Submission by the Armidale Air Quality Group on the Review of Australia's Vehicle Emissions Standards by the Motor Vehicle Environment Committee (MVEC)
by Dorothy L Robinson,
Armidale Air Quality Group


Current Knowledge of the Costs of Air Pollution on Health

Recent research continues to confirm the damaging effect of particulate air pollution on health. For example, an estimated 400 deaths in Sydney can be attributed to immediate effects of particulate air pollution. These are deaths which happen on the day, or day after, a high pollution episode, compared with an unpolluted day (1). A similar relationship between mortality and episodes of high particulate air pollution was observed in Brisbane (2).

Immediate or short-term effects, however, represent only a small proportion of the total effect. Prospective studies, such as the US Six-Cities Study (3), related air pollution to mortality over periods of several years, enabling adjustment for differences in income, lifestyle, tobacco smoking and other relevant factors. As well as deaths on the day of, or day following, a high pollution episode, these more accurate studies assessed the effects of continued exposure to moderate levels of pollution and demonstrated significant effects of particulate pollution on lung cancer as well as heart and respiratory diseases.

In the Six-Cities study, each additional 10 m g/m3 of fine particle (PM2.5) pollution was found to increase mortality by 14%, seven times greater than the immediate short-term effects observed in Sydney. Adjusting results for Sydney to include both long and short-term effects, PM2.5 pollution may therefore be responsible for some 2,800 deaths every year in Sydney and 7,000 deaths Australia-wide.

Using an estimated cost of $7 million for each additional death (4), the true cost of PM2.5 pollution in Australia would be about $49 billion every year. Ideally, cost-benefit analyses should be based on costs of both long and short-term effects of air pollution, not just those immediately apparent within a day of a high pollution episode.


Particulate Emissions from Diesel Engines listed as a Carcinogen and Toxic Air Contaminant

On 27 August 1998, California EPA officially listed particulate emissions from diesel engines as a toxic air contaminant (5). It is estimated that 14,850 Californians will die of cancer from diesel exhaust. This is despite the fact that only 2-4% of California's vehicles are diesel-powered (5), but they produce 40% of NOx and 60% of particulate pollution from vehicles. One chemical in diesel exhaust, 3-nitrobenzanthrone, is the most strongly carcinogenic chemical ever analysed (6). California has just announced a $25 million Incentive Program to reduce emission from diesel-powered sources.

The disproportionate amount of pollution from diesel vehicles, and its extremely toxic nature has resulted in California Attorney General Dan Lungren and environmental groups suing four of the State's largest grocery stores. The environmental groups stated their goal is to get grocery chains to convert their entire fleets to cleaner-burning fuels, such as liquefied natural gas (LNG). In response, three of four grocery chains named in the lawsuit have stated they will purchase more than 100 LNG-powered trucks.

In view of the research demonstrating large and significant health hazards from diesel particulate emissions, Australia needs to protect the health of the community by adopting World Best Practice emission standards at the earliest opportunity. Failure to do so might lead not only to legal action against transport companies, but possibly also against the Government Agencies entrusted with setting the emission standards. The increased popularity of contingency fee payments for lawsuits ("no win, no fee") enables action to be taken, for example by a cancer victim living close to a freeway, if the case is considered to have a reasonable chance of success.


Should standards in Australia lag behind other countries?

If Europe can adopt Euro 3 by the year 2000, and Euro 4 by 2005, the onus will be to justify why Australia can't do the same, or at least introduce Euro 3 for diesel engines by 2002 and the Euro 4 diesel standards at the same times as Europe. Similarly, if the EU, US, Canada, Japan, Hong Kong and Singapore all had a maximum sulphur limit for diesel of 0.05% by the end of 1997, why not Australia? (It is assumed that the harmonisation of emission standards internationally will require the introduction of Euro 4 or equivalent by 2006, though this is not entirely clear from the discussion document.)

A comparison of projected emissions for the Sydney Metropolitan Air Quality Study (MAQS) Area (Tables 14 and 15 of the discussion document) makes interesting reading. Under Euro 2, CO, HC and NOx emissions from petrol cars will fall by 75%, 73% and 84% from the baseline to 2015; emissions from non-petrol vehicles will fall by 4%, 0% and 3%. By 2015, non-petrol vehicles, (presumably most were assumed to be diesel), will be responsible for 60% of CO, 81% of HC and 89% of NOx emissions from vehicles in the MAQS area. Projections by the BTCE for Australia as a whole suggest NOx emissions will rise from 90,000 tonnes to 111,000 tonnes and particulate emissions from diesels will fall from about 11,000 tonnes in 1999 to 7,200 tonnes in 2015. Given the association between PM2.5 pollution and health, this is nowhere near adequate. Indeed, other research suggests a particle trap could reduce diesel particulate emissions by 90-95% (7). A tightening of the heavy vehicle emission standard even beyond Euro 4, if international agreement is obtained, might provide additional encouragement for the switch to alternative and cleaner fuels.

