What the EIA Actually Says About Ash
The Deadly
Ashtray
Cigarettes carry more health warnings than this ash report. TNG's consultants produced a document about 196,000 tonnes of hazardous residue that says it must not be relied upon for any purpose — then filed it with the Fiji Government as their ash management plan.
See the Evidence ↓When 900,000 tonnes of rubbish burns every year, it does not disappear. Burning concentrates the most toxic components of the entire waste stream — heavy metals, dioxins, furans, persistent organic pollutants — into ash. That ash has to go somewhere. This is where TNG’s plan falls apart.
TNG — the Australian company behind this incinerator — hired GHD, a large Australian engineering firm, to produce a report on what would happen to the ash. That report is Appendix M of the EIA: the Bottom Ash and Fly Ash Reuse Report. It is nine pages of substantive content followed by a marketing brochure. It contains no disposal plan. It identifies no receiving facility. It does not assess the environmental risk of storing hazardous ash beside the ocean and the reef.
Its opening section states that it must not be relied upon for any purpose. GHD’s standard disclaimer, printed on the footer of every page, states the same thing. This document was submitted to the Fiji Ministry of Environment and Climate Change as TNG’s ash management plan.
Eight Critical Failures — One Document
GHD’s ash disposal report fails in eight distinct ways. Each failure alone would be disqualifying in a rigorous regulatory process. Together, they reveal an EIA submission that does not contain a plan — it contains a placeholder.
The Document Says It Must Not Be Relied Upon — In Its Own Words
Filed with the Government. Explicitly says it cannot be used to guide decisions.
The purpose clause in Section 1.1 is unusually direct:
“This report is provided as an interim communication under our agreement with The Next Generation Fiji. It is provided to foster discussion in relation to technical matters associated with the project and should not be relied upon in any way or for any purpose.”
GHD’s standard disclaimer — printed on the footer of every page — reinforces this:
“This document is in draft form. The contents, including any opinions, conclusions or recommendations contained in, or which may be implied from, this draft document must not be relied upon. GHD reserves the right, at any time, without notice, to modify or retract any part or all of the draft document.”
Up to 196,000 Tonnes of Ash Per Year — No Plan for Any of It
The scale of the ash problem is stated clearly. The solution is not.
The report acknowledges the fly ash (APCr) output directly:
“The proposed Fiji EfW facility will have a design capacity of 900,000 tonnes per annum (tpa), so at full capacity the facility would be expected to generate approximately 18,000 to 54,000 tpa of APCr.”
18,000 to 54,000 tonnes of hazardous fly ash per year. Every year. For 25–30 years. This is what the report acknowledges for fly ash alone. What the report does not address is bottom ash — the coarser residue from the furnace floor, constituting approximately 20–30% of the waste stream by weight. At 900,000 tpa throughput, bottom ash production would be approximately 130,000 to 180,000 tonnes per year. It does not appear in the body of this report.
Classified as Hazardous Waste — Explicitly, by TNG’s Own Consultants
Not contested. Not a community claim. GHD states it directly.
There is no ambiguity about the nature of fly ash from a mixed municipal waste incinerator:
“Unless subjected to further treatment, APCr is generally classified as hazardous waste.”
The fly ash concentrates heavy metals — chromium, lead, zinc, mercury, cadmium — along with dioxins and furans drawn from the entire waste stream. It must be stored, handled, transported, and disposed of or processed under hazardous waste protocols. The question of where that happens, and how, is what this report was commissioned to answer.
Three Disposal Options Described — None Committed To
A plan says what will happen. This document says what could happen.
Section 2.1 presents three theoretical approaches to APCr management:
- Landfill — burial in a suitably engineered hazardous waste facility
- Immobilisation — blending with cement to reduce leachability, then landfill or use as structural elements
- Carbonation — using CO² to react with the APCr to form a lightweight aggregate
The document discusses each option. It does not select one. It does not commit to one. It does not identify a licensed facility in Fiji capable of receiving hazardous waste at this scale.
The Proposed “Solution” Is a UK Marketing Brochure Pasted Into an Appendix
No contract. No feasibility study. No regulatory approval. Advertising material.
The carbonation approach is presented via a specific vendor: UK-based O.C.O. Technology.
“UK-based O.C.O. Technology utilises accelerated carbonation to stabilise APCr from EfW facilities… The carbonated APCr is then reused as a carbon-negative manufactured limestone aggregate for the construction industry.”
“OCO is a recognised leader in the field, having achieved End of Waste status in the UK for its APCr treatment technology.”
“End of Waste status in the UK” is a UK regulatory designation. It has no legal standing in Fiji. There is no equivalent Fijian regulatory framework for this designation. There is no assessment of whether Fiji’s construction industry could absorb tens of thousands of tonnes of processed ash aggregate annually. There is no evidence OCO Technology has any presence, licence, or operational capacity in Fiji or the Pacific.
