Table: 3.7 Mike Farrier Consulting

General

Limitations of the guide need to be carefully specified.

Noted. To include section on target audience (cross reference submission by Auckland Regional Council).

Section 1.2 added.

Modelling requires data which is not often precise and assumptions need to be made. This needs to be carefully explained for those not familiar with modelling.

Noted.

The target audience for this document is now clearly explained.

Accuracy of emissions measurement does not reflect reality. Comparative measurements of mass emissions of stack testing are precise to ±15% if done by the same person, compared to ±25% if done by different people. Accuracy of measurement is likely to be of the same order. Emissions are not necessarily constant due to process variations. Vapour, which will condense as PM10, is not accounted for.

Noted. The GPG for Dispersion Modelling includes recommendation to use maximum emission rate.

Vapour condensation is beyond the scope of this GPG.

Section 8.1.2 amended to include cautionary note regarding accuracy of measured emissions data and reiterate recommendation in GPG for dispersion modelling.

Meteorological data needs to be collected over substantial time frame. Wind direction and stability vary, and these dictate where worst dispersion occur.

Section 8, p.53 includes recommendation for review of 10 years met data where available.

Good to first discuss application with controlling authority only if the authority provides site specific details. Suggest meeting of consultants and control authority promoted prior to modelling.

Already included in Section 2.4.

Highlighted in new “recommendations” section.

Caution is needed on interpretation of output data.

Agreed, the GPG reflects this (refer Section 8.6).

No action.

Recommend control authorities request monitoring at time of consent (to allow comparison of predicted with actual air quality). Accountability needs to be built into the process.

Agreed. Unfortunately, this is outside the legislative scope of this GPG.

No action.

Endorse site specific ambient monitoring, but fraught with difficulty of measurement technique / interpretation / location.

Noted.

No action.

Guide should include best practice in abatement technology. Lack of knowledge of what technology is available. Consents should lead operators to best practice. Guide should discuss importance of control technologies in detail.

Agreed. Reference to the New South Wales emissions limits already provided in section 6.2. A full reference would run to over 30 pages.

No action.

Efficiency of installed air control devices often neglected.

Noted. This is a guide for assessment, not the setting of consents.

No action.

Characterising receiving environment possibly the most important – should be an initial consideration in any assessment (not just Tier 3).

Reporting section makes it clear that this is required for all tiers.

Refer addition of “Receiving Environment” in section 4.4 in response to submission by URS.

Limitations of the AUSPLUME computer dispersion model are not often appreciated, or explained sufficiently.

Noted. The GPG for dispersion modelling has extensive discussion on this.

No action.

Do not support that industry fund a modelling study on industrial PM10 emissions from high stacks (suggested at Christchurch workshop). Suggest ministry fund a study of emitters from low stacks in rural areas – to compare the accuracy of current dispersion modelling practice.

Whilst outside the scope of this GPG the Ministry notes research of this nature is currently being undertaken.

No action.

Need information on how the METSAMP data used with AUSPLUME is best interpreted. Suggest not suitable for representing the exposure of individual receptors.

Not applicable in this GPG.

No action.

MfE should continue to work with control authorities to develop meteorological data sets.

The Ministry continues to push for this in the FRST programme (no success to date). This is beyond the scope of this GPG.

No action.

Overall

Would like to see more accountability and integrity in modelling work – the guideline should be a tool for industry, and not simply something opposing modellers can use for debating purposes.

Noted. The GPG for Modelling covers this point.

No action.