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Appendix 2: Summary of interviews with all councils

Q2.1 Background and context

This section attempts to record key information for each region to assist with establishing a clear picture of air quality management, as opposed to air quality regulation.

What are the key air quality issues for your region?

Council responses varied significantly in this section and are summarised individually below.

Auckland Regional Council:

Our biggest airshed (isthmus and four cities) has regular exceedances; - 7 exceedances and 6 breaches of PM10 in 2007 and 11 exceedances and 2 breaches of NO2 in 2007.

Whilst the NO2 breaches are primarily traffic related, the PM10 seems to be increasing every year and these are occurring at background residential sites.

Our second issue is that some of our other airsheds are likely to exceed in the future due to population growth (close to Kumeu, Pukekohe and actual exceedance in Orewa). In 2051 we expect 2.3 million people (up from 1.34 million in 2006). This equates to a jump from 430,000 to 860,000 households.

Environment Bay of Plenty:

Rotorua – PM10 from home heating. Very high number of exceedances (29 last year, 24 this year and only June) for a North Island town.

Environment Canterbury:

Primarily domestic heating related PM10 constrained airsheds. 80 – 95% in 7 gazetted areas (Rangiora – 89%; Kaiapoi – 94%; Christchurch - ~80%; Ashburton – 84%; Timaru – 95%).

Proposed Canterbury Natural Resources Regional Plan (NRRP) currently under appeal. This forms the basis for air quality management throughout the Canterbury region, including the provisions of stricter wood burner design and efficiency rule (1.0g/kg and 65% thermal efficiency for new wood burners throughout the region); and Christchurch contains specific tighter rule than elsewhere in Canterbury for domestic emissions.

Environment Southland:

5 exceedances measured in Invercargill using High Vol (nothing with BAM). Previously also measured < 5 exceedances per year in Gore.

Home heating is the primary source in all airsheds. Roughly 60:40 split coal and wood. Widespread installation of heat pumps is taking the ‘shoulders off the season’ (ie, PM10 emissions).

Environment Waikato:

Fine particulate – primarily from domestic home heating. 4 airsheds (Taupo, Tokoroa, Te Kuiti & Putaruru) with reasonably small population that all exceed the NES up to 10 times a year.

2004 monitoring for Tokoroa had one year with over 30 exceedances but this is not backed up by more current monitoring. Remains a question mark over this data.

One reasonably large population centre (Hamilton) that exceeds only a couple of times a year. Typically exceedance concentrations 60 – 70s (exception Taupo & Tokoroa previous data up to 80s).

Gisborne District Council:

We have PM10 data since 1992 (1 day in 6) from a site located at the airport which has shown no exceedances to date.

Overall, we do not see air quality as a priority issue for this region which is why we have limited monitoring data. We have two emissions inventories which reinforce this understanding.

Greater Wellington:

Unregulated domestic emissions causing occasional exceedances (by a narrow margin) of the PM10 standard in Masterton and Wainuiomata.

Hawke's Bay Regional Council:

PM10 well above NES, especially in Hastings, huge reductions needed (79%). Napier somewhat less but still significant (55% reduction needed).

Horizons Regional Council:

Our key source is domestic heating and key pollutant is PM10.

We have gazetted two airsheds Taihape & Taumarunui based on winter-time monitoring using mini-vols (7-day sampling) in June/July 2001 which measured exceedances.

Marlborough District Council:

Domestic heating in Blenheim - require reduction in PM10 emissions in the Blenheim airshed is approximately 25%.

Rural burning of prunings and vegetation from vineyards and other sources.

Commencing monitoring in Picton this year – may be issue in future.

Nelson City Council:

Top 3 in NZ for air pollution, primarily domestic sources. Regional plan provisions operative and incorporates the national ambient air quality guidelines (including annual guidelines) and environmental indicators (actually have 66% regional target for the longer term (100% for medium term)). Plan now also includes NES and goes further – applies it to all solid fuels.

Northland Regional Council:

Key air quality issue is SO2 in Marsden Point airshed and potentially PM10 in Whangarei. Concerns over lack of understanding of temporal and spatial variation within our airsheds. Not convinced current monitoring location picking up worst levels but not sure where we should be monitoring. Don’t know what we don’t know.

Notably there is a lack of political will to implement changes (eg, backyard burning took 2.5 years and 5 attempts). If we do face issues for Whangarei it’s highly unlikely we have the political backing to achieve change to meet NES.

Otago Regional Council:

Lots of small airsheds with very high levels of exceedances. Primary source is domestic solid fuel combustion – includes coal, not just wood.

Extremely cold winters with harsh weather leads to fears over certainty of electricity supply. People don’t believe heat pumps will work in the extreme cold. Housing stock is of poor quality (ie, poorly insulated, older, draughty and very large).

Taranaki Regional Council:

Taranaki has had no recorded exceedances for PM10 or any indication of exceedances of any of other the NES pollutants. Additional monitoring also gives no indication of any major changes in our key sources.

Tasman District Council:

PM10 in Richmond – primarily from home heating.

Perception issues setting up conflict scenario eg, horticultural and land clearance fires, Nelson Pine Industries industrial discharge – council is not being thought to act consistently. Submissions on notified boiler consent applications from people unhappy about not being allowed to have a burner.

West Coast Regional Council:

Our key issue is PM10 from domestic fires. Housing stock is of very poor quality.

Engagement with the community is a challenge for us – convincing people there is a problem and then what can be done about it. There is a strong history of people using coal (free in some cases) for heating of homes and water – historically this has been a cheap fuel but getting more expensive now.

NB: People need to heat overnight otherwise houses fall to very low temperatures. We do see a 7 am spike (not as strong as the evening one but definitely pronounced).

What other information relevant to air quality management in your region should be noted when undertaking a review of implementation of the NES for air quality in your region?

Auckland Regional Council:

The ARC has invested approximately $2M running 60 monitors at 15 sites with a running cost of around $1.2M per year. We have the longest continuous monitoring record in New Zealand (back to the early sixties).

To generate the straight line path at an appropriate frequency we feel it necessary to review our regional emissions inventory annually. Previously we only reviewed it every 5 years. As a result most years we are making adjustments.

Auckland is unique in that it faces pressure not only from a large population but also that we have the highest exposure and health impacts in New Zealand. These arise from both domestic and vehicle sources. This means that exceedances occur randomly at any month of the year (not just winter). The implication is that we have to bring down our entire mass loading.

Environment Bay of Plenty:

High deprivation index for whole of Eastern Bay of Plenty (Rotorua, Whakatane). This contrasts with Tauranga which has a low deprivation index. (Socio-economic Profile of the People of the Bay of Plenty Region – Census 2001).

Urban/coastal split. Most exceedances occur inland despite significant residential coastal development.

Environment Canterbury:

Environment Canterbury is a national leader in wood burner regulation having developed most of the science and supporting policy (eg, wood burner authorisation process) to support effective air quality management. Clean Heat started well before either the NES or the EECA funded schemes. The NRRP was the framework within which all this happened.

Environment Canterbury has put extensive funding into training, developing and keeping excellent air quality technical skills. Environment Canterbury is considered a leader in regional air quality management.

Environment Southland:

Biggest issue is still equipment – accuracy.

Still getting our head around how to use the monitors, technical aspects of monitoring are a concern for us.

Environment Waikato:

Some communities have limited ability to fund retrofitting of clean heat and insulation
(eg, Tokoroa and possibly Te Kuiti & Putaruru) due to high deprivation index. These communities are different to communities like Christchurch where you have large ratings base with both higher and middle incomes to draw from. This makes it hard for these communities to access EECA funding which requires matched funds. Environment Waikato has taken money from our regional investment fund to get EECA funds for Tokoroa (and now Taupo &
Te Kuiti).

Gisborne District Council:

Gisborne is a relatively large region (4th largest in land area in New Zealand) with a very small population (42,000).

Greater Wellington:

The cost of electricity in Masterton, one of the airsheds where the PM10 level is breached, is the highest in the region (and up with the highest nationally). As with our other non-complying airsheds, the residents in Masterton are mostly less affluent than elsewhere in the region.

Hawke's Bay Regional Council:

Deprivation index in Hawke’s Bay urban areas lower than national average (the “wine country” image is misleading!); deprivation index particularly low in areas of highest emission density.

Horizons Regional Council:

Air quality does not receive high priority with our council. Our top four issues in the One Plan are water quality, water quantity, biodiversity and sustainable land use.

