Submissions - Armidale's Draft Air Quality Policy

 Survey form responses
A survey form asked about people's understanding of the health effects of woodsmoke and possible policy options.  The forms were available in public places (library, pubs, credit union, council offices) with nearby collection boxes for the completed forms, and handed out at the industry forum and the public meeting.

A total of 84 completed forms were collected, though the similar handwriting (ticking the same boxes indicating that woodsmoke isn't harmful) suggested that the same person might have completed more than one form.

Only 34% thought woodsmoke a serious health problem
Previous surveys have shown that the majority of woodheater owners do not understand the health effects of woodsmoke, and this was also apparent in the responses to questions asked by Council.  Only 34% of respondents disagreed with the statement that woodsmoke does not pose a serious health threat to Armidale residents.  This is despite the UNE study showing that woodsmoke is associated with about 750 additional visits to Armidale GPs for respiratory complaints, and the thousands of studies showing that PM2.5 pollution (including woodsmoke) is linked with premature mortality as well as heart and lung diseases.

23% of respondents said it affected their health
In this survey, nearly a quarter of respondents agreed that woodsmoke was having a negative effect on their health, again suggesting that (despite the beliefs of woodheater users) this is a serious problem.  Sadly, is seems that unless people, especially woodheater owners, have personal experience of health problems, they would prefer not to believe the scientific evidence.

Opponents generated groundless fears
There have been no major changes in the enforcement aspect of the policy.  It has always been possible to find woodheater users who create excessive smoke.  In 2001, the Northern Daily Leader reported that "TOUGH fines will be imposed on Armidale’s air polluters next month in an effort to reduce dangerous smoke emissions that are putting the health of city residents at risk."   Because of the substantial health damage, penalties are necessary to guard against blatant disregard of other people's health.
Council officers are trained to help, and do their utmost to explain how to use woodheaters correctly.  So far, no one has been fined, and no one who genuinely tries to do the right thing is likely to be fined.
The advice of health authorities is clear - not to use woodheating when non-polluting alternatives are available.  However, people without alternatives should keep warm by using their woodheaters as carefully as possible. 

Australian standard-setting process failed
There is no safe level of PM2.5 pollution (or indeed PAH).  NZ calculated the health costs of PM2.5 pollution and imposed much stricter standards, notably a limit of 1.5 g/kg on all woodheaters installed on blocks less than 2 ha.  Areas where woodsmoke builds up have even stricter regulations.  In Otago, heaters emitting 0.7 g/kg or less are allowed as replacements for more polluting heaters, but new houses and houses currently without woodheaters are not allowed to install them.  Moreover, heaters with emissions ratings greater than 1.5 g/kg must be removed by 1 Jan 2012.

Attempts by the joint Australian/New Zealand Standards Committee to set similar limits fell foul of the principle that all sectors have to agree before a standard can be changed.  In early 2007, the Standards Australia Committee Meeting minutes state: "The committee agreed to a reduction to 3.0 g/kg with the majority further in agreement that 2.0 g/kg was more appropriate."
They voted 15:4 to halve the emissions limit to 2 g/kg, but since 2 of the 4 votes against the change represented 50% of formal wood heating industry votes, the changes could not be adopted.

NZ concluded that this process was inadequate some years earlier.  Instead of being dictated to by industry, NZ chose to protect the health of its people by regulation.  Christchurch imposed an emissions limit of 1.5 g/kg in January 2000, with proposals to adopt 1.5 g/kg for all woodheaters installed in urban area in October 2003These proposals became law in September 2005.

In a series of papers in Clean Air and Environmental Quality, Prof John Todd discusses why the current system of self regulation in Australia fails to protect our health. 
1)  When audited, emissions of many popular models bore no relation to lab-test emissions in the audit.  Prof Todd's research program in 2005 required purchase of four woodheaters. Laboratory tests showed that three of the four did not meet the emission standard, demonstrating significant non-compliance two years after the National Audit.
2) real-life emissions are much higher than the lab test results - on low-burn particle emissions can be 7 to 8 times higher than the AS4013 rating
3) The industry body owns the test lab, participates in the auditing process and was allowed to veto changes to the Australian Standard despite a 15:4 vote that the emissions limit should be halved
4) The next generation of woodheaters must be 1 g/kg or less to achieve acceptable air quality in areas with a high proportion of woodheaters and ideally we should aim for a further order of magnitude to 0.1 g/kg.

