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Greenhouse Gas Emissions from Industrial Process Heat (NPS:IGHG, NES:IGHG)

The National Policy Statement for Greenhouse Gases from Industrial Process Heat (NPS:IGHG) and National Environmental Standards for Greenhouse Gases from Industrial Process Heat (NES:IGHG) support councils in their decision making on discharges to air of greenhouse gas emissions from industrial sectors using process heat.

What are the regulations?

The Ministry for the Environment and Ministry of Business, Innovation and Employment released new national regulations:

These came into force on 27 July 2023 to support councils in their decision making on discharges to air of greenhouse gas emissions from industrial sectors using process heat.

The NPS:IGHG and NES:IGHG work alongside each other to provide nationally consistent policies and requirements for reducing greenhouse gas emissions from industries using process heat by:  

  • prohibiting discharges of greenhouse gases from new low to medium temperature coal boilers immediately and from existing coal boilers after 2037 (after this date no further consents can be issued)
  • requiring resource consent to be held for new and existing fossil fuel boilers that emit 500 tonnes and above of CO2-e per year, per site
  • requiring resource consent applicants to prepare and implement greenhouse gas emission plans and set out actions to reduce emissions.

Why are they needed?

Process heat makes up 33 per cent of of New Zealand’s overall energy use and contributes approximately eight per cent of gross emissions. More than half of process heat is supplied using fossil fuels, mainly gas and coal.

What activities are affected?

The regulations affect industries that use fossil fuels in heat devices to generate industrial process heat, that produce greenhouse gas emissions. This may include for example:

  • including in the manufacturing of products (metals, chemicals etc)
  • processing of raw materials (milk into milk powder, wood pulp into paper, woolscour, fellmongery etc.
  • horticulture when industrial heat is used to grow plants or other photosynthesising organisms indoors.

The regulations do not apply to emissions from non-fossil fuels used in industrial processes (such as wood, solar), electricity generation, or industries using fossil fuel-fired heat devices to heat space and water heating in commercial buildings.

The regulations also do not apply to 'low emissions sites' which emit less than 500 tonnes of carbon dioxide a year. 

An Air Quality Consultant called Emission Impossible have provided a free calculator to help determine whether sites are considered low emission sites and which sites need consent. You will need the number of boilers used on the site, the heat output (in kW), the efficiency of the boiler (if known), the fuel type and the hours each boiler is in operation per year to use this calculator.

Where resource consent is required under these regulations, resource consents need to be lodged with Hawke's Bay Regional Council by 26 January 2025.

Emission Plans

Where an activity requires resource consent, an emissions plan is required. If the site is a high emission site, the emission plan is required to be reviewed by a suitably qualified person (SQP). A list of SQPs is available from the Carbon and Energy Professionals website.

How the regulations apply depends on whether the heat device is new or existing, what fuel it burns and what heat rate it burns at.

Important definitions

  • Industrial process heat is defined as the thermal energy used in industrial processes, including manufacturing and processing of raw materials, or to grow plants (or other photosynthesising organisms) indoors.  

  • Heat devices are defined as a device that produces industrial process heat (i.e. boiler, furnace or engine or other combustion device) but does not include a device that is not used for the primary purpose of generating heat (i.e. if a device is used for generating energy, it is not regulated by the NES:IGHG).

  • Fossil fuels include – coal, diesel, liquid petroleum gas, oil, peat, plastic and used oil (or any derivative of these) but does not include biogas or biomass.

  • Back up heat devices, which are a heat device which produces industrial process heat, operate for 400 hours or less each year and are only used when heat is required but cannot be produced by another heat device at the site (because of maintenance, an unexpected event or there is a temporary spike in demand) are not regulated.

  • Low-emissions sites are defined as a site that emits less than 500 tonnes of carbon dioxide equivalent of greenhouse gases from fossil fuel burning heat devices (not including back up device).

  • High-emission sites are sites that emit more than 2,000 tonnes of carbon dioxide equivalent of greenhouse gases from a heat device per year. These require an additional level of information provided, where resource consent is triggered.

Frequently asked questions (FAQs)

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Emission Impossible have provided a free calculator to help determine whether sites are considered low emission sites. If the site is a low emission site, there are no further requirements under the new legislation.

If the site is a low emission site, there are no further requirements under the new legislation.

The regulations do not specify who writes the emissions plan, but if the site is a high-emission site, a Suitably Qualified Person (SQP) must review the emissions plan. A list of SQPs is available on the Carbon and Energy Professionals website. Other air quality consultants may also be able to undertake the work, contact us to check.

An Emissions Plan for the activity would need to be prepared in accordance with Regulations 13, 14 and 15 of the NE:IGHG which can be found here

A Suitably Qualified Person (SQP) must review emissions plans for high-emissions sites that emit more than 2,000 tonnes of CO2-e per year from heat devices using fossil fuels to generate industrial process heat.

Activities that were previously permitted activities prior to 27 July 2023 (when the NES-GHG came into force) but require a resource consent under these new regulations are required to be lodged with the Council by 26 January 2025. Provided an application is submitted by that date, the activity can continue until a decision has been made on the application.

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