Clean Air, Better Health - NSW Clean Air Strategy

Consultation: NSW Draft Clean Air Regulation (underlined text = hyperlinks)
If you think current legislation needs improvement, send in a submission!email to Air.Policy@environment.nsw.gov.au by 5 pm, 3 June 2022, cc to ausairqual@gmail.com

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Key points & recommendations (email to Air.Policy@environment.nsw.gov.au by 5 pm, 3 June 2022)

The proposed changes do not address the MAJOR source of NSW’s hazardous air pollution - wood heaters - and the RIS does not comply with Better Regulation Principles set out in Appendix A of the RIS.
Better Regulation Principle 3 (RIS, page 53) requires the impact of government action to be properly understood by considering the costs and benefits of a range of options. The failure to consider highly cost-effective and beneficial options in the RIS such as recommendations 1 & 2 below violates Better Regulation Principle 3. This failure should be corrected as a matter of urgency.
Running costs of modern, efficient reverse cycle heater-air-conditioners (a few hundred dollars per year) pale into insignificance compared with the health costs of using wood heating. A brand new wood heater installed in 2021 has estimated health costs (over 15 years) of $48,528 in the Greater Sydney Metro Region (GMR) if burning 2 tonnes of firewood per year, and $80,844 if burning 3.43 tonnes per year (Sydney average, Federal Government’s Consultation Regulation Impact Statement, 2013, Table 2.2).

Recommendation 1. The POEO needs a major upgrade informed by a benefit cost analysis evaluating whether new wood heaters with estimated health costs of thousands of dollars per heater per year should be permitted on residential blocks smaller than 2 hectares that have electricity grid connections. A position paper by 11 experts from the Centre for Air pollution, energy and health Research (CAR, an NHMRC Centre of Research Excellence) states that 'Current Australian wood heater standards are insufficient to protect health'. This is totally unacceptable. As well as insisting on a that a new standard is developed as a matter of urgency, all wood heaters that emit unsafe amounts of pollution should be withdrawn from use.
Recommendation 2. In the interim, local councils need improved guidance and legislation to manage the installation of new wood heaters, including requirements to consult neighbours whose health might be impacted by the pollution.
Recommendation 3. NSW residents whose health is being damaged by other peoples’ wood heater pollution are largely unable to protect themselves (Asthma Australia study). The POEO needs major revisions to include effective provisions to assist residents who are currently suffering damage to their health or lifestyle because of other peoples’ wood smoke. Councils should be advised that video evidence (which is entirely consistent with the current POEO act) is acceptable evidence of excessive smoke. Other evidence, including validated PM2.5 measurements from community monitoring should also be considered acceptable.

PM2.5 is considered the most hazardous air pollutant. Particles less than 2.5 millionth of a metre are called PM2.5. Of the 4.51 million deaths worldwide attributed to ambient air pollution in the Lancet’s 2019 Global Burden of Disease study, 92% were for PM2.5 and 8% for ozone. Of the 492,600 premature deaths in 2018 attributed to air pollution in Europe by the European Environment Agency, 85% were for PM2.5, 11% for NO2 and 4% for ozone.

Effective strategy needed to reduce unacceptable and increasing PM2.5 levels that now exceed the National standard of 8 µg/m3 (annual average), let alone the stricter 7 µg/m3 required by 2025.

In Sydney – 46% of PM2.5 exposure from wood heaters, despite only 4.4% of Sydney households using wood as main heating (Fig 13, draft NSW Strategy).

No safe level of PM2.5 pollution. PM2.5 are so tiny they behave like gases and enter our houses even when all doors and windows are shut. When we breathe them in, they bypass the body’s defences and penetrate the deepest recesses our lungs where they can cross into the bloodstream and transport toxins to all organs in the body.

Wood heater PM2.5 is increasing, power station PM2.5 decreasing. In the Sydney-Newcastle-Wollongong area, estimated population exposure to PM2.5 from wood heaters increased from 31% (study published in 2019) to 42% (Fig 13, draft NSW Clean Air Strategy). Over the same period, the same sources show estimated population exposure to PM2.5 from power stations declined from 17% to 6%.

People exposed to woodfire heaters said they are largely unable to protect themselves from the smoke, according to the 2020 Asthma Australia Survey, that found 77% of Australians believe new wood heaters should not be allowed in built-up urban areas. Here are some personal experiences of problems and health damage imposed by new wood heaters.

Recommendations - wood heaters

1) No further damage to public health – no new heaters to be permitted in areas where there could be an increased risk to people living nearby, because of the NZ research that one additional modern woodstove per hectare increased by 7% the risk children under 3 would need hospital emergency treatment. Wood heaters meeting current Australian standards haven't been studied in Australia, but in NZ real-life emissions in NZ average 8 times worse than the AS/NZS4013 lab test measurements, implying they are almost as polluting as existing models and have health costs exceeding $3,000 per stove per year.

2) Reduce the health damage by removing existing heaters when houses are sold in urban areas. This costs the taxpayer nothing, does not interfere with anyone’s use of an existing wood heater, but was found to be a highly cost-effective option according to research commissioned by the NSW Government showing wood heater pollution is an $8 billion health problem in NSW in 2011 that could be reduced by 75% by not allowing new wood heaters to be installed and requiring existing ones to be removed when houses are sold.

