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2 An Overview of Response to Submissions

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

  • Auckland Regional Council

  • Beca

  • Ministry of Transport

  • North Shore City Council

  • Transit New Zealand.

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. Significant structural change to the Land Transport Guide would have necessitated structural change to its sister document (the Industry Guide) and is not generally favoured by the Ministry. In most cases, therefore, such structural change was not carried out. Requests for small or minor structural changes (eg, addition of subsections) so as to clarify and simplify the document were, however, addressed wherever possible.

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. An attempt has been made to balance these views so as to present a nationally consistent methodology that permits flexibility where needed (and justified). Additional explanatory text has also been provided to the guide for these areas.

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).

One submitter requested delayed publication so further case studies could be provided. The development of detailed case studies, however, requires substantial effort and validation and the results, by their nature, are region and example specific. This was felt to be beyond the scope of the guide and, the case studies have yet to be provided.

2.1 Specific changes

The following significant 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. Section 3 of this report provides a detailed summary of all issues raised and changes made.

  • 1.2 Section on “Target Audience” added.

  • Figures 1.1 and 1.2 amended to indicate other relevant good practice guides.

  • 2.4 Section on “Designations and Notices of Requirement” added.

  • 2.5 Section on “Land-use Consents” added.

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

  • 4.3.2 Section on “National Environmental Standards” added.

  • 4.4 Section on “Comparing Project Options” added.

  • Five major updates to this section to highlight importance of regional plans and give clear recommendations on order of priority of application of criteria.

  • 5.3 Section on “Regional Plans” added.

  • 5.4 Section on WHO guidelines updated for 2005 release.

  • 5.5 Section on “Other Air Quality Criteria” added.

  • 6 Tier 1 significantly changed to clarify, and now called “Preliminary Assessment” (consistent across both guides).

  • 7 Tier 2 now called “Screening Assessment” (consistent across both guides).

  • Table 7.1 updated with more recent data.

  • 7.2.4 Section on “Derivation of significance criteria” added.

  • Table 8.1 updated with more recent data.

  • 8.2.1, 8.4.1, 8.4.2 and 8.4.5 updated to be consistent with amendments to Industry Guide.

  • 8.4.4 Section on “Assessment of photochemical smog or other regional scale impacts” added.

  • 8.5 Section on health risk assessment largely deleted.

  • Section 9 (Assessment of Community Impacts and Comparison of Project Options) deleted with content moved to other sections.

  • References updated (eg, World Health Organization guidelines).

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