Email Air.Policy@epa.nsw.gov.au by Friday, 20 Jan 2017.



Clean Air for NSW Consultation
 email Air.Policy@epa.nsw.gov.au by Friday, 20 January 2017.
The EPA would like the following info at the top of emailed submissions:
First name, Last name, Organisation (if applicable)
Email address, Phone number, Postcode
Or fill in their online form (scroll down to bottom of page).

Key points to include in submissions
    The most health-hazardous pollutant in our air (responsible for more premature deaths than any other pollutant) is PM2.5 pollution - fine particles less than 2.5 millionth of a meter that penetrate the deepest recesses of our lungs where they can enter the bloodstream and transport toxins to every organ of the body including the brain.

    Despite being used by less than 5% of households in Sydney as the main form of heating, the Clean Air for NSW Consultation paper shows that residential wood heating emits more PM2.5 in Sydney than any other human activity.  Yet the only proposal (apart from unspecified further research) is to adopt what is misleadingly called "updated Australian/NZ standards".  The NZ Government considers these 'standards' so polluting that they were abandoned in 2005 in all urban areas of NZ.  
   
    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.  When Launceston residents became aware of the health damage from woodsmoke, the vast majority chose to switch to non-polluting heating.  That successful woodsmoke program reduced wintertime deaths from respiratory disease by 28% and cardiovascular disease deaths by 20%. Year round, for men, the reductions were 23% (respiratory), 18% (cardiovascular) and 11.4% (all deaths). The focus was on explaining the health effects of woodsmoke pollution and replacing wood stoves with non-polluting heating.

   In all NSW climate zones, non polluting alternatives have lower running costs than buying firewood and cause less global warming.  Most people who understand the health damage from breathing woodsmoke, that there is no safe level of PM2.5 pollution, that new wood stoves typically emit more PM2.5 per year than 1000 passenger cars support the recommendation of NSW's top doctor. 

    The NSW EPA should therefore implement the NSW Chief Medical Officer's recommendation not to allow new wood heaters in urban areas, require existing wood heaters to be removed when houses are sold ensure that remaining wood heaters are phased out within 7 years.  The policy should include effective education programs to alert families to the health damage from woodsmoke pollution and the low cost of switching to non-polluting alternatives, protect residents who affected by other people's woodsmoke and provide financial assistance so that low-income families to switch to non-polluting heating.

Previous NSW Government Consultation – Woodsmoke Control Options

 

In June 2011, the NSW Government received a consultancy report it commissioned on the health & economic costs of woodsmoke pollution.  The report was kept secret until NSW Greens MP Cate Faehrman used FOI to release it.

 

It shows the average new woodheater is more polluting than several hundred new diesel SUV (sports utility vehicles) and has very large health costs – thousands of dollars per year. Woodsmoke contains many toxic and carcinogenic chemicals shown to cause genetic damage in babies and lead to reduced IQ and behavioural problems.  

 

New technology (e.g. sensor-controlled airflow and gas boosting if needed to ensure clean-burning temperatures) could dramatically reduce emissions.  NZ’s industry developed dozens of cleaner models in response to new standards set by the NZ Government in 2005.  As with diesel vehicles (whose emissions have been slashed by more than 99% over the past 20 years), the latest technology could result in clean wood heaters. 

 

Regrettably, the Australian wood heating industry put profits over health – it vetoed recommendations by the Australian Standards Committee (approved 15 votes to 4 in 2007) for reduced emissions.  After this veto, research to develop a new Aus/NZ wood heater standard and a new test reflecting real-life emissions was abandoned.

 

Government inaction allowed the problem to continue for many years.  However, the NSW Government is finally consulting councils and the community about what should be done – email woodsmoke.reduction@epa.nsw.gov.au by 14 Dec 2012 (though submissions submitted over the weekend will also be accepted).

 

If you have time, read the Briefing Woodsmoke_Discussion_paper_Nov2012 or info on the Urgent Need for a New Woodheater Standard and the submission from the community representative of Armidale Dumaresq Council's Domestic Education Committee.

 

If pressed for time, please consider a short submission to woodsmoke.reduction@epa.nsw.gov.au noting the following:

·     Allowing new heaters that emit even 20 times as much pollution as the health-based standard for a SUV (0.1 kg per year) should not be considered acceptable, let alone the 100 to 400 times more pollution of models currently on sale in Australia.  Current models rated 1 g/kg have real-life emissions of 13 kg of PM2.5  - 133 time as much as a new SUV (Sydney) or 280 (colder areas).  The installation of new log-burning heaters should not therefore be allowed until a new test reflecting real-life emissions has been developed that can guarantee new heaters are no more polluting than 20 diesel SUVs that satisfy the health-based standard for diesels.

