Submissions on the National Air Quality Agreement and CASANZ's survey to determine its response

National Clean Air Agreement Consultation - Federal Government
Email submissions to
Airquality@environment.gov.au by April 17, 2015.
Link to consultation document "Working towards a National Clean Air Agreement"

Suggested Responses to Questions

1. Do you agree with the proposed goal, purpose, principles and scope as a basis for the National Clean Air Agreement? If not, please explain and provide alternatives if appropriate.

No.  It’s too vague.  The aim should be to implement all cost-effective measures to achieve an optimal sustained reduction in air pollution and exposure for all Australians, with associated health, environmental and economic benefits.

If asbestos had not yet been banned, most people would consider it highly inappropriate just to reduce its use, rather than eliminate this serious health hazard.  The current goal is unacceptable because it fails to distinguish between what is best for the community as a whole (including economic impacts) and smaller reductions in pollution that might be favoured by profit-driven industries.

2. What, in your view, do you consider as a high priority air quality issue(s) that could be considered under the National Clean Air Agreement? Please provide evidence.

The highest priorities should be the issues that provide the largest net benefits.  These include $20-24 billion of savings from cleaning up pollution from domestic wood heaters, $1.9 billion from adopting US standards for non-road diesels, $0.6 billion from adopting new standards for boat engines and lawnmowers, $0.6 billion from adopting international best practice particulate control at coal mines, $0.35 billion from a MOU to reduce shipping vessel speeds for ocean transits, $0.1 billion for diesel trains driver assistance software as well as other measures that generate significant net health and environmental benefits.

As other issues are identified by benefit-cost analyses, they should also be prioritized according to their net benefits.  Net benefits should include the health benefits of reduced emissions as well as the benefits of reduced greenhouse gas and PM2.5 emissions from burning coal compared to the replacement with alternatives such as wind and solar power.

The resources allocated to all identified issues should be in proportion to estimated net benefits. 

3. Can you provide any suggestions for cooperation/partnerships and/or knowledge, education and awareness for the purpose of assisting governments to manage air quality?

The National Clean Air Agreement should be used to avoid the current inefficient situation of duplication when all states have to consider the same issue and carry out separate benefit-cost analyses and regulatory impact statements (RIS).  The Agreement should allow the Commonwealth to carry out a single benefit-cost analysis and RIS for clean air legislation that applies to all states. 

Policies and priorities should be driven by consideration of the costs and benefits.

Previous Commonwealth initiatives such as the NEPM and the NPI have suffered substantially because of inadequate resources and funding.  Air pollution is a health issue.  The net benefits listed above of over $25 billion show that an inadequately funded Clean Air Agreement that was unable to achieve the desired health benefits would be a false economy.  Provision of adequate resources should be an integral part of the agreement.

Two essential partnerships have already been identified in the consultation document.  1) a National Air Quality Data Service managed by the Bureau of Meteorology to improve access to information and reporting on air quality and 2) $8.88 million in funding for a clean air and urban landscapes hub to support environmental quality in urban areas.  An effective partnership with the clean air hub could be one way to provide essential public education on the sources and health effects of air pollution and how to combat it.

Proposed Principles

The principles should be reordered so that they focus on the task – to generate overall community benefits – instead of the procedures.  Although costly disruptions from policy changes are undesirable, so are the health costs of air pollution.  If asbestos were still permitted, what would be an appropriate lead in time for phasing it out?  Regulations are requirements should aim to strike a balance between the cost of action and the cost of delays.

1. The Agreement facilitates action to address current and emerging air quality issues.

2. The Agreement aims to maximize overall community benefits, including net economic benefits, taking account of social and environmental outcomes of measures, whether regulatory or non-regulatory.

3. Responses to air quality issues under the Agreement maintain best practice approaches, consider the latest evidence available and identify the most appropriate level of government to take the lead.

4. Policy decisions under the Agreement are relevant, timely, consider available resources, allow for effective consultation and appropriate lead-in times that minimise the health costs of unnecessary delays as well as any costly disruptions that may result from policy changes.

