Air quality

Abstract

Air quality planning is needed to safeguard the life-supporting capacity of the air and to avoid, remedy or mitigate any adverse effects of activities on the environment. Air quality effects can occur at a global, regional and local level. Global scale effects on air quality are a national issue and the role of the RMA in managing this issue is a current challenge faced by practitioners. This note focuses on planning that can be done by regional councils and territorial authorities to address regional and local scale effects of air emissions.

Note: Frequently asked questions on the national environmental standards for air quality are also available

Guidance note

Context and history
Regional council and territorial authority functions for air quality
First steps information gathering
Issue identification
Policy response
Rules
Technical approach/Best Practicable Option
District plan air quality provisions
Buffer zones and separation distances
Cross-boundary issues
Anticipated environmental results
Monitoring and review
Information requirements for resource consents

Context and history

The RMA necessitates an air quality management approach that involves measuring the state of the air and assessing the influence of pressures on air quality. The approach increasingly used in New Zealand can be described as air-shed management. This is where an air-shed or zone with particular characteristics - eg an industrial or a rural area - is managed to reflect those characteristics. Fundamentals to this approach are:

guidelines, indicators or standards;
air quality monitoring;
emission inventories; and
air-shed modelling.

The RMA brought a major change to regulating air pollution in New Zealand. Although the Clean Air Act 1972, which focused on controlling air emissions at source, was repealed, its provisions formed the basis of transitional regional plans (sections 368 and 369 of the RMA).

Air quality planning needs to be understood in the context that:

there were no comprehensive air quality plans under the Clean Air Act, for example to deal with transport and domestic emissions (although local responses were possible, eg the Christchurch Clean Air Zone Orders 1977 and 1984);
the Health Act was previously (and still can be) used to deal with health effects and nuisances, eg odour and domestic fires;
air quality was a new function for regional councils. Expertise was thinly spread because it had previously been centralised in the Department of Health;
ambient air quality monitoring was minimal;
many of the first plans under the RMA were intermediary, principally because section 418, which provided for existing permitted activities, was expiring (although this was later changed by amendment); and
there are jurisdictional overlaps between regions and territorial authorities under the RMA.

Regional council and territorial authority functions for air quality

The RMA gives the primary responsibility for air quality to regional councils (and unitary authorities). Territorial authorities (TAs) have RMA responsibilities for managing the effects of land uses, and these can impact on air quality. TAs also have responsibilities under the Health Act, but these functions are excluded from district plan provisions.

Regional councils have responsibilities under section 30 for the control of discharges of contaminants to air.
Territorial authorities have responsibilities under section 31to achieve integrated management of the effects of the use, development or protection of land and associated natural and physical resources to control subdivision. This includes effects on amenity values.

These roles can often cause tensions when managing air quality. The split jurisdiction is a significant issue. Relationships need to be managed and roles integrated.

Options for managing and/or clarifying relationships and responsibilities include:

the regional policy statement (RPS), which could define the boundaries of regional and district council functions;
good consultation between TAs and regional councils during plan preparation; and/or
negotiated memorandums of understanding between TAs and regional councils, with functions established through delegations.

The RPS and the air plan can identify role definition as an issue that needs addressing, and some definition can be provided. Relationships, however, need to be tailored depending on the issues and resources within particular districts in a region.

Good dialogue and partnerships are the best means of ensuring clarity of roles and responsibilities, ultimately by a negotiated memorandum of understanding.

First steps information gathering

The first round of air plans generally suffered from a lack of information on which to base issue, objective, policy and method development. It was frequently assumed that air quality was good. However, once data had been gathered, it was found that in many cases the quality was lower than expected. Carbon monoxide from transport, and respirable particulate matter (PM10) from domestic fires and transport, have been identified as particular issues requiring urgent attention.

For the next round of plans, more information should be available to aid in plan development. Ideally the information base should incorporate information on (a) the state of the environment and (b) pressures that may affect air quality.

(a) The state of the environment should be assessed by:

council staff observations and public complaints;
regional ambient air quality monitoring data that tracks compliance with ambient air quality criteria (eg MfE ambient air quality guidelines);
relevant meteorological data (this may include a meteorological monitoring programme to complement the air monitoring network);
identifying areas where good air quality is important, eg National Parks or pristine areas, communities with vulnerable populations. This can help identify priorities for protection;
public consultation and perceptions, including consultation with iwi; and
health effects studies where levels breach guideline values.

