Environment Ministers Meeting, 15 Dec 2015

Sign the petition: Save 700 lives a year by cleaning up air and woodsmoke pollutionAlso send a personal email to the Environment minsters with only a few clicks - see below.  If woodsmoke affects your health, please also consider a personal phone call to discuss air pollution with their advisers - contact details below.

Use this web page to email all environment ministers - an easy way (only a few clicks) to make your opinions really count!  Envirojustice's draft text does not mention woodsmoke, so change as desired & ask all minister to decide on 15 Dec 2015 to implement effective measures to clean up woodsmoke.  Just copy and paste a subject line of your choice and the draft text below into this form. Edit or reorder paragraphs as desired, click the box to tell Envirojustice what updates you want, then click 'send my email'!

Chose a subject line & paste into the subject-line box - write your own for greater impact 
Please reject the flawed woodheater "standard" and consult health experts on air pollution on 15 Dec
Clean up air pollution in mining towns by asking woodheater users to switch to non-polluting heating
 "Working" with the woodheating industry won't clean up woodsmoke pollution!
The  NSW Chief Medical Officer's advice is more important than wood-heating industry profits
Clean up air and woodsmoke pollution on 15 Dec to save lives
Save 700 lives a year by cleaning up air and woodsmoke pollution
Save $20 billion in health costs by heeding the NSW Chief Medical Officer's advice on 15 Dec 15
Please heed the NSW Chief Medical Officer's advice, not the profit-driven wood-heating industry

Draft to paste into the 'Dear Ministers' box - edit or reorder paragraphs for greater impact.  
Dear Ministers
,

Adopting stricter particle standards at your meeting on 15 Dec 2015 would save billions in health costs. A 6 ug/m3 PM2.5 standard could avoid over 700 premature deaths every year and was supported by more than 94% of the 500 public submissions on air pollution.

The NEPC economic analysis identified $3.6 billion in savings from adopting US standards for non-road diesels, international best practice for controlling PM emissions from mines, US2010 emissions standards for outboards and watercraft, and US phase 2 gardening emissions standards.

Even greater savings of $20 billion could be achieved by effective measures to tackle wood-heater pollution.  Without woodsmoke, average PM2.5 exposure in Newcastle-Sydney-Wollongong would fall from 6.9 to 5.5 ug/m3, and from 6.2 to 5.2 ug/m3 in Melbourne, allowing the 6 ug/m3 standard to be achieved.

NSW Chief Medical Officer Kerry Chant said wood heaters are so detrimental to health she supports banning and phasing them out in built-up urban areas. There are major flaws in the current standard-setting process because changes cannot be made without the approval of the wood heating industry. This process is so bad that one of only two independent representatives on the committee recommended that action to ban domestic solid fuel heating should be seriously considered.   

We don't ask the tobacco industry to approve changes to cigarette legislation, so it is astonishing that changes to wood heater pollution standards must be approved by the wood heating industry, but not health experts.

Modern wood heaters are so polluting that, in the mining town of Muswellbrook, near to open-cut mines and power stations generating enough electricity for 3.25 million homes, chemical fingerprinting showed that a few hundred wood heaters are the major source of PM2.5 pollution (62% in winter, 30% year round).  Woodsmoke pollution was also been identified as a major source of wintertime pollution in Liverpool, Sydney.  An evening's wood heating emits as many toxic chemicals as in the smoke from a quarter of a million cigarettes.

We therefore urge all ministers to 
1) reject the current flawed "standards" set by the wood heating industry
2) set up a committee of health and epidemiological experts to find the best possible solution to the current $20 billion health costs of wood heater pollution.  
3) endorse a National Clean Air Agreement, with appropriate support and leadership, to implement the $3.6 billion savings from the other measures listed above and the 6 ug/m3 PM2.5 standard that would avoid 700 premature deaths per year
4) investigate other cost-effective ways to reduce pollution and health costs, many of which will also reduce global warming from lower methane and black carbon emissions.  

Your support for 1-4 above It would be an excellent way to save nearly $25 billion in health costs, avoid 700 premature deaths every year, and achieve the health-based air pollution standards supported by the overwhelming majority of the community.  

We are counting on you,


Treehugger.com: Air pollution makes your brain age faster, destroying white matter like a neurotoxin It's already quite clear that air pollution is very bad for us: It's bad for our hearts, for our lungs, it causes cancer, triggers asthma, etc. It's estimated to cause about 7 million deaths per year, more than malaria and AIDS combined. In fact, it's so bad that the World Health Organization now puts air pollution in the same category as tobacco smoke, UV radiation and plutonium!
But if all that wasn't enough to convince us all to take this problem seriously, a new study published in the Annals of Neurology provides evidence that air pollution can cause damage to the brain directly (not just indirectly, through inflammation of the vascular system)."

The July 2015 Environment Ministers meeting stated: “Ministers agreed in-principle to reduce air pollution from wood heaters by working with business to ensure compliance with tougher new Australian Standards for new wood heaters and adopting effective measures to reduce emissions from existing wood heaters.”

