Over the past few years there has been an increasing call from many people in business, local government and the wider community for the Ministry for the Environment to develop national environmental standards. This call was repeated at a series of breakfast meetings the Ministry for the Environment hosted in mid-2002, where there was support in principle for the introduction of standards to provide national consistency and a minimum standard of protection for the community.
The Ministry for the Environment then worked closely with regional councils to agree on priorities for national environmental standards. Air quality management was seen as being the first priority. There are two main reasons for this. Firstly, air quality is a significant health and environmental issue in New Zealand which requires improvement to ensure the sustainability of our towns and cities. Secondly, ambient air quality management has typically used a system of guideline values and guidance so there is considerable technical and scientific analysis on which to base numerical standards that protect human health.
In August 2003 the Government gave the Ministry for the Environment approval to consult on the first suite of national environmental standards. Consequently, in October 2003 the Minister for the Environment notified a range of proposed national environmental standards for air quality. The standards were presented as a package consisting of:
- ambient standards for carbon monoxide (CO), particles (PM10), nitrogen dioxide (NO2), sulphur dioxide (SO2) and ozone (O3)
- prohibitive standards, which prohibit various activities that discharge unacceptable quantities of contaminants into the air, particularly dioxins
- an emission standard for the design of small, domestic, solid-fuel-burning appliances.
Public notices informing people of the submission period were placed in major papers on 25 October 2003. The notices informed people of:
- the subject matter of the proposed national environmental standards
- the Minister's reasons for considering that the proposals are consistent with the purposes of the Resource Management Act 1991
- how people could make a submission
- the deadline for submissions.
A copy of the public notice is included in Appendix A of this report.
During November 2003 the Ministry for the Environment undertook a comprehensive road show across New Zealand, holding over 30 meetings in 16 regions, and talking to over 1000 people. Implementation of the proposed national environmental standards was one of the key topics discussed at the road show meetings, and once again there was support in principle for the development of national environmental standards.
The deadline for submissions was 5 pm on Friday 5 December 2003. Due to concerns expressed by some parties over the short timeframe for comment, submissions were accepted until midday 24 December 2003.
Details of the proposals and how they will be implemented was made available during the submission period in the Ministry for the Environment report Proposed National Environmental Standards for Air Quality: Air Quality Technical Report No. 46.
A proposed national environmental standard addressing the collection and destruction of landfill gas was notified in parallel.
1.2 Purpose of this document
This document presents an overview of the submissions received on the proposed national environmental standards for air quality. The public notice recommended that people include in their submission any changes they would like seen to the proposed standards. As a consequence, a large proportion of this report contains submitters' suggested changes to the proposals. These may be viewed as being in opposition to the proposals, although in many cases the submissions offered conditional support.
Chapter 2 is a summary of the key themes raised by submitters, while chapter 3 is a more detailed summary on a submitter-by-submitter basis. The chapter follows the structure of the Proposed National Environmental Standards for Air Quality: Technical Report No. 46, with a brief summary of the proposal followed by submissions received relating to that section.
This report is intended to provide a concise summary of the views expressed. It is not intended to provide an analysis of those views or recommendations in response to the submissions. This will be done in a separate report, which will be presented to Cabinet later this year.
The summary of submissions received on the proposed landfill gas collection and destruction standard is included in a separate document available from www.mfe.govt.nz.