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The Australian Air National Environment Protection Measure (NEPM) is about protecting human health

In Australia the Air Quality NEPMS https://www.legislation.gov.au/Details/C2004H03935 are a measure "to be implemented by the laws and other arrangements participating jurisdictions consider necessary". Performance against the Air NEPM is assessed at compliance stations located at sites representative of air quality likely to be experienced by the general population. Australia has had national standards and goals for ambient air quality since 1998 (althought the harmful fine particulates (PM2.5) was added in the 2016 revisions to the Air NEPM, to be reported on annually from June 2018). The Air NEPM mandates a consistent approach to air quality monitoring, which has been applied by all states and territories, but — recognising the different legislative arrangements in each jurisdiction — does not dictate the means to be applied to achieve the goals. Performance against the standards and goals is published annually.

In a recent unsuccessful grant application of mine, a reviewer commented that I had a lack of understanding of the process of the development of the standards and asserted:

"1) the criteria are not health-based as such, and the regulatory
policy decisions are not all about minimising health impact"

and

"2) the NEPM for ambient air quality only provides for ambient air
quality that allows for the "adequate" protection of human health
and well-being"

This reviewer makes the assertion that "adequate" protection of health is not the same as "minimising health impact". I guess the argument is that an "adequate" minimum level of health impact should consider a balance between the costs of expenditure on continued reductions in emissions against the benefits to health.

So I think that the criteria ARE health-based, and that the NEPM IS about minimising human health impacts (with the caveat that this is in the context of an economic cost-benefit assessment). For example in the US Colorado continually strives to reduce air pollutant emissions in ways that ensure public health and environmental protections, while maintaining a vibrant economy.

Such a cost-benefit analysis was included in my grant application, and I argue that this is vital to equip state Environmental Protection Authorities (EPA) with metrics to inform interventions. Such interventions are needed as Australian governments try to achieve the National Clean Air Agreement (made between the Commonwealth and each state and territory jurisdictions) which aims to implement strengthened laws that move to even tighter standards in 2025.

Posted in  air pollution policy relevant research


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