Most submitters agreed with the ideal key elements of a comprehensive policy framework. Submissions also showed a strong level of support for the proposed priorities of the work programme opportunities. All of the proposed high-priority opportunities were especially strongly supported.
Are these the ideal key elements for a New Zealand contaminated land framework?
Of the 27 submitters (44%) who responded to this discussion point, almost all (24) agreed with the elements identified in Table 1 of the discussion paper. Three submitters partially agreed, suggesting additional key elements or mostly minor modifications to the elements.
Table 2: Response to key elements, by submitter ID
| Key elements | Submitter ID |
|---|---|
|
Agreed with key elements |
4, 8, 9, 15, 18, 19, 20, 22, 24, 27, 28, 30, 31, 32, 40, 42, 44, 45, 46, 47, 48, 49, 52, 53, 60 |
|
Partially agreed, with modifications |
29, 58, 61 |
Are the priorities that have been assigned to each opportunity appropriate? If not, what are more appropriate priorities?
Forty-six submitters (74%) responded to this discussion point. Table 3 shows the degree of alignment to the suggested Ministry for the Environment priorities.
Table 3: Submitter and Ministry priorities for identified opportunities for change
| Opportunities | Ministry priority | Submitter priority | ||
|---|---|---|---|---|
| High | Medium | Low | ||
|
Produce nationally consistent methods for deriving health-based soil contaminant levels |
High |
37 |
0 |
0 |
|
Produce a standard (for human health) that defines management actions |
High |
32 |
1 |
2 |
|
Increase the size of or modify the Fund |
High |
27 |
1 |
3 |
|
Provide added certainty with a standard |
High |
26 |
0 |
1 |
|
Produce guidance on the management of contaminated land information |
Medium |
1 |
25 |
1 |
|
Establish a collection of national information on contaminated land |
Medium |
4 |
24 |
3 |
|
Require tracking of contaminated soil and waste using WasteTRACK |
Medium |
4 |
23 |
4 |
|
Investigate options for addressing liability barriers |
Medium |
12 |
19 |
1 |
|
Provide guidance on how agencies establish working relationships |
Medium |
11 |
15 |
0 |
|
Provide new guidance |
Low |
2 |
1 |
22 |
|
Review and revise existing guidance |
Low |
6 |
0 |
22 |
|
Investigate establishing a scheme of accredited auditors |
Low |
4 |
2 |
21 |
|
Investigate training for practitioners |
Low |
6 |
5 |
19 |
|
Produce a standard (ecological) that defines management actions |
Low |
11 |
3 |
18 |
|
Produce nationally consistent methods for deriving ecologically-based soil contaminant levels |
Low |
15 |
6 |
14 |
Note: Dark-shaded cells with bold numbers indicate the highest number of submitters.
Submitter responses generally showed a strong level of consensus with the Ministry-assigned priorities. All proposed high-priority opportunities were very strongly supported.
Four proposed initiatives showed a weaker alignment:
produce nationally consistent methods for deriving ecologically-based soil contaminant levels – submitters were split between those who agreed with the Ministry and gave this initiative a low priority (14) and those who considered it a high priority (15)
produce a standard (ecological) that defines management actions – a significant number (11) of submitters considered this opportunity to be a high priority in contrast to the majority of submitters (18), who agreed with the suggested low priority
provide guidance on how agencies establish working relationships – although the majority of respondents (15) agreed with the medium priority given, a significant number (11) considered this initiative more urgent
investigate options for addressing liability barriers – although the majority of respondents (12) agreed with the medium priority given, a significant number (19) considered this initiative more urgent than stated.