NSW Consultation - woodsmoke

Email submissions on the NSW EPA consultation to:  woodsmoke.reduction@epa.nsw.gov.au by 5 pm Friday 15 May 2015

Detailed information for NSW EPA Consultation:
Amendments to the Protection of the Environment Operations (Clean Air) Regulation 2010.  

Default should be not to allow new wood heaters, unless councils decide otherwise

Health experts advise that current wood heater models are too polluting to be allowed. 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. The NSW Asthma Foundation warned that: wood smoke emissions in winter pose a bigger health danger in built up urban areas than cars or cigarettes. Australian 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.

No safe level of PM2.5 pollution – 25 ug/m3 equates to smoking 3 cigarettes/day. Health authorities warn there is no safe level of PM2.5 pollution.  Medical doctor & epidemiologist at the University of Newcastle, Dr Ben Ewald, told the Senate Inquiry into air pollution and health that exposure at the current advisory limit of 25 ug/m3 has equivalent mortality risks to actively smoking 3 cigarettes a day.  The recent consultation on particle standards showed overwhelming support for a reduction to 20 ug/m3 PM2.5. Woodsmoke was described as worse than car exhausts.

The American Heart Association explains: “Fine particulate matter affects more people than any other pollutant, with chronic exposure causing the most deaths from serious disease”.

PM2.5 linked to heart attacks, strokes, cancers, lung diseases & affects babies and children at levels well below 25 ug/m3.  Woodsmoke-affected towns such as Armidale have many days above the current limit of 25 ug/m3, let alone 20 ug/m3.  Few people in Armidale realise that the entire city often suffers air pollution levels worse than everyone smoking 3 cigarettes a day, or than in Canada, woodsmoke levels of just 6 to 10 ug/m3 were found to increase the risk of chronic obstructive pulmonary and adversely affect blood vessel health, indicating increased risk of heart disease.  There is limited awareness that, as well as increased risk of heart attacks, strokes, cancers and lung diseases, toxic chemicals in woodsmoke known as PAH have been linked to genetic damage in babies and reduced IQ when children start school.  Similar problems have been noted in developing countries, where children whose mothers cook with wood (as opposed to kerosene) have reduced IQ, memory and poorer social skills. An Australian study linked using a closed wood heater to childhood brain tumours; another found that wood stove use increased the risk of acute lymphoblastic leukaemia in childhood

Increased exposure of just 2 ug/m3 PM2.5 increases the risk of silent stroke by 46% and decreases brain volume by 0.32%.  A study published in the American Heart Association journal, Stroke, found that an increase in PM2.5 exposure for people over 60 of just 2 μg/m3 was associated with a 0.32% smaller total cerebral brain volume and a 46% higher risk of covert brain infarcts, a type of silent stroke. One in six people in Australia will be affected by stroke. It is the nation’s leading cause of disabilityLiving downwind of an Australian wood heater (new or old) will often increase annual PM2.5 exposure by more than 2 ug/m3.

A peer-reviewed study of spatial variability of PM2.5 pollution in Armidale concluded that wood heaters increased annual population exposure to PM2.5 pollution by about 11.5 ug/m 3, implying that residents will suffer 2.6 times as many covert brain infarcts as they would if the city had no woodsmoke pollution.  PM2.5 concentrations were highest in residential areas (rather than in the CBD, where the PM2.5 is measured by the local council).

1 day's heating = 120,000 cigarettes.  Wood smoke was found to cause 12 to 30 times as many tumours in mice and mutations in bacteria as the same amount of cigarette smokeA single wood heater chimney burning 20 kg wood (a day's heat) emits about 200 grams of PM2.5, as much as in the smoke from 10,000 cigarettes, with the tumour potency of at least 120,000 cigarettes.

2 hours wood-heating = 1 year of driving.  Woodsmoke PM2.5 was described as worse than car exhausts.  The average new wood-heater emits l car emits about 20 grams of PM2.5 in 2 hours, as much as the average petrol car emits in an entire year.

