National Environmental Standards on Air Quality - Amendment Proposals Submission from Marlborough District Council - Ministry for the Environment
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National Environmental Standards on Air Quality –
Amendment Proposals
Submission from Marlborough District Council
Marlborough Context
In February 2020 the MDC released the decision on the Proposed Marlborough Environment Plan (PMEP).
The PMEP was developed following a review of the operative planning documents in the Marlborough
region, and it implemented relevant national direction in place at the time of drafting. This included
drafting the provisions of the PMEP to implement the current NESAQ.
Marlborough’s annual State of the Environment monitoring has shown that in the last 10 years the current
standard of not more than one exceedance of the PM10 daily standard of 50μg/m3 has been met twice,
while the number of breaches of the standard has varied between one to ten times.
It would be fair to say that sufficient time has not yet passed post the notification of the PMEP to be able to
fully assess the effectiveness of those provisions but there remains a level of comfort that, with the
implementation of additional non‐regulatory behavior programmes in the future, the PMEP will implement
the existing NESAQ. The implementation of the existing NESAQ through the PMEP has, and will continue to
be, at a cost to the community and the Council is very mindful of this in the context of the potential for the
proposed NES amendments to add additional costs.
However, the Council does recognise the benefits of focusing on PM2.5 in some manner to achieve greater
health outcomes. This is reflected in the Council’s commitment to monitoring PM2.5 over the past three
years. The data obtained through this monitoring has allowed the Council to make informed submissions
with respect to compliance and the potential effects of the proposal.
Approach in Submission
The Council appreciates having this opportunity to provide feedback, and would welcome any opportunity
to contribute to the final drafting of the NESAQ. Council staff are available to answer questions in relation
to any of the matters raised in this submission.
The MDC has generally taken the approach of providing feedback where there are matters in the National
Environmental Standards on Air Quality (NESAQ) Amendment Proposal that have particular impact in a
Marlborough context, or where we support the concerns raised on other matters by other regions. The
matters raised include support for the introduction of an annual PM2.5 standard, alternative options to the
daily PM2.5 standard proposed, costs and benefits of the proposals, support for non‐regulatory
programmes, and the lack of health benefits associated with reducing the design criteria for burners. We
are also taking this opportunity to raise concerns around the basis on which the proposals have been
developed, and the assessments of the impact of the proposals, particularly in a Marlborough context.
The Council sought expert advice from Dr Emily Wilton from Environet Limited on the content of the
proposed amendments to the NESAQ, and in particular requested an assessment of the implications for
Marlborough, both generally and relative to the PMEP. Environet’s report has informed this submission,
and is attached as part of the Council’s feedback. Dr Wilton also joined with the Council in recent
consultative discussions with the Ministry, along with other regional councils.
1The format of this submission follows the questions posed in the consultation document, to the extent that
the MDC wishes to provide feedback. The question numbers used (e.g. Q1) relate to the numbering in the
consultation document rather than being sequential. Please refer to Dr Wilton’s report for additional detail
on the feedback provided.
Resourcing Issues
The Council would like to note that having recently completed (subject to the appeal process) a full review
of the region’s planning documents, including a significant community process over a number of years,
revisiting the air quality provisions so soon after reaching this milestone would potentially have substantial
resource implications that would not have been planned for in the near future. This could potentially be
mitigated to some degree by a transitional approach being taken to the amendments, and central
government support with behavior programmes.
This is separate to the costs to the community from the implementation of the NESAQ amendments, which
are discussed further in this submission.
Summary of matters raised by the MDC
General support for the introduction of new standards focusing on PM2.5 rather than only PM10. For
managing chronic health effects.
The Council seeks alternative options to the daily PM2.5 standard for managing acute health effects.
The assessment of the costs and benefits of the proposed daily PM2.5 standard has been based on
incorrect assumptions that Marlborough would meet the proposed standards.
The lack of acute health benefits in a Marlborough context from the proposed addition of a daily
PM2.5 standard at 25µg/m3, particularly given the potential costs for the community of imposing
further regulation.
Central government support and resources in relation to non‐regulatory approaches to improving
air quality and meeting NESAQ standards.
The lack of health benefits associated with reducing the NESAQ design criteria for wood burners
from 1.5g/kg to 1.0g/kg.
Concerns that the technical assessment in the NESAQ proposal documents includes errors, which
lead to inaccurate predictions of annual average concentrations for 2018 and 2028 for Blenheim.
The Council supports the concerns raised by the Nelson City Council regarding the process of
authorising new woodburners, in particular MDC supports shifting the responsibility for authorising
appliances to the appropriate Government Ministry, or other non‐local government entity.
Introduce PM2.5 as the primary regulatory tool to manage particulate matter pollution
Q1. Do you agree the proposed PM2.5 standards should replace the PM10 standard as the primary
standard for managing particulate matter?
Not as proposed. The Council in principle supports PM2.5 standards being used to manage
health impacts, however not the proposed daily PM2.5 standard of 25µg/m3. It is the Council’s
view, informed by expert advice, that the basis for this standard as proposed is flawed and
2should be reviewed. If it is not reviewed, and the justification for the standard continues to be
the WHO 2005 guidelines, a standard of around 40‐45µg/m3 would be appropriate for
Blenheim.
Over three years of PM2.5 monitoring data is available for Blenheim which has enabled a better
understanding of the ratio of PM2.5 to PM10 particularly over the winter months when higher
levels of particulate matter occur from domestic heating sources. A PM2.5 standard based on a
PM10 concentration of 50μg/m3 (24‐hour average) using the rationale in WHO (2005) for
Blenheim would likely be around 40μg/m3 but could be as high as 45μg/m3. For this
concentration, as would be expected under the rationale for the setting of the standard, no
additional management measures would be required over and above those proposed to
achieve the reductions required in PM10.
The Council supports the introduction of an annual PM2.5 standard for managing chronic health
impacts. However it is the Council’s view, based on expert advice, and considered in the
Marlborough context, that the daily PM10 standard would be appropriate to retain for the
management of acute health effects from domestic heating emission source.
The Council recognises that the proposed change to PM2.5 is a significant change and the
financial implications to the Council and more importantly to the community of this change in
a post COVID economy is likely to be a just as significant.
