Working towards a National
Clean Air Agreement
Summary of Submissions
July 2015
© Copyright Commonwealth of Australia, 2015.
Working Towards a National Clean Air Agreement: Submissions Summary is licensed by the
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This report should be attributed as ‘Working Towards a National Clean Air Agreement: Summary of
Submissions, Commonwealth of Australia 2015’.
The views and opinions expressed in this publication are those of the authors and do not necessarily
reflect those of the Australian Government or the Minister for the Environment.
While reasonable efforts have been made to ensure that the contents of this publication are factually
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INTRODUCTION
In April 2014, all of Australia’s Environment Ministers agreed to consider working towards a
National Clean Air Agreement to address the challenges regarding our air quality and to
chart a course for a clean air future. A discussion paper Working towards a National Clean
Air Agreement was released on 27 February 2015. It served as a basis to engage business
and community representatives to help inform the development of the Agreement.
The discussion paper outlined proposed elements of the Agreement (goal, objectives,
principles, scope) and a process to prioritise action to address air quality issues. It also
outlined a proposal to include an agreed work plan for periodic review that would focus
actions to develop practical solutions to air quality priorities and identify roles and
responsibilities for implementing those actions.
The discussion paper posed questions to prompt feedback on the proposals for the
Agreement. Views were sought on air quality priorities, potential actions to address air
quality issues and possible partnership opportunities with non-government organisations to
help deliver better air quality outcomes. The period for written submissions closed on
17 April 2015.
There was considerable interest in the process, with over 300 submissions received. It is
clear from the submissions received that air quality is a current and likely future area of
interest and concern for many sectors and individuals. It is also clear that action to help
ensure a clean air future is supported.
Feedback confirmed that there is broad support across all sectors for the development of an
Agreement. Submissions highlighted that there is ongoing community concern about air
quality in Australia and its impacts on communities. There is broad interest in gaining
improved access to better air quality information, including for public use and research.
Furthermore, submissions identified a clear need for ongoing cooperation and coordination
between governments in managing air quality and delivering improved outcomes. There was
acknowledgement that national consistency can provide certainty, as well as a simplified
approach, with respect to mobile emission sources and for businesses which operate in
multiple jurisdictions.
A variety of suggestions were made for ways to improve air quality outcomes into the future.
These supported the proposal in the discussion paper for the Agreement to encompass a
range of approaches to strengthen air quality management including through: standards;
emission reduction measures; cooperation and partnerships; and knowledge, education and
awareness.
The suggestions raised cover a diverse range of issues and approaches regarding air quality
in Australia. This reaffirms the proposed approach of the Agreement in supporting the
prioritisation of air quality issues and directing management effort where it can be most
effective. The feedback received will serve as a valuable resource to inform both current and
future work under the Agreement.
SUBMISSIONS RECEIVED
A total of 324 submissions were received. Just over 200 submissions were from individuals.
Submissions from non-government organisations/community groups represented the next
largest sector, followed by businesses and industry bodies. Research, professional and local
government sectors were also represented in submissions. A breakdown of submissions by
stakeholder group and location is provided in Appendix 1. A list of organisations that made a
submission is also included.
Submissions were reviewed by the Department of the Environment on behalf of the States
and Territories. This summary provides an overview of the views raised in submissions. It is
not meant to be exhaustive nor intended to repeat text verbatim in the written submissions.
Rather, common issues and themes from feedback received are captured and, where
relevant, specific examples included.
The views summarised are those raised in submissions and do not necessarily reflect those
of the Department or States and Territories Governments.
Design of the National Clean Air Agreement
The intent of the goal, purpose, principles and scope was generally supported with some
submissions suggesting that they need to be clearly articulated. In particular, a strong view
was expressed that protecting human health should be the primary focus of the Agreement
and this should be emphasised in the Agreement’s goal, purpose and principles.
Within the community sector, there was concern that attempts to minimise regulatory burden
could undermine air quality outcomes. These views were also raised in submissions from
other sectors. In addition, unnecessary delays caused by lengthy analysis of actions to
manage air quality issues should be avoided while still allowing for appropriate consultation
and lead-in times.
Within the business and industry sectors, there was a view that actions incorporated under
an Agreement would need to be appropriate, feasible, cost-effective and based on robust
evidence.
Submissions from the research sector considered that research should be explicitly rather
than implicitly captured in the Agreement’s scope to reflect its importance in providing
current information to inform policy development and satisfying the public’s need for
information.
The discussion paper included a draft work plan of possible measures that could initially be
considered under an Agreement. Some submissions noted that the proposed work plan
appeared to only include measures that were already underway.
Feedback regarding the proposed basis for the Agreement’s priority setting process to
develop future work plans and focus actions to tackle air quality issues was limited.
Suggestions received focused on having a transparent process with publicly available
criteria for priority setting and a defined process to address priorities on the work plan,
including consultation with business and the community and impact analyses. There was
also a view that independent experts including health professionals could assist in
developing future work plan priorities.
There was also a view that the Agreement should ensure that all jurisdictions have input in
identifying priorities so that the policy agenda is not driven by those jurisdictions with more
resources and state-specific issues. It was noted that flexibility needed to be retained to be
able to work with specific circumstances of each state or territory.
General comment from the community and business suggested that in identifying priorities
under the Agreement, sources that are the largest contributors to air pollution and have the
biggest impact on human health should be prioritised, as well as measures that will have the
biggest impact on pollution and health. In considering measures, successful initiatives
implemented overseas to address air pollution were suggested to serve as a guide.
Submissions also suggested that transparency could also be built into the process through
reporting. This could include providing reasoning for not including identified air concerns in
future work plans (for example, how the issue is being addressed by other avenues). Other
suggestions included building in regular review and reporting processes for the Agreement
itself and individual actions on the work plan.
Air Pollution – Sources of Concern
Submissions showed a high level of community concern about local air quality, particularly in
areas with higher levels of air pollution due to local activities (for example, industrial activity
or wood heater use). The main concerns are due to exposure and adverse health impacts,
either personally experienced or concerns for possible impacts to others including future
generations.
Some submissions raised concerns about environmental impacts and cited societal benefits
of improving air quality. Environmental impacts raised included: air pollution negatively
impacting on food production and damaging other vegetation and the health of native
wildlife, as well as the impact of shipping emissions on the Great Barrier Reef.
Sources of air pollution that were identified in submissions included, in no particular order:

diesel engines (on-road vehicles, non-road diesel engines and equipment, shipping)

wood smoke

transport emissions including from road traffic, rail and aviation

non-road spark ignition engines and equipment (garden equipment and marine engines)

coal (mining, stockpiling, transportation and burning) – specific areas of concern were
related to the Hunter Valley, New South Wales and Anglesea, Victoria

dust (including pollen)

bushfires and open-air burning (including back yard, land practices and controlled burns)

industrial activity including extractive processes

changing conditions associated with climate change

tobacco smoke and second hand smoke

indoor air.
The main pollutants of concern included particulate matter (PM10 and PM2.5) and sulfur
dioxide. Other pollutants of concern included ultrafine particulate matter, methane, nitrogen
dioxide, carbon monoxide, ozone, mercury, lead, benzene, volatile organic compounds, and
coal seam gas. Carbon dioxide and other greenhouse emissions were raised as concerns in
relation to climate change.
Submissions generally did not question the drivers for air quality challenges such as
population growth and increasing energy and transport demands. However, some
submissions considered that the existing air quality management framework in Australia is
insufficient or ineffective, and in itself poses a challenge to Australia’s future air quality.
Approaches to manage air quality issues under an Agreement
Most of the measures suggested in submissions to address air quality issues fit within the
proposed scope of the Agreement, that is: standards; emission reduction measures;
cooperation and partnerships; and knowledge, education and awareness.
Standards
Similar feedback to that received on proposed varied standards for particulate matter in the
National Environment Protection (Ambient Air Quality) Measure (AAQ NEPM) was provided
in submissions to the discussion paper.
There were calls from the community sector and individuals to strengthen the AAQ NEPM
particle standards without delay, and strengthen the standards for the other air pollutants
listed in the AAQ NEPM, especially sulfur dioxide. The strictest possible standards were
supported, along with calls to introduce compliance and enforcement to the standards. In
addition, further national action was considered necessary to monitor emissions of ultrafine
particles for the purposes of measuring peak and cumulative exposure.
Some submissions from business and industry supported national ambient air quality
standards in general, but considered that inconsistencies across jurisdictions in the
implementation of the AAQ NEPM to point source emissions need to be addressed.
Some submissions suggested that all States and Territories should be required to create
provisions for the inclusion of strict and enforceable pollution limits as part of environmental
protection licensing (load-based and strong deterrent penalties for exceedances of
standards). In some cases, more stringent emission standards for mercury and sulfur dioxide
from coal-fired plants were called for.
Some submissions suggested that health impact assessments should be mandatory during
the planning phase of all projects of state significance, and projected exceedances of annual
and 24-hour average particle pollution thresholds for either PM10 or PM2.5 should be
grounds for the refusal of planning approval.
Some submissions also suggested that a focus should be on reducing exposure to air
pollution and to make explicit that the ambient air quality standards do not indicate a ‘safe’
level.
There was support for keeping and improving the National Environment Protection (Diesel
Vehicle Emissions) Measure and National Environment Protection (Air Toxics) Measure. In
particular, there was a suggestion to expand the Air Toxics NEPM with legally enforceable
standards to enact Australia’s obligations to support the Stockholm Convention and to
provide an air toxics reduction strategy for persistent organic pollutants.
Some submissions suggested that the Agreement should include a commitment to
implement the 23 recommendations of the Review of the National Environment Protection
(Ambient Air Quality) Measure (completed in 2011) as well as the 13 recommendations of
the Senate Inquiry into the Health Impacts of Air Quality in Australia (2013).
A range of alternatives were suggested in addition to the existing approach to managing
ambient air quality including setting targets for particular pollutants, capping maximum
allowable limits of some pollutants, or banning particular sources or pollutants. There was
also a call to regulate carbon and other greenhouse emissions as air pollutants.
Other standards related to managing air pollutant emissions at the source were also raised
in submissions and are captured under the following section. These include fuel quality,
vehicle emission and product emission standards. Some industry submissions noted a need
to consider related standards (for example, fuel quality, greenhouse gas targets and vehicle
emission standards) at the same time. In addition, it was noted that timely and adequate
consultation was critical, as unanticipated changes could have adverse impacts not only for
business operations but in some cases safety.
Emission reduction and exposure reduction measures
A diverse range of measures to reduce emissions and reduce exposure to air pollution were
suggested. These included regulatory measures such as national standards through to more
local and individual approaches. A summary list of measures suggested is included at
Appendix 2.
Cooperation and partnerships
There was an overall sense from submissions that all levels of government should continue
to collaborate to manage Australia’s air quality. In addition, it was considered that
governments should strengthen existing and encourage new partnerships with sectors that
could inform and influence positive air quality outcomes. These included the infrastructure,
renewable energy, research, health, community and business sectors. Health and
environmental experts should also be engaged by governments to support decision making.
Some submissions provided potential partnership and cooperation avenues including:

exploring opportunities to improve air quality through infrastructure approaches

strengthening partnerships with organisations gathering air pollution data

working with non-government sectors already active in addressing (local) air quality
issues, to learn and share knowledge from their experiences (this could range from
practical solutions to education programmes to work place safety approaches)