Horizons Regional Council covers a big region (incorporating 7 District Councils) with only 100,000 ratepayers. An air quality monitoring station costs around $80K which is 1% of our overall budget. Our annual budget for air quality is $60K of which $50K gets chewed up
by monitoring.

Marlborough District Council:

Marlborough is quite a windy location, particularly in the spring and autumn. Blenheim experiences around 3 - 14 exceedances a year (2004 data the highest year to date, monitor thought to be located next to particularly smoky chimney).

Nelson City Council:

Monitoring record has proved difficult - not always had good long-term monitoring in all airsheds. Used to be 1 day in 3 with mobile partisol but no consistent, robust, record. Daily monitoring since 2001 in Airshed A has proved pivotal. Then the inventory. This is the secret to effective management of the airshed. Cannot have any good policy debate without good data.

Northland Regional Council:

Council considers 2013 ‘deadline’ will be amended (ie, there is flexibility on this date). Also of the opinion that a government change will modify the standards to be more business friendly.

Otago Regional Council:

Overnight damp down feature (on older, non-NES compliant burners) important in our towns because if the fire goes out, the house freezes. This puts people off upgrading to cleaner burners.

Tasman District Council:

Resourcing issues for staff and funding. Most staff doing air quality as part of larger job.

Campaign monitoring in other areas indicates no problems (to date).

West Coast Regional Council:

EECA have indicated Reefton has a high deprivation index.

Coal is a form of currency on the west coast (and Reefton) – it is written into the miners contracts that they receive around 8 tonnes of coal per year.

Q2.2 Enforcement of regulations

This section focuses on the regulatory requirements of the NES for air quality.

Q2.2.1 Prohibited activity standards

Are you aware of any breaches in your region of the six bans that came into effect on 8 October 2004?

Table A2.1: Identified breaches of the prohibited activity standards

Council Landfill Tyres Bitumen Coated Wire Oil
Auckland          
Bay of Plenty   tick   tick  
Canterbury   tick   tick  
Gisborne   tick      
Hawke's Bay       tick  
Horizons   tick   tick  
Marlborough   tick   tick tick
Nelson          
Northland   tick   tick  
Otago          
Southland tick tick tick tick  
Taranaki tick tick      
Tasman   tick      
Waikato       tick  
Wellington   tick   tick  
West Coast   tick      

Councils did not identify any breaches of the ban on new high temperature hazardous waste incinerators.

Have you undertaken any enforcement action in relation to the prohibited activity standards?

Environment Bay of Plenty and Environment Southland indicated breaches of the prohibited activity standards in their regions but reported no enforcement action.

The remainder of councils issued 18 abatement notices and 81 infringement notices, and carried out two prosecutions. Notably, the Environment Waikato prosecution of a recidivist offender (who was already in prison) resulted in a six month jail term extension. This prosecution related to breach of the regional plan, however, and not the regulations.

The West Coast Regional Council was unique in using written formal warnings only.

The need to burn is either strongest in Marlborough and the Manawatu regions or the Marlborough District Council and Horizons Regional Council have the strictest approach to enforcement with 37 and 22 infringement notices respectively.

Did you grant any consents for an incinerator at a school or hospital before 1 September 2006?

Ten councils granted consent for 71 incinerators at schools in their regions. Marlborough District Council has a consent for a hospital incinerator that was granted in 1998 and is due to expire 2033.

Table A2.2: Consents for school incinerators granted before 1 September 2006

Council School Incinerators
Auckland
Bay of Plenty 4
Canterbury 1
Gisborne 8
Hawke's Bay 13
Horizons 16
Marlborough 1
Nelson
Northland 11
Otago
Southland
Taranaki
Tasman
Waikato 13
Wellington
West Coast 1
Total 71

Whilst conditions vary, a number of the school incinerators were little more than open drums.

From this limited review, Northland Regional Council appears to be the only council to have physically inspected all incinerators since granting consent. Northland further limited consent period for 3 – 5 years and indicated to applicants that renewal was unlikely.

Is there other information relevant to the prohibited activity standards (eg, enforcement of regional plan provision that relates to a ban, monitoring of activities to ensure bans upheld)?

The majority of councils indicated that the prohibited activity standards were mostly catered for under existing regional plan rules. A few indicated that enforcement had improved since the regulations came into force.

What barriers, if any, exist to efficient enforcement of the prohibited activity standards?

All councils reported that enforcement was complaints driven. In the larger (and more rural) regions this can be problematic as noted by Horizons Regional Council:

We have a very large region and can only respond to complaints – which can take time (and resources). Often by the time we get there either the fire has gone down or the wind has changed or it was a malicious complaint anyway. Also, finding out about the occurrence – if a farmer chucks a tyre on a fire we’re not going to find out about it until much later.

What, if anything, could the Ministry do to assist with effective enforcement of the prohibited activity standards?

The majority of councils felt that nothing further was needed from the Ministry.

Three councils (Environment Southland, Gisborne District Council and Horizons Regional Council) suggested preventative education would be useful. Two councils (Environment Canterbury and Marlborough District Council) suggested additional funding to assist with compliance and enforcement.

In your view, are the prohibited activity standards effective?

The majority of councils indicated that yes, the prohibited activity standards were effective. Gisborne District Councils response was illuminating:

Yes. Particularly for coated wire – we used to have an auto dismantler who used to do this in town in a 44 gallon drum. Every few months we used to get called out – since the NES came into force we’ve issued 1 abatement notice and he’s stopped doing it. We also pointed out that it was now a national regulation and that we had stronger regulatory powers to prosecute.

Most councils also noted that the prohibited activity standards largely reflected existing provisions in the regional plans.

Q2.2.2 Design standards

Are all landfills in your region compliant with the landfill design standard?

There are four large landfills not currently complying with the design standard. Councils indicated that two of these (Marlborough and Otago) are due to problems with engineering design.

Table A2.3: Landfill compliance with the design standard

Council Complying Non-Complying
Auckland Redvale, Whitford, Rosedale, Greenmount  
Bay of Plenty NA  
Canterbury Kate Valley  
Gisborne NA  
Hawke's Bay Yes  
Horizons Awapuni, Bonnie Glen  
Marlborough   1 landfill non-complying
Nelson NA  
Northland NA  
Otago   Green Island
Southland Yes  
Taranaki NA  
Tasman NA  
Waikato Tirohia, Hampton Downs  
Wellington Southern, Spicers, Silverstream Wainuiomata, Otaihunga
West Coast NA  

Note: NA = not applicable.

Are all wood burners installed in your region, post 1 September 2005, compliant with the wood burner design standard?

All unitary authorities responded positively.

The remainder of councils gave a mixed response to this question with some indicating yes and others unsure. The majority of councils had not liaised with their territorial authorities at all since the standards were introduced in 2004.

Have you undertaken any enforcement action in relation to the design standards?

With two exceptions, no councils have undertaken any enforcement action in relation to the design standards. The exceptions are Environment Canterbury and Nelson City Council who partnered the Ministry in the national performance review of wood burners.

Is there other information relevant to the design standards (eg, details of liaison with territorial authorities to facilitate implementation of the wood burner standard, rules in regional plan more stringent than wood burner standard, etc)?

The Auckland Regional Council indicated that there has been a significant breakdown in relationships between the council and territorial authorities. There is currently a royal commission of inquiry into Auckland governance.

Environment Canterbury was unique in reporting close liaison with territorial authorities over the implementation of the wood burner standard. Horizons Regional Council indicated they liaise with territorial authorities in their region and Otago Regional Council reported consultation with territorial authorities over proposed regional plan rule changes.

Both the West Coast Regional Council and Environment Southland noted that the wood burner standard was very unlikely to have had any impact in their regions because the majority of purchases were for multi-fuel burners.

What barriers, if any, exist to efficient enforcement of the design standards?

There was a clear focus on the limitations of regional council enforcement when building consents are issued by territorial authorities.

One or two councils were unclear who is responsible for enforcement of the standards.

What, if anything, could the Ministry do to assist with effective enforcement of the design standards?

There was strong support of the Ministry’s national performance review of wood burners with requests for this to be repeated and/or extended. This was seen as more efficient than sixteen different councils attempting to stay in touch with wood burner manufacturers.

Councils were further supportive of the national authorised list. Environment Canterbury suggested that authorisation of burners be carried out at the national level (currently Environment Canterbury and Nelson City Council authorise burners on behalf of all other councils).

Several councils requested either a reporting requirement for territorial authorities to regional councils about wood burner installations or a link between the Building Code and the regulations.

