Nick Smith’s announced that some highly-polluting airsheds will be allowed until 2020 to meet air quality standards, costing something in the region of several hundred lives, but saving jobs — and why I think this is okay

About as many deaths as lung cancer. Four times the road toll.

Half New Zealand’s population lives in polluted airsheds, where invisible particulate matter — PM10 — exceeds acceptable standards. That’s how many people die prematurely from the pollution: 1,640 per year.

It’s not so much the smoggy factory, or the dirty diesel (though both contribute, especially in Auckland). Counter-intuitively, “by far the main source of PM10 emissions in New Zealand is solid-fuel burning by households”. Open fires, old non-compliant wood burners, wet wood are the worst causes in the worst areas.

Timaru averages 39 exceedances, Christchurch 21. In 2008, Otago saw 91, in the Alexandra-Arrowtown-Clyde-Cromwell area. The World Health Organisation (WHO) says three are acceptable. Auckland, with all its gridlocked vehicles, has just five — however, Smith compares that with Sydney and Brisbane's two and three, and says it is not good enough.

In 2004, the Clark government made regulations, requiring all regional councils by 2013 to have no more than one exceedance per year of the WHO standard. Otherwise, if the over-pollution persisted, no new or existing air discharge consents could be granted or renewed.

Instead, Smith has a new more relaxed, split target: “We are going to give moderately polluted areas, like Auckland and Napier … with under ten exceedances a year, until 2016 to reach this standard. For those higher polluted areas like Christchurch, Timaru … with over ten exceedances a year, the new standard will require they get under three by 2016 and be fully compliant by 2020.” He is also excluding from the standard exceedances caused by acts of God — volcanic eruptions, Australian bush fires, dust storms.

It’s a straight trade-off. “This policy has been strongly influenced by cost-benefit analysis.” He says the consequences of the status quo would have been extreme and poorly directed, because home fires, not industry, are the primary source, and there would have been a massive downside in terms of jobs.

“It is true that there is some loss of health benefits by giving more time to reach the standard — a drop from $1,911 million to $1,746 million. The real shift is that the costs are reduced from $867 million to $196 million … the benefit to cost ratios [improve] from 2.2 to 8.9.”

A drop in "health benefits" from $1,911 million to $1,746 million. Let’s have that again, in terms of lives? In October 2009, the NZIER advised Smith’s Ministry an estimated 635 deaths would be avoided by meeting the standards in 2013; meeting them from 2020 would avoid 153, a difference of 482 deaths (Table 8, p 45).

Smith’s proposal is a little different: compliance from the least-worst polluting airsheds from 2016, and also from 2016, a dramatic cut in the allowed exceedances, for the worst of those who aren’t compliant.

Let’s say, then, that the number is less than half that large. Significant, nonetheless, and set off against it is the fact that the NZIER workings were based on a pollution-related premature death statistic of around 700 per annum — itself less than half Smith’s 1,640 “best estimate”.

Smith’s policy is still aspirational. It also could have been worse.

The WHO guideline allows three exceedences of the standard per year. The aspiration, when we finally get there, will still be more stringent than WHO’s, though pushed out to 2020. Other countries provide for the exclusion of ‘exceptional events’ from the count of exceedences, as Smith is proposing. Smith’s Technical Advisory Group (TAG) recommended that, in addition to the two steps taken, the number of exceedances permitted should be increased from one to three days per year.

I know, I know: it wouldn’t be a true blue TAG, if it didn’t leave its Minister room to look moderate.

I think that this is a sadder policy, but a smarter one too. [Ed: but see further below, about whether it was the smartest.] For example:

  • Mandatory offsetting from 1 September 2012 for any new significant industrial consents in polluted airsheds: instead of being banned, they must offset any increase by funding an equivalent number of households to change domestic heating.
  • In Christchurch, the EQC is working in partnership with the Energy Efficiency and Conservation Authority to replace as many of the 30,000 damaged chimneys as possible with clean heating. “It is the silver lining to Christchurch’s tragic earthquake.”

Better than Must Do Something ... let’s Ban It.

In the end, I guess I’m relaxed. Among the highest priorities, this’ll stay on the radar, and be fixed. Sigh. It always helps so much with environmental impetus, when it's all about us. Let me rephrase that: it helps when we can prove the direct cause and effect.

Comments (11)

by Mr Magoo on February 01, 2011
Mr Magoo

Come on now. Get with the program Claire.

If at first you don't succeed, redefine success!

I mean it is a lot easier than showing leadership and competence running the country. That is just too hard and when you are a bunch of rich men without any ideas beyond increasing the wealth of the wealthy while retaining power.

And besides it is invisible. That means no photo ops. No video. I mean what kind of relaxed and optimitic press conference can we stage over this? We removed the invisible things from the air and you wont notice?

Like I said...get with the program.

by Claire Browning on February 01, 2011
Claire Browning

Mm. Fair point. What I really should have said, though, is "... and why I (and the Labour party) think this is okay". There is an odd sort of silence coming from the red corner. It makes me think that they've gotten with the program, too.

