Draft Plan to Save NSW Energy and Money
1) Cover file with details & references 2) Completed Submission Form
Senate Inquiry into The impacts on health of air quality in Australia
Woodsmoke submissions. As well as the AAQG submission (no 94), several submissions mention woodsmoke, including NSW Asthma Foundation (no 50, woodsmoke recommendations, pages 20-23), Dr James Markos, Dr John Todd (no 87), The Australian & NZ Clean Air Society (no 113), Camden Council (no 143), NE Greens (no 62), submission 3, submission 39, submission 66, submission 88, submission 90, submission 119, submission 123, submission 134, submission 153. Submission 67 notes the considerable confusion created because the NPI fails to provide adequate warning that it does not report domestic PM2.5.
Implementation of the 3 most cost-effective woodsmoke control options in the NSW report (Table 2, right) instead of the ineffective options considered in the Federal Government consultation was emphasized in the AAQG supplementary submission .
Air pollution vs active smoking. Prof. Higginbotham said at the Newcastle Hearing (see page 20):
"A colleague in my office has looked at what it would be like to breathe air for PM2.5 at the standard of 20 micrograms per cubic metre. Using a very long-term dataset he found that it was equal to smoking three cigarettes a day." In 2012, Armidale had 23 days with PM2,5 levels in excess of the standard (range 28 to 65 ug/m3), equivalent to forcing everyone in the city to actively smoke at least 100 cigarettes.
Problems and delays with updating PM2.5 & woodheater standards were discussed at the Canberra Hearing
Contact details for Senate Inquiry: 02 6277 3515 ; firstname.lastname@example.org
Summary (published Sept 2013) of the 59 Submissions to the Federal Government Consultation on Wood Heater Pollution
A total of 28 submissions from individuals (47% of all submissions) report on the difficulties of resolving the issue of emissions from neighbouring wood heaters. Twenty three (39% of all submissions) report adverse health effects on their families often requiring increasing medicinal solutions, including steroid use for asthma diagnoses in children. Similar neighbourhood examples are also cited in submissions from other stakeholders, such as academic and community groups.Twenty three respondents (39% of all submissions) report on the failure of local government regulations to resolve the problem, citing statutes in some states that require measurement of smoke plumes over time and distance variables during periods when these are difficult or impossible to obtain (e.g. at night). These submissions note also that most local government authorities do not have the resources to attend to neighbour issues and when they do, are reluctant to impose penalties available to them under their by-laws. At every one of the public meetings there was at least one report from attendees on the issue of neighbouring wood heaters affecting their lives.
Twenty five submissions (42%) called for the wood heaters to be banned in urban areas. 56% (33 of 59 submissions) supported an outright ban, or a moratorium on new installations until better regulations can be implemented. Submissions calling for a ban indicated that it could be enforced through the removal of wood heaters on the sale of the property.
As a result of these submissions, a decision RIS is being prepared. "Commonwealth, State and Territory governments are currently working to finalise the Decision RIS. The work will reflect the new Standards for wood heater efficiency (AS/NZS 4012:2014) and emissions (AS/NZS 4013:2014) developed by Standards Australia in 2014, in consultation with industry and government."
Unfortunately, because of the lack of any health experts on the Standards Australia Committee, and the fact that the wood heating industry has a veto over any amendment might adversely affect their profitability, any RIS that simply endorsed an industry-set "standard" represents a continued threat to our health.
Federal Government Consultation - Reducing emissions from wood heaters
Estimated health cost $20 to $24 billion
Government aims for 3% to 8% reduction - is this adequate for a cost > $20 billion?
The Federal Government has released a Consultation Regulation Impact Statement (CRIS)
Email submissions to: email@example.com
The options in the CRIS are very weak, and will achieve almost only a tiny fraction of the estimated $12 billion for the whole country ($4 billion for NSW, Table 2 right)) from phasing out wood heaters when houses are sold, or not allowing new heaters to be installed ($2 billion benefits in NSW, Table 2) or about $6 billion for the whole country.
Even a brand-new heater, burning 10 kg of wood in an evening will result in 0.1 kg of PM2.5 emissions - as much currently permitted for a new diesel car or 4WD travelling 20,000 km, or in the smoke from 5,000 cigarettes. PAH (polycyclic aromatic hydrocarbons) are considered some of the most toxic chemicals in both cigarette and wood smoke. Burning 10 kg of firewood in an Australian wood heater will emit as many PAH as in the smoke from 160,000 cigarettes.
The AAQG Draft Submission (more details below): focuses on the Precautionary Principle Government’s primary role should be protect public health. The extremely large health benefits of the woodsmoke reduction options considered by the NSW woodsmoke control options report (Table 2, right) demonstrates that public health would be much better served by the immediate introduction of the 3 most cost-effective measures, as an interim solution until a satisfactory health-based standard for new woodheaters can be developed. The funds raised by licensing fees should be used to fund a national woodsmoke education program and the replacement of wood heaters with upgraded insulation and efficient heat pumps, gas or wood pellet heating. In Christchurch, NZ, electricity consumption increased by just 1% when wood heaters were replaced by insulation and efficient heat pumps, representing a substantial saving for low-income families compared to the cost of buying firewood. With methane emission from the average wood heater causing more global warming than the CO2 emissions from other forms of heating, the 3-fold reduction in harmful air pollution, global warming and heating expenses represents a win-win-win situation for health, the environment and the family budget.
Make a submission
Concerned about the health effects of woodsmoke? Email a submission to firstname.lastname@example.org (on or before 15 Jul 2013) pointing out that the estimated net benefits of $0.75 to $1.8 billion are hopelessly inadequate to deal with an estimated health cost of $20 to $24 billion. Moreover, the most cost-effective option considered by the Federal Government (option 7, with net benefits of $1.803 billion), was the least effective option (net benefit of $298 million) in NSW, and that the 3 most cost effective measures in Table 2 would provide at least 20 times the health benefits.
