Standards and monitoring of air quality
Government involvement in establishing air quality standards to protect
human health is important as individuals cannot readily control the extent to
which they may be exposed to harmful air-borne pollutants.
On 26 June 1998 the Commonwealth and State and Territory governments
agreed to the National Environmental and Protection Measure for Ambient Air
Quality (NEPM). This measure sets air quality standards that are legally
binding on each level of government. The desired environmental outcome from the
NEPM is achieving 'ambient air quality that allows for the adequate protection
of human health and well-being.'
The NEPM regulates six air pollutants: carbon monoxide, nitrogen dioxide
(NO2), photochemical oxidants, sulphur dioxide, lead and particles.
An advisory reporting standard for PM2.5 was incorporated in 2003
and an Air Toxics National Environmental Protection Measure (AT–NEPM) was added
The current approach to controlling air pollution in Australia was
explained to the committee as identifying thresholds for specific hazardous air
pollutants and set these as air quality targets. Sources of pollution are then
monitored to attempt to achieve these targets.
These thresholds are articulated in the NEPM:
and averaging period
ppm (parts per million) measured over an eight hour period
ppm averaged over a one hour period
ppm averaged over a one year period
ppm of ozone measured over a one hour period
ppm of ozone measured over a four hour period
ppm averaged over a one hour period
ppm averaged over a 24 hour period
ppm averaged over a one year period
µg/m³ (micrograms per cubic metre) averaged over a one year period
as PM 10
µg/m³ averaged over a 24-hour period
as PM 2.5
reporting standard: 25 µg/m³ over a one day period; 8 µg/m³ over a one year
The previous chapter discussed the evidence regarding safe exposure
limits to pollution, highlighting that in most cases the lower the exposure
level the better, and that as a rule of thumb there is no safe level of
exposure that does not cause some level of harm.
The exposure limits outlined in the NEPM were agreed based on the
available academic literature, comparable international standards, and
Australia conditions. As the Department of Sustainability, Environment, Water,
Population and Communities' (Department) website explains:
The standards were set on the basis of scientific studies of
air quality and human health from all over the world, as well as the standards
set by other organisations, such as the World Health Organisation. Australian
conditions, eg climate, geography and demographics, were taken into account in
estimating the likely exposure of Australians to these major air pollutants.
Each air quality standard has two elements: the maximum acceptable
concentration and the time period over which the concentration is averaged.
As is indicated by the term 'adequate protection' of health in the NEPM,
it can be seen that the allowable limits of pollutants in the atmosphere are a
necessary compromise between health and necessity. So long as people drive
cars, require electricity and farm the land, some level of human created
pollution is unavoidable – not to mention sources such as bushfires. As was
noted by the National Environmental Protection Council (NEPC): 'The extent to
which health risk can be minimised will be dependent on a range of factors,
including economic, social and environmental considerations.'
The International Laboratory for Air Quality and Health (ILAQH) put
forward the case that standards are a compromise between competing interests
including the economy and human health, stating 'standards are based on all
kinds of reasons, including economic; therefore, objectives are like this as
well. So this is not based on health.'
The development process behind the NEPM targets was explained to the
committee by the New South Wales Environment Protection Authority (NSW EPA):
The development of the NEPMs goes through several steps. The
first is to go to the literature on what the epidemiological risks are for a
given amount of pollutant. The second step is to look at the monitoring data
that you have in population centres. Then you map the population sizes, the
morbidities from those populations. Then you do a cost-benefit looking at what
are the levels that would reduce morbidity and mortality and total health
economic cost to the community by reducing those levels to a certain amount.
That is how they are arrived at, to look at what is the best cost-beneficial
target that we can have in the nation. They are developed on population levels
and that requires numbers of people to be exposed to get certain health
savings, because if you do it out on the Nullarbor you are not going to save
many lives, so the cost-benefit of doing something out there is really quite
negligible but the cost-benefit of doing something in a big city or a large
population area is much higher. So they are developed on the cost-benefit model
and therefore they are applied on the cost-benefit model.
