Proposed National Environmental Standards for Air Quality

• 1 Introduction
• 2 Overview of Submissions
• 3 Detailed Submission Summary
• Appendix A: Public Notices
• Appendix B: Index of Submitters

3.5 Air toxics, especially dioxins (prohibited activities)

3.5.1 General submissions

Eighty-four percent (1203) of submissions received, the Greenpeace form submissions, support the proposed ban on new high-temperature hazardous waste incinerators. These submissions note that incineration is dangerous and outdated, it releases deadly dioxins, and alternatives to incineration exist. These submissions support the ban on new high-temperature waste incinerators, and propose that the government also ban municipal waste incineration (including waste-to-energy), ban backyard burning, ban new school and hospital incinerators outright, and phase out existing incinerators. The submissions also ask the government to take action to eliminate all dioxins from our air, land and water.

Submitter 1 queries why the burning of plastics used on farm bales are not included as a prohibited activity.

Submitters 2, 39 and 40 seek a ban on backyard burning to be included as part of the standard.

Submitters 5 and 31 oppose the prohibition of waste-to-energy plants in the standard because it would exclude the use of wood waste and other wastes in energy plants, which is a beneficial use.

Submitters 6, 163 and 174 generally support the prohibited standards but seek the banning of all forms of low-temperature incineration ("backyard" burning), with the exception of units in rural areas burning only untreated wood, vegetation and paper.

Submitter 29 wants the Ministry to consider the submitter's activities, including fire training, quarantine incineration and disposal of explosives, for which there is no practical alternative.

Submitter 43 wants all unnecessary incineration to be prohibited because industrial and backyard incineration releases extremely health-damaging toxins into the atmosphere and incinerator ashes are contaminated, causing problems when disposed of.

Submitter 46 is concerned that the standards are based on public perception, which is a major divergence from the effects-based approach used under the RMA. The submitter asks that all the standards be based on RMA effects-based principles and that references to prohibiting activities on the basis of public perception be deleted.

Submitter 65 would like to see remedies for the disposal of farm hazardous wastes and the siting of refuse sites for farm waste disposal - including tyres, coated wire and other prohibited material - before implementing the proposed standards in rural areas. The submitter considers that incineration of farm refuse, not including hazardous waste, should be allowed without resource consent.

Submitter 107 seeks incentives to encourage recycling and prevent burning of plastic wastes on farms.

Submitter 109 supports the prohibited activities in principle, but has concerns that some of the materials may be difficult to dispose of by alternative means and comments that alternatives, without significant adverse effects, need to be established. The submitter requests education to reach small communities to ensure they are aware of the standards and their implications.

Submitter 113 questions the need for the prohibited standards because most councils have prohibited activities in their air plans which emit significant quantities of toxic substances.

Submitter 120 comments that the phrase "in the open" is not clear or certain for enforcement purposes, and suggests that the phrase be defined; for example, "areas not within a specially designed and constructed combustion facility".

Submitter 121 requests that plastics, other than clean polyethylene, be considered for inclusion among the materials affected by the standard.

Submitter 123 supports the proposed prohibited activities and asks that they be retained as proposed except as they seek amendments to the section addressing school and hospital incinerators.

Submitter 125 wants waste-to-energy to be preserved as an option.

Submitter 128 comments that in order to be consistent the standards need to consider emissions from crematoria and backyard burning.

Submitter 136 wants burning waste at construction sites, including treated timber and plastic offcuts, to be added to the list.

Submitter 143 supports the adoption of prohibitive standards and the principle of banning activities that are toxic and unnecessary. However, for activities that as yet cannot be substituted, such as crematoria and metallurgical processes, the submitter asks that standards based on the best available techniques be put in place.

Submitter 143 also asks for:

• a ban on outdoor burning of waste (excluding vegetation, untreated wood, paper and cardboard)
• education material to be developed on the health and environmental effects of burning waste in outdoor fires
• a ban on municipal waste incineration, with particular reference to waste-to-energy incineration.

Submitter 154 supports the proposed standards in this section and asks that they be retained.

Submitter 162 opposes the prohibited activity status because it is an extreme resource management method and should only be used when the effects are so severe that the activities should not occur under any circumstances. The submitter seeks a review of whether the prohibited activity status is an appropriate mechanism to manage the effects on the environment.

Submitter 171 supports the intention of the majority of the proposed standards but seeks clarification on how they will deal with other air toxics for which ambient air quality guidelines were set in 2002.

Submitter 173 seeks a ban on backyard burning to be included as a national standard.

