Open letter to Coal Action Network Aotearoa on air quality in Southland
To whom it may concern:
I am writing to CANA because of your stated interest in our views on Environment Southland’s Proposed Regional Air Plan - “Based on [Straterra’s] past behaviour, we expect they will be trying to defeat, delay or otherwise get around any proposals that increase the environmental standards coal companies are required to meet.”
If CANA had wanted to know what Straterra’s position is, you could have asked us.
For the record, Straterra upholds the right of any council to manage the air quality in their region. We also say that Policies and Rules in RMA Plans should be based on facts and evidence. Both considerations are requirements of the RMA.
CANA states that “the coal mining lobby has … a different agenda”. Yes, we do - our agenda is that a rigorous approach to planning is needed, to uphold the rule of law, for New Zealand to present low sovereign risk to businesses/investment.
Turning to the problem definition, as CANA puts it: “Environment Southland’s research has found that home fires/burners account for over 90% of the PM10 [fine particulate or sooty] emissions in both Invercargill and Gore.” That is a fair summation of the council’s position.
So, “home fires/burners” are the problem. What are the causes?
The science says that PM10 emissions from home heating have multiple causes: old, inefficient burners, including open fires; the type of fuel used, in particular, wet wood; variability of fuel; and the way burners are installed and operated.
The council drew attention to all of these issues in the Proposed Regional Air Plan, and in so doing, has illustrated the complexity of the problem.
In other parts of New Zealand, the approach to solving this complex problem has been to require more efficient burners in homes. Southland could consider adopting that approach, with suitable transition provisions. That would be supported by Straterra.
But CANA’s proposal does not go to the burner problem. It simply expresses opposition to coal: “Every lump of coal burned is another attack on our climate.” That accusation is relevant to all fossil fuels, but not to reducing PM10 emissions in parts of Southland.
CANA states “air quality is a problem in many parts of Southland”. Is it? The council’s concern is Gore and Invercargill, not Fiordland National Park or Rakiura/Stewart Island or anywhere else in Southland.
As to the suggestion that “the coal companies want to maximise their profits” – well, that’s a good definition of private enterprise, including the banks that manage CANA members’ personal savings and loans. Any company that did not want to maximise profits would face questions from shareholders who expect a return on their investments – and it is the taxes on those profits that pay for schools, hospitals, roads . . .
Of course, the company profit motive is always subject to complying with the laws of the land. As an industry, we seek laws and regulation that enable responsible economic development. Perhaps, Straterra and CANA can agree on this objective as rational and desirable.