Rotorua Air-Quality Options Analysis
1
Introduction
This options analysis report investigates and analyses each of the 22 options proposed
in the Draft Rotorua Air Quality Action Plan. It also makes recommendations to the
Rotorua Air Quality Joint Committee for including each option in the Action Plan.
1.1
Background
The Resource Management (National Environmental Standards Relating to Certain Air
Pollutants, Dioxins, and Other Toxics) Regulations 2004 (NESAQ), introduced a
maximum allowable ambient concentration of 50 μg/m3 (24-hour average) for
particulates of 10 microns or less (PM10). The Rotorua urban airshed regularly exceeds
this limit, with the majority of emissions being from domestic fires used for heating, with
a smaller contribution from industry. Increased concentrations of PM10 in the air have a
proven adverse effect on human health.
Several discussions and workshops have been held between parties with an interest in
reducing the particulates in the airshed. These include councillors and staff from both
Rotorua District Council and Environment Bay of Plenty (the Bay of Plenty Regional
Council), staff from the Ministry for the Environment, and the Rotorua Air Quality
Working Party. From these discussions and workshops, several options to improve air
quality have emerged, using both regulatory and non-regulatory methods.
No single action will improve Rotorua’s air quality – the solution will need to combine
several options and include them in the Rotorua Air-Quality Action Plan, which aims to
improve the health of Rotorua residents and visitors by improving ambient air quality.
The Rotorua Air-Quality Joint Committee has been established to select a suitable
package of options for the Action Plan, and to oversee their implementation.
2
Options Considered
The options to be analysed by this report are summarised in the table below.
EMISSION CAPS – To ensure future growth does not increase emissions
New houses
Option A
Ban or restrict solid-fuel burners in new houses
Existing houses
Option B
Ban or restrict new solid-fuel burners in existing houses
New and existing houses
Option C
Require solid-fuel burners to comply with a more
stringent design standard than NESAQ
EMISSION REDUCTIONS – To reduce the particulates going into the airshed
Solid-fuel burner control
Option D
Ban the backyard burning of waste
Option E
Require burner upgrade at point of property sale
Option F
Phase out the use of open fires for home heating
Option G
Phase out solid-fuel burners 15 years or older
Option H
Phase out non-NESAQ compliant solid fuel-burners
Option I
Phase out all solid-fuel burners
Incentives
Option J
Offer subsidy to low-income households
Option K
Apply for EECA funding for Clean Heat Project
Option L
Offer a loan on rates to middle-income households
Option M
Offer a loan on property to households
Option N
Apply for EECA funding for EnergyWise Project
Option O
Offer incentives to landlords
Option P
Offer incentives for HNZC houses
Industry
Option Q
Review resource consent conditions for major industry
Option R
Provide a consultant for major industry
Option S
Provide cash incentive to upgrade equipment
DRY WOOD – Ensure that wood supply in Rotorua is good quality
Option T
Promote the burning of dry wood
COMMUNITY AWARENESS – Keep the community aware and involved
Option U
Promote community awareness
INFRASTRUCTURE – Large-scale developments to provide alternative heating
methods
Option V
Develop infrastructure
3
About the Options Analysis
3.1
Links
Some options may target the same sectors of the population as other options. For
example, Option E proposes to require those who sell their properties to upgrade any
solid-fuel burner in the home. Many of these burners may also be targeted in options F
and G (open fires and burners older than 15 years), thus reducing the effectiveness of
Option E.
It is extremely difficult to accurately calculate the interaction between options, so this
has not been attempted. Instead, the links between options have been specifically
identified.
3.2
Best Practice
Most options presented are already in place in other regions of New Zealand. In
particular, Environment Canterbury and Nelson City Council have an advanced
scheme of regulations and incentives to encourage conversions to cleaner heating
methods. Where appropriate, best practice has been included in the assessment.
3.3
Assumptions
The analysis uses the best information available from recent research and surveys, but
gaps still remain in terms of understanding the level of potential uptake of various
options and the exact benefit (in terms of removing particulate matter) that will occur.
Assumptions are required in some areas so decisions can be made and these are
listed for each option. Through the implementation process these assumptions will be
monitored and the programme regularly reviewed to allow for iterative adjustments or
re-targeting if required.
3.4
Regulatory Methods
Some options must be implemented through laws (a regulatory framework). There are
two Government acts that have set processes for doing this.
The Resource Management Act 1991 (RMA) allows for rules to be included in a district
or regional plan. A change to these plans can be a lengthy process that involves public
notification, submissions, further submissions, and a hearing. Under the RMA, hearings
decisions can be appealed and potentially end up going through a lengthy court
process that can seriously delay implementation (in some cases by years). For longterm changes, this process is appropriate and both Nelson City Council (NCC) and
Environment Canterbury (ECan) chose this method to install their regulations. While
NCC has an operative plan, ECan is still waiting for settlement of appeals before it can
implement its rules.
The Local Government Act 2002 (LGA) allows for the introduction of bylaws as a
regulatory method. This process involves public notification, submissions, and a
hearing. No appeals to the hearing decision are possible. It is much more streamlined
and can be completed in approximately two months. Implementation and compliance
can be carried out by either the regional or district council.
However, the time available to make effective changes within the Rotorua community is
limited, with 1 September 2013 set as the compliance date. A combination of regional
rules and local bylaws will help change behaviours in Rotorua, both in the short and
long term.
3.5
Equity
In developing a package of activities, the councils are conscious of the need to find an
equitable distribution of costs and benefits. It is important to consider the contributions
that each part of the community makes (domestic, commercial, industrial and transport)
and to ensure that there is not a disproportionate impact on any particular sector. In
this sense the start point for looking at fair outcomes for Rotorua is that the polluter
should pay.
However, it is not possible to develop an exactly equitable solution due to transaction
costs, unknown behaviour responses, and ability and willingness to pay. This is where
the councils need to consider the range of options available and find the fairest
package of actions.
The investment in solving the problem should be targeted at achieving a value-formoney outcome. This is where consideration of equity also extends into the use of
funding sources from the local and regional ratepayer communities.
How equitable is it for the wider population to contribute to a localised problem? In this
case the problem is generated within Rotorua so although it can seen as not equitable
that the regional community contributes to solving it, the wider community does
ultimately face the cost of the problem through the costs to community health.
A discussion about equity is particularly important where subsidies are being
considered. The rationale for subsidies (financial transfers) is clearly established if:
 A behaviour change will not occur due to affordability
 Regardless of affordability behaviour change will not eventuate
 The benefits are significant enough to warrant a subsidy being applied.
In the case of domestic heating solutions will require financial subsidies to privately
owned assets (as home improvements). Such subsidies need to be treated with care.
This also applies to any transfers to profit-generating assets (such as rental or
industrial assets) which are often viewed negatively by the community. However, these
transfers may have a part to play in delivering positive benefits in relation to the cost
outlay.
Complete equity cannot be achieved, but is more equitable than not acting at all.
4
Options Analysis
4.1
Emissions Capping
While options to reduce the current level of emissions may make up a large proportion
of the Action Plan, it is also useful to consider actions that will reduce the amount of
emissions into the airshed in the future.
Future trends can be difficult to predict. For instance, there is a market surge towards
installing heat pumps for home heating, but should power cuts occur this may
encourage a shift back towards solid-fuel heating. It is recommended that regulations
are in place in advance of a trend shift, to prevent air quality from getting worse. The
intent is not to eliminate solid-fuel heating, but to ensure that the cleanest, most current
technology is used.
The woodburner design standard in the NESAQ does not apply to multiburners or open
fires. In effect, this means that it is still legal to place an open fire or multiburner in a
home within the Rotorua airshed even though these burners are inefficient and pollute
the air. The options suggested in this section will help address that.
Option A – Ban or Restrict Domestic Burners in New Houses
4.1.1
This option has two alternatives with slightly different outcomes:
Option Ai Ban solid-fuel burners in new homes. This is a complete ban on installing
any solid-fuel burner in a new house. Heating options are limited to heat pumps and
gas.
Option Aii Restrict solid-fuel burners in new homes. This allows solid-fuel burners to
be installed in new houses, but only those that meet NESAQ design standards (1.5g/kg
and 65% efficiency), effectively banning open fires and multiburners. Heating options
include heat pumps, gas, pellet fires, and low-emission woodburners.
Option
Ai
Aii
1
Best
practice
Tasman
District
Council
Nelson
City
Council
Tonnes
removed
None
Tonnes
prevented
1 tonnes
Tonnes
added
None
Costs
Links
$200,0001
$/
tonne
n/a
None
0.5 tonnes
0.5 tonnes
$200,0001
n/a
Ai,
Bi,
Bii, U
Costs are not cumulative. Rules can be set up concurrently at one cost.
Aii,
Bi,
Bii, U
Assumptions