1. Major Problem: the “tougher new Australian Standards” are meaningless & totally inadequate, because they were set by a Committee whose protocols do not allow changes to be made without the agreement of the wood heating industry. 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.

Current wood heater models are so polluting that, even in Muswellbrook, (population 11,791) surrounded by open cut mines and two power stations that generate enough electricity for 3.25 million homes, chemical fingerprinting of the PM2.5 pollution collected in the town showed that the small proportion of homes that use wood heaters are the largest single source of PM2.5 pollution - 62% in winter, 30% over the entire year.

Current wood heaters are also so polluting that, because of wood heater pollution in Western Sydney, the NSW EPA were unsure whether they could meet anytightening of the PM2.5 standard into the future.”  6 ug/m3 PM2.5 standard could prevent the premature deaths of about 700 Australians every year.  It would be a real tragedy if a small proportion of households (only 4.3% of households use wood as the main form of heating in Sydney) are allowed to cause a major pollution problem that prevents tighter PM2.5 standards that would avoid 700 premature deaths every year. 
   
2. Recommendation. At their meeting on 15 December 2015, the Environment Ministers should therefore implement the recommendations of the NSW Chief Medical Officer and NSW Asthma Foundation for a moratorium on the installation of new heaters until a new health-based standard has been developed, phasing out existing heaters when houses are offered for sale and an annual levy on use of current heater models to fund education programs and replacement of wood heaters with non-polluting heating (see 8, below right).

Additional Information

3. The “tougher new Australian Standards” are totally inadequate because they were set by a Committee whose protocols do not allow changes to be made without the agreement of the wood heating industry.  The Senate Inquiry “Impacts on health of air quality in Australia” confirmed (para 6.35, p 63) that the failure (to agree to an interim limit of 2/kg while a new emissions test was being developed) "was the result of a failure of the technical committee to reach consensus within the meaning of Standards Australia's rules, which according to the minutes supplied to the committee was a result of opposition from industry representatives."  The industry representative, Demi Brown, was found to have misrepresented the truth to the Senate Inquiry.

A new committee (without a single health or epidemiological expert) was convened in late 2013.  Committee mem­bers would have understood that there was no chance of making any changes not supported by the wood heating industry, and therefore there was no alternative except to go along with the wood heating industry’s proposals. 

Many submissions on the wood heating industry’s proposals pointed out that the current emissions test bears little relationship to the real-life emissions of a new heater.  The the proposed changes would therefore make little or no difference to the health costs of domestic wood heating, estimated at $20-24 billion.  Sadly, there was no transparency about the decision making process.  None of the submissions, nor the Committee’s response them, were made public.

One of the few independent members of the Committee, The Clean Air Society of Australia and New Zealand (CASANZ) clearly considers the new “standard” totally inadequate because, in a subsequent submission to the NSW Government, it stated that: "action to ban domestic solid fuel burning for domestic heating should be seriously considered”.

4. The “tougher new Australian Standards” (set by the wood heating industry) are meaningless – they are based on a test that does not represent real-life emissions.  The "standard" that will apply in Australia from August 2019 was required in all urban areas of NZ in 2005.  Yet after 10 years, and removal of all non-compliant heaters, NZ still has totally unacceptable pollution, e.g. 48 days over 50 ug/m3, in a small town where woodsmoke is the only pollutant.  Many small towns (e.g. Arrowtown, pop 2445) required all heaters with emissions rating greater than 1.5 g/kg to be removed by 1 Jan 2012.  All new heaters must have emissions ratings < 0.7 g/kg.  A small town of 2445 people is likely to have only a few hundred wood heaters.  Nonetheless a few hundred wood heaters rated < 1.5 can create horrendous pollution.  In 2014, Arrowtown (pop 2445) had 48 days exceeding 50 ug/m3 PM10, with a maximum daily average of 148 ug/m3.

Arrowtown, NZ – pop 2445.

Arrowtown, NZ - pop 2445

 


5. Current “Australian standard” much worse than in NZ.  Because of opposition from the wood heating industry, the “standard” required in all urban areas of NZ in 2005 will not apply to Australia until 2019.  The current “standard” in Australia is 2.5 g/kg.  The photos (left) show emissions of new heaters rated < 2.5 g/kg installed in Armidale after Council passed a requirement that all new heaters installed in new houses must be rated < 2.5 g/kg.

These photos, together with measured pollution in NZ towns where all wood heaters must have emissions ratings < 1.5 g/kg (below left), show that there is no hope that the “tougher new Australian standards” will make much difference to the amount of health-hazardous PM2.5 pollution in Australia.

