Local Government Air Quality Toolkit

Module 1:
The science and management of air quality

Contents

1 Measuring air pollution 38

1.1 Measurement and management 38

1.2 Interpreting measurements 40

1.3 DECC monitoring network 43

1.4 Interpreting DECC monitoring data 46

1.5 Additional campaign monitoring 50

1.6 Site-specific monitoring 50

1.7 Emission monitoring and measurement 50

2 Meteorology and air quality 56

2.1 Atmospheric stability 56

2.2 Pollution discharge and dilution 61

2.3 Behaviour of pollution plumes 62

2.4 Predicting pollution effects 63

2.5 Two practical examples 63

2.6 Air quality modelling 65

3 Air pollutants 68

3.1 The normal atmosphere 68

3.2 Gaseous impurities 69

3.3 Particulate matter 74

3.4 Ozone and photochemical oxidants 83

3.5 Odours 87

3.6 Toxic air pollutants 92

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4 Management of air quality 96

4.1 General management of air quality 96

4.2 The management cycle and air quality 99

4.3 Assessing air quality issues 109

4.4 Planning 110

4.5 Consents, notices and enforcement 111

4.6 Complaints and community feedback 112

4.7 Resources 113

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1 Measuring air pollution

1.1 Measurement and management

To manage and monitor changes in air pollution it is necessary to measure the amounts of pollutants in
the air. The two basic physical quantities used in measuring air pollution are mass and volume.

Mass, the amount of matter

The metric (SI) unit of mass is the kilogram with the symbol
It is common to use the term
‘kg’—about the mass of a one-litre carton of milk.
‘weight’ interchangeably
Other metric units of mass that are commonly used are the gram with ‘mass’ to indicate the
for household-sized amounts of material and the tonne for amount of matter. Strictly,
industrial-sized amounts: weight is the force of gravity
on the mass.
• 1 kilogram (kg) = 1000 grams (g)
• 1 tonne = 1000 kg

For some toxic pollutants

For the very small amounts of air pollutants two smaller units
the much smaller unit of
are used:
nanogram (ng) is used:
• 1 milligram (mg) = 1/1000 g = 10 – 3 g = 10 – 6 kg 1 nanogram = 10 – 9 gram
• 1 microgram (µg) = 1/1000,000 g = 10 – 6 g = 10 – 9 kg = 10 –12 kg

Volume, the space occupied by matter

The metric (SI) unit of volume is the cubic metre—about the volume of a home refrigerator.
Other metric units of volume that are commonly used are the cubic centimetre and the litre:
• 1 cubic metre (m3) = 1000 litres (L)
• 1 L = 1000 cubic centimetres (cm3), or
• 1 cm3 = 1/1000 L = 10 – 3 L = 10 – 6 m3
The cubic centimetre is the same size as one millilitre (mL).
It is standard to use the capital ‘L’ here to avoid confusion with the numeral ‘1’.

Relative amounts of air pollutants

Common ways of indicating the relative amounts of air pollutants are:
Concentration as ‘mass per volume’:
• milligrams per cubic metre
mg/m3 or mg m– 3
• micrograms per cubic metre
μg/m3 or μg m– 3

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A ratio of ‘volume of pollutant per total volume of air’:

The non-standard unit ‘parts
• parts per million ppm per hundred million’ (pphm)
may be encountered in some
• parts per billion ppb
early data.

Conversion tables for common air pollutants

To convert from parts per million
(ppm) to micrograms per cubic at 0oC at 25oC Only gaseous pollutants can be
metre (μg/m3) for multiply by multiply by expressed as the volume per
ozone 2141 1962 volume ratio (v/v)—never
particulate pollutants. However,
nitrogen dioxide 2053 1880
both forms can be expressed
sulfur dioxide 2858 2619 as mass per unit volume.
carbon monoxide 1250 1145 To convert from volume per
methane 716 656 volume to mass per volume the
temperature, pressure and
hydrogen fluoride 893 818
chemical properties of the
gaseous pollutant must be
used.

To convert from micrograms per

cubic metre (μg/m3) to parts per at 0oC at 25oC
million (ppm) for multiply by multiply by
ozone 0.0004670 0.0005097
nitrogen dioxide 0.0004872 0.0005318
sulfur dioxide 0.0003499 0.0003819
carbon monoxide 0.0008002 0.0008734
methane 0.001397 0.001525
hydrogen fluoride 0.001120 0.001223

Changes in temperature or pressure cause the volumes of gases to change much more markedly
than the volumes of solids or liquids. So, when dealing with air pollution, it is necessary to have
agreed conditions of pressure and temperature when quoting data.
Two conditions commonly used are:
STP = ‘Standard Pressure & Temperature’: 00C and one atmosphere pressure.
NTP = ‘Normal Pressure & Temperature’: 250C and one atmosphere pressure.