3) Education to promote widespread understanding of the facts about wood smoke. Legislation against smoking at work was initially controversial, but now has almost universal support. People who are likely to want similar protection against wood smoke once they understand that burning 15 kg of wood in an enclosed wood heater – an evening’s heat – produces as many toxic PAH as in the smoke from a quarter of a million cigarettes, that real-life emissions of new heaters are little different from older models, that health experts recommend not using wood heaters when alternatives are available, that wood smoke increases the risk of dementia, that in Tasmania hospital admissions for heart failure started to increase as soon as PM2.5 exceeded 4 µg/m3, a tiny fraction of the current Australian PM2.5 standard of 25 µg/m3, and that modern efficient heater-air-conditioners are more environmentally friendly than wood heating and have lower running costs than buying firewood (see below).

Every submission counts! Submissions close on 3 June 2022, but emails to Air.Policy@environment.nsw.gov.au will probably still be read. NSW Government website: www.environment.nsw.gov.au/topics/air/clean-air-strategy/draft-nsw-clean-air-strategy-public-consultation

Welcome decrease in power Station PM2.5 (now about 7% of population exposure in Sydney-Newcastle-Wollongong). Fig 16 of draft NSW Clean Air Strategy shows a projected fall in emissions from 1,000 tonnes in 2020 to 200 tonnes by 2034.

Regular independent testing will be required to verify the reported level of emissions and ensure a just transition to non-polluting renewable generation enabling current power station workers have access to retraining and future employment.

Vehicle pollution decreasing as electric vehicles replace those powered by petrol and diesel.

Permitting new wood heaters counteracting the benefits of less power station and vehicle pollution - the average new wood heater emits more PM2.5 in the first hour after lighting than a petrol card in an entire year of driving and a neighbour with even the cleanest wood burner is like have eight-trucks sitting in your street with their engines idling all night.

Muswellbrook (population 11,791) is surrounded by open cut mines and two power stations that generate enough electricity for 3.25 million homes. About 600 households in the urban area use wood stoves, but according to chemical fingerprinting of the pollution in air samples collected throughout 2012, wood heater emissions represented 62% of Muswellbrook's PM2.5 pollution in winter and 30% over the entire year. The smoke pollution from domestic wood-heaters is in yellow, smoke from wildfires and forestry burn-offs is in green, secondary sulfate from local sources such as power stations in orange and industry aged sea salt in light blue.

Supporting Information

Why permit new wood heaters that cause health problems for people living nearby? The “Growing up in New Zealand” study found that every additional modern woodstove per hectare increased by 7% the risk children under 3 would need hospital emergency treatment. The vast majority of stoves in the NZ study would have been modern, low-emission models, because NZ introduced stricter standards in 2005 for new wood stoves in urban areas than required for new stoves in NSW in 2021.

Why permit new wood heaters that increase the risk of hospital admission for heart attack? In Tasmania, researchers noted the main cause of elevated PM2.5 is biomass smoke from wood heaters during winter and bushfires and planned burns at other times of the year. Hospital admissions for heart failure (HF, the leading cause of hospitalisation for adults aged over 65 years) started to increase in Tasmania as soon as PM2.5 exceeded 4 µg/m3, a tiny fraction of the current Australian PM2.5 standard of 25 µg/m3.

Permitting new wood heaters counteracts benefits of reduced electricity & vehicle pollution - the average new wood heater emits more PM2.5 in the first hour after lighting than a petrol card in an entire year of driving, a neighbour with even the cleanest wood burner is like eight-trucks sitting in your street with their engines idling all night, one modern 'eco-friendly' wood stove is more polluting than 6 diesel trucks or 18 diesel cars.

Widespread support for not allowing new wood heaters Asthma Australia asked the Australian public about their attitudes to woodfire heaters and regulation in a nationally representative survey of 25,000 people completed in November 2020 . They found most people, particularly those with asthma, support leaving woodfire heaters behind for better, healthier alternatives.

Three-quarters of the general population surveyed (77%) agree that woodfire heaters should not be allowed in urban or built-up areas and over half agree they should be phased out (55%) or banned completely (54%). Support for regulation was even higher amongst people with asthma with 84% support for regulation of woodfire heaters in urban built-up areas, 71% support for a scheme to phase them out completely, and 65% agreeing they should be banned

Education programs persuaded about 4,000 Launceston to households not to use wood heaters. About 2,000 accepted a small subsidy to remove wood heaters. Another 2,000 removed heaters entirely at their own expense, resulting in a 54% reduction from 66% to 30% of households using wood heaters[7]. This successful federally-funded wood smoke program reduced deaths in winter from respiratory disease by 28% and cardiovascular disease by 20% for a cost of about $21 per resident.

Efficient heat pumps cheaper than buying firewood. Efficient heat pumps (also called heater-air-conditioners or reverse cycle aircon) have very low running costs compared to buying firewood. In Sydney, for example, the estimated annual cost of wood heating was $1,300 (3.43 tonnes of firewood at $380 per tonne), compared to an estimated annual running cost of $110 for a 2.5-5 kW system and $168 for a 4-6 kW system. Poor people are most disadvantaged by current policies, because they suffer the pollution but can’t afford to buy expensive firewood

Efficient heat pumps more environmentally-friendly than buying firewood. Heat pumps move air heated by the sun from outside to inside the home, so cause very little global warming. Wood heaters, by contrast, emit methane, black carbon, carbon monoxide and CO2. The average wood heated home will cause more global warming over the next 20 years (the critical period if we are to keep global warming well below 2 degrees) than 50 similar homes heated by reverse cycle, or 50 fuel efficient petrol cars each travelling 10,000 km per year.