6. Failure to set a health-based standard for wood heaters is preventing the introduction of stricter PM2.5 standards that could save 700 lives per year.  A book review published in 2015 in “Air Quality and Climate Change” points out that: “the NSW EPA in their annual report to NEPC noted that much of the PM2.5 pollution they measured at came from wood burning in the Richmond and Liverpool Street Sites (Sydney) and they were unsure whether they could meet any tightening of the PM2.5 standard into the future.”  Elsewhere, it has been calculated that a 6 ug/m3 PM2.5 standard could prevent the premature deaths of about 700 Australians every year.  It would be a real tragedy if allowing a small proportion of households (only 4.3% of households use wood as the main form of heating in Sydney) are allowed to cause a major pollution problem that prevents tighter PM2.5 standards that could prevent many premature deaths every year. 

7. Health savings: $18 billion by not allowing new wood heaters and phasing out existing ones. The estimates in Appendix 1 show that the health benefits of phasing out existing heaters when houses are sold ($12 billion) and not allowing new wood heaters to be installed ($6 billion) are much greater than any other single measure to reduce PM2.5 pollution.  If a new test is developed to measure real-life emissions, it will be possible to set a limit based on the health costs and the benefits of using wood heaters.  Once new models have been developed that satisfy the health-based standard, it will be possible to install new wood heaters without significant damage to public health.

8. Asthma Foundation Recommendations to save the $18 billion health costs:
1. Removal of existing heaters that do not meet a health-based standard when houses are offered for sale.
2. Not allowing the installation of new heaters that do not meet the health-based standard .
3. Licencing fees to cover the cost of wood smoke-reduction programs, informing people about the health effects of woodsmoke and assisting people whose health or lifestyle has been affected by wood smoke.
Short TV ads encouraged residents of Launceston to switch to non-polluting heating.
Deaths in winter from respiratory disease fell by 28% and cardiovascular disease by 20%.  Year round, for men, the reductions were 23% (respiratory), 18% (cardiovascular) and 11.4% (all deaths).   

Fig 49 of the Upper Hunter Fine Particle Characterisation Study final report shows the sources of PM2.5 pollution in Muswellbrook.  Smoke from domestic wood-heaters is in yellow, smoke from wildfires and forestry burn-offs is shown in green.  Current wood heater models are so polluting that, even in Muswellbrook, (population 11,791) surrounded by open cut mines and two power stations that generate enough electricity for 3.25 million homes (more than the number of homes in NSW) the small proportion of homes that use wood heaters are the largest single source of PM2.5 pollution - 62% in winter, 30% over the entire year.

Appendix 1. Costs and benefits of different measures to reduce PM2.5 pollution

 

Health Benefit $million, NSW

Cost NSW $million

Net Health Benefit, $million

NSW

Australiaa

NSW woodsmoke-control measures5

W4) Phase out at sale of house

$4,015

-$36

$3,978

$12,419

W2) Ban on heater sales

$2,206

-$134

$2,071

$6,466

W7) Licensing fees

$1,267

$11

$1,278

$3,990

W6) Sales tax on new wood heaters

$1,049

-$1

$1,048

$3,272

W9) Cash incentive phase out

$879

-$12

$867

$2,707

W8) Levying an excise/tax on biomass fuels

$419

$36

$455

$1,421

W5) Fuel moisture content (20%) regulations

$399

-$33

$366

$1,018

W3) Efficiency standards (60%,3g/kg)

$301

-$3

$298

$930

Measures investigated by the NEPC6

 

Regulation: firewood moisture < 20% (already required in WA)

$1,034

Wood-heaters: 60% efficiency, 1.5 g/kg, in-service measures

$4,178

MOU to reduce shipping vessel speed for ocean transits

$352

US2010 outboard & watercraft standards, US phase 2 gardening emission standards

$616

Diesel trains driver assistance software for line haul locomotives

$80

Retrofitting high-polluting (urban) non-road diesel equipment with DPFs

$6

International best practice PM control measures at coal mines

$643

US non-road diesel standards (excluding < 19kW)

$1,922

Requiring new locomotives to meet US Tier 4 standards

$1

Sum of all NEPC non-wood-heater measures

$3,620

NSW measures were scaled up by pro-rating for population, i.e. dividing by the proportion of the Australian population living in NSW (32.0% in 2013).  For measure W5, the proportion of the population excluding WA was used because WA already has a 20% moisture limit for firewood. Benefits of the NSW measures are Net Present Values (NPV) to 2030.  The Net Benefits of the NEPC measures (Table ES7 of the NEPC Economic Analysis) are NPV in 2011 dollars and cover the 20-year period from 2017 to 2036.

Appendix 2.  The NSW Air Emissions Community Web tool (image, left) shows that residential wood heating is responsible for more PM2.5 emissions in Sydney that all other sources combined

The NSW Air Emissions Community Web tool (image, below) shows that residential wood heating is responsible for more PM2.5 emissions in Sydney that all other sources combined


 This is despite being used as the main form of heating by only 4.3% of households,
ABS data showing the main for of energy used for space heating for 2008, the year the most recent Emissions Inventory was compiled. 

Since then, the situation has become even worse!
Section 3.1, p7 of the cost benefit analysis reports that estimated wood heater sales could have been as high as 11,500 wood heaters in 2014.


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