Please also consider send the AAQG a copy (airqual AT 3sc DOT net DOT au) and letting us know if we can publish it on the website. This may double the effectiveness of your submission by encouraging other people to ask the Government to protect public health by improved measured to reduce woodsmoke.
Options considered in the Federal Government CRIS
1) National audit and education programs
2) National audit, education and replacement incentive programs
3) Report emissions on compliance plate, education and audit programs
4) Report emissions on compliance plate, star ratings labels, education and audit programs6) A compliance and education program, 60% efficiency standard and 3 g/kg emission standard
5) Report emissions on compliance plate, star ratings labels, education and audit programs and a 60% efficiency standard
7) A compliance and education program, 60% efficiency standard and 3 g/kg emission standard and in-service measures
8) A compliance and education program, 65% efficiency standard and 3 g/kg emission standard and in-service measures
9) A compliance and education program, 60% efficiency standard and 1.5 g/kg emission standard and in-service measures
Reporting emissions test results on the compliance plate and the star rating labelling scheme would start in 2015. Option 6 (a 3 g/kg and 60% efficiency) by 2016, Option 8 (3 g/kg and 65% efficiency) by 2018 and Option 9 (1.5 g/kg and 60% efficiency) by 2020.
No reasons are given for the substantial delays. NZ did not need long delays - its 1.5 g/kg emissions limit and 65% efficiency limit were introduced on 1 September 2005, after public consultation and a cost-benefit analysis that showed significant reductions in mortality.
The AAQG draft submission provides a detailed response. The main points are summarised below.
Main points of AAQG Draft Submission: Precautionary Principle
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).
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 < 3 g/kg have real life emissions = 8.8 g/kg; B: heaters rated < 1.5 g/kg have real life emissions = 6.7 g/kg).
cEfficient heat pumps in Sydney, Melbourne and Perth can deliver at 10 units of heat to a home for every unit of electricity used.
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).
Submission to the Launceston Public Meeting by Dr James Markos, Respiratory Physician
I found it interesting that the authors identified the high cost in $ attributable to the adverse effects from wood smoke. The costs may even be higher than those quoted in the report from other information I have received. Be that as it may, the report predicted that annual emissions would fall by 5,000 tonnes (12%) over the next 20 years, as older heaters are replaced by newer ones (which are supposedly less polluting and operator-independent). I also note that the reduction is predicted to fall from between 3% & 18% per year, depending on which of the 9 options are undertaken. The strictest option is to create a national regulatory body and to regulate that wood heaters meet emission standards of under 1.5 g/kg.
I wonder why the 9 options offered to reduce wood smoke do not include a complete ban on the new installation of wood heaters. I say this because I agree with a key statement made in the document. In the Executive Summary, the 3rd paragraph states: “As poor wood heater operation is usually the main reason for excessive emissions, improvement in technology may be appropriate to ensure emissions are less dependent on operator skill”. From my reading of information provided by Prof John Todd about the science of wood combustion in wood heaters and from meeting many people over the years who are keen users of wood heaters, I have formed the view that even an old wood heater used optimally is better than a new wood heater used incorrectly. I have heard many stories about people using new wood heaters incorrectly, including devising ways to shut the air inlet (contrary to the manufacturer’s design) to slow down the overnight burn and also burning waste in the heaters.
Another reason to consider a complete ban on new installations is this following assertion. In my opinion, if every home in the Tamar Valley used a wood heater, and if this was a modern one which meets current emission standards, and if each wood heater was operated optimally, then I believe there would be a higher concentration of wood smoke in the winter in the Tamar Valley than exists at present. This follows from the inherent high output of particles which are emitted during the initial start-up and with the addition of each new log (albeit less than at start-up). If all these emissions are trapped low in the winter inversions that we see, then they will affect the health of residents of the Valley. I believe that the main reason that the particle pollution has fallen in the Tamar Valley in recent years is because of the reduced numbers of wood heaters in use rather than any improvements in their operation (even though the latter may have improved a also). This was predicted by modelling made by the CSIRO which estimated that the NEPM limit for PM10 of 50 ug/m3 would be reached when total usage in the valley fell to 5,000 wood heaters and that the PM2.5 limit of 25 ug/m3 would be reached when the numbers fell to 2,000 wood heaters.
From the above, it follows that the major reductions in wood smoke emissions have resulted from a switch to alternative home heating in the winter, and there are statistics which show an increased uptake of electric heating over the same period of time. A minority of households in the Tamar Valley (and in other populated inland valleys in Australia) are responsible for the wood smoke which disperses through the entire air shed and which affects everyone’s health and which can be measured as a high cost in $, as quoted in the RIS.
As you are aware, the technology exists at present for very low emission combustion of wood via pellet heaters, whose emissions are below 1 g/kg and with negligible start-up emissions. My vote would be to permit these to be used, but to restrict the new installations of wood-heaters. For the latter, I would favour the tightest regulation possible (eg Option 9 in the RIS, with emissions below 1.5 g/kg) together with a fee payable to the regulatory body akin to a “polluter’s tax” to act as a deterrent and to help offset some of the costs of the regulatory body (which would not be needed if wood heaters were banned). I would also recommend setting a target reduction in wood smoke emissions with a review of the policy in 5 years, keeping open the option of a complete ban on new wood heater installations if appropriate particle levels have not been reached by then.
Thank you for presenting my views to the meeting.
I will include these and other comments later in my formal submission to this process.
Launceston TAS 7250