The Ministry for the Environment (MFE) is finally developing a new national direction – either a national environment standard, national policy statement or hopefully both – to help councils’ decision-making on greenhouse gas discharges to air.
From 31 December 2021 regional councils will finally be able to consider the effects of greenhouse gas (GHG) emissions under the Resource Management Act 1991 (RMA) something that ECO has long campaigned for and that the Minister for the Environment, David Parker has pushed through Parliament. Such consideration includes when making air discharge rules and considering applications for air discharge permits. Process heat currently contributes about 8% of New Zealand’s total GHG emissions and makes up 17% of the emissions covered under the net zero emissions target for 2050 (though ECO considers this target should be earlier than 2050).
The government has committed to prohibiting the installation of any new coal-fired boilers for low and medium temperature process heat. The proposals in this discussion document would implement this ban and begin a phase-out of existing coal and other industrial fossil fuels. The proposals will also create incentives for the industry to adopt more energy-efficient practices to support the transition.
The changes will also allow local authorities to “have regard to” emission reduction plans and national adaptation plans when preparing RMA plans and policy statements. The Climate Change Response (Zero-Carbon) Amendment Act 2019 set a 2050 target of net-zero GHG emissions (other than biogenic methane) and a framework to guide domestic climate actions as they transition into a low-emissions economy.
The national direction under the RMA is proposed as a regulatory tool to develop nationally consistent rules, with a focus on decarbonising process heat. The proposals include:
- Implementing the Government’s commitment to ban new low and medium temperature coal boilers;
- Phasing out coal in existing sites by 2037 for low and medium temperature process heat, through re-consenting;
- Phasing out use of other fossil fuels such as diesel and natural gas by requiring a switch to less emissions intensive fuels such as electricity, unless no economically or technically viable alternatives exist; and
- Requiring industrial sites above a threshold to have an emissions plan to encourage energy efficiency, best practice, and transition to low-emission fuels.
MFE says that the comprehensive review of the resource management system will provide opportunities for reducing emissions in an integrated way. At this stage it is unclear to ECO how that will happen. . We do know though that this is a good moment to amend the EEZ and Continental Shelf Act to remove the exclusions from consideration of GHG emissions that mirror those previously in the RMA. We hope the Minister for the Environment will do so soon.
The MFE consultation seeks to:
- Achieve national consistency and certainty in the management of industrial greenhouse gas emissions under the RMA; and
- Reduce industrial GHG emissions to mitigate the adverse effects of climate change and support New Zealand’s transition to a low emissions economy.
The proposals include different requirements depending on the size of the activity, the specific industry and whether it was a new or existing site. The proposed thresholds are that:
- The requirements would not apply to low-GHG emitting sites (a specified threshold below 100 tonne CO2-e/year, 50kW, 2 MW, or those operating fewer than 400 hours per year). Examples given are small commercial space heating and food processing sites, and boilers used for
back-up or supplying peak demand.
- Small sites are those emitting between 100 and 2,000 tonne CO2-e/year, for example,
horticulture, smaller food processing sites;
- Large sites are those able to emit over 2,000 tonne CO2-e/year eg large food processing
sites, emissions-intensive industry.
ECO welcomes the long-overdue development of a national policy statement and standards under RMA on GHG emissions.
The proposals are generally weak when it comes to reducing natural gas use in industrial premises. The report suggests a carbon price of over $120/tonne is required to phase out natural gas use. Overall the proposals will need to be strengthened if NZ is to meet the 1.5oC Paris Agreement target. Clearly, regulations rather than market prices are needed as long as the Emissions Trading System is so poorly designed and implemented.
Submissions close 20 May 2021 with Email: email@example.com
The full proposal report is: MFEs proposal document on phasing out fossil fuels in process heat [PDF 2.6MB]
For more details see: Phasing out fossil fuels in process heat