Submitters 11, 174 and 206 support the proposed standards.

Submitters 36, 75, 100, 187, 148, 202 and 221 support the proposed standards in sections 3.2.1 to 3.2.7, except that submitter 202 opposes proposed standard 3.2.6 and submitters 75, 100 and 187 oppose proposed standard 3.2.7.

3.5.2 Proposed prohibited standards

Open burning of tyres

The 1203 Greenpeace submissions support the prohibition on burning tyres.

Submitters 31, 11 and 127 support the prohibition on burning tyres.

Submitter 68 wants it to be made clear in the regulations that councils could consider disposing of tyres through an appropriately designed pyrolysis plant.

Submitter 120 suggests that the standard be reworded to incorporate "tyres and other rubber".

Submitter 143 supports the ban on the open burning of tyres and wants the ban extended to burning tyres in cement kilns because of concern over dioxin emissions and because "true" recycling of tyres is much more energy efficient.

Road-seal burning

The 1203 Greenpeace submissions support the prohibition on road-seal burning.

Submitter 85 wants the term "bitumen burning" to be substituted for "road-seal burning", and requests a lead time of at least 12 months before the prohibition takes effect.

Submitters 31, 111, 127 and 143 support the prohibition on road-seal burning.

Submitter 177 supports the prohibition of road-seal burning, but wishes to include an exemption for if (or when) future technology is available that is capable of reducing emissions to an acceptable level.

Submitter 186 is concerned about the standard because road-seal burning has traditionally been an important part of road maintenance, it lasts for short periods, and occurs in restricted areas at most every 15 years. The submitter considers that considerable costs could be added to road maintenance as a result of the ban.

Coated-wire burning

The 1203 Greenpeace submissions support the proposed ban on coated-wire burning.

Submitters 31, 127 and 143 support the standard, but submitter 31 also wants the ban to be extended to include "motor vehicles or parts of motor vehicles, or any other mixture or combinations of metals and combustible substances", other than in a proper incineration facility.

Submitter 175 questions the basis for banning only plastic-coated wire and not other material that can result in dioxins, such as burning copper chrome arsenic timbers, car bodies and machinery, and considers the approach to be inconsistent. The submitter wants criteria to be established for identifying those air toxics that are to be banned, and these criteria used to list activities in the standard that are banned.

Burning of oil in the open

The 1203 Greenpeace submissions support the prohibition on burning oil in the open.

Submitters 2, 75 and 111 support the standard but request that provision be made to burn oil in the open for fire-training purposes and special effects for films.

Submitters 31 and 127 support the standard.

Submitter 113 considers that national standards are not required for this activity and is concerned about statements in the proposed document such as "there is a limited amount of information available on the amount of oil burned in the open air in New Zealand and its potential health effects" and "alternative methods for frost protection are available". An analysis of the options for frost protection is required because they all have varying environmental effects, costs and effectiveness. The submitter is also concerned that there is no quantification of the terms "temporary activities", "populated areas" or "adequate controls", and considers that burning oil for frost protection should be able to be assessed via the resource consent process to allow consideration of the local situation.

Submitter 120 requests that oil burning in "frost-pots" for frost protection be excluded from the prohibited activity, or that a phase-out approach be considered.

Submitter 121 requests that the Ministry allow clean burning of new oil for frost fighting on production land.

Submitter 143 supports the ban on open burning of oil and wants the ban extended to burning in cement kilns because of concern over dioxin emissions and because "true" recycling is much more energy efficient.

Submitters 169 and 209 request that a provision allowing open oil fires for fire-training purposes be included in the standard.

Submitter 202 requests that provision be made for burning oil in smoke pots or similar devices for frost protection, and that this be made a discretionary or restricted discretionary activity.

Landfill fires

The 1203 Greenpeace submissions support the proposed standard.

Submitter 109 generally supports the standard and comments that the emphasis on "known burning" of material is appreciated because such fires can occur by accident.

Submitter 113 considers that a definition of landfill is required to ensure that on-farm burning of waste plant material is not included.

Submitters 31, 111, 127 and 143 support the standard.

Submitter 175 considers it is uncertain what "known" burning and "near a landfill" might mean and seeks clarification of these terms.

Waste incineration in schools and hospitals

The 1203 Greenpeace submissions consider that all new school and hospital incinerators should be banned outright. The submissions note that low-temperature incinerators are just as toxic as the bigger high-temperature incinerators. The submissions request that the government phase out all incinerators that are currently polluting our environment by 2005.

