Proposed National Environmental Standards for Air Quality

• 1 Introduction
• 2 Overview of Submissions
• 3 Detailed Submission Summary
• Appendix A: Public Notices
• Appendix B: Index of Submitters

3.6 Emission standard for new home-heating appliances

Submitter 1 is concerned about the application of a technology standard to domestic heating that is perhaps not based on modelling, when industry is required to model. The submitter wants modelling to demonstrate that the proposed standard for wood burners is robust and will meet the air quality standards, and that the modelling takes into account the actual emission profile. The submitter also seeks information on the replacement rate of appliances and an analysis of how quickly this will affect air quality.

Submitter 2 considers that the standard should be based on emissions so that it can accommodate any add-on emission control. The submitter considers that the testing standard urgently requires revision and that the standard needs to be lower than 4 g/kg for it to have any effect. The submitter wants direction to be provided to councils on how to encourage replacement of old burners, potentially via a national incentive scheme. Because the rate of burner replacement will be low, a three- to four-year timeframe is very optimistic.

Submitters 6, 163 and 174 generally support the standard, but want:

• clarification on whether the standard applies only to "urban" areas and whether these are defined according to district and city council plans
• all new and retro-fitted open fires to be subject to the requirements of the design standard, and controls over existing open fires to be considered on a regional basis
• district and city councils to be explicitly charged with ensuring compliance with the standard.

Submitters 12 to 24, 30, 32, 47 to 64, 92, 103, 105, 106, 132, 141, 142, 132 and 187 to 196 request that the standard be set at 4 g/kg because they believe this standard has not been allowed sufficient time to take effect. In particular, there are a large number of old appliances, appliances are not properly maintained and operated, and there are no controls on firewood. An education programme for the correct operation of solid-fuel appliances would be more productive.

Submitters 12 to 24, 30, 32, 47 to 64, 92, 103, 105, 106, 132, 141, 142, 132 and 187 to 196 also request that:

• overseas test methods that deliver equivalent results to those in AS/NZS 4013:1999 be recognised as suitable alternatives
• a code of practice and industry regulations be adopted for firewood merchants
• a programme for the removal of inefficient burners and open fireplaces be instigated
• the installation of cookers, heat circulating fires and boilers be exempt
• some areas with unique problems be allowed to adopt lower emission levels provided there is sufficient evidence to justify the action.

Submitter 19 seeks clarification of the role of regional councils in implementing the standard, and wants appropriate amendments to be made to the Building Act 1991 to allow territorial authorities to implement the standard.

Submitter 25 requests that coal burning be banned unless in a 4 g/kg enclosed appliance, that older open fires be phased out and replaced with circulating heat designs, and that the measures not limit the consumer's right of choice. The submitter opposes the 1.5 g/kg limit and considers it should be 4 g/kg.

Submitter 26 is opposed to the 1.5 g/kg standard because there is no evidence that it is justified in an ordinary urban context. The submitter considers that the approach unduly focuses on wood and coal when increasing petroleum fuel combustion is more of an issue. The submitter seeks a standard that is based on a pollution per heat output basis, and a definition of the terms "urban", "wood" and "coal".

Submitter 31 supports the standard in principle but is concerned about its enforceability, and in particular whether the standard would be breached at the point of sale or when a non-complying burning was actually in use. The submitter notes that enforcement officers cannot enter domestic dwellings without a search warrant, and if the standard is unenforceable then it is inappropriate.

Submitter 36 supports the standard.

Submitter 44 seeks more and stronger education programmes aimed at ensuring the market understands all the issues and has all the information to make an informed choice. The submitter seeks financial incentives and subsidies to use lower-emitting fuels where air quality warrants such incentives.

Submitters 25 and 74 request that the standard address controls on:

• firewood quality (eg, moisture content)
• an education programme focusing on fuel, maintenance and operation
• the use of certified people to install and maintain appliances.

