Submissions

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 MarkosDr 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 88submission 90, submission 119 submission 123submission 134, submission 153Submission 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 ; community.affairs.sen@aph.gov.au

   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 ConsultationReducing 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: 
scew.secretariat@environment.gov.au
    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 scew.secretariat@environment.gov.au (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 programs 
5) Report emissions on compliance platestar ratings labels, education and audit programs and a 60% efficiency standard
6) A compliance and education program, 60% efficiency standard and 3 g/kg emission 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
Regulations should be guided by the precautionary principle if there are serious doubts about the safety of an activity, it should not be permitted unless there are clear benefits outweighing the safety considerations. 

Australian wood heaters are estimated to emit 40,000 tonnes of particulate air pollution per year.  The total estimated health costs ($8 billion in NSW) are nearly 4 times greater than traffic pollution. The table (right) shows the alarming estimates in the Consultation Regulation Impact Statement (CRIS) of the health costs – thousands of dollars per wood heater per year – of new wood heaters in urban areas. The CRIS reports no offsetting benefits - buying firewood is very expensive – over $1,000 per year in Melbourne, a city where Matthew Wright, chairman of ‘Beyond Zero Emissions’ recently replaced gas heating with electric heat pumps. Matthew’s system delivers 10 units of heat for every unit of electricity, causing less than a sixth the global warming of a typical new wood heater in Melbourne, with running costs less than a tenth the cost of buying firewood. 

With much better, cheaper ways of heating homes, the government’s primary role should be protect public health. There is no safe level of PM2.5 pollution – the costs in Table 1 apply irrespective of whether air quality standards are met or whether wood heaters are major contributors to poor air quality.

A National program  is therefore required to reduce the health damage from breathing woodsmoke in all urban areas, whether or not wood heaters are demonstrably a major contributor to air quality problems.  Estimated health costs of a single wood heater in an urban area surrounded by other houses do not depend on whether other houses use wood heating.  In fact, the case for removing a single wood heater detrimentally affecting the health and lifestyle of several neighbours using non-polluting heating is arguably greater than the case for removing wood heaters elsewhere. 

The CRIS argues that “removal of non-compliant heaters on the sale of a house and bans on installation in critical airsheds were not considered feasible as part of a national program” because such measures would be “blunt in terms of imposing unnecessary restrictions on households in areas not experiencing air quality impacts related to wood heaters”.  However, as noted above, this argument is incorrect – the CRIS paper shows that all existing wood heaters in all urban areas have estimated health costs of thousands of dollars per heater per year

A National Program is therefore required to protect public health by developing a satisfactory standard for new heaters and requiring the removal of all heaters (e.g. when houses are offered for sale) that do not comply with the desired standard and therefore have unacceptable health costs. 

Recommendations

1)   That the Federal Government commissions research to develop a real-life emissions test and standard for new wood heaters that ensures the estimated health costs are less than any benefits of using wood heaters. 
2)   A moratorium on the installation of new log-burning heaters in urban areas until models have been developed that comply with this standard. 
3)   As in Christchurch, NZ, models with AS4013 emissions rating < 1.0 g/kg should, however, be permitted as replacements for more polluting models. Pellet heaters with emissions rating < 1.0 g/kg would also continue to be permitted in all houses.  
4)   All log-burning heaters in urban areas that do not comply with the new standard to be removed before houses are offered for sale. 
5)   An annual levy on woodheater use (with subsidies for low-income families) in urban areas to fund an education program and provide subsidies to upgrade insulation and replace wood heaters with high efficiency gas, electric, solar or wood pellet heaters. 
6)   A National Woodsmoke Education program to inform people about the health problems caused by breathing woodsmoke, the Australian Lung Foundation recommendation not to use wood heaters when non-polluting alternatives are available, and the recommendation of the UN Environment Program and World Meteorological Association that developed countries phase out log-burning heaters to reduce global warming as well as improve health. The woodsmoke education program should explain that the average new wood heater emits 190 to 400 times as much PM2.5 (believed to be the most health-hazardous air pollutant) as the average new car or diesel sports utility vehicle. Advice should also be offered on the savings from installing insulation and the cost of alternative heating.
7)   All cities and airsheds likely to have high woodsmoke levels to measure the most health-hazardous air pollutant (PM2.5) and issue ‘Don’t Light tonight’ warnings on local TV, radio and the internet for all areas where breaches of the PM2.5 standard from woodsmoke are forecast. 
8)   A National Air Pollution hotline to allow people affected by woodsmoke to obtain assistance. 
9)   The inaccuracies, known since 2008, in the National Pollutant Inventory (NPI) which under-estimates particle emissions from woodheaters by about 50% should be fixed immediately. Other major inaccuracies in the NPI (e.g. the lack of accurate data for PM2.5 and for toxic chemicals such as ethylbenzene) should be fixed at the same time and new protocols developed to ensure that major errors in the NPI are fixed in a timely manner. 

Many people are concerned about allowing people to smoke cigarettes near outdoor playing fields, despite the fact that a single wood heater emits as much PM2.5 per hour as in the smoke from 500 cigarettes, with carcinogenic potency of perhaps 6,000 cigarettes per hour.
Most people who understand the woodheater-cigarette comparison are likely to support strict measures to reduce woodsmoke, e.g. not allowing new heaters to be installed until a satisfactory health-based standard has been developed, as well as annual licencing fees and, before houses are offered for sale, requirements to remove all woodheaters that do not comply with the new health-based standard.

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 costs New wood heaterb

Annual cost: whole-house heating with efficient heat pumpc

A

B

Tasmania

$150

10.28

$1,540

NA

NA

$500 - $700

Sydney

$380

3.43

$1,300

$7,938

$6,044

$150 - $300

Wagga 

$180

4.08

$730

$4,057

$3,089

$300 - $600

Melbourne

$300

3.75

$1,130

$8,679

$6,608

$150 - $300

Perth

$270

3.09

$830

$7,151

$5,445

$150 - $300

aPrice, wood use and annual wood heating costs from Table 2.2 of the consultation RIS (CRIS)    
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).[3]  
cEfficient heat pumps in Sydney, Melbourne and Perth can deliver at 10 units of heat to a home for every unit of electricity used.[1]  

  Table 2. Estimated health benefits and costs of woodsmoke control options in NSW

 

 

 

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[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).




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.

 

Yours sincerely

 

James Markos

Respiratory physician

Launceston TAS 7250

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