Publications

The NZGA has made submissions to local and central government on policy relating to geothermal development and energy use in New Zealand.

Recent Submissions

Submission on expanding the purpose of existing energy levies 2016
This submission relates to consultation undertaken by MBIE on repurposing existing energy levies. NZGA supported an option that would allow EECA programmes to support direct use applications, along with adequate data capture.
Submission on Rotorua District Council Geothermal ByLaw
This submission advocated a range of measures directed at good practice, bore safety and safe environments.
Submission on Energy Efficiency and Conservation Authority (EECA) Work Programme 2016/17
This submission relates to documents found here http://www.ea.govt.nz/about-us/corporate-projects/201617-planning-and-reporting/consultation/#c15604. NZGA suggested a range of means by which geothermal energy could assist energy efficiency measures, and welcomed discussions on partnering with EECA to bring these to pass.
Submission on Health and Safety at Work (Major Hazard Facilities) Regulations Exposure Draft 2015
This submission was made in response to an Exposure Draft of Major Hazard Facilities Regulations in which revised definitions of hazardous substances led to the accidential inclusion of geothermal binary cycle plant under the major hazard facility classification.
Submission on Electricity Demand and Generation Scenarios 2015
This submission was made in response to a Ministry of Business Innovation and Employment discussion document and gave insight into how geothermal projects may actually proceed.
Submission on development of regulations related to the new Health and Safety at Work Act
This submission was made in response to a Ministry of Business Innovation and Employment discussion document on Regulations for the new Health and Safety at Work Act. Threshold levels set out in this indicates it is an error to class geothermal binary cycle plant as major hazard facilities on a threshold basis. For context see http://www.mbie.govt.nz/about-us/consultation/development-of-regulations-to-support-the-new-health-and-safety-at-work-act
Submission on the Proposed Transmission Pricing Methodology
This submission was made on the proposed new transmission pricing methodology consultation policy put forward by the Electricity Authority.  It was proposed to apply costs to generators who were not in a position to respond and this undermined value of existing and future assets (especially for merchant generators and including assets associated with Treaty of Waitangi settlements), and increased uncertainty for investors. For context see http://www.ea.govt.nz/our-work/consultations/priority-projects/tpm-issues-oct12/
Submission on the Proposed Regional Policy Statement for Northland
This submission was made on the proposed RPS for Northland, a region containing high temperature geothermal resources.  It was supportive of a number of policies, but underlined the importance of renewable energy for the region and the nation, and of infrastructure associated with Ngawha power stations.  The RPS needed further consideration of the value of the Ngawha geothermal resource, its surface features, and the use of the resource for electricity production, tourism, cultural well-being, and for other potential uses such as direct heat applications.
For context see http://www.nrc.govt.nz/newrps
Submission on Technical Guide for the National Policy Statement for Renewable Electricity Generation
This was an invited submission and was given in the form of two marked up versions (short and long) of the draft report. The long version is shown. The draft document had erroneously stepped in to policy setting and narrow definition of good field management. Very extensive changes were made to the geothermal sections of the report, while less extensive changes were offered elsewhere.
Submission on the United States Blue Ribbon Panel Geothermal Report
This was an invited submission on a report on recommended US direction in geothermal research and funding. It was recommended that attention be given to policy aspects around permitting, and market failure aspects around direct use, possibly including a low temperature programme. It supported some funding of drilling and exploration programmes while recognising that it was developers responsibility to bring projects to a decision point. The international workload was pointed out as a means of sustaining any geothermal company. Alignment with IPGT research on EGS was encouraged. We encouraged the expansion of the pool of competent personnel to achieve growth.

All Submissions

NZGA submissions are listed in descending date order in the following table and may all be downloaded.

