Table: 3.1 Auckland Regional Council – Janet Petersen

Target audience

The target audience is unclear and should clearly state its directed at skilled air quality practitioners (as per industry submission).

New section 1.2 added.

Consistency

Inconsistent level of detail – s8.5 too detailed/need more detail on sensitivity of receiving environment. Need consistency and more emphasis on introductory and general assessment issues.

Amended reverse sensitivity section in Chapter 6 (Tier 1) and added ‘sensitivity table’ similar to industry (Table 6.2). Amended 8.2.2 to cross ref Table 6.2.

Reduced Section 8.5 (risk) to cross reference industry guide (not as relevant to transport).

Consistency

Confusing arrangement of report especially 9. Chapter 9 useful, but a combination of issues not addressed in other parts (some sections of chapter also out of order). Chapter 9 separated from Tiered process (but relate to Tier 2 and 3).

- Suggest rearranging 8 and 9.

Removed Chapter 9. Moved assessment of community impacts to Section 4.4. Moved detailed methodology to Appendix 4. Changed order of sections where appropriate.

Tiered approach

Tiered process needs further clarification. Particularly terminology (ie, screening is used to describe both Tiers 1 and 2).

Tier 1 appears to be two separate processes.

Tier 1 changed to clarify that it is a preliminary assessment. Amended Tier 1 to clarify difference between Tier 1 assessment of projects that require further assessment and projects that do not. Amended chapter heading for Tier 2 to “screening assessment” (consistent with industry guide).

Tiered approach

Need more info about stages and timeframes of transport project and when different assessment types should be undertaken. Preliminary assessments of environmental effects should be considered at the beginning of the project.

Added paragraph to Section 4.3. Also amended Chapter 6 (Tier 1) to emphasise this.

Recommendations

Suggest summary of main recommendations at the end of major sections.

Summary added to each chapter but this includes major points only. Impractical to reflect extensive detail in summarised recommendations.

1

Need further background information for context ie,

• overall environmental effects of transport

• stages of transport project and how tiered approach works in this context

• information on regulatory framework for notices of requirement and consenting process and relationship – as this is often confusing for those not involved

• spatial effects of transport projects

• construction effects – ie, refer to dust emissions GPG

• effects of unsealed roads.

GPG for air only – no to overall environmental impacts of transport, no to spatial effects, no to unsealed roads.

Section 1.2 added to clarify target audience and explain what this document does and doesn’t do. Regarding “project stages” – other sections have been amended to clarify that preliminary assessment is at beginning of project, etc.

Added Sections 2.4 and 2.5 regarding designations and consents.

Amended Section 1.1 to cross reference GPG Dust (refer Transit comment below).

3.1.2

Last sentence not true for SO2 and NO2 – refer to Ambient Air Quality Guidelines, 2002.

Amended.

3.3

Clarify last bullet “experience of details of air quality assessments”.

Amended to “experience of what is required in air quality assessments”.

4.2.1
Tier 1

Confusing. Needs rewording to better explain purpose of quantitative and qualitative aspects.

Tier 1 amended to clarify (see comments above).

4.2.3
Tier 3

The example is more relevant to Tier 2 than Tier 3.

Example removed.

4.3

What is meant by airshed designation in this case?

Amended 4.3.2.

4.4

Difficult to distinguish ‘corridor’ v ‘community’ v ‘airshed’ effects, and should assess all anyway.

Section 4.4 deleted because this is only really relevant to Tier 3. All information is now provided in 8.4.3 and 8.4.4.

4.4

Importance of public concerns.

Noted.

5
Air quality criteria

Incorporate new WHO guidelines.

New section added. (Main section overhauled to be consistent with changes to Industry GPG.)

5.1

Needs rewording regarding “requirements for resource consents”, if “requirements” refer to the air quality guidelines should also refer to regional policies and plans.

Amended to remove reference to “requirements”.

5.3

Would be useful to name the five NEPC pollutants. Not clear what recommendation is regarding non-criteria pollutants.

Superseded by amendments for consistency with Industry GPG.

6.1

First three paragraph fit better under the main heading.

Heading 6.1.1 should be deleted.

Need an explanation of distinction between quantitative and qualitative – and when they should be used.

Note that Tier 1 can be used for comparative assessment of options prior to the final design phase of a project.

Amended.

Table 6.1

Reconsider logic behind table – some need Tier 2/3 assessments not suggested by table.