Q2. Do you agree we should include both a daily and an annual standard for PM2.5?
The Council supports the introduction of an annual PM2.5 standard but not the daily PM2.5
standard as proposed. The MDC has an existing monitoring programme in place for PM2.5 since
2017, as it recognises that it is an appropriate measure for managing impacts of particulates on
health. It is the Council’s submission that a review of the basis for the proposed daily standard
is necessary given the matters raised by Dr Wilton in the Environet report, particularly
regarding the veracity of the technical reports supporting and justifying the proposals. There is
concern that the pathway to the proposals presented has not been sufficiently considered in
the New Zealand context.
As discussed in the Environet report, Dr Wilton does not consider the NIWA methods are
sufficiently robust as to provide estimates of annual average PM2.5 or daily PM2.5 and suggest
that an alternative approach is adopted. While an annual average PM2.5 standard is supported,
it is Dr Wilton’s view that the WHO 2005 guidelines do not represent the best available
information to inform that standard.
Q3. Do you agree the standards should reflect the WHO guidelines?
Yes, in principle, however not in the manner applied in the proposals. The Council is also wary
of the timing of the proposed amendment given that the WHO guidelines are now over 15
years old and are currently being reviewed, and there are already indications that the
proposed reviewed guidelines would not be reflective of the current proposals in front of us.
Concerns are held about the potential impact of the proposed amendments on the
community; this concern is increased by the potential for the WHO review to lead to another
3round of regulatory changes in the near future. One option would be to delay the NES
amendments until the WHO guidelines review is completed, this would avoid potentially
introducing new regulation to the community twice.
Of significant concern with the proposed amendments is that the WHO 2005 guidelines are
used as justification but in a New Zealand context the daily standard proposed does not
actually reflect the guidelines. If it did, the daily standard would be more like 40‐45µg/m3 for
the Blenheim Airshed.
The MDC is also aware that there is further work being undertaken in New Zealand to update
the Health and Air Pollution in NZ (HAPINZ) 2012 study which will use more recent data and
could provide useful guidance with a New Zealand context to inform the standard.
Q4. Do you consider that your airshed would meet the proposed PM2.5 standards? If not, what emissions
sources do you expect to be most problematic?
Based on the monitoring of PM2.5 in the Blenheim Airshed over the past three years, the
standards would not be met. In 2017, there would have been 72 exceedances had this
standard been in place, in 2018 61 exceedances, in 2019 33 exceedances, and so far in 2020
there have been 21 exceedances already. Monitoring has also shown that the proposed
annual standard of 10µg/m3 has not been met in the last three years. In 2017 the annual level
was 14µg/m3 reducing to 13µg/m3 in 2018 and 11.5µg/m3 in 2019. The emission source that is
most problematic is domestic home heating. Based on monitoring to date this emission source
for the winter months, when this source is dominant, has a ratio of PM2.5 to PM10 of 0.8 to 0.9,
indicating that the majority of PM in Blenheim from this source is PM2.5.
It is noted that the data collected for the Blenheim Airshed is at odds with the NIWA research
provided in support of the amendments, in particular the under‐estimation of the number of
exceedances, and therefore the impact of implementation of the new standards. This is one of
the significant areas of concern for the Council regarding the basis on which the proposals have
been made. This concern is compounded by the Market Economics evaluation being informed
by the NIWA 2016 model data not the updated NIWA 2019 model that supports the proposals.
In the Council’s view the daily standard in particular needs to be reviewed in light of the
inaccuracies in the technical reports.
Part of Environet’s evaluation on the impact of the proposed amendments for the MDC was
analysis of the level of reductions that would be required in the Blenheim Airshed to meet the
proposed PM2.5 standards. Based on the worst case scenario year of 2017, for which records are
available for both PM10 and PM2.5, the analysis has shown that daily winter PM2.5 concentrations
would need to halve in order to meet the proposed PM2.5 daily NESAQ. The reduction required in
annual average PM2.5 concentrations to meet the proposed annual average PM2.5 standard of
10µg/m3 is 30%.
Environet evaluated the effectiveness of the PMEP measures in reducing annual average PM2.5
which suggested that a target reduction of 30% may be met by measures to reduce daily winter
PM10 by 38%. However, concern was raised that outdoor burning during spring would reduce the
ability to meet that level of reduction and further regulation would be required. In regards to the
proposed daily PM2.5 standard, Environet’s assessment highlighted that even with the PMEP
4regulations and effective behaviour change programmes, this would not be met. Even if a
requirement was introduced that by 2022 households had to replace old burners with ultra‐low
emission burners (ULEB) this would unlikely be sufficient to result in compliance with the proposed
daily standard before 2032. As such other regulatory measures would also have to be imposed
along with ULEB’s, such as not allowing solid fuel burners in new dwellings or existing dwellings that
do not currently use solid fuel.
Whilst ULEBs have reduced in price since their introduction to the market, they are still more
expensive than standard burners and many households, particularly in a post COVID‐19 economy,
will not be able to afford the additional capital costs associated with ULEB. Alternatively the option
to move to non‐solid fuel alternatives would likely result in higher living costs as around 20% of
wood used in Blenheim is self‐collected. This in turn has the potential to lead to colder homes
which also have serious health issues.
Retain the PM10 standard with reduced mitigation requirements for breaches
Q5. Do you agree councils should be required to keep monitoring PM10?
Yes – as a daily standard until a review of the proposed daily PM2.5 standard is completed.
Q6. What would be the additional costs involved in retaining PM10 monitoring alongside PM2.5
monitoring, versus the potential loss of valuable monitoring information?
For Marlborough we are already monitoring both PM10 and PM2.5 in our gazetted Blenheim
Airshed and as such there would be little cost recovery by the removal of the PM10 monitoring
but a significant loss of valuable long term monitoring data. However should other areas of
Marlborough, for example Picton, require new monitoring to be set up there would potentially
be a greater set up cost in regards to the purchase of monitoring equipment for both PM10 and
PM2.5 rather than just one.
Polluted airsheds and resource consents
Q7. Do you agree an airshed should be deemed polluted if it exceeds either the annual or the daily PM2.5
standard?
