The Energy Efficiency and Conservation Agency (EECA) and MBIE are calling for submissions on their paper Process Heat in New Zealand: Opportunities and barriers to lowering emissions.

We’d love you to make a submission, because 60% of process heat in New Zealand comes from burning coal and gas. If we’re serious about action on climate change, the use of fossil fuels for process heat needs to come to an end – urgently.

You can submit by email or post, and your submission must be sent before 5pm on Friday, 22 February 2019. See Part C below for how to make your submission.

In this document:

A: What’s This All About And Why Should I Submit?
B: What Should I Say In My Submission?
C: How Do I Submit?

If you already know you want to submit, skip down to Part B: “What Should I Say In My Submission?”.

Part A: What’s This All About And Why Should I Submit?

What’s process heat?

It’s heat primarily used for warming spaces and industrial processes.
If your local school or hospital has a boiler that’s used to hear the premises – that’s process heat.
If the local dairy factory uses energy to dry milk powder – that’s process heat.
And a lot of that process heat is generated by burning fossil fuels: coal and gas.

Why should I care?

We’re in a climate crisis. We need to do lots of stuff to stand a chance of getting out of it – but first and foremost, we need to stop doing the bad stuff. And burning coal and oil and gas is at the very top of the list of bad stuff.

Burning cheap fossils fuels in dairy factories not only directly produces lots of emissions, it also helps prolong the industrial dairying model which is devastating our waterways The more coal and gas Fonterra and its allies are allowed to burn, the more cows they can spatter across our precious landscape, and the more damage they can cause.

So we need to take every chance we can to reduce greenhouse gas emissions from process heat – and that means replacing fossil fuels by renewable sources.

What are the basics on process heat in New Zealand?

Here’s the official Government word on process heat (added emphasis is ours):
Energy (including transport) contributes nearly 40% of New Zealand’s total gross emissions. Process heat makes up one-third of New Zealand’s overall energy use and contributes approximately 9% of gross emissions.
60% of process heat is supplied using fossil fuels, mainly gas and coal.
78% of New Zealand’s process heat is used in industry, particularly manufacturers that turn resources into products eg, heat is used to turn wood into pulp and paper or to process milk into powder, as well as sanitise equipment.
The commercial sector uses 10% of New Zealand’s process heat, mainly for space heating large buildings and offices.
The public sector uses 7% of our process heat eg, hospitals use steam for sterilisation and heating buildings.


Are there any alternatives to using fossil fuels?

Yes! Better sources of heat are available, including wood waste (which is renewable provided forests are replanted after harvesting) and electricity generated from renewable sources. These alternatives are easier to implement in some places that others – but if we’re serious about reducing emissions, our priority has to be urgently transitioning these plants off coal and gas.

Part B: What Should I Say In My Submission?

If you have the industry or technical knowledge necessary to engage with all the detailed discussion questions in the paper, we encourage you to do so.

But you don’t have to be an expert to have your say! As the discussion paper says:

“This paper includes questions you may like to respond to in your submission. Your submission does not need to answer all of these questions.

The Ministry of Business, Innovation and Employment (MBIE) and the Energy Efficiency and Conservation Authority (EECA) also encourages any other comments you may have regarding process heat use and the transition to a low emissions economy. Where possible, please include evidence to support your views, for example, references to facts and figures, or relevant examples.”

So, whether or not you address the more technical questions, here are the points we encourage you to make – in your own words, but along these lines:

Overall comments

  1. Most important of all is to stop any new investment in fossil fuel plant. The limited efficiencies gained by Fonterra in their existing plants are more than outweighed by the building of new plant in the dairy industry, running on coal or gas. All new plant should be renewably fuelled, or we are just wasting our time.
  2. A mandatory carbon price of at least $50/tonne, raised at regular and pre-announced intervals to reach $100 within a couple of years, is needed to drive the urgent and significant emissions reductions that must be made.
  3. The Government should put legislative and regulatory changes in place to ensure that, as existing heat plant reaches the end of its economic life, it is replaced by heat plant that is not fuelled by fossil fuels, but is powered from renewable energy sources.
  4. Measures should also be put in place to ensure that existing fossil fuel powered heat plant is not run beyond the end of its economic life in an effort to avoid replacing fossil fuel energy sources by renewable sources.
  5. Where existing fossil-fuel powered heat plant has an economic life that extends past 2030, the Government should put in place legislative and economic measures to ensure that this plant is replaced by heat plant that is powered by renewable energy sources.
  6. If hydrogen is used as an energy source for process heat, it must be generated by renewable means, not derived from fossil fuels
  7. Replacing one form of fossil fuel energy source with another is completely unacceptable. In particular, the idea that natural gas is a “transition fuel” away from coal is nonsense. Fossil fuels should be replaced by renewables, not other fossil fuels.


Suggested response to detailed questions

There are 27 detailed questions in the discussion document. Here are suggested responses to a few of them. (Don’t let the reference to “organisations” in the questions put you off – this is a public consultation and you are entitled to respond!)

Q4: Does the NZ ETS provide an incentive to significantly reduce emissions beyond current levels for business who receive industrial allocation?

No. A carbon price of at least $50/tonne, raised at regular and pre-announced intervals to reach $100 within a couple of years, is needed to drive such significant emissions reductions. If carbon prices of this magnitude are to be accepted, the revenue needs to be paid back to the people on an equal per capita basis.

Q17: What does your organisation consider are the largest barriers to the electrification of its production?

It’s clear from the discussion in this section that companies and institutions’ unfamiliarity with electricity as a source of process heat is a substantial barrier to its adoption. Here, the Government should partner with both public and private sector users of process heat to ensure the early uptake of electricity for process heat at a range of scales.

Electrification should not proceed beyond the point where all new capacity can be provided from renewable sources.

Q21: What does your organisation consider to be the largest barrier(s) to the use of biomass for supplying heat?

The largest barrier to the use of biomass for process heat is one that is not listed in this section of the discussion paper: the lack of a carbon price that means that companies pay the true cost of their greenhouse gas emissions. With such a price in place, companies that currently emphasise the barriers listed in this section may well find that these barriers were less substantial than they currently claim.

However, it will also be important to ensure that other sources of emissions related to biomass (e.g. transport emissions) are minimised, and that the sources of biomass are environmentally sustainable (e.g.using wood waste rather than crops grown for biomass).

A major barrier is consultants who are familiar with coal and gas and just use their existing templates to design plant. EECA should compile a list of consultants who are familiar with the use of wood waste and other waste biomass and will recommend quality boilers to use these fuels.

Q27: Has your organisation identified any other barriers to, or co-benefits from, the direct use of geothermal heat that we have not included above?

Although geothermal energy is not a fossil energy source, exploiting geothermal energy sources does result in CO2 production. While these are substantially less than from the burning of fossil fuels, this means that renewable energy sources should still be preferred to geothermal energy.

Part C: How Do I Submit?

You can submit by email or post, and your submission must be sent before 5pm on Friday, 22 February 2019.

Please include your name, or the name of your organisation, and contact details. You can make your submission by:

Attaching your submission as a Microsoft Word or PDF attachment and sending it to or

Mailing your submission to:

Energy Markets
Ministry of Business, Innovation, and Employment
PO Box 1473
Wellington 6140
New Zealand

Please direct any questions that you may have in relation to the submission process to