NEPC Consultation

Brief Summary of Submissions

  • 109 Individually-composed non-confidential personal and group submissions
  •   25 on-line survey responses
  • 420 emails to Ministers and the NEPC - see right-hand column
  • 40 pre-printed postcards - see right-hand column
  •   7 confidential submissions
 The 420 emails to ministers and the NEPC expressed support for a maximum daily average PM2.5 of 20 ug/m3, maximum annual average of 6 ug/m3, maximum daily average PM10 of 40 ug/m3, maximum annual average of 20 ug/m3.

Of the 109 individually-composed submissions that expressed an opinion, 72% favoured a 20 ug/m3 limit for daily average PM2.5 and 73% a 6 ug/m3 annual limit.  For PM10, 80% favoured a daily limit of 40 ug/m3 and 93% of those expressing an opinion supported a 20 ug/m3 annual limit.

The on-line survey asked respondents if they supported a 25 ug/m3 daily PM2.5 standard and if they supported an 8 ug/m3 annual PM2.5 standard. All but one of the respondents that expressed an opinion favoured these options or more stringent PM2.5 standards.  In addition, 36% stated without prompting that a preference for a 20 ug/m3 daily PM2.5 standard and 33% for a 6 ug/m3 annual PM2.5 standard.  79% of survey respondents supported a 40 ug/m3 daily max PM10 standard and 95% an annual standard of 20 ug/m3 PM10.   A spreadsheet  has been compiled with details of the calculations and other information.

Conclusions.  The submissions expressed overwhelming public support for strict air pollution standards, notably PM2.5 standards of 6 ug/m3 (annual) and 20 ug/m3 (daily max) and PM10 standards of 40 ug/m3 (daily max) and 20 ug/m3 (annual average). There was also a general consensus that the standards should be adopted without delay - NEPC processes in the past have taken far too long.


Summary of Issues

The current NEPM process is bogged down with bureaucracy, and so has failed to meet its vitally important aims of minimising the risk from adverse health impacts of exposure to air pollution for all people wherever they may live (recommendation of the 2011 review) and providing equivalent protection to all Australians wherever they live (original aim).

The true net benefits of adopting the economically feasible measures are at least $24 billion, not the claimed $8.8 billion. 

Measures that would generate an estimated $15 billion in net benefits (from woodsmoke-control) were omitted from the economic analysis, implying that the NEPC did not consider economically feasible measures.    ‘Adoption of international best practice PM control measures at coal mines’ was considered, but not the costs and benefits of covers for coal wagons.  As a general principle, polluters should be required to pay the estimated health costs of their pollution.  This would discourage polluting activities and provide funds to monitor air pollution, evaluate and implement appropriate pollution-reduction strategies, assist people whose health is affected by air pollution, and cover costs to the health system.

Delays have wasted money and cost lives by focussing on less hazardous pollutants instead of PM2.5 - the pollutant most closely linked to the greatest heath costs.  The impact statement for the Draft Variation to the National Environment protection (Ambient Air Quality) Measure states:  The greatest proportion (>99%) of the health costs accrue from avoiding premature deaths due to long-term exposure to PM2.5. With limited resources, the most cost-effective approach is to focus efforts on the most health-hazardous pollutants.  Delays in revising the NEPM have created a perverse situation, where, for example, the NSW EPA has 13 sites in Sydney measuring PM10, but only 4 measuring PM2.5.  The public would be better served by more streamlined processes (perhaps based on national clean air laws) to implement legislative changes on monitoring and reducing emissions when the benefits are obviously much greater than the costs, e.g. estimated benefits of $4,015 in NSW for costs of just $36 million from requiring wood-heaters to be removed before houses are offered for sale.

Annual PM2.5 average of 6.0 μg/m3; daily max PM2.5 of 20 μg/m3; annual average PM10 of 20 μg/m3; daily max PM10 of 40 μg/m3 are achievable if all $24 billion of economically feasible measures are implemented.  The $24 billion of economically-feasible measures include the woodsmoke-control measures which could generate $15 billion of net benefits but for some unknown reason were not considered by the NEPC.