90 new houses built each year within the airshed (averaged over the last four
years).
Approximately 50% of all new houses have solid-fuel burners installed.
Emission rate from compliant woodburners is 4.5 g/kg.
1200 kg/year of wood is used per burner.
Discussion
Either version of this rule is a simple way of preventing unsuitable heating methods
from being installed. As the houses have not yet been built, the difficulties associated
with retrofitting existing homes, are not present.
However, Option Ai has several implications. If all solid-fuel burners were banned in
new houses, the only remaining options would be to install heat pumps or reticulated
gas heaters. Restricting all heating methods to two fuels is undesirable – increased
dependence on gas uses a non-renewable resource more quickly and contributes to
climate change, while electricity is also under national pressure. When power demand
peaks during winter, the extra is generally sourced from thermal power plants, again
contributing to climate change.
A complete ban on installing solid-fuel burners in new houses is being implemented by
Tasman District Council in Richmond. Fast housing growth in this area makes the rule
an appropriate way of controlling further emissions. Rotorua, by contrast, has a slow
growth rate, and the adverse environmental effect of adding approximately 0.1
tonnes/year of particulates to the airshed from new houses does not outweigh the
implications of such a restrictive rule. Widespread encouragement of a single type of
heating appliance is not considered to be the solution.
There is also the significant chance that Option Ai would be challenged in court. The
manufacturers of pellets and pellet fires are likely to oppose any rule that excludes their
product from being installed, as has already happened in Canterbury.
With the technology available to use efficient, low-emission solid-fuel burners (pellet
fires and NESAQ-compliant woodburners), there is little justification for excluding these
from the suite of heating options for new houses. Option Aii would require any solidfuel burner installed in a new house to meet NESAQ requirements. This automatically
excludes open fires and multiburners which have high emissions, but does not limit
heating options. There is an environmental impact, as particulates will continue to be
added to the airshed. However, this can be monitored and the option reassessed if the
impact is found to be significant.
It is recommended that Option Aii be included in the Action Plan.
Recommended Action:
Require all solid-fuel burners installed in new houses
to comply with NESAQ requirements.
4.1.2
Option B – Ban or Restrict Domestic Burners in Existing Houses with no Existing
Burner
This option also has two alternatives with slightly different outcomes:
Option Bi Ban solid-fuel burners in existing houses that do not have a burner
installed. This would effectively mean that any house that uses another method of
heating (gas or electricity) cannot install a solid-fuel burner.
Option Bii Restrict solid-fuel burners in existing houses that do not have a burner
installed, to those that can meet NESAQ design standards. Solid-fuel burners can still
be installed where there isn’t one, but must comply with the 1.5g/kg and 65% efficiency
criteria (these criteria would exclude open fires and multiburners).
Option Best
practice
Bi
Tasman
District
Council
Bii
Nelson
City
Council
1
Tonnes
removed
None
Tonnes
prevented
4.6 tonnes
Tonnes
added
None
Costs
$/tonne
Links
$200,0001 n/a
Ai, Aii,
Bii, U
None
None
4.6 tonnes
$200,0001 n/a
Ai, Aii,
Bi, U
Costs are not cumulative. Rules can be set up concurrently at one cost.
Assumptions



Approximately 1% of households (855 houses) that do not have a solid-fuel
burner would look to install new burners. (This estimate is not based on any
data. A social science study would be required for a more accurate estimate.)
Emission rate from compliant woodburners is 4.5 g/kg.
1200 kg/year of wood is used per burner.
Discussion
Ideally, Option Bi should be adopted to prevent future emissions where none now exist.
However, Option Aii allows the installation of NESAQ-compliant solid-fuel burners in
new houses. This creates an inequity where those in existing houses are penalised
more than those building new homes.
Because of the social implications of causing a regulation inequity, the preferred
solution is to choose Option Bii. This would impose the same restrictions on solid-fuel
burners in both new and existing houses, requiring all burners to meet NESAQ
requirements. Again, this will automatically exclude open fires and multiburners
without limiting heating options. While this option has the potential to add a significant
amount of emissions to the airshed, it is unlikely that this will actually occur. Trends
show a growth in the installation of heat pumps. Unless there is a widespread shift
back to solid-fuel heating, there is unlikely to be large-scale conversions to
woodburners. Should this occur, this option can be reviewed.
As with Option A, provided all new solid-fuel burners installed comply with NESAQ
requirements, there is little justification for excluding them from the airshed. It is
recommended that Option Bii be included in the Action Plan.
Recommended Action:
Require all solid-fuel burners installed in existing
houses to comply with NESAQ requirements.
Option C – A Rule Requiring Solid-Fuel Burners to Comply with a More Stringent
Design Standard than NESAQ
4.1.3
This option is similar to Options Aii and Bii where the NESAQ design standard for
woodburners (1.5g/kg of emissions and 65% efficiency) is applied to all solid-fuel
burners, effectively banning open fires and multiburners. The rule can then be made
more stringent, for example requiring solid-fuel burners to have a design standard of
1.0g/kg emissions and 65% efficiency, applied to any solid-fuel burner installed in any
house within the airshed. Environment Canterbury and Otago Regional Council both
have rules that enforce a stricter design standard (1.0g/kg and 0.7g/kg respectively).
Discussion
Lowering emission requirements beyond those required by NESAQ enforces a better
design standard, encouraging manufacturers to build better, more efficient appliances
and leading to environmental benefits. In theory, a woodburner designed to a more
stringent standard should have lower emissions.
However, evidence from real-life emission testing of woodburners indicates there is
little to no performance difference between a woodburner that complies with a design
standard of 1.5g/kg, and one that complies with 1.0g/kg (or lower). Once the
woodburner is used outside the testing laboratory, it is prone to incorrect use, such as
burning inappropriate fuels. The emissions measured from real-life testing averaged at
4.5g/kg, regardless of the design standard of the woodburner.1
Enforcing a more stringent design standard with no technical justification leaves the
rule open to legal challenge. Until there is a proven environmental advantage for
introducing this requirement, it is an option not recommended for inclusion in the Action
Plan.
Recommendation:
Do not pursue this action at this stage.
Emission Reductions – Solid-Fuel Burner Control
4.2
The following options are regulations intended to reduce the amount of particulates
going into the airshed from domestic fires. The majority of domestic fires are used for
heating and approximately 50% of all households use solid-fuel burners for this
purpose, while backyard burning to dispose of greenwaste or household rubbish is
carried out by 11% of households2. Controlling these sources using the options below
will reduce the total amount of particulates discharged.
Option D – Prohibit the Backyard Burning of Waste
4.2.1
This option proposes to prohibit the backyard burning of rubbish and green waste as
the emissions inventory3 shows that this activity releases 5 tonnes of PM10 into the
airshed each year.
1
Ministry for the Environment, Warm Homes Technical Report: Real-life Emissions Testing of Wood Burners in Tokoroa, June
2007.
2 S Iremonger & B Graham, Rotorua Domestic Heating Survey, Environment Bay of Plenty Environmental Publication 2006/14,
September 2006
3 S Iremonger & B Graham, Rotorua Air Emissions Inventory 2005, Environment Bay of Plenty Environmental Publication
2007/02, 2007.
Best practice
Environment
Canterbury
Tonnes removed
5 tonnes
Costs
$200,0001
$/tonne
$40,000
Links
None
Otago Regional
Council
1
Costs are not cumulative. All rules can be set up concurrently at one cost.
Assumptions

The emissions inventory shows that 11% (1892) of all Rotorua households use
backyard burning to dispose of waste.

