2 An Overview of Response to Submissions

Formal comments were received from eight submitters, and their individual contributions have been acknowledged in the updated document. The eight submitters were:

Auckland Regional Council
Air and Environmental Services Ltd
Holcim
Kevin Rolfe & Associates Ltd
Mike Farrier Consulting
NIWA
Beca
URS New Zealand Ltd.

A number of the comments were on corrections, detail, formatting, spelling etc – these have all been addressed.

Several comments related to the overall structure of the document (for instance suggesting that the three-tier approach was not appropriate). Significant structural change to the Industry Guide would have necessitated structural change to its sister document (the Transport Guide) and is not generally favoured by the Ministry. In most cases, therefore, such structural change was not carried out.

Several comments related to specific issues for specific councils (for instance not requiring ecosystems effects analysis, or health risk analysis, or inappropriate background values). It is important to note that the Guide is a national document, attempting to cover all jurisdictions and eventualities, not just those relating to individual councils. Where appropriate an attempt has been made to further explain the reasoning behind this.

As can be expected, several comments were also at variance with each other, and with the outcomes of the public meetings and views of the Ministry. Again some attempt has been made to further explain these, but large scale edits were not made (beyond those detailed here).

A new feature has been added to both Guides – a brief summary ‘Recommendation’ for each section. This is to be consistent with other Good Practice Guides (eg, the Good Practice Guide for Atmospheric Dispersion Modelling).

Two or three submitters requested ‘more examples’. One submitter offered to provide case studies but unfortunately later withdrew their offer. Examples are valuable and some brief instances are included. The development of detailed case studies, however, requires substantial effort and validation and the results, by their nature, are region and example specific. With one exception (see below) these have not, therefore, been added.

A new section on NOx conversion has been added as an Appendix. This includes some new analysis, relevant mainly to Auckland and other major urban centres that might experience NOx issues.

2.1 Specific changes

The following changes were made to address the specific issues raised, covered by order in the document, rather than by submitter. Some comments were made by more than one submitter.

1.2 Section on “Target Audience” added.
Figures 1.1 and 1.2 amended to indicate other relevant Good Practice Guides.
2.3 Section on “Regional Policies” added.
3.2.3 “Pre-hearing” vs. “Pre-application”. All references to “Pre-hearing” clarified.
4.2 Section on 3 Tier approach. The Auckland Regional Council in particular suggested this was confusing and unnecessary. This point was accepted, and further justifications added throughout the document.
4.2.1 Some further description sought on defining what Tier 1 represents. This is regarded as potentially being too prescriptive. The current wording is adequate – although note is made in several places about early discussions with Council. More relevant in some regions than others.
4.2.4 Section on “How to decide which tier” added.
4.3.1 Section on PM10 and standards amended to include others (mainly NO2 and SO2).
4.4 Section on “Receiving Environment” added.
5.0 major update to this section to highlight importance of regional plans and give clear recommendations on order of priority of application of criteria.
5.1 Redefining ‘fine particulates’ as PM10 (consistent with Ministry for the Environment policy and to avoid confusion). Also throughout document.
5.3 Section on Regional Plans added.
5.4 Section on WHO guidelines updated for 2005 release.
5.5 International guidelines section added.
Table 7.1 Background. Submitters found this contentious. It was left in but made more clear that it is an ‘Example’ and a starting point – not an absolute reference.
Figure 7.1 Amended to indicate recent updates.
7.3.1 Making it more clear that ‘screening’ modelling has strict limitations.
8.2.1 Clarification on ‘10 years’ as ideal time for assessing trends. Emphasis on ‘ideal’, accepting that it will not be possible in many regions. It is noted, however, that more and more 10-year long records ARE available and within the lifetime of this documents there will be dozens.
8.4.2 Section on “Accumulation effects” added.
8.4.4 Section on background air concentrations (from Baring Head) added.
8.5 Section on health risk assessment largely deleted.
References updated (eg, WHO Guidelines, NSW EPA Guidelines).

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