Every day of delay causes another 1 or 2 unnecessary premature deaths.  The Summary for Policymakers of the Health Risk Assessment on Air Pollution reports that annual mortality attributable to long-term PM2.5 exposures above background is equivalent to approximately 1590 deaths at typical ages (2.2%) in Sydney, Melbourne, Brisbane & SE Qld and Perth, and that decreasing average annual PM2.5 exposure to 6 μg/m3 would lead to a decrease in attributable mortality of 34%.[6]  A 34% decrease represents about 540 fewer deaths every year.  Scaled up to the whole country, achieving these targets by implementing the $24 billion of economically-feasible measures is likely to save 700 lives per year, about 2 deaths per day.

Without polluter-pays taxes, the community is forced to subsidize polluting activitiesPolluters-pays taxes are needed to pay the health costs of their pollution.  The lack of such taxes is forcing the general community to subsidize polluting activities.  National Clean Air Laws are needed to oversee the implementation of the economically beneficial pollution-reduction strategies and avoid unnecessary delays and premature deaths.  Every day of delay causes another 1 or 2 unnecessary premature deaths.

New monitoring protocols are needed to ensure pollution is measured in the areas where it causes the greatest harm. Even for small populations such as Geeveston, Tas (a small town of 277 houses where the 25 μg/m3 PM2.5 target was exceeded 99 times in 20 months, mainly due to domestic wood heating), it is not acceptable to ignore the public health issue by not measuring PM2.5 (either directly or using nephelometers).  The NEPM protocols should specify use of portable systems (such as those developed by EPA TAS) to identify areas of unacceptable pollution and enable monitoring and pollution-reduction strategies to be implemented.

Net benefits over $24 billion from economically feasible measures, not $8.8 billion

The NSW Government’s economic analysis of woodsmoke control options reported that the estimated health costs of woodsmoke in NSW amounted to over $8 billion[1], but that a new emissions test and health-based standard (set by experts with no financial interest in the wood heating industry) together with 3 simple control measures could reduce the damage by at least 75%.

1) Remove all heaters that do not meet a health-based standard when houses are offered for sale
2) Permit only heaters meeting the health-based standard to be installed
3) Licensing fees to cover the cost of wood smoke-reduction programs and assist people whose health or lifestyle has been affected by wood smoke.
[1]

Despite a much colder climate with daily average temperature below freezing from December to March, Montreal is implementing similar measures.  The installation of new log-burning heaters was banned in 2009.  Since then, the number of smoggy days in winter (where PM2.5 concentrations exceed 35 μg/m3 for more than 3 hours over 75% of Montréal) has fallen from 29 in 2009 to 10 in 2013[2].  Rather than creating hardship, the policy appears to have met with sufficient approval that it is now being extended to require all existing wood stoves to be removed by the end of 2020.[3]

Australian health authorities have voiced support for similar measures, e.g. the NSW Asthma Foundation.  The NSW Chief Medical Officer Kerry Chant said that wood heaters are so detrimental to health she supported banning and phasing them out in built-up urban areas.[4]  As well as emitting more PM2.5 (noted above to be the most health-hazardous air pollutant) per year than 1,000 passenger cars, domestic wood heaters are also bad for the environment and cause more global warming than other forms of heating.[5]

Scaled up to the whole of Australia, the 3 woodsmoke measures listed above are estimated to generate net benefits of about $20 billion, $15 billion more than the ineffectual proposals for woodsmoke in the NEPC’s economic analysis.  Adding the $15 billion to the $8.8 billion net benefit in the NEPC analysis leads to the conclusion that economically feasible measures to reduce PM pollution have net benefits of $24 billion. 