Submitter 74 notes that there has been continuous development of the open fire, with innovative design and new materials seeing reduced emissions and increased efficiency.

Submitter 75 supports the development of the standard but wants an efficiency component to be incorporated, or the standard expressed on the basis of g/MJ heat output. This type of standard would allow comparison on the basis of different fuel types. The submitter requests that a test method that allows for innovation be provided, and wants the standard to be applied to wood and coal appliances throughout the country regardless of where they are used because this will provide for certainty and consistency for all parties. The submitter also seeks clarification on whether all appliances not meeting the criteria are prohibited (eg, open fires, second-hand burners, other enclosed burners), and wants central-heating appliances, cooking appliances and appliances solely for water heating to be exempt from the standard.

Submitter 75 requests that the Building Bill 2003 contain provisions so that territorial authorities can easily implement and enforce the standards through the Building Act 1991.

Submitter 89 supports the standard as it only covers new dwellings and appliances and will not affect existing appliances or open fires and appliances in rural areas.

Submitter 109 supports the standard in principle, but considers that it would be appropriate to apply the standard to all areas rather than having separate standards for rural areas.

Submitter 110 seeks a level of 1 g/kg or an emission-to-power output of 77 mg/MJ because there are already 28 approved sub 1 g/kg appliances and they are no more expensive to purchase or install. Efficiency is important because burning less fuel produces less air pollution. The submitter asks that a minimum efficiency level of 65% be imposed and that emission quantification be on the basis of milligrams of particulate per megajoule of useable heat. The submitter wants the test method to encompass the real-time use of wood burners (including start up) to accurately quantify emissions, because the current methods do not reflect real conditions. Finally, a system to control the sale and use of unsuitable fuels should be introduced.

Submitter 111 supports the labelling and testing regime and requests that it be retained.

Submitter 112 comments that it will be important to consider the implications of standards when setting benefit levels and supplements for low-income people, and for local government to develop subsidy schemes to encourage cleaner options.

Submitter 120 supports a national approach to addressing emissions from domestic burners, but is concerned that the standard does not provide flexibility to recognise that air quality characteristics vary across the country. The submitter requests that consideration be given to the standard being made subject to an air shed's PM₁₀ contamination and wants the Ministry to work with regional councils to establish standards. The submitter seeks a clear definition of what is an "urban area", or that the rule be applied to all areas to avoid confusion and assist appliance retailers and purchasers. Educating people on efficient and cleaner techniques for operating domestic burners must emphasise that for health, safety, and comfort reasons clean and efficient home heating techniques are best. The submitter also wants education to include other forms of heating and the programme to be co-ordinated nationally.

Submitter 120 is concerned that the roles and responsibilities of central government, regional councils and district councils in monitoring and enforcement are not identified. The submitter considers that the responsibilities should be linked to agencies approving the appliances for installation (ie, city and district councils).

Submitter 121 wants the proposed emission standard for new appliances to be adopted, and requests that either (a) the standard is universally applied, or (b) the existing identified urban areas, as identified by the Regional Plan: Air for Otago, is adopted for Otago.

Submitter 121 wants the terms "installed" or "reinstalled" to be carefully defined to avoid doubt, such as when an appliance is being shifted within a building. The submitter also wants the Ministry to pursue a national campaign to promote the appropriate use of home fires.

Submitter 123 supports the standard and asks that it be retained as proposed.

Submitter 125 wants the Ministry to develop a 1.5 g per kg of fuel standard and a fuel efficiency standard of 65%. The submitter also requests that the Ministry include improvements to the specification of heat output by manufacturers in the standard.

Submitter 127 wants the standard to include an efficiency limit such as a thermal efficiency of 65%, or a MJ/kg of fuel use rating.

Submitter 131 considers that the standard should be "equal to or less than 1g/kg" to reflect current design capabilities. An efficiency or mg/MJ criterion should be considered. There should also be powers to license fuel merchants subject to moisture content and fuel characteristics.