(b) Identify pressures and how these are likely to change over time, using methods such as:

desktop analysis based on information from literature and data from other locations with similar characteristics e.g. topography, population size, industry types
a regional emission inventory of point, area and mobile sources to identify the contribution from the various sectors, eg industrial, agricultural, domestic, natural and transport; and/or
atmospheric dispersion models to predict the effects of sources across the air-shed now and in the future.
Once the state of the environment has been assessed, areas within the region requiring particular air quality management should be identified.

Issue identification

Information is the key to successful identification of issues for the plan. Where information has not been available to fully characterise air quality and pollution sources, this lack of information has been identified as an issue in itself. Some councils (eg Environment Canterbury) delayed plan preparation because of insufficient information. Issues for the next round of air plans should be clearer as data becomes available through the implementation of plans and monitoring programmes.

An issue must be a clear statement about a matter that needs addressing. Air quality issues often centre on the discharges of contaminants and their effects. Themes for issue identification are summarised in below, and also outlined in Table 1:

Table 1: Air quality issues

Issue	Sources	Potential effects
Odour	Pig farms, landfills, wastewater treatment, composting	Local air quality	Health, nuisance & stress	Detracts from amenity & enjoyment
Fine particles (PM₁₀ and PM_2.5)	Motor vehicles especially diesels, home heating fires, most combustion sources	Air sheds and local air quality	Premature death, respiratory disease, asthma attacks etc	Visibility degradation, smog, deposition
Dust – total suspended particulate (TSP)	Quarries, stockpiles, unsealed roads	Local air quality	Respiratory, eye & nose irritation, lung disease (if hazardous dusts)	Deposition, smog & visibility
Chemical or gaseous contaminants	Motor vehicles, oil refining, foundries, volcanoes	Local air quality and air-sheds	Respiratory illness, nausea	Corrosion, visibility & photochemical smog
Combustion products	Domestic heating, boilers, power stations, backyard fires, rural burnoff, road-seal burning, motor vehicles	Local air quality & air-sheds	Respiratory and cardiovascular disease, reduced infection resistance, nerve and organ damage, increased risk of cancers, premature death.	Deposition, corrosion, smog & visibility
Agrichemical drift	Horticulture and weed spraying	Local air quality	Skin irritation, stress, headaches, vegetation damage	Livelihood of organic growers

Effects identified include those on human health, amenity and the environment. Effects can be either widespread across air-sheds or localised.

Policy response

Air quality zones or management areas are a good basis for developing regional objectives based on air quality guidelines. Objectives for localised air quality effects are also required, eg for dust, odour and agrichemical drift.

Section 3.3 of the Ambient Air Quality Guidelines 2002 Update (MfE 2002) discusses a framework for using the air quality guidelines and establishing regional criteria, using air quality categories developed through the Environmental Performance Indicators (EPI) Programme.

Table 2 lists five air quality categories (action, alert, acceptable, good and excellent). While these values are somewhat arbitrary, they have been widely used in planning processes since their introduction in 1997.

Table 2: Summary table of actions required by air quality category to meet air quality guidelines (from Appendix 2 of the Ambient Air Quality Guidelines)

See Summary table of actions required by air quality category to meet air quality guidelines (large table)

Table 2 shows, in particular, that pollution levels above 66% of any national guideline value fall within the 'alert' category as defined by the EPI Programme. This warning level indicates that the guideline value could be exceeded if upward trends are not curbed. In a sense, this provides a definition of degraded air. It implies that 66% of the guideline is the threshold above which action should be considered to maintain reduce emissions. In this situation it may be necessary to develop policies to curb a potential upward trend, or to enhance air quality, depending on the circumstances, local community aspirations and the costs and benefits of possible actions.

This concept is illustrated in Figure 1:

Figure 1 EPI categories as a basis for regional guidelines

Text description of image:
The figure lists ideal local body responses to each of the four air quality categories. Regional councils must maintain air quality levels in the Excellent (0% to 10%) and Good (10% and 30%), and acceptable (33% to 66%) levels. If air quality is measured at the Alert level (66% to 100%) regional councils must act to at least maintain the current level, and preferably to enhance it. This may involve setting specific policies. If air quality exceeds the guideline action must be taken to enhance air quality.

