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Suggestions for comments on Pittwater's Proposed Wood Smoke Reduction Policy http://www.pittwater.nsw.gov.au/council/documents_on_ex/document_pages/woodsmoke
Email comments by 5 pm, 27 Feb 2015 to pittwater_council@pittwater.nsw.gov.au  

SUMMARY
   Council's decisions should be based on the recommendation on health experts.  The NSW Chief Medical Officer, the Australian Lung Foundation, the NSW Asthma Foundation and the UN Environment Program/World Meteorological Association all recommend not allowing new wood heaters to be installed.

   A consultancy report commissioned by the NSW Government noted that wood smoke is an $8 billion health problem in NSW but that a 75% reduction could be achieved by:
1) not allowing new heaters to be installed; 2) requiring existing heaters to be removed when houses are sold and 3) annual licencing fees for wood heaters, which could also provide funds for education and assistance to residents whose health or lifestyle is adversely affected by other people's wood smoke. 

   The AS/NZS 4013 test does not reflect real-life emissions.  It was set by a Committee with no formal representation by health experts, under threat that the wood heating industry could veto any changes that might adversely affect their profits.  Most people would consider any benefits of wood heaters to be far less than the estimated health costs of a new heater installed in Sydney $4,897 per year (until August 2015 ), $4,091 per year (from August 2015-2019) and $3,357 (from August 2019). 
 
   Many people might have supported cthe ontinued use of asbestos-containing fibro cement, if they had no idea about the health problems it causes.  The same applies to wood heater smoke, which, along with other PM2.5 has been described as the "new asbestos".  Until a new wood heater standard has been developed by independent health experts, Pittwater Council should follow the recommendation of health experts, and the example of Waverley and Holroyd councils and the Oran Park and Turner Rd growth precincts, and not allow new wood heaters to be installed.  Council should also consider the two other highly cost-effective policies that, according to the NSW Government report, along with not new heaters to be installed could reduce the $8 billion health costs of wood heaters in NSW by 75%.

NSW Chief Medical Officer recommended banning new wood heaters and phasing out older ones
Last year, the NSW Chief Medical Officer Kerry Chant says wood heaters are so detrimental to health she supported banning and phasing them out in built-up urban areas as an option to control wood smoke.  This recommendation applies to all wood heaters, not just older models.  http://www.smh.com.au/nsw/states-top-doctor-says-we-should-consider-banning-wood-fire-heaters-20140705-zsx92.html
The reason for this is discussed in the attached peer-reviewed paper.  With average firewood consumption of about 2 tonnes/year, the average brand new wood-heater emits about 20 kg PM2.5 and has estimated health costs (using the NEPC economic analysis estimate of $280/kg for PM2.5 emissions in Sydney, or the estimate of $263/kg from the Federal Government's wood heater consultation RIS - see below) of more than $5,000 per year.

Current AS/NZS 4013-2014 set by the wood heating industry not independent health experts
The attached peer-reviewed paper explains that development of a new emissions test to better reflect real-life emissions was abandoned in 2007 after the wood heating industry vetoed recommendations by the majority of the Standards Australia Committee CS-062 to halve the emissions limit as an interim measure while a new test was being developed, and also to seek advice from health authorities about a suitable health warning to remind operators that woodsmoke is harmful and the importance of operating heaters correctly (Australian Senate 2013). When reconvened in 2013 with fewer community representatives and no health experts, CS-062 approved a revision based on the existing test, with limits of 2.5 g/kg from August 2015 and 1.5 g/kg in 2019.  Given the threat of no progress at all if the wood heating industry were again to veto changes, these limits bear no relation to an adequate or acceptable health-based standard for new wood heaters.

Real-life emissions from new heaters installed in a new housing estate in Armidale, NSW are shown in Figure 5 of the attached peer-reviewed paper.  All except the top left smoke plume are from heaters installed in new houses after Council required them to have emissions ratings of 2.5 g/kg or less - i.e. meet the standard that will be required under Pittwater's proposed policy. The level of emissions shown was evident for nearly 1 hour (middle photo) and about 10 hours for the heater installed in August 2014, after an application to Council and provision of all appropriate education material (bottom photo).