Submitter 133 requests that the standards address all domestic home-heating methods including open fires, and that existing sources of home heating be addressed at a national level. The submitter considers that the 40kW limit is an unnecessary loophole.

Submitter 135 opposes the 1.5 g/kg limit and considers that the 4 g/kg limit is more realistic. The submitter considers that eliminating the "human error factor" is more important. The submitter would support national standards and/or registration for fuel suppliers and public education.

Submitter 136 supports the standard but is concerned about the policing of such controls.

Submitter 144 wants the standards to also cover minimum standards for existing residential burners. In particular, existing as well as new discharges should be required to discharge vertically and unimpeded by any obstruction that would reduce the vertical efflux velocity. The standard should include a prohibition on burning plastics, rubber and other noxious materials in any residential fire and a requirement that any residential burner shall not cause an objectionable effect beyond the boundary of the property where the discharge originates.

Submitter 146 asks that pellet fires be excluded from the standard because in terms of mode of operation and performance they are like an LPG or diesel fire. The submitter wants pellet fires to be permitted anywhere due to their low emissions, and wants a section added stating that local rules should give priority to appliances that are better than the standards.

Submitter 149 considers that a standard of 4 g/kg is achievable and realistic, and that this should be implemented in conjunction with education on burner operation and fuel quality.

Submitter 154 supports the proposed emission standard and asks that an efficiency requirement be included.

Submitter 159 supports the standards but considers that it also needs to:

• include an efficiency standard of 65%
• impose controls on fuel quality
• promote education on operation of wood burners
• prohibit the use of "overnight burns" and burn times as a promotional tool for wood burners
• encourage innovative designs to improve efficiencies.

Submitter 159 is concerned that the standard will eliminate multi-fuel heaters from the market because they cannot achieve the standard, and this will disadvantage some regions.

Submitter 164 requests that a minimum appliance efficiency be included in the standard, that the standard test methods be reviewed to better reflect actual practices in the home, and that a national incentive scheme to replace old fires and wood burners with clean appliances be introduced.

Submitter 165 supports the standard in principle but requests that the emission limit be set at 4 g/kg and considers that there should be no distinction between urban and rural areas. The submitter wants the quality of firewood to be addressed.

Submitter 179 opposes the standard and considers that education about burner operation, maintenance and firewood quality should be the focus to achieve reduced emissions. The submitter is concerned that a person will not be able to reinstall an existing wood burner if it is shifted as part of home renovations. The submitter is also concerned about the definition of an urban area and "changing goal posts" in areas where there is development, and wants all areas to be covered by the current 4 g/kg level.

Submitter 182 requests that the standard only be applied at specific locations where background air quality does not meet the standard. Coal and multi-fuel appliances that are in use on the West Coast cannot meet the standard of 1.5 g/kg and the standard is therefore inappropriate. The submitter considers that an emission standard of 4 to 10 g/kg would be sufficient to bring about an improvement in air quality on the West Coast.

Submitters 146 and 201 want all appliances to be tested using fuel typically used in the appliance, rather than the idealised wood block used to test wood burners, for example. The submitter notes that the idealised fuel is 16 to 20% moisture compared to wood fuel, which is typically 25% moisture, and pellet fuel, which is 8% moisture.

Submitter 146 asks that the limit be set at 1 g/kg because 1.5 g/kg does not represent best available technology.

Submitter 146 wants the weightings for testing to be 5% high, 40% medium and 55% on low setting, while for older houses the equal weightings can be retained.

Submitters 146 and 201 oppose the standard because it does not allow for differing energy contents of fuels or efficiencies of appliances. The submitters propose a dual standard of 1 g/kg plus 0.35 g/kW hr.

Submitter 146 wants the standard amended to require the use of appliances that use manufactured, controlled-quality fuel to be tamperproof in operation and prohibited from burning rubbish or poor-quality fuel.