Links to autism. Prof Frank Kelly, director of the environmental research group at King's College London, discussed the research linking PM2.5 pollution to autism: "I think if it was this study by itself I wouldn't take much notice, but it's now the fifth that has come to the same conclusion”.

Need health-based wood heater standard. Our society has cracked down on passive smoking. It's now illegal for spectators to smoke at outdoor sports events. Yet a single wood heater chimney burning 10 kg wood (an evening's heat) emits about 100 grams of PM2.5, as much as in the smoke from 5,000 cigarettes, and has tumour potency of at least 50,000 cigarettes - wood smoke was found to cause 12 to 30 times as many tumours in mice and mutations in bacteria as the same amount of cigarette smoke.

It is now time to take account of the recommendations of health authorities such as the Chief Medical Officer, and the lack of a health-based standard for new wood heaters. Standards Australia's protocols allow industry to veto proposed changesA new emissions test was under development in 2007 until the wood heating industry vetoed recommendations approved by 15 votes to 4 by the previous Standards Australia committee to set an interim limit of 2 g/kg and require wood heaters to display warnings to alert users to the dangers of breathing woodsmoke.  Work on the new test was abandoned after the veto in 2007.  A new committee with no health nor epidemiological experts was formed in 2013 at the request of the wood heating industry.  Unsurprisingly (given the industry veto), the revision required only minimal changes - the emissions limit will be reduced to 2.5 g/kg from August 2015. 

The photos show emissions from brand new heaters in brand new houses in Armidale.  The newest installation (August 2014) was noted to have emitted smoke continuously at the level shown for over 10 hours, despite Armidale Council’s education policy and requirement for new heaters to be rated less than 2.5 g/kg.  All except the top left chimney have ratings known to be less than 2.5 g/kg.  Reducing the limit on a test that does not measure real-life emissions does not appear to be effective.  In New Zealand, several small towns, e.g. Alexandra (pop 4824), Arrowtown (pop 2400), Clyde (pop 900), Cromwell (pop 4896) have virtually no other sources of air pollution apart from wood-heaters. These towns reduced the limit for new heaters to 0.7 g/kg and required those with AS4013 ratings over 1.5 g/kg to be removed by January 2012. Despite this, the four towns had respectively 42, 24, 7 and 29 exceedances of the 50 mg/m3 limit in 2012.

Education programs have little effect on emissions from existing heaters.  Launceston's $2.05 million education and wood-heater replacement program did not solve their problem of emissions from new heaters.  Real-life emissions from AS4103 heaters operated by motivated volunteers (observed in several cases to refuel the heater in the middle of the night, rather than leave it to smoulder) averaged 9.4 g/kg.  This suggests that the best that can be expected from a new heater burning 3 tonnes of wood per year is about 30 kg PM2.5, similar to annual PM2.5 emissions from 2,000 petrol cars each driving 15,000 km per year in the city.

Armidale Dumaresq council’s submission to the Federal Government in 2013 on wood-heater regulation states: “It is estimated that Council has committed more than $300,000 (excluding wages) in the past 10 years on wood smoke abatement measures”. Despite this, over the last 3 years (2012-14) PM2.5 from May to August averaged 14.9 ug/m3 at the CBD, compared to 13.9 ug/m3 for June to August in 1999. 

Industry-set “standards” are meaningless.  Allowing the wood heating industry to set standards makes no more sense than allowing the tobacco companies to set policy on cigarettes.  New standards for vehicles (set by the Federal Government) reduced PM2.5 emissions from diesel cars and SUV by more than 99%Councils should therefore insist on a new wood heater standard, set by independent health experts, before any more heaters are installed. History shows that when new standards are set, industry soon develops less polluting models.

UN Environment Program recommends phasing out log-burning heaters to reduce global warming. This option is best for health and, as the UN Environment Program/World Meteorological Organisation advises, also helps limit global warming to 2 degrees.  On low burn, enclosed wood heaters emit substantial quantities of methane, carbon monoxide, black carbon and ozone precursors.  Over the critical period between now and when the 2 degree target is likely to be exceeded, the average house using wood heating is likely to cause about 10 times as much global warming as one using an efficient electric heat pump. 

