3 Individual Submissions

p 92

¼ fleet has catalytic converters. Pilot project indicates 71% (10% ineffective).

Amended Appendix 3.

Fuel spec changes

Please update changes to sulphur.

Updated Appendix 3 to reflect fuel spec reviews.

p iii, p 11

Editorial comments.

Amended.

Provisional status

Wait until June and then incorporate more case studies.

Publication delayed beyond June 2007, no case studies provided by Transit.

NB: It should be recognised that there are several parts of the guide that might need to be updated within a few years.

Updates and support

Want a web-based document that can be updated easily.

To include a FAQ section.

May present problems with users not being sure of which version is current. Happy to provide FAQ for website. Please provide questions.

Exemptions

Request explicit guidance that assessments are not required for minor works (eg, temporary diversions, maintenance works) and any project not likely to increase emissions.

Would like to add exemptions to document as examples occur.

Noted.

Please provide additional examples of suitably exempt activities.

Explicit guidance provided page 1 (bold type), section 4 (bold type) and Table 6.1.

Health risk assessments

Not comfortable with recommendation for health risk assessment, requested it be removed.

Noted.

Section 8.5 significantly reduced, but not deleted.

Non-criteria pollutants

Assessments should be limited to regional plan and NES pollutants only.

Noted. The RMA requires that assessments cover all potential adverse impacts.

Background air quality

Table 8.6 may lead to excessive process and false initial conclusions. Please remove.

Believes general issue of background air quality requires better definition. Requests FRST research be incorporated into Guide when available.

Noted. Table is considered essential to provide much needed consistency of approach in the absence of anything else.

Current guidance as comprehensive as state of knowledge permits.

Removed the word “background”, and replaced with “existing” air quality”.

Significance criteria

Expressed concerns over use of significance criteria. Please indicate values provided as provisional and indicative only.

NB: This is guidance only – all values only indicative.

The significance criteria apply to tier 2 assessments. If exceeded it is intended that a more accurate (tier 3) assessment be undertaken. The guide further states CO, NO2 and PM10 are indicator contaminants and that if the significance criteria are not exceeded, then assessment of other pollutants should not be necessary.

Section 7.4.2 “Derivation of significance criteria” added. Specifically references discussion on “reasonableness” and that they provide an indication only.

Land Transport NZ Toolkit

Please provide clearer guidance as to status and use of toolkit.

Noted. Toolkit not mentioned in GPG. Has no current ‘owner’ so not appropriate to mention in the GPG.

Construction dust

No guidance – please cross reference GPG for dust.

Amended page 1.