17th April 2015
Submission to the Discussion Paper: ‘Working towards a National Clean
Air Agreement’
Summary of key points
 The 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 measures.
 Governments (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 governments.


Governments 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 direction
The 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 Inquiry1 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.
1
Senate Inquiry ‘Impacts on Health of Air Quality in Australia’ 16 August 2013
http://www.aph.gov.au/Parliamentary_Business/Committees/Senate/Community_Affairs/Completed_inquiries/
2010-13/airquality/report/index
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 production
Motor 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.2 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 Organization3 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. 4 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. 5
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). 6 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)7, particulates and silica8,9,10,11, propellants, occupational dust
exposure.12
2
Smit, R., 2014, Australian Motor Vehicle Emissions Inventory for the National Pollutant Inventory, Department
of the Environment, p.31 http://www.npi.gov.au/system/files/resources/e8311456-8a41-4473-9fa1d2f9994ff8da/files/australian-motor-vehicle-emissions-inventory-2014_0.pdf
3 International Agency for Research on Cancer, press release no 221 17 Oct 2013 - http://www.iarc.fr/en/mediacentre/iarcnews/pdf/pr221_E.pdf
4 Reducing Air Pollution from the Oil and Natural Gas Industry EPA’s Final New Source Performance Standards
and National Emission Standards for Hazardous Air Pollutants, April 17, 2012
http://www.epa.gov/airquality/oilandgas/pdfs/20120417presentation.pdf
5 http://toxtown.nlm.nih.gov/text_version/locations.php?id=150
6 A Kibble, T Cabianca, Z Daraktchieva, T Gooding, J Smithard,
G Kowalczyk, N P McColl, M Singh, S Vardoulakis
and R Kamanyire Review of the Potential Public Health Impacts of Exposures to Chemical and Radioactive
Pollutants as a Result of Shale Gas Extraction: Draft for Comment, PHE-CRCE-002
http://www.hpa.org.uk/Publications/Environment/PHECRCEReportSeries/PHECRCE002/
7 http://www.environmentalhealthnews.org/ehs/newscience/benzene-linked-to-sperm-abnormalities
8 www.osha.gov/dts/hazardalerts/hydraulic_frac_hazard_alert.htm
9 NIOSH Hazard Review, Health Effects of Occupational Exposure to Respirable Crystalline Silica. National
Toxicology Program [2012]. Report on carcinogens 12th ed. U.S. Department of Health and Human Services,
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)13 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. 14
The practice of flaring releases hydrogen sulphide, methane, BTEX 15 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.16
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-226.17 The level of reported
Public Health Service.
10 L. J. Bhagia, Non-occupational exposure to silica dust, Indian J Occup Environ Med. 2012 Sep-Dec; 16(3): 95–
100. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3683189/; Also see Fracking Sand May Pose Health Hazard
To Workers, Residents, 11/16/2012 7:25 pm http://www.huffingtonpost.com/2012/11/16/fracking-sand-healthhazard-_n_2146992.html; In Frac Sand Land, Residents Have Little Protection Against Silica Dust Exposure http://www.earthworksaction.org/earthblog/detail
in_frac_sand_land_residents_have_little_protection_against_silica_dust_expo
11 Queensland Gas Company Environmental Health Assessment Report Tara Complaint Investigation Report,
January 2013 Final REF: 0181432R01 (known as the ERM Report)
12 http://www.iarc.fr/en/media-centre/pr/2012/pdfs/pr213_E.pdf
13 Reduce Emissions and Operating Costs with Appropriate Glycol Selection HAROLD O. EBELING, Latoka
Engineering, L.L.C., Tulsa, OK LILI G. LYDDON, KIMBERLY K. COVINGTON, Bryan Research & Engineering, Inc.,
Bryan, Texas
http://www.bre.com/portals/0/technicalarticles/Reduce%20Emissions%20and%20Operating%20Costs%20with%
20Appropriate%20Glycol%20Selection.pdf
14 http://www.epa.gov/airquality/oilandgas/pdfs/20120417presentation.pdf
15 http://www.med.upenn.edu/ceet/documents_user/MarcellusShale_Penning3.pdf
16 Stohl, A., Klimont, Z., Eckhardt, S. et al. (2013). Black carbon in the Arctic: the underestimated role of gas flaring
and residential combustion emissions. Atmospheric Chemistry and Physics. 13: 8833–8855. Also see
http://ec.europa.eu/environment/integration/research/newsalert/pdf/349na5.pdf
17 Fact Sheet FS-163-97
October, 1997 Radioactive Elements in Coal and Fly Ash: Abundance, Forms, and
Environmental Significance, USGShttp://pubs.usgs.gov/fs/1997/fs163-97/FS-163-97.html; Note in 2014, Santos
coal seam gas project 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. See ‘Santos coal seam gas project contaminates
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. 18
Both radon and radium emit alpha particles, which are most dangerous when inhaled or
ingested. Radium is a known carcinogen19 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.20 Consuming radium in drinking
water can cause lymphoma, bone cancer, and leukemias.21 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,22 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. 23
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 dangerous
A human health risk assessment of air emissions around US UG activities, 24 concluded that
residents closest to well pads i.e., living less that 1/2 mile from wells, have higher risks for
aquifer’ SMH 2014 http://www.smh.com.au/environment/santos-coal-seam-gas-project-contaminates-aquifer20140307-34csb.html
18 http://www.world-nuclear.org/info/Safety-and-Security/Radiation-and-Health/Naturally-OccurringRadioactive-Materials-NORM/#.UTlc2qXfCcM
19 http://www.atsdr.cdc.gov/toxfaqs/tf.asp?id=790&tid=154
20 NRC. Health effects of radon progeny on non-lung-cancer outcomes. In: Health Effects of Exposure to Radon,
BEIR VI. Washington, DC:Committee on Health Risks of Exposure to Radon (BEIR VI), National Research Council,
National Academies Press (1999). http://www.nap.edu/openbook.php?record_id=5499&page=118
21 EPA. Radionuclides: Radium [website]. Washington, DC:Office of Radiation and Indoor Air, U.S. Environmental
Protection Agency (updated 6 March 2012). http://www.epa.gov/radiation/radionuclid
es/radium.html#affecthealth
22 Warner NR, et al. Impacts of shale gas wastewater disposal on water quality in western Pennsylvania. Environ
Sci Technol 47(20):11849–11857 (2013); http://dx.doi.org/10.1021/es402165b.
