Proposal saves only 0.4% of $8 billion health costs - not fit for purpose
Reducing wood heater pollution is one of 3 key initial actions of the the National Clean Air Agreement. Given the $8 billion estimated health cost of wood heater pollution, a 0.4% reduction is hardly fit for purpose.
Assessment uses grossly incorrect assumptions
The VW scandal shows that highly controlled tests in the laboratory don't represent what happens in real-life. This is a major issue for wood heater pollution. Real-life emissions of 37 heaters installed in ordinary homes were measured in six New Zealand cities. In the lab test, emissions averaged 0.85 grams of particles per kilogram of firewood burned, well within the requirements that will apply in Australia from 2019. Since 2005 (and even earlier in Christchurch), NZ has required stricter lab test results for heaters installed in urban areas than those that will apply in Australia in 2019. But real-life emissions of the 37 NZ heaters averaged 6.6 grams/kg firewood, nearly 8 times worse than the lab tests (see Appendix)
Despite the NZ results, the Victorian Policy Impact Assessment (PIA) assumes new heaters will have real-life emissions of 2.6 g/kg, nothing like the real-life measurements in NZ!! The totally unrealistic value in the PIA seems to be a guesstimate extrapolated from CSIRO’s 2008 work on much older heaters that satisfied a lab test introduced in 1993. Why were grossly inaccurate guesstimates used when much better information was available? Like the proposed policy, the policy impact assessment is not fit for purpose and should be redone.
Were the consultants unaware of the research into real-life emissions in New Zealand? Was any pressure exerted by vested interests to further profits by making new heaters appear much cleaner than they are? How will this failure be addressed and what steps will be taken to prevent such grossly unacceptable, dangerously incorrect policy assessments in future?
Good policies maximize total benefits, not benefit-cost ratios
The estimated net benefit of Alternative Policy 2 (increase existing wood heater replacement rate) was $463 million, 14 times better than the proposed policy.
Many of Infrastructure Victoria’s proposals have estimated benefit-cost ratios of 1.0-1.4. A policy with a benefit-cost ratio of 8.8 and net benefits of $463 is far superior to one with a net benefit of just $33 million, even if some additional legislation is required for its adoption.
This assessment fails the ‘pub test’. The health costs of air pollution are dominated the cost of premature deaths. If asked to choose between a policy that saved 261 lives for a cost of $59 million or one that saved 16 lives for a cost of $213,000, who would not want to save more lives?
Biased summary of previous consultations, leaves unanswered questions
The PIA mentions the ‘Consultation Regulation Impact Statement for Reducing Emissions from Wood Heaters’ (CRIS) in April 2013. A majority (33) of the 59 submissions on the CRIS either advocated banning or phasing out all wood heaters in urban areas (25 submissions) or not allowing new wood heaters to be installed (8 submissions). Nearly half of all submitters reported suffering from unresolved problems caused by neighbouring wood heater pollution, with 39% of all submissions reporting adverse health effects often requiring increasing medicinal solutions, including steroid use for asthma diagnoses in children. Similar neighbourhood examples were also cited in submissions from other stakeholders, such as academic and community groups.
None of these problems was considered in the Vic EPA policy impact assessment. Instead of recognising the hardship and suffering caused by caused by breathing other people's woodsmoke, the PIA simply suggests that local councils (that were obviously unable to solve these problems) should continue with more of the same failed policies
Only 10 submissions on the CRIS supported of the wood heating industry, but these 10 submissions are given more prominence in the PIA than the 39 submissions supporting effective regulations to clean up the air, something the proposed policy fails to do. The bias is so substantial – negligent guesstimates of real-life emissions from new heaters that are nothing like the real-life data from NZ, an evaluation process that considers saving 261 lives for $59 million inferior to saving 16 lives for a cost of $0.21 million, and a complete failure to provide any practical solutions for neighbours suffering serious health effects from nearby wood heaters. The outcome couldn’t have been any better for the wood heating industry if they had written the policy themselves!
The Vic EPA’s web page advertising the Waste Manage Policy (Solid Fuel Heating) consultation states: “EPA would like to hear from all interested stakeholders, particularly those in the solid-fuel heater industry, to consider how they may be affected by the proposed variation.” Why focus on the wood heating industry, but not health advocates? Which is more important – a sick child needing hospital treatment or the profits of the wood heating industry?