Green waste makes up 58%; household waste the remaining 42%.

An average of 220kg/household is burned annually.
Note: No information is available on the frequency of burning.
Discussion
A ban on backyard burning can be interpreted as too controlling – there is an
expectation that householders should be able to carry out activities on their own
property with a minimum of restrictions.
However, this right also applies to other householders enjoying their backyards without
being exposed to detrimental discharges. Backyard burning of inappropriate materials
is a nuisance to neighbours, particularly in an urban environment. When the airshed is
already heavy with particulates,unnecessary burning becomes even more
inappropriate.
Backyard burning is currently a permitted activity, unless it is considered objectionable
or offensive. This judgement is subjective at best, and is difficult to assess and
regulate. The vast majority of complaints to Environment Bay of Plenty’s Pollution
Hotline concern smoky fires. A blanket ban on all backyard burning within the airshed
would solve the problem of subjectivity.
The intent of the rule is not to impose on activities such as braziers, barbecues, hangi,
pizza ovens and other recreational fires which the majority of the population engage in
from time to time. These activities are not generally considered to be either a nuisance,
or a significant contribution to the particulates within the airshed.
Although it will inconvenience those who burn rubbish and green waste in their
backyard, banning this activity will result in a significant reduction in particulate
emission. Other disposal options or rubbish and green waste are available, which
include composting and recycling. There is considerable environmental benefit in
prohibiting this activity, not only reducing the amount of particulates going into the
airshed, but also preventing the destruction of materials that could otherwise be
recycled.
It is recommended that Option D be included in the Action Plan.
Recommended Action – Prohibit the backyard burning of waste.
4.2.2
Option E – Require Burner Upgrade at Point of Property Sale
This option would require any non-complying solid-fuel burner to be upgraded (by
either vendor or purchaser) at the time a house is sold. A total of 1500 houses are sold
in Rotorua each year and approximately half have solid-fuel burners that do not
comply.
Best practice
Tasman
District Council
Tonnes
removed
(average)
5.6
tonnes/year2
Costs
$/tonne
(average)
Links
$200,0001
$35,714
B, C, F, G, H,
I, J, L, M, O,
P, U
1
Costs are not cumulative. All rules can be set up concurrently at one cost.
Averaged over five years with diminishing effect each year due to properties already affected
being resold.
2
Assumptions








A total of 750 houses with solid-fuel burners are sold each year (720 wood and
open burners; 30 multiburners).
The rule has a diminishing effect over time as some refitted properties will be
resold.
Emission rate from multiburners is 22g/kg.
Emission rate from old open and woodburners is 9g/kg.
Replacement appliances: 338 homes to compliant woodburners, 75 to pellet fires,
338 to zero-emission appliances.
Emission rate from compliant woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
1200 kg/year of wood is used per burner.
Discussion
Whether this rule requires the vendor or the purchaser to upgrade the appliance, there
is an economic burden. A new appliance can cost up to $6000 (depending on what is
chosen), which is a significant expense. However, the point of property sale is when
money is most likely to be available to finance a burner upgrade and this option is a
relatively simple way to enforce conversions without imposing financial hardships. As
house values in Rotorua are generally lower, the expense of an upgrade may be more
significant than elsewhere, but there is no reason why those affected by this rule could
not qualify for any incentives offered (discussed in later sections).
A social implication also arises from this rule, and from any other rule that requires a
solid-fuel burner to be removed for reasons of non-compliance. In some cases,
particularly if the house is being purchased as an investment and will be rented, there
is no requirement to replace the burner with a suitable alternative. Lower socioeconomic families, already affected by poor health, are those most likely to tenant
these houses which will then have sub-standard heating.
While poorly insulated and heated homes are a health concern, this issue falls outside
the jurisdiction of the air-quality issue. There is a limit to which behaviours councils can
control (and a limit to the tolerance of the general public in being told what to do).
Whether insulation or a suitable heating appliance is installed, is up to the individual
homeowner.
Tasman District Council worked closely with real estate companies when introducing
this rule, and a similar approach is recommended here. Real estate agents are one of
the first points of contact when buying or selling a house and their input for
implementing this rule will be valuable.
It is recommended that Option E be included in the Action Plan.
Recommended Action:
Require any non-complying solid-fuel burner installed
in an existing house to be upgraded to comply with
NESAQ requirements at the point of property sale.
Option F – Phase Out Existing Open Fires for Home Heating
4.2.3
This option proposes to ban any open fire that is being used for heating in a home
within the airshed. It can be separated into two options.
Option Fi Ban open fires after September 1, 2018. This allows a 10-year phase-out
period. As this rule will not take effect until after the 2013 deadline it has a limited effect
in terms of the airshed complying with NESAQ.
Option Fii Ban open fires after September 1, 2013. This is the deadline for airsheds to
comply with NESAQ rules and allows a 5-year phase-out period.
Option
Fi
Best
practice
None
Tonnes
removed
0.8 tonnes2
Nelson City 7 tonnes3
Council
Fii
Costs
$/tonne
Links
$200,0001
$250,000
$200,0001
$28,571
B, E, Fii,
J, K, L,
N, O, U
B, E, Fi,
J, K, L,
N, O, U
G,
M,
G,
M,
1
Costs are not cumulative. All rules can be set up concurrently at one cost.
Based on 10% of all homes with open fires converting before 2013.
3 Based on 100% of all homes with open fires converting by 2013.
2
Assumptions







A total of 855 houses use open fires for heating.
Emission rate from open fires is 9g/kg.
For Option Fi, replacement appliances: 38 woodburners, 9 pellet fires, and 38
zero-emission appliances.
For Option Fii, replacement appliances: 385 woodburners, 87 pellet fires, and
385 zero-emission appliances.
Emission rate from compliant woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
1200 kg/year of wood is used per burner.
Implications
Those who have the means and inclination to convert their open fire to a more efficient
appliance would most likely have already done so. Without a rule, there is little
incentive for anyone to replace this form of heating and the adverse environmental
effects will continue. The expected voluntary conversion of open fires is estimated at
about 85 homes.
The total contribution of particulates to the airshed from open fires is 7.5 tonnes/year.
This is a significant contribution from just 5% of Rotorua’s population. With open fires
being one of the most inefficient methods of home heating, they contribute a lot to
pollution, but little to the overall health and wellbeing of the householders.
Introducing a rule to prohibit open fires is a suitable method of ensuring that
conversions take place. However, either version of this rule is reasonably contentious,
with potential to impose financial hardship on many home owners. If this rule is
introduced alongside appropriate incentives (discussed in later sections) the hardship
would be minimised.
There is a potential inequity caused through forcing the replacement of open fires in
existing homes, while still allowing new solid-fuel burners to be installed inside homes
in the airshed. However, allowing modern, clean-burning technology is more
acceptable than allowing the continued use of something that has long been
superseded.
It is recommended that Option Fii be included in the Action Plan.
Recommended Action:
4.2.4
Prohibit the use of open fires for home heating after
September 1, 2013.
Option G – Phase Out Solid-fuel Burners 15 Years or Older
Generally, the older the burner the less efficient the technology, and the more
emissions produced. This rule would phase out all burners within the airshed that are
more than 15 years old, approximately half of all burners.
Best practice
Environment
Canterbury
1
Tonnes
removed
25 tonnes
Costs
$/tonne
Links
$200,0001
$8,000
E, J, K, L, M,
N, U
Dependent on appeals and court processes.
Assumptions






