Submission to the Discussion Paper: ‘Working towards a ...



17th April 2015Submission to the Discussion Paper: ‘Working towards a National Clean Air Agreement’Summary of key pointsThe facilitating framework and principles for the Agreement need to be re-written to require governments to give priority to pollution sources which are the greatest contributor to pollution levels and/or have the biggest impact on human health in Australia.Cost benefit analysis should not be used to delay action on priority issues, but should be used as a tool to determine which pollution control measures will provide the greatest reduction in pollution for the money spent.The Agreement principles must prioritise action on human health rather than considerations about the burden on polluters. Priority should be given to the pollutants and pollution sources that create the greatest health impacts; and pollution sources that create a disproportionate and unfair burden on certain communities such as coal mining, coal fired power stations and unconventional gas mining.Measuring is not controlling. We need to revise standards and control measures and fines (and perhaps even jail terms) for those industries (and those responsible within companies) that exceed these control ernments (Federal and States) must include clear measures in the work plan before the Agreement is finalised that will result in significant reductions in pollution levels in Australia to protect human health.The NPI must be strengthened and appropriately resourced to ensure all significant sources are reported including coal stockpiles, coal transport and unconventional gas; and that the data is available in such a way that it can be properly utilised and understood by the community, as was its original intention.The Agreement should commit to implementation of the recommendations from the Ambient Air Quality NEPM Review and the Senate Inquiry ‘Impacts on health of air quality in Australia’.Instead of being silent the Government needs to make available Appropriate funding and resources to tackling air pollution by all Australian ernments need to recognise the inherent problems in our current approach to air pollution regulation, including the NEPMs, and begin to move towards a system of national clean air laws.NTN suggests instead that:Air pollution measures become need to be nation-wide and binding.Nation-wide regulations that prevent emissions increasing. Expand the National Environment Protection (Ambient Air Quality) Measure to ensure that polluters comply with these standards and that community members can access monitoring data. A (very small) step in the right directionThe Discussion Paper notes that particle pollution and ozone concentrations frequently exceed national pollution standards in some urban and regional areas, and that the health bill of Australia’s unchecked pollution problem is now $24.3 billion. With a rapidly growing population, it is urgent to effectively control pollution. The discussion paper also rightly points out that “…. outdoor air pollution and particulate matter (PM) – present in both outdoor air pollution and diesel exhaust - as causes of lung cancer. Furthermore, for PM, there is no evidence of a threshold below which no adverse health effects occur ….meaning that the impacts from exposure may be seen even when current air quality standards are being met.” The Clean Air Agreement is a positive step toward controlling pollution and improving air quality. The ministers propose to base the Agreement on a set of principles that include evidence-based decision-making, effective consultation, a commitment to best-practice pollution control and periodic review. The National Toxics Network welcomes these proposed principles and considers them a minimum working environment.However we are very disappointed that the Discussion Paper provides scant details on how exactly Australian governments will achieve this aim. It also contains no measures beyond actions that have already been announced by governments. As a community we are very concerned about air pollution, and demand that the Federal Government and the States commit to measures that will reduce the sources of pollution that most affect our health and the environment. Clearly given the discussion papers admission of the dangers of air pollution, acceptable levels especially for PM should be zero or very close to it.Setting the right priorities. The priorities for pollution control strategies should reflect the relative contribution of various pollution sources, and the health impacts of those sources. The Agreement’s facilitating framework and principles should require governments to prioritise those pollution sources which are the greatest contributor to pollution levels and/or have the biggest impact on human health in Australia.The discussion paper notes that particle pollution (PM) is a significant problem. Measures to reduce PM2.5 emissions are especially important. A 2013 Senate Inquiry heard evidence that PM2.5 emissions are “the most health-hazardous air pollutant, responsible for 10 to 20 times as many premature deaths as the next worst pollutant, ozone”.In addressing fine particle pollution, the discussion paper proposes to prioritise tackling wood heaters and non-road spark engines and equipment and to strengthen the reporting standards for PM under the National Environment Protection (Ambient Air Quality) Measure, but contains no specific measures to tackle PM emissions from the biggest sources of pollution, that have the biggest impact on human health.Importantly measuring is not controlling. We need to revise standards and control measures and fines (and perhaps even jail terms) for those industries (and those responsible within companies) that exceed these measures.Focus on those pollution sources that will make the biggest difference to our Nation’s