strengthening internal government networks across agencies that can influence air
quality outcomes (for example health, infrastructure, transport, energy, climate change
agencies) and learn from successful programmes and policies.
Knowledge, education and awareness
Submissions in general indicated a clear desire for improved public education and
awareness of air quality issues, and a need for improved public access to current and
reliable air quality information and data. Submissions highlighted a need for air quality
information to be readily available and for information provided to the public to be done so in
a manner that is easy to understand. Submissions suggested this as a way to empower
communities and individuals in being better able to deal with managing exposure to air
pollution.
Sectors including research and academics highlighted a need for improved air quality
monitoring, including methodologies and reporting, and for streamlined access to this
information. In particular, provision of a national database for air quality and improved
emissions inventories were supported to allow for more robust analysis of air quality and air
quality trends in Australia to assist decision-making.
A summary list of suggestions made is at Appendix 3.
Other approaches
In addition to the suggested measures aligning with the proposed scope of the Agreement,
some submissions provided feedback regarding mechanisms to deliver current and future
measures more broadly. These included:

underpinning cooperative approaches with regulation

developing a nationally consistent approach to the application and enforcement of air
quality regulation, for example, through: consistent national standards for mobile
sources; Commonwealth legislation; a single regulatory body; and the ability to ensure
air quality considerations are taken into account in planning projects