This principle of population level risk that is used in the NEPM is
articulated by the NEPC:
For the purpose of setting air quality standards, the risk
characterisation applies to population risk not individual risk. Population
risk refers to an assessment of the extent of harm for the population as a
A review of the NEPM in 2011 by the National Environmental Protection
Council (NEPC Review), the first since the NEPM was made in 1998, found that:
Implementing the NEPM has led to a greater understanding of
air quality in Australia which has, in turn, led to an improved understanding
about the health impacts of air pollution on the community...Therefore,
governments now have the opportunity to act more strategically to manage and
further improve air quality in Australia, moving beyond strict compliance with
the standard to a focus on reducing population risk.
The NEPC Report summarised the current state of affairs under the NEPM:
Overall, the results of the health reviews show that there
are significant health effects at current levels of air pollution in Australian
cities. These findings indicate that the current standards are not meeting the
requirement for adequate protection of human health. There is evidence that
these standards should be revised to minimise the impact of air pollution on
the health of the Australian population.
In light of this conclusion, the review included 23 recommendations –
many of which would – if implemented – go a long way to significantly address
issues raised throughout this inquiry. The NEPC Review recommended to:
Revise the desired environmental outcome of the NEPM to 'minimise
the risk from adverse health impacts from exposure to air pollution for all
people wherever they may live';
Revise the desired environmental goal to make reference to the
air quality standards and incorporation of exposure reduction targets for
Remove lead from the Ambient Air Quality NEPM and include in the
Air Toxics NEPM during the scheduled Air Toxics NEPM review of 2012;
Revise the standards for all air pollutants in Schedule 1 of the
NEPM to take into account new evidence around the health effects of air
Introduce compliance standards for PM2.5;
Introduce an 8-hour standard for ozone;
Introduce an annual average standard for PM10;
Introduce an exposure reduction framework and targets for priority
Remove allowable exceedances from Schedule 2 and introduce a
natural events rule;
Redesign monitoring networks to represent population exposure on
a pollutant-by-pollutant basis without compromising data collection for
long-term trend analysis. A procedure to determine the location and number of
sites similar to EU and/or US EPA is recommended;
Remove the population threshold and formula to enable monitoring
on potential population risk rather than on population size;
Amend requirements of monitoring methods (clause 16 and Schedule
3) to allow appropriate Australian Standards methods; or methods determined by
the EU and/or US EPA as Reference or Equivalence Methods;
Remove Schedule 5 of the NEPM;
Develop nationally consistent approaches to assess population
exposure, including appropriate modelling and emissions inventories;
Revise the assessment (clause 17) and reporting (clause 18)
protocol to include additional performance assessment indicators and expanded
reporting requirements to enable inclusion of population exposure
determinations, severity of exceedances and effectiveness and management
Revise guidance documents and templates associated with
assessment and reporting to accommodate presentation of clear messages, to
allow for better communication and more accessible air quality reports;
Amend the NEPM protocol (part 4) to incorporate natural event
rule including definition of these events and criteria for assessment and
Require timely reporting of all exceedances, with jurisdictions
publicly releasing the analysis of these events on their respective websites
within 3 months of the event;
Disband the existing PRC and replace with a specialist working
group or groups with a broader range of expertise to assist with scientific and
technical matters. This working group would report to the Air Quality Working
Evaluate the options to assess ozone and secondary particle
Initiate research into the composition of particles in Australia
and associated health impacts;
Initiate health research on the impact of air pollution (in
particular, particles) in regional areas; and
Monitor and report coarse particle fraction.
Evidence received by the committee indicated that the recommended
changes from the review will be prioritised and responded to via the
development of the National Plan for Clean Air (NPCA) by the Council of
Australian Governments Standing Council on Environment and Water (SCEW) for
delivery in 2014.
The Department emphasized the collaborative nature of SCEW, but assured the
committee that the relevant governments continue to work together to address
the recommendations of the review, stating:
The Australian government cannot establish, vary or revoke a
NEPM unilaterally...The Australian government will continue to work with states
and territories to respond to the recommendations of the review of the air NEPM
in the delivery of the National Plan for Clean Air. The plan is to be delivered
to COAG by the end of 2014.
National Plan for Clean Air
In 2011 SCEW agreed to formulate a National Plan for Clean Air (NPCA) to
be released in 2014. Representatives from SEWPaC explained to the committee the
purpose of NPCA:
It is intended, firstly, to look at the review of the air
quality NEPM and the recommendations there and incorporate appropriate action.