Is step 3 relevant for a screening assessment?

Effects over eight hours also important for CO.

Clarify ‘significant’.

Amended table to remove step 3 – this addresses first three points.

Table already states that if there is doubt, a Tier 2 assessment will quickly clarify what is significant.

7

Use of word ‘screening’ confusing when used for Tier 1.

Suggest using ‘conservative’ or describe the difference instead.

Amended so that Tier 1 is ‘preliminary’ and Tier 2 is ‘screening’ (consistent with industry guide).

Figure 7.1

Suggest assessing all links can be just as straightforward as ‘worst case’ – suggest adding to second box.

Highlighted “if necessary”.

Table 7.1

Request explanation of how to determine PM10 data from TSP – ARC suggest all TSP is considered PM in this case.

Request note describing composition of fleet for calculation.

Amended with footnote.

Amended – refer to Table 8.1.

7.2.3

Most assessments are for future years – suggest change to “additional future years”.

Should mention NZTER has predicted data for future years.

Amended.

7.4.2

Significance criteria given as percentage but not clear why.

Use recent WHO annual guideline for NO2.

Explained and amended so that is 5% for long term averages and 10% for short term – slightly simplified.

Annual averages not included because background work hasn’t been done (review of New Zealand concentrations etc).

Also Tier 2 is only a first order screening assessment, which is very conservative, so should be adequate to consider 1 and 24 hour at this stage.

8.1.2
Pages 42–43

Unclear recommendations (last two paragraphs of “traffic data requirements”).

Tried to clarify. Already states that analysts must use their judgement – we can’t be prescriptive because there are too many variables involved.

8.1.3

Reorder section and add subsections.

Need to note if all sections on non-exhaust emissions are based on the ARC emissions inventory.

Micro assessment not relevant or useful.

Rail emissions not relevant to GPG p.49.

Added subsections to clarify. Restructuring limited to retain consistency with industry guide.

Amended “non-exhaust emissions factors” paragraph slightly. (There is already a footnote under each table.)

This was retained because some users believe microsimulation is necessary. This is intended to clarify that it usually is not.

Rail emissions retained – GPG now “Land Transport”.

8.2.1

Monitoring should be strongly advised for Tier 3.

More discussion on background.

Last paragraph on page 53 contradicts Table 8.6.

Clarify Figure 8.2 (average of worst value in each of preceding five years).

Values in Table 8.6 so high would preclude consideration of the project.

Monitoring should be undertaken in these areas.

Content sufficient.

Inserted new sentence in first section.

Reworded last sentence of paragraph to clarify.

Amended.

Reworded slightly – “This approach is very conservative, and a more accurate assessment of existing air quality, or a health risk assessment may be required if this results in a prediction of unacceptable air quality effects”.

Amended.

8.2.2

Reverse sensitivity useful but unclear how it would be handled in practice.

The intent is to signal that reverse sensitivity should be considered.

8.4.3

Not clear when assessment of airsheds would be required.

No known New Zealand examples as yet. Amended section 8.4.4 to clarify that it is about smog/regional effects and emphasised that recommendation is to consult regional council if there is a significant net increase in emissions. Amended title.

9

“Study area” needs clarification.

Amended (now Appendix 4).

9.3.2

Why only PM10 in this section?

Amended section A4.2 to state that method may be similarly applied to other pollutants.

10.1

“Consent” should be “notice of requirement”.

Possibly check limitations on operation (example of State Highway 1).

Removed reference to consent process.

Removed comment.

10.2

More information on offsets.

Noted.

10.3

Local bylaws another option to be included.

Section 10.1 and 10.3 could be combined.

Amended to include.

Amended to combine.

11

Separate pre and post monitoring.

What to do if concentrations higher that expected.

Not considered necessary.

Not part of this guidance remit.

Appendices

Multiple comments.

Removed ‘linear extrapolation’.

Added comment regarding 20 m.

Amended table and removed text regarding five and 50 m because these have been removed from Table 6,1.

Deleted sentence. Added explanation of why information provided.

Included references to WHO review, amended comments re benzene and sulphur in fuel to reflect fuel spec review, removed comment regarding vehicles being minor contributor to SO2.

Updated to reflect NOx treatment in Industry GPG.

Typographic and technical errors

Multiple comments.

Did not delete heading 7.1 on page 31.

All other amendments made.