establishing a national base line or minimum standard for clean air

appropriate funding and resources committed by all levels of government.
Some submissions noted that climate change impacts should be considered and addressed
under the Agreement. In this regard, measures to address climate change may have
benefits for air quality through reducing emissions of air pollutants, and vice versa. Measures
to address climate change were also seen to have the benefit of mitigating weather
conditions that would lead to increased air pollution problems.
APPENDIX 1: SUMMARY OF SUBMISSIONS BY STAKEHOLDER GROUP AND LOCATION
Figure 1 provides information on the proportion of submissions which represented different sectors.
The majority of submissions were from individuals/groups based in Victoria and New South Wales. This, in
part, reflects the fact that campaign-style submissions were predominantly from these two States.
Figure 2 provides a breakdown of submissions based on location.
List of submissions from organisations
Sector
Business/industry
Local government
Professional
Research
Political
Organisation
Australian Diesel Engines Distributors Association
Australian Institute of Petroleum
Australian Marine Engine Council
Australian Petroleum Production & Exploration Association
Blended Fuel Solutions NZ
Business Council of Australia
Caltex Australia
Carnival Australia
Cement Concrete & Aggregates Australia
Cement Industry Federation
Centron Fuel Technology
Construction Material Processors Association
Energy Supply Association of Australia
Environmental Performance Australia Ltd
Federal Chamber of Automotive Industries
Firewood Association of Australia
Gas Energy Australia
Greenbase
Infrastructure Sustainability Council of Australia
Island Marine Enterprises
Maritime Industry Australia Ltd
Minerals Council of Australia
Outdoor Power Equipment Association
Plastics and Chemicals Industries Association
Robert Bosch (Australia) Pty Ltd
The Australian Home Heating Association
Truck Industry Council
Hobsons Bay City Council
Liverpool City Council
Maribyrnong City Council
Surf Coast Shire Council
Asian Clean Fuels Association (based in Singapore)
Australian Institute of Landscape Architects
Australian Medical Association
Australian Medical Students' Association
Clean Air Society Australia and New Zealand
Doctors for the Environment Australia
Centre for Air quality and health Research and evaluation (CAR)
Clean Air and Urban Landscapes Hub
CSIRO
Peter MacCallum Cancer Centre
New England Greens
Sector
Community
Organisation
Alliance for a Clean Environment
Australian Air Quality Group
Australian Coal Alliance
Australian Conservation Foundation
Ballarat Climate Action 2015
Brooklyn Residents Action Group
Bulga Milbrodale Progress Association
Cleanairtas
ClimActs
CLIMARTE
Climate Action Pittwater
Climate and Health Alliance
Climate Action Sydney Eastern Suburbs
Community Over Mining
Conservation Council of South Australia
Conservation Council of Western Australia
Correct Planning and Consultation for Mayfield
Denman, Aberdeen, Muswellbrook and Scone Healthy Environment Group
Edmund Rice Conference Centre, Mulgoa NSW
Environment Council of Central Queensland
Environment East Gippsland
Environmental Defenders Offices of Australia
Environmental Justice Australia
Fly Fair/CEAC Inc
Franciscan Missionaries of Mary, JPIC Team
Friends of Gore Bay
Friends of Steele Creek
Geelong Sustainability Group
Groundswell Gloucester
Hunter Community Environment Centre
Hunter Property Management
Hunter Environment Lobby Inc
Koala Action Inc
Latrobe Valley Support Network
Locals Into Victoria's Environment (LIVE)