So it will undertake analysis to see what should be done to implement those
recommendations. Secondly—and this links to that review—it will undertake a
health risk assessment and also look at developing an exposure risk reduction
framework. Both of those are incorporated in the review of the air quality
NEPM. So this is looking at shifting the paradigm somewhat. The WHO in its
guidelines has said that there is little evidence to suggest that there is a
threshold below which adverse health impacts are unlikely to occur. The current
approach is really threshold based. Most OECD countries are moving to an
exposure risk reduction framework.
The Victoria EPA informed the committee that:
The NPCA, will...include an exposure reduction approach which
will take into account health effects at low levels. This will shift the
emphasis of policy responses from reducing pollution to reducing the risk of
harm from pollution. It will also shift the emphasis from providing an absolute
level of protection to also finding the economically optimum point for
intervention. The exposure reduction framework will provide efficiency outcomes
by maximising health benefits across a population.
The CAR supported the use an incremental scale to achieve the lowest
possible pollution levels,
a view supported by the AMA.
The NEPC Review argued that a move towards an exposure reduction approach would
align Australia with international best practice while improving health outcomes:
There appears to be significant merit and across-the-board
stakeholder support for an exposure reduction framework...the air quality
standards do not provide absolute protection and any reduction in exposure will
have a net positive health benefit. The introduction of an exposure reduction
approach will align Australian air quality management policy with international
best practice approaches.
The NEPC Review argued that an exposure reduction framework would be to
reduce exposure for communities living in close proximity to large emission
Under the current monitoring protocol in the NEPM, people who
live near major sources of pollution such as roads do not have air quality
monitoring data and are likely to be exposed to higher levels of air pollution
than that measured at performance monitoring stations. The exposure reduction
approach would drive improvements in air quality across the whole population
and not focus on meeting standards at the designated monitoring stations.
The committee heard that an exposure reduction framework is better able
to take into account the individual communities' appetite for risk when
considering specific air quality controls:
We are currently doing interdepartmental work on this—when I
say 'we' it is New South Wales Health but I am also on the national
environmental health council and they will be looking at these results as
well—and we are also doing interjurisdictional work on this at the moment to
come up with an incremental level above which you should not pollute. That is
based on the same way that you set standards for everything else, which is:
what is the risk appetite of the community? We accept risks from radiation, so
you get one in 10 to the minus six excess cases of disease per one millisievert
above background. For most water quality indices for our drinking water, we
will accept a 10 to the minus four or 10 to the minus five increase in risk
above background. We are doing the same sort of work around air, looking at: if
we translate those sorts of risks that the community is generally going to
accept for their environmental hazards and we apply that to air, what numbers
do we come up with? That work is in train at the moment.
As I said before, most standards are set this way, but there
is usually a risk appetite of somewhere between 10 and minus four and 10 and
minus six excess risk above and beyond what you would normally get. In other
words, if you got one case in 100 normally, then you would have an extra one
case in 10,000 above those one cases in 100 of increased risk for a particular
health outcome and we are usually talking about death here. That is the way
that the process is working for us to look at this as an approach. This hasn't
been done before. People have used the NEPM as a standard, saying: 'Okay,
you've got to hit this goal.' That is not necessarily correct, because that
goal may be too lenient or it may be too strict in certain circumstances. As
the discussion earlier noted, you cannot use NEPM on very small populations
that are exposed to a particular development. It does not lend itself to that
because of the way it was developed. This approach will lend itself to that and
it will be much clearer to people who are exposed to these risks what their
actual level of risk is and what risk society is asking them to tolerate on
behalf of development for all of society. 
As the previous chapter showed, there is no safe level for exposure to
most pollutants, and as was explained above, some pollutants that were
previously thought to have threshold effects are now deemed to have no safe
limit. This evidence, along with the findings of the NEPC Review, indicates
that the exposure reduction model is the best approach to protect human health
from harmful air pollutants. The committee notes the efforts of governments
around Australia to move towards the exposure reduction approach to ensure the
health of all Australians is adequately protected.
The committee recommends that the Australian Government's representative
to the Standing Council on Environment and Water support the adoption of the 23
recommendations of the Ambient Air Quality NEPM Review.