Estimated health costs of Pittwater's new wood heaters - more than $4,000 per heater per year until 2019.
Table A3.2 (above, click to enlarge) from The Federal Government's Consultation Regulation Impact Statement (CRIS) reported that the estimated health costs amounts to $263 for every kg of PM2.5 emitted in a major capital city such as Sydney.  The NSW Government's Economic Appraisal of Wood Smoke Control Measures indicates that and Australian wood heater rated < 2.5 g/kg has real-life emissions of 8.2 g/kg, one rated < 1.5 g/kg has real-life emissions of 6.7 g/kg and one rated < 4 g/kg (the current standard until August 2015) has real-life emissions of 9.8 g/kg. 
Based on average firewood consumption in Sydney of 1.9 tonnes per year, the estimated health costs of a new wood heater installed in Pittwater satisfying AS/NZS 4013-2014 will be:
$4,897 per year (until August 2015 )
$4,091 per year (from August 2015 when the emissions limit reduces from 4 g/kg to 2.5 g/kg)
$3,357 per year (from August 2019 when the emissions limit reduces to 1.5 g/kg
).

NSW Asthma Foundation recommends not allowing new heaters to be installed, removing existing ones when houses are sold and licencing fees to cover the cost of wood smoke reduction programs
The NSW Asthma Foundation made three key recommendations that together would reduce wood smoke health costs by 75 per cent. 
1) Removal of existing heaters that do not meet a health-based standard when houses are offered for sale. (Health Benefit $4,016m, Cost $36m, Net Benefit $3,978m)
2) Not allowing the installation of new heaters that do not meet a health-based standard. 
3) Licensing fees to cover the cost of wood smoke-reduction programs with assistance for people whose health or lifestyle has been affected by wood smoke.(Health Benefit $1,267m, Cost +$11m, Net Benefit $1,278m)
“These are not outlandish ideas, but measures supported the Government’s own costings. Together these measures could significantly reduce air pollution and improve public health for a very modest cost,” Ms Goldman said.
 “These new standards still fall short and will have little effect on the massive air pollution and health problems it causes.”
http://www.asthmaaustralia.org.au/MR/NSW/New-Australian-Wood-Heater-Standard-Decade-Behind.aspx
Note that the revised AS/NZS 4013-2014 is not a health-based standard - there were no health experts on the Committee all too aware of the potential threat of a veto by the wood heating industry if the proposals were likely to affect their profitability. 

Three simple measures could reduce $8 billion health costs of wood smoke in NSW by 75%

 

 

 

Health Benefit
$million

Cost $million

Net Benefit $million

4) Phase out at sale of house

$4,015

-$36

$3,978

2) Ban on heater sales

$2,206

-$134

$2,071

7) Licensing fees

 

$1,267

$11

$1,278

6) Sales tax on new wood heaters

$1,049

-$1

$1,048

9) Cash incentive phase out

$879

-$12

$867

8) Levying an excise/tax on biomass fuels

$419

$36

$455

5) Fuel moisture content regulations

$399

-$33

$366

3) Emission standards (3g/kg, 60% efficiency)

$301

-$3

$298

Source:  Tables 26 and 28, AECOM Office of Environment& Heritage: EconomicAppraisal of Wood Smoke Control Measures  An estimated 40,000 tonnes of PM2.5 are emitted from Australia's wood heaters (Federal Government CRIS), including 11,530 in NSW (OEH report, Table 17, p31), with the health costs of woodsmoke in NSW estimated at $8.072 billion over 20 years if no remedial action is taken (Table 26, p46).

Several Sydney Councils do not permit new wood heaters to be installed
Waverley and Holroyd do not permit new wood heaters to be installed, with others requiring non-polluting heating in new developments, e.g. Manooka Valley, Oran Park and Turner Road Growth Precincts. In Canbera, woodheaters are not permitted in the new residential suburbs of the Molonglo Valley because of air quality

The Australian Lung Foundation (ALF) recommends:use alternative methods (instead of wood heaters) for climate control, including insulating and improving the energy efficiency of homes, flued gas and electric heaters and energy efficient house design” http://lungfoundation.com.au/wp-content/uploads/2012/06/Woodsmoke-The-Burning-Issue.pdf

Proposed policy lacks details about the resolve complaints when residents' health or lifestyle are affected by a neighbour's wood smoke emissions
Although the policy says it "aims to provide a consistent and effective framework to assist in the assessment and determination of installations and complaints regarding domestic solid fuel burning appliances"  it is not clear how this is to be achieved.  How does Council plan to manage the situation where the health of an asthmatic child or elderly resident is damaged when a neighbour installs a new heater?  What is being done to resolve existing complaints where residents' health or lifestyle are being affected by a neighbour's wood smoke emissions?
  The draft policy does not even say whether neighbours will be consulted before the installation of new wood heaters is approved.  The smell of smoke from a new heater rated < 2.5 g/kg is often noted more than 500 metres downwind of the chimney, so the best practice would require consultation of all occupants of houses within 200 to 500 metres of the new chimney.

