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New Zealand's National Implementation Plan under the Stockholm Convention on Persistent Organic Pollutants

Foreword

Executive Summary

Glossary

Part 1: Introduction

Part 2: New Zealand’s Response to the Articles of the Stockholm Convention

Part 3: An Action Plan for Dioxins and Other Annex C Chemicals

Appendix 1: Government Activity on the Stockholm Convention

Appendix 2: Government Reports on Persistent Organic Pollutants

Appendix 3: Chemicals Listed in Annex C: Definition, Risks, Toxicity

Appendix 4: Reproduction of Article 5, Stockholm Convention

Appendix 5: Reproduction of Annex C, Stockholm Convention

References

Part 2: New Zealand’s Response to the Articles of the Stockholm Convention continued

Activities relevant to managing POP-contaminated land

Guidelines

The Ministry for the Environment has published a number of good practice guidelines.  Those relevant to the identification and environmentally sound management of POP-contaminated land include:

• Health and Environmental Guidelines for Selected Timber Treatment Chemicals, 1997
• Contaminated Land Management Guidelines No. 1: Reporting on Contaminated Sites in New Zealand, 2003
• Contaminated Land Management Guidelines No. 2: Hierarchy and Application in New Zealand of Environmental Guideline Values, 2003
• Contaminated Land Management Guidelines No. 3: Risk Screening System, 2004
• Contaminated Land Management Guidelines No. 4: Classification and Information Management Protocols, 2006
• Contaminated Land Management Guidelines No. 5: Site Investigation and Analysis of Soils, 2004.
• Identifying, Investigating, and Managing Risks Associated with Former Sheep-dip Sites: A Guide for Local Authorities, November 2006.

Investigation and remediation activity

There has been significant activity by local government and industry to identify, investigate and clean-up contaminated sites.  For example, a number of councils have commenced work on a process of identifying sites that appear on the Ministry’s Hazardous Activities and Industries List (HAIL).  There have also been investigations into agricultural land historically contaminated with POPs pesticide residues (e.g. investigation of horticultural sites in the Waikato, Bay of Plenty, Auckland and Tasman regions).  The Waikato Pesticides Awareness Committee Inc investigated contaminated sheep-dip sites within the framework of a project that was funded by the Ministry’s Sustainable Management Fund.  Several regional councils have been active in promoting the investigation and remediation of timber treatment and wood waste disposal sites contaminated with dioxins, while the Auckland Regional Council has also investigated DDT and PCB seabed contamination arising from historical discharges from a dockyard.

Contaminated Sites Remediation Fund

A Contaminated Sites Remediation Fund is administered by the Ministry for the Environment to provide government financial assistance for the clean-up of high-priority sites where no party is clearly liable.  The Fund has provided NZ$6 million over three years (2003–2006) to clean-up specific contaminated sites.  In May 2006 the Government announced an additional $1.5 million each year for the next three years (2006/07–2008/09) for the Fund to continue to assist regional councils with the investigation and remediation of contaminated sites.  The first major expenditure from the fund is being used to clean New Zealand’s most contaminated site: the former Fruitgrowers Chemical Company site at Mapua, in Tasman District.  This ex-industrial pesticide manufacturing site is contaminated by DDT, dieldrin and lindane.

The Ministry for the Environment is leading the clean-up of the Mapua site in conjunction with, and with financial assistance from, the Tasman District Council.  Remediation work is progressing well using a newly developed mechano-chemical dehalogenatation process to decontaminate the soil to an acceptable level prior to its on-site reinstatement.  As of November 2006, over 5200m³ of an estimated 6000m³ of contaminated soil had been treated and reinstated.  Contaminated marine sediments located adjacent to the site are also being removed and replaced with clean material.  Approximately 1.4 tonnes of pure pesticide, including original sacks of product, have so far been discovered buried on the site.  On completion of the remediation, 40% of the land is to be set aside as public space, with the remaining area designated for residential and commercial land use.

Up to NZ$1 million per year of the Contaminated Sites Remediation Fund is allocated on a contestable basis to local government for the clean-up of high-priority sites in their jurisdiction.  Over 20 projects for the investigation, remediation planning and actual clean-up of contaminated sites have been part-funded by government, with the remaining contribution coming from local government, landowners and industry.  Some of the sites involve POPs; for example, the fund is contributing to investigations by the Bay of Plenty Regional Council and the Whakatane District Council into sites around Whakatane where dioxin-contaminated wood waste was dumped.

