Your submission may address any aspect of the proposed subject matter of the standard. However, the Ministry for the Environment would also greatly appreciate any specific comment you may have on the following questions.
- Have the problems been defined correctly?
- Are there other problems you can think of?
- What is the magnitude of these problems?
- Do you agree with the policy objective?
- Is there an alternative approach that has not been considered?
- Do you agree with the analysis provided in this section?
- Do you have any general comments about the proposed standard for the inspection and maintenance of on-site wastewater systems?
- Should the proposed standard apply to private dwellings only, or should it apply to all on-site systems (including consented systems) that treat domestic wastewater, including hotels, motels, camping grounds, restaurants, schools and marae?
- Do you agree with the inspection interval of three years?
- Should inspections be coupled with an immediate pump-out?
- Do you agree with the proposed critical components for the checklist (see Appendix 7)?
- Should the proposed standard prescribe a minimum level of treatment (eg, secondary) for new on-site systems? (This could have the effect of banning the installation of new septic tanks in favour of treatment systems that provide greater levels of treatment.)
Implementing the proposed standard
- Should the proposed standard apply to targeted areas as proposed, or across the whole of New Zealand?
- Do you agree with the risk assessment methodology and the proposed criteria for identifying targeted areas?
- Do you see any problems with the implementation and administration of the proposed standard?
- What would be an appropriate training level for inspectors/certifiers? Is a unit standard qualification for inspectors an appropriate method for ensuring consistency of inspectors?
Benefits and costs
- Have we accurately reflected the range of costs and benefits arising from the proposals for a national environmental standard, and who might bear the costs or receive the benefits?
- Are there any costs and benefits we have overlooked?
- Do you have information you would like to see included in the cost−benefit analysis that will occur after the submissions are received and analysed?
- Are our estimates of costs and benefits accurate?
- Do you have information on costs and benefits that could assist the second stage of our assessment (of the impacts of any final proposals)?
- Do you have any information on costs and benefits that we have been unable to quantify?