Pittwater

Pittwater council to allow new heaters with real-life emissions of 6.7 grams PM2.5 per kilogram of firewood and estimated health costs of $6,000 per year
At the meeting of 18 March 2015, Councillors Young and Griffith (who both own old wood-burning heaters) proposed a motion to allow new wood heaters only on the Scotland Island and the Western foreshore, but it was defeated.  Councillors Ferguson (owner of a wood-heaters), Hegarty (owner of 2 wood-heaters), White (uses solid-fuel stove for home heating), McTaggart (has a fireplace using wood smoke), Grace, Millar and Townsend  all voted for the recommendation to allow new heaters, with all those installed after 1 September 2016 to have nominal emissions less than 1.5 g/kg (see footnote to Table 1, right) estimated real-life emissions of about 6.7 grams per kg firewood and health costs of many thousands of dollars per year.

Misplaced faith in an Australian 'standard'

Comments made in Pittwater Council’s briefing document on its Woodsmoke Policy suggest that their officials believe that the current standard has been endorsed by the NSW EPA.

 As shown by the comments below, none of the submissions supported the status quo.  The vast majority formally supported a ban on new installations.  The others made comments such “Policy to make it clear that solid fuel burning fires, heaters or stoves emit toxic pollutants that are injurious to human health” and “Wood smoke fireplaces are a very selfish form of heating, you get all the heat, the neighbourhood gets all the pollution” implying that not allowing new installations would be a desirable outcome.

In response to the above submissions, Pittwater Council’s briefing paper states:
"The recommendations of this report will take Council to the forefront of imposing greater wood smoke related controls which align with NSW EPA efficiency and emission targets.
"The NSW EPA does not legislate a ban on solid fuel wood heating appliances.
"The Australian Standards are accepted by the NSW EPA as the appropriate form of measuring wood smoke emissions and efficiency controls.

Table 1 (right hand column) shows that a brand new wood heater with a lab test rating of 1.5 g/kg is expected to have average real-life emissions of 6.7 g/kg.  If installed in Sydney, expected annual health costs are $3,524 if it burns 2 tonnes per year, or $6,060 if burning 3.43 tonnes (average wood use in Sydney according to the Commonwealth's wood heater consultation RIS).

The NSW EPA should comment on whether it formally endorses a 'standard' that could lead to the installation of new heaters imposing health costs of more than $3,000 per heater per year on the rest of the community.

 Brief Summary of the 14 submissions received

No new houses should be built with chimneys and wood fires should be eventually phased out altogether.
2 Replace residents' wood heaters with gas heaters, once and for all.
3 It is unclear how the policy will achieve its objectives. It falls well short of providing solutions that are not already available to council in existing legislation, standards and policies… Policy to make it clear that solid fuel burning fires, heaters or stoves emit toxic pollutants that are injurious to human health.
4 Seek a ban on the installation/use of solid fuel heaters in urban built up areas.
5 Would you please advise what legal loophole permits Councils to continue to approve wood heaters despite the serious consequences on the health and lifestyle of so many innocent victims of this major public health hazard.
Wood smoke fireplaces are a very selfish form of heating, you get all the heat, the neighbourhood gets all the pollution.
Ban totally the use of all solid fuels for burning fires in urban areas over a period of time, ie over the next four years.
8 Following the mail-out of brochures with rate notices last May (2014), I continued to observe the same smoking chimneys throughout winter. Continued effort to attract public attention will be required and I urge Council to persevere with this aim in the interests of public health and long – term environmental benefit.
Chimneys within a 50m radius of windows or open living space such as a veranda, carport or similar habitable structure, shall have a height of no less that 2m above the eaves of the house.
10 Recommend: (i) not allowing new wood heaters to be installed. (ii) phasing out of older models in urban areas. (iii) requiring existing heaters to be removed before houses are sold. (iv) annual licence fees to fund education programs and assist neighbours whose health or lifestyle is adversely affected by other people’s wood smoke.
11 Council should ban new woodstove installations and phase out existing installed wood burners.
12 Ban new installations of wood heaters so that the problem does not keep perpetrating itself.
13 In many ways, wood smoke is worse than cigarette smoke not just because of its greater toxicity but because the damage is inflicted not on the user but over a wide range of people in the neighbourhood who have absolutely no control over it.
14 Council should impose its own stricter standard locally, to effect that no new wood heaters can be installed