Yes – certainly being considered a polluted airshed would provide further support towards
more stringent regulations and support for behavior change programmes.
For the reasons explained elsewhere in this submission, we would not support the use of the
proposed daily PM2.5 standard until it is reconsidered and the concerns raised are adequately
addressed.
Q8. If all new resource consent applications to discharge PM2.5 into a polluted airshed must be offset or
declined, how would this affect your activities, or activities in your region?
Like many regions in NZ the offset provisions have not been extensively used in Marlborough.
However they provide a deterrent and/or incentive to applicants to consider all operational
options to ensure air discharges are kept to a minimum within the airshed.
Q9. Can you identify a more appropriate, measurable threshold for controlling consented discharges in a
5PM2.5 context?
As mentioned previously offsets have not been used extensively in Marlborough but some
form of threshold for considering the impacts from industrial discharges into airsheds is useful.
The rationale behind a change from a PM10 to a PM2.5 threshold for offsets is not clear and it is
suggested that more work should be undertaken before an additional threshold is introduced.
Q10. Do you agree that if councils do not have adequate PM2.5 data, the airshed’s classification under the
PM10 standards should apply?
Monitoring of PM2.5 in Marlborough has shown that during the winter months the majority of
PM10 is PM2.5 with the source of PM being predominantly from domestic heating. If a Council
has only been monitoring PM10 and the dominant emission source is domestic heating then
from the data we have gained in Marlborough it is likely that it would be appropriate for the
airshed’s classification to be based on the PM10 standards.
Domestic solid‐fuel burner emissions standard
Q11. Do you agree with the proposal to reduce the emissions standard to no more than 1.0g/kg? If not,
what do you think the standard should be?
Based on the expert advice from Environet, the Council is of a view that there will not be
health benefits associated with reducing the design criteria for wood burners from 1.5 g/kg to
1.0 g/kg in Blenheim, or anywhere else in New Zealand. There is no scientific evidence that
supports the assumption that reducing the design criteria for wood burners to 1.0 g/kg will
result in improvements in emissions from wood burners.
While supported in principal, there will be no health benefits associated with the application of
the design criteria for wood burners to all other domestic solid fuel burners for Blenheim as
this measure is already required via the PMEP. This raises concerns in terms of community
costs versus benefits, particularly with relative new regulation in place via local planning
documents that was developed to implement the existing NESAQ.
The MDC recommends a process is followed to assess the effectiveness of policy options
of reducing the design standard for woodburners, as set out in the attached Environet
report.
Q12. Are there areas where a lower (more stringent) standard could be applied?
Several other regions in New Zealand have lower emission standards which have been
effective in decreasing PM in those areas. If the reduction of the emission standard is to
support reduction in PM from this source and the associated health effects then the
emission standard should be based on obtaining real life reductions. This in practice means
that ULEB’s would be required. As the proposal stands the reduction in emission standard
from 1.5g/kg to 1g/kg only removes a small number of burners from the approval list and
is unlikely to gain large health benefits. If the main goal to be achieved is significant
reduction in PM in airsheds that are dominated by domestic heating sources then perhaps
more stringent standards should be applied now across all polluted airsheds?
Consideration needs to be given to the costs to the community of continued incremental
decreases in burner emissions against the costs of ULEB appliances. The MDC would
6support the government investigating ways to make ULEB appliances more affordable.
All domestic solid‐fuel burners covered
Q13. Do you agree the new emissions standard should apply to all new domestic, solid‐fuel burners newly
installed on properties less than two hectares in size?
The MDC agrees with this aspect of the proposal but seeks clarification if this will apply to all
burners installed on a property, that is both indoor and outdoor. The MDC has experience of
installations being sought within the Blenheim Airshed for the heating of outdoor amenity
spaces, and these still contribute to the PM load into the airshed.
Q14. Do the current methods to measure emissions and thermal efficiency need updating or changing?
For example, to address any trade‐off between thermal efficiency and emissions, or to test other
types of burners or burner modifications that seek to reduce emissions?
Changing the units of the standard, for example to mg/MJ, may be appropriate to tackle the issues
of trade‐offs between emissions and efficiency. However, burner testing is very complex so there
should be clear goals for this change and clear levels set based on real life testing. In principal the
MDC sees the benefit of some trade off in efficiency in order to make significant gains in emission
reduction.
Timing, implementation and transitional provisions
Q21. Do you agree that lead‐in times are required for starting to monitor PM2.5 and for burners that will
no longer be compliant? What lead‐in times do you suggest and why?
MDC has been monitoring PM2.5 for three years, so a picture of air quality relative to that
measure is beginning to be built. However it is understood that across regional councils the
monitoring will be at various stages for different airsheds, therefore lead‐in times are
supported by the Council.
Of greater concern to the Council are the lead‐in times for burners that will no longer be
compliant. Having so recently undertaken a review of our planning documents and imposed
regulation to implement the existing NESAQ, there is the potential for the Council to have to
revisit relatively new installations (e.g. to replace them with ULEB or other forms of home
heating) at an unacceptable cost to the community, both economically and from a health
perspective as there may be an increase of cold homes. While there is clear support for lead‐
in times for replacing non‐compliant burners, the Councils primary position is that the change
in emissions standard to no more than 1.0g/kg would not have the health benefits purported,
and there is no scientific evidence that the reduction would result in improvements in
emissions from wood burners.
The MDC is of a view that given the potential costs of the amended regulation, that there be
no compliance date in the amended NESAQ. The Council’s suggestion is that the compliance
date could be set by the Councils in consultation with their community.
Q22. Are there any matters you think would require transitional provisions? If so, what?
The Council suggests that a transitional provision around exceedances would also be
appropriate to enable Council’s to put in place non‐regulatory programmes and align plans.
7Other comments
Q23. Do you have any other comments you wish to make?
