21 June 2018

By Bronya Lipski

Environmental Justice Australia has been fighting for better air pollution laws in Australia for years.

We are pleased that the Victorian government has released an Air Quality Statement, which ‘kicks off engagement with all Victorians about what our priorities for future air quality management should be’.

But we were disappointed that the government wants to make ‘cost effectiveness’ a key concern in measures employed to reduce air pollution.

Air pollution causes at least 3000 deaths a year in Australia. It causes chronic disease and disability for tens of thousands more. Dramatically reducing people’s exposure to air pollution is the only way to reduce these rates of death and disease.

Actions taken to reduce air pollution should not be reduced to their cost effectiveness. This is the approach taken in the United States under their Clean Air Act, which requires the federal Environment Protection Agency to set national air standards based entirely on protecting public health and welfare without consideration for cost.

The Victorian government’s Air Quality Statement is an opportunity for the government to dramatically improve air quality and community health outcomes.

Here are four things Environmental Justice Australia strongly encourages the Victorian government to do.

1.       Expedite the introduction of a load-based licencing scheme

Load-based licensing puts a price on the emission of toxic pollutants like mercury, fine particles (PM2.5), sulfur dioxide (SO2) and oxides of nitrogen (NOx) – and links companies’ licence fees to their pollution levels. So if a company installs pollution reduction technologies, it will save money on its licence fees.

This system only works if the pollution price is high enough to give the company a genuine incentive to clean up its act. New South Wales has had a load-based licencing scheme since 1999. It is generally seen as a scheme that could have a positive influence on the pollution loads of big industrial emitters. But Doctors for the Environment has called for the NSW government to increase pollution licence fees so they match the cost of the health damage caused by air pollution because the load based licencing scheme has been made less effective by pollution prices being too low.

At present the vast majority of the costs of air pollution are borne by the environment and by communities that live near the industrial facility, rather by than the entity doing the polluting.

The Victorian government has declared that it will ‘remove barriers to load-based licencing, to enable it to be considered as one possible tool to efficiently achieve desired regulatory outcomes as a part of an integrated toolkit’. This process needs to be expedited to ensure polluters pay an adequate amount that reflects the health impacts and other externalities of air pollution and provides a genuine incentive to reduce pollution.

2.       Significantly cut toxic pollution from power stations by installing best available technology

The current review of the licences for the Latrobe Valley’s three remaining power stations is an opportunity for the state Environment Protection Authority to bring the power station licences into line with international best practice.

To do this the government could (and should) simply require power stations to install best available pollution reduction technologies. The technologies are available and in use overseas. They include fabric bag filters to better remove fine particle pollution, selective catalytic reduction to catch nitrogen oxide emissions, flue gas desulphurisation to significantly remove SO2 emissions, and activated carbon injection and disposal to reduce mercury.

The barrier to installing these pollution control systems at the brown coal-fired power stations in Victoria is essentially bureaucratic. For the sake of public health, the Victorian government should immediately demand that the power station operators install best practise pollution reduction technologies.

3.       Do not fund, commission, or approve new coal-fired power stations, coal-to-hydrogen facilities, or waste-to-energy incinerators

This should be a no-brainer. The era of burning stuff to make electricity is rapidly drawing to a close. Australia is the land of plenty when it comes to renewable energy. There should be no need for anyone to propose new coal-fired power stations. Or highly speculative coal-to-hydrogen pilot projects. Or 1950s-style plans to burn waste.

Yet we keep hearing politicians talking up these ideas. If the Victorian government is genuine about ‘securing a clean air future for our state’, these schemes won’t even get to square one.

4.       Strengthen Victoria’s air pollution laws

The Victorian Air Quality Statement should start where the problem with air pollution starts – with the laws that regulate ambient air quality and emissions limits. Australia’s air pollution laws and standards are insufficient to protect human and environmental health. Some changes have been made to the National Environment Protection (Ambient Air) Measure to tighten standards for course and fine particle pollution, and currently the Victorian government is leading the National Environment Protection Council process to make standards stricter for ozone, nitrogen dioxide and sulphur dioxide pollution.

However Victoria is not bound to the national standards and can make our air pollution laws stricter to better protect human and environmental health. The EPA has powers to instruct heavy polluters to reduce their emissions and to make licence conditions stronger than what they currently are. If our environmental regulator is not encouraged to utilise the powers available to it then polluters won’t change their behaviour.

The Victorian government should be commended for starting this process of developing an Air Pollution Strategy. Written submissions on the Clean Air Statement close on 30 June 2018. EJA urges all who care about clean air to make their voices heard.

Read EJA’s submission on the Victorian Air Quality Statement (PDF, 545KB)

Pic of Yallourn Power Station by Max Phillips