Objectives

Objectives should express what would resolve the air quality issue. They should be tailored for the various air quality management areas and address local issues.

Where air quality is cleaner than guidelines, the objective should aim to maintain or improve that quality.
Where air quality is degraded, include a commitment to its improvement.

Policies

Policies should describe how air quality objectives are to be achieved. Policies also provide a guide to decision-making. They should aim to achieve the emissions reductions required to meet guideline values where they are breached or to minimise adverse health effects. For example:

Promote measures to address motor vehicle exhaust emissions.
Avoid adverse effects from agrichemical spray drift
Apply ambient air quality targets.
Restrict outdoor burning.
Restrict installation of home heating fires to low emission burners.

Methods

Methods are actions to implement air quality policies and are the means of achieving the air quality objectives. Regulatory methods, ie rules that prohibit or require resource consent or specify standards, are often appropriate for dealing with the effects of:

some industrial or trade discharges;
domestic sources (in some regions);
agrichemical use;
outdoor burning;
waste management; and
intensive farming.

The effects of some sources, when taken individually, are minor and would not be considered for regulatory control on their own. However, a regulatory approach may be justified where there are potential cumulative effects eg motor vehicles and domestic fires. A non-regulatory approach may be appropriate for:

some industrial discharges, eg best practice guidance, responding o complaints;
domestic sources (in some regions), eg information provision, responding to complaints;
transport sources, eg advocacy to improve use and maintenance of vehicles, and transport planning to lower emissions from vehicles and to reduce congestion.

Include a method to address the air-related functions of the regional council and the TAs. For example, specify functions to be formally delegated, or state that a memorandum of understanding will be negotiated.

Presumptions about discharges to air: industrial and trade premises and other discharges

Section 15 of the RMA distinguishes between discharges from industrial and trade premises and other discharges. Industrial and trade premises require consent unless the discharge is permitted in a rule in a plan, while other premises are permitted to discharge to air as of right.

This presumption needs to be considered in the formulation of the plan, in particular, in the construction of a catch-all rule for industrial and trade premises that are not addressed elsewhere in the plan.

The catch-all rule should default to the discretionary activity category, to be consistent with the presumption under the RMA.

Rules

Rules must be clear and provide certainty. Where a subjective term is included, guidance or a definition must be provided to restrict interpretation. For example, if no objectionable odour or dust is included as a condition, the plan should identify the assessment criteria and the process used to determine if an air discharge is objectionable. Likewise, if terms such as sensitive receiving environment are used in rule formulations, they should be defined.

When formulating rules, consider the role of other plans and use cross-referencing to avoid repetition or conflict. Rules about waste management, land use or water discharge can contain conditions related to effects on air quality, and may reduce the need for separate rules.

Where a rule includes a threshold e.g. combustion processes over 10 MW are discretionary or a process related condition, the section 32 analysis must justify the threshold or condition in terms of its effects on the environment.

Technical approach/best practicable option

Many councils have incorporated the best practicable option (BPO) into their air quality planning, particularly in the absence of good data, or for issues which are difficult to monitor or set environmental limits for.

The BPO is a recommended approach:

where there is a lack of effects information;
where a precautionary approach is justified; or
for issues such as odour where the effect is difficult to quantify.

The BPO approach can be justified on an effects basis for certain technical approaches, and is therefore likely to continue to be used. Check the requirements in section 70(2) before making rules requiring the best practicable option to be adopted.

District plan air quality provisions

Territorial authority responsibilities for air management are indirect, through controls on the use of land (section 9) and subdivisions. Under section 75(2)(c) of the RMA territorial authority plans cannot be inconsistent with the relevant RPS or regional plan.

When developing district plans, TAs need to consider the role of regional councils in managing air discharge matters. TAs should:

work with the regional council to address air quality issues, notwithstanding anything the regional policy statement or regional plan might say;
consider the implications of the plan on land use patterns, transport needs and hence air quality; and
make provision to consider where to locate new developments to protect the development from pollution, and to protect potentially polluting industry from unreasonable constraints i.e. take account of sensitivity and reverse sensitivity and avoid encroachment.