Technical Assessments
On the Council’s behalf, Environet has considered the quality of the technical aspects of the
NESAQ. Their assessment of the technical work supporting the NES amendment proposals
raises concerns about its robustness. The outputs of the 2014 PM2.5 assessments have been
demonstrated (through monitoring) to not provide a reasonable approximation. No adequate
assessment of the health basis for the guidelines and the appropriate setting of guideline
levels has been carried out. The methods used for assessing the impacts of existing measures
and providing an approach for estimating the impacts of policy options is inadequate and the
assessment of the impacts of policy options has no technical grounding. Environet have good
understanding of the process of cost benefit analysis for air quality (having worked closely with
economists on similar air quality projects including the 2004 NESAQ) but are not qualified to
provide review comments on the economic methods and assumptions. They do note that the
impact of policy options on air quality has been assessed by the economists and it should be a
scientific assessment, rather than an economic one, and therefore is flawed. The technical
information underpinning the economic analysis is inadequate and the outputs are
nonsensical.
The MDC was disappointed to see that updated PM2.5 data provided to the Ministry and
used by NIWA in its updated 2019 model of PM2.5 in New Zealand report was not also used
to inform an updated cost benefit analysis.
Education/Behavioural Programmes
The NESAQ proposed amendment includes a brief mention of the importance of non‐regulatory
education programmes, to continue to drive progressive improvement in home heating
performance and ambient air quality. While there is mention of government programmes to
assist parts of the population in affording new burners there is little nationwide government led
behavior change assistance. This has been left to the Regional Councils to undertake, and while
a few regions have had excellent programmes in this space, the resources to run these
programmes far exceeds those available to smaller Councils. The MDC would support a
nationwide, home heating government led behavior change programme, which is undertaken
with input from people with expertise in successful mass population behavior change. This
would provide a nationally consistent effort which would greatly help to effect change on a
large scale resulting in far more significant gains in PM reduction from home heating.
Post Covid‐19 Economic Recovery
Currently the MDC offers an energy funding service to ratepayers for approved home clean
heating installation. For this service the Council will provide funding for the cost of an approved
home clean heating solution, which will be recovered over nine years through a targeted
homeowner property rate. While this scheme is well used, in order to meet the changes to
Blenheim’s burner fleet, to meet the proposed daily PM2.5 standard this scheme could
potentially be overwhelmed. The MDC also supports and works closely with Energy Efficiency
and Conservation Authority (EECA) in relation to the Government’s Warmer Kiwi Homes
programme. The MDC would like to raise whether in the post COVID economy there is the
potential to expand this scheme to a larger proportion of the population that are likely to
experience financial hardship in the next few years and will not be in a financial position to
replace their burners? Given the restraints on council budgets it is unlikely that subsidises such
as those provide by EECA could be provided by the Council to assist the community with the
changes required to meet the proposed NESAQ.
8An expansion of the EECA subsidy scheme to a greater proportion of the population could also
support nationwide regional economic recovery with the stimulus of replacement burner or
heat pump installations on the local building industry and appliance suppliers. The EECA
programme also recognises that clean heat is only part of the solution and that this needs to be
combined with ensuring that the country’s housing fleet is also fit for purpose with both ceiling
and floor insulation as a minimum. Again expansion of this scheme would provide further work
to the local building industry and associated retailers to upgrade insulation.
It is likely that there would be excellent uptake of this scheme if expanded, with the result
being warmer drier homes for a greater proportion of the population and associated reduced
health effects and loss of productivity associated with cold damp homes.
As mentioned previously, the MDC would also support the government investigating ways to
make ULEB appliances more affordable, and this would also apply to heat pumps. Replacement
of burners for heat pumps eliminates emissions into the local air, however the price of
electricity is also critical to ensure that the installation of a heat pump does not increase
financial hardship, which may result is reduced use of the appliance and resultant colder
homes. As New Zealand moves towards a more electrified economy to meet climate change
obligations this provision of reasonably priced, renewable electricity generation will become
more and more critical.
The Council strongly encourages central government to consider support and resource
initiatives for non‐regulatory approaches and expansion of subsidy schemes to improving air
quality and meeting NESAQ standards.
Summary
The Council appreciates this opportunity to provide feedback on the National Environmental Standards on
Air Quality – Amendment Proposals, and welcome contact from the Ministry if we can be of any further
assistance.
9MARCH 2020
PREPARED FOR
Marlborough District Council
PREPARED BY
Emily Wilton, Environet Ltd
www.environet.co.nz
Evaluation of the NESAQ
proposed amendments
and the impacts for
BlenheimEnvironet Ltd accepts no liability with respect to this publication’s use other than by the Client. This publication may not be reproduced or copied in any form without the permission of the Client. All photographs within this publication are copyright of Environet or the photographer credited, and they may not be used without written permission.
