Official Information Act request: Defence estate environmental hazard governance and records
SPENCER JONES made this Official Information request to Ministry of Defence
The request was partially successful.
From: SPENCER JONES
Kia ora,
I am making this request under the Official Information Act 1982.
Scope and purpose
This request seeks information relating to policy-level governance, oversight, and record-keeping for environmental and airborne hazards associated with Defence estate facilities.
It does not seek personal information and does not assert individual causation or liability.
Timeframe
1 January 2000 to 31 December 2025.
Information requested
Please provide copies of any records held by the Ministry of Defence that fall within the following classes:
Policies, directives, or guidance documents relating to the management of environmental or airborne hazards on Defence estates (including biological, particulate, or chemical hazards).
Documents relating to record-keeping and retention requirements for hazard management records, including any disposal authorities relied upon.
Correspondence between the Ministry of Defence and NZDF, contractors, or other agencies relating to:
environmental hazard management;
monitoring or testing regimes;
incidents or exceedances;
record retention or destruction.
Any reviews, audits, or assurance activities concerning environmental or airborne hazard management or record-keeping.
Records not held
If any information within scope is stated to be “not held”, please advise:
whether the information was ever created;
if created, the retention policy or disposal authority relied upon;
the date and scope of any destruction or transfer;
whether another agency or contractor may hold the information.
Electronic copies are preferred.
If refinement would assist, please identify which parts of this request present difficulty.
Kind regards,
Spencer Jones
From: Information
Ministry of Defence
Kia ora,
Thank you for your request for official information. This will be managed
in accordance with the provisions of the Official Information Act 1982,
which may include transfer to a more relevant agency or Minister.
The Ministry may publish the content of our response to your request on
the Ministry of Defence website ([1]www.defence.govt.nz). Your personal
information will not be published. More information on making an official
information request with the Ministry of Defence is available here:
[2]https://www.defence.govt.nz/contact-us/o....
Ngā mihi,
Ministry of Defence
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||Ministerial|
||and Public |
||Services |
||Branch |
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||Manatū |
||Kaupapa |
||Waonga - |
||New Zealand|
||Ministry of|
||Defence |
|| |
|| |
|| |
|| |
|| |
||Defence |
||House, 34 |
||Bowen |
||Street, PO |
||Box 12703, |
||Wellington |
||6144, New |
||Zealand |
+------------+
-----Original Message-----
From: SPENCER JONES
[mailto:[FOI #33540 email]]
Sent: Sunday, 18 January 2026 2:55 p.m.
To: Information <[email address]>
Subject: Official Information request - Official Information Act request:
Defence estate environmental hazard governance and records
------------------------------------------------------------------------------
CAUTION: This email originated from outside of the organization.
Do not follow guidance, click links, or open attachments unless you
recognize the sender and know the content is safe. If in any doubt, please
forward the email to [3][email address] and then delete the email from
your Inbox. Thank you
Kia ora,
I am making this request under the Official Information Act 1982.
Scope and purpose
This request seeks information relating to policy-level governance,
oversight, and record-keeping for environmental and airborne hazards
associated with Defence estate facilities.
It does not seek personal information and does not assert individual
causation or liability.
Timeframe
1 January 2000 to 31 December 2025.
Information requested
Please provide copies of any records held by the Ministry of Defence that
fall within the following classes:
Policies, directives, or guidance documents relating to the management of
environmental or airborne hazards on Defence estates (including
biological, particulate, or chemical hazards).
Documents relating to record-keeping and retention requirements for hazard
management records, including any disposal authorities relied upon.
Correspondence between the Ministry of Defence and NZDF, contractors, or
other agencies relating to:
environmental hazard management;
monitoring or testing regimes;
incidents or exceedances;
record retention or destruction.
Any reviews, audits, or assurance activities concerning environmental or
airborne hazard management or record-keeping.