Pittwater's consultation inadequate because of the inadequacy of the background information
The background information to this policy is inadequate.  Most people have no idea that, although emissions standards for motor vehicles are set by the Australian Government, those for wood heaters were set under threat of a veto by the wood heating industry. Consequently, emissions of the average wood stove in Sydney (about 20 kg per year) are as bad as 1,000 passenger cars (about 20 grams per year, http://woodsmoke.3sc.net/cleancarbenefits )   How many people know that NSW Chief Medical Officer Kerry Chant said wood heaters are so detrimental to health she supported banning and phasing them out in built-up urban areas?  How many people know that the UN Environment Program and the World Meteorological Organization (UNEP/WMO) recommended phasing out log-burning heaters in developed countries to reduce global warming as well as improve health - http://woodsmoke.3sc.net/ghg  How many people know that the health cost of new wood heater installed under Council's proposed policy is estimated to lie between $5,000 and $3,300 per year?
If people know and understood these facts, would their responses be different?    Here are some examples of effective health messages used elsewhere

What would be the choice of responsible people who know all the facts?
Council should base their decisions on the recommendation on health experts such as the NSW Chief Medical Officer, the Australian Lung Foundation, the NSW Asthma Foundation and the UN Environment Program/World Meteorological Association.  It is really unfortunate too few people know and understand the health effects of woodsmoke or how wood heater pollution compares with other sources of PM2.5 emissions. Some information about policies and public information campaigns is available at: http://woodsmoke.3sc.net/policies-elsewhere
In the absence of appropriate information about asbestos-containing fibro cement, most people would probably have said that its use should continue.  However, it would have been an expensive mistake not to take steps to protect public health.  The same applies to wood heater smoke, which has been described as the "new asbestos"  because air pollution from wood fire heaters now poses a bigger immediate health danger to Sydneysiders than cars or cigarettes - http://www.smh.com.au/nsw/wood-fire-heaters-the-hidden-killer-20140628-zsop8.html

Utah Physicians for a Healthy Environment give 17 reasons to ban wood burning:
1. All pollution is not created equal. Wood smoke is the most toxic type of pollution in most cities, more dangerous than auto pollution and most industrial pollution. Lighting a wood fire in your house is like starting up your own toxic incinerator.
2. Lifetime cancer risk is 12 times greater for wood smoke compared to an equal volume of second hand cigarette smoke.
3. Burning 10 lbs. of wood for one hour, releases as much PAHs (polycyclic aromatic hydrocarbons) as 6,000 packs of cigarettes.
4. Toxic free-radical chemicals in wood smoke are biologically active 40 times longer than the free radicals in cigarette smoke.
5. Wood smoke is the third largest source of dioxins, one of the most intensely toxic compounds known to science.
6. The very small size of wood particles make them seven times more likely to be inhaled than other particulate pollution.
7. Wood smoke easily penetrates homes of neighbors creating concentrations up to 88% as high as outdoor air.
8. If you smell wood smoke, you know you are being harmed. The sweet smell comes from deadly compounds like benzene.
9. The most dangerous components of air pollution are much higher inside homes that burn wood compared to those that don’t, as much as 500% higher.
10. Considering the most dangerous part of particulate pollution, wood burning produces as much overall as all our cars during the winter.
11. The inhalable particulate pollution from one woodstove is equivalent to the amount emitted from 3,000 gas furnaces producing the same amount of heat.
12. Emissions from modern combustion appliances for wood logs may increase ten-fold if they are not operated appropriately, and most of them are not.
13. Wood smoke is the only pollution emitted right where people spend most of their time. It disperses poorly, is not evenly distributed and stays in the air longer because of its small size. Concentrations can be 100 times higher for neighbors of wood burners than what is captured at the nearest monitoring station. Real local “pollution victims” are created even when overall community levels are low.
14. If your neighbor is a regular wood burner, and follows all the rules, i.e. doesn’t burn during yellow or red alert days, but does during all “green” days, you can go an entire winter without having one single day of clean air. This is a civil rights issue.
15. According to California’s Bay Area Air Quality Management District, burning wood costs the rest of the community, primarily your next door neighbors, at least $2 in extra medical expenses for every lb of wood that you burn. An average fire then costs your neighbors about $40.
16. Long ago most communities passed ordinances protecting people from second hand cigarette smoke. Ironically those laws protect people at places they don’t necessarily have to be (restaurants, stores, buildings, etc). But in the one place they have to be, their own home, they have no protection from something even worse-wood smoke. People should have just as much protection from wood smoke as from cigarette smoke and for all the same reasons. We don’t allow people to blow cigarette smoke in your face, why should we allow people to blow wood smoke into your home?
17. Wood burning is not even close to carbon neutral over the short term, the next few decades, and it is that time frame that will make or break the climate crisis. Burning wood is extremely in inefficient. Per unit of heat created wood produces even more CO2 than the fossil fuels do. Furthermore, the black carbon particulate matter released enhances the absorption of radiant heat in the atmosphere, making global warming worse, and prematurely melts already imperiled mountain snow pack. 