New houses have clean, cost-effective alternatives.  Thanks to State Government regulations, new houses must have insulation and, thanks to Federal Government Minimum Energy Performance Standards (MEPS), the average new heat pump is about twice as efficient as 10 years ago.  Data provided by one manufacturer shows that even when the outdoor temperature is minus five degrees and the desired indoor temperature is 20 degrees, one of their units can deliver more than 4 kW of heat to the house while using only 1 kW of electricity.  At milder outdoor temperatures (e.g. 6 degrees), even less electricity is needed - the Coefficient of Performance increases to 4.6.

Over 4,000 wood heaters were replaced with non-polluting heating as part of Launceston's $2.08 million woodsmoke program which reduced deaths in winter from respiratory disease by 28% and cardiovascular disease by 20%.  Year round, for men, the reductions were 23% (respiratory), 18% (cardiovascular) and 11.4% (all deaths).

Recommended Changes to Proposed Policy

1) The default should be not to allow new log-burning heaters to be installed in urban areas until a health-based standard has been developed by independent experts.  As noted above, 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. The NSW Asthma Foundation warned that: wood smoke emissions in winter pose a bigger health danger in built up urban areas than cars or cigarettes. Australian Lung Foundation spokesman Dr James Markos said wood fire heaters should be banned from urban areas.

2) Councils that wish to allow new wood heaters should be required to conduct a cost-benefit analysis of permitting them and develop an effective policy for consulting neighbours before heaters are installed.   Smoke plumes from new wood heaters rated < 2.5 g/kg have been observed impacting house blocks over 200 metres away.  At the very least, all home owners within 100 metres should be informed.  Councils should also develop an effective policy to assist neighbours whose health or lifestyle is affected by other people's woodsmoke.  Councils and the community should be advised that even a single brand-new wood heater meeting the “standard” to apply from August 2015 is likely to increase PM2.5 exposure of the downwind neighbour by 2 ug/m3 and so result in significant reductions in brain volumes and a 46% increase in the risk of covert stroke.  Is this considered an acceptable risk? One in six people in Australia will be affected by stroke. It is the nation’s leading cause of disability.

3) The above recommendation has general public support, e.g. 56% of submissions for the Federal Government's Woodheater Consultation Regulation Impact Statement (CRIS) supported either a ban on all wood heaters, or not allowing new ones to be installed.

4) The NSW EPA should improve public awareness of the health effects of woodsmoke and amount of pollution from wood heaters.  People need to know the facts in order to make informed decisions.  Being told that woodsmoke is “harmful” or that wood heaters are “polluting” could simply mean that wood heaters pollute as much as cars, or that woodsmoke is no more harmful than passive smoking.  The evidence shown above implies that, even when people try to operate the average wood heater correctly, it still emits more PM2.5 (the most hazardous air pollutant) per year than 2,000 cars and that 25 ug/m3 of PM2.5 pollution in a city's air is equivalent to smoking 3 cigarettes a day.

The EPA should develop a communications strategy to explain the health effects of PM2.5 pollution and increase public awareness of the main sources of PM2.5 emissions in major urban areas such as Sydney and even Hunter Valley mining towns such as Muswellbrook (right).

Once the Montréalers understood that the average wood heater emits more PM2.5 pollution in just 9 hours than a mid-size car does in an entire year, there was general public support for not allowing new ones to be installed and phasing out existing heaters. This policy has led to a reduction in the number of smoggy days in winter (where PM2.5 concentrations exceed 35 μg/m3 for more than 3 hours over 75% of Montréal) from 29 in 2009 to 10 in 2013.

