Email submissions to:  woodsmoke.reduction@epa.nsw.gov.au by 5 pm Friday 15 May 2015

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:
  • PM2.5 are the most health-hazardous air pollutant, responsible for the greatest number of premature deaths
  • There is no safe level of PM2.5 pollution below which adverse health effects have not been observed
  • Serious health consequences of PM2.5 pollution include increased risk of lung diseases, cancers, heart attacks, strokes atherosclerosis, adverse birth outcomes and childhood respiratory disease, with emerging evidence of adverse impacts on neurodevelopment and cognitive function
  • PM2.5 are so small they behave like gases and seep into houses when all windows and doors are shut, just like the oxygen we need to sustain life
  • Emissions in densely populated urban areas that are breathed in by millions of people have the greatest health costs.
  • The NSW Air Emissions Community Web tool (image, right) shows that, despite being used as the main form of heating by only 4.3% of households in that year, residential wood heating is responsible for more PM2.5 emissions in Sydney that all other sources combined
  • A simple way to understand this this is to compare annual emissions from a passenger car (20 grams/year) with the 20 kilograms per year from a new AS4014-compliant wood heater.  The stove is 1,000 times more polluting!
  • Another simple way to understand this is that modern AS4013-compliant wood stoves emit about 10 grams of PM2.5 per kg burned, of about 0.3 kg per day.  Cigarettes produce about 20 mg of PM2.5, so the average stove produces as much PM2.5 as in the smoke from 15,000 cigarettes.  Tests on bacteria and mice show that woodsmoke causes 12 to 30 times as many tumours and mutations as the same amount of cigarette smoke, so the cancer-causing potential of the wood stove is similar to that in the smoke from 180,000 cigarettes  
  • There are several cases of neighbours experiencing health problems after new wood heaters were installed in recent years, see e.g. the case of a family in Pittwater: "In the winter of 2008 subsequent to significant rises in the cost of electricity we began to regularly experience strong blasts of wood smoke from various directions around us followed by ongoing infusion of smoke into our home which would last all night and often into the next day ... After exhaustive attempts to try to remedy the situation and upon advice from GP’s and specialist medical practitioners I was finally forced to sell my home and move. It is incomprehensible to us that a wood burner has greater rights to burn wood and pollute than we have to breathe clean air and to live safely and comfortably in our own home." 
  • Another example of health problems from a new heater installed in 2010. "Our next door neighbour installed a new and approved wood burning heater in 2010. His house is single story and the flue for the new heater barely rises above his eaves ... The smoke from this flue immediately entered most rooms of our old, renovated house. My wife’s asthma was triggered by the smoke and last winter she developed bronchitis and needed multiple treatments with antibiotics."
  • A high proportion of people not using wood heaters - nearly 60% in a recent survey in Armidale and the New England region - report experiencing problems because of smoke from other houses (graph, right hand column).  Under current legislation, which requires officials to observe a continuous smoke for at least 10 minutes, including a period when the plume extends for at least 10 metres, such problems are rarely resolved satisfactorily.  
  • The current 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 proposed policy: $4,897 per year (until August 2015 ), $4,091 per year (from August 2015-2019 for councils that do not adopt the limit of 1.5 g/kg) and $3,357 (for councils adopting the limit of 1.5 g/kg and all councils from August 2019). 
  • State and Federal Governments should provide leadership and base legislation on the advice of health authorities, especially when the public has little or no idea of the proportion of PM2.5 emissions in urban areas from domestic wood heating.  If people had no idea about the health problems causes by asbestos, as is the case for wood smoke, many people might have supported the continued use of asbestos-containing fibro cement. Would the NSW Government have considered that acceptable?
  • 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, the NSW Government should therefore follow the recommendation of health experts
  • 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 
  • The NSW Asthma Foundation also recommend not allowing new wood heaters to be installed and phasing out older models
Results from a survey in Armidale and New England in 2012 show that almost 60% of respondents not using wood heaters experienced problems with wood heater smoke from other houses.
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)

Many people mistakenly think that using wood heaters