“Growing up in New Zealand” study: 1 woodstove per hectare = significant health damage
The “Growing up in New Zealand” study found that every additional modern woodstove per hectare increased by 7% the risk children under 3 would need hospital emergency treatment (for all causes except accidents). The emissions and efficiency requirements introduced in New Zealand in 2005 for all urban areas are stricter than those to apply in Australia in 2019. The failure of the 2005 NZ standard to produce meaningful reductions in pollution (despite being stricter than the proposal for Victoria in 2019) has been recognized in NZ, e.g. by the introduction of a completely different test for all new heaters to be installed in Christchurch. Unless the policy proposed for Victoria is changed, many children will need hospital treatment because of a failure to protect them from unacceptable levels of woodsmoke pollution
Alternative policy could save up to $6 billion
A consultancy report for the NSW government in 2012 concluded that wood smoke pollution was an $8 billion health problem in NSW, but that not allowing new heaters and removing existing heaters, e.g. when houses are sold, would reduce estimated health costs by 75%. This equates to an estimated net saving of $6 billion in Victoria for a cost of perhaps $170 million, i.e. 35 times as many benefits as costs. Why was this option not taken seriously?
Should have investigated other alternatives, e.g. Christchurch’s policy
The PIA mentions other policies such as that in Christchurch, NZ, before the AS4013 test was abandoned (because of its inability to predict real-life emissions). To avoid the potential problem highlighted in the PIA that not allowing new heaters might encourage existing wood heater users to hold on to older models, Christchurch allowed new heaters to be installed, but only as replacements for more polluting models. Christchurch’s current policy of requiring all new heaters to satisfy an improved wood heater test designed to represent real-life emissions should also have been investigated.
The
Mutual Recognition act did not prevent changes to protect the health of
Victorians from unflued gas heater pollution. Unflued gas heaters 1) can be
installed only as replacements for older unflued gas heaters and 2) must
satisfy Energy Safe Victoria requirements. A similar policy for wood heaters
could prevent many premature deaths and saved billions in health costs. Why
wasn’t it considered?
Current proposals don’t protect sensitive groups
(pregnant women, children, elderly, asthmatics) from the unhealthy pollution of
nearby wood heaters
According
to the PIA, past consultations “support EPA’s belief that there is still a high
degree of community concern about air quality, including concern about the use
of wood heaters.” Also noted is the fact that the EPA receives complaints about
inaction by local councils in addressing problems caused by other people’s
woodsmoke. There is general agreement
that there is no safe level of PM2.5 pollution and that significant health damage
can result from the increased PM2.5 exposure from living next to a modern wood
heater (as was observed in the Growing up in NZ study). The policy should
therefore include provide safeguards to ensure that wood heaters do not damage
the health of nearby residents.
Natural gas is not the answer
Modern, efficient heat pumps (also
called reverse cycle air conditioners) have superseded wood stoves and natural
gas as the most cost-effective heating.
They can deliver 5 or 6 times as much heat to the home as they use in
electric power, are affordable (as cheap as buying a wood stove) and have lower
running costs than buying firewood. In
addition they cause a lot less global warming, and don't damage our health.
A report in
2015 by Tim Forcey: “Switching off gas - An examination of declining gas demand in Eastern Australia” explains: “Economic
fuel-switching results in significant energy-cost savings for former domestic
gas consumers. Based on analysis by MEI and the Alternative Technology
Association, people living in up to one million homes across eastern Australia
(and most particularly in Victoria) can start saving hundreds of dollars on
their heating bill tomorrow if they switch off their gas heater and turn on
their reverse-cycle air conditioner.
“Space-heating cost savings of
$1,733/year (a savings of 77%) were modeled for a large home in Canberra and
$658/year (63%) for a large home in Melbourne. Unfortunately, householders are
unaware of these remarkably-large and quick savings because of out-of-date and
inaccurate information. It is possible that in Victoria alone, households could
collectively and immediately save on the order of $250 million/year by using as
a space-heater the reverse-cycle air conditioners they already have in their
homes.”
This PIA continues the promulgation of out-of-date and
inaccurate information. Instead of wasting taxpayers’ money on the Regional Gas Infrastructure Program, the government should
explain the cost and climate
benefits of modern, efficient, heat pumps compared to wood and gas heating.
Surplus funds should be used to improve public health by subsidising the replacement
of wood stoves with heat pumps.
Current proposals inconsistent with precautionary principle
The mistakes made with asbestos should not be repeated with woodsmoke. As the most significant source of the most health-hazardous air pollutant (PM2.5) in urban areas, woodsmoke has been labelled the new asbestos. The average brand new heater emits more PM2.5 per year than 1,000 petrol cars. Indeed, the NSW Asthma Foundation warned that: wood smoke emissions in winter pose a bigger immediate health danger in built-up urban areas than cars or cigarettes. Australian Lung Foundation spokesman Dr James Markos said that real-life emissions from new wood-heaters have little relationship to measurements from a perfectly operated test model under laboratory conditions. .