In your view, are the design standards for wood burners effective?

Nearly all councils viewed the design standards for wood burners as effective. However, most councils did not think the standards went far enough as they only applied to wood burners and did not affect key sources such as open fires and multi-fuel burners.

In your view, are the design standards for landfills effective?

Seven councils responded in the affirmative, two councils did not respond and one didn’t know. This question was not applicable to six councils.

Q2.2.3 Monitoring

Which areas do you consider likely to exceed the ambient standards?

Councils identified a total of 39 airsheds likely to exceed the ambient standards (please refer to the table below).

Are these areas being monitored in accordance with the methods specified in the regulations?

The majority of councils responded in the affirmative. Exceptions were five airsheds that are considered likely to exceed but aren’t being monitored in accordance with the regulations. Of these five, only Taumarunui has been gazetted. These airsheds all have populations less than 6000.

Table A2.4: Monitoring of airsheds likely to exceed the ambient standards

Council Airshed likely to exceed – monitored* Airshed likely to exceed – not monitored*
Auckland Auckland, Kumeu, Pukekohe  
Bay of Plenty Rotorua  
Canterbury Ashburton, Christchurch, Geraldine, Kaiapoi, Rangiora, Timaru, Waimate Hanmer, Kaikoura, Temuka
Gisborne  
Hawke's Bay Awatoto, Hastings, Napier,Whirinaki  
Horizons Taumarunui
Marlborough Blenheim  
Nelson Nelson A, Nelson B  
Northland Marsden Point, Whangarei  
Otago** Airsheds 1, 2 and 3 with monitoring carried out in: Alexandra, Arrowtown, Clyde, Cromwell, Dunedin, Milton, Mosgiel, Ranfurly and Oamaru.  
Southland Gore, Invercargill Winton
Taranaki  
Tasman Richmond  
Waikato Hamilton, Putaruru, Taupo, Te Kuiti, Tokoroa  
Wellington Wairarapa, Wainuiomata  
West Coast Reefton  

* In accordance with Schedule 2 of the regulations.

** Otago airsheds were gazetted collectively as Airsheds 1, 2 and 3. Monitoring need only be carried out in 1 area of these airsheds to satisfy the regulations. In reality, the following areas are also considered likely to exceed but are not being monitored continuously: Balclutha, Palmerston and South Dunedin.

What parameters are currently being monitored in your airsheds and what is the frequency of monitoring?

All councils are monitoring for PM10 continuously in accordance with the regulations in most areas that are likely to exceed.11 Auckland Regional Council and Environment Canterbury have the most extensive monitoring networks in the country with a significant historical record.

A number of councils are further undertaking co-located monitoring (ie, monitoring of PM10 using different monitoring methods in the same location). This includes Auckland Regional Council, Environment Canterbury, Environment Waikato, Environment Southland and Northland Regional Council.

How are monitoring results reported (eg, council website, annual monitoring report, periodic reports) and when are they available to the public?

A significant number of councils have live reporting to the internet for their monitoring data. This includes the following airsheds:

  • Environment Bay of Plenty: Tauranga, Rotorua, Whakatane

  • Environment Canterbury: Rangiora, Kaiapoi, Christchurch, Ashburton, Timaru, Waimate, Geraldine

  • Environment Southland: Invercargill, Gore

  • Environment Waikato: Te Kuiti, Tokoroa, Taupo, Hamilton, Putaruru

  • Greater Wellington: central Wellington, Lower Hutt, Upper Hutt, Wainuiomata, Tawa, Karori, Masterton

  • Otago Regional Council: Alexandra, Clyde, Cromwell, Arrowtown, Ranfurly, Central Dunedin, Mosgiel, Milton

  • West Coast Regional Council: Reefton

Environment Southland further reports daily to local television and radio.

All councils report at least annually to the public with most also providing state of the environment reports periodically (typically five-yearly). Auckland Regional Council have produced a CD with all monitoring data to date (1964 – 2006).

Environment Canterbury and Otago Regional Council further provide weekly updates via email to interested stakeholders.

What is your overall assessment of the monitoring data (excellent, good, fair, poor)?

The majority of councils rate their monitoring as either excellent or good. Two councils, Hawke's Bay and Northland Regional Council, assessed monitoring as fair with Northland citing staff resourcing being a problem.

Is there other information relevant to the NES monitoring requirements (eg, monitoring and quality assurance being carried out in accordance with The Good Practice Guide for Air Quality Monitoring and Data Management, independent audit of monitoring carried out regularly).

Whilst all councils carry out some form of quality assurance and data validation on their ambient air quality monitoring data, few hold accreditation and approaches vary. Most councils monitor in accordance with the Ministry Good Practice Guide for Air Quality Monitoring and Data Management and several are carrying out co-located monitoring.

Five councils carry out external audits regularly (Auckland Regional Council, Environment Bay of Plenty, Environment Canterbury, Gisborne District Council and Tasman District Council).

Several councils indicated the importance of having a strategy for their monitoring programmes.

What barriers, if any, exist to fulfilling the monitoring requirements of the regulations?

Funding. Councils were unanimous on this point.

What, if anything, could the Ministry do to assist with fulfilling the monitoring requirements of the regulations?

Several councils requested the Ministry specify minimum monitoring and reporting requirements.

There was strong support for the Ministry taking more of a leadership role with monitoring through the provision of annual audits and workshops to address issues such as differences between monitoring methods.

In particular, Greater Wellington noted:

The lack of an overarching body with responsibility for ensuring that all monitoring is carried out in accordance with standard methods, best practice and is being undertaken at representative sites is a concern. Monitoring in accordance with a standard still allows plenty of wiggle room. Councils use different methods of data validation. For example some councils do not log values below 0 (a valid artefact of TEOM or BAM monitoring method, which if removed would positively bias the data). The whole issue of measurement uncertainty and gravimetric equivalency needs to be addressed nationally.

Monitoring is critical to successful air quality management. Nationally it is important to be comparing apples with apples and currently this may not be happening. It is better to have no data than poor data. Monitoring is resource intensive (costly and time consuming) and throughout New Zealand technical expertise is thin on the ground.

Northland Regional Council further suggested:

Would like to undertake independent audit of data collection and analysis against the GPG (once it’s updated). Would like this to be a national initiative. Could start with a desktop assessment for some and then do a random number of field visits and assessments. Given the critical importance of this data both regionally and nationally, I consider that such an audit is necessary to ensure consistent data collection (ability to compare results between Regions) and also to provide independent verification and confidence to RC/Central government in the data.

Environment Southland suggested the Ministry attend the Local Area Monitoring Environmental Officers' Meeting. (To date this forum has focused on hydrological monitoring).

Q2.2.4 Public notice

Have any breaches of Schedule 1 of the regulations been measured in your region?

This question refers to breaches of the ambient standards since the regulations came into force in 2005.

All councils responded in the affirmative with the exception of Horizons Regional Council, Gisborne District Council, Northland Regional Council and Taranaki Regional Council.

If yes, were the breaches publicly notified?

Generally, all breaches were notified. Three exceptions that were brought to the Ministry’s attention are discussed below.

Environment Bay of Plenty measured breaches of the SO2 standard in Mt Maunganui during the summer of 2005–2006. These exceedances were not picked up for a few months and were not publicly notified.

Environment Bay of Plenty’s reasoning for not notifying these exceedances was due to a lack of confidence in the data (no multi-point calibration, no span checks, no check sheet record to understand what instrument was doing). Since then, two new monitors have been installed at different locations to investigate the source of the exceedance. Potential sources include Ballance fertiliser works, Hexion pine chemicals manufacture, and New Zealand Marine Oil Services (processing of waste marine fuels and burning of waste oil) as well as shipping. No further exceedances have, however, been recorded.

The monitoring data was used during the consent process as a prompt for more monitoring by Balance (fertiliser works). A new telemetry system means that any future exceedances would be notified to Environment Bay of Plenty immediately.

Six exceedances of the PM10 standard were measured by Ravensdown Fertiliser Cooperative Limited at Awatoto in Hawke's Bay during 2006. The monitoring data were provided during the consent process but were not publicly notified.

Marlborough District Council measured a breach of the PM10 standard (109 µg/m3) in November 2007. Investigation after the event revealed the reason for the exceedance to be a BBQ close to the monitoring site. The exceedance was not publicly notified.

All councils agreed to copy the Ministry when breaches are publicly notified in future.

Is there other information relevant to the public notification provisions of the NES (eg, QA process to identify and document spurious data not being notified)?

