On 25 January 2018, EPA released the policy impact assessment (PIA) for a proposed variation to the Waste Management Policy (Solid Fuel Heating) (“current policy”) and a consolidated version of the policy with proposed changes incorporated. The proposed variation would incorporate the efficiency standard into this policy and give practical effect in Victoria to measures agreed as part of the National Clean Air Agreement (NCAA).
EPA invited public submissions on the proposed changes. The consultation period commenced on 25 January and closed on 16 May 2018. EPA received 17 submissions on the PIA and proposed variation.
The variation to the Waste Management Policy (Solid Fuel Heating) was made and came into effect on 2 October 2018.
The NCAA was established by Environment Ministers in December 2015. A commitment of the NCAA was for all jurisdictions to adopt the new emissions (AN/NZS 4013:2014) and efficiency (AN/NZS 4012:2014) standards for wood heaters.
The emissions standard has been incorporated into the current policy since 2004. In 2017, EPA published its notice of intent to vary the current policy and began preparing the PIA. The primary purpose of the PIA is to determine whether Victoria should adopt the efficiency standard as a mandatory requirement for all new wood heaters in Victoria. The decision to be made was whether to:
- incorporate the efficiency standard into the Waste Management Policy (Solid Fuel Heating), or
- not incorporate the standard.
The PIA assessed the costs and benefits of adopting the efficiency standard in Victoria. The PIA demonstrates that incorporating the efficiency standard will have benefits to air quality, and that these benefits significantly outweigh the costs.
EPA received 17 submissions on the PIA and the proposed variation from a range of stakeholders, including the peak industry body representing the solid fuel heating industry, community members and other interested parties.
The PIA noted that the proposed variation would place a marginal increased economic burden on suppliers and manufacturers of solid fuel heaters, likely to be passed on to consumers and recovered through a slight increase in price for a new wood heater. No submissions were received from suppliers or manufacturers of solid fuel heaters, or any person identifying as a prospective consumer. A submission was received from the peak industry body representing the solid fuel heating industry
Consideration of feedback and EPA’s response
EPA considered all submissions received. In considering submissions, EPA maintained a focus on the objective and scope of the proposed variation, and on the degree of impact that would be imposed on different sectors of the public.
The majority of the submissions received raised concerns that the scope of the variation does not address all the impacts on human health from the use of solid fuel heaters. However, as noted through the notice of intent to vary the current policy, the objective of this variation is to incorporate the efficiency standard in accordance with the NCAA. Consequently, the proposed policy does not make any changes in response to matters raised outside the scope of this variation.
EPA considered all comments received on the proposed changes. As a result of comments raised, a change was made to enable IANZ accredited laboratories, the equivalent to NATA in New Zealand, to test a solid fuel heater in accordance with the standard.
A further change was made to the drafting of clause 10, supply of solid fuel heaters. The change in drafting provides more clarity and makes it easier for a supplier to know and be able to demonstrate that the solid fuel heater they are supplying is complaint.
Nevertheless, EPA acknowledges that community members impacted by wood smoke are strongly engaged in the issue, and this is reflected in the submissions received. Amongst the various issues raised the most prominent recurrent themes were: that wood heater emissions are harmful to human health; and the continuing need for further action to address emissions from wood heaters.
The health impacts of wood smoke are well documented. The incorporation of this standard will lead to an incremental improvement in air quality. EPA acknowledges that adopting the standard alone will not address all impacts from wood heaters (it will set minimum design requirements for appliances requiring them to be more efficient). Opportunities to further address impacts from wood heaters may be explored at a whole of government level, with the Victorian Government investing $1.2 million to develop a Victorian Air Quality Strategy in 2019.
In May 2018, the government released Clean Air for all Victorians, Victoria’s air quality statement. The statement acknowledges the need to better address poor air quality hot spots, such as locations subject to excessive wood smoke, and explore methods and opportunities to address these. This was released as a starting point for engagement with the Victorian community about priorities for future air quality management. Consultation on the air quality statement will be followed by a clean air summit and series of workshops. This process will inform the drafting of the Air Quality Strategy.
The Victorian Air Strategy will articulate clear, sustainable and cost-effective approaches the government will use to monitor and manage air quality over the next decade.
The table below sets out key themes from the submissions and EPA’s commentary.
|Health impacts from wood heaters
||EPA recognises that wood heaters are a contributor to air pollution, especially particulate matter, which is known to cause significant adverse health impacts.
Chapter 2 of the PIA discusses the range of health impacts associated with particulate matter.
As there is no clear level below which adverse health effects from particulate matter would not be observed, any reduction in ambient air concentrations of particulate matter will improve health benefits and reduce population exposure and risk. The PIA estimates that the incorporation of the efficiency standard will result in 671 tonnes of avoided particulate matter emissions over the life of the policy.
