Emissions Plan Guidance

The regulations

Ministry for the Environment and the Ministry of Business, Innovation and Employment have released a National Policy Statement (NPS) and National Environmental Standard (NES) for Greenhouse Gas (GHG) Emissions from Industrial Process Heat, that came into force 27 July 2023.

Councils are now required to factor in emissions produced by industrial process heat when assessing air discharge resource consent applications. The regulations provide a nationally consistent framework for reducing greenhouse gas emissions from industrial process heat.

The regulations support New Zealand’s commitment to lowering emissions in line with achieving our emissions budgets and net zero 2050, and our international commitments under the Paris Agreement.

Find out more about the NES and NPS

A focus on industrial process heat

Process heat is energy used specifically in industrial and manufacturing processes - for example, in turning wood into pulp and paper, processing milk into powder, or sanitising equipment. 

Process heat makes up around a third of our overall energy use and contributes approximately 8% of gross GHG emissions. This is a priority area for emissions reduction in New Zealand, as over half of the energy used is supplied using fossil fuels, mainly gas and coal.

The regulations will affect industries that use fossil fuels in heat devices such as boilers, furnaces, engines, or other combustion devices to generate industrial process heat, that produce GHG emissions. The regulations do not apply to emissions from non-fossil fuels used in industrial processes, electricity generation, or industries using fossil fuel-fired heat devices to heat space and water heating in commercial buildings.

EECA resources

EECA has published non-statutory guidance and information to help councils and industry with understanding key requirements of the regulations, including how to prepare and assess emissions plans required as part of a discharge to air resource consent application.

Emissions Plan Guidance

The Emissions Plan Guidance will help regional councils navigate the regulations, ensure they are able to implement them in their region, and provide the required approach to preparing and assessing an emissions plan. However, this guidance may also be useful to industry, especially consultants who have been hired to help develop emissions plans, and resource consent applicants.

The guidance includes: 

an introduction to the NPS-GHG and NES-GHG
an overview of resource consent applications, including details on how consent decisions and assessments are made
an overview of emissions plans
guidance on how to assess and prepare an emissions plan
resource consent conditions and compliance
additional support available for regional councils and businesses affected by the regulations.

Emissions Plan Guidance [PDF 13 MB]

Best Available Techniques Reference Documents

The Best Available Technique (BAT) Reference Documents provide a basis for assessing how a businesses’ current process compares with international practices in the same sector.

Information is provided in the BAT Reference Documents relating to many industrial sectors that the regulations apply to, to assist with both assessing and producing emissions plans as part of a resource consent application.

The BAT will also help applicants and regional councils identify opportunities for energy efficiency improvements, alternative processes, and fuel switching.

Best Available Techniques Reference Documents [PDF 1.3 MB]

Cost Assessment Tool

The Cost Assessment Tool (CAT), and its supporting user guide, should be used by applicants when assessing the financial viability of lower emission alternatives to a proposed new heat device under the regulations.

The CAT provides a common set of assumptions and calculation methods to help understand the financial impacts, and the emissions impacts, of process heat technology choices and consenting decisions. The CAT will also be helpful for applicants preparing a best practicable option (BPO) assessment for their emissions plans.

The key outputs of the CAT are ‘total lifecycle cost’ and ‘total emissions’. An alternative process, fuel, or energy source is likely to be financially viable if it has a similar or lower total lifecycle cost compared to the fossil fuelled process heat option.

Cost Assessment Tool [XLSX 9.9 MB]

Cost Assessment Tool User Guide [PDF 7.5 MB]

Non-fuel operating cost tables

Non-fuel operating cost tables have been prepared to provide an estimation of significant non-energy operating and maintenance costs by process heat technology and size range.

These tables can be used by applicants who are unsure of non-fuel operating costs to use for a cost assessment/financial viability test. The cost tables can also be used by regional councils to compare with the non-fuel operating costs used by applicants.