Territorial authorities should also include provisions in relation to any functions for air quality that have been delegated to them under section 33, Transfer of Powers.

Buffer zones and separation distances

Regional councils and territorial authorities should consider using separation distances where effects-based standards are largely qualitative, such as for odour, dust and spray drift. In these cases, it is more efficient and effective to use separation distances as a proxy for a qualitative standard. Plans need to recognise that buffer zones can work both ways. They can, for example, protect existing residential activities from new activities moving in, and also stop residential subdivision and development from occurring around existing activities.

Cross-boundary issues

Cross-boundary issues can be between geographical boundaries as well as between jurisdictions, and should be identified in the plan. They may be between:

districts, eg reduced ambient air quality in one district affecting another;
land and coast, eg emissions from ships;
regions, eg inconsistent policies such as for vegetation or road-seal burning or home heating controls; and/or
the region and the rest of New Zealand, eg consistency of ambient air monitoring data collection.

If there are no cross-boundary issues, this should be clearly stated in the plan.

Anticipated environmental results

Anticipated environmental results are indicators or measures that will be used when assessing progress to achieving the plans air quality objectives, eg:

ambient particulate (PM10) concentrations reduced by 60% of current levels by 2010;
a 50% reduction in the number of complaints relating to air quality by 2008; and/or
ambient air quality within regional criteria.

Monitoring and review

Regional councils, on the whole, need to undertake more ambient air quality monitoring. State what monitoring will be done to check whether anticipated environmental results are being achieved. This will monitor the effectiveness of the objectives, policies and methods, eg:

Monitor ambient air quality in areas most likely to be affected by air pollution, so air quality can be assessed in relation to guidelines and indicators.

Also:

Commit to review of the monitoring programme.
Commit to a review of the issues, objectives, policies and methods as necessary or when more monitoring data becomes available (at least every 10 years).

The monitoring programme design should be closely linked with a regions main issues of concern. The public should have the opportunity to comment on whether or not they believe the monitoring programme is sufficient. Results should be used to establish priority. Refer to the Good Practice Guide for Air Quality Monitoring and Data Management (MfE, 2000) for more information on monitoring programme design.

Information requirements for resource consents

Plans must include provisions specifying the information, including technical information that needs to be included with a resource consent application for a discharge to air.

A best practice example for regional plans is provided in the Proposed Canterbury Natural Resources Plan, Draft, 14 February 2002. Detailed schedules are provided that are relevant to specific activities discharging to the atmosphere.

District plan information requirements for resource consents relating to land use and the effects on air quality should include:

reasons for selection of the site itself;
the impact on amenity values;
the prevention of nuisance;
the impact on the road, transport networks and surrounding environment; and
the risk and impact of potential pollution insofar as it may affect other land uses.

Best practice examples

The following examples illustrate best practice in particular aspects of plan preparation, as described in the guidance note.

Natural Resources Regional Plan: Air Quality

The air quality chapter of Environment Canterbury's Natural Resources Regional Plan contains an objective based on air quality management areas and environmental performance indicators (EPIs). It also contains specific examples of effective and concise policies for addressing ambient and local discharges.

Amenity effects of land uses: Auckland Regional Council

Proposed Auckland Regional Plan: Air, Land and Water, chapter 4 (PDF 173KB)
The Auckland Regional Council has developed Air Quality Management Areas to integrate the management of land use planning, set out in the district plans, and air quality in terms of the ARC's responsibilities. This approach seeks to avoid issues of reverse sensitivity and conflicts between incompatible and competing land uses.

Amenity effects of land uses - New Plymouth District Council

Management Strategy (PDF 115KB)
Rules for pigs and chickens (PDF 50KB)
New Plymouth District Council differentiates zones and includes minimum separation distances in their plan to provide for the amenity effects of land uses and reverse sensitivity.

Amenity effects of land uses - Waimakariri District Plan

Proposed Waimakariri District Plan (as amended by decisions 24 February 2001), pages 12/14 to 12/15 (PDF 124KB)
The proposed plan contains objectives, policies and methods relating to the location and design of activities to manage land use effects on air quality. The main issue is intensive farming activities. Minimum separation distances are included in the plan.