·     NSW Greens policy (http://nsw.greens.org.au/sites/greens.org.au/files/policydownloads/Air%20Quality_1.pdf ) - requires a moratorium on the installation of new wood heaters (except pellet heaters) until a new health-based standard has been developed.  The NSW Consultancy report estimated that this would save $2,206 million in health costs for an outlay of just $134 million.

·     The NSW Consultancy report also noted that the most cost effective option for existing wood heaters (except pellet heaters, or ones that meet a yet-to-be-developed health-based standard) is to require their removal when houses are offered for sale.  This is estimated to save $4,015 million in NSW for an outlay of just $36 million

·     ‘Compromise’ solutions, e.g. requiring new heaters emit less than 1 g/kg according to the current test should not be considered acceptable, because the current test does not reflect real-life emissions.  The NSW Consultancy report estimated that a new heater rated 1 g/kg will have real-life emissions of 6.4 g/kg (as much as 133 diesel SUV in Sydney and 280 in colder areas) and annual health costs of $3167 in Sydney and $1562 per year in colder rural areas.  This is not sensible!!!

·     A possible exception might be the replacement of existing highly polluting heaters with ones rated less than 1 g/kg as an interim measure until a new health-based standard has been developed.

·     The Australian wood heating industry’s actions (vetoing the recommendations of the Australian Standards Committee), which led to the abandoning of research to develop a new test reflecting real-life emissions) must be strongly condemned.

·     The actions of the Australian wood heating industry representatives, the AHHA, should also be condemned, especially the way they mislead consumers about the level of emissions from new wood heaters and (in the light of evidence that Australia does not have a sustainable firewood supply, and the recommendations of the UN Environment program that developed countries should phase out log-burning heaters to reduce global warming as well as improve health - see http://woodsmoke.3sc.net/greenhouse ) the effect of Australian log-burning heaters on global warming

·     Governments should not put profits of any industry – tobacco, asbestos, vehicles or wood heating – before public health.

 

Please also consider ccing a copy of your email to airqual@3sc.net

Edit text in the form below & click 'Submit' for a quick submission
For small screens, click this link for a single column version of the form.

New heaters are almost as polluting as older models 
The photo below shows that the new "standard" of 2.5 g/kg, introduced in NSW in November 2016, provides little or no protection for downwind neighbours.  The table below shows estimates of real-life emission from the Briefing _paper, annual health costs for a heater installed in Sydney and colder rural areas and the number of Diesel SUV required to produce the same amount of emissions per year.
These numbers may under-estimate the amount of pollution.  For 5 heaters tested in Christchurch, NZ, with average lab-test ratings of 0.82 g/kg, real-life emissions averaged 9.8 g/kg, suggesting that many new heaters satisfying the "standard "will be just as polluting as older ones. 
 


Sydney

Colder rural area

 

Lab-test
per kg

Real-life
per kg

Real-life
per year

Health Cost
per year

Diesel SUV

Real-life
per year

Health Cost
per year

Diesel SUV

4 g/kg

9.8 g/kg

18.6 kg

$4436

186

39.2 kg

$2188

392

2.5 g/kg

8.2 g/kg

15.6 kg

$3706

156

32.8 kg

$1828

328

2 g/kg

7.0 g/kg

14.4 kg

$3420

144

30.2 kg

$1687

302

1 g/kg

6.4 g/kg

13.3 kg

$3167

133

28.0 kg

$1562

280

Source: 
AECOM Office of Environment & Heritage: Economic Appraisal of Wood Smoke Control Measures - Final Report, 29 29 June 2011.  Emissions by lab test rating, table 15 (9.8 g/kg for limit of 4 g/kg); table 18 (reductions of 10%, 22.9%, 28.6% and 34.3% for ratings of 3, 2 and 1 g/kg respectively).  Table 24 - estimated Health costs for capital cities ($235.26/kg PM2.5) and rural areas $55.82/kg PM2.5).  Estimates are based on assumes average firewood consumption of 1.9 tonnes per year in Sydney and 4 tonnes per year (the average for Armidale, NSW and Canberra) in a cold rural areas.

 
The Australian Wood Heating industry calls this level of pollution "clean and environmentally friendly", despite the fact that the estimated health effects in Sydney of a heater rated 2.5 g/kg are $3,000 to $4,000 per year.  Moreover, the UN Environment Program is so concerned about global warming from methane and black carbon emissions from domestic wood heaters that it recommends phasing out log-burning heaters in developed countries. 

NSW Economic Analysis and Dicussion paper provide estimates of the costs and benefits of variatious woodsmoke control option, shown in the table below.  People and organisations who care about their health, should strongly support all options with large health benefits for minimal cost.
 
Table. Estimated health benefits and costs of woodsmoke control options in NSW
 

 

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: Economic Appraisal of Wood Smoke Control Measures - Final Report, 29 June 2011
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