NCAA - Consultation on a National Clean Air Agreement

National Clean Air Agreement - Federal Government Consultation
Submissions must be accompanied by a Submission Cover Sheet

Download either 
A) Blank form: 
Submission cover sheet (DOCX - 104.73 KB) | (PDF - 502.51 KB)
B) Blank cover sheet plus suggested comments - as outlined below - that can be edited according to your wishes and desires (lazy option!).

Email the completed form to to by April 17, 2015.
For detailed information, see the Consultation document "Working towards a National Clean Air Agreement"
NB: The NCC and Envirojustice spoke to the Federal Department running the process - they stressed the importance of having lots of community submissions.

Suggested Responses to Questions.  

1. Do you agree with the proposed goal, purpose, principles and scope as a basis for the National Clean Air Agreement? If not, please explain and provide alternatives if appropriate.

No.  The aim is too vague.  It should be to implement all cost-effective measures to achieve an optimal sustained reduction in air pollution and exposure for all Australians, with associated health, environmental and economic benefits.

If asbestos had not yet been banned,  would it be acceptable just to reduce its use, rather than eliminate this serious health hazard?  The proposed goal is unacceptable because it fails to distinguish between what is best for the community as a whole (including economic impacts) and smaller reductions in pollution that might be favoured by profit-driven industries.

The principles should focus on the task – to generate overall community benefits – instead of the procedures.  Costly disruptions from policy changes are undesirable, but so are the health costs of air pollution.  If asbestos were still permitted, what would be an appropriate lead in time for phasing it out?  Regulations and requirements should aim to strike a balance between the cost of action and the cost of delays.  Suggested changed (including reordering) are shown below.

1. The Agreement facilitates action to address current and emerging air quality issues.

2. The Agreement aims to maximize overall community benefits, including net economic benefits, taking account of social and environmental outcomes of measures, whether regulatory or non-regulatory.

3. Responses to air quality issues under the Agreement maintain best practice approaches, consider the latest evidence available and identify the most appropriate level of government to take the lead.

4. Policy decisions under the Agreement are relevant, timely, consider available resources, allow for effective consultation and appropriate lead-in times that minimise the health costs of unnecessary delays as well as any costly disruptions that may result from policy changes.

5. Air quality management measures delivered are efficient and effective, and avoid creating cumulative or overlapping regulatory burdens that have significant cost implications.

6. Activities under the Agreement are consistent with Australia’s international obligations.

7. The Agreement and endorsed work programme is periodically reviewed to maintain a focus on achievement of desired outcomes and to ensure its continuing relevance.

2. What, in your view, do you consider as a high priority air quality issue(s) that could be considered under the National Clean Air Agreement? Please provide evidence.

The highest priorities should be the issues that provide the largest net benefits.  These include $20-24 billion of savings from cleaning up pollution from domestic wood heaters, $1.9 billion from adopting US standards for non-road diesels, $0.6 billion from adopting new standards for boat engines and lawnmowers, $0.6 billion from adopting international best practice particulate control at coal mines, $0.35 billion from a MOU to reduce shipping vessel speeds for ocean transits, $0.1 billion for diesel trains driver assistance software as well as other measures that generate significant net health and environmental benefits.

As other issues are identified by benefit-cost analyses, they should also be prioritized according to their net benefits.  Net benefits should include the health benefits of reduced emissions as well as the benefits of reduced greenhouse gas and PM2.5 emissions from burning coal compared to the replacement with alternatives such as wind and solar power.

The resources allocated to all identified issues should be in proportion to estimated net benefits, in accordance with principle 2 above.  It would be helpful to produce an updated version of Table 1 in the discussion document, including estimates of health costs such as the $20-24 billion health costs of domestic wood smoke.

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  This shows that a comprehensive woodsmoke policy should be top priority.  A National Clean Air Agreement should aim to achieve the greatest health and economic benefits.  The current "standard" for wood heaters was set by a committee without a single health expert - we don't know if the estimated $20 to $24 billion health cost of wood heater emissions was even discussed.  Even worse, the wood heating industry was able to veto any changes to that standard that it did not like.  A new heater satisfying this so-called "standard" will emit more PM2.5 per year than 1,000 passenger cars.  New heaters that satisfy all proposed standards until 2019 have been observed emitting pollution at the levels shown (right) for many hours.  

Given the $20 to $24 billion health cost of woodsmoke, finding a solution to this major problem should be top priority, until all current wood heaters have been removed and a new health-based standard has been developed that reduces PM2.5 and other emissions by at least 99%.

3. Can you provide any suggestions for cooperation/partnerships and/or knowledge, education and awareness for the purpose of assisting governments to manage air quality?

Avoid inefficiencies of repetition.  A National Clean Air Agreement should aim to avoid the current inefficiencies of repetition when all states have to consider the same issue and carry out separate benefit-cost analyses and regulatory impact statements (RIS).  The Agreement should allow the Commonwealth to carry out a single benefit-cost analysis and RIS for clean air legislation that applies to all states.  

Correct the deficiencies in the NPI.  The National Pollutant Inventory (NPI) is an essential part of the framework provided by the Commonwealth Government, but its utility is hampered by resource limitations.  For example, PM2.5 are considered the most health-hazardous pollutant. The NSW EPA inventory lists 31,744 tonnes of PM2.5 emitted to the NSW Greater Metropolitan Airshed (GMA), but the NPI lists only 3,919 tonnes (12% of the NSW EPA’s total) of PM2.5 emissions to the same airshed.  If the NPI is to live up to its name, and serve as a comprehensive, national inventory, it needs adequate resources.  The present situation of ignoring 88% of emissions of the most health-hazardous air pollutant in a major urban population centre is a false economy that should be corrected as soon as possible.