Submitters 6, 163 and 174 want the standards to prohibit these units altogether and comment that allowing the units to continue to operate appears to be inconsistent with the stringent requirements being placed on domestic heating appliances. If low-temperature school and hospital incinerators are not prohibited, the submitters ask that the standards only permit these units in rural areas subject to conditions, including restrictions on the volume (less than 1 tonne/hour) and type of material that may be burnt (untreated wood, vegetation and paper only). The submitters seek clarification that regional councils can decide to prohibit school and hospital incinerators despite the standard requiring these to obtain consent.

Submitter 31 wants the scope of this standard to be clarified. The submitter would support a ban on low-temperature incineration in schools, hospitals and backyard burning in urban areas, but would not support a ban on such burning in rural areas because the level of dioxins in rural areas is low and rural people have limited options for waste disposal.

Submitter 100 considers it would be appropriate to clarify what level of dioxins would be acceptable from such facilities to assist in their assessment via the resource process.

Submitter 111 supports the standard in part but considers that it should be applied to all large-scale waste incineration, such as in hotels or marae facilities. The submitter also asks that financial provisions be available from central government to meet the costs of upgrading to meet the new requirements.

Submitter 112 supports the intention of the standard but can see difficulties with schools implementing the standard with current funding levels. The submitter comments that schools should be given additional funding for investment in the technology required to gain resource consents if it is the most appropriate option, or to fund zero waste options.

Submitter 119 wants the Ministry to contact and inform schools and hospitals about the proposed standards and assist in identifying other waste disposal options. The submitter wants the wording "encourage" to be replaced with "provide" or "ensure".

Submitter 120 suggests that references to "hospital" be replaced with a broader term such as "medical centre", which would incorporate veterinary practices.

Submitter 121 considers that the banning of school and hospital incinerators may cause practical difficulties in disposing of materials, and wants the Ministry to give consideration to practical disposal options for school and hospital waste.

Submitter 123 seeks the following alternative wording for the standard:

The proposed standard is to prohibit

• all new waste incinerators in schools and hospitals that do not have appropriate pollution controls
• by 2008, all existing waste incinerator in schools and hospitals that do not have appropriate pollution controls

Incinerators that do not have appropriate pollution controls will be required to gain resource consents to operate.

Submitter 127 requests that waste incineration at schools become a prohibited activity and that a more co-ordinated approach to air quality be adopted by central government agencies, including the Ministry of Education.

Submitter 136 supports the requirement for all operations to gain consent by 2008.

Submitter 129 opposes the standard because if school incinerators are operated in a responsible manner, burning suitable materials, then their effects should be no more than minor. The submitter considers that small-scale low-temperature incinerators should be controlled through suitable performance standards as permitted activities in regional plans. Conversely, if the request is not granted, the prohibition should apply to all low-temperature incinerators including those in industrial, commercial and residential premises.

Submitter 139 is opposed to a blanket prohibition on waste incineration in hospitals and considers that if waste incineration is carried out in hospitals it should be done to a standard appropriate for protecting the environment. The submitter wants the words "and hospitals" to be deleted from the standard.

Submitters 143 and 174 seek a prohibition on all forms of low-temperature waste incineration, including hospital and school incinerators, regardless of consent standing.

Submitter 164 requests that all new incinerators be required to conform to internationally recognised design and emission standards and that all incinerators that do not conform to the standards be phased out.

Submitter 175 considers that it appears a new incinerator can get a resource consent but an existing incinerator is prohibited, and seeks clarification of how the standard will apply to new and existing activities.

Submitter 175 considers it inconsistent to single out schools and hospitals, when low-temperature incineration is commonly used on farms, commercial properties and in some residential areas, therefore failing to create a level playing field. The submitter wants criteria to be established for identifying air toxics that require resource consent, and the criteria used to list activities under the standard.

Submitter 226 supports the standard but considers that it is inconsistent (eg, to allow backyard burning), and requests that further consideration be given to consistency over these activities.

High-temperature hazardous waste incineration

The 1203 Greenpeace submissions support the proposed prohibition of new high-temperature hazardous waste incinerators because:

• incineration is dangerous and outdated. Incinerators do not destroy waste; rather they turn waste into toxic ash, gases and harmful chemicals such as dioxins;
• incineration releases deadly dioxins. Dioxins are some of the most toxic chemicals ever made by humans, and are linked to health problems such as cancer, birth defects and endometriosis. There is no proven safe level of dioxins;
• alternatives to incineration exist. Waste should be reused, recycled, or not created in the first place. Steam sterilisation and other methods exist for dealing with medical, quarantine and other waste that cannot be reused or recycled.