Memorandum of Understanding - Taranaki Regional Council

Taranaki Regional Council has a memorandum of understanding (PDF 82KB) with the TAs in its region in order to manage the relationship between air quality functions and the effects of land uses.

Monitoring provisions in the air plan - Environment Canterbury

Pages 182 to 187 of the Proposed Canterbury Natural Resources Plan (PDF 513KB)
Environment Canterbury has comprehensive monitoring provisions in its proposed plan. These specify monitoring that will be done in response to specific and measurable anticipated environmental results.

Information requirements for air discharge consents - Environment Canterbury

Pages 128 to 135 of the Proposed Canterbury Natural Resources Plan (PDF 712KB)
Environment Canterbury has comprehensive information requirements in its proposed plan relating to specific activities.

Spray drift and agrichemical provisions - Hawke's Bay Regional Council

Hawke's Bay Regional Resource Management Plan
The plan contains provisions dealing with potential adverse effects on human health, property and the environment from agrichemical use.

Assessment criteria for odour and dust - Environment Waikato

Proposed Waikato Regional Plan, section 6.4
Environment Waikato has incorporated assessment criteria for odour and dust into the plan to assist with determining permitted activity and resource consent conditions.

RMA provisions

The sections of the RMA with particular relevance for a regional air plan or district plan in relation to effects on air are:

S2. Interpretation
S5. Purpose
S6(b). Protection of outstanding natural features and landscapes
S7. Other matters
S15. Discharge of contaminants into environment
S17. Duty to avoid, remedy, or mitigate adverse effects
S30. Functions of regional councils under this Act
S31. Functions of territorial authorities under this Act
S33. Transfer of Powers
S70. Rules about discharges
S418. Certain existing permitted uses may continue

Case law

Very few major cases relate to air quality-related provisions of plans, although many cases relate to air discharge enforcement and resource consent decisions. Plan-related cases are:

Definition of reverse sensitivity: refer to A010/97 Auckland Regional Council v Auckland City Council.

Territorial Authority functions for controlling land use and providing for reverse sensitivity in plans: refer to A010/97 Auckland Regional Council v Auckland City Council & C198/00 Talbot v Timaru District Council.

Permitted activities in a district plan provide a baseline for effects allowable in the existing environment: refer to M343/98 Bayley v Manukau City Council & AP24/01 Keystone Ridge Ltd v Auckland City Council & Keystone Watchgroup (inc).

Objectionable and its assessment (as basis for developing assessment criteria in Plans): refer to AP99/93 Zdrahral v Wellington City Council.

NB. Case law on objectionable effects is available in the Odour Management Guide, 1994, and the Good Practice Guide for Assessing and Managing the Environmental Effects of Dust Emission, 2001. The odour management guide will be updated in 2002.

Related guidance notes

Frequently asked questions on the national environmental standards for air quality

Work in progress

Central government programmes

Development of guidance on atmospheric dispersion modelling. Timeframe: 2002. Agency: MfE
Odour management guide review and preparation of new guidance. Timeframe: 2002. Agency: MfE
Indicators for urban amenity. Timeframe: 2002. Agency: MfE
Guide to assessing discharges to air. Timeframe: Draft in December 2002. Agency: MfE
Action for Air A strategy for sustainable air quality. Timeframe: Draft in 2002. Agency: MfE
Health and economic impacts of air pollution in New Zealand. Timeframe: 2003. Agencies involved: MfE/Health Research Council /MoT
Draft particle action plan. Timeframe: 2003. Agency: MfE
Review of PM10, PM 2.5, H2S and CO guidelines. Timeframe: 2004. Agency: MfE
New vehicle emission standards. Timeframe: 2003. Agency: MoT
Reducing vehicle emissions - further policy work. Timeframe: 2003. Agency: MoT
Fuel Specification Regulations. Timeframe: 2003. Agency: MED
Monitoring of transport & air quality indicators. Timeframe: ongoing. Agency: Indicators Web page
Indoor air issues and responsibilities. Timeframe: 2003. Agency: MfE
Current work is also listed on www.mfe.govt.nz/issues/air/programme/

Air Quality Working Group

The Air Quality Working Group is comprised of air quality practitioners from all regional and unitary and some territorial councils. They meet twice a year to discuss good practice in air quality management, research and policy developments. The meetings are also a good opportunity to organise the sharing of resources, such as monitors, and arrange secondments etc. To join the air quality working group.