Comments by on Pittwater Council's Proposed Wood Smoke Reduction Policy
by the Australian Air Quality Group
Contact Officer: Robina Bramich (Principal Environmental Health Officer)
emailed to pittwater_council@pittwater.nsw.gov.au on 27/2/2015
SUMMARY
   Pittwater Council has a responsibility be guided by the recommendation on health experts.  The NSW Chief Medical Officer, the Australian Lung Foundation, the NSW Asthma Foundation and the UN Environment Program/World Meteorological Association all recommend not allowing new wood heaters to be installed.

   Few people know or understand the health effects of woodsmoke, e.g. that air pollution from wood fire heaters is said to pose a bigger immediate health danger to Sydneysiders than cars or cigarettes, that the NSW Chief Medical Officer recommended banning new woodheaters and phasing out older models in urban areas, that PM2.5 pollution has been described as the new asbestos, and that the NSW Emissions inventory shows than more than half of year-round PM2.5 emissions in Sydney now come from wood heaters, despite only 4.3% of households using wood as the main form of heating in 2008.

   A consultancy report commissioned by the NSW Government noted that wood smoke is an $8 billion health problem in NSW but that a 75% reduction could be achieved by:
1) not allowing new heaters to be installed;
2) requiring existing heaters to be removed when houses are sold and
3) annual licencing fees for wood heaters, which could also provide funds for education and assistance to residents whose health or lifestyle is adversely affected by other people's wood smoke. 

   The AS/NZS 4013 test does not reflect real-life emissions.  It was set by a Committee with no formal representation by health experts, under threat that the wood heating industry could veto any changes that might adversely affect their profits.  Most people would consider any benefits of wood heaters to be far less than the estimated health costs of a new heater installed in Sydney under Pittwater Council's proposed policy: $4,897 per year (until August 2015 ), $4,091 per year (from August 2015-2019) and $3,357 (from August 2019). 
 
   If people had no idea about the health problems it causes, 
as is the case for wood smoke, many people might have supported the continued use of asbestos-containing fibro cement.  Wood heater smoke, along with other PM2.5, has been described as the "new asbestos".  Until a new wood heater standard has been developed by independent health experts, Pittwater Council should therefore follow the recommendation of health experts, and the example of Waverley and Holroyd councils and the Oran Park and Turner Rd growth precincts, and not allow new wood heaters to be installed.  Council should also consider the two other highly cost-effective policies that, according to the NSW Government report, along with not allowing new heaters to be installed could reduce the $8 billion health costs of wood heaters in NSW by 75%.

DETAILS
NSW Chief Medical Officer recommended banning new wood heaters and phasing out older ones
Last year, the 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 as an option to control wood smoke.  This recommendation applies to all wood heaters, not just older models. http://www.smh.com.au/nsw/states-top-doctor-says-we-should-consider-banning-wood-fire-heaters-20140705-zsx92.html
The reason for this is discussed in the attached peer-reviewed paper.  With average firewood consumption of about 2 tonnes/year, the average brand new wood-heater emits about 20 kg PM2.5 and has estimated health costs (using the NEPC economic analysis estimate of $280/kg for PM2.5 emissions in Sydney, or the estimate of $263/kg from the Federal Government's wood heater consultation RIS - see below) of more than $5,000 per year.