health – coal and unconventional gas productionMotor vehicles are singled out as a priority. Motor vehicles accounted for approximately 17% of total national PM2.5 emissions in 2010, and just over 1% of PM10 emissions. By contrast, coal-fired power stations are responsible for 31% of total national PM2.5 emissions and coal mines for 23%. Coal mines are responsible for 46% of Australia’s total PM10 emissions - 30 times as much as all of Australia’s motor vehicles. And yet there is no mention of coal mines or coal-fired power stations in the Agreement. NTN would like to especially focus on the effects of airpollution due to unconventional gas production.In 2013, the World Health Organization declared that outdoor air pollution is carcinogenic. It had long been accepted that air toxics associated with oil and gas extraction activities can cause cancer and other serious, irreversible health effects, such as neurological problems and birth defects. In 2012, the USEPA stated that the oil and gas industry is the largest industrial source of VOC emissions in the U.S. Once considered a summertime pollutant, ozone had now become a problem in winter in areas with significant natural gas production. The US National Library of Medicine notes that operations at gas fields emit a wide range of pollutants including nitrogen oxides, volatile organic compounds (VOCs), carbon monoxide, sulfur dioxide, and particulate matter. Air emissions come from several sources in gas fields, including equipment engines, drilling rigs, pumpjacks, boilers, heaters, generators, combustion flares, storage tanks, injection pumps, dehydrators, vehicles, and oil and gas skimmers. They note that one of the major sources of air emissions at gas fields are compressor stations that move natural gas through pipelines and gas processing plants.The United Kingdom's Public Health Association also identified UG activities as sources of air pollution by primary pollutants such as oxides of nitrogen (NOx) and particulate matter (PM) and the precursors of secondary pollutants such as ozone (O3). They highlighted a diverse range of sources and air pollutants associated with the unconventional gas industry, which all have the potential to either cause cancer or other serious helath problems including: carbon monoxide, sulfur dioxide, hydrogen sulfide, nitrogen oxides, VOCs, BTEX (benzene, toluene, ethylbenzene, xylene), particulates and silica,,,, propellants, occupational dust exposure.While the primary component of natural gas is methane, it typically contains other hydrocarbons such as ethane, propane, butane, and pentanes and in some cases, may also contain hazardous air pollutants such as BTEX, hexanes, hydrogen sulphide, and carbon dioxide. Fugitive emissions associated with leaks from pumps, flanges, valves, pipe connectors etc. can include methane with these other gases. Gas Processing, which is required to remove impurities before natural gas can be used produces many by-products including ethane, propane, butanes, pentanes and higher?molecular?weight hydrocarbons, hydrogen sulphide, carbon dioxide, water?vapour and sometimes helium and nitrogen. These are often vented to the atmosphere, providing an important point source of air pollution from the industry. Dehydration units based on the ethylene glycols eg triethylene glycol (TEG), diethylene glycol (DEG) are also a likely source of BTEX emissions, and compressor stations have been shown to be a significant source of carbon monoxide and nitrous oxides as well as VOCs.Flaring (the burning off of natural gas from a new well) is a common practice in the gas fields and is recognised for its direct release of air pollutants. The USEPA has effectively banned gas flaring in most cases after January 2015 due to growing concerns over air pollution. The practice of flaring releases hydrogen sulphide, methane, BTEX and other contaminants associated with methane. Gas flaring is also recognised as a significant source of soot, or black carbon, pollution in the Arctic, with new research indicating that flaring from oil and gas developments is the largest source of this pollutant, responsible for 42% of black carbon pollution in the Arctic. Particulate matter, as well as being a carcinogen, has widespread adverse health impacts including heart attacks, strokes, diabetes, asthma, hypertension and renal disease amongst others. PM also provides an effective pathway for other contaminants such as heavy metals and radioactive substances into the broader environment. Naturally occurring radioactive materials (NORMs) are found in both coal seams and shale, eg uranium, thorium and their progeny radium-228 and radium-226. The level of reported radioactivity varies significantly, depending on the radioactivity of the reservoir rock and the salinity of the water co-produced from the well. The higher the salinity the more NORM is likely to be mobilized. Since salinity often increase with the age of a well, old wells tend to exhibit higher NORM levels than younger ones. Both radon and radium emit alpha particles, which are most dangerous when inhaled or ingested. Radium is a known carcinogen and?exposure can result in increased incidence of bone, liver and breast cancer.? When inhaled, radon can cause lung cancer, and there is some evidence it may cause other cancers such as leukemia. Consuming radium in drinking water can cause lymphoma, bone cancer, and leukemias. Radium also emits gamma rays, which raise cancer risk throughout the body from external exposures. Radium-226 and radium-228 have half-lives of 1,600 years and 5.75 years, respectively. Radium is known to bioaccumulate in invertebrates, mollusks, and freshwater fish, where it can substitute for calcium in bones. UG activities such as drilling, fracking, removal of produced water, earthworks and transport result in radioactive substances being