Contact the Ministry for the Environment Air team on 04 439 7400.

Urban air quality processes

NIWA is also undertaking work in this area.
Programme coordinator: Gavin Fisher

Relevant publications

Below is a list of relevant references for air quality planning. Many reports are available from the Ministry for the Environment's Air publications list.

Ambient air guidelines and indicators

Preliminary Assessment of Human Health Indicators of Air Quality
Published by Ministry for the Environment - June 1999
This technical report provides a review of research into human health indicators of air quality and studies linking health effects to air pollution.

Ambient air quality guidelines
Published by Ministry for the Environment - May 2002
These guidelines provide guidance in how to manage air quality. They set guideline values to ensure our air is clean and healthy to breathe. They replace those first published by the Ministry in 1994.

Health Effects due to Motor Vehicle Air Pollution In New Zealand
Published by Ministry of Transport - January 2002
The Ministry of Transport has commissioned this study in order to assess the health effects due to air pollution emissions from vehicles on the population of New Zealand.

Amenity, dust and odour

Good Practice Guide for Assessing and Managing the Environmental Effects of Dust Emissions
Published by Ministry for the Environment - September 2001
This guide provides guidance on how to assess and reduce the environmental impacts of dust emissions.

Good Practice Guide for Assessing and Managing Odour in New Zealand
Published by Ministry for the Environment - June 2003
An update on the 1995 "Odour Management Under the RMA", giving a national approach to assessing and managing offensive odours, and advice on how to assess, monitor and manage the effects of odour.

Visibility in New Zealand - National Risk Assessment
Published by Ministry for the Environment - October 2000
This is the second of two documents prepared for the Ministry on the effects of air pollution on atmospheric visibility in New Zealand.

Odour Management under the Resource Management Act
Published by Ministry for the Environment - June 1995
A guide for managing odours under the RMA. The focus of this guide is to provide practical assistance, whilst taking into account legal interpretations and the roles of Councils in odour management.

Amenity Values Under the RMA (PDF 1 MB)
Published by Ministry for the Environment - February 1996
An outline of the references to amenity values in the RMA. It emphasises defining the term with suitable specificity in District Plans and suggests ways in which local authorities can do this.

Monitoring

Good Practice Guide for Air Quality Monitoring and Data Management
Published by Ministry for the Environment - December 2000
A good practice guide on air quality monitoring and data management: explains how to transfer data to the National Air Quality Database and the role of MfE's Environmental Performance Indicators.

Good Practice Guide for Monitoring and Management of Visibility in New Zealand
Published by Ministry for the Environment - August 2001
Guidance on the benefits of clear visibility, contaminants and factors affecting it, monitoring methods, indicators of visibility degradation, and how emissions causing degradation can be managed.

Compliance Monitoring and Emission Testing of Discharges to Air
Published by Ministry for the Environment - August 1998
This guide contains information and recommendations on determining compliance monitoring requirements, writing consent conditions and conducting emission testing.

Planning

Regional Air Plans
Author: Regina Thompson, MfE [Clean Air Society of Australia and NZ]
Date: November 1996
This is an address to Clean Air Society of Australia and NZ and is only available in CASANZ conference proceedings.

Conditions in Discharge Permits and Regional Plans
Author: Ron Pilgrim, Kingston Morrison [Clean Air Society of Australia and NZ]
Date: November 1996
This is an address to Clean Air Society of Australia and NZ and is only available in CASANZ conference proceedings.

Legal issues relating to Regional Air Plans and Air Discharge Permits
Author: J Tizard [Clean Air Society of Australia and NZ]
Date: November 1996
This is an address to Clean Air Society of Australia and NZ and is only available in CASANZ conference proceedings.

Tangata whenua

Urban Air The relationship between Māori and air/air quality
Author: Dr Charlotte Severne,
Date: June 2001
This is an address to Energy Federation of NZ Inc. Conference and is only available in their proceedings.

Review of the Ambient Air Quality Guidelines: Seeking Comments from Maori
Published by Ministry for the Environment - April 2001
In April 2001 the Ministry sought feedback from Maori into our review of the 1994 Ambient Air Quality Guidelines. This information sheet provided some background information.