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1.2 Interpreting measurements

In addition to mass, volume and relative amount, two other parameters are important for the
measurement and interpretation of the levels of emissions and of ambient air pollution:
• the rate of emission from an activity or premises
• the time periods over which amounts or concentrations of pollutants are measured.

The technology of measurement also needs to be taken into account in several other respects:
• the collecting efficiency and representativeness of the sampling devices and instruments being
used to make the measurements
• the sensitivity of the analytical methods being used, either online within the measuring
instrument itself or ‘back in the laboratory’
• how the uptake by humans of the pollution is related to the instrument measurement and
associated analysis.

Amounts and rates of emissions

For air quality management and regulatory purposes the plant conditions during emissions
measurement need to be known, and for ambient air quality measurements the meteorological
conditions need to be known.
The ideas associated with the dispersion of pollutants will be discussed in more detail in the next
section on meteorology. This section deals with the basic ideas associated with the amounts,
concentrations and rates of the discharges.

Pollutant emissions from activities and premises typically disperse to a greater or lesser extent
depending on:
• where and how they are released
• their temperature
• the rate of discharge
• the topography of the surrounding land
• the prevailing meteorological conditions
• and, to a much lesser extent, the exit velocity of discharge.
The potential impact of pollutant discharges from activities ranging from the smoke of stubble burning
in a rural area, through dust on a construction site, to unpleasant odours from a fast food shop begins
with how much is released, the rate at which it is released and the type of pollutant.
For example an acute event may occur in which an amount of a pollutant is discharged over a short
period of time, maybe only a few minutes. This may result in a serious impact in the immediate
vicinity—such as odours from a food shop giving rise to complaints, wind-blown dust emissions near
sensitive land use on neighbouring properties or the discharge of a toxic chemical in an accident.

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The discharge of the same amount of such pollutants over a long period of time—that is, at a much
lower rate—may not have the same level of impact. However, if the pollutants have long-term health
effects, such as exposure to fine particles or cumulative toxic materials, the reverse may be true: short-
term higher-concentration exposures may have little effect while long-term lower-concentration
exposures may have a damaging effect.

When assessing or regulating the discharges from any activities it is important to address
management of both normal operations and the potential for acute events when the rate of
emission may be high.

Amounts, volumes and concentrations

Increasing amount

Increasing amount

Increasing Increasing
emission rate concentration

Decreasing time Decreasing volume

The discharge to the air of a given amount of pollutant may take place over a short or long period of
time—at different rates. When dispersed this same quantity of pollutant will then be mixed into
another larger volume of air.
The concentration of a pollutant and the time over which this is averaged are the significant
parameters in terms of impact on the local environment or human health; and consequently on its
measurement and the regulatory standards in the atmosphere that are set for its management.
For example 100 g of emitted CO when confined within a closed space like an unventilated basement
car park of volume 10,000 m3 has a concentration of 10 mg/m3. When dispersed into the open air, say
into a volume that is one hundred thousand (105) times greater, the same amount has a concentration
of only 0.1 μg/m3.

Rates and times

The rate at which pollutants are discharged from a premises is an important consideration for operators
and regulators in their management of the surrounding air quality. This rate is related to:
• the amount of the pollutant released in the activity
• the time over which this occurs
• the rate at which inside air containing the pollutant is extracted to the outside atmosphere
• the capacity of the premises’ filtration system to remove the pollutant from the air being extracted.

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Air pollutants like dust and solvent vapours are customarily taken out of work areas within premises
by means of extractor fans and ducting through filters or absorbers to stacks. It is important that the
volume rate of flow through these is large enough to remove enough air to keep the concentration of
pollutants inside at an acceptably low level. Removing the pollutants from the workplace into the
outside air may solve the occupational problem but leaves the pollution problem. The environmental
impact of these discharges must be managed.

Interior air quality is an issue of workplace health and safety rather than an environmental one.
Some local council officers have found it helpful to work in collaboration with WorkCover officers
when addressing the related air quality issues within and arising from premises and activities.