remobilized and relocated either via waste water, ‘bonding’ with particulates or via resuspension in air. Direct particle fallout, as well as washout from rain then provides an effective pathway for these contaminants to find their way into the wider environment and onto rooftops and into domestic water tanks. Radon-222 a decay product of Radium-226 also follows the gas lines and decays (through several rapid steps) to Pb-210, which can build up as a thin film in gas extraction equipment. In 2014, Santos coal seam gas project in the NSW Pilliga Forest was found to have contaminated aquifers with Uranium at 335 micrograms per litre, which is 20 times the Australian Drinking Water guideline of 17 ug/l. As nearly all uranium is in the form of Uranium 238, its detection well above drinking water levels should have prompted immediate testing for radionuclides in the groundwater such as Radium 226 and Radon 222, which are far more harmful to living organisms. Unfortunately, testing for radioactivity did not occur. Human Health Risk Assessment of air emissions – living near wells is dangerousA human health risk assessment of air emissions around US UG activities, concluded that residents closest to well pads i.e., living less that 1/2 mile from wells, have higher risks for respiratory and neurological effects based on their exposure to air pollutants; and a higher excess lifetime risk for cancer. The study took 163 measurements from fixed monitoring station, 24 samples from perimeter of well pads (130-500 feet from center) undergoing well completion and measured ambient air hydrocarbon emissions. Emissions measured by the fenceline at well completion were statistically higher (p ≤ 0.05) than emissions at the fixed location station (inc. benzene, toluene, and several alkanes.) The study may have underestimated risks to human health as it did not measure ozone or particulates. The USEPA methods used may also underestimate health risks of mixed exposures. Sampling around UG activities in Australia have shown the presence of BTEX including benzene on which the cancer risk was primarily based. Vulnerable Populations and Environmental JusticeThere are many children living in communities in close proximity to UG activities who are at particular risk from pollutants, due to the unique vulnerability of children to hazardous chemicals which is well recognized by WHO, UNICEF and UNEP. Children’s bodies are still developing, their detoxification systems are immature and their protective biological barriers such as the blood-brain barrier are still developing. They are also more at risk because they have higher respiration and metabolic rates than adults, they eat and drink more per bodyweight, and they live life closer to the ground, crawling, digging in dirt and putting objects in their mouths. Being unaware of chemical risks, children are less able to protect themselves from exposures and higher skin absorption rates may also result in a proportionally greater exposure. Maternal exposure to air pollutantsAs the placenta is not an effective barrier to chemical transfer from mother to the foetus and toxins can be transferred through breast milk as well, maternal exposure to air pollutants is very important. The timing of chemical exposures is significant. Research has shown that babies and children experience particular “windows of susceptibility” in their development. If exposures occur during critical times, it may contribute to health problems much later in life; for example, exposure to dioxin in utero can produce disabilities in neurological function and learning ability well into childhood. Early exposure to carcinogens can also increase the risk of developing cancer later in life. Similarly, early exposure to endocrine disrupting chemicals can affect an individual’s immune function or ability to reproduce. Some like the polycyclic aromatic hydrocarbons (PAHs) detected in urine of Tara residents and in the air around their homes are known to affect the endocrine system at extremely low levels with children and unborn babies the most vulnerable. Babies with elevated PAHs in their umbilical cord blood were much more likely to eventually score highly on the anxiety/depression scale than those with low PAH levels in cord blood. In utero and in early infancy, pollutants can cause permanent brain damage at levels of exposure that would have little or no adverse effect in an adult. Mixtures of chemicals have been implicated in cancer clusters, where the individual chemical would have been assumed to be safe at that level of exposure. In 2013, US researchers observed a positive association between the proximity of pregnant mothers to shale gas development and its density and the prevalence of congenital heart defects and possibly neural tube defects in their newborns. Environmental injusticeWhile environmental justice refers to the distribution and impacts of environmental problems and focuses on the right to a safe, healthy, productive and sustainable environment, environmental injustice describes the inequitable distribution of those who bear the risks. A spatial analysis of NPI pollution sources, their emissions and social disadvantage communities including those with indigenous status has revealed a clear pattern of environmental injustice. Researchers found that communities with the highest number of polluting sites, emission volumes, and toxicity-weighted air emissions had greater proportions of indigenous population and higher levels of socio-economic disadvantage. Like many other disadvantaged groups around Australia, the Tara community, appear to be disproportionately impacted by UG air pollution and have born the inequitable risks of UG development in the state of Queensland. The community has called for comprehensive air and water monitoring but this has not been done. Even if this was carried out a