Table: 3.1 Auckland Regional Council – Rachael Nicoll

Comments from “Group 3 Workshop Minutes” reflect ARC’s position.

Noted.

No action.

The target audience is unclear and should clearly state its directed at skilled air quality practitioners.

Noted. To include section on target audience (cross-reference submission by Michael Farrier).

1.2 Section on “Target Audience” added.

Too much emphasis on national environmental standards (NES), need more emphasis on regional plans, e.g. the term ‘significant’ in the good practice guide (GPG) is implied in same manner as NES, but the term ‘significant’ is used differently in RMA and other regulation.

To review use of ‘significant’ and amend as necessary.

To note importance of regional plans in Assessment Criteria section.

Done – three minor changes.

Major update to Section 5. New section on regional plans added (and WHO guidelines).

Inconsistent level of detail – need more detail on ‘sensitivity of receiving environment’ and ‘details of control equipment’ etc. Should consider section on ‘risk’ assessment.

Beef up receiving environment section. Leave emergency incidents out of GPG (too specific). No to new risk section (beyond scope of GPG) – instead delete current section.

Section 4.4 on “Receiving Environment” added.

Section 8.5 was subject to considerable dissatisfaction at workshop on draft GPG. This has been largely deleted to streamline the guide.

Should provide a summary of main recommendations at the end of major sections (as per GPG Ambient Monitoring).

Yes – to do.

A new feature has been added – a brief summary ‘Recommendation’ for each section (again to be consistent with other GPGs).

2

Need new section on regional plans and policy statements.

Agree.

2.3 Section on “Regional Policies” added.

3.2
(12)

Website reference needs to be updated to 2006.

Amend link to: http://www.mfe.govt.nz/ publications/rma/everyday/ index.html.

Done.

3.2.2
(para 3)

Change “Consenting authorities will not make a decision” about notification to “must not make a decision” until all necessary info has been provided.

Check legislation before amending.

Done.

4.2

ARC considers tiered approach unnecessary and confusing. Better for all applicants to consult ARC prior to AEE. Should only be two-tiered if necessary.

Noted. Retain three tiers.

This was beyond the scope of the review, with the three-tier approach used for consistency with companion documents (eg, the GPG on transport). This has not been changed.

4.2.1

Change to only one question: “is the activity permitted or is a resource consent required?”

Noted but not applicable to other regions. Retaining three tiers – no action.

NA.

4.2.2

Need more clarity on the differences between Tier 2 and 3.

Include example provided.

4.2.4 Section on “How to decide which tier” added.

4.3

Add to list: ‘elevated background levels’ (to be more specific than ‘existing air quality’).

Agree, to amend.

Done.

4.3.1
Last sentence

Include other ambient pollutants or add reference to NES.

Agree, add NO2 for Auckland and SO2 for Marsden Pt.

4.3.1 Section on PM10 updated to incorporate new airsheds and amended to include other pollutants (mainly NO2 and SO2).

Figure 4.2

Remove table – may be used to justify lower assessment. If retained – should be modified to include two tiers with some Tier 1 should go to Tier 2: no gazetted airshed and industrial land-use (if consent required).

Noted. No action.

NA.

4.4
Last paragraph

AEE reports should include details of existing consent requirements.

Should not include approximate page number for Tier 3 assessment.

Agree, to amend.

Guide only and notes each report different. No action.

Done.

5

Update to include WHO.

Agree, to amend.

Section on WHO guidelines added.

References updated (WHO Guidelines, NSW EPA Guidelines).

5.2.1

Name the five pollutants for (Australian) national environmental protection council (NEPC).

ARC recommends factor of 50 for low and 100 for highly toxic substances.

Agree, to amend.

Agree, to amend.

Done.

6
p.35
para 3

Tier 1 unnecessary (as 4.2.1 re permitted activity). Information too complex for Tier 1 (local geography and meteorology should be Tier 2. Any activity requiring offsets go to Tier 3.

Noted.

NA.

7.3
p.41

Need more detail on background concentrations: i.e. conservatism, modelled v monitored, percentiles, average times.

Use caution with advice on double-counting.

Agree, to amend in part.

Noted.

Some minor amendments to address concerns – but major edits not attempted.

Table 7.1

Caution – concern will be used as absolute. Need more context.

Noted.

Concerns noted but decision to leave in – making it more clear that it is an ‘Example’ and a starting point, and not an absolute reference.

7.4
para 2

Treat screening methodology with caution – should use local meteorology data where available.

Include note cautioning use of screening met.

7.3.1 Paragraph added making it more clear that ‘screening’ modelling has strict limitations.

8.4.2

Suggest use Baring Head for NO2 maximum O3 (unless localised data available).

Agree.

8.4.4 Section on background air concentrations (from Baring Head) added.

8.5.2

Would like to debate 80% figure.

80% is only an indication, not a recommendation.

NA.