The NSW Action for Air (2009 update, page 53) also comments on failures to comply.
In 2007 the NSW Department of Environment and Climate Change inspected 18 retail outlets, all of which had at least one woodheater that did not comply with NSW regulations

Most heaters currently installed in Australia are so polluting that, in areas of NZ where woodsmoke builds up, they would have to be removed within a few years, e.g. by 1 Jan 2012 in Otago.  Rather than continue to allow such sub-standard models to be installed, in many cases with health costs of several thousand dollars per heater per year, there should be a moratorium on the installation of new woodheaters in Australia until an appropriate health-based standard has been developed.

Similar problems from self-regulation affect other industries, e.g. unflued gas heaters also cause health problems, but they still continue to be installed in people's homes and even schools.  If these problems were better understood, it seems likely that most people would choose to pay the additional cost of a flue.

The cost of non-polluting heating will vary and the best option is to improve energy efficiency, e.g. using the Federal Government's free energy audits, to minimize the cost of heating.  For reverse cycle airconditioners, look at the "all options" label to determine its heating efficiency at 2C, which is perhaps more important that the standard test efficiency measurement at 7C, or consult Choice Magazine in your local library, or local specialists Armidale Sheet Metal & Airconditioning, who install insulation, and should be able to advise on the best options for cold climates.  Although individual models vary, some manufacturers (e.g. Daikin, Mitsubishi, and some LG models) appear to have higher than average heating efficiency.

Formal submissions on Council's draft policy
A total of 32 formal submissions were received, 11 from stakeholder groups and 21 from individuals.  More than half the formal written submissions (excluding those from woodheating industry) were in favour following the advice of health experts and not allowing woodheaters in new houses.  New houses have to be fully insulated and can be designed on passive solar principles so have affordable non-polluting alternatives. 

Stakeholder/Group submissions
Dr James Markos, respiratory physician & president of the Tasmanian Branch of the Australian Lung Foundation
Video submission from Darryl Johnson, President Tuggeranong Community Council, Canberra

Submissions from individuals -  please don't allow woodheaters in new houses.  Some submissions also suggest phasing out or reducing the number of existing woodheaters
1) Resident of Brown Street; 2) Resident of Newton Street; 3) Another resident of Newton St who believes his son's bronchiolitis was caused by woodsmoke; 4) resident of Speare Avenue; 5) UNE Professor; 6)Resident of Markham St; 7) Resident of Ash Tree Drive; 8) South Hill Resident; 9) Councillor; 10) former resident of Donelly St; 11) former resident of Barney St;  12) Wagga Wagga resident (Wagga also has high air pollution measurements).

Submissions from people whose health improved after moving out of the central (worst polluted) area
10) former resident of Donelly St; 11) former resident of Barney St; 13) former resident of Allingham St.

Submission - need compassion, working together, and different standards for old and new houses 14) Councillor

Other testimonies about health problems from Armidale's woodsmoke

Submission in 2006 from a family that left Armidale because of woodsmoke
Recommendation by retired local doctor that people affected by respiratory problems should move out of town

 Forced to move out of Armidale every winter because of horrific smoke (ABC Radio listener feedback, 11 November 2005. 1 min 25 secs, click green play button to hear).
(ABC Radio listener feedback, 11 November 2005) Non-polluting alternatives actually cheaper than wood!

Responses to Council's Questions
SD=strongly disagree, D=disagree, N=neutral, A=Agree, SA=Strongly Agree
The tables show percentages (of the 84 survey responses) in each category

I believe that woodsmoke is having a negative effect on my health
 SD  50
 D   20.2  N    7.1  A  11.9  SA 10.7

Wood smoke does not pose a serious health threat to Armidale residents
 SD 14.5
 D   19.3  N  10.8  A   24.1  SA 31.3

The benefits of wood heating outweigh any potential health costs associated with wood smoke pollution
 SD  10.7  D  17.9  N   11.9  A   20.2 SA  36.9

I've never thought about the health risks associated with wood smoke pollution
 SD  40.4  D  34.5  N   11.9  A    8.3   SA  4.8

Misleading comments - industry reps try to divert attention away from the real problem
Evidence shows that that woodsmoke is associated with increased risk of bronchiolitis, middle ear infections, heart disease (in an area where the main source of winter particulate pollution is woodsmoke) and respiratory diseases, that PAH are associated with reduced IQ of children, and that PM2.5 exposure increases the risk of cot deaths.