EXECUTIVE SUMMARY There will be no health benefits associated with the introduction of an annual average NESAQ for PM 2.5 of 10 µg/m3 in Blenheim. This is because Blenheim will likely be compliant with the proposed standard as a result of the status quo and no additional regulatory measures would be required. There will be health benefits associated with the introduction of a daily winter PM 2.5 standard but these will be dominated by the coincidental reduction in annual average concentrations (to below 10 µg/m3). Based on the rationale for setting the WHO standards the actual health benefits of a daily winter PM 2.5 standard should not be greater than those achieved through reductions to meet a daily winter standard of 50 µg/m3 for PM 10 . In the New Zealand context, the proposed PM 2.5 daily standard is more stringent because 25 µg/m3 is not the equivalent of a daily PM 10 concentration of 50 µg/m3. Based on the rationale in WHO (2005) the daily PM 2.5 standard of around 40-45 µg/m3 would be appropriate for Blenheim. The proposed NESAQ for PM 2.5 have not been set based on current scientific information, nor have they been set appropriately relative to the rationale in WHO (2005). It is our strong recommendation that they be reviewed. If they are not reviewed and WHO (2005) is the justification for the proposed standards then the acute impacts should be managed by the existing daily PM 10 standard of 50 µg/m3. That is there is no daily PM 2.5 standard. The reason for this is that WHO (2005) does not provide justification for a PM 2.5 daily standard that is more stringent than the PM 10 standard (i.e., it is based on PM 10 and health impacts observed for PM 10 ). In Blenheim the costs associated with meeting the proposed daily winter PM 2.5 standard would be significant to householders as they’d have to replace their burners with ULEB. Some household will be unable to afford the additional capital cost associated with ULEB and will have to opt for non-solid fuel alternatives which would result in higher living costs, for households that self-collect firewood. Around 20% of the wood used in Blenheim is self-collected. Cold homes in Blenheim is a potential outcome if the PM 2.5 standard is adopted. We do not believe there will be health benefits associated with reducing the NESAQ design criteria for wood burners from 1.5 g/kg to 1.0 g/kg in Blenheim or anywhere else in New Zealand. We do not believe there is scientific evidence that supports the assumption that reducing the design criteria for wood burners from 1.5 g/kg to 1.0 g/kg (tested to 4013) will result in improvements in emissions from wood burners. We do not support this measure. There will be no health benefits associated with the application of the design criteria for wood burners to all other domestic solid fuel burners for Blenheim as this measure is already required via the Marlborough Environment Plan. This measure is supported in principal, however. Our evaluation identified major issues with the technical assessment. The culmination of these errors is the prediction of annual average concentrations for 2018 and 2028 (Appendix 3 in the Market Economics Report) which are grossly inaccurate for Blenheim and other airsheds. The analysis draws the unlikely conclusion that areas with minimal historical regulation (greatest differential between existing and future burner fleet) will have minimal benefits (e.g., Putaruru) and areas of higher existing regulation will have significant improvements (e.g., Nelson Airshed A). The cost benefit analysis does not take into account the impact of existing legislation on PM 2.5 concentrations in each airshed. Consequently, the impacts of the proposed policy (even if accurately estimated) would be in error. The assessment of airsheds that will remain non-compliant following the introduction of the proposed policy will be in error. The proposed NESAQ and supporting technical reports appear incognisant of variability in meteorological conditions and the impact on airshed concentrations. This introduces an additional error. No assessment of the costs and benefits of the proposed daily winter PM 2.5 standard appears to have been carried out. No discussion of fourth highest or even highest daily winter PM 2.5 concentrations is made. No methodology for assessing the effectiveness of proposed measures on daily winter concentrations is detailed. The Ministry has not carried out a robust cost/ benefit analysis on the proposed policy. The assessment of benefits is flawed and the measures required to meet the proposed NESAQ for each airshed have not been identified so the costs associated with these measures cannot have been adequately included. Moreover, the
authors have not distinguished the policy impacts from existing air plan measures, so a robust cost analysis is even more unlikely. The authors of the ME report state that because of strict timeframes they were unable to audit or review information sets and did not verify information such as the current situation, the replacement rates, market churn, costs and cost differences, fuel costs and installation costs. In the case of the key variables that have significant impact on the analysis our information indicates that the current situation and the replacement rates assumed by ME are grossly out as are the results they have estimated for benefits in particular. It is our view that an annual average PM 2.5 standard is required. We do not believe WHO (2005) represents the best available information to inform that standard. We do not believe the NIWA methods are sufficiently robust as to provide estimates of annual average PM 2.5 or daily winter PM 2.5 and suggest that an alternative approach is adopted. The method proposed by Golder and Associates for estimating the status quo and impact of reductions in emissions on annual average concentrations is not robust. We do not believe there is any validity to the estimate of costs and benefits provided by Market Economics. It is evident from the quality of the proposed NESAQ that procurement procedures, co-ordination of work set and potentially timeframes set by the Ministry are unsatisfactory.
TABLE OF CONTENTS
1 Assessing the impacts of the proposed PM 2.5 NESAQ in BLenheim ............................................. 1
1.1 Method ....................................................................................................................................... 1
1.2 Reductions required in PM 2.5 ..................................................................................................... 1
1.3 Comparison to reduction target in MEP based on PM 10 (24-hour average). .............................. 2
1.4 Annual average PM 2.5 standard ................................................................................................. 2
1.5 Daily PM 2.5 standard .................................................................................................................. 3
2 Assessment of costs and benefits .................................................................................................... 6
2.1 Annual average PM 2.5 and impact of policy options ................................................................... 6
2.2 Costs and benefits assessment ................................................................................................. 6
3 Technical Issues with the NESAQ ..................................................................................................... 8
3.1 Emissions from wood burners .................................................................................................... 8
3.2 WHO guidelines ......................................................................................................................... 9
3.3 Worst case meteorology .......................................................................................................... 10
3.4 Cost benefit analysis ................................................................................................................ 10
3.5 Education as a tool .................................................................................................................. 16
3.6 Review – technical advice ........................................................................................................ 16
References .................................................................................................................................................... 171 ASSESSING THE IMPACTS OF THE PROPOSED PM2.5
NESAQ IN BLENHEIM
The NESAQ proposed amendments for particulate matter and mercury were released by the Ministry for the
Environment in February 2020. Environet Limited has been contracted by Marlborough District Council to
prepare a technical evaluation of the impact of the proposed amendments for the Council.
1.1 Method
1.1.1 Daily standards
The effectiveness of management options in achieving the existing NESAQ for PM 10 for Blenheim has been
conducted based on the methodology detailed in Wilton, (2012) for the Blenheim application and as a model
in (Wilton, 1998). The methodology underpinning this has been extensively peer reviewed by academics and
industry experts and has strongly withstood technical scrutiny via air plan hearings. The model can be applied
to daily winter PM 2.5 concentrations with the following adjustments:
• Target concentrations based on the fourth highest daily PM 2.5 because of the proposed allowance of
three exceedences per year.
• Adjustments in source contributions for PM 2.5 rather than PM 10
• Adjustments for natural source contributions (to be based on PM 2.5 rather than PM 10 ).
Determination of the reduction required in concentrations requires identification of concentrations for worst
case years to ensure ongoing compliance with a standard.
1.1.2 Annual standard
To assess the effectiveness of management measures relative to an annual standard the above model was
integrated with an annual model that compared emission sources and concentrations on a monthly basis (to
account for the differing seasonal impact of meteorological conditions and differing source contributions by
season). An application of this methodology to PM 2.5 annual average concentrations for Blenheim based on
initial PM 2.5 information available in 2017 is outlined in Wilton & Zawar-Reza, (2017).