Unacceptable delays = unnecessary deaths

There is overwhelming evidence of a strong, quantifiable relationship between PM2.5 pollution and adverse health effects including premature deaths, heart attacks, strokes.  Premature deaths from air pollution in Sydney resulted in the lost of an estimated 6,300 life-years in 2008.[6] The Summary for Policymakers of the Health Risk Assessment on Air Pollution reports that annual mortality attributable to long-term PM2.5 exposures above background is equivalent to approximately 1590 deaths at typical ages (2.2%) in Sydney, Melbourne, Brisbane & SE Qld and Perth, and that decreasing average annual PM2.5 exposure to 6 μg/m3 would lead to a decrease in attributable mortality of 34%.[6]  A 34% decrease represents about 540 fewer deaths every year.

‘Economically feasible’ + Woodsmoke Control (EF+WS) could 700 lives/year

The NEPC Economic Analysis[7] states: “the reduction of primary PM emissions will often be associated with a reduction in emissions of other pollutants that are precursors of secondary PM, thus reducing secondary PM formation”.  This is certainly true for woodsmoke.  In Aspendale, Melbourne, the secondary organic aerosol fraction of PM2.5 was greatest during the autumn and early winter months when the formation of inversions allows build up of particles produced by domestic wood-heater emissions.[8] 

The woodsmoke-control measures discussed above are therefore likely to result in even greater net benefits than the formal estimate of $24 billion noted above.  Many other measures found by the economic analysis to be ‘economically feasible’ will also reduce secondary particle formation and so achieve even greater benefits than predicted.  Table 3.2 (p29) of the Economic Analysis  reports average PM2.5 levels of 6.9 μg/m3 in the Sydney Greater Metropolitan Area and 6.2 μg/m3 in Victoria and Port Phillip.  It therefore seems highly likely that the desired target of 6 μg/m3 PM2.5 is achievable, saving over 500 lives per year. 

Health benefits of pollution control likely to be much greater than predicted

As well as premature deaths, studies have linked long-term exposure to PM2.5 to several new health outcomes, including atherosclerosis, cot deaths, adverse birth outcomes and childhood respiratory disease.[9]  Emerging evidence also suggests possible links between long-term PM2.5 exposure and neurodevelopment and cognitive function, as well as other chronic disease conditions, such as diabetes.[9]  These undesirable outcomes indicate that the health costs of air pollution are likely to have been under-estimated. 

Polluter-pays principle

Polluters should be required to pay the estimated health costs of their pollution.  This would discourage polluting activities and provide funds to monitor pollution, implement pollution-reduction strategies, assist people whose health is affected by air pollution and cover the costs to the health system.

Put most effort into monitoring & reducing the worst pollutants

The impact statement for the Draft Variation to the National Environment protection (Ambient Air Quality) Measure states:  The greatest proportion (>99%) of the health costs accrue from avoiding premature deaths due to long-term exposure to PM2.5.” The best and most cost-effective approach is to devote limited resources to the most health-hazardous pollutants.  Unfortunately, delays in reviewing the NEPM have created a perverse situation, where, for example, the NSW EPA has 13 sites in Sydney currently measuring PM10, but only 4 measuring PM2.5.  The public would be better served by a more streamlined process (perhaps based on national clean air laws) to update monitoring protocols and legislate pollution-reduction strategies where the benefits are obviously much greater than the costs, e.g. the estimated benefits of $4,015 in NSW for a cost of just $36 milling from requiring wood-heaters to be removed before houses are offered for sale.

A simple recommendation for monitoring sites to measure PM2.5 when the advisory PM2.5 standard was more likely to be exceeded than the PM10 standard could have been recommended as part of a streamlined NEPM review in 2005, for very little cost but great public benefit.  Evidence linking PM2.5 exposure to adverse health effects rather than coarser particles has been known for decades.  Studies published in 1993[10] and 1996[11] provided strong evidence that premature mortality is more closely linked to PM2.5 than particles between 2.5 and 10 microns. The continued delays in setting up adequate PM2.5 monitoring seems incomprehensible given the widespread acknowledgement that health impacts are more closely related to PM2.5 than PM10, e.g. the NSW EPA report on valuing the health impacts of air pollution states: A recent UK report states that PM2.5 is considered to be the best index of PM for quantitative assessments of the effects of policy interventions (COMEAP, 2009).”[12] 