Mackay Conservation Group
Maslin Beach Coastcare
Maules Creek Community
National Parks Association of NSW Armidale Branch
National Toxics Network Australia
Nature Conservation Council of NSW
Newcastle Bike Ecology Centre
Port Adelaide Bicycle Users Group
Port Adelaide Resident's Environment Protection Group
Quit Coal Friends of the Earth
Residents Against Intermodal Development Moorebank
Singleton Shire Healthy Environment Group
Surf Coast Air Action
Terminate Tullamarine Toxic Dump Action Group / Friends of Steele creek
Total Environment Centre
Voices of the Valley
Wollar Progress Association
APPENDIX 2: SUGGESTED EMISSION REDUCTION AND EXPOSURE REDUCTION MEASURES
A summary of the measures suggested in submissions is presented below, with no order of preference or
priority. The purpose is to provide an understanding of the scope of suggestions raised rather than to
provide a complete list. Suggestions have been grouped according to sector for ease of presentation,
although it is noted that some measures could apply across multiple sectors.
Energy, power generation and heating
 Mandate renewable energy resources (for example, solar power) to reduce demand for coal.
 Build a sustainable, long-term domestic alternative energy industry (including for example solar power, waste to
energy facilities including gasification, and hydro power).
 Distribute energy generation (for example, through solar grid).
 Employ world best practice pollution mitigation strategies/clean technologies such as scrubbers and filters for major
point sources/smokestack emissions (this would also apply to vent stacks on road tunnels).
 Measures to address wood heater emissions (ranging from an outright ban to national consistency in their regulation).
Transport
 Introduce/phase-in emission standards for non-road diesel engines, including rail, similar to those in the United States
and European Union.
 Introduce emission standards for non-road spark ignition engines and equipment.
 Strengthen national on-road vehicle emission standards, including evaporative emission standards and standards for
heavy duty vehicles.
 Require on-board refuelling vapour recovery technology for petrol light vehicles.
 Improve petrol bowser vapour recovery.
 Nationally uniform approach for regular motor vehicle inspections to ensure emissions control equipment is
functioning effectively.
 Modernise the ageing truck fleet.
 Reduce in-service vehicle emissions, particularly from older diesel vehicles (for example by retrofitting exhaust
controls on all heavy vehicles).
 Limiting truck access in high density/urban areas – noting total ban of diesel vehicles in Paris by 2020 and anti-idling
laws in New England, United States as examples.
 Push towards use of more sustainable vehicle options including hybrid vehicles (for example through procurement
policies).
 Supporting alternative modes of transport to reduce vehicle use (including public transport, rapid urban transit
systems).
 Encourage the use of alternative fuels which have lower life cycle emissions.
 Improve vehicle fuel efficiency (including through legislated vehicle standards).
 Measures to control emissions from shipping (for example, banning the use of low-grade diesel in Australian ports or
incentive programmes such as lower berth fees for lower emitting vessels).
 Simplify regulatory regime for fuel quality (two tiers of regulation – i.e. at both Commonwealth and State/Territory
levels – creates complexity and additional costs).
 Evidence based improvements to fuel quality standards (for example, sulfur and benzene levels).
Planning