Avoid unnecessary delays.  Implementing the pollution-control measures with greater benefits than costs (identified in the NEPM documents, plus the $20 to $24 billion of savings from woodsmoke control) would reduce average PM2.5 pollution to less than 6 μg/m3 and so save 700 lives per year -  Delays implementing the NEPM are delaying the implementation of these measures and costing many lives per year. 

Streamline Regulatory Impact Assessments. Regulatory Impact Statements are to determine whether benefits exceed costs.  In many cases, the evaluations conducted for the NEPM, or as part of the NSW woodsmoke control options evaluation should be sufficient to proceed with legislation.  When, as in Appendix 1, the benefit is over 100 times the cost – e.g. phasing out wood heaters when houses are sold is estimated to save $4 billion in health damage for a cost of just $32 million.  With net benefits of over $12 billion for the whole of Australia, further delays would cause significant costs but no benefits. 

Identify and remedy the causes of previous delays and inefficiencies.  One of the most significant failures of the regulatory process is the failure to manage wood heater emissions which, as shown by the NSW Air Emissions Community Web tool  (top right column) account for more than half of all PM2.5 emissions in Sydney.   Despite this, the Federal Government’s Wood-heater Consultation Regulation Impact Statement (CRIS) did not even consider whether new wood heaters that emit more PM2.5 per year than 1,000 petrol cars should be allowed.  The problem is that there is no effective standard for wood heaters.  New heaters that satisfy all  standards required until 2019 have been observed emitting pollution at the levels shown in the photos for many hours.  Yet the proposed Commonwealth wood heater decision RIS  "will reflect the new Standards for wood heater efficiency (AS/NZS 4012:2014) and emissions (AS/NZS 4013:2014) developed by Standards Australia in 2014". 
This “standard” was set by a committee that did not include a single health expert and there is no evidence it even discussed the estimated $20 to $24 billion health cost of wood heater emissions.  Even worse, the wood heating industry was able to veto any changes to that standard that it did not like.  This is no more sensible than allowing the tobacco companies to set policies on the health effects of cigarette smoking.  Because of these problems, a higher proportion of submissions on the CRIS favoured banning wood heaters in urban areas than any of the options considered in the CRIS.  A more flexible cost-benefit analysis showing total costs of woodsmoke pollution under each option, enabling full and transparent consideration of the costs and benefits, could have greatly assisted the decision process and perhaps saved time, effort and damage to health. 
Future protocols should therefore calculate and report the cost of all options, instead of the difference between them, to facilitate public understanding of such important issues.

Essential partnerships identified in the consultation document.  
1) a National Air Quality Data Service
managed by the Bureau of Meteorology to improve access to information and reporting on air quality and
2) $8.88 million in funding for a clean air and urban landscapes hub to support environmental quality in urban areas.  An effective partnership with the clean air hub could be one way to provide essential public education on the sources and health effects of urban air pollution and the most effective ways to combat it.

Other essential partnerships.  The Standards Australia process allows industry to veto any proposed changes.  It is therefore no more suitable for setting health standards than one that allows the tobacco industry to veto changes to policies on cigarette smoking.  The current “standard” for wood heaters was set by a committee that did not have a single health expert amongst its membership and there is no evidence that it even discussed the estimated $20 to $24 billion health cost of wood heater emissions.  The Federal Government should therefore introduce a moratorium on the installation of wood heaters until a new health-based standard had been set by independent experts.  Partnerships with health experts who are capable of reviewing the costs and benefits of polluting appliances, and developing appropriate policies, should therefore be an essential part of the National Clean Air Agreement. 

Educate and improve public knowledge about the health effects of air pollution.  Although there is considerable public support for reducing air pollution, many people have no idea about the sources of air pollution, e.g. that a typical new Australian wood heater is expected to emit more PM2.5 per year than 1,000 passenger cars.  An effective National education campaign on the sources of health-hazardous air pollution would be a very cost-effective way to avoid harmful emissions.  Some very interesting educational messages developed are shown at:

The public supported new Australian standards that added $980 to a $40,000 diesel SUV, but was estimated to save “more than $1.5 billion in public health expenditure over the next 20 years” - see “Car pollution crackdown will save lives but comes at a cost”. Yet even before the introduction of the new standards, pollution from new diesel SUV was nothing like the emissions shown above, of brand new heaters satisfying the current Australian standard; all except the chimney in the top left picture also known to satisfy the standard proposed until 2019.   More research is needed into whether people understand with the scientific study results that show woodsmoke is at least as harmful as PM2.5 pollution from other sources, and how to provide better information to allow the public to make informed decisions.

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.

Estimated health benefits and costs of woodsmoke control options in NSW




Health Benefit

Cost $million

Net Benefit $million

4) Phase out at sale of house




2) Ban on heater sales




7) Licensing fees





6) Sales tax on new wood heaters




9) Cash incentive phase out




8) Levying an excise/tax on biomass fuels




5) Fuel moisture content regulations




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




Source:  Tables 26 and 28, AECOM Office of Environment & Heritage: EconomicAppraisal of Wood Smoke Control Measures[3]
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)

  Current policies will allow wood heaters with the level of emissions shown to pollute residential areas for many hours a day.  S