5. Air quality management measures delivered are efficient and effective, and avoid creating cumulative or overlapping regulatory burdens that have significant cost implications.

6. Activities under the Agreement are consistent with Australia’s international obligations.

7. The Agreement and endorsed work programme is periodically reviewed to maintain a focus on achievement of desired outcomes and to ensure its continuing relevance.



The Clean Air Society Australia/New Zealand (CASANZ) is seeking public responses before April 2 to assist with preparation of a submission on “Working towards a National Clean Air Agreement” -  https://www.surveymonkey.com/s/R3CY526

Questions & ideas for responses.  Put into your own words for maximum effect.
1
. The proposed goal of the National Clean Air Agreement is “The sustained reduction in air pollution and exposure for all Australians, with associated health, environmental and economic benefits.”  Do you agree with this goal?
It's too vague.  The aim should be to use available resources to maximize the benefits of reducing pollution.  Rephrase as:
Implement all cost-effective measures to maximize the sustained reduction in air pollution and exposure for all Australians, with associated health, environmental and economic benefits

2. A number of current and planned activities are proposed for inclusion in the initial 2-year work plan. What do you consider the priority is for including each of the following activities?
The estimated health cost of wood heaters in NSW was $8 billion, equivalent to about $20-24 billion for all Australia, about 6 times the benefits from all other measures put together. The priority should be to implement all cost-effective measures starting with those that have the largest net benefit - i.e. achieve the $20-24 billion net benefits from cleaning up wood heater pollution.   

3. It is anticipated that achieving this goal would be facilitated by 
a) “Providing a facilitating framework to identify specific air quality issues where concentrated effort is needed and will afford health, environmental and economic benefits.”
Reviews have already identified $20-24 billion of savings from cleaning up pollution from domestic wood heaters, $1.9 billion from adopting US standards for non-road diesels, $0.6 billion from adopting new standards for boat engines and lawnmowers, $0.6 billion from adopting international best practice particulate control at coal mines, $0.35 billion from a MOU to reduce shipping vessel speeds for ocean transits, $0.1 billion for diesel trains driver assistance software for line haul locomotives, as well as other cost-effective savings.  The best way to achieve the goal of sustained reductions in air pollution and exposure and achieve the associated health,  environmental and economic benefits would be to provide a facilitating framework to ensure the cost-effective measures that have already been identified are implemented.

4. b) “Formalising cooperative management of air quality at the national, state and local levels to help develop effective and efficient policy settings to ensure Australia can respond to current and emerging air quality priorities.”  Agree.

5. A set of principles has been proposed to support prioritisation and decision-making under the Agreement. Please indicate the importance you place on each principle.
The primary principle for prioritizing the decision-making should be the net benefit, i.e. the health and environmental benefits less the cost.  All the other principles are secondary and should be considered as part of the implementation process after the priorities have been set.  

6. A number of measures have been suggested for including in the scope of the Agreement. Please indicate your view on the priority of each of the following.
Comment: Some of the measures listed above are distractions that are likely to hinder the real goal of reducing the health costs of air pollution.  Australia survived the Global Financial Crisis because of effective regulation, not partnerships with industry.  For similar reasons, effective regulations will be the best way to reduce air pollution and associated health costs.

7. Should the Agreement include a commitment on the level of resources required for each measure? Strongly Agree.

8. Are there other current or emerging air quality issues that require action by government?  Suggestions
It's pointless to worry about 'emerging issues' until the current priorities have been dealt with.

9. Are there other/overseas initiatives in air quality that would you like to see implemented in Australia? Comment/Suggestions
Montreal does not permit new wood stoves to be installed and existing ones are being phased out.

10. What role(s) would you like CASANZ to play in the National Clean Air Agreement? Comment, suggested role(s)
Encouraging a focus on the priorities that are expected to achieve the greatest health benefits for the least cost, e.g. cleaning up domestic wood smoke emissions.
Comments