Place buildings (such as schools, hospitals, aged care residences) that house sensitive individuals away from major
traffic junctions and manage pick-up/drop-off zones to avoid emissions from idling vehicles.
Utilise green infrastructure (the network of natural landscape assets in towns and cities – for example, green walls,
trees, parks and reserves) to remove air pollutants from the air.
Planning controls to limit/prevent further development in areas that exceed (or are likely to exceed) AAQ NEPM
standards.
Locate industrial plants and equipment away from sensitive population and residential areas.
Manage population size and urbanisation.
Focusing on energy efficiency and higher urban density in urban planning.
Establish intermodal freight terminals (ensuring that terminals are away from established residential homes and
communities).
Encourage increased use of interurban rail system for freight and passengers (including by, for example, improving
existing rail systems).
Establish [more], and encourage use of, walking and cycling networks.
Land practices
 Employ measures other than fire hazard reduction burns to reduce fuel loads.
 Improve farming practices to reduce release of pollutants.
 Better management of urban and agricultural waste; rather than incineration, employ methane gas capture for use as
biogas.
 Improving integration between planning and air pollution laws (for example, requiring ‘health impact assessments’ as
standard practice).
Human health and exposure
 Identified need to improve the general cardiovascular and respiratory health of the elderly to improve their ability to
deal with air pollution.
 Reduce worker exposure to traffic fumes by installing air curtains in drive through windows.
 Allow alternative work arrangements for pregnant women so travel during peak emissions periods is minimised.
 Target traffic emission hotspots in cities.
 Implement and enforce exposure standards in occupations and industries with an elevated potential for high
exposure.
 Provide workplace health and safety monitoring for miners, including those who leave the industry.
 Targeted multi-sector public health education programme to raise public awareness.
 Community education, public warnings and appropriate health advice to protect health outcomes from air pollution
(for example, in the case of bushfire events).
APPENDIX 3: SUMMARY OF SUGGESTIONS FOR KNOWLEDGE, EDUCATION AND AWARENESS
A summary of the suggestions in submissions is presented below, with no order of preference or priority.
The purpose is to provide an understanding of the scope of suggestions raised rather than to provide a
complete list. Suggestions have been grouped according to activity for ease of presentation, although it is
noted that some suggestions could apply across multiple activities.
Air quality monitoring, methodologies and reporting
 Use lower cost and portable equipment to monitor emissions in addition to that required under the AAQ NEPM to help
identify air quality challenges and provide an avenue to work with concerned communities.
 Increase number of, and/or review, monitoring station locations based on factors such as proximity to point sources and
population centres.
 Require mandatory monitoring in areas where there are known health effects occurring, for example near schools, aged
care residences, White Bay Cruise terminal.
 Determine monitoring requirements based on public health rather than population size (as in the AAQ NEPM).
 Measure cumulative impacts of air pollution.
 Develop a common approach to emission inventory methodologies across the country.
 Develop a National Air Quality Data Service.
 Use portable emissions measurement systems as an accepted practice to help provide information about the impact of
different vehicle fleet mixes on air quality.
 Provide real-time, publicly-available reporting.
 Link air quality monitoring and health surveillance studies when compiling reports.
 Link air quality reporting with other nationally coordinated reporting programmes (for example, the National Pollutant
Inventory, National Greenhouse Emission Reduction programme).
 Strengthen the National Pollutant Inventory and make the data more accessible for the general public.
 Independent monitoring to ensure transparency.
Education and awareness
 Community and/or national education programmes to raise awareness of the sources and health impacts of air pollution, or
on specific issues such as how individuals can reduce wood smoke emissions or the benefits of green infrastructure in
improving air quality.
 Raise awareness of the dangers of inhaling wood fire smoke through the use of health links such as the Asthma Foundation,
Lung Foundation and Heart Foundation.
 Utilise existing professional and community networks to distribute air quality information.
 Establish regular State of the Air Reporting.
Knowledge
 Regular liaison between government and the community to provide information about monitoring and administrative
progress.
 Develop an Australian air quality science research plan, including ways to identify research needs and identify where
research results inform priorities under the Agreement.
 Encourage more substantial scientific analysis of wood combustion and health costs and support industry driven education
programmes.
 Recognise existing industry stewardship commitments.
 Learn from successful initiatives to reduce air pollution implemented overseas.