Other POP-related funded projects include an investigation into former horticultural areas in Auckland, site investigations into former sheep-dips on the Rarangi aquifer in Marlborough, remediation planning for a disused agrichemical contractor’s spray-shed in Christchurch, and remediation planning for a timber treatment plant in the Otago region.

Timber treatment sites

The timber industry has cleaned up several former timber treatment sites contaminated with timber preservative chemicals (including pentachlorophenol) in accordance with Ministry for the Environment guidelines.  The Ministry is continuing to monitor the risks posed by contaminants on sawmill and timber treatment sites and the need for risk management strategies.  An assessment of the likely extent of dioxin contamination at sawmill sites is contributing to a revised estimate of the national reservoir of dioxin in soils.

Tax deductions for remediating contaminated land

The Income Tax Act 2004 has been amended to facilitate and encourage clean-up and management of contaminated land.  The new legislation, the Taxation (Base Maintenance and Miscellaneous Provisions) Act 2005, was enacted on 21 June 2005.  It provides tax deductions for business expenditure related to contaminated land clean-up and management.  The amendments (now in force) have removed barriers to business spending on contaminated land clean-up and management by providing for:

• an immediate tax deduction, which is now available for restoring contaminated land (other than for land developers)
• a memorandum account, called the Environmental Restoration Account (ERA), in which site restoration and monitoring costs can be matched against prior business income.  Essentially, this means businesses can set aside money now for future site restoration, such that the cost of meeting restoration obligations in the future reduces the overall tax liability of the business in the present and there is no impact on a taxpayer’s operating cash position.

Legal framework for contaminated land management

The Resource Management Act 1991 (RMA) was amended in June 2005 in several respects that bring clarity and emphasis within a legal framework to the management of contaminated land by local authorities (including land contaminated by POPs).  The Act now includes a definition of contaminated land.  Regional councils are specifically assigned a function (section 30 [10(ca)]) to investigate land for the purposes of identifying and monitoring contaminated land, and territorial authorities are specifically assigned a function (section 31[1][b]) to control any actual or potential effects of the use, development or protection of land, including for the purpose of preventing or mitigating any adverse effects of the development, subdivision or use of contaminated land.  Territorial authorities may require that data on land contamination be collected and assessed before an application for a residential sub-division is approved.  The Ministry for the Environment has, in partnership with local authorities, prepared a guideline for the management of contaminated land information (Ministry for the Environment, 2006).

Current initiatives

The Ministry for the Environment has commenced work investigating national environmental standards under the RMA for contaminated land.  The purpose of the standards would be to provide landowners, businesses and local government with certainty about whether contaminated land is sufficiently cleaned to protect people.  The standard would specify levels of contaminants in soil (including certain POPs) that are low enough so that risks to people are acceptable, and may include a generic methodology to derive New Zealand risk-based soil values applicable to any contaminant.

The following additional guidance has been prepared by the Ministry for the Environment to facilitate the identification and management of land contaminated by POPs and other contaminants:

• Identifying, Investigating and Managing Risks Associated with Former Sheep-dip Sites: A Guide for Local Authorities, 2006.

Guidance from the Conference of Parties

As per Article 6.2 of the Convention concerning co-operation between the bodies of the Stockholm and Basel Conventions, technical guidelines have been prepared addressing the environmentally sound management of wastes consisting of, containing or contaminated by POPs and other halogenated compounds.[Two guidelines have been prepared: (i) general technical guidelines for the environmentally sound management of wastes consisting of, containing or contaminated with POPs; and (ii) technical guidelines for the environmentally sound management of wastes consisting of, containing or contaminated with polychlorinated biphenyls (PCBs), polychlorinated terphenyls (PCTs) or polybrominated biphenyls (PBBs) (refer to COP.1/INF/12.)]  Further guidance is being prepared.  Apart from constituting an information resource, parties are reminded to take account of this guidance on the environmentally sound disposal of POP waste.

A summary of obligations and measures for stockpiles and wastes

A summary of Article 6 obligations and the status of the elements supporting the measures are listed in Table 6.