Non-fuel operating cost tables [PDF 7.2 MB]Cost Assessment Tool [XLSX 9.9 MB]

‘DIY’ Emissions Plan

Create a pragmatic and actionable emissions plan tailored to your business or organisation that will drive emissions reduction over time.

The following three resources are designed to complement each other in the development of your emissions plan. The user guide provides instructions, you can also watch the 'how-to' video here(external link).

DIY Emissions Plan User Guide [PDF 1.7 MB]
DIY Emissions Plan Calculations Spreadsheet [XLSX 593 KB]
DIY Emissions Plan Report Template [DOCX 106 KB]

We also have examples of the above documents that we have completed using dummy information, these are available below:

DIY Emissions Plan Calculations Spreadsheet Example with Dummy Data [XLSX 611 KB]
DIY Emissions Plan Report Example with Dummy Information [PDF 152 KB]

Suitably Qualified Person

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.

An SQP should be a practitioner who has been approved by the regional council, that has relevant tertiary qualifications, expertise in the technology and practices of industrial process heat, and experience to review and provide recommendations on reducing greenhouse gas emissions.

EECA has been working with Carbon and Energy Professionals (CEP) to develop a certification scheme for SQPs. A specific combination of existing certifications offered by CEP already meet the requirements to be acknowledged as an SQP. CEP has provided a list certified SQPs on its website under ‘Find an expert’.

There are energy and carbon professionals who may not be on the CEP list but that do meet the requirements to be an SQP. For more information see the Ministry for the Environment’s information sheet on the attributes of an SQP.  

Useful links:

Find an expert - Carbon and Energy Professionals | CEP(external link)

MFE Factsheet: Attributes of a Suitably Qualified Person(external link)

Fact sheets on the regulations

Ministry for the Environment has produced fact sheets that provide a summary of the requirements the National Policy Statement and National Environmental Standards for Greenhouse Gas Emissions from Industrial Process Heat.

MFE fact sheet for industry(external link)

MFE fact sheet for councils(external link)

The National Direction is set to reduce New Zealand’s emissions by 277,000 tCO₂-e per year - that's the equivalent of taking 100,000 cars off the road.

Source: https://www.beehive.govt.nz/release/government-ban-new-coal-boilers-place

Other helpful EECA resources

EECA’s Sector Decarbonisation Programme collaborates with sector associations and technical experts to connect New Zealand businesses with world-class innovation and best practice guidance to decarbonise at a sector level. The programme also provides new businesses with best practice knowledge when they enter the sector.

Find out more about the Sector Decarbonisation Programme

Resource consent applicants need to undertake a Type 3 (or equivalent) process heat thermal energy audit when developing emissions plans. This will help to understand the total thermal energy use for heat devices on a proposed of existing site and identify energy efficiency opportunities. EECA provides assistance for energy audits for eligible sites.

Find out more about EECA support for Energy Audits

The Energy Transition Accelerator (ETA) is a flagship programme run by EECA for businesses committed to reducing carbon emissions. An expert will help you onto a long-term pathway to emissions reduction by identifying technically and financially viable decisions and investments. The ETA will help identify opportunities and initiatives aligned to your business’s strategic decarbonisation and asset management plans. EECA provides assistance for ETAs for eligible sites.

Find out more about the Energy Transition Accelerator Programme

Organisations involved

Ministry for the Environment and Ministry of Business, Innovation and Employment	The National Direction has been developed by the Ministry for the Environment (MFE) and Ministry of Business, Innovation and Employment (MBIE).
Regional Councils	Regional Councils are responsible for implementing the NES and NPS, including assessing and making decisions on individual resource consent applications.
EECA (Energy Efficiency and Conservation Authority)	EECA is publishing a suite of non-statutory guidance to help councils and industry to understand and implement the regulations.

Contact us

If you have any questions in relation to the Emissions Plan Guidance and supporting documents, please email technicalenquiries@eeca.govt.nz