Table: 3.5 URS New Zealand Ltd – Rhys Kevern/ Andrew Curtis

General

Good background to assessment.

Section on NES too big (covered in other documents).

Noted.

Section included on request from other parties. No action.

3.2.3
(p.14 para 2)

Last sentence not clear if ‘pre-hearing’ meeting or ‘pre-application’ meeting (last sentence indicates before application).

This section about pre-hearing meetings requires clarification.

3.2.3 ‘Pre-hearing’ vs ‘pre-application’. All references to ‘pre-hearing’ clarified.

4.2.1
(p.18 para 2)

If activity permitted does not need to notify regional council – unless to confirm (i.e. certificate of compliance).

Some permitted activities require notification – but none require consent so agree that assessment not necessary.

Amended.

4.4
(p.21 para 5)

Description of receiving environment does not fit under description of proposal.

Agreed, to amend.

4.4 Section on “Receiving Environment” added.

Table 5.2
(p.24)

24 Category – people unlikely to be at schools/libraries for 24 hours.

Category applies to both 8 hour and 24 hour standards.

Some additional discussion added to make this clear.

p.27 “Offsets”

Offsets are not mitigation measures themselves.

Agreed, to amend.

Done.

5.1.4
p.28

Change ‘permitted’ to ‘allowed’ or ‘consented’ as permitted has planning connotation.

Agreed, to amend.

Done.

Table 5.4 p.29

Change ‘Chromium V1’ to ‘Chromium VI’.

Agreed, to amend.

Done.

p.32
Last paragraph

Only use WES as last resort. There are other ambient guidelines, i.e. “Texas Commission on Environmental Quality Effects Screening Levels”.

Agreed. Note, criteria section considerably changed following submission by Craig Stevenson.

Done – and highlighted in the ‘recommendations’ for the section added.

S6
pp.33–37

Tier 1 = too detailed for permitted activity – assessment should focus on conditions of the rule. Example of tyre re-treading given. Tier 2 = majority of applications where full assessment required. Tier 3 = large dischargers where there is likely significant public interest / need site specific meteorology / need ambient monitoring / calpuff monitoring.

Agreed.

Section 4.2.4 amended to clarify.

8.2.1
p.49

10 yrs of data = rare. Recent data would reflect area emissions profile, more than effect of meteorological changes.

Clarify recommendation of 10 years refers to met conditions – which should be reviewed in addition to ambient air quality data.

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.

8.4.2
p.51

Two times background too tough in New Zealand.

Clarify this is for pollutants with no data, ie, not PM10.

Done.

8.4.2
p.51

Ground level ozone only relevant for Auckland.

Noted.

This is the current thinking in 2007 – but may change within the lifetime of the GPG. No action.

8.5
p.54

Last bullet: If background levels of PM10 exceed the guideline then no consent can be granted anyway (after 2013).

This document applies to all, not just PM10.

No action.

8.5.2
p.55

Suggest include examples of use of multiple chemical exposure.

Noted.

Overtaken by removal of health risk assessment section.

Appendix 1

1: Rare to find a site with only one source, makes this form hard to use. What does ‘online’ process description mean?

2: MW/hr not a common unit – tonnes/day, units produced/day.

6: Suggest “Are the processes being undertaken in a designated air shed”.

No mention of potentially affected parties / consultation.

Noted.

Remove ‘online’

Agreed, to amend.

Agreed, to amend.

Noted – to include.

Done.

Done.

Done.

Done.