Records not held
If any information within scope is stated to be “not held”, please advise:
whether the information was ever created;
if created, the retention policy or disposal authority relied upon;
the date and scope of any destruction or transfer;
whether another agency or contractor may hold the information.
Electronic copies are preferred.
If refinement would assist, please identify which parts of this request
present difficulty.
Kind regards,
Spencer Jones
-------------------------------------------------------------------
This is an Official Information request made via the FYI website.
Please use this email address for all replies to this request:
[4][FOI #33540 email]
Is [5][Ministry of Defence request email] the wrong address for Official Information
requests to Ministry of Defence? If so, please contact us using this form:
[6]https://fyi.org.nz/change_request/new?bo...
Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
[7]https://fyi.org.nz/help/officers
If you find this service useful as an Official Information officer, please
ask your web manager to link to us from your organisation's OIA or LGOIMA
page.
-------------------------------------------------------------------
Note:
The information contained in this email message is intended only for the
addressee and is not necessarily the official view or communication of the
Ministry. If you are not the intended recipient you must not use,
disclose, copy or distribute this message or the information in it. If you
have received this message in error, please email or telephone the sender
immediately. Thank you"
References
Visible links
1. http://www.defence.govt.nz/
2. https://www.defence.govt.nz/contact-us/o...
3. mailto:[email address]
4. mailto:[FOI #33540 email]
5. mailto:[Ministry of Defence request email]
6. https://fyi.org.nz/change_request/new?bo...
7. https://fyi.org.nz/help/officers
hide quoted sections
From: Information
Ministry of Defence
Kia ora,
Please find attached our response to your Official Information Act
request.
Kind regards,
Ministry of Defence
+------------+
||Ministerial|
||and Public |
||Services |
||Branch |
|| |
||Manatū |
||Kaupapa |
||Waonga - |
||New Zealand|
||Ministry of|
||Defence |
|| |
|| |
|| |
|| |
|| |
||Defence |
||House, 34 |
||Bowen |
||Street, PO |
||Box 12703, |
||Wellington |
||6144, New |
||Zealand |
+------------+
-----Original Message-----
From: SPENCER JONES
[mailto:[FOI #33540 email]]
Sent: Sunday, 18 January 2026 2:55 p.m.
To: Information <[email address]>
Subject: Official Information request - Official Information Act request:
Defence estate environmental hazard governance and records
------------------------------------------------------------------------------
CAUTION: This email originated from outside of the organization.
Do not follow guidance, click links, or open attachments unless you
recognize the sender and know the content is safe. If in any doubt, please
forward the email to [1][email address] and then delete the email from
your Inbox. Thank you
Kia ora,
I am making this request under the Official Information Act 1982.
Scope and purpose
This request seeks information relating to policy-level governance,
oversight, and record-keeping for environmental and airborne hazards
associated with Defence estate facilities.
It does not seek personal information and does not assert individual
causation or liability.
Timeframe
1 January 2000 to 31 December 2025.
Information requested
Please provide copies of any records held by the Ministry of Defence that
fall within the following classes:
Policies, directives, or guidance documents relating to the management of
environmental or airborne hazards on Defence estates (including
biological, particulate, or chemical hazards).
Documents relating to record-keeping and retention requirements for hazard
management records, including any disposal authorities relied upon.
Correspondence between the Ministry of Defence and NZDF, contractors, or
other agencies relating to:
environmental hazard management;
monitoring or testing regimes;
incidents or exceedances;
record retention or destruction.
Any reviews, audits, or assurance activities concerning environmental or
airborne hazard management or record-keeping.
Records not held
If any information within scope is stated to be “not held”, please advise:
whether the information was ever created;
if created, the retention policy or disposal authority relied upon;
the date and scope of any destruction or transfer;
whether another agency or contractor may hold the information.
Electronic copies are preferred.
If refinement would assist, please identify which parts of this request
present difficulty.
Kind regards,
Spencer Jones
-------------------------------------------------------------------
This is an Official Information request made via the FYI website.