Approximately 3088 woodburners in Rotorua are 15 years old or more.
Emission rate from old woodburners is 9g/kg.
Emission rate from new woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
Replacement uptake: 1390 homes to compliant woodburners, 309 to pellet fires,
1390 to zero-emission appliances.
1200 kg/year of wood is used per burner.
Discussion
This rule has financial implications for a large number of households in Rotorua, and.
by making a blanket rule apply to all aged appliances, some that otherwise comply with
design criteria will be removed. There is also the risk that in 15 years’ time every
appliance that has been installed will then become obsolete.
However, the technology that existed 15 years ago allowed for woodburners to be
dampened down to allow for all-night burning. The wood would then smoulder over a
long period of time, and more particles were released. By contrast, woodburners that
comply with the NESAQ design standard do not allow for inefficient burning and have
much lower emissions. Once old woodburners have been replaced with new complying
burners there should be no future need for widespread replacements.
Although this rule is contentious, almost half of all the emission reductions that are
required can be accomplished through introducing this one rule. It is not surprising that
a rule that will affect a significant amount of the woodburning population will
significantly reduce emissions. Although there are financial implications for the
householder, there are already incentive programmes in place to assist with financing
conversions. Further incentives could be introduced (discussed in later sections), but
this will be at a cost to the council(s).
This rule will affect a significant proportion of the population. There are other actions
recommended that may achieve the required reductions that are not as far reaching or
contentious. It is recommended that Option G is not included in the Action Plan, but is
investigated for future implementation should further action be required.
Recommendation:
4.2.5
Consider prohibiting the use of woodburners 15 years or
older as a contingency option for the future.
Option H – Phase Out all non-NESAQ Compliant Solid-fuel Burners
This rule would phase out any solid-fuel burner (including open fires and multiburners)
that could not comply with the NESAQ design standard for woodburners (1.5g/kg, 65%
efficiency).
This rule is similar to the proposed actions of Options A and B However, where those
options only include replacing solid-fuel burners, this rule would require all existing noncomplying burners to be replaced. Almost all of the solid-fuel burners in Rotorua fall
into this category (some 8,200 homes).
Best practice
Environment
Canterbury
Nelson City Council
Tonnes
removed
73 tonnes
Costs
S/tonne
Links
$200,0001
$2,740
A, B, E, F, I,
J, K, L, M, N
1 Dependent on appeals and court processes.
Assumptions







Estimated that 8208 solid-fuel burners do not comply with NESAQ.
Emission rate from old woodburners and open fires is 9g/kg.
Emission rate from multiburners is 22g/kg.
Emission rate from new woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
Replacement uptake: 3694 homes to compliant woodburners, 820 to pellet fires,
3694 to zero-emission appliances.
1200 kg/year of wood is used per burner.
Discussion
Almost all the solid-fuel burners in Rotorua do not comply with NESAQ rules and
approximately 50% of all houses use solid fuel burners to heat their homes. Therefore
half the population would be affected by this rule, and be required to replace their
burners. While the positive environmental effect would be significant (all emission
reductions necessary will be achieved with one action), it would place the community
under huge financial pressure. Most households in Rotorua are lower socio-economic
and cannot afford to replace their appliance.
Although Environment Canterbury and Nelson City Council may use this rule to good
effect, they back it up with significant financial contributions to householders. But while
incentives may form part of the solution there are cheaper and less contentious ways of
encouraging conversions, rather than a blanket ban. This is an option that may be
investigated for Rotorua in future, but at present will not be pursued.
Recommendation:
4.2.6
Do not pursue this action further at this stage.
Option I – Phase Out Solid-fuel Burners
This rule would ban all solid-fuel burners and not allow replacements. Installations
would be limited to gas and electricity-driven heating appliances.
Best practice
None
Tonnes
removed
98 tonnes
Costs
$/tonne
Links
$200,0001
$2,041
A, B, E, F, G,
J, K, L, M, N,
U
1 Dependent on appeals and court processes.
Assumptions







Approximately 8550 woodburners in use within the Rotorua airshed.
Emission rate from old woodburners and open fires is 9g/kg.
Emission rate from multiburners is 22g/kg.
Emission rate from new woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
No replacement uptake of solid-fuel burners permitted.
1200 kg/year of wood is used per burner.
Discussion
At face value, this rule appears to be the single solution for the particulate problem in
Rotorua, now and for the future. This would require the retrofitting of every solid-fuel
burner in the airshed (8550 households), placing an enormous financial burden on the
community. The only alternatives are to install heat pumps or reticulated gas heaters.
Restricting all heating methods to two fuels is undesirable for reasons already
discussed (see Option A). This rule is likely to face legal challenge from the
community. The manufacturers of solid-fuel burners in particular would be likely to
oppose any rule that excludes their products from an entire city.
A blanket ban and consequent widespread conversion to a single type of appliance and
fuel is not considered to be the solution, for both social and environmental reasons.
Recommendation:
Do not pursue this action further at this stage.
4.3
Emission Reductions – Incentives
Regulations are one way of creating change within the community. However, as
discussed in the sections above, there are financial and social implications when
requiring compliance with rules. Incentives can mitigate many of these effects and
make it easier for households to convert their heating methods.
4.3.1
Option J – Offer Subsidy to Low-income Households
This incentive would involve providing a full subsidy for those homes unable to afford to
pay for the conversion themselves. In many areas of the country this subsidy not only
pays for the replacement appliance, but also for insulation (if required) and the removal
of the existing appliance.
Best practice
Environment
Canterbury
Nelson City Council
Tonnes
removed
23 tonnes
Costs
$/tonne
Links
$10 million
$434,783
E, F, G, K,
M, U
Assumptions