Codes of practice

NZS 8409:2004: Management of agrichemicals
Published by Standards New Zealand - September 2004
Provides practical and specific guidance on the safe, responsible and effective management of agrichemicals.

New Zealand Pork Industry Boards Code of Practice Pig Farming, 2nd edition
Date:August 1997.
Available from the Pork Industry Board.

Poultry Industry Association of New Zealand's: Poultry Industry, Agreed Standards and Codes of Practice
Available from the Poultry Industry Association of New Zealand.

Miscellaneous

Ambient Air Quality and Pollution Levels in New Zealand: Targets for Vehicle Emissions Control
Published by Ministry for the Environment - December 1998
This technical report summarises information on the effects of vehicle emissions on air quality in New Zealand.

Dioxin Action Plan
Published by Ministry for the Environment - October 2001
This paper presents a national action plan for reducing discharges of dioxin to air.

Good Practice Guide for Preparing Emission Inventories (PDF 496KB)
Published by Environet Ltd - June 2001
A step-by-step guide to preparing emission inventories in New Zealand, containing information on the purpose, process, methodology and application of emission inventory investigations in NZ.

A Guide to Health Impact Assessment Guidelines for Public Health Services, Resource Management Agencies and consent Applicants, Public Author: Health Commission
Date: 1995
Available from the Ministry of Health.

Reducing Emissions from Domestic Home Heating
Published by Ministry for the Environment - May 2002
This technical report assesses the options for managing the emissions from domestic fires.

AS/NZS 4013:1999: Domestic solid fuel burning appliances - Method for determination of flue gas emission
Published by Standards New Zealand - July 1999
Specifies a method and requirements for determining the rate of particulate emission from batch feed solid fuel burning appliances.

AS/NZS 2918:2001: Domestic solid fuel burning appliances - Installation
Published by Standards New Zealand - November 2001
Specifies requirements for appliance and flue installation for solid fuel burning appliances in dwellings.

Management of agrichemical spray drift
Author: Parliamentary Commissioner for the Environment
Date: 1993.
Available from the Office of the Parliamentary Commissioner for the Environment.

Websites

Current challenges in practice

Getting data and information on the state of the environment

There is a lack of information generally on air quality issues. This can be attributed to the historical context of air management where the focus was on controlling air pollution from industrial activities. Air quality has generally been a lower priority within regional councils. These were formed from catchments boards and so retained knowledge about water management, but no institutional expertise in air quality.

Getting regional council management and politicians to acknowledge the importance of gathering air quality data has been a considerable challenge. Some regions still lack sufficient information to manage air quality according to air quality areas. Also, many existing plans address only the industrial sources of air pollution.

Establishing emission factors from sources

The accurate identification of specific sources of air pollution is difficult. It also costs a lot. However, it is needed to prepare accurate emission inventories.

Of major concern are accurate emission factors for new domestic solid fuel-burning appliances. Testing procedures in the joint New Zealand/Australian standard represent somewhat idealised operating conditions (eg the way the appliance is loaded and the type of fuel used). In most instances, the testing standards do not indicate performance under actual operating conditions.

Section 32 - analysis of health effects

There is a lack of guidance on how to consider the health, economic and social impacts of policies and measures to manage air quality. Many s32 assessments are done purely from a technical air quality viewpoint or on a qualitative basis. This has caused problems with getting policies approved, eg options for domestic heating controls in Canterbury.

There is little information about the health effects and costs of air pollution on New Zealanders. To properly evaluate the costs and benefits of policies to improve ambient air quality, it may be necessary to undertake exposure assessments and risk characterisation for air pollutants. These overlap with public health responsibilities.

Climate change

Climate change threatens the life-supporting capacity of the air, but the role of local government in meeting greenhouse gas targets is unclear and a matter of debate. Further, there are problems with cross-boundary issues and section 32 analysis in introducing measures at a regional level. Plans may not be the most efficient way of achieving climate change objectives, which are on national and international agendas. For example, councils can use discretionary activity rules to manage individual sources on a case-by-case basis. This, however, generally only addresses the industrial sector, which should not be treated separately from other greenhouse gas sources.