recent study examining exposure from natural gas drilling and current air standards concluded that current protocols used for assessing compliance with ambient air standards do not adequately determine the intensity, frequency or durations of the actual human exposures to the mixtures of toxic materials released regularly at UNGD sites. They note that the typically used periodic 24-hour average measures can underestimate actual exposures by an order of magnitude and that reference standards inaccurately determine health risk because they do not fully consider the potential synergistic combinations of toxic air emissions. They make a number of recommendations none of which have been implemented in assessing Tara residents exposure to air pollutants. Regulatory authorities are aware that Australia’s environmental health guidelines do not take into account low-level, chronic exposure to environmental contaminants, particularly those that demonstrate endocrine and epigenetic impacts. Comprehensive environmental health impact assessments taking into account all exposure routes should have been carried out before any approval was given for UG activities, yet not even the most basic health impact assessment was undertaken, despite the growing warnings from researchers and respected regulatory agencies. The risks experienced by the residents impacted by UG activities remain unclear but there is growing evidence of serious health implications from UG. It is time for all Australian governments to heed the warning of the United Nations Environment Program and acknowledge that monitoring and regulatory safeguards around unconventional gas exploration and production still cannot remove the threat of adverse impacts to air quality and to the health of all those exposed. NTN suggests that the facilitating framework and principles for the Agreement must be re-written to require governments to give priority to pollution sources which are the greatest contributor to pollution levels and/or have the biggest impact on human health in Australia: coal and unconventional gas production.Cost - benefit analysis must not be used as a delaying tacticThe ‘facilitating framework’ for the National Clean Air Agreement should be based on a rigorous and transparent assessment of the costs of pollution and the benefits of pollution reduction. Pollution sources, substances and problems should be assessed according to their social, environmental and economic costs, and potential solutions and strategies should similarly be assessed according to their benefits. However cost benefit analysis should not be used to delay action on reducing the pollutants or pollution sources that have been prioritised as requiring action. Rather, once those priority pollutants or pollution sources have been identified, it should be used to assess which pollution control measures will product the most benefit for the investment.For example, Greenhouse gas abatement measures are often assessed using the ‘McKinsey cost curve’. The benefit of this systematic approach is that it readily differentiates between pollution control approaches that will have greatest ‘bang for the buck’ and those that - while popular or politically acceptable - will have minimal benefit in reducing pollution levels. Cost benefit analysis should not be used to delay action on priority issues, but should be used as a tool to determine which pollution control measures will provide the greatest reduction in pollution for the money spent.Prioritising human healthAt present the principles of the Agreement have a significant focus on ‘reducing regulatory burden’, ‘allowing for sufficient lead in times’ and ‘minimising disruptions that may result from policy changes’. This is false economy (at a huge cost to the Nation’s health) and an ideologically driven approach to the management of air pollution. The community’s expectation is that the governments prioritise actions that protect human health, ahead of corporate profits. As is clear from the significant health costs associated with air pollution, prioritising human health will also have significant economic (and environmental) benefits. In determining which human health impacts to prioritise, the principles should require: Prioritisation of the pollutants and pollution sources that create the greatest health impacts; and Implementation of ‘environmental justice’ principles whereby pollution sources that create disproportionate health impacts on certain communities, resulting in those communities bearing an unfair burden from pollution, should have targeted action, regardless of whether the number of people affected is at a smaller scale (e.g. lead affected communities).The Agreement principles must prioritise action on human health rather than considerations about the burden on polluters. Priority should be given to the pollutants and pollution sources that create the greatest health impacts; and pollution sources that create a disproportionate and unfair burden on certain communities coal and unconventional gas.Focus on measures that have the biggest impact on pollution levels and human health. As noted above, the Agreement should prioritise actions that will address the biggest sources of pollution and/or the sources that are creating the greatest health impacts. In light of this, the proposed work plan needs to be significantly improved. The work plan currently includes measures that have already been announced and/or are underway, and has not been developed with any regard to what measures need to be prioritised to reduce Australia’s pollution levels to protect human and environmental health. Australian governments must no longer ignore the most significant sources of pollution, and those which are having the biggest impact on human health. Most of the measures in the work plan have been discussed and delayed for years. Governments