The Greenpeace submissions call for the government to phase out all incinerators that are currently polluting our environment by 2005. The submissions consider that there should be a ban on municipal waste incineration, including waste-to-energy.

Submitter 1 is concerned about what processes are captured by the standard, and queries what constitutes low-temperature waste incineration: under what temperatures is it acceptable to burn waste and how is "waste" defined?

Submitter 2 is opposed to the standard and considers that applications should be able to be made via the resource consent process.

Submitters 5, 73 and 93 want the prohibition to be limited to situations where the resulting emissions do not comply with the proposed air quality standards.

Submitters 6, 163 and 174 seek a clear definition of "hazardous waste" and/or "high-temperature waste incineration" and clarification of why the proposed standards have moved away from the approach of the Dioxin Action Plan, and why the requirements of the Plan have been omitted from the standards.

Submitter 31 is opposed to the standard, which would capture existing incinerators when their consents expire. The submitter comments that such a ban lacks technical and scientific merit.

Submitters 40, 41 and 42 support the ban on new incinerators and want existing incinerators phased out due to the health hazards from dioxin.

Submitter 46 is concerned that the standards are based on public perception. The submitter opposes the standard because it rejects not only current technology but improved future technology, and because high-temperature incineration is one of a limited number of methods to dispose of agrichemicals. The submitter want standards to be established for high-temperature incinerators rather than a prohibition.

Submitter 66 is opposed to the standard because the dioxin emissions from high-temperature incineration are very low and do not pose a risk to human health. Incinerators designed and operated to destroy dioxins created in combustion should not be included in the standard as prohibited.

Submitter 67 is concerned that high-temperature incineration is the only practicable option to manage some environmental / public health risks. The submitter wants the standard to include the option to use high-temperature incineration as a permitted activity under specified conditions (eg, during a public health emergency or emergent threat), subject to approval from the Minister for the Environment and effective emission controls.

Submitter 68 seeks clarification on what is defined as an incinerator; for example, whether this includes pyrolysis and what existing and emerging technologies are considered acceptable. The submitter considers that pyrolysis should not be prohibited under the standard because it is a cleaner method for disposing of a range of hazardous wastes.

Submitter 72 requests that high-temperature incineration be considered through the consent process to ensure that future technology can be adopted. The submitter also wants the ban to exclude the disposal of treated wood waste associated with wood-processing plants.

Submitter 75 opposes the standard on the basis that there is no environmental justification for the proposal and that the alternatives are not satisfactory, especially given there has been no risk analysis or cost-benefit analysis of the proposal. The submitter wants the definition of "hazardous waste" to be clarified, and the activity to be provided for subject to stringent conditions.

Submitters 27, 39, 69, 70, 76, 77, 78, 79, 80, 81 and 82 request that all hazardous waste incinerators, including existing incinerators and waste-to-energy, be banned because alternatives exist and the submitters are concerned about health effects of the toxic emissions from incineration.

Submitter 100 opposes the standard and the proposal to prohibit waste-to-energy because:

• thermal treatment methods offer the only practical means of destroying dioxins
• larger releases of dioxins already occur from the land application of biosolids
• there is a very low level of health and environmental effects from modern incinerators.

Submitter 100 comments that the alternative technology of autoclaving is not suitable for toxic hazardous wastes, and wants emissions standards for dioxins to be set for incineration facilities rather than banning the technology.

Submitter 109 comments that the Ministry should ensure that appropriate alternative methods of disposal are available, in particular for medical wastes. The submitter also notes that alternatives for hazardous waste are crucial because the dangers of allowing waste to persist in the environment could be worse than incineration.

Submitter 113 opposes the standard, and considers that "public concern" is no basis for prohibiting an activity because there is no quantification of whether the concern is justified or perceived. The submitter considers that public concern could be addressed via the resource consent process or a call-in by the Minister. The submitter is concerned that prohibiting such incinerators precludes the uptake of new technology.

Submitter 118 does not support the standard because modern controls are available to the extent that the effects are acceptable, and the submitter considers that the activity is best handled via the resource consent process. The submitter wants the standard to be deleted or only apply where specified conditions have not been met. If the standard is retained, the submitter requests that hazardous waste be clearly defined, crematoria clearly excluded, and a further period allowed for consultation.

Submitter 119 wants the Ministry to clearly identify what is considered to be a hazardous waste and provide justification for banning hazardous waste incineration.