Please use this email address for all replies to this request:
[2][FOI #33540 email]
Is [3][Ministry of Defence request email] the wrong address for Official Information
requests to Ministry of Defence? If so, please contact us using this form:
[4]https://fyi.org.nz/change_request/new?bo...
Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
[5]https://fyi.org.nz/help/officers
If you find this service useful as an Official Information officer, please
ask your web manager to link to us from your organisation's OIA or LGOIMA
page.
-------------------------------------------------------------------
Note:
The information contained in this email message is intended only for the
addressee and is not necessarily the official view or communication of the
Ministry. If you are not the intended recipient you must not use,
disclose, copy or distribute this message or the information in it. If you
have received this message in error, please email or telephone the sender
immediately. Thank you"
References
Visible links
1. mailto:[email address]
2. mailto:[FOI #33540 email]
3. mailto:[Ministry of Defence request email]
4. https://fyi.org.nz/change_request/new?bo...
5. https://fyi.org.nz/help/officers
hide quoted sections
SPENCER JONES left an annotation ()
Public Annotation – Structural Split in Defence Estate Hazard Governance (OIA #33540)
This OIA confirms a clear structural split in how environmental and hazardous substance risks are governed across the Defence estate.
The Ministry of Defence (MoD) has formally confirmed that it does not manage environmental or airborne hazards operationally. Those responsibilities sit with the New Zealand Defence Force (NZDF).
MoD’s role is limited to conducting periodic audits under the Hazardous Substances and New Organisms Act (HSNO). It holds audit reports, but not the underlying estate-level hazard records or correspondence.
The response further confirms:
• Operational hazard management → NZDF
• Hazard record retention → NZDF
• Hazardous substances audit (HSNO) → MoD
• Ministerial reporting → MoD
• 25 years of correspondence → not centrally collated
• 2019 audit → commenced but not completed; material withheld under s9
This architecture creates a layered model:
Operator (NZDF) holds site-level data.
Auditor (MoD) holds periodic summaries.
Neither holds a unified, longitudinal environmental governance record.
The OIA does not establish wrongdoing.
It establishes fragmentation.
For researchers examining environmental exposure, asbestos management, airborne hazards, or record retention integrity across Defence estates, this structural split is the key governance finding.
Things to do with this request
- Add an annotation (to help the requester or others)
- Download a zip file of all correspondence (note: this contains the same information already available above).
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SPENCER JONES left an annotation ()
Public Annotation – Defence Estate Hazard Governance Architecture (What This OIA Reveals)
This OIA has now received a formal decision. While partially answered, it reveals an important governance architecture finding regarding environmental and airborne hazard management across the Defence estate.
The Ministry of Defence (MoD) confirms that it does not manage estate-level environmental hazards operationally. Those responsibilities sit with the New Zealand Defence Force (NZDF). MoD’s role is limited to audit and assurance under the HSNO Act framework, specifically hazardous substances controls.
Key structural findings from the response:
• Operational hazard management → NZDF
• Hazardous substances audit (HSNO) → MoD
• Record retention for estate hazards → NZDF
• Audit reporting to Ministers → MoD
The OIA confirms that:
• MoD does not hold operational hazard management policies (s18(g)).
• 25 years of correspondence was refused under s18(f) (substantial collation).
• A 2019 hazardous substances audit was commenced but not completed.
• 2019 audit materials were withheld under s9(2)(g)(i) and s9(2)(f)(iv).
• No confirmation was provided that airborne particulate, asbestos, mould, or legacy contamination risks fall within the HSNO audit scope.
The structural issue emerging is not whether audits occur — it is whether there is a single, coherent, accountable governance layer for environmental and airborne hazards across Defence estates.
This OIA demonstrates a classic policy/operator separation:
• MoD audits.
• NZDF operates.
• Records are fragmented.
• Historic correspondence is not centrally collated.
For researchers and journalists examining estate governance, environmental exposure, or record destruction concerns, this architecture split is central.
The request is technically completed but substantively partial.
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