PM2.5 ultrafine particles and other contaminants
Finding the correct balance between human health and other
considerations is a moving target as society's expectations change, and as the
evidence base grows. The NEPC Review notes some of this evolution:
Determining potential population health risk resulting from
ambient air quality exposure has been complicated by the fact that epidemiology
studies are now indicating there is no clear threshold for effect for the
current NEPM pollutants, with exposures below the standards still representing
a statistically significant and measurable health risk to the Australia
population...when the NEPM was made it was thought sulfur dioxide and carbon
monoxide had an identified threshold effect, and nitrogen dioxide and lead had
an apparent threshold effect.
The committee heard repeated calls throughout this inquiry for more
stringent air quality standards to be put in place for pollutants such as PM2.5,
ultrafine particles and some other contaminants.
Under the current NEPM PM2.5 is subject to an advisory
reporting standard rather than a compliance standard. A large number of
submissions and witnesses recommended that the advisory standard be replaced
with a compliance standard.
The decision to include PM2.5 as an advisory standard in the
NEPM from 2003 was to gather data to assess the impacts of PM2.5:
Advisory reporting standards are considered to be the
appropriate form for a standard for PM2.5 at this time, given the
lack of comprehensive data that would make it possible to establish compliance
standards and to fully assess the impacts associated with breaches of such
standards. The purpose of advisory reporting standards is to facilitate the
collection of data and provide a framework for reporting these data.
Since that time it has become clear that PM2.5 poses a risk
to human health. The NSW EPA noted that 'fine particles, PM2.5, are
the pollutants imposing the greatest health and cost burden on the people of
New South Wales.'
In recommending the introduction of a compliance standard for PM2.5
the NEPM Review noted that there is now sufficient Australian evidence to
justify a compliance standard:
This support is based on the understanding of the health
effects of PM2.5. The initial introduction of an advisory reporting
standards rather than compliance standards was due to a lack of monitoring
data. All jurisdictions have since been monitoring PM2.5 and there
is now sufficient data to develop compliance standards. The Review Team
considers that compliance standards should be introduced for PM2.5.
The introduction of a compliance standard appears to be supported by
and community groups including by the NSW EPA which commented:
Because of that growing awareness here and internationally
that we need to focus on PM2.5, we believe that the NEPM needs to
change. Specifically, the New South Wales EPA is strongly of the view that the
NEPM reporting standard for PM2.5 should be adopted as a compliance
standard. As well as the annual standard, the health evidence also indicates
that a daily standard is necessary.
Some submissions also called for UFP, particles of a diameter less than
0.1µm, to be subject
UFP are generally produced through combustion processes and can penetrate deep
into the lungs of humans and enter the bloodstream.
Professor Morawska highlighted that research of the effects of UFP on
human health is progressing, but there is still little understanding and
monitoring of UFP:
Epidemiological evidence is also mounting on the impact of
ultrafine particles on health; however, progress in this field is hampered by
the lack of monitoring of these particles. In general there is little
monitoring and hence understanding of a complex urban pollution mix, including
elemental carbon, primary organics and secondary organic aerosols.
The AMA advocated for a precautionary approach to ultrafine particles:
There is compelling evidence that exposure to ultrafine
particulates poses a significant threat to human health, however it is
currently not possible to precisely quantify the exposure levels that may
result in specific health effects. On this basis, a prudent precautionary
approach would necessitate provisional standards and measures designed to
reduce exposure to ultrafine particulates, particularly given their ubiquity
and presence in vehicle exhaust emissions.
As a result of the lack of current evidence, the ILAQH argued that:
There is a critical need for the routine monitoring of UFPs,
to provide input for epidemiological studies and in turn, the development of
regulations (it is unlikely that regulations would be developed without
The NEPC Review argued against the inclusion of UFP in the NEPM, arguing
that there is currently insufficient evidence to justify the inclusion of UFP:
The health reviews conducted as part of this review have
shown that, although there is some evidence for health effects linked to ultrafine
particles, there is not sufficient evidence to support the setting of standards
at this time. This finding is supported by the recent reviews conducted by the
WHO and by US EPA. In additional, as ultrafine particles are not routinely
monitored, there is no monitoring data available in Australia that would enable
the setting of standards.
While the committee appreciates that there may not be sufficient data at
this time to warrant a compliance standard, it does appear that there is enough
evidence to indicate that further and urgent research is required to assess the
levels population exposure to UFP and the impact that this has on human health.
In the same way that PM2.5 was initially included in the NEPM as an
advisory standard to gather data, UFP particles should be included in the NPCA.