Auckland Regional Council requested the Ministry show leadership by providing clear guidance that all exceedances need to be publicly notified.

In your view, are the monitoring and public notification requirements of the NES effective?

Five councils responded in the affirmative but most were non-committal. A number of councils commented on the limited readership of public notices and reported very little interest in exceedances reported to date.

An exception was Environment Southland who have fielded enquiries as a result of monitoring data supplied to regional television.

Q2.2.5 Airshed designation

Which areas in your region do you consider likely to exceed the ambient standards? Have these areas been gazetted as an airshed?

Councils consider 39 airsheds likely to exceed the ambient standards. Six of these airsheds are not gazetted.

Table A2.5: Gazettal of airsheds likely to exceed the ambient standards

Council Airshed likely to exceed – gazetted Airshed likely to exceed – not gazetted
Auckland Auckland, Kumeu, Pukekohe  
Bay of Plenty Rotorua  
Canterbury Ashburton, Christchurch, Geraldine, Kaiapoi, Rangiora, Timaru, Waimate Hanmer, Kaikoura, Temuka
Gisborne  
Hawke's Bay Hastings, Napier Awatoto, Whirinaki
Horizons Taumarunui  
Marlborough Blenheim  
Nelson Nelson A, Nelson B  
Northland Marsden Point*, Whangarei  
Otago Airshed 1, Airshed 2, Airshed 3**  
Southland Invercargill, Gore Winton
Taranaki  
Tasman Richmond  
Waikato Hamilton, Putaruru, Taupo, Te Kuiti, Tokoroa  
Wellington Wairarapa, Upper Hutt  
West Coast Reefton  

* Marsden Point is the only airshed in the country gazetted for sulphur dioxide.

** Otago airsheds were gazetted collectively as Airsheds 1, 2 and 3. The airsheds have since been notified collectively in a different order through a plan change as Air Zones 1 and 2.

Is there other information relevant to airsheds (eg, public consultation on boundaries of airsheds, limitations of monitoring data for areas likely to exceed, financial constraints for monitoring)?

Environment Waikato has gazetted airsheds that are likely to exceed as well as areas that might exceed (based on monitoring data between 66 per cent and 100 per cent of the standard). Environment Waikato further carried out extensive public and industry consultation on all airsheds before finalising gazette notices.

Note from the Ministry for the Environment:

Following a request from Otago Regional Council, in December 2005 the Minister for the Environment gazetted four airsheds as follows:

Airshed 1: Alexandra, Clyde, Arrowtown, Cromwell, Roxburgh, Naseby, Ranfurly

Airshed 2: Mosgiel, Palmerston, Green Island, South Dunedin, Milton

Airshed 3: Oamaru, Balclutha, Central Dunedin, North Dunedin, Waikouaiti, Port Chalmers

Airshed 4: Kingston, Queenstown, Wanaka, Hawea.

In December 2007, however, Otago Regional Council adopted a proposed regional plan change that referred to 3 Air Zones as follows:

Air Zone 1: Alexandra, Arrowtown, Clyde and Crowmwell

Air Zone 2: Balclutha, Green Island, Dunedin, Hawea, Kingston, Milton, Mosgiel, Naseby, Oamaru, Palmerston, Port Chalmers, Queenstown, Ranfurly, Roxburgh, Waikouaiti, Wanaka

Air Zone 3: Whole of Otago excluding areas in Air Zones 1 and 2.

This policy in the proposed plan change is currently under appeal. Otago Regional Council has yet to request that the airsheds notified in 2005 be re-gazetted. Implementation of the regulations must, therefore, be judged against the gazetted airsheds (only).

The following section applies to only those councils with gazetted airsheds.

Note: This excludes Gisborne and Taranaki.

What barriers, if any, exist to efficiently gazetting airsheds for your region?

Auckland Regional Council noted that the Greater Auckland airshed is based on the metropolitan urban limits (MULs). These MULs are under review, due to requests from territorial authorities, and are likely to require amending in future. This will necessitate a plan change and re-gazettal. Auckland noted that whilst necessary, this is not a particularly efficient process.

Otago Regional Council identified cost (approximately $5000 – 10,000) as a barrier to gazetting airsheds.

No other councils identified any barriers to gazetting airsheds.

What, if anything, could the Ministry do to assist with gazetting airsheds for your region?

None identified.

Do the airsheds gazetted in your region align with the relevant provisions of your regional plan?

Table A2.6: Alignment of gazetted sirsheds with regional plan provisions

Council Airsheds aligned with regional plan Airshed not aligned with regional plan
Auckland tick  
Bay of Plenty   X
Canterbury tick  
Gisborne NA  
Hawke's Bay   X
Horizons tick  
Marlborough   X
Nelson tick  
Northland tick X4
Otago   X
Southland   X
Taranaki NA  
Tasman tick  
Waikato   X
Wellington   X
West Coast   X

Notes:

1 Airsheds also aligned with district plans as far as practicable.

2 Proposed One Plan.

3 Marsden Point.

4 Whangarei, Kerikeri, Kaitaia and Dargaville.

NA = not applicable.

Is there other information relevant to airshed gazettal (eg, changes in regional plans and impact on existing gazetted airsheds)?

Otago Regional Council stated the following:

We don’t need the legal exactness required by the NES for our regional management of burners or the consents of industry. We think this is an unnecessary administrative burden.

Q2.2.6 Granting consents in accordance with section 17

Since 1 September 2005 have you granted any consents for discharges of PM10 in an airshed with a straight-line path?

Table A2.7: Consents granted in airsheds with straight-line path

Council Airshed Number of consents / details
Auckland Auckland 1 / OI NZ glassworks (old NZ Glass)
Bay of Plenty NA  
Canterbury ChristchurchTimaruAshburtonRangiora 65532
Gisborne NA  
Hawke's Bay NA  
Horizons NA  
Marlborough Blenheim 1 / Flight Timbers kiln and sawmill
Nelson Nelson 4 / Kiwi Orchids, Bens Oil, Fulton Hogan asphalt plant, Sealords shellfish plant.
Northland Whangarei 5 or 6
Otago Not supplied 3
Southland Not supplied 1 / School coal-fired boiler
Taranaki NA  
Tasman NA  
Waikato HamiltonPutaruru 61
Wellington NA  
West Coast NA  

Note: NA = not applicable.

For consents granted since 2005 in an airshed with straight-line path:

How was the significance, or otherwise, of the discharge established?

Auckland Regional Council:

NES reinforced by our regional plan so the legal interpretation of significant was not a key consideration in the consent decision. O-I New Zealand emissions actually only around 5% of the airshed discharge (42 tonnes/year PM10, modelled maximum 22 µg/m3 for 3 furnaces).

Environment Canterbury:

Fuel type, control equipment used, location in airshed, size relative to total airshed discharge, size relative to industry expansion allowance. This is in accordance with what the regional plan which allows for a 20% increase of industrial emissions of PM10 (ie, 2% per year).

Environment Southland:

Concentration not significantly increased as demonstrated through modelling by consultant.

[No additional details provided.]

Environment Waikato:

Significance was established through querying the contribution in terms of impact. If contribution within the error bars of monitoring (ie, < 5 µg/m3) then it was not considered significant. All plant considered to date have modelled maximum PM10 less than 5 µg/m3 so not considered significant.

Marlborough District Council:

A combination of total emission load contribution to the airshed (approx. 4%) and modelling to show ground level concentrations (up to 15% of the NES). Also looked at in terms of operation vs worst case pollution days etc.

Hearing decided it was ‘significant’ and consent only granted for 5 years with conditions.

Nelson City Council:

The consent activity criteria in the Air Quality Plan were used to determine significance ie, the rule thresholds set in the Plan were based on modelling done by NIWA to determine if the impact of a discharge on the airshed was insignificant (and therefore permitted). Anything else was considered significant and, now the NES is in place, needs to be assessed under the NES.

Northland Regional Council:

We looked at the % of the total discharge into the airshed.

We looked at the % difference between in peak ambient concentrations with and without the plant.

All discharges under consideration were < 10% (3-6%) and on that basis were not considered significant.

Otago Regional Council:

Existing activities granted consent on basis of 3 year grace period for ongoing discharge. After this time, upgrade to baghouse required. Significance not established (industry only 10% in whole airshed).

(Approach would have been different if new discharge).

For consents granted since 2005 in an airshed with straight-line path:

How have you considered the application in accordance with the straight-line path?

Auckland Regional Council:

We required a reduction strategy of 15% over current levels (and absorbing projected increased activity).