1.2 Reductions required in PM2.5
1.2.1 24-hour average PM2.5 standard of 25 µg/m3
The relevant PM 2.5 concentration from which to assess the reduction required to meet the standard is the
fourth highest in a year indicative of worst-case meteorological conditions. For Blenheim PM 2.5
concentrations of PM 2.5 have been monitored for three years. This would normally not comprise a large
enough dataset for any certainty around what worst case PM 2.5 concentrations could be. The worst year of
these three was 2017 when the fourth highest concentration was measured as 51.5 µg/m3. To check the
likelihood of this year representing worst case PM 2.5 concentrations (for a fourth highest value) the PM 10
dataset was examined for the period 2006 to 2019. This confirmed that 2017 and 2018 were likely worst-case
years in terms of fourth highest PM 2.5 concentrations.The reduction required in daily winter PM 2.5 concentrations to meet the proposed NESAQ of 25 µg/m3 was
therefore based on a value of 51.5 µg/m3 and calculated at 51%. This indicates that daily winter PM 2.5
concentrations would need to halve in order to meet the proposed NESAQ.
1.2.1 Annual average PM2.5 standard of 10 µg/m3
Annual average PM 2.5 concentrations are available for the years 2017 to 2019. The highest annual average
PM 2.5 concentrations was measured during 2017 (14.3 µg/m3). A comparison of annual average PM 10
concentrations from 2006 to 2019 indicates 2017 was likely a worst case year for annual average particulate
concentrations in Blenheim.
The reduction required in annual average PM 2.5 concentrations to meet the proposed annual average PM 2.5
standard of 10 µg/m3 is 30%.
1.3 Comparison to reduction target in MEP based on PM10 (24-hour average).
The Marlborough Environment Plan (MEP) was notified in June 2016 and includes measures to reduce PM 10
emissions from domestic heating and outdoor burning. The plan aimed to reduce 24-hour average PM 10
concentrations in Blenheim by 38% to meet the NES for PM 10 (one allowable exceedance).
The main measures targeting ambient PM 10 concentrations included in the notified Plan for the Blenheim
Airshed were:
• A ban on the use of open fires.
• The requirement that the emission limits specified for wood burners apply to all solid fuel burners.
• The staged phase out of older burners 15 years after installation.
• Outdoor rubbish burning only be a permitted activity in the Blenheim Airshed outside of May to August.
The MEP measures aim to reduce the daily winter PM 10 from domestic heating by around 32%. Wilton (2018)
suggests that in addition to the above measures a behaviour change programme targeting burner fuel and
operation may also be required to achieve the 38% reduction in daily winter PM 10 (and 32% reduction in
domestic heating emissions).
Because the relative contribution of sources to daily winter PM 10 differs to daily winter PM 2.5 and both will
differ to the annual PM 10 source contributions, the percentage reductions in each source required will be
different even if the overall reduction required was the same.
1.4 Annual average PM2.5 standard
An evaluation of the effectiveness of the MEP measures in reducing annual average PM 2.5 suggests that a
target reduction of 30% may be met by measures to reduce daily winter PM 10 by 38% (Figure 1.1). This
assessment depends on the assumption that households do not stockpile outdoor burning material during the
winter months for burning during the spring. If the latter assumption is not valid the annual average NES for
PM 2.5 would likely be met with the additional regulation that the prohibition on outdoor burning (currently May
to August) were extended to the whole year (Figure 1.2).
2Marlborough Environment Plan + behaviour change
programme (alternative disposals of winter prunings)
16 Proposed PM2.5 NES annual average
14
12
PM2.5 µg/m3
10
8
6
4
2
0
2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
Figure 1-1: Projected annual average PM 2.5 concentrations for MEP plus behaviour change
programme.
Marlborough Environment Plan + behaviour change
programme + no outdoor burning year round
16 Proposed PM2.5 NES annual average
14
12
PM2.5 µg/m3
10
8
6
4
2
0
2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
Figure 1-2: Projected annual average PM 2.5 concentrations for MEP, behaviour change programme
and prohibiting outdoor rubbish burning in the Airshed throughout the year.
1.5 Daily PM2.5 standard
Additional measures would be required in Blenheim to reduce daily PM 2.5 concentrations to meet the
proposed daily PM 2.5 standard of 25 µg/m3. Figure 1.3 shows that the requirement that households replacing
older burners replace them with ultra-low emission burners, if introduced in 2022 is unlikely to be sufficient to
result in compliance with the proposed standard by 2030. Ultra-low emission burners (ULEB) are burners that
meet an emission limit of 0.5 g/kg when tested to a method that more closely replicates real life operation of
burners than the NZS 4013 method required by the NESAQ. The method is referred to as the CanterburyMethod and has been integrated into the Air chapter of the Canterbury Natural Resources Regional Plan. As
with the NZS 4013 the emission limit of 0.5 g/kg is not considered to be the emission factor for burners that
meeting the ULEB standard.
It is possible with the measures proposed in Figure 1.3 that the standard could be met by 2032 with this
management measure or if earlier compliance is required additional reductions could be achieved through not
allowing solid fuel burners in new dwellings or existing dwellings that do not currently use solid fuel. The
evaluation in Figure 1.3 is based on the assumption of a 20-year replacement rate for existing wood burners.
Our advice to Councils is to regulate the replacement of burners (i.e., require the phase out of older burners)
to ensure that the reductions do occur. Air Plans for Nelson, Marlborough, Southland and Hawke’s Bay all
include regulations phasing out older wood burners based on our advice as does the Air Plan for Canterbury
based on the advice of Environment Canterbury staff. A key consideration with this requirement is that
regulation of the replacement of burners in households in Blenheim has just been required through the MEP.
MEP plus behaviour change programme (10% effective from 2020)
120%
MEP, BC plus no solid fuel burners in new dwellings or existing dwellings using
other heating methods
100%
MEP, BC plus all burner installs from 2022 are ULEB only
Percent of 2017 PM2.5 emissions
80%
60%
40%
20%
0%
2017
2019
2021
2023
2025
2027
2029
Figure 1-3: Assessment of measures to reduce daily winter PM 2.5 concentrations to meet the
3
proposed PM 2.5 standard of 25 µg/m (24-hour average, 3 allowable exceedences).
Marlborough Environment Plan + behaviour change
programme + new installs are ULEB
16 Proposed PM2.5 NES annual average
14
12
PM2.5 µg/m3
10
8
6
4
2
0
2017 2018 2019 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 2030
Figure 1-4: Impact of measures to reduce daily winter PM 2.5 concentrations to meet the proposed
3
PM 2.5 standard of 25 µg/m on annual average PM 2.5 .