Current AS/NZS 4013-2014 set by the wood heating industry not independent health experts
peer-reviewed paper explains that development of a new emissions test to better reflect real-life emissions was abandoned in 2007 after the wood heating industry vetoed recommendations by the majority of the Standards Australia Committee CS-062 to halve the emissions limit as an interim measure while a new test was being developed, and also to seek advice from health authorities about a suitable health warning to remind operators that woodsmoke is harmful and the importance of operating heaters correctly (Australian Senate 2013). When reconvened in 2013 with fewer community representatives and no health experts, CS-062 approved a revision based on the existing test, with limits of 2.5 g/kg from August 2015 and 1.5 g/kg in 2019.  Given the threat of no progress at all if the wood heating industry were again to veto changes, these limits bear no relation to an adequate or acceptable health-based standard for new wood heaters.

Real-life emissions from new heaters installed in a new housing estate in Armidale, NSW are shown in Figure 5 of the peer-reviewed paper.  All except the top left smoke plume are from heaters installed in new houses after Council required them to have emissions ratings of 2.5 g/kg or less - i.e. meet the standard that will be required under Pittwater's proposed policy. The level of emissions shown was evident for nearly 1 hour (middle photo) and about 10 hours for the heater installed in August 2014, after an application to Council and provision of all appropriate education material (bottom photo). 

Estimated health costs of Pittwater's new wood heaters - more than $4,000 per heater per year until 2019.
Table A3.2 (above, click to enlarge) from The Federal Government's Consultation Regulation Impact Statement (CRIS) reported that the estimated health costs amounts to $263 for every kg of PM2.5 emitted in a major capital city such as Sydney.  The NSW Government's Economic Appraisal of Wood Smoke Control Measures indicates that and Australian wood heater rated < 2.5 g/kg has real-life emissions of 8.2 g/kg, one rated < 1.5 g/kg has real-life emissions of 6.7 g/kg and one rated < 4 g/kg (the current standard until August 2015) has real-life emissions of 9.8 g/kg.  
Based on average firewood consumption in Sydney of 1.9 tonnes per year, the estimated health costs of a new wood heater installed in Pittwater satisfying AS/NZS 4013-2014 will be:
$4,897 per year (until August 2015 )
$4,091 per year (from August 2015 when the emissions limit reduces from 4 g/kg to 2.5 g/kg)
$3,357 per year (from August 2019 when the emissions limit reduces to 1.5 g/kg
).

NSW Asthma Foundation recommends not allowing new heaters to be installed, removing existing ones when houses are sold and licencing fees to cover the cost of wood smoke reduction programs
The NSW Asthma Foundation made three key recommendations that together would reduce wood smoke health costs by 75 per cent.  
1) Removal of existing heaters that do not meet a health-based standard when houses are offered for sale. (Health Benefit $4,016m, Cost $36m, Net Benefit $3,978m)
2) Not allowing the installation of new heaters that do not meet a health-based standard. 
3) Licensing fees to cover the cost of wood smoke-reduction programs with assistance for people whose health or lifestyle has been affected by wood smoke.(Health Benefit $1,267m, Cost +$11m, Net Benefit $1,278m)
“These are not outlandish ideas, but measures supported the Government’s own costings. Together these measures could significantly reduce air pollution and improve public health for a very modest cost,” Ms Goldman said.
 “These new standards still fall short and will have little effect on the massive air pollution and health problems it causes.”
http://www.asthmaaustralia.org.au/MR/NSW/New-Australian-Wood-Heater-Standard-Decade-Behind.aspx
Note that the revised AS/NZS 4013-2014 is not a health-based standard - there were no health experts on the Committee all too aware of the potential threat of a veto by the wood heating industry if the proposals were likely to affect their profitability. 

Three simple measures could reduce $8 billion health costs of wood smoke in NSW by 75%

 

 

 

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: EconomicAppraisal of Wood Smoke Control Measures  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).

