Parliamentary Commissioner for the Environment - Te Kaitiaki Taiao a Te Whare Pāremata

Submission on Proposed Changes to the Air Quality NES

Introduction

There is a link between air quality and health. Dirty air is a risk to human health. Even though most of New Zealand enjoys clean air, a few areas of New Zealand suffer serious outdoor air quality problems. While uncertain, recent studies estimate poor air quality in this country could cause between 7001 and 10002 premature deaths per year. Although air quality is often thought of as being an environmental issue, improving poor air quality is more about protecting human health.

In New Zealand, air quality is managed by Regional Councils who are required to comply with the National Environmental Standards for Air Quality. These standards include banning certain activities such as burning tyres, design requirements for wood burners, rules for landfill emissions and five ambient air quality standards. One of these ambient standards is for particulate matter less than 10 microns in size, known as PM10. This standard requires that the daily average PM10 concentration in air can exceed 50 μg/m3 only once per year.

With the aim of reviewing the PM10 standard, the Minister for the Environment appointed a Technical Advisory Group (TAG) who produced a detailed report in November 2009. Based on the TAG report, the Ministry in June of this year released a document proposing changes to the PM10 standard and requested public feedback. This submission is in response to that request.

The TAG report provides a valuable source of advice to decision makers on the PM10 standard. However, the TAG were constrained by their terms of reference. This submission seeks to add to the TAG report by describing air quality management in a broader context.

This submission consists of two parts. The first part describes specific challenges with regard to air quality management in New Zealand. The second part presents ten recommendations. Some of these recommendations are aimed at meeting the challenges described, and some are in response to specific proposals to amend the PM10 standard.