Table 6: Summary of Article 6 obligations to reduce or eliminate releases from stockpiles and wastes

Article 7: National Implementation Plan

The Ministry for the Environment prepared and consulted with national stakeholders on a draft plan during 2006.  The NIP was then finalised, approved by Cabinet, and submitted to the UNEP Secretariat in December 2006.

Parties are endeavouring to integrate their NIPs into their sustainable development strategies, where appropriate.  In supporting the goal of sustainable development, the Ministry for the Environment’s Statement of Intent 2005–2008 (Ministry for the Environment, 2005a) refers to a healthy environment as a strategic priority.  Ministry work programmes that support the goal of the Stockholm Convention include the development of national environmental standards for dioxins and other air toxics, the cleaning up of the legacy of previous practices that were not environmentally sound (such as the careless handling of toxic chemicals), and work to promote the New Zealand Waste Strategy.

Article 8: Listing of New POPs

Under Article 8 of the Convention, parties can submit a proposal to the Persistent Organic Pollutants Review Committee for assessment against the screening criteria specified in Annex D.  If the Committee decides the chemical meets the criteria, a draft risk profile is prepared in accordance with Annex E.  The Committee must also take into consideration the socio-economic issues listed in Annex F in preparing an evaluation of possible control measures.  The Committee submits recommendations to meetings of the Conference of the Parties (to the Stockholm Convention).

The 31 members of the Committee representing five regions are government-designated experts on chemical assessment or management.  Australia will hold a seat on the Committee for a four-year term, being one of seven countries representing the Western Europe and Other States region.  Meetings are open to observers and are held at least once a year.  The first meeting of the Committee, held during 7–11 November 2005, initiated consideration of the following chemicals for listing in Annex A of the Convention:[Further information on these chemicals and the work of the POPs Review Committee can be viewed on the Stockholm Convention website: http://www.pops.int/.]

• pentabromodiphenyl ether – a flame retardant used mainly in polyurethane materials incorporated into upholstery and furnishings
• chlordecone – an agricultural insecticide (not registered for use as a pesticide/animal remedy in New Zealand)
• hexabromobiphenyl – a flame retardant used in synthetic fibres and plastics
• lindane – a parasiticide (presently used in a small number of products in New Zealand for the human therapeutic treatment of head lice)
• perfluorooctane sulfonate – a chemical with the property of being both lipid- and water-repellent.  It is used widely as a surface-active agent for textiles and leather products, metal plating, food packaging, fire-fighting foams, floor polishes, denture cleansers, shampoos, coatings and coating additives, in the photographic and photolithographic industry, and in hydraulic fluids in the aviation industry.

Article 9: Information Exchange

The Ministry for the Environment is New Zealand’s designated focal point for exchanging information relevant to the Convention.  New Zealand has undertaken various organochlorine-related studies over the past decade (see Appendix 2).  Reports are generally placed on the website of the agency that undertook the work.

Article 10: Public Information, Awareness and Education

The generally accepted practice underlying environmental decision-making in New Zealand is to consult with stakeholders, and provide public information through a range of media, including publications, workshops and the internet.

During the latter stages of the Organochlorines Programme, 1995–2001, public meetings were held in all regions of New Zealand to present the findings of research, promote public understanding of POPs issues, discuss issues of concern raised, and provide opportunities for public input to the development of government policy.  The practice of providing information, undertaking education and outreach activities and consulting was considered an essential part of the success of the Organochlorines Programme.  A variety of communication tools were employed, including print media (bulletins, pamphlets, lay persons’ reports, scientific reports), conference presentations, public meetings, radio interviews with visiting experts, and submissions.

Undertaking broad-scale research involved the commitment of a diverse network of scientific, technical and managerial personnel involving government and industry sectors, and the research community.  An Organochlorines Consultative Group, comprising representatives from central and local government, industry and NGOs, was established for the duration of the Programme to facilitate policy advice and stakeholder input.  Further information on the work undertaken is referred to under Article 11.

Government activity on POPs issues in New Zealand has now moved into a phase of directly implementing the measures of the Stockholm Convention (see Appendix 1).  Oversight of POPs-related programmes and interests across government is being co-ordinated by a Senior Officials Group on Organochlorines convened by the Ministry of Health.

Most recently, a pamphlet Do You Have Banned Pesticides on Your Farm? has been promoted to the rural sector.  The pamphlet outlines the legal requirements for the storage of POPs and other unwanted agrichemicals pending their collection for disposal.