The committee recommends that the Australian Government advocate,
through the appropriate Council of Australian Governments process, the
inclusion of mechanisms to collect additional data on ultrafine particles.
A number of other contaminants were nominated for regulation to protect
human health. For example, the committee heard that there is currently no standards
around arsenic or cadmium for air quality; contaminants important for mining
communities where those metals are being extracted. Some communities are also
exposed to higher than average levels of lead and dust.
Although this report is unable to discuss these concerns in detail as little
evidence was received on these issues, the committee notes these concerns.
Reducing community exposure: buffer zones
The committee heard that one of the most effective ways of reducing
exposure to harmful pollutants is by separating populations from those
The Minerals Council of Australia explained that buffer zones can be used to
control dust and other emissions, improve visual amenity and for occupational
health and safety reasons.
The committee heard concerns from some communities such as Anglesea in Victoria
and Newcastle in New South Wales that mines, port, transport corridors power
stations are too close to vulnerable communities.
Buffer zones are already used in some jurisdictions for various industrial
developments. Queensland has a mandated buffer zone on coal mines of two
kilometres from towns with greater than one thousand inhabitants.
Wind farm developments are also subject to a two kilometre buffer zone in
Victoria and South Australia.
The verifiability of buffer zones was cited as one of their key benefits
as 'you do not have the uncertainty as to whether the standards are being met
through complicated monitoring. You can see there is a gap.'
Several groups called for a more extensive use of buffer zones to
control air quality.
The Asthma Foundation of New South Wales called for the '[establishment of] a
minimum buffer zone between human habitation and all new open-cut coalmines,
mine expansion and port infrastructure.'
ANEDO and the Lock the Gate Alliance both suggested that,
considering the potential scale of mining developments, two kilometres was an
A large number of submissions, while expressing concern regarding the health
impacts of air pollution on proximate communities, did not suggest the use of
and instead proposed stronger enforcement of current standards or more
The use of buffer zones does need to take into account the local
meteorological and planning circumstances. The town of Moranbah, for example,
has mines on three sides of it and their existing buffer zones were reported to
the committee to be limiting development in the town.
On the other hand, the Port Augusta City Council reported that although a
two kilometre distance exists between local power stations and the city,
prevailing winds mean that populations are exposed to air pollution.
The use of buffer zones to protect communities from large point-sources
of pollution such as coal mines, power plants, ports and transport corridors is
not a new idea. Having considered the evidence before it, the committee is of
the view that buffer zones – taking into account local conditions and
requirements – are an important tool in protecting communities from poor air
pollution. Importantly, buffer zones are physical control measures that the
community can see and authorities can accurately verify.
The committee recommends that buffer zones be used to protect populated
areas from large point-source emitters.
Air pollution monitoring and data
Currently in Australia there are two primary sectors responsible for
collecting data and monitoring air quality: governments collecting data to meet
their requirements under the NEPM; and private sector entities that are
required to undertake air quality monitoring as part of their various operating
The committee received evidence from a number of State government
environmental protection authorities outlining the way in which they monitored
air quality in their state. Western Australia and Victoria both reported the
use of a fixed network of monitoring stations – necessary to meet their
obligations under the NEPM – supplemented by mobile monitoring stations that
can be deployed to assess local air quality issues and undertake research into
specific point sources.
The NSW EPA operates 40 monitoring stations (15 in Sydney), and works with
industry to monitor emissions from local sources.
The NEPM provides explicit guidance on the location and operation of
performance monitoring stations, in accordance with the Australian Standard
AS2922–1987: Ambient Air – guide for siting of sampling units. The
stations must be located in a manner that contributes to obtaining a
representative measure of the air quality likely to be experienced by the
general population in a region.
The NEPC Review provides an explanation of the intent behind this approach:
The intent was to provide some sense of population exposure
by focusing on the higher levels to which a regional population was likely to
be exposed, without direct influence of local sources such as major traffic
areas; that is, where large proportions of the population experience similar average
Data from monitoring conducted by State and Territory governments is
widely available. The committee heard that the NSW EPA provides hourly air
quality updates and that residents can subscribe to SMS and email alerts
informing them of high pollution days.
Western Australian and Victorian residents can similarly view hourly updates on
their respective agency's websites.