Monitor where pollution targets are likely to be exceeded

New monitoring protocols are needed to require pollution to be measured in areas where targets are most likely to be exceeded.  In a 20-month study of Geeveston, Tasmania (a small town with 277 houses) the PM2.5 advisory standard of 25 μg/m3 was exceeded 99 times.  Despite the small population, such extreme pollution (77% of man-made PM pollution coming from wood-heaters, 11% from smoke plumes from forestry burns, 4% from waste combustion and 8% other sources) demonstrate a clear need for PM2.5 to be measured.  In such cases, nephelometer-based measurements such as the Tasmanian BLANkET (which has been shown to be almost interchangeable with the standard reference methods) are acceptable.  NEPM measurement protocols should be drafted so that, even for small populations such as Geeveston, it is not acceptable to ignore the public health issue by not measuring PM2.5 either directly or using optical proxies.  EPATAS has developed a portable system that could be used to identify areas of unacceptable pollution[13] and enable monitoring and pollution-reduction strategies to be implemented.

General responses to the NEPC consultation

Most people think of an air pollution ‘standard’ as a safe level.  This is clearly not the case.  The current NEPM reporting system is largely ineffective because it allows jurisdictions to exceed ‘standards’ without penalty.  Unless this is to change, the most effective approach will be to set the strictest possible aspirational standards (annual average PM2.5: 6.0 μg/m3; daily max PM2.5: 20 μg/m3; annual average PM10: 20 μg/m3; daily max PM10: 40 μg/m3).

National Clean Air Legislation and polluter-pays taxes are also needed to ensure all economically feasible measures such as the EF+WS measures discussed above are implemented as soon as possible. With 500 avoidable premature deaths per year, every day of delay causes another 1 or 2 unnecessary premature deaths.

NEPC Consultation Questions

Chapter 2: Characteristics and measurement of airborne PM

Ø       The characteristics of airborne PM are described in some detail. Would any further information on airborne PM characteristics assist in informing action to reduce airborne PM? If so, please provide details.

Ø       Please provide any additional Australia-specific aspects of PM measurement that you believe are important to the actions to reduce airborne PM being considered in this Impact Statement.

See comments above:  Put most effort into monitoring & reducing the worst pollutants - Monitor where pollution targets are likely to be exceeded

Chapter 3: Health effects and monetary costs of airborne PM

Ø       Is there any any additional Australia-specific information on the health effects or monetary costs of PM that should be included? If so, please provide details.

Chapter 3 states: ‘Reducing exposure to PM10 and PM2.5 in Sydney alone could save around $5 billion per year.’  The fact that this isn’t already being done is a testament to the failure of current processes!

Chapter 4: Policy context and legislation

Ø       Have all aspects of the current air quality management framework in Australia been adequately described? If not, please provide further details.

Ø       Have any significant regulatory developments, local or international, been overlooked? Please provide information.

Ø       What are your views on the feasibility of an exposure-reduction framework for PM in Australia?

An exposure-reduction framework is perfectly feasible, but it would be better to save $24 billion in health costs by implementing all economically feasible measures as soon as possible.  These measures are likely to substantially reduce pollution and achieve annual average PM2.5 of 6.0 μg/m3; daily max PM2.5: 20 μg/m3; annual average PM10: 20 μg/m3; daily max PM10: 40 μg/m3. The exposure-reduction framework should therefore be implemented in the small proportion of locations where the targets listed in this paragraph cannot be achieved within 5 years  

Chapter 5: Airborne PM in Australia

Ø       Do you think that any additional information on emissions and ambient PM concentrations in Australia is required to inform the actions being considered for reducing airborne PM?

Ø       Are there other issues that have not been considered or have not been attributed sufficient weight in the discussion?

