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Table: 3.2 Beca – Tracey Freeman

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Section

Beca summary points of submission

Review

Edits actioned

VOCs

Insufficient weight given to PM2.5. To incorporate new WHO guidelines.

Please include discussion of proportion of PM10 that is PM2.5.

Clarify where volatile organic compound (VOC) assessments necessary.

S3.1.3 should cross reference s 8.4.2.

What about 1,3 butadiene?

 

Removed “sometimes” from 3.1.3 bullet points. WHO guidelines incorporated in Section 5.

Amended.

Clarified benzene and 1,3 butadiene for major projects or where there is high background.

p 21

Spelling mistake.

 

Amended.

Section 5

To incorporate new World Health Organization (WHO) guideline for PM2.5.

 

Section overhauled to be consistent with industry GPG.

Table 7.3

Superscript typo.

 

Amended.

S 7.4.2

No data on PM2.5 – please include.

Please include WHO annual NO2 guideline in significance criteria list.

Noted.

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.

8.1.3

Query use of 20% cold start.

Query VOC evaporative assumption.

No emission factors for 1,3 butadiene.

 

Amended Section 7.2.2.

Leave this as is for now. Auckland Regional Council (ARC) will add evaporative emissions to the vehicle emissions prediction model (VEPM), which will supersede this. In the meantime these emission factors are the same as New Zealand Transport Emissions Rate (NZTER) – we don’t really know the assumptions.

Australian emission factors added to Table 8.5.

S 8.2.1, Table 8.6

Please include indicative concentrations for PM2.5 and annual NO2 in Table 8.2.1.

Include discussion assessments where NES for PM10 exceeded.

Noted.

Unfortunately, data not readily available so not included.

Transport assessments are not resource consent applications so different approach to Industry GPG. Approach has been to recommend consultation with regional council in cases where PM10 standard exceeded.

8.3.1

Should not emphasise CALINE4 transport model.

Noted. Emphasis is on practical guidance.

No action.

10.2

Paragraph ambiguous and unnecessary.

No evidence for recommendation regarding ‘at least’ equivalent be offset.

Noted. Paragraph included at user request.

This is a discussion of net increase in areas where air quality poor. Recommendation based on common sense.

No action.

NOx to NO2

Supports proposal to use 20% conversion ratio but further discussion needed.

Overtaken by submission by T Clarkson for industry GPG.

Some further discussion added regarding consistency with industry guide etc.

Long term NO2

Justification for inclusion of annual NO2.

Remove 24-hour and annual correlation.

Noted.

Amended.