4Figure 1.4 shows the projected impact of the measures targeting daily winter PM 2.5 on annual average concentrations. The 2028 predicted concentration for this scenario is 7.1 µg/m3. The inclusion of a daily PM 2.5 standard of 25 µg/m3 has significant air quality management implications for Blenheim relative to compliance with the annual average PM 2.5 standard of 10 µg/m3. Council would be required to consider addition regulatory options over and above those in the operative air plan. These would likely involve limiting the types of burners that could be installed in the Airshed to ultra-low emission burners. Whilst these burners have reduced in price since their introduction to the market households would not have access to lower cost solid fuel heating options with the introduction of this measure. Some household will be unable to afford the additional capital cost associated with ULEB and will have to opt for non-solid fuel alternatives which would result in higher living costs, for households that self-collect firewood. Around 20% of the wood used in Blenheim is self-collected. Cold homes in Blenheim is a potential outcome if the PM 2.5 standard is adopted.
2 ASSESSMENT OF COSTS AND BENEFITS
There are two significant issues with the Market Economics report with respect to the Blenheim Airshed:
• the estimate of annual average PM 2.5 concentrations, the status quo projections and the
effectiveness of the proposed policy
• the approach to determining costs and benefits associated with the proposed policy
2.1 Annual average PM2.5 and impact of policy options
The Market Economics (ME) report (dated November 2019) uses an annual average PM 2.5 concentration for
Blenheim of around 7.6 µg/m3 and estimates that this will reduce to around 5.5 µg/m3 as a result of the
measures proposed by MfE to reduce domestic heating emissions (Appendix 3 PM 2.5 annual average
concentrations µg/m3 under the proposed policy).
The estimated annual PM 2.5 of 7.6 µg/m3 is quite a lot lower than the value of 14.3 µg/m3 which should
represent PM 2.5 concentrations for Blenheim when considering reductions required for compliance. Because
the 7.6 µg/m3 is lower than the proposed standard in assessing the costs and benefits of the proposed
NESAQ it is unlikely that ME would have considered any costs associated with this standard for Blenheim
other than updating of the MEP as necessary to reflect the NESAQ.
From Figure 2.1 we can see that the predicted impact of the MEP measures achieve a 30% reduction in
annual average PM 2.5 . On top of this ME are predicting a reduction of a further 28% in annual average PM 2.5
concentrations, presumably as a result of the replacement of older burners with 1.0 g/kg burners. This is
unrealistic as a disproportionate number of burners should have been recently replaced through the MEP (at
the end of a 15 year life) and would therefore not be replaced until well after 2028. It is clear that the ME
report does not factor in a baseline scenario that reflects the Blenheim MEP.
We considered the possibility that the reductions illustrated in the ME report (Appendix 3) for 2028 were as a
result of reductions in daily winter PM 2.5 to achieve compliance. This was discounted because reductions
were shown for airsheds where exceedences of 25 µg/m3 were unlikely and because the daily PM 2.5 standard
was not discussed in the text.
The impact of policy options appears to have only been assessed for annual average PM 2.5 . In our view there
will likely be more airsheds in New Zealand like Blenheim that do not comply with the 24-hour average PM 2.5
standard than the proposed annual average standard. For most, the reductions required to meet the 25 µg/m3
standard will be greater than for the annual standard as they are for Blenheim. Thus, the regulatory measures
and consequently the costs will be higher. As demonstrated here for Blenheim there would likely be no
additional regulatory measures required to meet the proposed annual average NESAQ but significant
measures required to meet the daily measure.
2.2 Costs and benefits assessment
The costs associated with the proposed policy have not been assessed. Whilst the cost benefit attempts to
identify airsheds that might be non-compliant with the annual average no evaluation appears to have been
made of the costs associated with meeting the proposed PM 2.5 daily standard. As indicated above for most
areas the costs associated with meeting the policy will lie with the 24-hour average standard. The key costs
are therefore missing from the evaluation.
In Blenheim there are no additional health benefits of the proposed annual average standard. We believe that
the ME report assumes considerable benefit. A reduction in annual average PM 2.5 of around 30% is
estimated to occur as a result of existing measures to reduce daily winter PM 10 . In addition some further
6reduction in annual average PM 2.5 would occur as a result of measures to reduce the daily winter PM 2.5 . This benefit occurs because reducing daily winter concentrations also results in a reduction in annual concentrations. It does not occur as a result of the annual average standard, however. The health benefits will be dominated by the improvements in annual average PM 2.5 . The costs will be dominated by measures associated with meeting the daily winter PM 2.5 standard. The cost and benefits therefore need to be assessed for each standard separately for this evaluation to be adequate. We see no evidence of this in the ME report. If the Ministry wants the health benefits of an annual standard it should do so via targeting the annual standard. This would allow Councils to more effectively manage air quality relative to the exposure periods most relevant for health benefits.