The cost of delays in reducing air pollution has not been given sufficient weight.  Not implementing measures that could save 500 lives per year means that 1 or 2 additional unnecessary deaths for every day of delay in adopting the NEPM or equivalent legislation.

Chapter 6: The problem and the case for government intervention

Ø       Do you agree that further government involvement is required to address the potential future health impacts and costs of airborne PM?

Yes.  Is anyone seriously suggesting that the $24 billion worth of health benefits from the economically feasible measures would happen without legislation?

Chapter 7: Statement of options

Ø       Do you agree that the AAQ NEPM framework is an important element in the management actions to address ambient air quality in Australia?

Ø       Have any options for the metrics, averaging times, and values of the standards been overlooked?

Ø       Do you agree that the metrics and values of PM standards selected for analysis are appropriate for Australia?

Ø       Do you consider the options outlined for the form of the standards to be feasible for Australia? Have any options been overlooked?

Ø       Is there any other information relating to the options for an exposure-reduction framework that should be considered?

Yes.  Is anyone seriously suggesting that the $24 billion worth of health benefits from the economically feasible measures would happen without legislation?

 

Chapter 8 Impact analysis

Ø       Have all health, environmental, economic and social impacts of PM in Australia been identified? If not, please provide reasons and suggestions for additional analyses.

Ø       Have all key assumptions been correctly identified and included in the analysis? If not, please provide details.

No.  The economic analysis is deliberately conservative.  The benefits of reducing PM emissions are likely to be higher than the estimates in the economic analysis, and omitted $15 billion worth of health benefits from woodsmoke-reduction.  There is no reason to believe that a PM2.5 target of 6.0 μg/m3 (annual average) could not be achieved by implementing all economically feasible measures. 

Chapter 9: Preferred options

Ø       Do you agree with the introduction of an annual PM10 standard, given the apparent adverse health effects of coarse particles and their prevalence in some regions?

Ø       Do you support upgrading the current AAQ NEPM advisory reporting standards for PM2.5 to compliance standards?

Ø       Do you support the preferred numerical values for new/revised 24-hour and annual PM2.5 and PM10 standards? Which value for the 24-hour PM10 standard do you consider to be the most appropriate, and why?

Ø       What is your preferred option for the form of the 24-hour PM10 and PM2.5 standards? Should the options be trialled?

Ø       Do you have any comments regarding the possible inclusion of PM metrics, other than PM10 and PM2.5, in the future?

Ø       Do you agree with the preferred form of the exposure-reduction framework under which an exposure index based on monitoring would be used to track population exposure for major urban areas?

The NEPM should include a PM2.5 target, but the results discussed here indicate that it should be 6.0 μg/m3 (annual average).  Similarly the daily max should be 20 μg/m3.  Moreover, there is no reason why the NEPM shouldn’t have PM10 targets of 20 μg/m3 (annual average) and a daily max PM10: 40 μg/m3.  The monitoring protocols should, however, not require pollutants to be measured if there is little or no chance of the requirements being exceeded.  Protocols should also require PM2.5 measurement in areas where the standards are regularly exceeded, even if only a few hundred people are affected.

NCC submission guide
The Nature Conservation Council's submission guide outlines the main issues that should be considered.


420 submissions to the NEPC expressed the sentiments below.
Dear Minister,
     I am writing to express support for the immediate adoption of improved air pollution standards via the proposed variation to the Ambient Air NEPM. For too long, Australians have been exposed to harmful levels of pollution. It’s time to hold polluters accountable and put community health first.
     Particle pollution is a killer, ending more than 3,000 Australian lives prematurely each year. I’m pleased that you are considering standards for the fine particles (PM2.5) emitted from cars, power stations, wood heaters and other combustion sources. An annual standard of 6 micrograms per cubic metre should be adopted – it would save 700 lives each year.
     It’s also encouraging that you are considering lowering the 24-hour standard for course particles (PM10) from 50 to 40 micrograms per cubic metre and bringing in an annual compliance standard for PM10. There is no level below which particle pollution doesn’t damage respiratory and cardiovascular health. 40 micrograms should be adopted as the 24 hour standard and 20 micrograms should be adopted as the annual standard. Pollution should be reduced as much as possible, as quickly as possible.
     All these standards should be adopted without delay – NEPC processes in the past have taken far too long.
    Controlling air pollution will take more than just standards. Our pollution standards are frequently exceeded in some regions but regulators are slow to enforce or prosecute. Pollution could be reduced through simple measures like covering coal wagons and tackling emissions from wood heaters and diesel engines. I urge you to consider how Australia’s weak regulations for air pollution could be strengthened through a national Air Pollution Prevention Act.