Air pollution is a community issue. The public, including visitors to Australia, suffer the effects of air pollution. The community should therefore have a say in the trade-off between cleaner air and marginally increased transport costs. We therefore recommend that the MVEC have community representation, to help it do its job more effectively.


Responses to specific questions

Q1. Do you agree/disagree with the paperís argument for tighter standards for vehicle emissions and fuel parameters ?

In view of recent research concerning the health effects of air pollution, tighter standards, especially for diesel engines, are needed urgently and should be implemented as soon as possible.

Q2. In particular do you agree/disagree with the proposal to :
2.1 adopt Euro 2 standards?
2.2 apply the Euro 2 standards from 2002/3?
.3 lower fuel volatility and reduce diesel sulfur content

Euro 2 is now out of date. It will be superseded in 2000 by Euro 3. Current US standards are also stricter than Euro 2. What possible reason could there be for Australia to adopt such an out of date standard in 2002/3 rather than the European standard that will be current at that time (Euro 3)?

Most manufacturers will be planning to meet these standards for the vehicles they sell in Europe and the US, so compliance should not be an issue. If Australia has less strict emission standards than the US and Europe, manufacturers might be tempted to use Australia as a dumping ground for their older, more polluting models. This is hardly desirable or sensible.

The EU, US, Canada, Japan, Hong Kong and Singapore all had a maximum sulphur limit for diesel of 0.05% by the end of 1997. The Brisbane BP refinery has set the pace for this transition in Australia. Ultra-low sulphur content diesel will be available within 2 years. The production of low sulphur diesel throughout Australia will require significant restructuring and rationalisation of the refineries. However, such rationalisation is needed, for many other reasons. In addition, the anticipated community health benefit is significantly greater than the costs of the rationalisation.


Q3. Would you support the adoption of Euro 3 standards, noting that the costs and benefits of such a move have not been assessed in this paper, and that there are significant additional implications for fuel parameters in achieving compliance with Euro 3?
Q4 If you support the adoption of Euro 3 standards, should they be in lieu of Euro 2 in 2002/3, or follow adoption of Euro 2 (say 5 years later)

A harmonisation of international emission standards by 2005/6 will surely require the adoption of Euro 4 or its US equivalent, assuming the two are similar. In fact, Australia has signed an international treaty that requires us to adopt international standards by the year 2006. Even though the costs of a move to Euro 3 by 2002/3 have not been assessed in this discussion paper, the adoption of Euro 3 in Europe in 2000 presumably means it has been assessed as cost effective there. Given the recent research into adverse effects of air pollution, including the Six-Cities and other prospective studies, as well as the studies which resulted in the listing of diesel particles as a toxic air contaminant, there can be little doubt that Euro 3 would be found to be cost effective in Australia. In addition, the move to meet international emission standards as soon as practicable, will have long-term benefits in ensuring Australia is not at a competitive disadvantage when standards are finally harmonised in 2006.

To allow industry the longest possible time to adjust, the decision should be taken as soon as possible to adopt Euro 3 by 2002/3, followed by the agreed harmonisation to international standards including Euro 4 by 2005/6. The MVEC should also consider what standards should be adopted beyond then, particularly in relation to the reduction of particulate emissions from diesel engines, following California EPA's listing of diesel particulates as a toxic air contaminant and its lead in investigating what further standards and strategies - including a move to alternative fuels, emissions testing or retro-fitting of existing vehicles, are needed to protect our community from this toxic and highly carcinogenic air pollutant.

Dorothy L Robinson,
Armidale Air Quality Group



  1. Morgan G, Corbett S, Wlodarczyk, J, Lewis, P. Air Pollution and Daily Mortality in Sydney, Australia, 1989 through 1993. Am J Public Health. 1998;88:759­764.
  2. Simpson,RW, Williams G, Petroeschevsky A, Morgan G, Rutherford S. Associations between outdoor air pollution and daily mortality in Brisbane, Australia. Archives of Environmental Health, 52(6), 1997, 442-454.
  3. 2. Dockery, DW, CA Pope, X Xu, JD Spengler, JH Ware, ME Fay, BG Ferris, FE Speizer. An Association Between Air Pollution and Mortality in Six U. S. Cities. New England Journal of Medicine, 329(24); 1753-59, 1993.
  4. NEPC. National Environment Protection Council. Towards a National Environment Protection Measure for Ambient Air Quality", Discussion paper, July 1997.
  5. California Air Resources Board Diesel Fact Sheet and Press Release Identifying Diesel Particulate Emissions as a Toxic Air Contaminant &
  6. Devil in the diesel; lorries belch out what may be the most carcinogenic compound ever discovered. Fred Pierce. New Scientist (25 Oct 1997)
  7. Hamer M. Clean bill of health for particle trap. New Scientist, 21 Feb 1998.