Submitter 175 asks that the standard ban new open fires in urban areas because they have greater adverse effects on air quality than wood burners. The submitter is concerned that their exclusion from the standard may promote the use of open fires. The submitter also seeks specific exclusion from the standard of central heating appliances, cooking appliances and appliances used for water heating.

Submitter 184 wants the wood-burner standard to be reviewed every five years to keep pace with technology, and the standard to change to 1 g/kg as of 1 January 2006. The submitter requests that "urban area" be defined to protect small settlements and that councils be enabled to impose emission charges based on burner emissions to encourage improvements in technology.

Submitter 186 supports the development of national requirements for home heating, but wants the definition of "urban areas" to be population centres of 1000 persons or more. The submitter also wants the timing for replacement units to be addressed.

Submitter 204 supports the proposed national standards but seeks a standard for wood and coal heaters of 4 g/kg, because the 1.5 g/kg standard is likely to result in more wood being consumed for the same amount of heat output, which means more total emissions.

Submitters 101 and 207 oppose the requirement for mandatory labelling of gas appliances, because gas appliances easily meet the Environment Canterbury requirement that emissions of PM₁₀ be less than 40 mg/MJ. The submitters request that gas appliances be exempt from labelling requirements, but list requirements in relation to flue systems for gas appliances that should be applied.

Submitter 206 considers that the role of the Building Act needs to be addressed as part of the standard.

Submitter 209 comments that the limit of 40 kW for home heating is insufficient for larger homes being built in cold weather zones, which may have other heating demands such as a pool or hot water. The submitter suggests that a limit of 50 kW or more is required to accommodate these developments.

Submitter 209 comments that local authorities do not have the expert resources needed to deal with local issues, and suggests that the standard incorporate a team of nationally recognised experts to assist with setting local standards as required.

Submitter 214 considers that the standards should be applied only in areas where there is an air quality problem. The best multi-fuel burners capable of burning coal can barely meet 4 g/kg, while the replacement of old equipment which may emit 50 g/kg will result in a significant enhancement in air quality. The submitter considers that a non-regulatory approach is appropriate for communities on the West Coast because air quality is improving under the current regime.

Submitter 216 supports the need for national standards but disagrees with the proposed level of 1.5 g/kg because it does not take into account the efficiency of the appliance and does not guarantee that owners will operate the appliances correctly. The submitter considers that more education of wood-fire owners is needed.

Submitter 217 seeks a phase-in period of 5 to 10 years for the proposed emission limit of 1.5 g/kg, with an interim standard of 4 g/kg because many existing appliances meet 4 g/kg and a change to 1.5 g/kg will reduce the range of appliances available.

Submitter 217 supports the use of the AS/NZS test method and would not support the use of alternative test methods unless they are properly verified. The basis on which method equivalency is to be established should be specified in the standard (eg, when accepting results from overseas a requirement for the test laboratory to have IANZ or equivalent accreditation should be incorporated into the standard.

Submitter 217 also considers that the standard should be amended to include limits on efficiency specified in g/MJ (potentially calculated from the energy input), because it provides a better basis for comparison of appliances. While some appliances can comply with the g/kg requirement, they need large quantities of wood to provide the required heat and therefore the effective level of pollution is high in comparison to more efficient units.

Submitter 220 considers that allowing local authorities to introduce higher standards than the proposed national standards is at variance with the aims of the standards to provide "certainty and consistency".

Submitter 221 wants consideration to be given to fine and ultra-fine particles because there may be situations where all forms of combustion heating should be prohibited from vulnerable urban air sheds.

Submitter 228 wants a ban on the use of coal in domestic burners to be implemented within the four-year timeframe. The use of domestic burners should be prohibited when the pollution is forecast to exceed the guideline level, unless there is a power cut. The submitter also seeks:

• an enforcement regime for excessively smoky burners, burners without a permit and stack height controls
• a prohibition on installing burners in houses where there has not been one
• a requirement that permits to use burners be withdrawn when houses are sold.

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