Date Submission On Topic Type Size
June 2016 Options for repurposing of Existing Energy Levies – Submission seeking promotion of direct heat applications and adequate data capture. PDF 740KB
Mar 2016 Rotorua District Council Geothermal ByLaw – Submission on a range of good practice and health and safety measures. PDF 799KB
Nov 2015 Energy Efficiency and Conservation Authority (EECA) Work Programme 2016/17 – Discussions around the “2016/17 Appropriations, Authority Work Programme and EECA Work Programme”. PDF 154KB
May 2015 Electricity Demand and Generation Scenarios 2015 – Comments on how projects may proceed. PDF 560KB
July 2013 Regulation for the new Health and Safety at Work Act – Comments especially on ‘Major Hazards’ facilities PDF 212KB
Mar 2013 Proposed Transmission Pricing Methodology – Comments on transmission pricing in relation to generator costs. PDF 347KB
Dec 2012 Proposed Northland RPS – A submission emphasising regional geothermal assets. PDF 147KB
Aug 2012 Electricity Demand and Generation Scenarios – Comments on planned government modelling of electricity demand and generation. PDF 477KB
June 2012 NZGA Position Statement – A key document outlining broad NZGA views on geothermal development in New Zealand (updated from 2006). PDF 477KB
Feb 2012 Technical Guide NPS REG – A solicited marked draft of a technical guide to assist implementation of NPS on renewable electricity generation. PDF 729KB
Aug 2011 US Blue Ribbon Panel Geothermal Report – A solicited paper giving an NZ perspective on proposed US geothermal funding. PDF 131KB
July 2011 Proposed Waikato RPS – A structured further submission reinforcing earlier points. PDF 148KB
July 2011 IPGT Exploration Paper – A solicited support paper. PDF 111KB
May 2011 Proposed Bay of Plenty RPS – A structured further submission reinforcing earlier points. PDF 215KB
May 2011 Proposed NPS on Indigenous Biodiversity – A paper calling for caution because of unintended effects. PDF 172KB
Mar 2011 IPGT High Temperature Downhole Tools paper – A solicited supportive paper with some practical advice. PDF 129KB
Feb 2011 Environment Waikato Draft Regional Policy Statement – A broadly supportive paper. PDF 120KB
Feb 2011 Bay of Plenty Draft Regional Policy Statement – This referred back to the earlier paper and sought alignment with EW Operative RPS. PDF 81KB
Sept 2010 NZ Energy Strategy / Energy Efficiency and Conservation Strategy – A generally supportive submission but noting the lack of substance. PDF 151KB
Aug 2010 Climate Change Regulations Amendment – Supportive submission but advocating greater rigour in wording and justification. PDF 128KB
July 2010 International Partnership on Geothermal Technology – Unsolicited letter supporting NZ joining this leading-edge geothermal research partnership. PDF 19.5KB
Apr 2010 MED Geothermal Barriers Paper – A dialogue with MED on geothermal barriers. PDF 192KB
Mar 2010 Environment Bay of Plenty Regional Policy Statement – This submission emphasised the key role of geothermal energy as an energy source to be encouraged. PDF 316KB
Oct 2009 Climate Change Response (Moderated Emissions Trading) Amendment Bill 2009 – NZGA was concerned about dilution of price signals under the amended ETS. PDF 132KB
Sept 2009 Draft Climate Change Regulations 2009 details – This submissions addressed specific issues related to thresholds to avoid capture of non-industrial direct use, and to default emissions factors. PDF 149KB
July 2009 Draft Climate Change (Stationary Energy and Industrial Processes and Unique Emissions Factor) Regulations 2009 – NZGA comments on specific provisions mainly focused on the need for thresholds (and impacts without these) and unreasonableness of general default emissions factors and of the associated price signals being sent. PDF 214KB
Dec 2008 Draft Climate Change (Stationary Energy and Industrial Processes) Regulations 2008 – NZGA comments on specific provisions mainly related to geothermal measurement aspects. PDF 69.3KB
Oct 2008 NPS on Renewable Electricity Generation – Comments on the Government’s draft National Policy Statement related to renewable electricity. PDF 95.8KB
Mar 2007 NZES, TM and NZEECS – Combined submission on government energy and climate change policy frameworks. PDF 106KB
Dec 2006 PCE Questionnaire – Response to a PCE questionnaire on renewable energy and energy efficiency. PDF 60KB
Mar 2006 Transmission National Policy Statement – Comments on the proposed National Policy Statement and National Environmental Standards related to transmission PDF 117KB
Feb 2006 Geothermal Well Taxation – NZGA submission on treatment of geothermal wells for taxation purposes. PDF 110KB
Feb 2006 NZGA Position Statement – A key document outlining broad NZGA views on geothermal development in New Zealand. PDF 222KB
Feb 2004 Waikato Regional Plan – Statement of Evidence for the proposed Waikato Regional Plan and Regional Policy Statement. PDF 90KB
May 2003 Waikato Regional Plan – Comments on the geothermal sections of the proposed Waikato Regional Plan and Regional Policy Statement. PDF 61KB
May 2003 EECA Renewable Energy Program – NZGA submission to EECA proposing key target market activities to increase the uptake of renewable energy produced by the Geothermal sector. PDF 133KB
May 2003 Commerce Committee Inquiry into the Electricity Industry – Submission on the Commerce Committee Inquiry. PDF 39KB
Sept 2002 Bay of Plenty Regional Land and Water Plan – Further Submission on Bay of Plenty Regional Land and Water Plan. PDF 15KB
June 2002 Draft National Energy Efficiency and Conservation Strategy – NZGA Further Submission on the Government Draft National Energy Efficiency and Conservation Strategy. PDF 17KB
May 2002 Bay of Plenty Regional Land and Water Plan – Submission on Bay of Plenty Regional Land and Water Plan. PDF 14KB
Dec 2001 Draft National Energy Efficiency and Conservation Strategy – NZGA Further Submission on the Government Draft National Energy Efficiency and Conservation Strategy. PDF 15KB
Dec 2001 Draft National Energy Efficiency and Conservation Strategy – Initial submission on Draft National Energy Efficiency and Conservation Strategy. PDF 11KB
Dec 2001 MfE: Climate Change – Submission on Climate Change to the Ministry for the Environment PDF 15KB
Nov 2001 Post Winter Electricity Review – Submission on Post Winter Electricity Review. PDF 32KB
May 2001 Draft National Energy Efficiency and Conservation Strategy – NZGA Submission on Draft National Energy Efficiency and Conservation Strategy. PDF 22KB
June 2000 MfE: Environmental Performance Indicators – Ministry for the Environment Environmental Performance Indicators. Proposal for Indicators of the Environmental Effects of Energy . PDF 18KB