The chief medical officer of NSW said that wood heaters are so detrimental to health she supports banning and phasing them out in built-up urban areas. A review by the New Scientist in 2017 concluded that log-burning stoves are harming our health and speeding up global warming
Woodsmoke contains the same and very similar chemicals to cigarette smoke. A review by Naeher noted:“Organic extracts of ambient particulate matter (PM) containing substantial quantities of woodsmoke are 30- fold more potent than extracts of cigarette smoke condensate in a mouse skin tumor induction assay”. Studies in Canada found that just 5 ug/m3 of increased PM2.5 pollution increased heart attacks by 19% when the pollution was mainly from wood burning.[3]
Heart attacks and strokes are the tip of the iceberg. The PM2.5 and toxic chemicals in woodsmoke increase the risk of lung diseases, cancers, Alzheimer’s, cot deaths, still and premature births, genetic damage in babies, stunted lung development, reduced IQ in children and behavioural problems such as anxiety, attention deficit and autism.[4]
Tackling woodsmoke pollution has saved many lives. When Launceston residents understood the health effects of woodsmoke, the proportion of households using wood heating fell dramatically from 66% to 30% and average PM2.5 pollution during winter fell by 40%. The result was 28% fewer deaths in winter from respiratory disease and 20% fewer deaths from cardiovascular disease.
Given the serious health damage from the proposed policy, the precautionary principle and government’s Duty of Care to protect public health requires the government to not allow new wood heaters to be installed until their safety can be guaranteed. The $8 billion health damage from allowing wood heaters to be used by a small proportion of households in Victoria represents an intolerable cost. Consequently, existing wood heaters should also be phased as soon as practicable. If new legislation is required to achieve this, or ensure that future heating options do not damage public health, work should commence immediately on developing the legislation needed to achieve this aim. It would have been inappropriate and unconscionable to allow asbestos to continue to be installed in Victoria once the dangers were known, just because the product was legal in other states. The same argument applies to wood stoves. The Duty of care is to protect public health and safety, not the profits of the wood heating industry.
23 Dec 2014: NEPC publishes submissions on the NEPM AAQ variation
Brief Summary of Submissions
109 Individually-composed non-confidential personal and group submissions
25 on-line survey responses
420 emails to Ministers and the NEPC - see right-hand column
40 pre-printed postcards - see right-hand column
7 confidential submissions
The 420 emails to ministers and the NEPC expressed support for a maximum daily average PM2.5 of 20 ug/m3, maximum annual average of 6 ug/m3, maximum daily average PM10 of 40 ug/m3, maximum annual average of 20 ug/m3.
Of the 109 individually-composed submissions that expressed an opinion, 72% favoured a 20 ug/m3 limit for daily average PM2.5 and 73% a 6 ug/m3 annual limit. For PM10, 80% favoured a daily limit of 40 ug/m3 and 93% of those expressing an opinion supported a 20 ug/m3 annual limit.
The on-line survey asked respondents if they supported a 25 ug/m3 daily PM2.5 standard and if they supported an 8 ug/m3 annual PM2.5 standard. All but one of the respondents that expressed an opinion favoured these options or more stringent PM2.5 standards. In addition, 36% stated without prompting that a preference for a 20 ug/m3 daily PM2.5 standard and 33% for a 6 ug/m3 annual PM2.5 standard. 79% of survey respondents supported a 40 ug/m3 daily max PM10 standard and 95% an annual standard of 20 ug/m3 PM10. A spreadsheet has been compiled with details of the calculations and other information.
Conclusions. The submissions expressed overwhelming public support for strict air pollution standards, notably PM2.5 standards of 6 ug/m3 (annual) and 20 ug/m3 (daily max) and PM10 standards of 40 ug/m3 (daily max) and 20 ug/m3 (annual average). There was also a general consensus that the standards should be adopted without delay - NEPC processes in the past have taken far too long.
420 submissions to the NEPC expressed the sentiments below.
Dear Minister,
I am writing to express support for the immediate adoption of improved air pollution standards via the proposed variation to the Ambient Air NEPM. For too long, Australians have been exposed to harmful levels of pollution. It’s time to hold polluters accountable and put community health first.