Several Sydney Councils do not permit new wood heaters to be installed
Waverley and Holroyd do not permit new wood heaters to be installed, with others requiring non-polluting heating in new developments, e.g. Manooka Valley, Oran Park and Turner Road Growth Precincts. In Canbera, woodheaters are not permitted in the new residential suburbs of the Molonglo Valley because of air quality

The Australian Lung Foundation (ALF) recommends:use alternative methods (instead of wood heaters) for climate control, including insulating and improving the energy efficiency of homes, flued gas and electric heaters and energy efficient house design” http://lungfoundation.com.au/wp-content/uploads/2012/06/Woodsmoke-The-Burning-Issue.pdf

Proposed policy lacks details about the resolve complaints when residents' health or lifestyle are affected by a neighbour's wood smoke emissions
Although the policy says it "aims to provide a consistent and effective framework to assist in the assessment and determination of installations and complaints regarding domestic solid fuel burning appliances"  it is not clear how this is to be achieved.  How does Council plan to manage the situation where the health of an asthmatic child or elderly resident is damaged when a neighbour installs a new heater?  What is being done to resolve existing complaints where residents' health or lifestyle are being affected by a neighbour's wood smoke emissions?
  The draft policy does not even say whether neighbours will be consulted before the installation of new wood heaters is approved.  The smell of smoke from a new heater rated < 2.5 g/kg is often noted more than 500 metres downwind of the chimney, so the best practice would require consultation of all occupants of houses within 200 to 500 metres of the new chimney.

Pittwater's consultation inadequate because of the inadequacy of the background information
The background information to this policy is inadequate.  Most people have no idea that, although emissions standards for motor vehicles are set by the Australian Government, those for wood heaters were set under threat of a veto by the wood heating industry. Consequently, emissions of the average wood stove in Sydney (about 20 kg per year) are as bad as 1,000 passenger cars (about 20 grams per year, http://woodsmoke.3sc.net/cleancarbenefits )   How many people know that NSW Chief Medical Officer Kerry Chant said wood heaters are so detrimental to health she supported banning and phasing them out in built-up urban areas?  How many people know that the UN Environment Program and the World Meteorological Organization (UNEP/WMO) recommended phasing out log-burning heaters in developed countries to reduce global warming as well as improve health - http://woodsmoke.3sc.net/ghg  How many people know that the health cost of new wood heater installed under Council's proposed policy is estimated to lie between $5,000 and $3,300 per year?
If people know and understood these facts, would their responses be different?    Here are some examples of effective health messages used elsewhere

What would be the choice of responsible people who know all the facts?
Council should base their decisions on the recommendation on health experts such as the NSW Chief Medical Officer, the Australian Lung Foundation, the NSW Asthma Foundation and the UN Environment Program/World Meteorological Association.  It is really unfortunate too few people know and understand the health effects of woodsmoke or how wood heater pollution compares with other sources of PM2.5 emissions. Some information about policies and public information campaigns is available at: http://woodsmoke.3sc.net/policies-elsewhere
In the absence of appropriate information about asbestos-containing fibro cement, most people would probably have said that its use should continue.  However, it would have been an expensive mistake not to take steps to protect public health.  The same applies to wood heater smoke, which has been described as the "new asbestos"  because air pollution from wood fire heaters now poses a bigger immediate health danger to Sydneysiders than cars or cigarettes - http://www.smh.com.au/nsw/wood-fire-heaters-the-hidden-killer-20140628-zsop8.html