Electrostatic precipitators to be phased in over next 6 years to achieve this.

Environment Canterbury:

Used above definition of significance and no industrial consents met that criteria so no further consideration was needed.

Environment Southland:

NA – significance threshold not exceeded.

Environment Waikato:

NA – significance threshold not exceeded.

Marlborough District Council:

The application was considered as part of current emissions as the 7 MW has been operating since approx 2004. Currently Blenheim is compliant with its straight line path and emissions from Flight Timbers are already part of emissions that are being assessed against the straight line path.

Nelson City Council:

Yes – judged not that was unlikely to cause air quality to exceed the straight line path.

Northland Regional Council:

We looked at the monitoring data and it clearly demonstrates that we were under the NES for the year under consideration. We then attempted to account for meteorological variation by looking at % of calms and air temperature in previous years and compared that with the year where the monitoring shows no problems.

No real difference, monitoring looks ok and real therefore, complies with straight line path at time of application.

NB: Our straight line path is all determined by home heating (not industry) which is showing a reduction over the years. (Think this is due (in part) to NES).

Otago Regional Council:

We haven’t.

For consents granted since 2005 in an airshed with straight line path:

How were offsets, if used, incorporated into the application?

Auckland Regional Council:

Offsets were not used.

We have had discussions on offsets with Fletchers for Tasman Insulation. (Fletchers owns 15 of top 30 emitters in the region). They want to mothball some old plants, expand newer plants and do a deal on some of the middle plants – ie, consider the plants' emissions as a whole.

For legal certainty probably best to do this through one consent for all sites. ARC interested in still requiring best practice for all sites (to ‘offset’ competitive concerns for other industries being required to upgrade).

Care needs to be taken that offsets used in this manner doesn’t take up all the head space as this was supposed to be providing for new industry. Considering setting % limit on amount of free space attributed to one plant (do through Regional Policy Statement and subsequent iterations to regional plan).

Still in discussions.

Environment Canterbury:

Waimate dairy plant example (36 fires removed to allow new boiler) – conditions are attached (and offsets provision below) – see NZ Dairies Ltd (Waimate, Studholme) - CRC070222.1. Note that there is no condition re the 36 fires removed as the NES was not effective at that time as the dairy plant was not in the Waimate airshed. NZ Dairies Ltd did the conversions off their own back.

Environment Southland, Environment Waikato, Marlborough District Council, Nelson City Council, Northland Regional Council and Otago Regional Council:

Offsets not used.

For consents granted since 2005 in an airshed with straight-line path:

Is there other information relevant to consent conditions (eg, monitoring conditions, requirement for ‘continuous improvement’ or ‘best practice’)?

Auckland Regional Council:

Our councils require zero net increase from Oct 2005 emissions on all major PM10 discharges / consent holders (current & future).

Current industry to reach best practice as soon as possible and to implement continuous improvement to maintain a ‘headspace’ for future growth.

We require regular review of international best practice for each industry with annual reporting to council.

Increased monitoring requirements (mass emission value on an annual basis) to report to council annually.

We require both concentration limits and annual mass emission limits to be met.

Environment Canterbury:

The global consent for SERFL includes conditions requiring in-house monitoring (real life testing) of 5 pellet fires, every five years.

Environment Southland:

Boiler emissions required to be checked. [No additional details provided.]

Environment Waikato:

Our policy where there is uncertainty or a lack of science and the cost of obtaining that science is prohibitive is to promote best practice. Eg, Higgins asphalt plant required to investigate best technology for process.

Marlborough District Council:

Monitoring conditions imposed, requirement to reduce emissions by approximately 20% by 2012. This was thought to be achievable under best practice and would not entail excessive cost.

Nelson City Council:

Consents in our region are largely driven by the requirements of the regional plan. The NES is only a back-stop. We have our own GPG for industry applicants based on reductions needed in our airsheds.

Northland Regional Council:

First, all stack monitoring for particulate as part of a resource consent condition was changed from TSP to PM10. We no longer measure TSP.

We required a 30% reduction in particulate loading (kg/hr) from that originally applied for.

For the largest application (56 MW wood fired boilers for a sawmill) we required a further 25% reduction in PM10 emission rate by 1 Jan 2012.

Otago Regional Council:

Our approach with all industry is to require best practice for all future discharges
(25 – 50 mg/m3).

Tasman District Council:

[No consents granted but additional information provided below.]

Previously permitted boiler discharges in the airshed now require a consent under the regional plan as controlled activities. They have six months from June 2008 to apply. Tasman District Council is employing a student to help gather data on fuel use and operation to improve our emissions inventory data.

This includes schools. Council be talking to schools and HortNZ (who have been involved in the process all the way) to help the greenhouse growers through the process.

Rationale behind council ‘helping’ approach is that we need the data for air quality management of the whole airshed.

Since 1 September 2005 have you granted any consents for discharges of PM10 in an airshed, without a straight-line path, for which exceedances of the PM10 ambient standard have occurred, or are likely to have occurred?

Greater Wellington indicated that around 4 consents have been issued for industry in Masterton. [No additional details provided.]

Otago Regional Council indicated that a consent had been granted for a Fonterra cheese factory in Stirling. No monitoring data is available for Stirling but modelling indicated that exceedances (due to domestic sources) were likely. Consent was granted for 35 years with a requirement to upgrade in 3 years from 18 kg/hr to 2.5 kg/hr (25 – 50 mg/m3).

Environment Canterbury was unsure about consent decisions in areas that may exceed but which are currently not monitored.

All other councils responded in the negative.

For consents granted in airsheds likely to exceed, without straight-line path:

How was the significance, or otherwise, of the discharge established?

Greater Wellington:

We know from our receptor modelling work that around 80% of PM10 on high pollution nights in Masterton arises from domestic emissions, therefore industry is not usually considered significant in this context.

Airshed emissions inventories are another way of assessing significance (ie, industrial contribution very low compared to domestic). Therefore, it is straightforward to assess if you are looking at the airshed as a whole. More difficult to assess for near field effects – you may have local hot spots near the industry that are not reflected in the airshed monitoring station located some distance away in a residential area. This was done for Upper Hutt (currently not exceeding but close to it). Comparison with emissions inventory was not done for Masterton as inventory not prepared.

Otago Regional Council:

Significance not established.

How were offsets, if used, incorporated into the application?

Offsets were not used in the consents discussed above.

Is there other information relevant to consent conditions (eg, monitoring conditions, requirement for ‘continuous improvement’ or ‘best practice’)?

Greater Wellington:

No specific requirements for continuous improvement as such. Standard monitoring conditions regarding operating efficiency, stack testing, emission discharge rate, operations and maintenance manuals etc depending on scope and scale of discharge.

Otago Regional Council:

Emphasis on best practice. Review clauses in 35 year period.

Aside – not currently meeting new WHO level but will after 3 years.

Since 1 September 2005 have you declined any consents for discharges of PM10 in an airshed with a straight-line path?

Northland Regional Council is the only council to have declined a consent during this period. The consent was for an application to burn waste oil in a bitumen plant.

Environment Southland indicated they have discouraged applications (for example, an application to burn demolition waste was told not to bother applying).

One council commented that it was highly unlikely a consent would ever be declined.

For consents declined in airshed with straight-line path:

What was the basis for decline?

Northland Regional Council gave the following reasons for the decline:

  • increase in PM10 emissions

  • increase in acid gases

  • increase in dioxin emissions

  • increase in heavy metal discharges

  • increase in variability of output of emissions (VOCs, SO2, etc)

  • could only guarantee used oil would comply with specifications 90% of time.

How was the significance, or otherwise, of the discharge established?

Not relevant.

For all consents:

In your view, are the NES restrictions on the granting of resource consents of discharges effective.

Council opinion was split.

Northland Regional Council viewed the restrictions as partly effective but was concerned at the inconsistent approach for different pollutants. Northland suggested the principal source threshold approach for NO2, CO and ozone (regulation 20) be removed to be consistent with SO2 (Regulation 21). Auckland Regional Council was similarly concerned over the regulations inconsistent approach to different pollutants and did not consider the restrictions effective.

Greater Wellington, Hawke's Bay Regional Council and Marlborough District Council considered the restrictions to be ineffective because they penalise industry who are not the main source of PM10 exceedances. Further, some airsheds with PM10 issues may not have consented industries (eg, Wainuiomata).

By contrast, Environment Southland, Gisborne District Council and Otago Regional Council considered the restrictions to be effective. Environment Bay of Plenty considered the restrictions were effective for SO2.