What would be the choice of responsible people who know all the facts?

The role of the Department of Environmental Quality is to protect public health and the environment.  There appear to have been many submissions from people who have no idea that the average EPA-certified wood stove emits an estimated 97 lbs (44 kg) of PM2.5 per year, making it 2,200 times more polluting than the average gasoline-fuelled passenger car (which emits about 20 grams PM2.5 per year).

It seems that many people think that the average wood stove is no more polluting than the average car.  It is quite likely that these people would change their minds if they knew it was 2,200 times worse.

People who do not know about the toxic chemicals in wood smoke would quite likely change their minds if they knew that the lifetime cancer risk is 12 times greater for wood smoke compared to an equal volume of second hand cigarette smoke, or that airborne PAH (polycyclic aromatic hydrocarbons) have been linked to genetic damage in babies, reduced IQ and behavioral problems including anxiety and attention deficit when children start school and that burning 10 lbs. of wood for one hour, releases as much PAHs (polycyclic aromatic hydrocarbons) as 6,000 packs of cigarettes.  For a list of 17 important facts about wood burning and wood smoke see  http://www.monroecourier.com/21903/physicians-organization-gives-17-reasons-to-ban-wood-burning/

A policy to help inform the public and stop the problem from getting worse
When Montreal faced a similar problem, the first step was to stop the problem from getting worse by not allowing new wood stoves to be installed.  This does not affect current wood stove users, so they have no reason to object to it.  It is also remarkably effective way to help people understand that wood stove contribute disproportionately to air pollution.  Although such policies can be implemented with minimal cost or disruption, it appears to be working.  The number of smoggy days in winter (where PM2.5 concentrations exceed 35 μg/m3 for more than 3 hours over 75% of Montréal) fell from 29 in 2009 to 10 in 2013

To achieve similar benefits in Utah, the policy of not allowing the installation of new wood stoves would need to be added to existing policies of not allowing burning (except households that have no other forms of heating) on red and orange days.

Allowing people to think that it's OK to use EPA-certified stoves - that emit 2,200 times more PM2.5 than the average passenger car - on orange days would almost certainly create additional health problems.  When Libby, Montana, spent over $2.5 million replacing every single old, uncertified stove with a brand new EPA-certified one, the town had many days of extremely unhealthy PM2.5 pollution, most of which almost certainly came from wood stoves - see Fig 6 of the attached peer-reviewed paper discussing similar regulatory problems and disproportionate amounts of PM2.5 pollution emitted by wood stoves in Australia

Conclusions
Governments have a duty to protect public health. This must include tackling disproportionate sources of pollution such as wood stoves, including EPA-certified stoves which on average emit more PM2.5 pollution per year than 2,000 passenger cars.  Public education programs are needed to explain the health effects of wood smoke and the disproportionate amount of pollution from even EPA-certified stoves and that, for this reason, the installation of new stoves is no longer permitted. For this reason, wood burning is not allowed on red days and all forms of wood burning are also strongly discouraged on orange days.  Once the public understand and supports this health message, Montreal adopted a policy of phasing out most existing wood stoves by 2020. 
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