Particle pollution is a killer, ending more than 3,000 Australian lives prematurely each year. I’m pleased that you are considering standards for the fine particles (PM2.5) emitted from cars, power stations, wood heaters and other combustion sources. An annual standard of 6 micrograms per cubic metre should be adopted – it would save 700 lives each year.
It’s also encouraging that you are considering lowering the 24-hour standard for course particles (PM10) from 50 to 40 micrograms per cubic metre and bringing in an annual compliance standard for PM10. There is no level below which particle pollution doesn’t damage respiratory and cardiovascular health. 40 micrograms should be adopted as the 24 hour standard and 20 micrograms should be adopted as the annual standard. Pollution should be reduced as much as possible, as quickly as possible.
All these standards should be adopted without delay – NEPC processes in the past have taken far too long.
Controlling air pollution will take more than just standards. Our pollution standards are frequently exceeded in some regions but regulators are slow to enforce or prosecute. Pollution could be reduced through simple measures like covering coal wagons and tackling emissions from wood heaters and diesel engines. I urge you to consider how Australia’s weak regulations for air pollution could be strengthened through a national Air Pollution Prevention Act.
Sincerely,
Another 40 people sent postcards to the NEPC asking for strong national air pollution laws.
Summary of Issues
The current NEPM process is
bogged down with bureaucracy, and so has failed to meet its vitally important aims
of minimising the risk from adverse health impacts of exposure to air pollution
for all people wherever they may live (recommendation of the 2011 review) and providing
equivalent protection to all Australians wherever they live (original aim).
The true net benefits of
adopting the economically feasible measures are at least $24 billion, not the
claimed $8.8 billion.
Measures that
would generate an estimated $15 billion in net benefits (from woodsmoke-control)
were omitted from the economic analysis, implying that the NEPC did not
consider economically feasible measures.
‘Adoption of international best
practice PM control measures at coal mines’ was considered, but not the costs
and benefits of covers for coal wagons.
As a general principle, polluters should be required to pay the
estimated health costs of their pollution.
This would discourage polluting activities and provide funds to monitor
air pollution, evaluate and implement appropriate pollution-reduction
strategies, assist people whose health is affected by air pollution, and cover
costs to the health system.
Delays have wasted money and cost lives by focussing on less hazardous pollutants instead of PM2.5 - the pollutant most closely linked to the greatest heath costs. The impact statement for
the Draft Variation to the National Environment protection (Ambient Air
Quality) Measure states: “The greatest proportion (>99%) of the
health costs accrue from avoiding premature deaths due to long-term exposure to
PM2.5.” With limited resources, the most cost-effective approach is to
focus efforts on the most health-hazardous pollutants. Delays in revising the NEPM have created a perverse
situation, where, for example, the NSW EPA has 13 sites in Sydney measuring PM10, but only 4 measuring
PM2.5. The public would be better served
by more streamlined processes (perhaps based on national clean air laws) to implement
legislative changes on monitoring and reducing emissions when the benefits are obviously
much greater than the costs, e.g. estimated benefits of $4,015 in NSW for costs
of just $36 million from requiring wood-heaters to be removed before houses are
offered for sale.
Annual
PM2.5 average of 6.0 μg/m3; daily max PM2.5 of 20 μg/m3;
annual average PM10 of 20 μg/m3; daily max PM10 of 40 μg/m3 are achievable if all $24 billion of economically feasible measures are implemented. The $24 billion of economically-feasible measures include the
woodsmoke-control measures which could generate $15 billion of net benefits but
for some unknown reason were not considered by the NEPC.
Every day of delay causes
another 1 or 2 unnecessary premature deaths, or about 700 deaths per year. The Summary for Policymakers from the Health Risk Assessment noted that decreasing average annual PM2.5 exposure to 6 μg/m3 would result in 540 fewer deaths every year in Sydney, Melbourne, Perth, Brisbane & SE Qld, i.e. about 700 deaths per year for all Australia.
Tables A34 and A35 (right hand column) show that implementing the identified pollution-control measures with greater benefits than costs (including 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 in the NEPM are delaying the implementation of these measures that could save about 700 lives per year.
Without polluter-pays taxes, the community is forced to subsidize polluting
activities. Polluters-pays taxes are needed to pay
the health costs of their pollution. The
lack of such taxes is forcing the general community to subsidize polluting
activities. National Clean Air Laws are
needed to oversee the implementation of the economically beneficial
pollution-reduction strategies and avoid unnecessary delays and premature
deaths. Every day of delay causes
another 1 or 2 unnecessary premature deaths.