Submitter 120 considers that a non-complying status would be preferable to the prohibited activity and would allow rigorous assessment of proposals on their individual merits.

Submitter 128 is opposed to the standard and is concerned that the Ministry has abandoned the original approach of establishing a discharge limit for dioxins and furans. The submitter considers that should waste currently incinerated on-site need to be transported to another waste disposal facility, that the on-road dioxin emissions from the trucks would be greater than dioxin emissions from the existing incinerator. The submitter is also concerned that the standard is inconsistent with other provisions that will allow other waste disposal activities to continue, such as the controlled burning of tyres and waste incineration in schools and hospitals. Unqualified statements on the impact of dioxins on human health need to be properly referenced and comments relating to public concerns should be contextualised or removed. References highlighting the operation of one high-temperature incinerator in New Zealand should also be removed because they are inappropriate and unnecessary.

Submitter 131 asks that consideration be given to the availability of practical alternatives to medical waste incineration, and notes that high-temperature incineration generates relatively low dioxin levels and that prohibiting this activity should be re-examined to determine whether there are satisfactory alternative methods.

Submitter 136 is concerned that the standard relates to perceived rather than real impacts and considers there to be danger in excluding future options for hazardous waste incineration and waste-to-energy plants, because these plants can be designed to perform within acceptable standards and may be the best option available.

Submitter 139 asks that new high-temperature incinerators not be prohibited activities, but if the proposal is adopted then the standard should confirm that burning biocide-treated wood residues in new heat plant and waste oil in cement kilns are not prohibited activities.

Submitter 143 wants all incineration to be banned because there are alternative technologies and the activity is inherently polluting, creating air emissions and ash residues that are highly toxic and difficult to dispose of. The submitter wants existing incinerators to be phased out by 2005.

Submitter 147 supports the standard in relation to dioxins being released to the environment and the adverse effects associated with them.

Submitter 150 opposes the standard because it will necessitate disposal of waste overseas. The submitter wants the ban to be limited to those facilities that do not comply with the emission limits that were proposed in the draft dioxin national environmental standard.

Submitter 155 is opposed to the standard, and is concerned that it is based on emotive reasoning and is not supported by current fact, science or engineering practice. Dioxins from incineration have been reduced with modern control technologies, and considers that life-cycle analysis and risk assessment should be applied to the proposal. Better definitions are required for "high temperature" and "incineration", and is concerned that the proposal will allow burning hazardous waste in low-temperature incinerators. Furthermore, clarification is needed over whether using hazardous wastes/substances in energy plant constitutes incineration. The submitter wants high-temperature incineration to be controlled under the RMA, not banned.

Submitters 151 and 160 oppose the standard because it is unnecessarily restrictive and could capture technology that is necessary and beneficial. The submitters ask that such equipment be dealt with on an effects basis via the resource consent process.

Submitter 162 seeks more detail on what processes are included in the definition of incineration and the range of materials included in the ban. The submitter wants a blanket ban on high-temperature incinerators to be removed and any prohibited activity to be restricted to wastes where incineration produces a significant amount of dioxins.

Submitter 164 requests that the ban on high-temperature incinerators be removed, that all new incinerators be required to conform to internationally recognised design and emission standards, and that all incinerators that do not conform to the standards be phased out.

Submitter 166 operates an afterburner to incinerate esters and ethers for odour control, which is effectively a high-temperature incinerator. The submitter requests that afterburners be specifically allowed for in the proposal.

Submitter 169 requests that the effects on biosecurity of banning high-temperature incinerators and the value of high-temperature incineration and other new technologies such as pyrolysis be considered. The submitter requests that "incineration", "hazardous waste" and "high temperature" be precisely defined.

Submitter 171 wants the standard to explicitly state that it does not apply to the utilisation of waste, such as waste oil, for environmentally friendly energy recovery, particularly in the manufacture of cement, because the loss of the ability to utilise such wastes would be contrary to waste minimisation and reducing greenhouse gas emissions.

Submitter 173 supports the banning of hazardous waste incineration and would also support a ban on waste-to-energy and a phase-out of existing incinerators due to concerns about the impacts of dioxin.

Submitter 175 considers the status of existing high-temperature incineration to be uncertain because the standard only refers to new facilities, and seeks clarification on how the standard will apply to new and existing activities.

Submitter 175 opposes the standard because high-temperature incineration may be the most practical method for waste disposal and the option should not be eliminated. The submitter seeks a thorough analysis of current technology, costs versus benefits and the risks of high-temperature incinerators before prohibiting them under the standard.