must end the delay, deal with those issues as quickly as possible and focus attention on the sources of pollution that are the most significant. Governments must include clear measures in the work plan before the Agreement is finalised that will result in significant reductions in pollution levels in Australia to protect human health.Using a Federated approach to get an outcome for the whole NationThe Discussion Paper (pages 5-6) notes that states and territories have primary responsibility for environmental management and proposes no significant measures to strengthen nation-wide strategies. This is a clear failing in the Federal Governments responsibility for the whole Nation. The Discussion Paper proposes to leave each jurisdiction to deal with emissions from non-road diesel engines, wood smoke and shipping. This approach has already failed for decades and a strong national approach is necessary. Most companies contributing significantly to these emissions operate nationally, so a consistent national approach is necessary. Key issues are:At present, Australian state and territory governments are failing to control air pollution. Current non-binding national air pollution measures are not assisting in reducing pollution levels. The National Environmental Protection (National Pollutant Inventory) Measure ensures a consistent approach to reporting toxic emissions, but does nothing to prevent emissions increasing. Likewise, the National Environment Protection (Ambient Air Quality) Measure sets nationally consistent standards for six pollutants and ensures a more or less comparable approach to monitoring air pollution concentrations in Australian cities, but does nothing to ensure that polluters comply with these standards or that community members can access monitoring data. In some states (especially Western Australia) even accessing monitoring data is difficult. Our Commonwealth Government must do more. Governments should recognise the inherent problems in our current approach to air pollution regulation, including the NEPMs, and begin to move towards a system of national clean air laws.NTN suggests instead that:Air pollution measures become need to be nation-wide and binding.Nation-wide regulations that prevent emissions increasing. Expand the National Environment Protection (Ambient Air Quality) Measure to ensure that polluters comply with these standards and that community members can access monitoring data. Unfinished business: implementation of previous findings, funding and better data access for the community The discussion paper makes no reference to two recent government reviews, or the recommendations they contained to strengthen Australia’s approach to pollution control. We recommend that the Agreement include a commitment to implementing the 23 recommendations of the 2011 Ambient Air Quality NEPM Review and the 13 recommendations of the 2013 Senate Inquiry ‘Impacts on Health of Air Quality in Australia’ which included covering coal wagons.The Agreement should commit to implementation of the recommendations from the Ambient Air Quality NEPM Review and the Senate Inquiry ‘Impacts on health of air quality in Australia’.Strengthening the National Pollutant Inventory The NPI is Australia’s most comprehensive database reporting emissions of toxic substances to air, land and water. Unlike emission reports and estimates managed by states and territories, the NPI provides comparable, timely and systematically organised data for significant pollution sources. To achieve its purpose, however, the NPI requires improvements such as:The inclusion of particle emissions from uncovered coal stockpiles (at export terminals) and uncovered coal wagons. In communities such as Newcastle, Mackay and Gladstone, these are potentially significant sources of PM10 and other toxic substances?The inclusion of emissions from coal mines in the Latrobe Valley and other locations where the managers of coal-fired power stations also operate mines. Currently, mine emissions are incorporated into estimates of emissions from the coal-fired power stations they fuel rather than being separately reported. The NPI cannot improve emission reduction if it conflates pollution sources.The inclusion of PM2.5 emissions from wood heaters which are - in some airsheds - the dominant source of fine particles.The capacity to generate reports that track emissions from multiple sources over multiple years in order to identify trends. (E.g. All Australian coal mines for 5 years, or a specific power station over 10 years). Currently, the ‘form’ function on the NPI website can only generate a report for a single year.The NPI must be strengthened and appropriately resourced to ensure all significant sources are reported including coal stockpiles, coal transport and wood heaters; and that the data is available in such a way that it can be properly utilised and understood by the community, as was its original intention.Uncertain funding Air pollution kills more Australians than motor vehicle accidents, and costs the health system billions. But the Discussion Paper is silent on how pollution control measures will be funded, beyond citing two irrelevant programs. The $2.55 billion in Commonwealth Government support for the Emissions Reduction Fund (p.3) relates to CO2 emissions is not relevant to a strategy that aims to reduce toxic air pollution. Environment ministers must commit appropriate funds to pollution control, reflecting the significant costs of pollution on the community. Appropriate funding and resources must be committed to tackling air pollution by all Australian governments.All governments must give air pollution the priority it deserves, end ongoing delays and commit to measures to reduce the most significant sources of pollution as a priority. ................
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