Industrial Boiler & process heat Consenting under the new NPS-GHG/NES-GHG

There have been some big changes to industrial process heat consenting requirements in New Zealand with the new NES-GHG/NPS-GHG.

All industrial sites with fossil fuel process heat emissions above 500 t CO2-e per year will now need a consent with an emissions reduction plan to operate.

Sites without an existing discharge to air consent need to develop an emissions reduction plan and apply for a consent by 26 January 2025.

Sites with an existing discharge to air consent will need to include an emissions reduction plan as part of the reconsenting process at the expiry of the existing consent.

This page outlines what has changed, whether you will be affected, recommended next steps if you are and some further Q&A.

What has changed with new NPS

Industrial boiler & process heat consenting

What's changed with the new national policy statement?

Regional councils must now consider the effects of GHG emissions when assessing resource consent applications for the use of industrial process heat systems. This means consent applications will now need to include an emissions reduction plan. The plan must detail how the site will reduce GHG emissions based on an assessment of the best practicable option (BPO).

The threshold for sites requiring a consent has also changed:

Sites with more than 500 t CO₂-e/yr of fossil fuel emissions from process heat will now require a consent with an emissions reduction plan
Sites with more than 2,000 t CO₂-e/yr require a consent + the emissions reduction plan needs to be independently reviewed by a suitably qualified professional (SQP).

Wil my indutrial process heat system be affected?

will my industrial process heat system be affected?

If you already have a discharge to air consent then you will need to include an emissions reduction plan as part of the reconsenting process at the expiry of the existing consent.

If you do not currently have a discharge to air consent, it is much more likely that your process heat system will now require a consent. This is because the new 500 t CO₂-e/yr threshold will capture a lot more boilers than the region by region MW capacity thresholds used for discharge to air consents to date.

The easiest way to determine this is to look at your annual site fuel consumption. The table below shows the approximate site fuel usage levels above which a consent will now be required for the most common fossil fuel types.

So if you do not currently have a discharge to air consent, but your fuel consumption is above the levels shown above, you need to develop an emissions reduction plan and apply for a resource consent by 26 January 2025.

what does an emissions reduction plan look like?

A process heat emissions reduction plan typically has three key parts:

Site & process heat information, including detailed thermal energy load analysis
An assessment of process change, energy efficiency & demand reduction opportunities
An assessment of fuel switching to lower carbon heating options.

The three parts are then pulled together to determine the best practical option (BPO) for reducing emissions. This typically looks like a roadmap of financially and practically feasible emissions reduction projects scheduled for implementation over time. This can then be used to set annual emissions budgets and an overall emissions reduction target.

The Energy Efficiency & Conservation Authority (EECA) has published non-statutory guidance and information to help with understanding key requirements of the new regulations. This includes how to prepare and assess emissions reduction plans.

What step should I take to starting preparing an ERP

What steps should I take to start preparing an emissions reduction plan?

The first step is to start engaging with your regional council to confirm the impact of the changes on your site.

Based on the three key parts highlighted above, the following are good steps to consider next.

1. Site & process heat information:

Gather information on the heat plant, such as boiler make/model, capacity, condition and temperatures/pressures
Gather information on the system, such as process temperatures required, mass and heat flows, production levels, pipework condition and steam trap operation
Install thermal energy metering, such as steam meters or gas meters to understand your actual thermal load requirements in more detail.

2. Process change, energy efficiency and demand reduction opportunities

Engage with your engineering team to determine if any opportunities have already been identified
Review your site to identify easy wins such as systems operating when not required, uninsulated steam/hot water pipework and steam/hot water leaks
Engage a suitably qualified professional to carry out a thermal energy audit.

3. Low carbon fuel switching options

Engage with your engineering team to determine if any waste heat is available for high temperature heat pumps
Review your site to start to assess the practicality of fuel switching options such as determining the spare electrical capacity or identifying where biomass fuel could be stored on site
Engage a suitably qualified professional to carry out a low carbon fuel switching feasibility study.

how can lumen help?

Our Energy & Carbon Team has over 20 years experience working with industrial process heat users to improve energy efficiency and reduce carbon emissions.

We can help you navigate these new consenting requirements in several ways:

Emissions reduction plans:
- Develop a plan from scratch - a full assessment of process heat decarbonisation opportunities & development of an emissions plan for consent application
- Refresh a previously developed plan - such as updating an EECA Energy Transition Accelerator (ETA) Opportunities Assessment & consolidating into an emissions plan for consent application
Thermal energy audits - identify, quantify and prioritise process change, energy efficiency & demand reduction opportunities
Fuel switching feasibility studies - identify, quantify and determine the practicality of low carbon fuel switching options
Independent reviews - we have several Suitably Qualified Professionals (SQPs) who can carry out independent reviews of emissions reduction plans for sites > 2,000 t CO₂-e/yr.