23 Santos coal seam gas project contaminates aquifer, SMH 2014 http://www.smh.com.au/environment/santoscoal-seam-gas-project-contaminates-aquifer-20140307-34csb.html
24 Lisa M. Mckenzie, Roxana Z. Witter, Lee S. Newman and John L. Adgate, Human health risk assessment of air
emissions from development of unconventional natural gas resources. Science of the Total Environment March
21, 2012
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 Justice
There 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. 25
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.26 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.27
Maternal exposure to air pollutants
As 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. 28 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.29 Early exposure to carcinogens can also increase the risk
of developing cancer later in life.30
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
25
World Health Organization / Children’s Environmental Health. http://www.who.int/ceh/en/
Also see IFCS Children and Chemical Safety Working Group. 2005. Chemical Safety and Children’s Health:
Protecting the world’s children from harmful chemical exposures - a global guide to resources, October.
26 Landrigan, P J et al. 1998. Children's health and the environment: A new agenda for prevention research.
Environmental Health Perspectives 106, Supplement 3:787-794.
27 Lloyd-Smith, Mariann; Sheffield-Brotherton, Bro, 'Children's Environmental Health: Intergenerational Equity in
Action—A Civil Society Perspective' Annals of the New York Academy of Sciences, Vol. 1140:1, pp. 190200(11) 2008
28 Olin, S. R. & B. R. Sonawane. 2003. Workshop to Develop a Framework for Assessing Risks to Children from
Exposure to Environmental Agents, September 2003. Environmental Health Perspectives 111/12: 1524-1526
29 Pluim, H.J., J.G. Koppe, K. Olie, J.W. van der Slikke, P.C. Slot, & C. van Boxtel. 1994. ‘Clinical laboratory
manifestations of exposure to background levels of dioxins in the perinatal period. Acta Paediatrica 83: 583-587.;
OIlsen A., J.M. Briët, J.G. Koppe, H.J Pluim, & J. Oosting. 1996. Signs of enhanced neuromotor maturation in
children due to perinatal load with background levels of dioxins. Chemosphere: 33(7), 1317-1326.
30 Barton, H. A., V. J. Cogliano, L. Flowers, L. Valcovic, R. W. Setzer & T. J. Woodruff. 2005. Assessing Susceptibility
from Early-Life Exposure to Carcinogens. Environ. Health Perspect. 13(9): 1125–1133
cord blood. 31 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. 32
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.33 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.
34
Environmental injustice
While 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.35 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 36 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.
31
Perera, Frederica P.; Tang, Deliang; Wang, Shuang; Vishnevetsky, Julia (2012). "Prenatal Polycyclic Aromatic
Hydrocarbon (PAH) Exposure and Child Behavior at age 6-7". Environmental Health Perspectives.
doi:10.1289/ehp.1104315. http://www.ncbi.nlm.nih.gov/pmc/articles/PMC3385432
32 Dr Philippe Grandjean MD & Philip J Landrigan MD, Neurobehavioural effects of developmental toxicity, The
Lancet Neurology, Volume 13, Issue 3, Pages 330 - 338, March 2014 doi:10.1016/S1474-4422(13)70278-3
http://www.thelancet.com/journals/laneur/article/PIIS1474-4422(13)70278-3/abstract
33 Zeliger HI, Unexplained cancer clusters: common threads. Arch Environ Health. 2004 Apr;59(4):172-6.
http://www.ncbi.nlm.nih.gov/pubmed/16189988
34 McKenzie et al., Birth Outcomes and Maternal Residential Proximity to Natural Gas Development in Rural
Colorado, Environ Health Perspect; DOI:10.1289/ehp.1306722 http://ehp.niehs.nih.gov/1306722/ )
35 Jayajit Chakraborty and Donna Green 2014 Australia's first national level quantitative environmental justice
assessment of industrial air pollution, Environ. Res. Lett. 9 044010 doi:10.1088/1748-9326/9/4/044010
36 David Brown, Beth Weinberger, Celia Lewis and Heather Bonaparte, 2014
Understanding exposure from natural gas drilling puts current air standards to the test, DOI 10.1515/reveh-20140002 Rev Environ Health
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 rewritten 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 tactic
The ‘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’.37 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 health
At 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:
a) Prioritisation of the pollutants and pollution sources that create the greatest health impacts;
and
37
See www.mckinsey.com/insights/sustainability/a_cost_curve_for_greenhouse_gas_reduction (Exhibit 1)
b) 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 Nation
The 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 Review38 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
38
National Environmental Protection Council, 2011, Ambient Air Quality NEPM Review, available at
www.scew.gov.au/resource/national-environment-protection-ambient-air-quality-measure-review-reviewreport
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.