Exporting the Ash May Be Illegal — The Report Recommends “Investigation”
The proposed solution depends on exporting ash out of Fiji. This may violate international law. The EIA does not resolve it.
Section 2.3 is the most damaging passage in the document. It states:
“There are restrictions on overseas transport (transhipment) of wastes from Australia and other countries, including household waste, mixed plastics and other hazardous materials. These include the Basel, Rotterdam and Stockholm Conventions.”
“Investigation of constraints on export from country of origin and import of residues from the proposed EfW facility, and measures that would need to be implemented to demonstrate compliance, is recommended.”
No Environmental Risk Assessment for Ash Storage or Marine Contamination
The complete storage assessment is two sentences. The facility sits on a coastal peninsula next to the reef.
Section 2.2 — “APCr handling and storage considerations” — is three sentences long. Here is the substantive content in full:
“APCr is captured and pneumatically conveyed to silos at the EfW facility (similar to cement silos), and usually transported by road via conventional cement transport tankers. The material is hazardous and requires appropriate management and treatment.”
Two sentences. That is the entirety of the environmental risk assessment for storing hazardous ash on a cyclone-exposed coastal peninsula, next to the Dreketi Inlet, its mangroves, and the adjacent Pacific Ocean. Not assessed:
- Leachate from ash storage under rainfall
- Contamination pathways to the Dreketi Inlet and mangroves
- Runoff to the adjacent Pacific Ocean
- Ash spill scenarios during road or sea transport
- Long-term groundwater contamination from on-site storage
- Atmospheric dispersion from silo venting
- Structural failure of silos under cyclone-force winds
- Ash stockpile inundation under flooding
Bottom Ash Is Not Assessed — Despite Being Half the Document’s Title
130,000 to 180,000 tonnes per year. The document’s title promises an assessment. The body contains nothing.
The document is titled “Bottom Ash and Fly Ash Reuse Report.” Bottom ash — the coarser residue from the furnace floor, constituting approximately 20–30% of the waste stream by weight — does not appear in the body of the report.
At 900,000 tpa throughput, the facility would produce approximately 130,000 to 180,000 tonnes of bottom ash annually. Bottom ash from mixed municipal waste carries significant heavy metal contamination including lead, copper, zinc, and barium, and may contain unburned organic material including PAHs (polycyclic aromatic hydrocarbons).
What This Document Actually Is
Nine pages of substantive content. Three pages describing the problem. Two pages describing a UK technology with no Fiji presence. One paragraph on storage. One paragraph acknowledging the ash export plan may violate international law. Then a marketing brochure.
“This report… should not be relied upon in any way or for any purpose.”
— GHD Pty Ltd, Section 1.1, Bottom Ash and Fly Ash Reuse Report. Prepared for The Next Generation Fiji. Submitted to the Fiji Ministry of Environment and Climate Change, March 2026.This is not an ash management plan. It is a placeholder submitted to the regulator to suggest that an ash management plan might eventually exist. It does not identify a receiving facility. It does not assess environmental risk. It does not establish legal compliance. It does not commit to any approach.
The EIA presents this incinerator as an energy solution. Appendix M reveals that the most dangerous physical output of that incinerator — tens of thousands of tonnes of hazardous residue every year — has no destination, no treatment plan, no legal export pathway, and no environmental safeguards.
It all stays in Fiji.
Summary of Failures
What the Ash Report Does and Does Not Contain
| Issue | Status |
|---|---|
| Committed ash disposal plan | None — three options described, none selected |
| Licensed hazardous waste facility identified in Fiji | None identified |
| Bottom ash assessed | Not mentioned in the body of the report |
| APCr classified as hazardous waste | Yes — explicitly, by GHD |
| OCO Technology agreement or contract | No — marketing brochure only |
| Basel / Stockholm / Rotterdam compliance confirmed | Not assessed — “investigation recommended” |
| Leachate / marine contamination risk assessment | Not assessed |
| Cyclone / flood risk to ash storage | Not assessed |
| Document status | Interim communication — “must not be relied upon” |
| GHD liability | Disclaimed in full |
GHD Rates Cyclones as Extreme.
Then Doesn’t Model Them.
“GHD’s Climate Risk Scan rates tropical cyclones and sea level rise as EXTREME risks for this site. The same EIA calls sea level rise ‘negligible’ and does not model cyclones at all. The comprehensive assessment GHD recommends does not exist. It is not in the EIA.”
The ash disposal report says the ash export plan may violate international law — and recommends investigation. The Climate Risk Scan says a comprehensive climate risk assessment must be done — and recommends investigation. Neither investigation has been completed. Neither result is in the EIA.
A coastal industrial facility producing 196,000 tonnes of hazardous ash per year, rated at extreme cyclone and sea level rise risk, with no climate risk modelling and no ash export pathway. This is what TNG submitted.
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