Approximately 3686 solid-fuel burners in low-income houses.
Uptake for this incentive would be 70% (2580 houses).
Emission rate from old woodburners and open fires is 9g/kg.
Emission rate from multiburners is 22g/kg.
Emission rate from new woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
Replacement uptake: 1161 homes to compliant woodburners, 258 to pellet fires,
1161 to zero-emission appliances.
1200 kg/year of wood is used per burner.
The conversion cost of one house is approximately $4000.
Discussion
Conversions are a significant expense even for middle-income earners. For lowincome homeowners or tenants, it is even more onerous, and aAlmost half of all solidfuel burners within the airshed are in low-income homes. Because of the expense of
changing burners, these homes are more likely to have aged, inefficient burners that
emit more particulates.
This incentive would have huge benefits. Clean heat, especially when combined with
insulation, leads directly to healthier homes. This in turn means fewer hospital and
doctor’s visits which reduces the strain on the health system, and more able members
of the community, whether in education or employment. The removal of an estimated
24 tonnes of particulates from the airshed has health benefits for the wider community,
not just those who receive a new heating appliance.
However, there is a social inequity caused by offering full subsidies to one sector of the
community. Middle-income earners are expected to bear all or some of the cost of their
replacement appliance, while low-income earners receive a full subsidy. In addition,
providing full subsidies requires a high level of funding for less environmental benefit.
In the future, some form of subsidy will most likely be required to assist the low-income
sector. However, there are other incentives (discussed below) that will remove
particulates from the airshed for less funding. At this stage, it is recommended that
those options are explored first. This option can be explored at a later date if
necessary.
Recommendation:
4.3.2
Consider offering a subsidy to low-income households, as
a contingency action.
Option K – Apply for Energy Efficiency and Conservation (EECA) Funding for
Clean Heat Project
Central Government funding is being provided via EECA’s Clean Heat Project to cofund replacement burners for low-income homes. The fund is competitive, and limited
to $1.4 million a year, for four years. If the application is successful partners provide
funding which is matched 1:1 by EECA. The project is aimed at low-income
householders who hold a Community Services Card. The house must be pre-1978,
located in a designated airshed, and have insulation already installed. A non-compliant
solid-fuel burner must be the main heating source. The project will replace the burner
with a clean-heat appliance (flued gas, heat pump, compliant woodburner, pellet fire).
Environment Bay of Plenty contracted Energy Options to apply for funding through this
scheme. The application was successful and Environment Bay of Plenty received
$150,000 in funding, to match $150,000 that was provided by EECA.
Tonnes removed
2008/2009 0.7 tonnes
2009/2010 0.9 tonnes
2010/2011 1.1 tonnes
Costs
2008/2009 $150,000
2009/2010 $185,248
2010/2011 $220,288
$/tonne
Total 2.7 tonnes
Total $555,536
$205,754
Links
A, B, E, F, G, J, M, U
Assumptions









Approximately 86 homes will be converted in 2008/2009; 105 in 2009/2010; 125
in 2010/2011.
Emission rate from old woodburners and open fires is 9g/kg.
Emission rate from multiburners is 22g/kg.
Emission rate from new woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
Replacement uptake: 221 homes to compliant woodburners, 32 to pellet fires, 63
to heat pumps (based on Clean Heat Project 2007-2008).
1200 kg/year of wood is used per burner.
The conversion cost of one house is approximately $3800.
Funding of $150,000 - $200,provided each year (matched 1:1 by EECA).
Discussion
The Clean Heat Project has been set up specifically to assist regional councils with
clean-heat conversions. Greater weighting is given to the worst airsheds, where there
are more health issues, with Rotorua the sixth-worst airshed in the country, and the
worst in the North Island. There is a large proportion of low-income families living within
the airshed that are unlikely to afford a heating conversion without a high level of
subsidy. By taking advantage of this funding, these conversions occur at half the
normal cost.
Environmental benefits are minimal, with about 100 houses being converted every
year. The total particulate reductions over the whole course of funding will amount to
only 3 tonnes (the removal of at least 60 tonnes of particulates a year is the desired
outcome of the Action Plan).
But every reduction is helpful, particularly if it is for a reduced cost. Therefore it is
recommended that an application for this fund is made for each year that the funding is
available.
Recommended Action:
4.3.3
Apply for EECA funding for the Clean Heat Project.
Option L – Offer a Loan on Rates to Middle-income Households
This option proposes to pay for the replacement of solid-fuel burners in middle-income
homes. Homeowners then repay the loan through an appropriate mechanism, such as
rates, over an extended time period (e.g., 10 years).
Best practice
Environment
Canterbury
Nelson City Council
Tonnes
removed
13 tonnes
Costs
$/tonne
Links
$7.7 million
$592,308
E, F, G,
($1.8m in interest;
($138,462 non- M, N
$5.9m
capital recoverable)
recovered over time
via rates)
Assumptions










Approximately 2127 solid fuel burners in middle-income houses.
An estimated 70% of eligible houses would apply for this incentive (1489
houses).
Emission rate from old woodburners and open fires is 9g/kg.
Emission rate from multiburners is 22g/kg.
Emission rate from new woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
Replacement uptake: 670 homes to compliant woodburners, 149 to pellet fires,
670 to zero-emission appliances.
1200 kg/year of wood is used per burner.
Capital conversion cost for one house is about $4000. but will be recovered in the
long term.
Interest costs per house is approximately $1200.
Discussion
Homeowners who take advantage of this loan receive an efficient appliance
immediately, which decreases heating costs. The loan can then be paid back over
time, easing the burden of changing their appliance. There are social benefits from
clean heat and healthier homes that extend beyond a reduction in air pollution.
The initial financial outlay for this option is significant, and if the councils were to take
out a loan to cover the capital cost there would be interest costs involved. While most
of the finances will be recovered in the long term, during the time that it is tied up in this
project, the money is not available for other tasks. However, the environmental benefit
of removing 13 tonnes of particulates is significant. If combined with a rule to enforce a
change of heating method, the uptake would likely be even greater and the benefits
more pronounced.
Although middle-income earners are among those most likely to be able to take
advantage of this incentive, this option could also be extended to include all private
homeowners (up to middle income) within the airshed.
It is recommended that Option L be included in the Action Plan.
Recommended Action – Offer a loan on rates to private homeowners.
4.3.4
Option M – Offer a Loan on Property to Households
This option would involve the council providing homeowners with the capital to upgrade
their burners immediately. The cost is then recorded as a debt on the property. No
money is required until the property changes ownership (or after a set period of time).
Best practice
Nelson City
Council
Tonnes removed
11 tonnes
Costs1
$8.8 million
$/tonne
$800,000
($2
million
in ($181,818
interest ;
recoverable)
$6.8 million capital
recovered over time
via rates)
Links
B, E, F, G, J, K,
L, N, U
non-
Assumptions









Approximately 20% of all houses with solid-fuel heating will apply for this
incentive (1710 households).
Emission rate from old woodburners and open fires is 9g/kg.
Emission rate from multiburners is 22g/kg.
Emission rate from new woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
Replacement uptake: 770 homes to compliant woodburners, 170 to pellet fires,
770 to zero-emission appliances.
1200 kg/year of wood is used per burner.
The capital cost for one house is about $4000, but will be recovered in the long
term.
Interest costs per house is approximately $1200.
Discussion
Many homeowners may not be in a position to convert heating methods using any of
the other incentives, and the elderly are one group who would benefit from this
incentive, tending to have mostly fixed assets, such as owning the house that they
occupy. Converting an appliance is expensive and they have few funds available, even
for a loan on rates as discussed above. This option provides immediate capital for the
appliance to be upgraded, benefiting the whole community. Properties tend to increase
in value over time, while the loan amount remains the same (dependent on whether
interest is to be charged). Therefore, when the property is sold, the owner is in a better
position to repay the capital.
As in Option L, the initial financial outlay to fund this option is significant. While the
capital will be recovered in the long term, during the time that it is tied up in this project,
the money is not available for other tasks. However, the environmental benefit of
removing 11 tonnes of particulates is significant. If combined with a rule to enforce a
change of heating method, the uptake would likely be even greater and the benefits
more pronounced.
It is recommended that Option M be included in the Action Plan.
Recommended Action:
4.3.5
Offer delayed rates repayments to householders.
Option N – Apply for EECA Funding for EnergyWise Project
EnergyWise is a project that invites financial partners to offer interest-free loans to
middle-income earners to convert to clean heating. EECA pays the interest component
of the loan, up to $1200 per house, while the financial partner provides the capital for
the conversion, and recovers the debt over time.
Best practice
Tonnes
removed
Energy Options 4 tonnes
Costs
$/tonne
$1.6 million
$400,000
recovered via
rates
(EECA provides
$490,000
in
interest costs)
Links
B, E, F, G, L,
M, U
Assumptions









