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Meeting with CDS, 27 March 2025
Purpose
1. You are meeting with Clifton Madgwick (Managing Director, CDS) and Aimie Hines
(Senior Consultant, Capital NZ) on 27 March 2025. This briefing has been prepared to
support you at that meeting. It includes:
i.
background information about CDS and why they wish to meet with you
ii. an overview of the concerns A-Gas has raised about the CDS facility’s destruction
technology
iii. an offer CDS will make for you to officially open their domestic destruction facility,
and associated considerations regarding this invitation.
2. Kara Lok (Manager, Waste Sectors Policy) will be attending this meeting with you.
Officials meet regularly with CDS.
3. Talking points and biographies for the CDS attendees and are attached as appendices.
Context
Background information on CDS
4. CDS is a wholly owned subsidiary of the Trust for the Destruction of Synthetic
Refrigerants. However, CDS operates independently of the Trust as a separate
business.
5. CDS is currently building the first facility in New Zealand that will be capable of
destroying synthetic refrigerants. The facility will be located in Kawerau, Bay of Plenty.
Steam Plasma Arc Refrigerant Cracking technology
6. There are several different types of plasma arc technology that can be used for the
destruction of synthetic refrigerants. For example, argon and nitrogen gas plasma arc
technologies are both commonly used globally.
7. The CDS destruction facility will use Steam Plasma Arc Refrigerant Cracking (SPARC)
technology to destroy synthetic refrigerant gases. This technology is being supplied by
Canadian company PyroGenesis.
8. SPARC technology is not currently in use anywhere else in the world for the destruction
of synthetic refrigerants. However, the company supplying the technology (PyroGenesis)
has other types of plasma arc facilities that are currently operational internationally.
9. The CDS facility will have an emissions stack. It will also produce salts (which will be
sent to landfill) as a byproduct and will discharge water into the tradewaste system. As
the facility will be processing hazardous waste, there are risks involved with each of
these discharges.
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10. CDS has assured Officials that the SPARC facility is expected to operate at a
destruction efficiency of >99.99% (in line with Montreal Protocol destruction efficiency
criteria).
Consenting status of the destruction facility
11. CDS has finished constructing the building that will house the domestic destruction
facility. The land itself is owned by another party (Kawerau Enterprise Agency) and
leased to CDS.
12. CDS have indicated that they have successfully obtained a wastewater (trade-waste)
permit from Kawerau District Council. An air discharge consent from Bay of Plenty
Regional Council will also be required. At the time of drafting, CDS has not yet filed an
application for their air discharge consent.
Current and future policy settings for domestic destruction facilities
13. Currently, the Resource Management Act (RMA) is the only policy mechanism in place
that regulates the establishment and operation of a synthetic refrigerant destruction
facility.
14. While the RMA does not specifically discuss destruction facilities, standard
environmental parameters around discharge to air and water apply. As the facility will be
processing hazardous waste, Officials expect Kawerau District Council and Bay of
Plenty Regional Council to be carefully considering any destruction facility consent
applications.
15. In addition to the existing RMA consenting requirements, the synthetic refrigerants
product stewardship scheme will introduce new reporting and destruction efficiency
verification requirements. The objective of these requirements is to ensure that domestic
destruction occurs at an efficiency level in alignment with Montreal Protocol criteria
(>99.99% destruction removal efficiency).
16. s 9(2)(f)(iv)
.
Concerns raised by A-Gas
s 9(2)(b)(ii)
19. s 9(2)(g)(i)
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CDS request for you to officially open the domestic destruction facility
20. CDS has informed Officials that they intend to invite you to officially open the SPARC
facility once it becomes operational. CDS have advised Officials that they are working
towards the plant being operational in the middle of this year.
21. s 9(2)(g)(i)
22.
23.
Import for destruction of Ozone Depleting Substances from the Pacific Islands
24. One additional topic CDS may wish to discuss is the importation of ozone depleting
substances (ODS), controlled under the Montreal Protocol on Ozone Depleting
Substances, from the Pacific Islands. Mr. Madgwick has recently provided Officials with
a high-level estimate of existing ODS stocks in several Pacific Island countries. We have
yet to substantiate these estimates.
25. The Ozone Layer Protection Regulations (OLPR) 1996 do not provide for the import of
ODS for destruction. Regulation 29 sets out the exemptions that may be granted by the
Environmental Protection Authority for the import of bulk controlled substances. This
does not include an exemption for the purpose of destruction. It is likely that when the
OLPR were drafted, the ability for destruction of ODS within New Zealand was not
foreseen.
26. Some of the ODS in the Pacific Islands are currently being sent to Australia for
destruction, where those shipments face importation levies. CDS would like to import
ODS from the Pacific Islands to destroy them in New Zealand. New Zealand does not
currently charge for import/export permits under the Ozone Layer Protection Act.
27. Allowing for the importation of ODS for the purpose of destruction would require an
amendment to the OLPR. As a part of the policy development process, options would
need to be accessed regarding whether any importation/application changes should
apply.
28. s 9(2)(g)(i)
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