Findings from the data from periodic point source monitoring, at least in
Victoria, is presented 'regularly' via the internet and community meetings.
Because the NEPM is focused at the population level, the data does not
measure air pollution likely to be experienced by any one individual. The NEPC
Review explains that:
The NEPM standards were established as ambient standards;
that is, pertaining to broad air quality within air sheds. They were not
generally aimed at assessing air quality at localised point sources, such as
those from industrial plants.
This measurement of airshed exposures was criticised during the inquiry
as hiding the true air quality in places that people live and work. For
communities and residents in close proximity to large emitters, they cannot be
sure of their actual exposure as data is reported for the airshed as a whole.
The AMA argued that this consequence of this system is that individual
communities often cannot accurately gauge their specific exposures:
The original intent of Australia's air quality monitoring
network was to avoid monitoring near localised sources of pollution, such as
industrial areas or heavy traffic flow areas, and to capture instead the
average concentrations of pollutants in a specific region, or 'airshed'.
Monitoring was not designed to measure the variability in pollutant levels
within a specific airshed. As a consequence, the air monitoring that is
undertaken under the current [NEPM] is likely to significantly underestimate
real-life exposures for many sections of the population. In addition,
monitoring activity is limited in geographic coverage and is not, for example,
undertaken in regional areas where there may be poor air quality due to
industrial or agricultural practices. As a result, the ability of communities
and local governments to access information about air quality in their own
areas is often limited.
As a result of the use of ambient standards, the committee heard that
many communities that are collocated with industrial sites, mines, or major
transport routes and infrastructure are being exposed to air quality that does
not meet the NEPM standard's object of protecting health,
and that currently 'monitoring of pollution and health impacts locally is
unsatisfactory and a cause for concern among the local community.'
Representatives from Moranbah in Queensland argued that the lack of information
about population exposure is as much a concern for residents as the exposure
One reason for monitoring air pollution levels is to use that data to
improve our understanding of the impact poor air quality has on human health.
The committee heard concerns that the current design of the NEPM air monitoring
regime may be inadequate to collect the necessary data to properly assess the
health impacts of poor air quality.
An impact of this system, reported by the AMA, is that the necessary data to
draw causal links between health impacts and poor air quality is not being
The Moranbah Cumulative Impacts Group also called for monitoring to be better
integrated with health information to 'provide an accurate picture of any risks
to human health or otherwise.'
The Australian Network of Environmental Defender's Offices (ANEDO) also called
for 'monitoring stations in areas where the community is being affected –
schools, the nearest home, and so forth.'
Doctors for the Environment expressed frustration that the current system
limited the ability to draw causal links between air quality and human health:
At the moment it seems crazy to the community that the
sources that are most polluting, which could be major roads or coal fired power
stations, are actively excluded because the EPA is looking for an airshed
average and that affects the airshed average. It is very mechanistic. It is not
actually giving us the information about risk, which is really what we are
after in order to reduce that for the population.
The committee was informed that in the United States and European Union
air quality monitoring considers population exposures rather than airshed
concentrations of pollutants.
The NEPM Review noted the concerns that current monitoring does not
adequately capture human exposure to pollutants and recommended a redesign of
the monitoring networks to represent population exposure.
Some pollutants currently monitored under the NEPM are measured as
averages over a period of time. This has impacts on the presentation of data,
with short intervals of elevated pollution levels being hidden within the
averages. It was argued that:
A 24-hour average just hides those spikes and does not really
give you a true picture of useful information you can use for health impact,
that you can correlate spikes directly with health impact and see what is going
on. You cannot get that from averaged information.
You bodgie up air quality all the time by doing averages. You
do an average over a period of time and you get something that comes inside the
set parameters and that neglects the fact that on a number of occasions you had
serious exceedences, which caused major health issues. You have to go for the
large spikes as well as the averages if you are going to get any sort of idea
about what impact these are having on health.
In the case of lead, the NEPM measures use an average of TSP. It was
argued that this obscures actual contaminant concentrations:
So, the standard is based on an annual average. What this
does not do is, first, take into account the short-term fluctuations, which are
very significant—and that information is in the documentation that I sent to
the parliament. It also does not take into account the effect of very small
particulates, because you have a dilution by consequence of including all
particulates, including coarse particulates, in the measurement. As particles
become smaller their surface area to volume increases, and it is well known and
well understood that most of the contaminants reside in the very fine
While the committee recognises that certain NEPM standards are evaluated
as averages, the committee did not hear any reason why raw data could not be
made available to the public. The availability of this data might assuage
concerns about exposure and also allow for additional research into
correlations between high pollution levels and other markers of health impacts
such as hospital admissions.