Air extracted to the atmosphere

• Volume rate of extraction
• Concentrations of pollutants
• Amounts of pollutants emitted to the
atmosphere in a given time

Pollutant vapours inside the

premises
• Amounts of pollutants
released in a given time
• Concentrations of pollutants
inside the premises (OH&S)
• Volume rate of extraction

Filtration system to remove pollutants:

• Volume rate of extraction
• Concentrations of pollutants in the air drawn through
the filtration system
• Amounts of pollutants trapped in a given time

The filtration system being used must then be able to remove enough of the pollutants so their
concentrations in the flow from the stack into the outside air are also acceptable—an environmental
pollution issue. When any extracted air is discharged to the outside atmosphere from a stack, the
location and height of the stack must allow acceptable dispersion.

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1.3 DECC monitoring network

The NSW Government commenced air quality monitoring 50 years ago. During this period the
monitoring network has been maintained, expanded and developed into a modern, reliable and
accessible management tool.
Extensive information on the DECC monitoring network is available from the DECC website at
www.environment.nsw.gov.au/air/airqual.htm.

Rural monitoring sites are located in the following cities; most are operated by DECC in
collaboration with the local council:
Albury TEOM PM10

Bathurst TEOM PM10 and ozone

Tamworth TEOM PM10
Wagga Wagga TEOM PM10

The current monitoring network for Sydney, the Lower Hunter and the Illawarra regions are shown
below. In each map the colours show the heights above sea level.

The current DECC monitoring network in the Sydney Metropolitan Region

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The current DECC monitoring network in the Lower Hunter

The current DECC monitoring network in the Illawarra

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Purposes of the DECC network

The current purposes of the DECC network are to:
• measure the quality of outdoor air to which the general community is exposed
• provide information needed for daily bulletins & forecasts (e.g. the Regional Pollution Index) and
health warnings
• indicate progress in air quality management, and
• provide inputs to planning.

DECC monitoring locations

DECC monitoring locations (‘monitoring stations’) are carefully located according to accepted
standards to allow consistency of measurement over time of the general atmosphere in an area. Each
location takes account of regional meteorology and the proximity of sources. Some local councils
provide support to DECC in the operation of monitoring stations.
The monitoring stations are not intended to measure the impact of specific sources, such as
individual factories or transport corridors.

Monitored air pollutants and data

The air pollutants routinely measured in the network include:
• ozone (O3)
• nitrogen oxides (NOx)
• sulfur dioxide (SO2)
• carbon monoxide (CO)
• particulate matter as:
– total suspended particles (TSP)
– particulate matter smaller than 10 μm (PM10)
– particulate matter smaller than 2.5 μm (PM2.5)
– visibility effect measured by nephelometry
• lead (Pb).
These pollutants are described in section 3 of this Module.
The measurements are generally continuous except for TSP and lead which are measured on a 6-day
repeating cycle giving 61 samplings per year.
Meteorological conditions are also routinely measured in the network, including wind speed,
direction and turbulence.

The methods and instruments used to monitor these pollutants are scientifically complex and do
not need to be understood in order to use the monitoring data. Further information is available on
the DECC website: www.environment.nsw.gov.au/air/nepm/index.htm

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1.4 Interpreting DECC monitoring data

DECC routinely reports monitoring data collected in the network. The data is available on the DECC
website www.environment.nsw.gov.au/air/airdata.htm and is updated daily or quarterly, depending on
the parameter.

The regional pollution index (RPI)

As a consequence of a major review of monitoring needs in 1993, a regional pollution index (RPI) is
calculated and reported twice daily for three regions in Sydney (Eastern, North Western and South
Western), three sites in the lower Hunter and four sites in the Illawarra.
The morning RPI covers the period from 3.00 pm the previous day to 6.00 am that day (15 hours) and
the afternoon RPI covers the period 6.00 am to 3.00 pm that day (9 hours). The RPI reports are based
on measured concentrations of ozone and nitrogen dioxide and a measure of visibility. A simple
description of how the RPI is calculated can be found on the DECC website:
www.environment.nsw.gov.au/air/rpi.htm.

Variability

The observed variability for different pollutants arises from many different factors:
– the physical and chemical behaviour of the pollutants in the different seasonal weather
conditions
– changes in people’s travel and energy use patterns at different times of the year
– seasonal patterns in the use of wood heaters

– seasonal cycles in farming practices

– hazard reduction burning in cooler months

– the occurrence of natural events like droughts, dust storms, rainfall and bushfires.