The Ministry for the Environment has prepared The Users Guide to Resource Management (National Environmental Standards Relating to Certain Air Pollutants, Dioxins and Other Toxics) Regulations 2004.[See The Updated Users Guide to Resource Management (National Environmental Standards Relating to Certain Air Pollutants, Dioxins and Other Toxics) Regulations 2004 (Including Amendments 2005) (second draft), Ministry for the Environment, 2005b.]  The Users Guide provides a “plain English” description for practitioners in local government of how best to implement the regulation.  The Users Guide refers to the standards addressing dioxins and other toxics, ambient air quality, the woodburner design standard, and the control of greenhouse gases at landfills.

New Zealand does not have a national database suitable for use as a pollutant release and transfer register for POPs, because the control of releases of pollutants to the environment is administered as a regional council function.  However, the particular requirement to estimate releases of unintentional POPs, addressed under Article 5, is being undertaken at a national level.  Also, records are being kept of the quantities of POPs being collected and disposed of.

Article 11: Research, Development and Monitoring

Government reports relating to POPs are listed in Appendix 2.  A brief overview of the Government’s POPs-related research and monitoring is set out below.

Ministry for the Environment

The Organochlorines Programme in the Ministry for the Environment was set up in 1995 to establish the state of the New Zealand environment with respect to organochlorine chemicals and to identify priorities for further work.  Under the Programme, completed in 2001:

• levels of organochlorines in the wider New Zealand environment were studied
• the sources of dioxins emitted to air, land and water were identified and quantities estimated
• the levels of dioxins and PCBs in the diet of New Zealanders and the levels of POPs present in human serum were measured, and risk evaluations were undertaken.

Ministry for the Environment reports from the Organochlorines Programme can be viewed and downloaded from: http://www.mfe.govt.nz/publications/hazardous/index.html#organochlorines.

An overview of the conceptual design of the Organochlorines Programme is presented in Figure 1.

Ministry of Health

The Ministry of Health published a study in 2001 of the concentration of persistent organochlorine contaminants, including polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDDs/PCDFs), polychlorinated biphenyls (PCBs), and organochlorine pesticides in the milk of New Zealand women (Bates et al, 2001).  The main objective of the study was to investigate whether measures to reduce exposure to persistent organochlorine compounds in New Zealand had led to detectable reductions in the levels of these compounds in human milk over the period 1988 to 1998.  This research also enabled New Zealand to participate in the third round of the World Health Organization (WHO) study of levels of PCDDs/PCDFs and PCBs in human milk.

Planning for a fourth WHO-co-ordinated survey of levels of POPs in human milk is under way internationally under the auspices of the Global Environment Monitoring System / Food Contamination Monitoring and Assessment Programme (GEMS/Food).  The programme presently involves collaboration among some 80 countries.  A Ministry of Health-commissioned study that will assess the levels of POPs in breast milk in New Zealand consistent with the WHO protocols is beginning in October 2006 and is scheduled for completion in mid-2008.  The findings from this study will be compared with previous data to detect trends in POPs exposure.  The results will be shared with the WHO.

New Zealand Food Safety Authority

The New Zealand Food Safety Authority (NZFSA) runs several wide-ranging residue monitoring programmes for products of animal origin.  In addition, a New Zealand Total Diet Survey looking at the total dietary intake of key nutrients, contaminants and residues is undertaken every five or six years.  Another programme carried out by NZFSA is the Food Residues Surveillance Programme, an ongoing monitoring programme primarily for horticultural and imported produce.  The results of NZFSA’s residues testing programmes are available on the web at www.nzfsa.govt.nz/consumers/food-safety-topics/chemicals-in-food/ residues-in-food/index.htm.

Of the nine pesticide POPs specified under the Stockholm Convention, the analytical methods used in NZFSA programmes are able to test for the following seven organochlorines: aldrin, chlordane, dieldrin, DDT, endrin, heptachlor and hexachlorobenzene.  Mirex and toxaphene are not tested for in NZFSA programmes because these chemicals were never registered for use in food production.  Dioxins, furans and PCBs are not presently monitored by the NZFSA.