Some large-scale emitters undertake their own air quality monitoring
either on their own initiative or as required as part of their operating
licences. These monitoring sites can provide a more detailed picture of air
quality being experienced by a proximate community. EPA Victoria reported to
the committee that the use of industry monitoring – subject to agreed standards
– is standard practice around the world:
[EPAs] require businesses that pollute to monitor and report
on their pollution, but there are often concerns from the community that that
is not independent, even though it is subject to rigour in the way in which it
It was reported to the committee, for example, that North Queensland
Bulk Ports (NQBP) that for over 20 years they have conducted coal dust
monitoring around the coal terminals and nearby communities,
and that power stations in the La Trobe valley and Anglesea in Victoria conduct
The committee heard concerns that the data from these monitoring
stations was inaccurate and difficult to obtain,
and does not necessarily measure for things such as PM2.5.
The committee heard evidence from ANEDO that the monitoring requirements in
operating licences are often insufficiently specific to ensure that
point-source monitoring is conducted in places that will accurately represent
It was the view of Doctors for the Environment that, overall, 'there is an
overreliance on industry to provide information, and that is frequently far
from adequate and far from transparent.'
Industry bodies, such as NQBP, disputed the negative characterisation of
their monitoring practices. They informed the committee that their monitoring
was conducted by 'independent consultants' and was thus a reliable indicator of
The Victorian EPA informed the committee that they monitor industry established
monitoring equipment to ensure that the data is accurate and appropriate
monitoring standards and practice are being observed.
The committee is not in a position to verify claims regarding the
validity of data, but is of the belief that effective industry monitoring of
air quality – especially when one industry is creating a large amount of air
pollution such as coal mining in the Upper Hunter Valley area – should be
encouraged to supplement government data collection.
The committee regularly heard that it was difficult for the community to
access air quality data, especially data collected from a point source emitter
as part of an operating licence. The ANEDO informed the committee that 'it is a
torturous and difficult process for the locals to try and get hold of the
relevant monitoring data.'
Doctors for the Environment elaborated on the difficulties of accessing
industry gathered data:
...the trouble with industry monitoring is that it goes to the
EPA but it is not transparent and so it is not readily accessible for citizens
or people in the community. To be able to extract information from the EPA, as
David has mentioned, you have to be extremely committed with your time and
energy, generally. People really need something they can quickly look up and
get some indication of what sort of problem there is.
The committee heard the example of the difficulty the residents of
Anglesea in Victoria faced in trying to access data collected by Alcoa:
...at the moment that data is difficult to access. It can be
accessed at times through—for example, the reporting that companies do to the
EPA. However, that reporting may or may not be made public. So, for example,
the community was not able to access the particulate matter data recorded at
Anglesea power station without having gone through a process of freedom of
information and eventually a decision being made by the Victorian parliament
that Alcoa Anglesea was required to provide its health impact assessments to
that community. It was a period of years that that community was seeking
information that contained monitoring levels before they were able to be
provided with that information.
It was recommended by ANEDO that 'real-time online monitoring data' be
available to the public.
Quit Coal made the same recommendation so that residents near heavy pollution
sources would have the necessary information 'that would allow them to take
action to protect themselves.'
NQBP disputed that data on air quality was difficult to obtain, pointing
out that their independent monitoring was available on their website.
The committee notes however that there appears to be a gap of around one month
between the data being collected and published.
Industry monitoring of emissions is an important tool in ensuring
compliance with licensing conditions and protecting human health. As the
creators of potentially harmful pollutants, industry has a responsibility to
ensure that human health is preserved and the reliable and regular data is
collected. The committee is of the view that this information should be made
available to the public in as close to real-time as possible.
The committee recommends that pollution monitoring should accurately
capture population exposure for communities and homes proximate to pollution
The committee recommends that providing monitoring and real-time data of
air quality be a condition of environmental approvals issued by the Australian
Government unless an operator can demonstrate that air pollution created by the
development will not impact upon human health.
Navigation: Previous Page | Contents | Next Page