Submitter 182 wants high-temperature hazardous waste incineration to be a discretionary activity.

Submitter 187 is opposed to the standard because prohibiting all new high-temperature hazardous waste incinerators will create problems with the disposal of clinical, cytotoxic and quarantine waste because alternatives are not readily available. It is appropriate to prohibit high-temperature incineration for POPs, PCBs and obsolete pesticides because these incinerators are highly specialised, very expensive and inappropriate for New Zealand given the small quantities of materials requiring destruction here.

Submitter 200 opposes this standard because it is overly restrictive and not effects-based, and the technology is the only viable means of disposal for some forms of waste.

Submitter 201 opposes the standard because resource consents are currently required and this provides a mechanism that allows careful consideration of the technology and circumstances of each proposal. Blanket prohibition is unnecessary and undesirable.

Submitter 202 opposes the standard because there is no practical method of destroying persistent organochlorines other than incineration. The submitter wants strict emissions controls to be set rather than prohibiting the activity.

Submitter 208 opposes the standard because it does not suggest an alternative to high-temperature incineration and does not provide a timeframe for the prohibition. This approach discourages new clean technologies for dealing with problem wastes and may prohibit beneficial waste-to-energy projects, such as from wood waste residues, which could be classed as hazardous.

Submitter 209 opposes the standard on the basis that acceptable technologies may be developed for such waste disposal and these will be excluded by the current wording, which may put New Zealand at a disadvantage. The submitter suggests that the paragraph be reworded to include specific limits on materials or emissions.

Submitter 211 supports the banning of incineration on the basis that it makes our environment unhealthy.

Submitter 212 is opposed to the standard because there have been considerable technological advances since incinerators were identified as a significant source of dioxins. The submitter notes that the ban would mean we would lose control over the impact our hazardous wastes have on the environment when they are exported for incineration. The submitter also asks that the potential for future waste-to-energy projects not be excluded by the ban.

Submitter 213 is opposed to the standard, but if the standard is to remain the submitter requests that detailed definitions of "incineration", "hazardous waste" and "high temperature" be provided, and that these definitions be agreed with industry representatives. Banning the activity is based on emotion, is not supported by science or engineering practice, and that modern high-temperature incinerators are not a major source of dioxins. The submitter is also concerned that low-temperature incineration poses a substantially greater risk to human health and yet is not addressed in the standard. The intention of the standard is to ban only new incinerators, but the RMA treats renewals as new applications and this may trigger the ban when the submitter seeks renewal of its consent for a combustion process utilising waste oil.

Submitter 213 requests that the banning of high-temperature incineration be removed and replaced with minimum standards for emission performance irrespective of the nature of the incinerator (ie, high or low temperature).

Submitter 214 opposes the standard and wants options for thermally treating hazardous waste (such as pyrolysis) to remain provided site-specific effects criteria are met.

Submitter 218 is opposed to the standard because incineration is sometimes the only disposal option specified on some Material Safety Data Sheets. The proposed standard also closes the door on new technology, and is inconsistent because it does not ban refuse burning in the open. The submitter wants open burning of refuse to be prohibited, and high-temperature incineration removed from the prohibited activities.

Submitter 220 is opposed to the standard and the announcement that the Ministry is also considering banning incinerators for urban waste disposal, because incineration technologies continue to advance and may offer a far more acceptable solution to waste. The submitter wants energy-from-waste schemes to be encouraged rather than prohibited.

Submitter 225 seeks policy and legal clarification to harmonise the definitions of "unwanted organism" or "risk goods" under the Biosecurity Act 1993, and "hazardous waste" under the standard. The submitters also wants the definition of hazardous waste to be made environmentally meaningful rather than applicable exclusively to human and animal health.

Submitter 225 is concerned that the standard implies that medium- or low-temperature burning of infectious material would not adversely affect air quality, which is not substantiated by science. The submitter disagrees with the comment that "incineration is an obsolete technology for disposal of hazardous wastes," and notes that air curtain incinerators are an internationally accepted option for carcass disposal in the event of an exotic animal disease. The submitter also notes that the statements regarding public concern and ash residues are not applicable to the incineration of unwanted organisms. The submitter seeks a contingency clause to allow MAF to incinerate hazardous biological waste and quarantine waste where other disposal methods are not suitable.

Submitter 226 is opposed to the standard and considers that modern high-temperature incineration may have a place in the disposal of some hazardous wastes. The submitter considers that decisions should be made at the regional level via air quality plans.

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