New monitoring protocols
are needed to ensure pollution is measured in the areas where it causes the
greatest harm. Even for small populations such as Geeveston, Tas (a small town
of 277 houses where the 25 μg/m3 PM2.5 target was exceeded 99 times
in 20 months, mainly due to domestic wood heating), it is not acceptable to
ignore the public health issue by not measuring PM2.5 (either directly or using
nephelometers). The NEPM protocols
should specify use of portable systems (such as those developed by EPA TAS) to
identify areas of unacceptable pollution and enable monitoring and
pollution-reduction strategies to be implemented.
Net benefits over $24 billion from economically feasible measures,
not $8.8 billion
The NSW Government’s economic
analysis of woodsmoke control options reported that the estimated health costs
of woodsmoke in NSW amounted to over $8 billion[1], but that a new emissions test and health-based standard (set
by experts with no financial interest in the wood heating industry) together
with 3 simple control measures could reduce the damage by at least 75%.
1) Remove all heaters that do not meet a health-based
standard when houses are offered for sale
2) Permit only heaters meeting the health-based standard to
be installed
3) Licensing fees to cover the cost of wood smoke-reduction
programs and assist people whose health or lifestyle has been affected by wood
smoke.[1]
Despite a much colder climate
with daily average temperature below freezing from December to March, Montreal is implementing
similar measures. The installation of
new log-burning heaters was banned in 2009.
Since then, the number of smoggy days in winter (where PM2.5 concentrations
exceed 35 μg/m3 for more than 3 hours over 75% of Montréal) has
fallen from 29 in 2009 to 10 in 2013[2]. Rather than
creating hardship, the policy appears to have met with sufficient approval that
it is now being extended to require all existing wood stoves to be removed by
the end of 2020.[3]
Australian health authorities have voiced support for similar
measures, e.g. the NSW Asthma Foundation.
The NSW Chief Medical Officer Kerry Chant said that wood heaters are so
detrimental to health she supported banning and phasing them out in built-up
urban areas.[4] As well as emitting more PM2.5 (noted above
to be the most health-hazardous air pollutant) per year than 1,000 passenger
cars, domestic wood heaters are also bad for the environment and cause more
global warming than other forms of heating.[5]
Scaled up to the whole of Australia, the 3 woodsmoke
measures listed above are estimated to generate net benefits of about $20
billion, $15 billion more than the ineffectual proposals for woodsmoke in the
NEPC’s economic analysis. Adding the $15
billion to the $8.8 billion net benefit in the NEPC analysis leads to the
conclusion that economically feasible
measures to reduce PM pollution have net benefits of $24 billion.
Unacceptable delays = unnecessary deaths
There is overwhelming evidence
of a strong, quantifiable relationship between PM2.5 pollution and adverse
health effects including premature deaths, heart attacks, strokes. Premature deaths from air pollution in Sydney
resulted in the lost of an estimated 6,300 life-years in 2008.[6] The Summary for Policymakers of the Health Risk Assessment
on Air Pollution reports that annual mortality attributable to long-term PM2.5
exposures above background is equivalent to approximately 1590 deaths at
typical ages (2.2%) in Sydney, Melbourne, Brisbane & SE Qld and Perth, and
that decreasing average annual PM2.5 exposure to 6 μg/m3 would lead
to a decrease in attributable mortality of 34%.[6] A 34% decrease
represents about 540 fewer deaths every year.
‘Economically feasible’ + Woodsmoke Control (EF+WS) could 700
lives/year
The NEPC Economic Analysis[7] states: “the reduction of primary PM emissions will often
be associated with a reduction in emissions of other pollutants that are
precursors of secondary PM, thus reducing secondary PM formation”. This is certainly true for woodsmoke. In Aspendale, Melbourne, the secondary
organic aerosol fraction of PM2.5 was greatest during the autumn and early
winter months when the formation of inversions allows build up of particles
produced by domestic wood-heater emissions.[8]
The woodsmoke-control measures
discussed above are therefore likely to result in even greater net benefits
than the formal estimate of $24 billion noted above. Many other measures found by the economic
analysis to be ‘economically feasible’ will also reduce secondary particle
formation and so achieve even greater benefits than predicted. Table 3.2 (p29) of the Economic Analysis reports average PM2.5 levels of 6.9
μg/m3 in the Sydney Greater Metropolitan Area and 6.2 μg/m3
in Victoria and Port Phillip. It
therefore seems highly likely that the desired target of 6 μg/m3
PM2.5 is achievable, saving over 500 lives per year.