3 TECHNICAL ISSUES WITH THE NESAQ 3.1 Emissions from wood burners The proposed amendments include the recommendation of reducing the wood burner design criteria emission limit from 1.5 g/kg down to 1.0 g/kg. This criterion specifies NZS 4013 as the test method and the analysis appears to have been based on this approach. The assumption that by reducing the emission limit below 1.5 g/kg whilst retaining the 4013-test method will result in material differences in particulate emissions is not supported by scientific studies. This is a complex technical issue that does not appear to have been identified by the Ministries advisors prior to the assessment of impact of policy options (reports dated November 2019) or adequately addressed in the technical documentation. A report prepared by Glenn Seymour (Strategic Energy) in March 2020 attempts to address some of the technical issues relating to wood burner emissions and testing procedures as they relate to the NESAQ proposals but does not adequately identify this issue or evaluate it in a robust manner. Section 3.10 of the report considers the results of testing of ULEB both in the laboratory and in real life and notes that “the development of the new category of ULEB has lead to a significant reduction in emissions from laboratory testing but also, and more importantly, in their emissions from actual usage in homes”. The situation is then summed up as “cleaner in the laboratory, cleaner in the home”. Despite having recognised that it was the development of the ULEB (complete with real life testing approach) that resulted in this outcome the assessment does not appear to recognise that the outcome is specific to the technology of ULEB burners tested. This is one of only two positionings within the report that in some way suggests that reducing the NESAQ criteria to below 1.5 g/kg will have an emissions benefit. The second is the final paragraph of section 3.10 of the report and reads as follows: “looking at the AS/NZS 4013 emissions and CM1 emissions in Table 7 one possible conclusion is that reduced real life emissions could be achieved by adopting lower regulated emissions levels base on AS/NZS 4013 testing without the need to implement a simulated real life testing method”. Table 7 relates only to ULEB testing. It would be an error of logic to draw a conclusion from results of testing of a double chamber ULEB burner and apply it to an NESAQ burner. It is even less appropriate when data for the NESAQ burners exists but does not support the premise, as is the case here. There are no conclusions relating to this issue in the executive summary. The evaluation of improvements in emissions from the proposed change to the design criteria for wood burners (i.e., reducing the emission limit from 1.5 g/kg to 1.0 g/kg) is the most significant technical issue for the proposed NESAQ outside of the setting of the NESAQ concentration limits for PM 2.5 . Not only have the Ministry (and its advisors) failed to recognise and evaluate this issue at an appropriate stage in the process (i.e., prior to evaluating the effectiveness of a policy), the eventual assessment is alarmingly incognisant of the significance or scale of the issue and lacks any appropriate scientific assessment of the issue. To assess the benefits of the policy option, and the resultant improvements in air quality, some assumption must have been made regarding the difference in emissions between the current NESAQ design standard and the proposed standard. A layperson might view the emission limits as representing real life emissions and assume that a 33% reduction in emissions would occur as a result of changing the emission limit from 1.5 g/kg to 1.0 g/kg. It is concerning that no discussion on this assumption was found in the Market Economics report and that the projections aspect of the cost benefit analysis (i.e. the assessment of improvements in air quality associated with policy options) was part of the cost benefit model rather than an assessment by experts in air quality. It is our view that both logic and real-life emission test results do not support the concept of air quality benefits associated with reducing the emission limit to a level below 1.5 g/kg (when tested to NZS 4013). Real life test data shows that the design of standard NESAQ wood burners allows for significant operator impact. This is not just during start up phase but occurs throughout the burn cycle. The Canterbury Method (CM1) was largely about incentivising technology that would minimise the impact of the operator. One concern also 8
shared by others on the CM1 development team was that a “current technology” burner might be approved under the ULEB process. We note that NESAQ technology burners have recently been approved as ULEB. The extent to which these burners will result in improved real-life emissions relative to the existing suite of burners (current real life emissions averaging around 4.5 g/kg) is unclear. Whilst we concur with some of the conclusions of the Strategy Energy Report it is our view that it does not adequately identify or address the key issues and it does not demonstrate an adequate understanding of issues relating to emissions from wood burners, the test methods and their application to air quality management. 3.2 WHO guidelines There is, and has been for some time, compelling evidence in support of an annual average PM 2.5 standard as the key variable for managing the health impacts of particulate pollution. Annual exposure is typically used for assessing the health benefits of improving air quality for the purposes of cost benefit analysis. This is because the majority of the mortality impacts (highest cost variable) occur as a result of longer term exposures (Kuschel et al., 2012) and WHO recommends that annual average take precedence over the 24- hour average since, at low levels, there is less concern about episodic excursions (WHO, 2005). There are acute impacts associated with short term exposure, but the magnitude of impact is lower than for chronic exposures. In 2005 the WHO set the annual average for PM 2.5 at 10 µg/m3. It should be noted that this is a 15 year old standard and has been highlighted for review in light of ongoing health impacts research (WHO, 2013). The PM 2.5 24-hour average WHO (2005) guideline was set based on the rationale that it should be the equivalent level of a PM 10 standard of 50 µg/m3 (WHO, 2005). Consequently, the PM 2.5 24-hour average standard should be no more stringent that the PM 10 standard in terms of the concentration limit. In the rationale for setting the standard, WHO states that “the PM 2.5 is based on the PM 10 standard with an assumed ratio of PM 2.5 to PM 10 of 0.5,” which is noted as being typical of developing country urban areas. WHO (2005) states that “when setting local standards, and assuming the relevant data are available, a different value for this ratio, i.e., one that better reflects local conditions, may be employed”. For Blenheim the ratio of PM 2.5 to PM 10 is well established with over three years of monitoring data available. The monthly average ratio for PM 2.5 to PM 10 for periods when breaches occur (winter months) ranges from 0.7 to 0.9 but is likely higher if just breach days are considered. A PM 2.5 standard based on a PM 10 concentration of 50 µg/m3 (24-hour average) using the rationale in WHO (2005) for Blenheim would likely be around 40 µg/m3 but could be as high as 45 µg/m3. For this concentration, as would be expected under the rationale for the setting of the standard, no additional management measures would be required over and above those proposed to achieve the reductions required in PM 10 . In fact, the guideline if set accordingly would be less stringent as the WHO PM 10 and PM 2.5 24-hour average guidelines are set based on a 99th percentile concentration and therefore allow three exceedences, whereas the NESAQ for PM 10 allows only one. Compliance with a 24-hour average PM 2.5 standard, in itself would result in significantly less health benefit and based on the way this guideline has been developed if set in accordance with the rationale in WHO (2005) it would have no additional benefit in terms of impacts on acute affects than the current NES for PM 10 . WHO (2005) does not provide justification for the management of acute impacts of PM 2.5 over and above what is currently being managed for PM 10 . Consequently, given WHO (2005) is given as the basis for determining the NESAQ for particulate in New Zealand there is no reason to change from the PM 10 standard to a PM 2.5 standard for managing acute impacts. The WHO value of 25 µg/m3 can be adapted in areas where information on the relationship between PM 2.5 and PM 10 is available in line with the rationale for the setting of the standard. Using that rationale, a value of around 40 µg/m3 would likely be the appropriate for urban areas of New Zealand. It is our view that the scientific evidence supports the adoption of an annual average PM 2.5 standard. We do not believe it supports the adoption of the WHO (2005) guidelines. WHO (2005) is based on information that
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