Utah Physicians for a Healthy Environment give 17 reasons to ban wood burning:
1. All pollution is not created equal. Wood smoke is the most toxic type of pollution in most cities, more dangerous than auto pollution and most industrial pollution. Lighting a wood fire in your house is like starting up your own toxic incinerator.
2. Lifetime cancer risk is 12 times greater for wood smoke compared to an equal volume of second hand cigarette smoke.
3. Burning 10 lbs. of wood for one hour, releases as much PAHs (polycyclic aromatic hydrocarbons) as 6,000 packs of cigarettes.
4. Toxic free-radical chemicals in wood smoke are biologically active 40 times longer than the free radicals in cigarette smoke.
5. Wood smoke is the third largest source of dioxins, one of the most intensely toxic compounds known to science.
6. The very small size of wood particles make them seven times more likely to be inhaled than other particulate pollution.
7. Wood smoke easily penetrates homes of neighbors creating concentrations up to 88% as high as outdoor air.
8. If you smell wood smoke, you know you are being harmed. The sweet smell comes from deadly compounds like benzene.
9. The most dangerous components of air pollution are much higher inside homes that burn wood compared to those that don’t, as much as 500% higher.
10. Considering the most dangerous part of particulate pollution, wood burning produces as much overall as all our cars during the winter.
11. The inhalable particulate pollution from one woodstove is equivalent to the amount emitted from 3,000 gas furnaces producing the same amount of heat.
12. Emissions from modern combustion appliances for wood logs may increase ten-fold if they are not operated appropriately, and most of them are not.
13. Wood smoke is the only pollution emitted right where people spend most of their time. It disperses poorly, is not evenly distributed and stays in the air longer because of its small size. Concentrations can be 100 times higher for neighbors of wood burners than what is captured at the nearest monitoring station. Real local “pollution victims” are created even when overall community levels are low.
14. If your neighbor is a regular wood burner, and follows all the rules, i.e. doesn’t burn during yellow or red alert days, but does during all “green” days, you can go an entire winter without having one single day of clean air. This is a civil rights issue.
15. According to California’s Bay Area Air Quality Management District, burning wood costs the rest of the community, primarily your next door neighbors, at least $2 in extra medical expenses for every lb of wood that you burn. An average fire then costs your neighbors about $40.
16. Long ago most communities passed ordinances protecting people from second hand cigarette smoke. Ironically those laws protect people at places they don’t necessarily have to be (restaurants, stores, buildings, etc). But in the one place they have to be, their own home, they have no protection from something even worse-wood smoke. People should have just as much protection from wood smoke as from cigarette smoke and for all the same reasons. We don’t allow people to blow cigarette smoke in your face, why should we allow people to blow wood smoke into your home?
17. Wood burning is not even close to carbon neutral over the short term, the next few decades, and it is that time frame that will make or break the climate crisis. Burning wood is extremely in inefficient. Per unit of heat created wood produces even more CO2 than the fossil fuels do. Furthermore, the black carbon particulate matter released enhances the absorption of radiant heat in the atmosphere, making global warming worse, and prematurely melts already imperiled mountain snow pack. 

Health Cost of a New Wood Heater

As shown in Table 1, real-life emissions of wood-heaters rated 1.5 g/kg (the ‘standard’ to apply in Australia after August 2019) will average 6.7 g/kg, resulting in estimated health costs of more than $3,000 per year in Wagga Wagga and more than $5,000 per year in other capital cities.  Health costs of a new wood heater rated 2.5 g/kg (the ‘standard’ to apply in Australia from August 2015 to August 2015) are even higher.

Table 1. Estimated annual cost of heating per household (selected locations) and estimated health costs compared to the cost of alternative heating (an efficient reverse cycle heat pump).

 

 Firewood Price ($/tonne)a

Wood use  tonnesa

Annual wood heating costa

Annual health costsb New wood heater rated

Annual cost: whole-house heating with efficient heat pump

2.5 g/kg

1.5 g/kg

Tasmania

$150

10.28

$1,540

NA

NA

$500 - $700

Sydney

$380

3.43

$1,300

$7,386

$6,060

$150 - $300

Wagga

$180

4.08

$730

$3,775

$3,097

$300 - $600

Melbourne

$300

3.75

$1,130

$8,075

$6,626

$150 - $300

Perth

$270

3.09

$830

$6,654

$5,459

$150 - $300

Price, wood use and annual wood heating costs from Table 2.2 of the consultation RIS (CRIS)  http://www.scew.gov.au/strategic-priorities/clean-air-plan/woodheaters/index.html  bAnnual Health costs based on CRIS Table 3.2  – $263,000 per tonne in capital cities and $113,000 per tonne in Wagga. Real-life emissions calculated from Table 18, of the NSW OEH economic appraisal of wood heater control options. A: wood heaters rated < 2.5  g/kg have real life emissions = 8.2 g/kg;  B: heaters rated < 1.5 g/kg have real life emissions = 6.7 g/kg).1
Efficient heat pumps in Sydney, Melbourne and Perth average 10 units of heat to a home for every unit of electricity used.2  The most efficient model delivers 6 times as much heat to the home as the electric energy used, at an outside temperature of  6 degrees centigrade, and 4.5 times as much when the outdoor temperature is a freezing cold 10 degrees below zero ( ‑10 
C).