Q2.3 Action plans for compliance

Do you have an action plan in place, or drafted, to achieve compliance with the PM10 standard by September 2013? Do you think the action plan will succeed?

Table A2.8: Airsheds, existence of action plans and assessment of compliance

Council Airshed with action plan in place, or drafted Airshed with no action plan
  Likely to comply Unlikely to comply Likely to comply Unlikely to comply
Auckland       Auckland
Bay of Plenty Rotoruaa      
Canterburyb Ashburtona
Geraldine
Rangiora
Waimate
Christchurcha
Kaiapoia

Timarua
   
Hawke’s Bayc   Hastingsa
Napier
   
Horizons     Taumarunui  
Marlborough     Blenheim  
Nelson Nelson Aa

Nelsonb

     
Northland     Whangarei  
Otago Airshed 1a
Airshed 3
Airshed 2 (Milton)a    
Southland     Invercargill
Gore
 
Tasman Richmonda      
Waikato     Hamilton
Putaruru
Tokoroaa
Te Kuiti
Taupo
Wellington     Wainuiomata
Upper Hutt
Mastertond
(Wairarapa)
West Coast       Reeftona

a Heavily over-allocated airshed.

b Environment Canterbury advise they are taking a variety of measures to address air pollution in Timaru, including proposed plan changes, the Clean Heat project and a working party. The original interview did not define this as an action plan. Table A.2.8 has been amended to reflect this advice, but the original interview comments have not been updated and list Timaru as an airshed unlikely to comply.

c Hawke’s Bay Regional Council notified a proposed plan change to achieve compliance with the ambient standards in December 2008, after this review was completed. Table A.2.8 has been amended to reflect this change, but the original interview comments have not been updated.

d Masterton (Wairarapa) airshed alternates annually between compliance and non-compliance with the PM10 standard. Greater Wellington considers that Masterton is unlikely to comply with the PM10 standard by 2013.

 

Councils further identified the following airsheds as likely to exceed the PM10 standard. Assessment of compliance by 2013 for these airsheds was not requested:

  • Auckland: Orewa, Pukekohe, Kumeu

  • Canterbury: Temuka, Hanmer, Kaikoura

  • Hawke's Bay: Awatoto, Whirinaki

  • Southland: Winton.

Does the action plan align with the relevant provisions of your existing regional plan?

Six councils have action plans in place to meet the PM10 standard by 2013. Of these, five action plans align with the regional plan.

Note: The review did not address the content of action plans in detail.

Table A2.9: Alignment of action plans with regional plans

Council Action plan aligned with regional plan Action plan not aligned with regional plan / other
Auckland   No action plan
Bay of Plenty   X
Canterbury tick X2
Gisborne NA  
Hawke's Bay   No action plan
Horizons   No action plan
Marlborough   No action plan
Nelson tick  
Northland tick  
Otago tick  
Southland   No action plan
Taranaki NA  
Tasman tick  
Waikato   No action plan
Wellington   No action plan
West Coast   No action plan

Notes:

1 Ashburton, Geraldine, Kaiapoi, Rangiora, Waimate.

2 Christchurch and Kaiapoi may require amendment, Timaru has no (specific) action plan.

3 Whangarei and Marsden Point – significant uncertainties surround other airsheds.

4 Milton may require amendment.

NA = not applicable.

 

Extensive information was provided by councils on a range of air quality initiatives in airsheds, some with action plans, some without. The following section summarises responses from only those airsheds identified as unlikely to meet the PM10 standards by 2013.

For areas with an action plan in place but unlikely to meet PM10 standard:

How does the plan address all elements of an air quality management framework; ie, monitoring, emission inventories, predictive models, regulatory instruments (eg, proposed plan revisions), communication and strategy?

[This question applies to Environment Canterbury and Otago Regional Council.]

Environment Canterbury: Christchurch Airshed

NRRP (notified June 2002). Christchurch (currently subject to appeal) – prohibited activity for discharges from open fires and 15 year old ‘non clean air approved’ burners; exemptions for heritage buildings and in times of emergency power outage; no new solid fuel burners in new homes or homes without solid fuel; no wintertime outdoor burning; emission standards for large scale solid fuel burning devices.

Clean Heat Project has begun in February 2003.

Refer to Ecan website for monitoring data; emissions inventory; projections analysis done 3‑yearly (in progress currently); annual home heating survey; annual monitoring reports and annual report on the LTCCP community outcomes which cover air quality. Also, Canesis modelling re trend for Christchurch shows a slight decrease in concentrations.

Environment Canterbury: Kaiapoi Airshed

Refer NRRP and Variation 12 of this. Kaiapoi (at hearing stage) – non-complying activity by
1 May 2010 or at point of sale if earlier for discharges from open fires and pre-2001 ‘non clean air approved’ burners, and by 31 August 2013 or at point of sale if earlier for discharges from post-2001 ‘non clean air approved’ burners; exemptions for heritage buildings and in times of emergency power outage; only pellet fires in new homes or homes without solid fuel; requirement to obtain resource consent (restricted discretionary activity) to demonstrate performance is still as good after 15 years of operation of ‘clean air approved’ burners; no wintertime outdoor burning; emission standards for large scale solid fuel burning devices.

Refer to Ecan website for monitoring data; emissions inventory; projections analysis done 3-yearly; annual monitoring reports and annual report on the LTCCP community outcomes which cover air quality.

Otago Regional Council: Airshed 2 – Milton

Proposed plan change in 2007, currently resolving 4 appeals.

Air Zone 2 proposed rules:

  • All new burners must meet 1.5 g/kg in Air Zone 2.

  • All existing burners can stay forever.

No emissions inventory for Milton. We do have home heating survey from the MfE (which includes Milton).

(Backyard burning effectively banned by requirement for being 50 m from boundary in current plan. Also cannot cause nuisance to neighbours).

NB: no assistance programme for air zone 2.

For areas with an action plan in place but unlikely to meet PM10 standard:

What is the key risk to the success of this action plan?

[This question applies to Environment Canterbury and Otago Regional Council.]

Environment Canterbury: Christchurch and Kaiapoi Airsheds

Because the NRRP is such a slow process under the RMA – only now at Environment Court stage. If we need to undertake further variations this will take even longer.

Non-compliance with rules (eg, people still using their fires after phase-out date passed, people still burning outdoors).

Emission projections – are our assumptions correct. What if we have it wrong?

Otago Regional Council: Airshed 2 – Milton

Not as cold, not as extreme. Biggest risk is slowing of economy so that people no longer renovate (ie, slow down of natural attrition). We’re relying on them to upgrade their burner.

What barriers, if any, exist to the success of this action plan?

[This question applies to Environment Canterbury and Otago Regional Council.]

Environment Canterbury: Christchurch and Kaiapoi Airsheds

Not enough central government funding.

No certainty to central government funding.

Lack of public confidence in security of electricity supply and cost of electricity (and other fuels like gas and pellets) are barriers to change away from wood burning.

Speed of RMA processes in getting our plan operative.

Otago Regional Council: Airshed 2 – Milton

None.

For areas with an action plan in place but unlikely to meet PM10 standard:

Is there other information relevant to the success of this action plan (eg, council support/opposition to proposed initiatives, funding issues)?

[This question applies to Environment Canterbury and Otago Regional Council.]

Environment Canterbury: Christchurch Airshed

Successful Clean Heat scheme established (we had a head start on the issue in Christchurch).

Commissioners recommending we do other further variations but these need to get through the appeals process first. Then we need to develop joint working processes with the city council.

Environment Canterbury: Kaiapoi Airshed

Clean Heat scheme established on 1 July 2008. Joint Working Group established with Waimakariri District Council and their community Boards. The proposals for the variation and Clean Heat approved by the Joint Working party and Waimakariri District Council supportive of action taken but need ongoing financial support for Clean Heat as this programme is a much limited version of that in Christchurch and if need to widen, much greater financial assistance is needed.

Otago Regional Council: Airshed 2 – Milton

Airshed 2: Palmerston, Mosgiel, Green Island, South Dunedin and Milton: No.

What, if anything, could the Ministry do to assist with achieving this action plan?

[This question applies to Environment Canterbury and Otago Regional Council.]

Environment Canterbury: Christchurch and Kaiapoi Airsheds

Continue/increase EECA funding for retrofitting clean heat and insulation.

Change regulations to make it clear that if an airshed is breaching, consents can still be granted if an action plan is in place, and steps are being taken to reduce PM10 emissions (eg, European Union initiatives).