Health benefits of pollution control likely to be much greater
than predicted
As well as premature deaths, studies
have linked long-term exposure to PM2.5 to several new health outcomes,
including atherosclerosis, cot deaths, adverse birth outcomes and childhood
respiratory disease.[9] Emerging evidence
also suggests possible links between long-term PM2.5 exposure and
neurodevelopment and cognitive function, as well as other chronic disease
conditions, such as diabetes.[9] These undesirable
outcomes indicate that the health costs of air pollution are likely to have
been under-estimated.
Polluter-pays principle
Polluters should be required to
pay the estimated health costs of their pollution. This would discourage polluting activities
and provide funds to monitor pollution, implement pollution-reduction strategies,
assist people whose health is affected by air pollution and cover the costs to
the health system.
Put most effort into monitoring & reducing the worst
pollutants
The impact statement for the
Draft Variation to the National Environment protection (Ambient Air Quality)
Measure states: “The greatest proportion (>99%) of the health costs accrue from
avoiding premature deaths due to long-term exposure to PM2.5.” The best and
most cost-effective approach is to devote limited resources to the most
health-hazardous pollutants.
Unfortunately, delays in reviewing the NEPM have created a perverse
situation, where, for example, the NSW EPA has 13 sites in Sydney currently measuring PM10, but only 4
measuring PM2.5. The public would be
better served by a more streamlined process (perhaps based on national clean
air laws) to update monitoring protocols and legislate pollution-reduction
strategies where the benefits are obviously much greater than the costs, e.g.
the estimated benefits of $4,015 in NSW for a cost of just $36 milling from
requiring wood-heaters to be removed before houses are offered for sale.
A simple recommendation for
monitoring sites to measure PM2.5 when the advisory PM2.5 standard was more likely
to be exceeded than the PM10 standard could have been recommended as part of a
streamlined NEPM review in 2005, for very little cost but great public
benefit. Evidence linking PM2.5 exposure
to adverse health effects rather than coarser particles has been known for
decades. Studies published in 1993[10] and 1996[11] provided strong evidence that premature mortality is more
closely linked to PM2.5 than particles between 2.5 and 10 microns. The
continued delays in setting up adequate PM2.5 monitoring seems incomprehensible
given the widespread acknowledgement that health impacts are more closely
related to PM2.5 than PM10, e.g. the NSW EPA report on valuing the health
impacts of air pollution states: “A recent UK report states that PM2.5
is considered to be the best index of PM for quantitative assessments of the
effects of policy interventions (COMEAP, 2009).”[12]
Monitor where pollution targets are likely to be exceeded
New monitoring protocols are
needed to require pollution to be measured in areas where targets are most
likely to be exceeded. In a 20-month
study of Geeveston, Tasmania (a small town with 277 houses) the
PM2.5 advisory standard of 25 μg/m3 was exceeded 99 times. Despite the small population, such extreme
pollution (77% of man-made PM pollution coming from wood-heaters, 11%
from smoke plumes from forestry burns, 4% from waste combustion and 8% other
sources) demonstrate a clear need for PM2.5 to be measured. In such cases, nephelometer-based
measurements such as the Tasmanian BLANkET (which has
been shown to be almost interchangeable with the standard reference methods)
are acceptable. NEPM measurement
protocols should be drafted so that, even for small populations such as
Geeveston, it is not acceptable to ignore the public health issue by not
measuring PM2.5 either directly or using optical proxies. EPATAS has developed a portable system that
could be used to identify areas of unacceptable pollution[13] and enable monitoring and pollution-reduction strategies
to be implemented.
General responses to the NEPC consultation
Most people think
of an air pollution ‘standard’ as a safe level.
This is clearly not the case. The
current NEPM reporting system is largely ineffective because it allows jurisdictions
to exceed ‘standards’ without penalty.
Unless this is to change, the most effective approach will be to set the
strictest possible aspirational standards (annual average PM2.5: 6.0 μg/m3;
daily max PM2.5: 20 μg/m3; annual average PM10: 20 μg/m3; daily max PM10: 40
μg/m3).
National Clean Air
Legislation and polluter-pays taxes are also needed to ensure all economically
feasible measures such as the EF+WS measures discussed above are implemented as
soon as possible. With 500 avoidable premature deaths per year, every day of
delay causes another 1 or 2 unnecessary premature deaths.
NEPC Consultation Questions
Chapter 2:
Characteristics and measurement of airborne PM
Ø
The
characteristics of airborne PM are described in some detail. Would any further
information on airborne PM characteristics assist in informing action to reduce
airborne PM? If so, please provide details.