The government has announced its preferred policy package for reducing greenhouse gas emissions in response to climate change and the Kyoto Protocol. A discussion document on this package has been released and cosultation meetings were held in May to discuss the preferred policies.

The report states:

"The Government intends to amend the RMA in order to remove the ability of councils to control activities, via resource consents or rules in plans, for the purpose of reducing greenhouse gas emissions and their effects on climate change. It expects that in time, climate change price instruments will address greenhouse gas emissions in a more consistent and efficient manner than RMA controls on emissions to air.

The objective of any RMA amendment would be to avoid putting RMA resource consent applicants in the 'double jeopardy' position of being required to mitigate effects under the RMA framework, when they also have to meet obligations under the Government's national climate change policies".

The report is available from the website of the New Zealand Climate Change Programme.

The preferred policy package has not been approved yet, but if a Bill is drafted in line with the package then this will certainly bring challenges to local government. It seems however that RMA tools can continue to be used for controlling land uses and developments, and the local amenity and health effects of greenhouse gas emissions. That is, councils will still be able to use the RMA to consider whether urban development, land use and transport proposals might increase the emissions of greenhouse gases and thereby exacerbate changes in the climate. Also, emissions of some greenhouse gases have local effects and it is intended that councils still be able to consider local effects in their decision-making processes.

Transport and land use

More work needs to go into regional transport planning and urban design to manage the effects on air quality. National controls on vehicle emissions are coming into place. However, work done by the Ministry of Transport has shown that gains made at a national level by improving emissions from individual motor vehicles are not sufficient in themselves to achieve the necessary air quality improvements. Roading design and other measures to reduce congestion may be the best means for reducing emissions from motor vehicles.

To reduce dependence on private vehicles and improve the consideration of air quality issues in transport and district planning, a co-ordinated approach is needed among TAs, Transit NZ, and regional councils.

A challenge also lies in the number of different agencies responsible for transport planning (Ministry of Transport, Land Transport Safety Authority, Transfund and local government). As noted above a co-coordinated approach is necessary to resolve many of the issues associated with transport, air quality being just one of these.

Gaps and overlaps with health effects

There are both gaps and overlaps in the management of air quality. These include:

overlaps between regional councils for offensive or objectionable effects under the RMA, and the Ministry of Health and TAs for nuisance under the Health Act;
uncertainty about the lead agency in matters of public health and environmental health. For example, this overlap led to difficulties with the management of agrichemical spray drift incident response, before regional plans clearly addressed the issue; and
the lack of a responsible agency for non-workplace indoor air. This leaves a significant gap for an issue where the effects of air pollutants can be significantly greater than the effects of outdoor exposures, eg unflued heating appliances.

Hazardous substances and HSNO

Hazardous substances as air discharges are referred to as hazardous air pollutants or HAPs. HAPs have often been overlooked in the past management of air pollution in New Zealand, although several are now included in the 2002 Ambient Air Quality Guidelines. There has often been a lack of information about acceptable environmental criteria, and air management has focused on classical ambient air pollutants. The 1994 MfE Ambient Air Guidelines recommended a precautionary approach to managing HAPs. As a result different approaches have been used to assess discharges and interpret monitoring results, usually on a case-by-case basis.

The Ministry for the Environment has developed some guideline values for priority HAPs for air-shed management and specific guidance on managing hazardous air contaminants from individual sources is currently being prepared. This draft guidance will be published in December 2002 for comment.

A related issue is the emerging uncertainty over the role of councils in managing hazardous air pollutants, particularly with the introduction of the Hazardous Substances and New Organisms Act (HSNO) and the transition provisions. This is complicated by the flexibility within the Act for the enforcement regime. Many agencies are still potentially involved. HSNO has implications for air plan policy development, for example in the area of agrichemical use or in design of ambient air monitoring programmes.

The links between air quality and hazardous substances as air pollutants should be considered in plans. However there is insufficient consensus and too many emerging issues to recommend a practice at this time.

Acknowledgements and editorial comments

This guidance note was prepared by Deborah Ryan, Sinclair Knight Merz, July 2002.

NB: Phil Gurnsey (on secondment to MfE from Environment Canterbury) assisted the Editorial Panel in its review of this guidance note.

This guidance note was prepared in August 2002.

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