Ban solid fuel open fires in airsheds with exceedances of the ambient standards (existing and new) ie, prevent new ones being installed (easy) and require the removal of existing open fires (hard re enforcement).

Phase-out non-complying burners in airsheds with exceedances of the ambient standards.

National ban on outdoor burning in airsheds with exceedances of the ambient standards.

Improve the RMA/Building Act integration eg, ensure Territorial Authorities actively check compliance of wood burners before installation. But if the Building Code/Act changes, then nobody would be able to enforce the NES or authorise solid fuel burners as there would be no independent enforcement authority to do this (assuming the installers would then become the ‘enforcers’ as the Territorial Authorities would not have to undertake building consent inspections).

Otago Regional Council: Airshed 2 – Milton

Nothing.

For areas with no action plan in place and unlikely to meet PM10 standard:

Is there other information relevant to the decision not to prepare an action plan (eg, lack of industry in airshed under consideration, limited monitoring data, staff capacity issues)?

[At time of interview, this question applied to Auckland Regional Council, Environment Canterbury, Environment Waikato, Hawke's Bay Regional Council, Greater Wellington and the West Coast Regional Council.]

Council responses to this question varied from extensive air quality management actions (Auckland Regional Council) to sparse details (Hawkes Bay Regional Council, West Coast Regional Council). Responses for those airsheds identified as not likely to meet the PM10 standard by 2013, with no action plan in place, are summarised below.

Auckland Regional Council: Auckland Airshed

We have policies and targets for reductions but we’re still working on an implementation plan. Due to go to politicians in November 2008 with Regional Policy Statement. We anticipate, however, that the minute the Regional Policy Statement is notified we will be bogged down working on consultation and appeals. We have a strategy for the transport sector. This includes 7 priorities that we lobbied central govt on - 5 of which have since been adopted and the other 2 are in process.

The domestic sector requires a similar 58% reduction – but our emissions inventory isn’t sufficiently robust for us to yet formulate a strategy. Council approved us spending a year doing the base science to give more justification for future policy. Policies to implement NES for domestic fires (ie, how to get 58% reduction) now being presented to council in March 2009 to coincide with Regional Policy Statement review.

Environment Canterbury: Timaru Airshed

Set up a Joint Working Party with Timaru District Council and currently going through process in consultation with the Timaru District Council in developing additional regulatory measures over and above what is currently in the Proposed NRRP and Clean Heat Project which begins from 1 July 2008.

Environment Waikato: Te Kuiti and Taupo Airsheds

For all the airsheds we have actual monitoring. We have emissions inventories to identify the key contributors (always home heating). Primary focus is therefore, on home heating.

We do not have an action plan per se for each airshed. We have, however, worked out how many burners in each non-compliant airshed, need to be replaced to achieve compliance with the NES by 2013. Solutions tailored to each airshed and include rules, education and incentive schemes.

Plan to go to community with discussion document (Aug/Sept) outlining issues for all the airsheds and outlining options for solutions in each airshed.

This will feed into a plan change and then through LTCCP process we will go back to the community with an incentive scheme proposal.

Hawke's Bay Regional Council: Napier and Hastings Airsheds

Time, and to a lesser extent staff and financial resources, have been the main factor. Limited monitoring data and other information (airshed modelling, source apportionment for natural background sources, more detailed household wood burner data) at time NES introduced. This has taken 3-4 years to gather, so Council only just now in a position to proceed with developing policy responses.

Greater Wellington: Wairarapa (Masterton) Airshed

Up till now we have focussed our efforts on source apportionment work – to produce a scientifically defensible quantification of the sources of particulate pollution in our at-risk airsheds and the actual relative contribution of the sources (including natural sources) to ambient concentrations.

A major issue for us is that where exceedances are only by a narrow margin – the required emissions reductions could be within the margins of error for emissions inventories. Further, given our airsheds are only just out of compliance there is arguably less of a driver for us to achieve compliance.

West Coast Regional Council: Reefton Airshed

The lack of an action plan is related to lack of information on what is needed to achieve the NES. Currently calculating impact of various scenarios; eg,

  • Removing all open fires; or

  • Convert 50% of multi-fuels to NES compliant wood burners; or

  • Convert 25% of multi-fuel burners to heat pump or gas.

It is worth noting that there are no real drivers, other than health, to meet the standard (ie, no industry in Reefton). Continuous monitoring in Reefton commenced in 2006.

For areas with no action plan in place and unlikely to meet PM10 standard:

What do you see as the key risk to the success of your plans/policies?

[At time of interview, this question applied to Auckland Regional Council, Environment Canterbury, Environment Waikato, Hawke's Bay Regional Council, Greater Wellington and the West Coast Regional Council.]

Whilst all councils require reductions in home heating emissions, Auckland Regional Council is unique in also requiring reductions in vehicle emissions to meet the PM10 standard by 2013. A key risk for the Auckland Regional Council therefore, is the Ministry of Transport not delivering on proposed actions.

Both Auckland Regional Council and Environment Waikato identified political buy-in and the length of time for required plan processes as key risks to achieving the standards.

Environment Canterbury were concerned over the assumptions used for emission projections and the risk of those assumptions being wrong.

What barriers, if any, exist to the success of your plans/policies?

[At time of interview, this question applied to Auckland Regional Council, Environment Canterbury, Environment Waikato, Hawke's Bay Regional Council, Greater Wellington and the West Coast Regional Council.]

Auckland Regional Council noted they had missed out on central government funding for loans to retrofit clean heat because the Council did not support matched funding.

Environment Canterbury identified a large number of barriers to achieving the PM10 standard in Timaru including:

  • timing of regional plan processes (only now at the Environment Court stage of the proposed plan)

  • non-compliance with rules

  • not enough central government funding (for retrofit programmes)

  • no certainty to central government funding

  • lack of public confidence in security of electricity supply and cost of electricity (and other fuels like gas and pellets) are barriers to change away from wood burning.

What, if anything, could the Ministry do to assist with achieving your plan/policies.

[At time of interview, this question applied to Auckland Regional Council, Environment Canterbury, Environment Waikato, Hawke's Bay Regional Council, Greater Wellington and the West Coast Regional Council.]

Auckland Regional Council, Environment Canterbury and Environment Waikato were unanimous in suggesting the Ministry amend the regulations to regulate and/or ban new solid-fuel open fires, coal burners and multi-fuel burners in airsheds that exceed the PM10 standard. Environment Canterbury and Environment Waikato further requested that non-compliant burners be phased out by 2013.

Environment Canterbury requested further funding for clean heat retrofits under the EECA Clean Heat and EnergyWise programmes and a national ban on outdoor burning in airsheds exceeding the PM10 standard.

Environment Canterbury also requested the Ministry do the following:

Change regulations to make it clear that if an airshed is breaching, consents can still be granted if an action plan is in place, and steps are being taken to reduce PM10 emissions (eg, European Union initiatives).

Note on compliance with other ambient standards

The Marsden Point airshed is unique in New Zealand being gazetted for sulphur dioxide (SO2).

Northland Regional Council ambient air quality monitoring indicates the airshed is currently complying with the SO2 ambient standard. Northland notes, however, that monitoring only began six months ago.

Northland Regional Council estimates there is a 60 – 70 per cent probability the Marsden Point airshed will continue to comply with the SO2 ambient standard. The 30 – 40 per cent uncertainty rests primarily on unplanned outages at the Marsden Point oil refinery. Such outages have historically contributed to breaches of the SO2 ambient standard.

Northland Regional Council has prepared the Marsden Point Strategic Air Quality Plan. The intent of this strategic plan is to plan for future industry in the SO2 constrained airshed.

Q2.4 NES – general

This section addresses more general questions about the effectiveness, or otherwise, of the NES for air quality.

What, if any, perverse incentives have been created by the introduction of the NES for air quality?

The following perverse incentives were identified:

  • anecdotal evidence points to an increase in multi-fuel burner installations

  • assistance scheme experience indicates some people put off upgrading a burner or choose to install coal burners, multi-fuels or open fires if they can’t find a compliant wood burner that they like (for aesthetic reasons)

  • trend towards true greenfield sites for siting of new industry. For example, Goldpine proposed new sawmill in Ruakaka to be well away from other industrial areas.

The following potential perverse incentives were identified:

  • manufacturers re-labelling wood burners as multi-fuels

  • significant increase in domestic electricity consumption as people switch from wood burners to heat pumps may have adverse impacts

  • increase in granting of long-term consents to avoid 2013 deadline.