2127 middle-income households with solid-fuel burners.
Of the households eligible, 20% estimated to apply for this incentive (425
homes).
Emission rate from old woodburners and open fires is 9g/kg.
Emission rate from multiburners is 22g/kg.
Emission rate from new woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
Replacement uptake: 191 homes to compliant woodburners, 43 to pellet fires,
191 to zero-emission appliances.
1200 kg/year of wood is used per burner.
The cost for one house is about $4000, but will be recovered in the long term.
Discussion
Central Government has made $26 million available nationally for interest-free loans
via the EnergyWise Project.. This fund is different to the Clean Heat Project where a
limited amount of money is available each year and allocated to specific areas and lowincome households only.
The assumption that only 20% of all middle-income houses would apply for this
incentive is conservative. A rule that required the upgrade of certain appliances would
increase the uptake of this incentive. Even if the uptake were increased to 100%, the
interest costs required from EECA would amount to only $2 million (2042 houses at
$1200 each). There is no reason why Rotorua could not obtain this level of funding for
this incentive.
While capital is required to kick-start the process, this money is eventually repaid by
the community. With Central Government paying the interest costs, this option
effectively costs nothing. If uptake was increased to 100% then up to 20 tonnes of
particulates could be removed from the airshed for little more than administration costs.
It is recommended that Option N be included in the Action Plan.
Recommended Action:
4.3.6
Apply for EECA funding for EnergyWise Project.
Option O – Offer Incentives to Landlords
This option would offer landlords a 50% subsidy to convert solid-fuel burners to cleaner
heating appliances.
Best practice
Environment
Canterbury
Tonnes
removed
21 tonnes
Costs
$/tonne
Links
$4,700,000
$223,810
B, E, F, G, J, K,
L, M, N, U
Assumptions








2323 homes not owned by the resident but privately owned.
Emission rate from old woodburners and open fires is 9g/kg.
Emission rate from multiburners is 22g/kg.
Emission rate from new woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
Replacement uptake: 1045 homes to compliant woodburners, 231 to pellet fires,
1045 to zero-emission appliances.
1200 kg/year of wood is used per burner.
The subsidy would be 50% of the total cost of conversion ($2000).
Discussion
One-third of all homes in Rotorua are privately owned but not occupied by the owner.
Because landlords are not directly affected (and most likely due to the significant costs
of converting appliances) there is little incentive for landlords to replace ageing solidfuel burners with cleaner heating methods. This has a direct impact on the tenants,
who have to endure inefficient, potentially expensive heating. These tenants are often
lower-income families who may already have poor health. Targeting landlords with a
specific subsidy is one option suggested to encourage clean-heat conversions.
The implication of this option is that public funding is being provided for private
homeowners to upgrade their property. While every incentive is essentially doing this,
using the money to improve an investment property (as opposed to the house that the
owner is actually living in) makes this incentive less palatable.
However, with such a large proportion of houses owned by those that do not live in
them, some form of incentive should be offered to encourage conversions. A
compromise is to allow landlords to be eligible for the interest-free packages as
proposed by the options discussed above.
Recommendation:
4.3.7
Do not pursue this action further at this stage.
Option P – Offer Incentives for Housing New Zealand Corporation Houses
There are 600 HNZC houses within the airshed, many of them aged and containing
open fires or inefficient woodburners. Environment Bay of Plenty has recently worked
with HNZC to co-fund the replacement of woodburners with pellet fires in 10 homes.
There is the potential to follow this up with a similar programme. This option proposes
to fund 50% of the conversions necessary in all HNZC houses.
Best
practice
None
Tonnes
removed
4 tonnes
Costs
$/tonne
Links
$1 million
$250,000
B, E, F, G, U
Assumptions









600 homes within the airshed owned by HNZC.
90% of HNZC homes have solid-fuel heating (540 homes).
Emission rate from old woodburners and open fires is 9g/kg.
Emission rate from multiburners is 22g/kg.
Emission rate from new woodburners is 4.5g/kg.
Emission rate from pellet fires is 1.4g/kg.
Replacement uptake: 270 homes to compliant woodburners, 270 to heat pumps.
1200 kg/year of wood is used per burner.
The subsidy would be 50% of the total cost of conversion ($2000).
Discussion
The benefits of this option are providing improved heating and lower heating costs to a
section of the community that is financially disadvantaged. However, for many of the
same reasons why it is not considered suitable to fund landlords to improve their
properties, it is also inappropriate to use ratepayers’ money to upgrade Central
Government property. HNZC has in place a programme to insulate its housing stock
nationwide. A corresponding programme to upgrade heating appliances will follow on
from that. It is felt to be the responsibility of Central Government, not local government,
to fund this project.
Recommendation:
Do not pursue this action further at this stage.
4.4
Emission Reductions – Industry
Large-scale industrial discharges (those that require a discharge permit) make up 24%
of the particulate emissions within the airshed. Two sawmills (McAlpines and
Tachikawa) are the biggest contributors, making up almost all of the 24% attributed to
industry. Both these mills are in the eastern sector of the airshed, so the effects of any
emissions reductions will be localised.
Modelling indicates that even if all industrial emissions were to cease, domestic
emissions alone would still breach the standard. However, it is not fair to ask private
homeowners to convert their appliance at considerable cost, while industry continues to
use aged, inefficient equipment. Air quality is a community issue, and needs to be
addressed by all members, including industry.
A recent emissions evaluation of the major industrial sources was carried out by a
consultant to Environment Bay of Plenty. Suggestions for reducing the amount of
particulates discharged into the airshed ranged in effectiveness and expense as shown
in the table below.
Solution
Improved fuel management
and combustion monitoring
Upgrading multicyclones
Installing electrostatic
precipitators
4.4.1
Tonnes
removed
4-12 tonnes
Estimated Cost
$/tonne
$50,000
$12,500 - $4167
15 tonnes
73 tonnes
$200,000
$1 - 2 million
$13,333
$13,697 - $27,397
Option Q – Review Resource Consent Conditions for Major Industry
This option recommends that resource consent conditions for the two main industrial
contributors of particulates (McAlpines and Tachikawa) are reviewed (via the Resource
Management Act process). This review of conditions could include requirements to
carry out any of the three reductions options. Particulate concentrations and mass
emission rates can be revised and adjusted to require industry to reduce overall
emissions.
Discussion
When the air discharge consents were approved, there was no gazetted airshed in
Rotorua.
But starting a consent review and requiring large-scale changes to particulate-control
equipment will create tension between the councils and industry if not approached in
the right manner. While a review of consent conditions may eventually be required to
enforce the changes, this process can be initiated after discussions. Councils can work
together with industry to ensure a solution is reached that is beneficial to all parties.
It is recommended that Option Q be included in the Action Plan, along with a
recommendation to engage with industry.
Recommended Action:
Engage with industry regarding emission reductions
and review resource consent conditions for major
industries.
4.4.2
Option R – Provide a Consultant for Major Industry
The emissions evaluation of the industrial consents was done by an external consultant
with expertise in air-quality discharges, although the evaluation was intended to be a
brief summary of all discharges in the airshed, not a detailed assessment of each one.
This option proposes to provide a consultant for McAlpines and Tachikawa to evaluate
the air-discharge aspects of the process, and give a detailed analysis of how systems
can be improved. This will then be used to review the consent conditions as proposed
by Option Q The cost of a consultant is estimated to be $5,000 for each sawmill (a total
of $10,000 for both).
Discussion
Although private businesses will receive financial support from the councils, the total
cost is minimal. The environmental benefits from clearly identifying potential
improvements in particulate management outweigh the costs. Many private
homeowners work at the sawmills, and it is in the interests of the community to ensure
the continued viability of the sawmills in Rotorua.
It is recommended that Option R be included in the Action Plan.
Recommended Action:
4.4.3
Provide a consultant for major industry.
Option S – Provide Cash Incentive to Industry to Upgrade Equipment
Once the consultant’s report (from Option R has been completed, there is the
possibility of providing financial support to industry through a one-off cash incentive for
improved equipment. This ranges from a medium-cost option, such as upgrading
multicyclones, to installing electrostatic precipitators. The approximate cost (for both
industries combined) ranges from $400,000 - $2 million.
The installation of better technology may reduce the particulate discharge to a fraction
of current levels. Electrostatic precipitators, in particular, wouldl remove almost all of
the industrial contribution to the airshed.
Discussion
Although the environmental effects are significant, potentially removing more tonnes of
particulates than is necessary to solve the problem, the effects are localised. Even with
the removal of all the particulates from industry, the airshed will exceed the standard
from domestic emissions alone.
Ensuring that the sawmills remain viable is a positive investment in terms of providing
emplyoment to the wider community. However, with the localised environmental effect
that it will have, the funding for this option may have more effect if spent elsewhere.
This is an option that should be considered in the future to help reduce emissions in
this sector of the airshed if required.
Recommendation:
Consider providing a cash incentive to industry to upgrade
equipment, as a contingency action.
4.5
Option T – Dry Wood
The burning of wet wood causes an increase in particulates from domestic
woodburners. This option includes initiatives to ensure that most homeowners in
Rotorua use dry wood in their woodburners. Initiatives include:





Good Wood Scheme; merchants that guarantee dried, seasoned wood are
endorsed by the councils
Design a Wood Shed competition
Buy your Wood Early campaign
Require a wood shed with all new installations of burners
Prohibit burning of wood with greater than 25% moisture.
Best practice
Nelson City Council
Christchurch
City
Council
Tonnes
removed
0.3 tonnes
Costs
$/tonne
Links
$100,0001
$333,333
A, B, E, F, G, J,
K, N
1 Dependent on what actions are proposed.
Assumptions






8208 homes that have solid-fuel burners.
75% of homes already use dry wood, leaving 2052 homes to be targeted by this
option.
Of those homes that burn wet wood 10% could be influenced to burn dry wood
(205 homes).
Reducing moisture content by 5% leads to 15% reduction in emissions.
Emission rate from old woodburners is 9g/kg.
1200 kg/year of wood is used per burner.
Discussion
Two-thirds of those that use solid-fuel burners in Rotorua buy their wood, which means
that by controlling the quality of wood being sold affects a good proportion of the woodburning population.
However, there is evidence that 75% of people who use wood, already burn
appropriately dry and seasoned wood. The remaining 25% of households most likely
contain many individuals who either don’t care, are not aware of the need to season
wood, or don’t have time to ensure a good wood supply. The chances that a voluntary
scheme would succeed in changing the behaviour of these people are low. A rule to
enforce the use of good wood may assist with shifting more behaviour.
Despite the low percentage of expected behaviour change, and the corresponding low
environmental success, there are simple and cheap initiatives that can be put in place
to encourage good wood supplies that do not necessarily involve regulation.
There is also an advantage in promoting good wood as a useful public
awareness/relations opportunity. As the burning of wood is at the core of the air-quality
issue this is an obvious conduit into people’s homes to provide information to firewood
users about best practice.If the need to obtain good wood is reinforced this may
encourage better behaviour in the 25% of people burning unseasoned wood.
Recommended Action:
Promote dry wood burning.
4.6
Option U – Community Awareness
This option ensures the community is kept informed of air-quality issues, incentives,
penalties and ways to improve their own home-heating methods. Suggestions include:





Community Air Quality Liaison; an employee who targets houses with smoky
chimneys and informs and educates them
Warm Homes Expo
Daily air-quality prediction
Campaign to dob in a smoky chimney/backyard burner
Buy back smoky vehicles.
The emissions reductions are estimated to be 0.5 tonnes over a 5-year period.
Discussion
It is accepted that community awareness, education, and communication is an
essential component of any Action Plan. Without community awareness of what is
being done and what incentives are available, all other actions become meaningless.
The examples given above are only a small component of the many options that could
be implemented to promote community awareness. This option requires further
development, but it is recommended for inclusion in the Action Plan.
Recommended Action:
4.7
Promote community awareness.
Option V – Infrastructure Development
This option involves looking at the potential for large-scale network infrastructure to
provide alternatives for wood-based home heating. The two most likely candidates are:


Extension of the gas reticulation system into those areas that do not already have
gas main distribution
District heating schemes based on hot-water reticulation using geothermal or
biomass energy for heating the water.
Discussion
Gas reticulation is subject to an operating market and market decisions will dictate the
expansion rate and spread of the network. There would need to be certainty around the
number of customers that would be likely to connect, and price may be an issue with
this. There is the ability to invest public funds in to a private company, such as through
a joint venture, but this is generally not an area that local authorities are comfortable
with unless there are clear social or environmental gains and where the costs (and any
inherent subsidies) are acceptable in both financial and political terms. Gas can also be
supplied through the use of bottled gas distribution.
Intuitively, Rotorua’s geothermal resource appears to be a potential replacement for
wood burning home heating. Technological advances and research into the nature of
the geothermal fields may deliver opportunities for large- and small-scale heatreticulation systems or for transfers from wood burning to geothermally generated
electricity.
Electricity generation from woody biomass offers another avenue that is currently being
explored. The location of Rotorua near forestry activities may mean that this delivers
benefits for air quality in the future.
The desire to see increases in renewable sources of energy is supported by the New
Zealand Energy Strategy (NES), and geothermal and biomass generation fit with the
aims of Central Government’.
However, significant financial resources and development lead times for any new
infrastructure are likely to exceed the timeframes for meeting the requirements of the
NES. There is a need to maintain a watching brief on infrastructure and resource
opportunities so local authorities are able to respond as appropriate (noting that there
may be a number of reasons for becoming involved – not just for air quality).
In particular, Environment Bay of Plenty has a role in understanding and managing
geothermal resources so that opportunities can be exploited. The opportunities relating
to new generation may not necessarily have a co-benefit for improving air quality and
this may need to be a link that is proactively sought through local authority
mechanisms.
Recommended Actions:
Maintain a watching brief on infrastructure and resource opportunities to enable
appropriate and timely responses.
Continue research on management of the geothermal resource and to identify
opportunities.
5
Summary of Options
Option
Description
Ai
Aii
Bi
Bii
C
D
E
Tonnes Removed
(5 years)
Ban
solid-fuel removed prevented
added
burners in new
homes
0
1
0
Restrict
solid- removed
fuel burners in
new homes
0
prevented
added
0.5
0.5
Ban new solid- removed
fuel burners in
existing homes
0
prevented
added
4.6
0
Restrict
new removed
solid-fuel
burners
in 0
existing homes
prevented added
n/a
Require solid- n/a
fuel burners to
comply with a
more stringent
design standard
than NESAQ
Prohibit
5
backyard
burning of waste
Require burner Year 1: 6.9
Costs
$/tonne
$200,000
n/a
Action
Plan

