Submission: Community Member, Armidale Dumaresq Council Domestic Energy Education Committee

Submission: wood smoke control options for NSW

I wish to comment on the options for wood smoke control in NSW. My concern is that wood smoke pollution is a serious health problem that has not been sufficiently addressed to date.

 I live in Armidale and have been a Community Representative on the Council committee responsible for wood smoke control since it was established. The local Council has for many years endeavoured to address the problem but has been hamstrung by a lack of funds and the lack of a suitable legislative framework. Council sought legal advice on whether or not they had the power to ban the installation of new wood heaters and were told that they did not. Consequently wood heaters are being installed in new housing developments. No wonder that Council’s (largely token) efforts to control wood smoke pollution have had little or no effect.

Scientific studies are regularly published linking fine particles and the chemicals found in wood smoke with asthma, bronchitis, emphysema, cancer, heart disease and reduced life span in humans. Recent research has linked the PAHs found in wood smoke to genetic damage in babies and to behavioural problems and reduced IQ in children. Even the inhalation of chemically inert fine particles is hazardous to health.

In country towns wood smoke is responsible for the vast majority of air pollution. Fortunately this is seasonal although in towns like Armidale the cool season is relatively long. Also, the unfortunate geography of Armidale (it is situated in a valley surrounded by hills) makes it particularly susceptible to temperature inversions that trap wood smoke pollution on cold, calm nights. Since approximately half the homes in Armidale use wood heaters, there is a great deal of wood smoke pollution in Armidale in the cool months. Wood heaters can be found in use nine months of the year due to occasional unseasonable cold periods. Some household’s burn wood for cooking and heating water. Consequently they pollute all year round.

Wood smoke can even enter homes that are tightly sealed. This is true even when there is no wood heater in close proximity. Therefore it is imperative to reduce the amount of wood smoke in the air. Otherwise the whole community is breathing air containing elevated levels of fine particles, also containing dangerous chemicals, for very significant periods during the cooler months of the year.

A large part of the problem stems from the fact that wood heaters are rarely operated at their rated emission level (which is a theoretical minimum obtained from a laboratory test where all parameters are ideal - i.e., in a completely unrealistic situation). Numerous factors effect wood smoke emissions from a wood heater. For example, there are right and wrong ways of placing wood in the wood heater, starting the fire, etc. The flue must also be kept clean. Firewood must be of good quality, dry and seasoned. It must be stored under cover, off the ground, and stacked so that air can circulate through the woodpile. Getting the details of any of the above wrong can result in significantly increased wood smoke emissions from that wood heater.

In overseas communities with similar wood smoke problems to ours, they have found that the only solution is to ban wood heaters, including the latest “low pollution” models. Pending the banning of wood heaters we should ensure that wood heaters are operated correctly. If we can achieve this we will make a significant reduction in our air pollution.

However, even when operated correctly, even the latest models of wood heaters cause significant pollution. Therefore all wood heaters must be replaced with non-polluting alternatives over the medium to long term. As a first step we should ban the installation of any new wood heaters.

The responsibility for controlling wood smoke emissions (the major contributor to air pollution in much of rural Australia) should not be left primarily in the hands of local government. Local government has a long and continuing history of vacillation on this subject, perhaps partly due to conflicts of interest, lack of expertise, lack of funds, etc.

 In Armidale many years of sporadic and unprofessional “education” of the public has resulted in insignificant changes in the knowledge of the public. For example, the Armidale Woodsmoke Report 2003 carried out by Malte Nachreiner and Dr Don Hine of the School of Psychology at the University of New England revealed that 47% of Armidale’s population still believe that wood smoke does not adversely affect their health.

Air quality was first raised as a significant issue at a public meeting held in 1994 to introduce Armidale City Council’s first State of the Environment (SOE) Report. Air Quality Monitoring and public education commenced in 1995. To date there has been little change in air pollution levels.

 Education on the hazards of wood smoke pollution needs to be properly funded and carried out professionally. The same applies to the regulation of wood heater operation. There need to be clearly set out guidelines on what is and what is not permissible in the way of wood smoke emissions. Additionally, sufficient grounds for penalties to be imposed on polluters must be stipulated, and these regulations must be enforced.

The EPA should fund professional press, radio and television education campaigns that will once and for all educate the public on the dangers of wood smoke pollution. Local government has been ineffectual in this regard.

Armidale Dumaresq Council has not publicised a complaint line for people to report smoky chimneys. It also finds it difficult to fund smoke patrols, especially out of business hours. Since most wood smoke pollution is generated in the hours of darkness, the rare Council smoke patrols are ineffective in identifying and deterring the main polluters, in particular those householders who leave their wood heaters smouldering (and polluting) all night.

 To my knowledge the Council has not issued a single smoke abatement notice despite the same wood heaters being identified as pouring out vast plumes of smoke every year. As previously stated, legal advice to Council was that the legislation did not allow them to ban wood heaters and that they might be sued if they did.

This is all the more reason for the EPA to take a more prominent role on this issue, especially in educating the public on the dangerous health effects of wood smoke and enforcement of penalties for wood smoke pollution.

 The Council has a detailed policy for dealing with wood smoke pollution. However much more time and effort was spent on developing the policy than has been spent on controlling wood smoke. The perennial excuse for not investigating smoky chimneys and conducting wood smoke patrols is lack of time and staff time. However my experience, after a decade of service on the Council’s Domestic Energy Committee, is that it is of very low priority to the busy Council officers.

 Elected councillors have consistently rejected taking any of the strong actions to discourage the use of wood heaters that have been proposed to them by the Domestic Energy Committee. There has been limited success with subsidies for replacing wood heaters with other forms of heating. This can never achieve much when people are still permitted to install new wood heaters.

 If left to the local Council, political considerations will override the vastly more important health considerations. In the foreseeable future Armidale Dumaresq Council councillors will never approve the banning of wood heaters if the decision is left up to them. Consequently I strongly believe that the NSW government, through the EPA, should decide the wood smoke controls to be used in each local government area or part thereof.

Because local government has generally been ineffectual in reducing wood smoke pollution, I request:

 1. The EPA takes over public education on this issue and properly funds professional education programs utilising all media. The education programs would be to educate the public on the health effects of wood smoke and the proper operation of wood heaters, to encourage the use of alternative methods of heating, etc.

 2. The EPA establishes and publicises a Wood Smoke Pollution line that the public can telephone to report excessively smoking chimneys.

 3. Wood heaters should be phased out within, say, 10 years. (That is, after 10 years it will become illegal to use one.)

 4. Pending the banning of wood heaters, annual license fees should be levied on households which wish to continue to operate wood heaters. I suggest a sliding scale so that the license fees are increased each year as an incentive for the owner to replace the wood heater with an alternative heating source. The license fees should be substantial (e.g. $500 in the first year, increasing by $100 a year).

 5. Installation of all new wood heaters is to be banned.

 6. It should be a requirement that wood heaters are removed when houses are sold.

 7. The EPA or local government authority should have the power to ban the emission of visible wood smoke during weather conditions conducive to high wood smoke pollution (e.g. on calm, clear nights in areas prone to temperature inversions). Substantial fines should be imposed on those who ignore the ban.

 8. That the EPA decides what level of control of wood smoke is to apply in each area or part thereof.

 9. Wood smoke control options 2, 3 and 6 should be mandated in Armidale.

 10. There should be a legislated plan for removal of all solid fuel combustion heaters, such as wood heaters and open fireplaces, from Armidale by a certain date, say 2025.

 Alan Joynt

30 November 2012