Make a quick submission against Fonterra's coal expansion plan

Fonterra needs resource consent for the planned expansion of its Studholme plant - and because that resource consent application has been publicly notified, you get the chance to tell Fonterra that in 2015, increasing our dependence on coal and our greenhouse gas emissions just isn't on.

Submissions close at 5pm on Friday 27 November - but why wait? Get your submission in today! And if you have any questions about the submissions process, please contact

How to make a submission:

Sometimes the word “submission” can be a block to people who want to get involved in having their say on various matters as part of the democratic process. A submission is actually a simple letter containing an expression of how you feel about a subject and what you want to see happen.

Find out as much information as you can about the subject e.g. dates, outcomes, effects, others who might like to have a say, other opinions. Websites, newspaper items, advertisements and libraries are all helpful along with your personal experiences and passions.

State whether you are acting as an individual or as a representative of a group.

Divide the aspects you want to cover into paragraphs, e.g.

1. the purpose of your submission (e.g. whether you wish to oppose the project in full, or raise concerns about some aspects of it) and the reason you are making a submission.
2. any personal involvement with the topic e.g. that you live locally, reasons for visits to area, personal knowledge, why you value that area (e.g. retirement - peace and quiet), dismay at changing values of area, impact on family/ friends
3. actions you wish to see happen and reasons
4. aspects of their plans which you do not like and reasons
5. summarise your ideas
6. state if you wish to be heard at the hearing.

You can be very effective if you give reasoned arguments and state your personal experiences as opposed to form letters. It is estimated that for every person who takes the time to write there are 100 who never get around to it but have opinions similar to yours - so this is another reason to write! Your effort counts for 100 others!

Suggested submission text: 

In addition to your personal reasons for submitting, here are some points you might want to use, mainly focusing on Fonterra’s choice to use coal rather than wood. There are a few suggestions on other issues, but by no means all of them. Please add your personal comments on the issues most important to you. Unless otherwise stated, application part numbers and page numbers below relate to “Volume 1 – Assessment of Environmental Effects”, or “Vol. 1 AEE” for short.

Climate Change

Under New Zealand law, evidence about the effect of the project on climate change is inadmissible – which is crazy! That law needs to be changed, so if you think building new coal-fired boilers will be bad for the climate, please say so – even if those hearing the application are prohibited from taking that into account. However, we are allowed to talk about the effect of climate change on the project. These could include drought making the plant’s water supply problematic, sea level rise affecting the outflow pipe, and increased possibilities of flooding. You can work in these arguments under the relevant headings below.

Consideration of Alternatives (5.6)

• The applicant considered alternative sites for the plant, but it did not consider alternative methods of achieving the aims of the project, in that there is no evidence that it adequately considered using wood-only boilers. This alternative should have been considered and reported on in the application. If it was considered and rejected, detailed reasons should have been given. Therefore, the consideration of alternatives is inadequate.

• The application describes the reasons for rejecting alternative sites in insufficient detail to constitute adequate consideration of these alternatives.

Particular Regard To Use and Development of Renewable Energy

• Under the Resource Management Act (Section 7(j)), particular regard should be given to the use and development of renewable energy. This regard could have been demonstrated by selecting wood-only boilers for use in the Studholme expansion. By choosing boilers than can be run on coal, or an 80:20 coal-biomass mix, and indicating that coal is the preferred option (p. 105), Fonterra has failed to have particular regard to the use and development of renewable energy.

Air Quality (5.5.5), Dust (3.5.3), and Public Health

• Coal dust is bad for human health. Fonterra should not be increasing the coal dust hazard by building new coal boilers. Fonterra lists a number of ways in which coal dust could be released at the site – e.g. filtration system (baghouse) failure or poor coal handling (p. 64). Fonterra claims that dust emissions would be limited to the site itself, but they do not provide sufficient evidence.

• Fonterra admits that many hazardous substances will be used at the expanded plant, including “diesel, diesel additive, LPG, nitric acid, caustic, hydrochloric acid, sulphuric acid and food grade caustic.” (5.6.5, p. 85). Fonterra claims that with appropriate mitigation the potential adverse effects of such substances will be “less than minor”, but it does not provide adequate evidence to support such a view.

• The emissions from burning coal are also bad for human health. Fonterra should have chosen to install wood-fired boilers instead of boilers that will run on at least 80% (and probably 100%) coal, thereby increasing emissions of such toxic chemicals, including carbon monoxide, sulphur, sulphur dioxide, nitrous oxides, arsenic, cadmium, mercury, and volatile organic compounds. Using wood rather than coal would reduce harmful emissions and pollutants.

• Fonterra admits in its resource consent application that emissions from individual boilers will sometimes exceed emission standards (p. 62), but claims that this is OK because, at other times, these emissions will fall below the standard. This ‘averaging’ approach should not be permitted.

Stormwater and Flooding (5.5.6)

• If any extreme rainfall events occur during construction of the plant extension, Fonterra states (p. 68) that stormwater above the consented limits will be discharged into Waimate Creek. This is unacceptable.

• Dust and emissions from the plant will be washed into local waterways. Given the range of toxic substances emitted when coal is burnt, this is a significant threat to public and animal health.

Landscape and Visual Effects (5.5.4)

Fonterra admits the large new structures proposed will have substantial visual impact (p. 56) and admits the new structures cannot be screened in full (p. 57). Fonterra has failed to provide sufficient mitigation for this substantial visual impact.

Economic Effects (5.5.2) – for the economists among us!

• Fonterra has failed to have regard to the potential beneficial economic effects of growth in the wood processing industry that would be caused by a decision to use wood-fired boilers, and the new jobs that would be created.

• Fonterra states (p. 53) that no externality costs arising from the incorrect pricing of utilities provided by central or local governments will apply. But it has failed to account for increasing carbon prices over the life of the project.

Wastewater Outfall (Vol. 2 AEE)

Fonterra’s proposed wastewater outfall is a long pipe that discharges to the sea (p. 43). This pipe:

• Endangers Waimate Creek.

• May be vulnerable to rupture caused by accident, vandalism or earthquake

• Is vulnerable to climate change.

With NIWA’s advice already outdated by new studies, Fonterra has failed to adequately allow for the effect of climate on this aspect of the project. 

Read the Consent Applications in full:

CRC160873 (Land Use Consent)

CRC160875 (Land Use Consent)

CRC160940 (Water Permit)

CRC160874 (Discharge Permit)

CRC160876 (Coastal Permit)

CRC160871 (Discharge Permit)

CRC160872 (Discharge Permit)

RMA150031 (RMA Continuation Application)


Submissions close Nov 27th.

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