Ø Please provide any additional Australia-specific
aspects of PM measurement that you believe are important to the actions to
reduce airborne PM being considered in this Impact Statement.
See comments above:
Put most effort into monitoring & reducing the worst pollutants - Monitor
where pollution targets are likely to be exceeded
Chapter 3: Health effects and monetary costs of airborne PM
Ø Is there any any additional Australia-specific
information on the health effects or monetary costs of PM that should be
included? If so, please provide details.
Chapter 3 states: ‘Reducing
exposure to PM10 and PM2.5 in Sydney alone could save
around $5 billion per year.’ The fact
that this isn’t already being done is a testament to the failure of current
processes!
Chapter 4: Policy context and legislation
Ø
Have all aspects
of the current air quality management framework in Australia been adequately
described? If not, please provide further details.
Ø
Have any
significant regulatory developments, local or international, been overlooked?
Please provide information.
Ø What
are your views on the feasibility of an exposure-reduction framework for PM in Australia?
An exposure-reduction framework is perfectly feasible,
but it would be better to save $24 billion in health costs by implementing all
economically feasible measures as soon as possible. These measures are likely to substantially
reduce pollution and
achieve annual average PM2.5 of 6.0 μg/m3; daily max PM2.5:
20 μg/m3; annual average PM10: 20 μg/m3; daily max PM10:
40 μg/m3. The
exposure-reduction framework should therefore be implemented in the small
proportion of locations where the targets listed in this paragraph cannot be
achieved within 5 years
Chapter 5: Airborne
PM in Australia
Ø
Do you think
that any additional information on emissions and ambient PM concentrations in Australia
is required to inform the actions being considered for reducing airborne PM?
Ø Are there other issues that have not been considered
or have not been attributed sufficient weight in the discussion?
The cost of delays in reducing air pollution has not
been given sufficient weight. Not
implementing measures that could save 500 lives per year means that 1 or 2
additional unnecessary deaths for every day of delay in adopting the NEPM or
equivalent legislation.
Chapter 6: The
problem and the case for government intervention
Ø Do you agree that further government involvement is
required to address the potential future health impacts and costs of airborne
PM?
Yes. Is anyone
seriously suggesting that the $24 billion worth of health benefits from the
economically feasible measures would happen without legislation?
Chapter 7:
Statement of options
Ø
Do
you agree that the AAQ NEPM framework is an important element in the management
actions to address ambient air quality in Australia?
Ø
Have any options
for the metrics, averaging times, and values of the standards been overlooked?
Ø
Do you agree
that the metrics and values of PM standards selected for analysis are
appropriate for Australia?
Ø
Do you consider
the options outlined for the form of the standards to be feasible for Australia?
Have any options been overlooked?
Ø Is there any other information relating to the
options for an exposure-reduction framework that should be considered?
Yes. Is anyone
seriously suggesting that the $24 billion worth of health benefits from the
economically feasible measures would happen without legislation?
Chapter 8 Impact
analysis
Ø Have all health, environmental, economic and social
impacts of PM in Australia
been identified? If not, please provide reasons and suggestions for additional
analyses.
Ø Have all key assumptions been correctly identified
and included in the analysis? If not, please provide details.
No. The
economic analysis is deliberately conservative.
The benefits of reducing PM emissions are likely to be higher than the
estimates in the economic analysis, and omitted $15 billion worth of health
benefits from woodsmoke-reduction. There
is no reason to believe that a PM2.5 target of 6.0 μg/m3
(annual average) could not be achieved by implementing all economically
feasible measures.
Chapter 9:
Preferred options
Ø Do you agree with the introduction of an annual PM10
standard, given the apparent adverse health effects of coarse particles and
their prevalence in some regions?
Ø Do you support upgrading the current AAQ NEPM
advisory reporting standards for PM2.5 to compliance standards?
Ø Do you support the preferred numerical values for
new/revised 24-hour and annual PM2.5 and PM10 standards? Which
value for the 24-hour PM10 standard do you consider to be the most
appropriate, and why?
Ø What is your preferred option for the form of the
24-hour PM10 and PM2.5 standards? Should the options be
trialled?
Ø Do you have any comments regarding the possible
inclusion of PM metrics, other than PM10 and PM2.5, in
the future?
Ø Do you agree with the preferred form of the
exposure-reduction framework under which an exposure index based on monitoring
would be used to track population exposure for major urban areas?