Nowhere in world have education programs or wood-heater change-outs enabled people to use log-burning heaters without creating harmful pollution.  The photos above of brand new heaters in new houses in Armidale shows that, even after being given all relevant information on correct operation, new heaters are adding considerable amounts of harmful pollution to an overloaded airshed.  When there is no safe level of pollution, authorities much strike a compromise between the health damage suffered by the community from permitting health-hazardous air pollution and the economic benefits of allowing that pollution.  Vehicles and industry pollute, but the economic costs of not having vehicles or industry would be considerable.  In contrast, because there are affordable, environmentally-friendly alternatives, there is little benefit in allowing new heating that is so detrimental to health that the NSW chief medical officer says is detrimental to health she supports banning and phasing them out in built-up urban areas

The communication strategy should include TV adverts to improve public understanding of the health effects of woodsmoke, e.g. by comparing the health effects of woodsmoke with other pollution such as environmental tobacco smoke and car pollution.  The compilation of advertising material from other health authorities, in particular the 30 second videos by Utah Physicians for a Healthy Environment and the San Francisco Bay Area 'Spare the Air' campaign, are good examples of what is needed to counter the biased information from the wood-heating industry, that, like the advertising from cigarette companies, is used to increase profits, even at the expense of public health.

5) The POEO should be amended to assist residents whose health or lifestyle has been affected by other people’s woodsmoke.
A survey of residents in the New England Region showed that almost 60% of residents that do not use wood heating sometimes or often experience problems because of other people’s wood heating – see graph.  There have been several complaints to Armidale Council about the brand new heaters with emissions ratings less than 2.5 g/kg shown above.  Despite photographic evidence of plumes exceeding 10 metres in length (in the case of a new heater installed in August 2014, on one occasion lasting for at least 10 hours continuously) Armidale Dumaresq Council has not been able to do anything to help.  The level of emissions shown has continued unabated.  The POEO should therefore be amended to a) permit photographic evidence of the level of emissions to be used as evidence and b) allow evidence in the form of PM2.5 measurements from appropriately-calibrated portable devices provided to residents affected by other people’s woodsmoke and c) revise the definition of excessive smoke to anything that lasts for more than 10 minutes, other than very faint smoke that extends no more than 2 metres from the chimney.

6) The POEO should be amended so that existing wood heaters are phased out when houses are sold and licencing fees introduced to cover the cost of woodsmoke-reduction strategies, including education programs and subsidizing the replacement of wood heaters with non-polluting alternatives.  Just because the NSW EPA has no current powers to require wood heaters to be removed when houses are sold doesn't mean that introducing legislation to achieve this is a bad idea.  Given the estimated benefit of $4,015 million for a cost of just $36 million (see table in right hand column), it would be an extremely bad idea not to introduce the necessary legislation.  The NSW EPA should therefore work towards the introduction of appropriate legislation.

7) Transparency.  In the interests of transparent government, the NSW EPA should publish a summary of all submissions received together with all submissions not listed as confidential.

Risk of legal action.  In the absence of a health-based standard, if Councils continue to allow the installation of new heaters, there is a risk of legal action if residents suffer health damage from breathing woodsmoke.  As noted above, five studies have now linked PM2.5 pollution to autism, as well as a considerable number of studies linking PM2.5 to heart attacks, strokes, lung diseases and cancers, at levels well below 25 ug/m3, or even 20 ug/m3, with even an increase of 2 ug/m3 linked to a 0.32% decrease in brain volume and a 46% increase in covert brain infarcts.  Councils should be advised that even a single wood heater can increase the downwind neighbour’s PM2.5 exposure by more than 2 ug/m3.

The  Federal Government's National Clean Air Agreement is still under consideration. It is expected to go to the Council of Australian Governments (COAG) in July 2015.

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)

PM2.5 is considered the most health-hazardous air pollutant; a recent study an increase of 2 μg/m3 in PM2.5 exposure was associated with a 0.32% smaller total cerebral brain volume and a 46% higher risk of covert brain infarcts, a type of silent stroke.   Despite its proximity to mines and power stations generating electricity for 3.25 million homes, CSIRO's chemical fingerprinting showed that 62% of PM2.5 in Muswellbrook in winter was from domestic wood heaters.  People need impartial information to counter the widespread misunderstanding that the woodsmoke-polluted air they breathe has only a fraction of the PM2.5 pollution from coal and power station pollution in the Hunter Valley, when it fact woodsmoke is also the dominant pollutant in the air of Hunter Valley towns such as Muswellbrook.