YCAT urges community groups and individuals to make submissions to the review of Air Pollution standards
The 3068 Neighbourhood Group from Clifton Hill has made a submission with particular reference to the failing of the East West Link Comprehensive Impact Assessment to deal with Air Pollution from the project.
1. Background on making a submission: Proposed variation to the National Environment Protection (Ambient Air Quality) Measure in relation to the standards for particles
2. Public consultation: Submissions close 10 October 2014 and responses will be made publicly available unless marked as ‘confidential’. The responses will be considered in the development of a final proposal to vary the Ambient Air Quality NEPM.
3. How to make a submission: The Impact Statement and draft varied measure are now open for public comment and provide stakeholders with an opportunity to provide their views on the information and options presented.
4. Submissions can be made to the NEPC by completing an online questionnaire or in writing.
5. Submissions can be made in writing and addressed to: The Executive Officer, National Environment Protection Council, Department of the Environment, GPO Box 787, Canberra ACT 2601. Alternatively, submissions can be emailed to: NEPC@environment.gov.au
Additional information
ABC Science: Air quality standards ‘increase pollution and health risks’ ( 1 October 2014)
Deadly air pollution continues to be a problem in Australia because air quality standards are being misused, say experts. The standards governing six key outdoor pollutants are being interpreted as an acceptable upper limit of pollution, says health statistician Associate Professor Adrian Barnett of the Queensland University of Technology.
The Age: Final $6.8b East West Link design ignores government’s own expert planning advice (30 September 2014)
A 10-storey tunnel ventilation stack will be built in Collingwood, near homes and the Clifton Hill Primary School, despite the government’s project assessment committee saying it should be located hundreds of metres to the east.
Collingwood Air Pollution Lecture (17 September 2014)
On 17th September 2014, a presentation on the Health Impacts of Air Pollution was held for concerned parents in the Collingwood area. Collingwood has some of the worst traffic in Melbourne but the air quality is not regularly measured. Keele Street Creche now has monitoring but it is unclear if any results will be released to the public before the election.
The following guide to making a submission was prepared by Nature Conservation Council of NSW. This page is mirrored from Nature Conservation Council
NEPM AAQ variation 2014 – Guide for submissions
The aim of this document is to assist preparation of submissions to the Ambient Air Quality NEPM variation for people and organisations concerned with the health and environmental impacts of air pollution. Points have been contributed by Environmental Justice Australia, Nature Conservation Council of NSW and Doctors for the Environment Australia. In this document the Draft Varied National Environment Protection (Ambient Air Quality) Measure 2014 is referred to as the draft NEPM variation. The Draft Variation to the National Environment Protection (Ambient Air Quality) Measure Impact Statement is referred to as the impact statement.
Take action
Australia’s state, territory and Commonwealth governments are currently reviewing the national air pollution standards. Submissions close 10 October 2014 and will be considered in the development of a final proposal to vary the National Environmental Protection Measure (NEPM) for Ambient Air Quality.
- Read more about the review here.
Not enough is being done to prevent air pollution
Air pollution contributes to the premature death of over 3,000 Australians each year [1]. The serious health consequences from exposure to different sources of air pollution are now well established. There is international consensus that there is no ‘safe’ level of exposure for many pollutants, and that there are harmful effects from exposure at levels well below the current air quality standards.
The coal mining industry, Australia’s main source of particle pollution, has admitted their emissions grew by up to 187% during the last decade.
In many Australian communities, air pollution levels frequently exceed the current national standards without meaningful consequences for polluters. In other communities, inadequate monitoring means that we don’t know nearly enough about our exposure to harmful levels of air pollution. Without better pollution monitoring and enforcement and stricter licensing of polluters, many communities will continue to be put at risk[2].
The Council of Australian Governments (COAG) has accepted that current air quality laws are deficient, and in 2011 committed to developing and adopting a National Plan for Clean Air by the end of 2014. Despite COAG working on this reform since 2011, the Commonwealth Environment Minister recently announced that the plan would be delayed for another two years, until July 2016. Commonwealth and State and Territory governments are not treating air pollution with the seriousness and urgency it deserves.
Key points for NEPM variation submissions
Make the annual average PM2.5 standard a compliance standard of 6ug/m3 rather than an advisory standard. Science tells us that there is no safe level of PM2.5, so the lowest possible level should be chosen as the standard. This should be combined with a mechanism to drive exposure even lower. As noted in the impact statement “The greatest proportion (>99%) of the health costs accrue from avoiding premature deaths due to long-term exposure to PM2.5” (p.ix). Achieving 6 ug/m3 would reduce the estimated 1590 deaths in Sydney, Melbourne, Brisbane and Perth attributed to PM2.5 pollution by 34%, avoiding about 700 premature deaths.
Make the 24 hour PM2.5 standard a compliance standard of 20ug/m3 rather than an advisory standard. This is long overdue. The levels of 25ug/m3 or 20ug/m3 are proposed in the impact statement, although the draft NEPM variation itself lists 25ug/m3. 20ug/m3 should be adopted. The impact statement shows that 20ug/m3 is already being achieved at most monitoring sites on most days and so is achievable (p70). Reducing the peak exposures would have health benefits of less hospitalisations and less exacerbations of respiratory symptoms.