As an aside, Northland Regional Council noted the following bonus from the introduction of the regulations:

We are seeing some consultants (who blame the NES for everything) now recommending things that are already required under our air plan. Strengthening of push to best practice.

Are you aware of any resource consents being ‘brought forward’ to avoid potential restrictions after 2013?

Environment Waikato:

Yes. Genesis (Huntly power station) looks likely.

A couple of asphalt plants in Hamilton due to expire in 2016 – not sure.

Most of the big Fonterra plants are due to expire before 2013 anyway and Kinleith due to expire 2023 so not affected.

Northland Regional Council:

Yes – one or two.

Golden Bay Cement (due 2011) lodging next month. Possibly due to climate change issues, also making changes to plant so combining all into one new consent application.

Carter Holt Harvey Whangarei sawmill applying 5 years early partly to address 2013 issues.

Tasman District Council:

Possibly – Nelson Pine considering applying in 2009 (consent declines 2011). This is being driven by expansion of Richmond towards the plant.

What, if anything, could the Ministry do to assist with effective enforcement of the regulations?

Unfortunately, due to a design error in the protocol this question was only asked of three councils with the remainder focusing on improving enforcement of the prohibited activity standards and the design standards.

Environment Canterbury suggested we amend regulations so that councils could still grant consent to industry if there was action plan in place (even if the PM10 standard was exceeded).

Nelson City Council requested monitoring of consents or commissioning a good lawyer to review what’s happening around the country. Nelson further expressed concern that case-law will only occur if somebody appeals – who appears for the people? Nelson further suggested training and/or debate for all council staff on issues like long term effects, concentration vs mass, interpretation of significance.

Tasman District Council had no suggestions.

What barriers, if any, exist to the successful implementation of the NES for air quality?

All councils identified resourcing as a barrier to successful implementation, be it staffing or funding. Probably the most extreme example is Northland Regional Council who appear to be significantly understaffed:

Only two of us to deal with all incidents (around 500 a year), all air plan changes, all resource consents (80 major industries in Northland including largest cement factory in New Zealand, only oil refinery), all State of the Environment monitoring and all reporting for an area 5.1% of New Zealand land size.

It should be noted, however, that Northland Regional Council anticipates meeting the ambient standards by 2013.

There was a common view that the regulations unfairly penalise industry when the key source is domestic heating. This was accompanied by a commonly held view that the regulations would be amended to remove/amend the 2013 deadline.

Councils further agreed that relationship difficulties with territorial authorities was hampering the success of implementing the wood burner standard.

A number of councils identified timing as a barrier to successfully implementing the regulations. This was largely due to the length of time required for regional plan changes.

A few councils further noted the problems inherent in regulating the domestic sector – that this was seen as nanny state interference.

Finally, Nelson City Council noted the importance of staff attitude towards implementation.

Staff have ability to either make or break the regulations – it often comes down to attitude and trying to make it work. I’d like to see more willingness around the country to give the NES a chance to work. Staff can have a big influence on politicians and senior management through their advice, and if we are overly pessimistic that can get reflected in the political and management level. But if we are more proactive, and can-do, that instead can be reflected.

What, if anything, could the Ministry do to assist with achieving the original intent of the regulations?

Council response was significantly varied. All answers are provided here in full.

Auckland Regional Council:

Ban open fires.

Require multi-fuels to meet NES.

Ban coal burners in airsheds exceeding the PM10 NES.

Ban any solid fuel combustion in new houses in airsheds exceeding the PM10 NES.

Give us control over sale of fuel.

Environment Bay of Plenty:

Include coal burners and open fires in the design standards (ie, close the back door) for new burners.

Keep monitoring performance of wood burner manufacturers.

Environment Canterbury:

Take out consequences for industry if action plan in place. Or increase number of allowable exceedances.

Put an annual average into Schedule 1 (and the regulations). This is supported by a population exposure approach to regulation (as opposed to current focus on short-term exposure over 24 hours). In other words, make it more explicit that we are regulating to improve long-term exposure.

MfE to undertake further analysis of PM2.5 and exposure times (acute versus chronic) etc.

MfE to develop a real life standard test for solid fuel burners and put into the NES rather than rely on AS/NZS4012/4013 (is too costly for a single Council to do for national benefit in the long term).

Environment Southland:

Leaving aside the regulatory approach, we believe greater emphasis on financial incentives to improve home heating and doing stuff around fuel supply would yield better reductions in PM10.

If there was a standard on new multi-fuels (ie, 1.5 g/kg which only 1 does to date) this would help but wouldn’t solve the problem.

Ban on new open fires in airsheds exceeding NES, is an obvious big step in the right direction.

We’ve generated an awareness in the general public and now we have a need for non-biased home heating advice for home owners who call us.

More networking with regional councils. Regional councils have a role of supporting Territorial Authorities – the Ministry has a role of supporting us. This should be done more frequently – NAQWG we only send one staff member. We get so much more out of you coming here than NAQWG – more regional support/presence. It also builds a more positive relationship between Environment Southland and MfE.

Environment Waikato:

Burners that meet the NES are around 50% better than pre-NES burners. It would be improved by having a test methodology that better reflects real life emissions as opposed to test laboratory conditions (ie, addresses emissions during start-up).

Would like multi-fuels to be included in the NES.

From a national perspective, open solid fuel fires should be phased out (we’re doing this anyway).

Amend the regulations so that non-NES compliant burners cannot be operated past 2013 in airsheds that exceed the NES. ie, open fires, multi-fuels and old crappy wood burners.

Ban backyard burning in airsheds that exceed NES. We’re considering making this
non-complying (ie, need consent).

Industry is a non-player in all our airsheds. The consequences for non-compliance fall on the wrong sector. Good mechanism for focusing people’s attention but this risks industry setting up in locations that are clean (ie, Matamata vs Tokoroa). This isn’t fair as the reality is it would make very little difference to air quality in either town (but obvious big social impact through jobs).

Staff view is that we don’t believe central government would allow industry to be declined after 2013 – particularly not for the big players.

Gisborne District Council:

Not much. It is up to us to enforce it really.

In the Gisborne region there is a lack of education (eg, ban on open burning of tyres).

Greater Wellington:

More integrated support is required from central government to address the issue of improving energy efficient housing through the Building Act.

Consider including ban on burning of treated timber (CCA), including LOSP (light organic solvent preservative) treated timber – both in open and in heating appliances, also would simplify process if included plastic as a another category for banned substance for burring.

Hawke's Bay Regional Council:

No response.

Horizons Regional Council:

Funding. Air quality in our region is not a priority.

Marlborough District Council:

Perhaps regulations or guidelines on urban backyard burning and outdoor burning.

Include multi-fuels in the design standards.

Nelson City Council:

Not sure – danger in picking the festering scab of a sore in trying to fix the regulations. Much rather have an imperfect regulation that is working okay-ish than risk losing gains to date.

Northland Regional Council:

The Ministry should amend the NES to address key issues consistently being faced by Regional Councils/Unitary Authorities.

Amend the NES to ban backyard burning in airsheds that exceed the PM10 standard.

Specify minimum, and mandatory, monitoring and reporting requirements.

Undertake national audits of data monitoring and analysis.

Amend the NES to include an annual PM10 standard.

Amend the NES to include a PM2.5 standard (annual and 24 hr).

Identify additional funding streams to assist with implementation of the NES. (eg, amend NES so that industries pay a surcharge if in gazetted airshed that is exceeding standard).

We need a carrot to make up for central government telling local government what to do.

Otago Regional Council:

Include coal and multi-fuel burners in NES (ie, apply 1.5 g/kg to other fuels).

Link the building consent process to the NES. Require Territorial Authorities to provide information on building consents for burners to regional councils.

NES for industrial emissions.

Taranaki Regional Council:

Introduce a ban on backyard burning in all urban areas to eliminate dioxin emissions.

Work harder to get MoT to regulate vehicle emissions quicker.

Tasman District Council:

Review the wording of the NES for certainty and clarity.

Streamline process to help people get wood burners out of the airshed (ie, facilitate funding through EECA). (We appreciate the expertise and capacity of organisations like Energy Smart to deliver the complex EECA funded projects). Gives us longer to do it. 2013 not enough.

West Coast Regional Council:

Funding for implementation (ie, monitoring equipment, staff and research to determine scale of issue and appropriate response).

 


11  Except Taranaki Regional Council who consider no areas likely to exceed in their region.