If the total amount of air pollution discharged by sources only changes slowly, as is the case for large
urban or industrial areas, then the main variability in air quality will depend on daily and weekly
patterns of discharge and daily and seasonal variations in meteorology and weather.
So the changes in traffic flow throughout the day, with morning and evening peak periods, will
markedly change the rates of emissions of nitrogen oxides (NOx) and volatile organic compounds
(VOCs). Likewise activity patterns on weekdays will be significantly different from those on
weekends.
Dispersion is affected by variation in synoptic conditions. During the day some synoptic patterns
favour conditions where dispersion is governed by synoptic winds or regional sea breezes, while at
night, dispersion can be influenced by regional topography and ‘stable drainage’ flows. More of these
aspects are considered in the following section on meteorology.

Measured ambient pollutant concentrations depend on many factors and a general trend may be
overlaid with the consequences of particular events.

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 Mic r o g r am s p er c u b ic m et r e at 00 C Micr ogr ams per cubic metr e at 00C

0
100
200
300
400
500
600
0
5
10
15
20
25
30
January . 2001 January . 2001
Fe b r u a r y . 2 0 0 1 February . 2001

pictures.
Ma r c h . 2 0 0 1 March . 2001
A p r il . 2 0 0 1 April . 2001
Ma y . 2 0 0 1 May . 2001
June . 2001 June . 2001
J u ly . 2 0 0 1

Monitoring Reports.
July . 2001
particulate pollution.
August . 2001 August . 2001
Se p t e m b e r . 2 0 0 1 September . 2001
Oc tober . 2001 October . 2001
No v e m b e r . 2 0 0 1 November . 2001
De c e m b e r . 2 0 0 1 December . 2001
January . 2002 January . 2002
Fe b r u a r y . 2 0 0 2 February . 2002
Ma r c h . 2 0 0 2 March . 2002
A p r il . 2 0 0 2 April . 2002
Ma y . 2 0 0 2 May . 2002
June . 2002 June . 2002
J u ly . 2 0 0 2 July . 2002
August . 2002 August . 2002
Se p t e m b e r . 2 0 0 2 September . 2002
Oc tober . 2002 October . 2002
No v e m b e r . 2 0 0 2 November . 2002
De c e m b e r . 2 0 0 2 December . 2002
January . 2003 January . 2003

Maximum 1-hour level in the month

Fe b r u a r y . 2 0 0 3 February . 2003
Ma r c h . 2 0 0 3 March . 2003
A p r il . 2 0 0 3 April . 2003
Local Government Air Quality Toolkit

Ma y . 2 0 0 3 May . 2003
June . 2003 June . 2003
J u ly . 2 0 0 3 July . 2003
August . 2003 August . 2003

All Hours Average

Se p t e m b e r . 2 0 0 3 September . 2003

Var iations of 1-hour clock aver ages of TEOM - PM10 in Lindfield

Oc tober . 2003 October . 2003

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No v e m b e r . 2 0 0 3 November . 2003
De c e m b e r . 2 0 0 3 December . 2003

hour concentrations in each month for the same monitoring station at Lindfield.
January . 2004 January . 2004
Fe b r u a r y . 2 0 0 4 February . 2004
Monthly all hour s aver ages of TEOM - PM10 in Lindfield (1-hour clock aver ages)

Ma r c h . 2 0 0 4 March . 2004
A p r il . 2 0 0 4 April . 2004
Ma y . 2 0 0 4 May . 2004

intended only to illustrate variability and how different averaging methods give very different
June . 2004 June . 2004
Bushfires of course occur principally in the hot summer months and contribute significantly to

It is evident that the monthly averages smooth out large spikes in concentrations that occur over

J u ly . 2 0 0 4 July . 2004
sun during summer makes this the principal season for photochemical smog and ozone formation.

August . 2004 August . 2004

shorter periods of days or even hours. This can be seen in the next graph showing the maximum 1-
greater in summer than in winter. However, the higher temperatures and stronger radiation from the
There will also be significant seasonal influences due to weather. Dispersion tends to be generally

The two graphs here are not meant to be representative of regional or even local trends. They are
matter at one Sydney metropolitan monitoring station, as reported in the DEC Quarterly Air Quality

Se p t e m b e r . 2 0 0 4 September . 2004
The graph below shows the variations in monthly all hours averages for concentrations of particulate

Oc tober . 2004 October . 2004

No v e m b e r . 2 0 0 4 November . 2004
De c e m b e r . 2 0 0 4 December . 2004
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The Quarterly Air Quality Monitoring Reports published by DECC contain monitoring data for the
key pollutants and can be accessed at: www.environment.nsw.gov.au/air/datareports.htm

Intermittent sampling
Large unmeasured
peak in pollutant

24-hour sampling Fluctuating

periods every ‘real’ pollutant
sixth day concentration

In the case of some pollutants the sampling has been intermittent by choosing to take 24-hour
samples every sixth day. This protocol reveals trends in particulate pollution over longer periods of
months, seasons and years but may miss acute events that occur on days when sampling is not done. In
the diagram the sharp peak is not recorded simply because it did not occur on one of the sampling
days.