Health benefits from lower emissions will vary between regions due to climatic, meteorological, demographic and population exposure factors. Though greater health benefits can be expected in areas of higher population density, where higher numbers of individuals are likely to be affected by any reductions in exposure. Similarly, improvements in air quality in regional areas are expected to realise improved health outcomes, albeit to a lower degree.
|Inadequate policy response
||The objective of the variation to the current policy is to incorporate the efficiency standard into the Victorian legislative framework. As such, the question under consideration is whether to adopt the efficiency standard into the waste management policy or not adopt the standard into the waste management policy. As noted on page 17 of the PIA, other options were discussed for comparative purposes.
This current policy work is focused on adopting the efficiency standard to ensure Victoria meets the commitment of the NCAA, as agreed by all Environment Ministers. This will help to reduce emissions across the State and provide an incremental improvement in air quality.
The adoption of the efficiency standard will provide an incremental improvement, though it is acknowledged that adopting the standards alone won’t address all impacts from wood heaters. The adoption of options, other than mandating the efficiency standard for solid fuel heaters manufactured and supplied in Victoria, was not within the scope of this variation. These may be explored at a whole of government level through the development of the Victorian Air Quality Strategy.
|Limiting use of wood heaters
||The options of banning, restricting or phasing out wood heaters was not within the scope of this policy variation. The purpose of this PIA was to assess whether to incorporate the efficiency standard into the current policy or not.
The options of increasing the replacement rate of old wood heaters and banning the sale of new wood heaters, were included as alternative options for comparison purposes.
As discussed in chapter 6, of the PIA while taking actions to increase the replacement rate of existing heaters has a higher net benefit in dollar terms, this is only because of the scale of the option. It has the worst benefit-cost ratio and the highest cost per tonne of avoided particulate matter.
Banning the sale of new wood heaters would likely result in the ongoing use of older, less efficient models. It should be noted that many people rely on wood heaters as their sole source of heating during the colder months.
The Government is working with Victorians to secure a clean air future with its commitment to release a comprehensive Victorian Air Quality Strategy in 2019. The Government commenced consultation with Victorians to inform the Strategy's development, through Clean Air for All Victorians: Victoria’s Air Quality Statement, and a Clean Air Summit in August 2018. These processes will look at various options to secure a clean air future for Victorians.
|Difficulty addressing emissions from wood heathers on neighbouring properties
EPA is aware that impacts of wood smoke from a neighbour’s property can be difficult to resolve. It is also evident that these impacts are experienced more frequently in densely populated urban areas where houses are in closer proximity to each other.
Local councils have powers under the nuisance provisions of the Public Health and Wellbeing Act 2008. EPA provides advice on its website about what to do if people have concerns about smoke from their neighbour’s wood heater.
Addressing these issues is beyond the scope of the variation to the current policy and is likely to require a whole of government approach. The Victorian Air Quality Strategy may provide an opportunity to explore the most effective and appropriate measures to address this particular problem.
|Localised wood smoke and the inequity of urban vs rural impacts
||EPA acknowledges that the impacts of wood smoke are experienced differently and at different scales, with a range of factors influencing their prevalence. The incorporation of the efficiency standard will result in a reduction in particulate matter and is expected to have a net benefit in all areas.
The problem of localised smoke was out of scope for consideration as part of this policy variation. However, the Victorian Government acknowledges that some locations are subject to localised air pollution issues such as excessive wood smoke. The Clean Air Statement provided an initial means for engaging with interested parties on this. The Statement discusses exploring options for improving protections for vulnerable Victorians in locations with poorer air quality, such as those subject to excessive wood smoke.
|Discrepancy between real-life emissions and AS/NZS 4013 tested emissions
||Several comments noted that real-life emissions are often different to emissions measured in accordance with AS/NZS4013. The PIA recognises that real life usage may be different to that in a controlled laboratory setting. Modelling assumptions are explained in Appendix B of the PIA. Consideration was given to the different emissions factors depending on the age of a heater, the proportion of these in place and different operation types. The average emission factor reflects these considerations.
It is important to note that this PIA assesses the costs and benefits of incorporating the efficiency standard (AN/NZS 4012). The emissions standard is already incorporated into the Waste Management Policy (Solid Fuel Heating)
|Concerns about the AS/NZS
||The decision for all jurisdictions to incorporate the Australian Standards for emissions and efficiency was made at a National level by Environment Ministers. Environment Ministers considered a Decision Regulation Impact Statement, which examined options to reduce emissions from wood heaters in Australia. The preferred option agreed by ministers was the adoption of new Australian Standard emission and efficiency standards for new wood heaters and sharing best management practices across jurisdictions.
The purpose of the PIA was to assess the costs and benefits of incorporating the nationally agreed efficiency standard into the Victorian Waste Management Policy (Solid Fuel Heating). As noted in the PIA, there is a rigorous process for changing Australian Standards, including consultation with industry and governments.