By the way, here is the Cabinet paper, and here is the Regulatory Impact Statement (RIS). I went looking for the RIS, wondering (on reflection) if I might want to change my answer, on the basis that a smartER policy is not necessarily the smartEST. That's the document that sets out all the costs and benefits of all of the options. And sure enough:

The options are set out from p 12 of the RIS. They include the preferred option (option 1: split targets), and another option 4 called 'strict compliance'. That is that all airsheds would be permitted only one exceedance by the end of 2016. On p 15, a table shows the benefit : costs ratio. The strict compliance option would have had the best ratio, at 9.3. Smith and Cabinet have preferred the second-best. That might have been because of advice that it was "not as certain as other options", because of "challenging implementation issues" and doubts about whether that target compliance date was "credible". I think that means they decided it was just a bit too hard.

The RIS also has more about the cost of life. I hoped it would analyse each option in those terms, but am not wholly surprised (or surprised at all) to see it doesn't do this.

What it does say is that the status quo -- the 2013 requirement, which in reality is not going to be met, but would be met by 2016 -- would avoid "around 990 premature deaths" in the 2008-2020 period (pp 9-10). That figure is the revised equivalent to the NZIER's 635, that I quoted.

by Save Happy Valley on February 02, 2011
Save Happy Valley

Perhaps Gerry Brownlee and Energy Minister Don Elder had a word to Nick re air standards:

From Solid Energy statement:

Solid Energy had previously advised it would withdraw from supplying coal to the household market by the beginning of 2013, in line with the National Environmental Standards for air quality, which recognise that burning solid fuel in open fires and older domestic burners causes significant air quality and health issues in many of our towns and cities.  The Government has recently announced that it will review the timing for the implementation of the standards. As a result, Solid Energy may alter its deadline for completing its withdrawal from the household market to be consistent with the outcome of that review and to continue our support for local communities who have limited other options for secure affordable home heating.

Household coal: Solid Energy’s decision on whether to proceed with the briquetting plant will be based on demand from industrial and commercial customers.  The lignite briquettes could also be used for home heating.  As part of the studies Solid Energy will investigate the feasibility of bagging briquettes for the household market at the now-closed Ohai Mine bagging plant until such time as the National Environmental Standards for air quality are implemented.


by Claire Browning on February 02, 2011
Claire Browning

Ah. Here is the link to that statement, dated September 11, 2009. 

by Save Happy Valley on February 02, 2011
Save Happy Valley

and suprise suprise who is happy:


Straterra welcomes pragmatism on air-quality standards

The Government’s relaxing of unrealistic deadlines for entry into force of air-quality standards injects a welcome dose of sanity into this debate, Straterra CEO Chris Baker says.

“Environment Minister Nick Smith has announced a practical and achievable plan for improving air quality in New Zealand and he deserves to be congratulated for that, not censured,” Mr Baker said today.

Hon Dr Nick Smith responded today on Morning Report, Radio NZ, to criticisms by environmental groups of the delay from 2013 to 2020 of entry into force of air quality standards for 15 air sheds. He said industries are a minor contributor to air pollution, compared to home heating and vehicles, but sticking to the 2013 deadline would punish industries most, while not achieving any meaningful gains for air quality.

Mr Baker said Minister Smith’s plan to continue converting homes to cleaner forms of heating and new emissions standards for vehicles is the “realistic plan”, to quote the Minister, to “support economic growth and look after the clean, green image”.

“This is a case of making policy decisions based on facts, which is of course the responsible, 21st Century approach to governing this country,” Mr Baker said.


A responsible 21st century based on burning 19th century fuel...


Worth noting:

Straterra Board Members:

Don Elder - Solid Energy CEO Brent Francis - Coal Association of NZ Chris Baker - CEO of Straterra and Executive Chairman of the Coal Association of New Zealand
by Save Happy Valley on February 02, 2011
Save Happy Valley

Burn that coal, who cares about air quality!



In order to receive resource consents for the project, Solid Energy had to prove it would comply with conditions covering air emissions, noise and water discharge

The proposed plant - capable of producing about 90,000 tonnes of briquettes a year from 150,000 tonnes of Southland lignite - would supply the New Zealand industrial market with briquettes, and trial their value for export.


by Simon on February 03, 2011

"In order to receive resource consents for the project, Solid Energy had to prove it would comply with conditions covering air emissions, noise and water discharge"

Hmff! In my experience, Solid Energy's consultants will not 'prove' anything, they will just make lost of not-very-well supported assertions that they will comply with conditions and that 'effects will be minor'.

Also galling, is that for the air discharge permits, there will be NO consideration of the adverse effects of greenhouse gases. From 2004, greenhouse gas emissions became, as a matter of law, largely irrelevant in deciding resource consents.

See Section 104E of the Resource Management Act.

"When considering an application for a discharge permit or coastal permit to do something that would otherwise contravene  section 15 or section 15B relating to the discharge into air of greenhouse gases, a consent authority must not have regard to the effects of such a discharge on climate change, except to the extent that the use and development of renewable energy enables a reduction in the discharge into air of greenhouse gases, either—(a) in absolute terms; or (b) relative to the use and development of non-renewable energy."

by Save Happy Valley on February 03, 2011
Save Happy Valley

I think the challenge of Labour if it want to be taken seriously on climate change is to create a policy that has binding domesitc emissions reductions - meaning taking on Solid Energy and ensuring NZ shifts to a low carbon economy.


The RMA doesn't deal with climate change - and the ETS is useless - so there is a lack of decent climate policy in New Zealand.

by Claire Browning on February 03, 2011
Claire Browning

Here is Labour's statement, issued yesterday.

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