In the most recent New Zealand Total Diet Survey (2003/04), the only POPs detected were DDT metabolites and dieldrin, both of which arise from the historical use of these pesticides.  Dietary intake (per bodyweight) of dieldrin accounted for 4.31% of the acceptable daily intake (ADI) for the 6–12 months infants (the highest of the age/sex groups modelled).  The estimated dietary intake for the 6–12 months group for total DDT metabolites accounted for 0.43% of the ADI.  Dietary exposure of other age/sex groups was considerably less.[The ADIs for DDT and dieldrin are 10 ug/kg bw/day and 0.1 ug/kg bw/day, respectively. The source for these figures is IPCS, 2002.]

In the 2003/04 Food Residues Surveillance Programme, the only POPs found in New Zealand produce were in one sample of tomatoes, which had 0.02 mg/kg of both DDE (4,4’) and DDT (4,4’).  No POPs were found in the 2004/05 programme.  Results for 2005/06 have yet to be reported.

Department of Labour

Research into the health effects on timber workers exposed to pentachlorophenol (PCP)

The use of PCP for antisapstain and the preservative treatment of timber ceased in 1989.  Questions remain about the health effects among former timber workers resulting from their exposure to PCP.  Two years ago the Government provided funding to undertake research into the health effects of work-related PCP exposure.  The Department of Labour has commissioned an epidemiological study to clarify the health outcomes resulting from exposure of former workers to PCP in the timber industry.

The research consists of two streams:

• a historical cohort study focusing on mortality and cancer incidence
• a cross-sectional morbidity study investigating the prevalence of chronic health problems in a random sample of people who had worked in the timber industry at the time PCP was used.

The two-year study aims to ascertain whether former timber workers exposed to PCP are dying earlier, developing cancers more often, or suffering more chronic health problems.  This work is currently being undertaken by the Centre for Public Health Research of Massey University.  It involves both a mortality and a morbidity study.  It is expected that this research will be completed in the latter part of 2007.

Research into the health effects arising from dioxin exposure among former process workers at the Ivon Watkins Dow plant (Paritutu, New Plymouth) involved in the manufacture of 2,4,5-T herbicide

The manufacture of 2,4,5-T at the Ivon Watkins Dow (IWD) plant in New Plymouth ceased in 1987.  (Tetrachlorodibenzo-p-dioxin, or TCDD, was a contaminant in 2,4,5-T associated with the manufacture of this herbicide.)  For many years most public policy attention around this site focused on claims of environmental pollution, but following the release of reports commissioned by the Ministry of Health in late 2004 and early 2005 into dioxin levels in a sample of local residents, attention shifted to the public health and occupational health effects of dioxin exposure associated with the plant itself.  In response, the Department of Labour in New Plymouth established a process for former workers to register their concerns.

Two separate worker-related dioxin exposure studies have commenced.

• Dow AgroSciences, in conjunction with the University of Otago, recently completed a General Mortality Study of former IWD workers.  They are also undertaking a study of current and former workers to examine any link between historical work-related dioxin exposures and health status.  This work is scheduled to be completed in mid-2007.
• The Centre for Public Health Research (Massey University) has obtained funding for a three-year research study into dioxin exposure levels and the health status of former IWD workers.  This work is scheduled to be completed in late 2008.

Article 12: Technical Assistance

New Zealand, through the New Zealand Agency for International Development (NZAID), works with developing countries to mainstream sound environmental management into all development assistance.  NZAID places a high priority on developing countries’ requests for capacity building in environmental management and has recently developed a policy to guide environmental assistance activities within the Agency’s overall poverty elimination mandate.  The policy focuses NZAID’s activities on partner priorities that are most closely linked to poverty.

As a small donor, NZAID also works closely with larger donors to align activities and approaches.

Much of New Zealand’s regional and bilateral development assistance is focused on the Pacific.  Currently NZAID allocates NZ$6.025 million per annum to its Pacific Regional Environment Programme, with an additional NZ$0.075 million allocated to the Secretariat of the Pacific Regional Environment Programme (SPREP) for core and programme funding.  Recent or ongoing New Zealand-assisted programmes that help achieve Stockholm Convention objectives include:

• the Pacific Year of Action Against Waste Project, managed by SPREP, which aims to assist all SPREP member countries to address their current solid waste management issues (US$64,363 in 2005); this, alongside other similarly focused waste projects, is progressively working to reduce total volumes of waste being generated by supporting recycling, reuse and recovery initiatives, and improved disposal practices for the remaining solid waste
• development of a Pacific Regional Waste Management Strategy, managed by SPREP (US$170,882 in 2004/05)
• the Rarotonga Monitoring Project for testing for POPs in lagoon water (NZ$75,000 over 2004–2006)
• the Kiribati Pollution Enabling Project to improve enforcement of pollution control measures, mandated in the Kiribati Environment Act 1999 and Regulations 2001 (AU$45,296 over 2004–2006)
• the Tokelau Community Waste Management Project (NZ$165,000 over 2003–2005)
• a food-basket survey for Fiji carried out by the University of the South Pacific in conjunction with ESR (NZ$192,500 over 2004/05).