Increases of 2 ug/m3 PM2.5 exposure have now been shown to decrease brain volume of people over 60 by 0.32% and increase the risk of silent stroke by 46%.  One in six people in Australia will be affected by stroke. It is the nation’s leading cause of disability. Living downwind of an Australian wood heater (new or old) can easily increase annual PM2.5 exposure by more than 2 ug/m3.

Given the availability of affordable alternatives, such as heater-air-conditioners that can deliver 6 times as much heat to the home as the electric energy used, when the outside temperature is above 6 degrees centigrade, and 4.5 times as much when the outdoor temperature is a freezing cold 10 degrees below zero (‑10°C), is it acceptable to install new wood heaters in urban areas that are likely to increase the risk of silent stroke by 46% for the downwind neighbour?

Is it acceptable to permit the installation of new wood heaters that are expected increaser annual health costs (as shown in Table 1) by over $3,000 per heater per year?  Or do regulators agree with the opinions of the health experts listed in Note 1 below, including NSW Chief Medical Officer Kerry Chant that wood heaters are so detrimental to health she supports banning and phasing them out in built-up urban areas?

 

Note 1 – Opinions of Health Experts
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 areasThe NSW Asthma Foundation warned that: wood smoke emissions in winter pose a bigger health danger in built up urban areas than cars or cigarettesAustralian Lung Foundation spokesman Dr James Markos said wood fire heaters should be banned from urban areas. He said real-life emissions from new wood-heaters have little relationship to measurements from a perfectly operated test model under laboratory conditions. The UN Environment Program/World Meteorological Organization (UNEP/WMO)recommended phasing out log-burning heaters in developed countries to reduce global warming as well as improve health.  56% of submissions to the Commonwealth Government's Woodheater Consultation Regulation Impact Statement supported either a ban on all wood heaters, or not allowing new ones to be installed.

Emissions of a new wood heater

A consultancy report for the NSW Government estimated that a new wood heater rated 2.5 g/kg has real-life emissions of 8.2 grams per kg firewood burned and one rated (g/kg) 1.5 g/kg has real-life emissions of 6.7 g/kg, implying that a heater rated 1.5 g/kg burning 1.9 tonnes per year will emit 12.8 kg PM2.5 and one burning 3.43 tonnes per year will emit 23 kg PM2.5 per year.

Area polluted by a new wood-heater rated 1.5 g/kg in 3 hours

As noted above, real-life emissions of 6.7 g/kg imply emissions of 20 grams in 3 hours. This is more than the average passenger car emits in an entire year.  20 grams is enough to increase PM2.5 to by 2 ug/m3 over a square kilometre to a height of 10 metres.  The greatest increases will be for neighbours living downwind of the new heater, who are likely to be exposed to PM2.5 levels many times higher than the average for the square kilometre surrounding the chimney.  A single new heater can easily increase annual PM2.5 exposure of the downwind neighbour by more than 2 ug/m3.

Sources of information on health costs

1.         NSW OEH, Economic Appraisal of Wood Smoke Control Measures, 2011, AECOM Australia Pty Ltd. Prepared for the Office of Environment and Heritage.  Available at: http://www.epa.nsw.gov.au/woodsmoke/smokecontrolopts.htm.

2.         Wright, M., Why I have six air conditioners, in Climate Spectator.http://www.businessspectator.com.au/article/2011/10/5/smart-energy/why-i-have-six-air-conditioners (accessed 13 March 2012)2011.

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