     Sincerely,

Another 40 people sent postcards to the NEPC asking for strong national air pollution laws.

NEPC web survey

Public Meetings on the proposed New Air Quality (particle) standards
- see below for dates.
Melbourne, 10 Sept, 5pm - 7pm, Level 4 Conference Room, EPA Victoria, 200 Victoria Street Carlton, 3053
Morwell, 11 Sept, 5pm - 7pm,  Morwell Bowls Club, 52 Hazelwood Road, Morwell, 3840


Attendees should ask why $15 billion of economically-feasible measures to reduce particle emissions from woodsmoke were omitted from the NEPC economic analysis, and to confirm that including the highly cost-effective woodsmoke control options listed below would increase the value of the economically-feasible measures to $24 billion, and allow the target of 6 ug/m3 PM2.5 to be achieved.

The NSW Government’s economic analysis of woodsmoke control options reported that the estimated health costs of woodsmoke in NSW amounted to over $8 billion[1], but that

A new emissions test and health-based standard (set by experts with no financial interest in the wood heating industry) together with 3 simple control measures could reduce the damage by at least 75%.
1) Remove all heaters that do not meet a health-based standard when houses are offered for sale
2) Permit only heaters meeting the health-based standard to be installed
3) Licensing fees to cover the cost of wood smoke-reduction programs and assist people whose health or lifestyle has been affected by wood smoke.
[1]

These measures are supported by the NSW Asthma Foundation, and the NSW Chief Medical Officer Kerry Chant, who said wood heaters are so detrimental to health she supports banning and phasing them out in built-up urban areas.

Contributions to PM2.5 exposure in the modelled area of NSW (mainly Newcastle-Sydney-Wollongong, see Table A34, below):  Domestic Wood heaters 16.3%, motor vehicles 7.1%, coal dust 2.8%. 


Above is the NEPC's estimates of PM2.5 exposure by source (for modelled areas of NSW and Victoria, see p59 of the Economic Analysis Appendices).  In Sydney, 16.3% of all PM2.5 exposure is due to wood-heaters (perhaps 20% including the secondary component, compared to 7.1% from motor vehicles and 2.8% from coal dust ) despite only 4.3% and 5.0% of households using wood as the main heating in 2008 and 2011 respectively).  Eliminating this source of PM2.5 would therefore reduce PM2.5 from 6.3 μg/m3 in 2008 in Sydney (p vii of the Summary for Policy Makers of the Health Risk Assessment on Air Pollution in Australia) to 5.0, and from 6.9 μg/m3 in the NSW GMR 2011 (Table 3.2, p29 of the Economic Analysis Main report (EAMR)) to 5.5 μg/m3, suggesting that a target of  6.0  μg/m3 is achievable.

