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Working Towards a Comprehensive Policy Framework for Managing Contaminated Land in New Zealand: Report on Submissions

Executive summary

1 Introduction

2 Overview of submissions

3 Key elements and work priorities

4 National environmental standards

5 Roles and responsibilities

6 Guidance

7 Liability

8 Accreditation

9 Capability

10 National information

11 Additional research areas

12 Additional opportunities

13 Workshop overview

Appendix A: Index of submitters

Abbreviations

References

6 Guidance

When asked what guidelines need to be revised, submitters most commonly suggested the timber treatment, petroleum hydrocarbon guidelines and CLMG No. 5. However, many submitters considered that all guidelines need to be revised into one overarching guideline.

Twenty-nine further guidelines were suggested. The most common suggestions were for: remediation options, roles and responsibilities, horticultural soils, and remediation by natural attenuation.

Revision of guidelines

Twenty-four submitters (39%) responded to this discussion point. Not surprisingly, the most commonly suggested guidelines for revision were some of the oldest, specifically, the Health and Environmental Guideline for Selected Timber Treatment Chemicals (Ministry for the Environment and Ministry of Health, 1997), and the Guidelines for Assessing and Managing Petroleum Hydrocarbon Contaminated Sites in New Zealand (Ministry for the Environment, 1999). While most agreed that both of these guidelines are still technically adequate, they considered they need revision to address significant errors and a growing number of inconsistencies with later Ministry guidelines.

Six submitters thought that Contaminated Land Management Guidelines No 5: Site Investigation and Analysis (Ministry for the Environment, 2004) needs revision because it is inconsistent with advice in the earlier timber treatment guidelines and requires clarification to minimise user confusion over requirements for composite and representative sampling.

Five responded that Contaminated Land Management Guidelines No. 2: Hierarchy and Application in New Zealand of Environmental Guideline Values (Ministry for the Environment, 2003) needs revision, because it is too strict and does not relate to local conditions.

The comment was also made that a more comprehensive set of New Zealand values needs to be derived.

Five submitters suggested that the classifications in the recently released Contaminated Land Management Guidelines No. 4: Classification and Information Management Protocols (Ministry for the Environment, 2006) need to be expanded. It was believed that this is necessary to promote national consistency on how councils record and report information about land.

A common theme across all submissions was the need to schedule regular reviews of the guidelines to incorporate evolving policy, methods and technologies to ensure the guidance remains useful and the Ministry’s policy advice is current and consistent. Some suggested a five-yearly review period.

Others suggested that instead of revising individual documents, all existing guidelines (especially the industry guidelines) be combined into one overarching guideline. They also recommended that all guidance containing soil contaminant values needs to be precautionary, and open and transparent about the uncertainties contained in their derivation.

Table 12: Suggestions for revising guidelines, by submitter ID

Further guidelines

Thirty submitters (48%) made suggestions for 29 different guidelines. The most commonly suggested (8) was guidance on remediation options (clean-up technologies and methods) to promote cost-effective in situ management and remediation over the currently preferred “dig and dump” option.

There was significant support (6) for developing guidance on roles and responsibilities to help the various agencies clarify their respective contaminated land roles. Many (6) also wanted model rules for district and regional plans to help address the inconsistency of contaminated land provisions in local government plans by applying a model plan rule. Model rules were also a common suggestion as a standard (see section 4.5).

Other commonly suggested guidelines included:

• identifying and managing the risks associated with the subdivision of horticultural land (5)

• remediation by natural attenuation (4)

• investigating groundwater contamination from contaminated sites (3).

All further guidelines suggested by submitters are listed in Table 13.

Table 13: Further suggestions for guidelines, by submitter ID

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