‘Expert withdraws support for pyrolysis plant due to unreliable data.’ )

 

The January 18 article by Matthew Dallas reads as follows:

 “Until this week, Curtis was confident the plant would not have a negative effect on the environment. A 2021 report he co-authored, based on Bioplant data and modelling, indicated the plant should not be able to be smelt outside its boundary, and its gas emissions would have no impact on the surrounding area.

But his supplementary report to the commissioners on Monday, having considered additional evidence from Bioplant consultants, found there was insufficient information and “fundamental errors” in modelling.

He said he could not be confident there would be no air quality effects from the plant’s discharges, and he could “no longer support the granting of an air discharge consent” based on the information presented to date.

While Curtis welcomed additional data that provided greater clarification to the process, there were too many unknowns, aspects of the new evidence “confused things even more,”  and data inconsistencies and faulty modelling made it impossible to determine whether there would be off-site odour effects.

He also highlighted that no detail for an onsite wastewater treatment plant had yet been provided by anyone on Bioplant’s team.

"INCONSISTENT DATA, FUNDAMENTAL ERRORS, AND FAULTY MODELLING." Andrew Curtis

What does seem consistent here is the lack of consistency in both the Waimate and Fielding proposals and the accompanying air quality reports, yet initially, Andrew Curtis signed off on both. 

PDP has had two attempts at providing an air quality assessment report for Project Kea, both signed off by Andrew Curtis, but the air quality expert peer reviewing PDP’s report is saying the information between the air quality assessment report and the operational, technical overview report is inconsistent.

The first air quality assessment report was 65p, and the second was 102p. This clearly shows how insufficient the first attempt was.

Maybe its time Mr Curtis provides some consistency and withdraws his support for Project Kea?