In Victoria Port Phillip, PM2.5 exposure (6.2 μg/m3, Table 3.2, p29 EAMR) is lower than in the NSW GMR, as is wood-heater use (2.6% in 2008, 3.5% in 2011) and the primary wood-heater component of PM2.5 exposure (7.7%).  However, an analysis of secondary PM2.5 in Aspendale, Melbourne, found that secondary organic aerosols (SOA) accounted for 1.1 μg/m3 (13% of measured PM2.5) and that the "SOA fraction of PM2.5 was greatest during the autumn and early winter months when the formation of inversions allows build up of particles produced by domestic wood-heater emissions".   Targeting the small proportion of households using wood has the main form of heating (2.6% in 2008, 3.5% in 2011) could reduce PM2.5 exposure to about 5.6 μg/m3, from direct emissions with perhaps a further reduction to 5.2 μg/m3 from reduced SOA.  The continued crackdown on diesel emissions by requiring new vehicles to meet Euro 5 standards from 2013 to 2016 and Euro 6 by July 2018 could take average exposure below 5 μg/m3.  This again implies that the NEPM target of 6.0  μg/m3 is achievable and that a higher target would be inappropriate. 

Projected PM2.5 concentrations, NEPC Economic Analysis



Web-based survey questions and suggested answers

 Identification of preferred options

 Do you support upgrading the current AAQ NEPM advisory reporting standards for PM2.5 to compliance reporting standards?Yes

Do you support the preferred numerical value for a new 24-hour PM2.5 standard of 25 μg/m3?
No – the implementation of the economically feasible measures
economically feasible measures together with the 3 most cost-effective woodsmoke control measures from the NSW Woodsmoke Control Options Economic Analysis should enable a greater reduction to 20 μg/m3

 Do you support the preferred numerical value for a new annual average PM2.5 standard of 8 μg/m3?
No – the implementation of the economically feasible measures together with the 3 most cost-effective woodsmoke control measures from the NSW Woodsmoke Control Options Economic Analysis should enable a greater reduction to 6
μg/m3

Do you support the introduction of an annual average PM10 standard?
Yes

Do you support the numerical value for an annual average PM10 standard of 20 μg/m3?
Yes

Which value for the 24-hour PM10 standard do you consider to be the most appropriate?
40
μg/m3

Which option for the form of the 24-hour PM10 and PM2.5 standards do you prefer? Please rank as many of the following options as you wish in order of preference from 1 (most preferred) to 4 (least preferred). Please feel free to provide further comment
In order of preference 2 (with the proviso of having no exceedances except for natural events), then 1, 3.  Option 4 is 4 last.  Option 2 would not be preferred if more than 1 exceedance was allowed.

Do the options for the form of the standards require further analysis or trialling prior to amending the form of the standards?
NO

Do you have any comments regarding the possible inclusion of PM metrics, other than PM10 and PM2.5, in the future?
NEPMs should be reviewed every 3-5 years – this should be considered in the next review. 

Do you agree with the preferred form of the exposure-reduction framework, under which an exposure index based on monitoring would be used to track population exposure for major urban areas?
An exposure-reduction framework is perfectly feasible, but it would be better to save $24 billion in health costs by implementing all economically feasible measures as soon as possible. 

Characteristics and measurement of airborne PM

Are you able to provide any relevant additional information on Australia-specific aspects of PM measurement that that is not included in Chapter 2 of the Impact Statement?
The need to put the most effort into monitoring & reducing the worst pollutants and monitoring locations where pollution targets are most likely to be exceeded

Health effects and monetary costs of airborne PM

Are you able to provide any additional Australia-specific information on the health effects or monetary costs associated with PM that is not included in Chapter 3 of the Impact Statement?
Chapter 3 states: ‘Reducing exposure to PM10 and PM2.5 in Sydney alone could save around $5 billion per year.’  The fact that this isn’t already being done is a testament to the failure of current processes.  In addition, for the country as a whole, there is a further $15 billion of net benefits from woodsmoke-reduction measured that were not considered in the NEPC economic analysis.

Policy context and legislation

Have all aspects of the current air quality management framework in Australia been adequately described in the Impact Statement?
Are there any significant local or international regulatory developments that have been overlooked?

There are an additional $15 billion of net benefits from woodsmoke-reduction measured that were not considered in the NEPC economic analysis.