The NEPM should include a PM2.5 target, but the
results discussed here indicate that it should be 6.0 μg/m3
(annual average). Similarly the daily
max should be 20 μg/m3.
Moreover, there is no reason why the NEPM shouldn’t have PM10 targets of
20 μg/m3 (annual average) and a daily max PM10: 40 μg/m3. The monitoring protocols should, however, not
require pollutants to be measured if there is little or no chance of the
requirements being exceeded. Protocols
should also require PM2.5 measurement in areas where the standards are
regularly exceeded, even if only a few hundred people are affected.
Sources of Additional Information
1. NSW OEH.
Economic Appraisal of Wood Smoke Control Measures: AECOM Australia Pty Ltd.
Prepared for the Office of Environment and Heritage. Available at:http://www.environment.nsw.gov.au/woodsmoke/smokecontrolopts.htm; 2011
2. Service de l’environnement. Environmental Assessment
Report. Air Quality in Montreal.:
Available at: http://ville.montreal.qc.ca/pls/portal/url/ITEM/FA74E517B58BC070E0430A930132C070; 2013
3. AAQG. Woodsmoke News. Australian Air Quality Group. Available at: woodsmoke.3sc.net/news; 2014.
Available from.
4. Gilmore H. State's top doctor says we should consider
banning wood fire heaters. Sydney Morning Herald Available at: http://wwwsmhcomau/nsw/states-top-doctor-says-we-should-consider-banning-wood-fire-heaters-20140705-zsx92html. 2014 July 5, 2014.
5. AAQG. The Most Effective Ways for Individuals to Reduce
their Global Warming. Australian Air Quality Group. Available at: http://woodsmoke.3sc.net/ghg; 2014. Available from.
6. Morgan G, Broome R, Jalaludin B. Summary for Policy Makers
of the Health Risk Assessment on Air Pollution in Australia. Prepared for:
National Environment Protection Council: University Centre for Rural Health,
North Coast, Education Research Workforce.
Available at: http://www.environment.gov.au/protection/nepc/nepms/ambient-air-quality/variation-2014/impact-statement; 2013
7. Kulkarni PBK. Economic analysis to inform the national plan
for clean air (particles): Pacific Environment and Marsden Jacob Associates on
behalf of the NEPC Service Corporation.
Available at: http://www.environment.gov.au/system/files/pages/dfe7ed5d-1eaf-4ff2-bfe7-dbb7ebaf21a9/files/nepc-economic-analysis-final-report.pdf; 2013
8. Keywood M, Guyes H, Selleck P, Gillett R. Quantification of
secondary organic aerosol in an Australian urban location. Environmental
Chemistry. 2011;8(2):115-26.
9. WHO. Review of evidence on health aspects of air pollution –
REVIHAAP Project. http://www.euro.who.int/__data/assets/pdf_file/0004/193108/REVIHAAP-Final-technical-report.pdf; 2013
10. Dockery DW, Pope CA, 3rd, Xu X, Spengler JD, Ware JH, Fay ME,
et al. An association between air pollution and mortality in six U.S. cities. N
Engl J Med. 1993;329(24):1753-9.
11. Schwartz J, Dockery D, Neas L. Is daily mortality associated
specifically with fine particles? J Air Waste Manag Assoc. 1996;46:927-39.
12. Aust N, Watkiss P, Boulter P, Bawden K. Methodology for
valuing the health impacts of changes in particle emissions – final report:
PAEHolmes for NSW Environment Protection Authority (EPA); 2013
13. Innis J, Bell A, Cox E, Cunningham A,
Hyde B, Smeal A. Car-based surveys of winter smoke concentrations in some
Tasmanian towns, 2010-2012: EPA Division, DPIPWE, 134Macquarie St, Hobart,
Tasmania. Available at: http://emobilise.com.au/files/programs/56/abstracts/10764.pdf; 2013
NEPC web survey
Public Meetings on the proposed New Air Quality (particle) standards - see below for dates.
Melbourne, 10 Sept, 5pm - 7pm, Level 4 Conference Room, EPA Victoria, 200 Victoria Street Carlton, 3053
Morwell, 11 Sept, 5pm - 7pm, Morwell Bowls Club, 52 Hazelwood Road, Morwell, 3840
Attendees should ask why $15 billion of economically-feasible measures to reduce particle emissions from woodsmoke were omitted from the NEPC economic analysis, and to confirm that including the highly cost-effective woodsmoke control options listed below would increase the value of the economically-feasible measures to $24 billion, and allow the target of 6 ug/m3 PM2.5 to be achieved.
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