The Ministry for the Environment hosted a UNEP regional consultation with SPREP member countries on the draft BAT/BEP (best available techniques/best environmental practice) guidelines over 2–4 March 2005 in Wellington.  The aim of the consultation was to inform countries about the draft guidelines, obtain feedback on regional needs, and help countries prepare for the first meeting of the Conference of the Parties to the Stockholm Convention (May 2005) concerning the draft BAT/BEP guidelines.  Arising from this consultation, the Ministry worked with SPREP in preparing a model Dioxin Action Plan – BAT/BEP User Guideline suitable for Pacific Island countries.

Articles 13 and 14: Financial Resources

The Global Environment Facility (GEF) was launched in 1991 to provide grants and concessional funds to eligible countries for projects that benefit the global environment and promote sustainable livelihoods in local communities.  Countries are eligible for GEF funds if they qualify for World Bank loans, or receive technical assistance grants through a country programme of the United Nations Development Programme (UNDP).  The facility is jointly implemented by the UNDP, the United Nations Environment Programme and the World Bank.

Under Article 14 of the Convention, the GEF has been given interim designation as the principal entity entrusted with the operations of a financial mechanism referred to in Article 13.  New Zealand has committed 4 million Standard Drawing Rights (SDR)[Standard Drawing Rights (SDR) is based on five major currencies. SDR is converted to national currencies using an average daily exchange rate over a period of time.] to each of the past three replenishment rounds. The GEF’s current funding mandate covers ozone depletion, climate change, international waters and biodiversity, land degradation and, most recently, POPs.

Article 15: Reporting

The format and frequency of reporting were decided by the first Conference of the Parties (COP).  New Zealand’s international reporting requirements and a schedule for the next six years to 2011 are as follows.

Table 7: New Zealand’s reporting requirements, 2007–2011

National Implementation Plan (NIP)

The NIP is required to be submitted to the Stockholm Secretariat on or before 23 December 2006, this being within two years of the date of entry into force of the Convention for New Zealand (23 December 2004).

First National Report

New Zealand’s first National Report (as for all parties) is to be submitted to the Stockholm Secretariat by December 2006 for tabling at COP-3 in May 2007.  The format for national reports can be viewed on the Stockholm Convention’s website.[The format for national reports can be viewed at: http://www.pops.int/]  The purpose of reporting is to assess progress towards achieving the Convention’s obligations.  This reporting is simplified by there being no production and use of POPs pesticides in New Zealand (with the exception of small quantities imported for laboratory use as analytical standards).

Reporting beyond 2006

This requires, progressively:

• progress reports on eliminating the use of PCBs, by December 2008 and every five years thereafter
• a second National Report, reporting on the range of measures identified in the NIP, by December 2010 and every four years thereafter
• the Action Plan for Dioxins and Other Annex C Chemicals – reporting on the range of measures identified in the Action Plan, by December 2010 and every five years thereafter.  In essence this requires a five-yearly rolling review of measures to reduce dioxin releases, and updates of dioxin release inventory estimates.

Article 16: Effectiveness Evaluation

Article 16 requires the Conference of the Parties (COP) to periodically evaluate the effectiveness of the Convention, beginning four years after coming into force (i.e. in 2008).

The second meeting of the COP, in May 2006, decided to complete the first effectiveness evaluation at its fourth meeting in 2009.  The evaluation, to be compiled by the Secretariat of the Convention, will be based on a global monitoring report, national reports and non-compliance information.  A working group will co-ordinate and oversee implementation of a global monitoring plan and report progress to the third meeting of the COP.

Articles 17 to 30

The remaining articles (Articles 17 to 30) concern the international administration of the Convention and are not considered relevant to the New Zealand NIP at this stage.

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