Dioxin Action Plan

Foreword

Executive Summary

Introduction

Taking Action on Dioxin

Why We Should Take Action

Sources of Discharges to Air

Actions for Waste Disposal Sources

Actions for Other Sources

Application of Actions

Appendix 1

Appendix 2

Appendix 3

2 Taking Action on Dioxin

2.1 An international commitment

International concern about organochlorines has increased steadily since the early 1970s. Most developed countries have taken a variety of initiatives to deal with environmental problems caused by these chemicals.

In 1997 the United Nations Environment Programme (UNEP) began work on developing an international legally binding instrument on certain persistent organic pollutants (POPs), including dioxin. An intergovernmental negotiating committee has drawn up a convention, the Stockholm Convention, which New Zealand signed in May 2001. This convention requires that each signatory develop an action plan for dioxin. The action plan is to contain both techniques and environmental practices that are the 'best available'.

'Best' is defined as "most effective in achieving a high general level of protection of the environment as a whole".

'Available' is defined as meaning "those techniques that are accessible to the operator and that are developed on a scale that allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and advantages".

The recommendations made in Sections 5 and 6 of this action plan provide a basis for a major part of New Zealand's dioxin action plan, in the form of a set of initiatives consistent with the Stockholm Convention that will reduce discharges of dioxin to air.(See footnote 6) The action plan will not meet all of New Zealand's obligations under the Stockholm Convention, and other actions will be forthcoming.

2.2 Dioxin policy at a national level

Dioxin control policies, including regulation, may be set nationally by central government or regionally by local authorities. The Ministry for the Environment believes that policy instruments for controlling dioxin should be adopted at a national level for the following reasons.

• Movement of dioxin across regional boundaries: The pathways by which dioxin finds its way into human tissue cross regional boundaries. People can be exposed by drinking milk and eating meat from distant farms where dioxin discharged to air has been deposited on to pasture.
• The effect on trade and tourism: Our agricultural exports are labelled 'from New Zealand' and their quality reflects on the entire country. New Zealand's relatively clean environment has economic value, which we must protect.(See footnote 7) Our clean green image is a national image.
• Action on an international stage: New Zealand's commitment to the Stockholm Convention means that leadership needs to be shown at a central government level to ensure the country is well prepared and able to meet its international obligations on POPs.
• The costs of policy-making: The control of dioxin is a complex matter, and the costs of evaluation and decision-making are high. One national policy-making exercise is much cheaper than many regional policy-making exercises. As well as improved efficiency, consistency nationally will result in overall improved results.

Although it makes sense to design dioxin policy at a national level, the dioxin action plan must then be implemented by regional councils, because these agencies are responsible for controlling discharges to air under Section 30 of the Resource Management Act 1991 (RMA). In particular, councils will be responsible for monitoring and enforcing any regulatory initiatives of the action plan.

Many regional councils have already taken steps to improve air quality and environmental management practices through regional air plans. For the most part, these plans will have a beneficial effect in reducing dioxin discharges. It is desirable that the steps proposed in this action plan are not inconsistent with regional air plans.

2.3 Choosing appropriate actions

Because the sources of dioxin discharges to air are diverse, a dioxin action plan will contain different kinds of control measures or policy instruments. Six generic types of policy instruments are potentially relevant.

Some general comments on the advantages and disadvantages of the different types of policy instruments for reducing dioxin discharges to air can be made.

Do nothing

This choice should be made if the source is collectively small, or it is expected that dioxin discharges from the source are declining steadily from changes taking place for other reasons.

Monitoring and analysis

There is great uncertainty about the amount of dioxin being discharged from some sources. Information may be gathered through mandatory reporting as well as through publicly funded research. If a source is potentially large, though little is known about it, then information collection may be the best choice.