Establish an annual standard for PM10 of 20 μg/m3. There is good scientific argument for an annual PM10 standard on the basis of exacerbation of lung disease, reduction in lung function in both adults and children, and development of lung cancer from chronic exposure. There is no evidence that these risks are removed by controlling annual average PM2.5. WHO guidelines are for a 20 μg/m3 annual mean.
Improve the 24 hour standard for PM10 to 40 μg/m3. The impact statement notes that on average the current standard of 50ug/m3 is being achieved (p.69) and that a tightening of the standard could encourage future improvements in air quality (p.70).
Timeline for implementation: The draft NEPM variation (Part 2 Section 6) suggests allowing up to ten years for jurisdictions to comply with the standards. This ‘moratorium’ is unacceptable. State regulators should do everything within their powers to ensure compliance from the commencement of the NEPM.
The cleanest air possible: There is no threshold below which particle pollution has no adverse impact. Health experts are universally critical of the practice of managing ‘up to’ the national standards. The objective of the proposed NEPM is “ambient air quality that allows for the adequate protection of human health and well-being.” The expression “adequate” is open to interpretation and does not create a basis for a strong regulatory framework. The objective should be “ambient air quality that protects human health and well-being.”
Exposure reduction framework is needed: An exposure reduction framework is discussed in the impact statement but it does not appear in the draft NEPM variation itself. As the science is well established that current exposure is causing health problems, long term targets to progressively decrease exposure should be adopted.
Community involvement: For too long, community members and groups have been ignored in the policy process for developing, implementing and reviewing air pollution standards. Industry groups have been much more actively engaged than non-government groups and individuals. A protocol for community involvement should be negotiated and adopted, along the lines of the protocol that guided community involvement in the initial development of the NEPMs for Ambient Air and the National Pollutant Inventory.
Access to comprehensive and timely monitoring data: The NEPM should require state regulators (EPAs) to ensure easy and timely access to monitoring data including data from both EPA and industry monitoring. In the absence of meaningful enforcement action by state regulators, community access to data is often the main driver to reduce pollution. In many parts of Australia, monitoring data is difficult, expensive or impossible to access. The simplest arrangement would be the creation of one website where community members could access monitoring data from all states and regions in a standardised format. The NSW EPA air quality monitoring website is an excellent model for this. The monitoring plans and annual reports referred to in the draft NEPM variation (p.8, 10) should also be publicly available on a coordinated national webpage.
Protecting human health in small communities: The NEPM currently exempts smaller population centres from monitoring and reporting obligations – levels only need to be monitored for population centres over 25,000 people. Monitoring by population size alone is not adequate protection. This is particularly important for people whose health is threatened by industrial activity setting up close to established residential areas of smaller populations. There should be stronger requirements for monitoring in small towns or suburbs where there is reason to believe that standards are being exceeded. The NEPM should require monitoring and reporting for both PM2.5 and PM10 in population centres of 5000 or more, particularly communities known or expected to experience high pollution levels.
The NEPM should also provide clear direction to States on the matter of where to monitor rather than leaving this to the discretion of state regulators (e.g. the draft NEPM variation states “additional performance monitoring stations may be needed” (p.9) but leaves it up the jurisdiction to determine whether to do so). An exposure reduction and continuous improvement model is recommended for all exposed populations.
Australia’s federated policy processes: Institutional arrangements for developing, implementing and monitoring Australia’s air pollution control laws are failing. The Council of Australian Government’s Standing Committee on Environment and Water (SCEW) was disbanded in December 2013 and no alternative arrangement has been put in place. The National Environment Protection Council is under-resourced to the extent that it has inadequate capacity to manage this consultation. One consequence of these short-comings is that the NEPM review has been stalled for years and the national Clean Air Action Plan (or Agreement) has been postponed despite its agreed urgency. A strong and proactive approach to air pollution prevention requires robust and well-resourced institutional arrangements capable of decisive policy intervention.
The variation must be finalised without delay. Government representatives have indicated that the aspirational timeframe to make the variation is mid 2015, or longer. Having considered standards for PM2.5 for over a decade, there is no reason for the National Environment Protection Council to continue to delay. All State, Territory and Commonwealth Governments must ensure the NEPC adopts this variation as a priority – by the end of 2014.
New research and policy development is needed for the future: There is growing concern internationally about the health impacts of ultrafine particles. The 2011 review of the NEPM noted that there was not enough data to make a standard for ultrafine particles. The National Environment Protection Council should investigate including a reporting standard for ultrafine particles so we can better understand their impact on health. Similarly an 8 hour standard for all particulates should be considered as a new policy measure to better capture the significant short term impacts that can occur.
The proposed variation is only part of the solution. National air pollution prevention laws are needed.Australia’s current system of policies and laws to prevent and control air pollution, including the Ambient Air NEPM, are failing. The national air pollution standards adopted in 1998 are breached regularly, particularly in coal-affected communities. States currently do not take adequate steps to ensure the standards will be met through their laws, policies and licencing arrangements. A stronger set of national policies and laws are required to protect community health. The NEPM variation is a welcome but inadequate step toward effective air pollution laws. Commonwealth leadership to develop national air pollution prevention laws is needed as a priority.
[1] Begg, Vos, Barker, Stevenson, Stanley & Lopez, The burden of disease and injury in Australia 2003, Australian Institute of Health and Welfare, Cat. no. PHE 82, Canberra (2007), p234, available here.
[2] Environmental Justice Australia, Clearing the Air: Why Australia Urgently Needs Effective National Air Pollution Laws, May 2014