Comments by industry at the Public Formum argued that there was no evidence that woodsmoke was causing elevated particulate levels, or indeed that it was harmful.  This is despite the evidence that elevated monthly average pollution occurs only in the wood heating season.  Indeed, only 3.9% of ACT households burn wood as the main form of space heating (ABS estimate for 2008), yet the National Pollutant Inventory shows that wood heating is responsible for two thirds of particulate emissions.

The untruthfulness of industry's claims about the lack of evidence that woodsmoke is harmful is demonstrated by the peer-reviewed scientific papers published by Air Quality Group members, e.g. spatial variability, PM2.5 pollution and estimated health costs of woodsmoke pollution in Armidale  published in the prestigious journal Atmospheric Environment.

A peer-reviewed paper on health costs of PM2.5 pollution including woodsmoke was published in the Health Promotion Journal of Australia.  A third peer-reviewed paper summarising the health effects of woodsmoke pollution, was published in 'Clean Air', the journal of the Australian and New Zealand Clean Air Society.  The air quality group's PM2.5 measurements, combined with council's measurements, were used in a peer-reviewed paper demonstrating  8.8 additional visits to Armidale GPs per day (about 750 visits per year) because of woodsmoke.

Christchurch, NZ, has much stricter emissions limits than Armidale, and much more traffic, but 76% of air pollution is from woodsmoke

If Armidale's pollution were due to traffic, the highest measurements would be in the CBD during peak hours, not in residential areas late in the evenings when the only source of pollution is from woodheaters.

Spinning incorrect and misleading information in the hope of increasing profits is a shameful way of doing business - if the same applies to supplying goods and services - buyers beware!

AS for the AHHA, Demi Brown claimed in a press release that the number of woodsmoke complaints in Armidale fell from 34 in 2003/4 to 2 in 2004/5.  Records provided to the Domestic Energy Committee show that Council received 69 complaints in 2007, 17 in 2008 and 13 in 2009.  The fact that these are much higher than 2004/5 suggests that the number of complaints may depend more on Council's attitude and concerns about dobbing in neighbours than the amount of smoke.  Usually people have to be desperate to complain, and even when they do a submission in 2006, from a family that left Armidale because of woodsmoke explained that one reason for leaving was "the failure of Council despite 3 years of appeal to prevent the ongoing pollution of the urban air quality in our neighbourhood."  
Given that there is no safe level of PM2.5 pollution, surely meeting the National Air Quality Standards (set as a compromise between the health costs and the costs of avoiding pollution in metropolitan areas) would be a much better way to determine the extent of the problem?  Surely also, these measurements should not be taken in the less-polluted CBD environment, but in residential areas where woodsmoke builds up?  
Dr Dorothy L Robinson,
May 9, 2010, 4:58 AM
Dr Dorothy L Robinson,
May 8, 2010, 8:44 PM
Dr Dorothy L Robinson,
May 9, 2010, 5:19 AM
Dr Dorothy L Robinson,
May 8, 2010, 9:30 PM
Dr Dorothy L Robinson,
May 8, 2010, 9:19 PM
Dr Dorothy L Robinson,
May 8, 2010, 11:55 PM
Dr Dorothy L Robinson,
May 9, 2010, 5:30 AM
Dr Dorothy L Robinson,
May 8, 2010, 9:16 PM
Dr Dorothy L Robinson,
May 9, 2010, 5:11 AM
Dr Dorothy L Robinson,
May 9, 2010, 12:50 AM
Dr Dorothy L Robinson,
May 9, 2010, 5:10 AM
Dr Dorothy L Robinson,
May 8, 2010, 9:17 PM
Dr Dorothy L Robinson,
May 9, 2010, 1:27 AM