Averaging periods
It is important to consider the averaging period for air pollution monitoring data. Ambient monitoring
is usually carried out in accordance with NEPM monitoring protocols—that is, for the following
different time periods for different pollutants:
• 1 hour (clock hour average)
• 4 hours (rolling 4-hour average of 1-hour averages)
• 8 hours (rolling 8-hour average of 1-hour averages)
• 1 day (calendar day)
• 1 year (calendar year).
In general, existing pollution and meteorological patterns result in the maximum measured
concentrations becoming lower with longer averaging times; that is, a maximum daily average is
typically much lower than a maximum 8-hour or maximum 1-hour average.

Air quality data for the same pollutant can only be compared for similar averaging periods.

Data for different averaging periods cannot be directly compared.

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Different averaging periods are used in some aspects of air quality management such as impact
assessment. These include for example:
• 10 minutes (sulfur dioxide)
• 15 minutes (carbon monoxide)
• 7, 30 and 90-day (rolling) averages (hydrogen fluoride).
Longer averaging times tend to relate to pollutants which can have longer term cumulative effects on
health, vegetation or property—for example, the toxic metal lead which is described in more detail
below.
Shorter sampling times tend to relate to acute, immediately detected pollutant impacts, such as those
resulting from sulfur dioxide and ozone exposure.

Health and meteorological aspects of averaging

It is important to appreciate that there are two factors that are associated with the averaging times
specified for air pollutants in standards:
• health impacts—pollutants having chronic impacts (e.g. heavy metal toxics) tend to be specified
by longer averaging times, while those having acute effects tend to be specified by shorter
averaging times, and
• meteorological and climatic effects—variability in air movements and air turbulence generally
result in ambient concentrations being lower for longer averaging times for a constant rate of
emission from a point source.
The relationships between averaging time and impact and between averaging time and meteorology
tend to coincide, but are not necessarily identical. Hence care is needed in considering all aspects of
exposure as illustrated below:

Health impacts, averaging times and exceedences

For some pollutants, clinical and epidemiological research indicates their health impact is
essentially chronic and mainly due to prolonged exposure causing cumulative damage to some
body organs or tissues. If this is the case, the NEPM may include a standard with a long averaging
period of one year and an associated goal of zero exceedences of this. This is appropriate only on
the assumption that the human body can effectively deal with somewhat higher maximum
concentrations over shorter exposure times and without either irreversible damage or permanent
accumulation of the pollutant within some part of the body.
For some pollutants (including those with chronic impacts), the medical evidence indicates that
short term exposures do in fact have acute detrimental effects on people’s health, particularly the
vulnerable in the community such as children, the elderly and those with existing medical
conditions. In these cases the NEPM standards are specified for much shorter averaging periods
of one, four or eight hours.
As clinical and epidemiological research continues to identify the health impacts of both long-term
and short-term exposures to different concentrations of different pollutants, the air quality
standards and goals, and other regulations, may be adjusted to reflect this new knowledge.

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1.5 Additional campaign monitoring

From time to time DECC carries out monitoring campaigns for specific pollutants such as volatile
organic compounds (VOCs), as precursors to ozone formation, and toxic air pollutants. More
information is available from the DECC website: www.environment.nsw.gov.au/air/toxics.htm

1.6 Site-specific monitoring

Some large industries are required to install ambient monitors in locations affected by their operations
to measure the specific impact from their emissions, where these are significant. The results of this
monitoring are reported to DECC or the Department of Planning, or both departments.
Usually there are requirements established through development consent conditions for these
monitoring results to be made available to the public through local monitoring committees.

1.7 Emission monitoring and measurement

Emission concentration limits specified for non-scheduled premises are for:
• black smoke or opacity, and
• particulate matter.
Occasionally councils will wish to specify testing for toxic and odorous emissions, but most emission
testing will be related to the above two forms of air pollution.

