Email submissions to: firstname.lastname@example.org by 5 pm Friday 15 May 2015
Draft Regulation amendment (PDF, 231KB) Wood smoke amendment Q&As
Comments by April 17 also needed on the Federal Government's National Clean Air Agreement
Suggested changes to the proposed policy:1) 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. This recommendation, and those of other health experts such as the NSW Asthma Foundation, implies that, unless a local Council considers that wood heaters will not cause a problem, new wood heaters should not be permitted. Councils that wish to allow them should base this decision on an analysis of the health costs and benefits of permitting them in some or all of the local government area, and also include provisions in their policy for consulting neighbours who are likely to be affected by the smoke, before installations go ahead. It is not uncommon for smoke from new heaters to be noticed over 150 metres from the chimney, so all neighbours living within 100 metres of the proposed chimney should be informed. The policy should also include details of how to resolve complaints from neighbours who are affected by woodsmoke pollution.
2) 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.
3) Many people think that a new woodheater is no more polluting than a new car. Yet, for PM2.5, which is considered the most health-hazardous air pollutant, the average new wood heater is more polluting than 1,000 passenger cars. Indeed, the NSW Air Emissions Community Web tool shows that residential wood heating is responsible for more PM2.5 emissions in Sydney that all other sources combined. The NSW EPA should increase public awareness of the health effects of PM2.5 pollution, the proportion of PM2.5 pollution from wood heaters and estimated health costs of the average wood heater in NSW by undertaking a public education program. Doctors groups and government agencies have produced innovative 30 second TV ads and other material to increase public awareness of this issue.
4) 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, 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.
5) Similarly, given the estimated benefits of $1,267 million for and estimated revenue of $11 million, it would be an extremely bad idea not to introduce licencing fees for wood heater use. The NSW EPA should therefore work towards the introduction of appropriate legislation that allows the revenue to be used for education on the health effects of smoke from solid fuel heaters, assisting low-income families to install healthier, non-polluting heating and deal with complaints about smoke.
6) Local Councils have very limited knowledge of the health effects of woodsmoke and lack the skills to solve problems when a person's health or lifestyle is affected by a neighbour's wood heater. POEO legislation should be amended to allow video and photographic evidence. Portable monitors should also be made available to allow residents to measure PM2.5 pollution on their properties. The definition of unacceptable smoke should be set according to what most people would consider unacceptable, e.g. pollution of 10 ug/m3 above background anywhere on a neighbour's property, continuous smoke for 10 minutes including a plume of at least 5 metres for more than 1 minute. Some of the funds from 5) above could be used to help fund the service, including offering subsidies to replace offending heaters with non-polluting heating. Video evidence should be reviewed by the NSW EPA if local councils have not resolved the problem within 7 days.
7) The restrictions on installing new wood heaters should apply to all heaters with expected real-life emissions of more than 100 grams per year, equivalent to 0.05 grams per kg wood burned for a heater burning 2 tonnes of firewood per year. New technology has reduced emissions from diesel cars by more than 99%. Stringent emissions limits for wood stoves is likely to achieve similar reductions in pollution, by a combination of clean-burning technology and filtration systems.
Easy way to make a submission: cut and paste the above comments into the form at the bottom of the NSW EPA Consultation page
Consequences of not adopting the above recommendations
The photos (click to enlarge) show examples of real-life emissions from domestic wood heaters in new houses in a relatively new housing estate. All except one (top left) were installed after Armidale Dumaresq Council required new heaters in new houses to have emissions ratings less than 2.5 g/kg.
Complaints to council have not resulted in any noticeable reduction in emissions. Does the EPA consider it acceptable to subject neighbours to this level of emissions for many hours? If not, the default should be not to allow councils to install new wood heaters unless they have fully considered the issue and determined the csts and benefits of their proposed policy.
Reasons why the NSW EPA's proposals are inadequate:
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
Source: Tables 26 and 28, AECOM Office of Environment & Heritage: EconomicAppraisal of Wood Smoke Control Measures
Many people mistakenly think that using wood heaters