Encourage voluntary abatement

Voluntary abatement may be especially effective for sources where dioxin discharges can be reduced at relatively low cost. Greater progress may be achieved by the use of 'carrots' such as green awards and 'sticks' such as the threat of regulation. Guidelines and targets have preceded dioxin regulation in some countries, and have the cost-saving advantage of not attracting legal challenges. However, encouraging voluntary abatement for sources that are regulated in other countries will not send a strong clean green message, and may not be protective of New Zealand's economic interests.

Set upper limits on discharges

Compulsory upper limits on end-of-pipe discharges of dioxin from major point sources could be set in the form of a National Environmental Standard (NES) under the RMA. Other OECD countries have taken this regulatory approach, with waste incineration as the first priority. An advantage is that such a standard would bring New Zealand into line with our trading markets, and send an unequivocal clean green message offshore.

It is difficult to see how a compulsory upper limit on the concentration of dioxin in ambient air could be enforced. Elsewhere, such limits have been set as guidelines.

Ban certain activities

The RMA controls the discharges from an activity, rather than the activity itself. As such, activities cannot be banned. But if the dioxin discharges from an activity cannot be controlled and other activities can be substituted, it is possible - and may be appropriate - to ban the discharge from the activity altogether. An example is a ban on discharges from landfill fires. In practical terms, this amounts to a ban on the activity.

Economic instruments

In theory, economic instruments automatically generate efficient outcomes. For instance, tradable permits for discharging dioxin would lead those for whom dioxin control is expensive buying permits from those for whom dioxin control is cheap. However, neither a pollution tax nor a tradable permit system is practicable for controlling a 'trace' pollutant like dioxin.

2.4 An effective and efficient action plan

Section 32 of the RMA requires that the policy instruments chosen to reduce dioxin discharges to air be both effective and efficient. For some sources, this may mean no action at all; for others it may mean the encouragement of behaviour change through education, and for others it may mean regulation of some kind.

An action plan for reducing discharges of dioxin to air will be:

• effective if the objective of a significant reduction in the creation of dioxin is achieved
• efficient if the objective is achieved at least cost.

Assessing effectiveness

For dioxin reduction to be effective, it must be technically feasible. Which is to say, no policy instrument can be effective unless technical options for reducing dioxin discharges exist. These options may be pollution control equipment, or substitute process technologies that can replace the dioxin-discharging technologies. Checking technical feasibility is particularly important when regulation is the chosen policy instrument. Note, however, that regulation should not prescribe technical solutions.

Effectiveness can be undermined by human behaviour. For example, control technology may be installed, but operated incorrectly. Thus, monitoring will be an important component of a dioxin action plan.

The degree of confidence that the predicted effectiveness of a dioxin policy instrument will actually be realised is also important. If information about a source of discharges is poor, then predictions of reductions in dioxin from that source will be very uncertain.

Assessing efficiency

The most efficient dioxin action plan will be the one in which the benefits exceed the costs by the greatest amount. If the policy instruments to be used are not economic, some other way must be found of building in efficiency. For instance, choices about details such as allowable limits and sources covered by a standard can be made to lead to efficient outcomes.

Cost-effectiveness analysis has been used to assess a variety of technical options for reducing dioxin discharges from some major sources. The cost-effectiveness of a technical option for dioxin control is expressed as a ratio of cost to effectiveness. These ratios are measured in units of dollars per milligram of dioxin reduced. The lower the ratio, the cheaper it is to reduce dioxin discharges by one milligram, and the more cost-effective the technical option is.

Footnotes:
6 The technical reports that provide the basis for these recommendations are listed in Appendix 1.

7 A loss in revenue from selected markets of up to $569 million for the dairy sector and $938 million for the inbound tourism sector has been estimated if New Zealand's environment was seen to be degraded; Valuing New Zealand's Clean Green Image, Ministry for the Environment, Wellington, August 2001.

8 It is important, however, that the intent of regulatory intervention is for dioxin reduction, rather than simply to keep up with the quantum of international regulation.