This is the submission that I made on Energy for Industry’s (EFI) recent consent application (CRC121424) to increase their steam production (and subsequent contaminants to air) at their Washdyke facility from 20 MW to 40 MW of steam output:

I chose to oppose the consent application.

Reasons for opposing the consent application:

Energy for Industry's (EFI) resource consent application, like all discharge to air applications, is very technical in nature. Because EFI carried out no public consultation in terms of this (and their prior) application, there has been very little time to study all of the applicable documents and carry out further research. As a result, I have only looked at a few of the numerous issues associated with the application.

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This letter was published in the Timaru Herald:

For Timaru and other highly polluted airsheds, the new target is to have less than three high pollution nights by 2016. Based on measurements since 1999, Timaru is currently trending to reach three high pollution nights by 2055! In comparison Christchurch is still trending to meet the original target by 2013.

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With Local Body elections looming it seems that Environment Minister Nick Smith has decided that the proposed changes to the National Environmental Standards for Air Quality are too hot to handle.

Submissions were due to be published on the Ministry for the Environment's web site by the end of last week. However the Minister has now informed his staff that he wants Cabinet to have a look at the proposal and a decision be made by Government before the submissions and the recommendations are made public. This is scheduled for some time in October, which will more than likely follow the conclusion of the Local Body Elections on October 9.

Environment Canterbury and the Timaru District Council both indicated that they lodged submissions. My submission is available here:

Air Quality Standards Submission

This is the submission that I made on the Ministry for the Environment's proposed changes to the standards for Air Quality:

Submission on the proposed amendments to the National Environmental Standards for Air Quality

Name of Submitter: Andrew McMillan

1.0 Introduction

Firstly, I would like to thank the Ministry for the Environment (MfE) for giving me an opportunity to make a submission on the proposed amendments to the air quality standards. With the deadline for full compliance looming and the report cards showing a very mixed bag of results, a review is indeed timely.

The health risks associated with PM10 exposure are well documented and internationally accepted. I happen to live in Timaru, which is in an airshed that consistently appears amongst the worst offenders in the country for PM10 pollution levels. From my point of view, what I’m looking for in terms of policy direction is to have measures put in place that will ensure the worst offenders can finally start to make some progress towards achieving a safe and healthy quality of air. More...

The latest Environment Canterbury (ECan) air pollution figures paint a dreary picture for both Timaru and South Canterbury. All three of the South Canterbury towns monitored (Timaru, Geraldine and Waimate) have trended up for the last two consecutive years. Kaiapoi is the only town in the remainder of the ECan's region to trend upwards.

Timaru's readings are by far the worst of all measured towns, with it's annual high pollution nights of 38 just below it's 10 year average of 42. Christchurch in contrast has only recorded 13 high pollution nights, which is under half it's 10 year average of 29.

Data sourced from www.ecan.govt.nz