Do you think an exposure-reduction framework is warranted in Australia?
An exposure-reduction framework is perfectly feasible, but it would be better to save $24 billion in health costs by implementing all economically feasible measures as soon as possible.  The economically feasible measures (including an additional net benefits of $15 billion from woodsmoke-reduction measured not considered in the NEPC economic analysis) are likely to substantially reduce pollution and achieve annual average PM2.5 of 6.0 μg/m3; daily max PM2.5: 20 μg/m3; annual average PM10: 20 μg/m3; daily max PM10: 40 μg/m3. The exposure-reduction framework should therefore be implemented in the small proportion of locations where the targets listed in this paragraph cannot be achieved within 5 years  

Airborne PM in Australia

Are you able to provide any relevant additional information on emissions and ambient PM concentrations in Australia that is not included in Chapter 5 of the Impact Statement?
The cost of delays in reducing air pollution has not been given sufficient weight.  Not implementing measures that could save 500 lives per year means that 1 or 2 additional unnecessary deaths for every day of delay in adopting the NEPM or equivalent legislation.

The problem and the case for government intervention

Please indicate the extent to which you agree or disagree with the following statement:
Government involvement is required to address emissions of and exposure to particles.

Statement of options
Please indicate the extent to which you agree or disagree with the following statement :
The AAQ NEPM framework is an important element of the suite of management actions to address air quality in Australia?

The current NEPM process is bogged down with bureaucracy and failed to meet the vitally important aims of minimising the risk from adverse health impacts of exposure to air pollution for all people wherever they may live (recommendation from the 2011 review) and of providing equivalent protection to all Australians wherever they live (original aim).
The AAQ NEPM framework should be an important element, but it has so far failed in this objective.   This review should recommend what changes and improvements are required to make the NEPMs an effective way to manage and improve air quality and protect the health of Australians.

Do you agree that the PM standards selected for analysis in the Impact Statement (including metrics, values and averaging times) are appropriate for Australia?
Yes.

Please indicate whether you consider the following options for the form of the standards outlined in the Impact Statement to be workable in Australia?
1)No change, i.e. the existing five annual exceedance days remains applicable for PM10, and would also apply to PM2.5 if a compliance standard is adopted.

2) A rule allowing a fixed number of exceedances (including zero) of a PM standard in a given year, based on the exclusion of exceptional events.
3) The 98th percentile PM10 and PM2.5 concentrations in a given year are compared with the respective standard with no exclusion of exceptional events.
3)
The 98th percentile PM10 and PM2.5 concentrations in a given year are compared with the respective standard and exceptional events are excluded.

All are workable, but some have higher benefit cost ratios than others

Is there any other information relating to the options for an exposure-reduction framework that should be considered
Formal Australia-wide adoption of all pollution-reduction measures identified as economically-feasible either in the NEPC economic analysis, or elsewhere (e.g. the additional $15 billion of net benefits from woodsmoke reduction measures not considered by the NEPC).  The introduction of polluter-pays taxes.   As a general principle, polluters should be required to pay the estimated health costs of their pollution.  This would discourage polluting activities and provide funds to monitor air pollution, evaluate and implement appropriate pollution-reduction strategies, assist people whose health is affected by air pollution, and cover costs to the health system. The lack of such taxes is forcing the general community to subsidize polluting activities.  National Clean Air Laws are needed to implement of all economically beneficial pollution-reduction strategies and avoid unnecessary delays and premature deaths.  Every day of delay causes another 1 or 2 unnecessary premature deaths.

Analysis of options

Have all health, economic and other impacts been identified in the Impact Statement?
Have all key assumptions been identified and included in the analysis of options in the Impact Statement?

If you would like to provide any final comments on any aspect of the Impact Statement, please feel free to do so here.

The economic analysis was deliberately conservative.  The benefits of reducing PM emissions are likely to be higher than the estimates in the economic analysis, and omitted $15 billion worth of health benefits from woodsmoke-reduction.  There is no reason to believe that a PM2.5 target of
6.0 μg/m3 (annual average) could not be achieved by implementing all economically feasible measures. 


 
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