$200,000
n/a

$200,000
n/a

$200,000
n/a

$200,000
n/a

$200,000
$40,000

$200,000
$35,714

4.6
Fi
Fii
G
H
I
J
K
L
upgrade at point Year 2: 6.2
of property sale Year 3: 5.6
Year 4: 5.0
Year 5: 4.5
Average: 5.6
Phase out the 1
use of open
fires for home
heating
after
September
1,
2018
Phase out the 7
use of open
fires for home
heating
after
September
1,
2013
Phase
out 25
existing
solidfuel burners 15
years or older
Phase out all 76
non-NESAQ
compliant solidfuel burners
Phase out all 98
solid-fuel
burners
Offer subsidy to 23
low-income
households
Apply for EECA Year 1: 0.7
funding
for Year 2: 0.9
Clean
Heat Year 3: 1.1
Project
Total
2.7
Average: 0.9
Offer a loan on 13
rates to middleincome
households
M
Offer a loan on 11
property
to
households
N
Apply for EECA 4
funding
for
EnergyWise
project
(based on
average)
$200,000
$250,000

$200,000
$28,571

$200,000
$8,000
–
$200,000
$2,740

$200,000
$2,041

$10 million
$434,783
–
$555,536
$205,754

$7,7 million
$592,308
($1,8
($138,462
million
noninterest
- recoverable)
$5,9 million
capital
recovered
over time)
$8.8 million
$800,000
($2 million
($81,818
interest
non$6.8 million recoverable)
(capital
recovered
over time)
$1.6 million
$400,000
(recovered
over time –
EECA
provides
$490,000 in



O
P
Q
R
S
T
U
V
6
Offer incentives
to landlords
Offer incentives
for
HNZC
houses
Review
resource
consent
conditions
for
major industry
Provide
a
consultant
for
major industry
Provide
cash
incentive
to
industry
to
upgrade
equipment
Promote
dry
wood burning
Promote
community
awareness
Maintain
a
watching brief
on infrastructure
and
continue
research on the
geothermal
resource
21
interest
costs)
$4.7 million
$223,810

4
$1 million
$223,810

(5-73)
$200,000
Not included in total as effects
localised
$40,000$2740

n/a

0
$10,000
15-73
$400,000 –
$2 million
$5,479 –
$133,333
–
0.3
$100,000
$333,333

0.5
$100,000
200,000

N/A
Significant
n/a

Discussion
Out of the possible 22 options, 15 have been recommended for inclusion in the Action
Plan (see table below). These options are generally the initiatives that will obtain the
biggest reduction in particulates for the least financial and social cost. Using the best
estimates possible, the implementation of these options will result in a net reduction of
66.5 tonnes of PM10 from Rotorua’s airshed. The total cost is estimated to be about
$19.5 million, with $14.3 million being recovered from the community as they pay off
their debt.
The reductions that may be achieved from the industrial component are not included in
the total reductions, due to their localised effect. Despite this, the reduction by industry
will have benefits in the eastern sector of the airshed.
Overall, the estimated reductions will exceed the 60 tonnes required to comply with the
NESAQ standards. This allows for future growth, and for any inaccuracies in the
assumptions and estimates that are implicit in every reduction calculation.
Suggested Package of Options for Action Plan
Option
Aii
Bii
D
Option Description
Key Assumptions
Restrict solid-fuel burners in 90 new houses are built each 0
new homes
year
Allows only those solid-fuel
burners that comply with
national standards to be
installed
in
new
houses,
effectively banning open fires
and multiburners
Restrict new solid-fuel burners
in existing homes
Tonnes
Removed
(5 years)
Tonnes
Prevented
(5 years)
0.5
Tonnes
added
(5
years)
0.5
n/a
4.6
Costs
(5 years)
$200,000
(Total cost of options
A, B, D, E, F)
Estimated that 50% of all new
houses will install solid-fuel
burners
Estimated that 1% of all 0
households that currently do
not use solid-fuel burners
For existing houses that do not (855 houses) will look to
currently use solid fuel, any new install new burners
burner must comply with
national standards, effectively
banning any new open fires and
multiburners
from
being
installed
Prohibit the backyard burning of A total of 1892 households 5
waste
use backyard burning to
dispose of waste
Any household within the
airshed is prohibited from Of that waste, green waste
burning rubbish or green waste makes up 58% and rubbish
in their backyard
42%
An average of 220kg is
burned per house, per year
$200,000
(Total cost of options
A, B, D, E, F)
$200,000
(Total cost of options
A, B, D, E, F)
E
Fii
Require burner upgrade at point Estimated that 750 houses
of property sale
that have solid-fuel burners
are sold each year
Any house sold within the
airshed that has a solid-fuel Replacement
appliances
burner must have the burner estimated to be:
upgraded at the point of sale
337.5 to woodburners
75 to pellet fires
337.5 to zero emission
$200,000
(Total cost of options
A, B, D, E, F)
Diminishing
effect each
year due to
properties
already
affected
being resold
Average of
5.6
tonnes/year
Phase out the use of open fires Estimated that 855 homes 7
for
home
heating
after use open fires for domestic
September 1, 2013
heating
Any open fire in a house
becomes
illegal
after
September
1,
2013
(the
deadline for complying with the
national ambient standard)
K
6.9
6.2
5.6
5.0
4.5
$200,000
(Total cost of options
A, B, D, E, F)
Replacement
appliances
estimated to be:
384.8 to woodburners
85.5 to pellet fires
384.8 to zero emission
Apply for EECA funding for Estimated that 316 houses 0.7
Clean Heat Project
will be converted by this fund 0.9
over the remaining three 1.1
Requires matched funds from years that funding is available
councils
to
replace
noncompliant solid-fuel burners in Conversion cost of each
low-income houses
house approximately $3800
Funding will total $555,536
over
three
years
(with
$555,536
matched funds from EECA)
Replacement appliances over
three years estimated to be:
221 to woodburners
32 pellet fires
63 heat pumps
L
M
Offer loan on rates to middle- Estimated that 1489 houses 13
income households
will qualify and apply for this
loan
Capital is provided to pay for
the replacement of solid-fuel Cost per house estimated at
burners
in
middle-income $4000 (capital) and $1200
homes. Homeowners repay the (interest)
loan through an appropriate
mechanism, such as rates, over Replacement
appliances
an extended time period
estimated to be:
670 to woodburners
149 pellet fires
670 heat pumps
$7.7 million
Offer loan on
householders
$8.8 million
property
to Estimated that 1710 houses 11
will qualify and apply for this
loan
Cost per house estimated at
$4000 (capital) and $1200
(interest)
Replacement
appliances
estimated to be:
770 to woodburners
170 pellet fires
770 heat pumps
(capital $5.9 million
recovered over time:
Interest $1.8 million)
(capital $6.8 million
recovered over time:
Interest $2 million)
N
Apply for EECA funding for Estimated that 425 houses 4
EnergyWise project
will qualify and apply for this
loan
$1.6million
(all capital, recovered
over time)
Cost per house estimated at
$4000 (capital)
Q
R
T
Replacement
appliances
estimated to be:
191 to woodburners
43 pellet fires
191 heat pumps
Review
resource
consent A review of resource consent
conditions for major industry
conditions
may
include
requirements
to
reduce
emissions
(5-73)
Not included
in total as
effects
localised
Provide a consultant for major Cost of a consultant is 0
industry
estimated at $5000 for each
of the two major industries in
this area
Promote dry wood burning
Estimated that 205 homes 0.3
could be influenced to burn
dry wood
$200,000
$10,000
$100,000
Reducing
the
moisture
content of wood by 5%
reduces emissions by 15%
U
Promote community awareness
V
Infrastructure development.
Observe - maintain a watching
brief
on
infrastructure;
Research - continue research
on the geothermal resource
0.5
$100,000
Summary Table
Summary of Reductions
Tonnes removed
Tonnes added
Net reduction
71.7
5.1
66.6
Summary of Costs
Total Costs
Total Recoverable
Net Cost
$19,265,536
$14,300,000
$4,965,536
$/tonne
$268,696
n/a
$74,558