Smoke and the Ringelmann chart

Incomplete combustion results in the formation of
black-to-grey smoke because of the black carbon
formed in the burning process. This has
traditionally been measured using a Ringelmann
chart under specified conditions.
The method is described here in more detail
than most emission tests since it is the one test
in the Regulation which can be carried out by
council officers unaided.

The Ringelmann chart

The Ringelmann chart in its original form is
constructed by cross-hatching 10 cm white
squares with black lines so that the squares are
successively covered with black in gradations of
20% from white to completely black. The black
This is a diagrammatic coverage of the squares, which appear as shades
representation only. of white → grey → black when viewed from the
Always use the standard
charts for readings! recommended distance, is then designated with a
number as follows:

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20% coverage Ringelmann No 1

40% coverage Ringelmann No 2
60% coverage Ringelmann No 3
80% coverage Ringelmann No 4
100% coverage Ringelmann No 5

Smaller, pocket-sized charts have been produced

by the British Standards Association which have
pigmented squares of equivalent ‘greyness’ to the
standard chart.

This is a diagrammatic
representation only.
Always use the standard
charts for readings!

Note that the North American standards for the Ringelmann method specify a different method of
reading with respect to illumination. Be sure to use the Australian/British method.

The Ringelmann method

The method of using the Ringelmann chart specified in Approved methods for sampling and analysis
of air pollutants 2005 is the method specified in Australian Standard AS 3543–1989 (being equivalent
to British Standard BS 2742:1969).

The principle of reading the Ringelmann chart

The principle of reading the Ringelmann chart requires comparing the shade of the smoke emitting
from the top of the stack to the closest shade on the chart. It only applies to black smoke (not coloured
smoke).

The proper location of the chart, the observer, the stack top and the sun (or sky illumination in
overcast conditions) are precisely defined in the Standard and must be followed if the readings are
to be accepted in any enforcement or legal action.

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In practice, reading the full size chart is difficult in most urban settings and requires a holder
which is able to be both independently secured and elevated about 4 m above the ground surface,
usually at a distance of 10 to 15 m from the observer.
The miniature chart, if marginally more difficult to read consistently, will be found easier to
manipulate. However, even this requires a small holder of about 1 m in length to read properly.
The diagrams below show configurations that could be used by local government officers.

Using the full-size Ringelmann chart

full-sized chart

Chart stand

Using the miniature Ringelmann chart

Chart holder

with miniature chart

Any officer intending to use the Ringelmann chart should refer to the instructions and the Standard
and follow them carefully in preparing for and making the observations.

Calibrated in-stack measurement

The POEO (Clean Air) Regulation also allows for opacity to be

The percentage ‘opacity’
measured by a calibrated in-stack instrument. In-stack instruments
of a gas stream is the
operate on the principle of suspended particles scattering and
percentage of incident
absorbing a beam of light. The light transmitted through the gas
light scattered and
carrying smoke or other particles is measured.
absorbed by the
particles in the gas: Approved Methods for Sampling and Analysis of Air Pollutants
(AMSAAP) sets rigorous requirements for instruments measuring
% opacity =
opacity for enforcement purposes. Note that these instruments, called
100 – % transmittance
‘transmissometers’, are an order of magnitude more expensive than
commonly installed ‘smoke meters’, although both types work on the
same principle of measuring light transmission. With appropriate
situation-specific calibration, transmissometers can be used to measure
particulate emissions continuously. (See section 1.7 ‘Continuous
particulate measurement’.)

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Stack instruments can be required as conditions of consent or as part of a notice or direction in

industries where maintaining clean combustion is a priority.
However, high-quality ‘transmissometer’ instruments are relatively expensive (typically $20,000 to
$40,000 each) and should not be required for the majority of small-to-medium installations which
are not likely to present combustion problems in operation, especially if gas fired. A simple ‘smoke
meter’ usually gives adequate warning of a combustion problem to the operator.

The relation between opacity and Ringelmann limits

The opacity corresponding to the Ringelmann 1 limit in the Regulation is 20%.
However, opacity measured instrumentally can be applied to any colour ‘smoke’, unlike the
Ringelmann method which can only be applied to black/grey smoke.

In-stack measurement of particles

Particulate emissions must be measured using an isokinetic

Isokinetic testing requires
technique to obtain an accurate reading. This requires that a stack
that measurements of gas
test be organised and set up with the necessary standard fittings in
velocity at each testing point
the flue or stack and with appropriate and safe access platforms for
in the stack or duct be
the testing team.
undertaken, and the suction
into the sampling probe Isokinetic testing is important if an accurate and legally
maintained at a rate to acceptable test is to be obtained for any gas stream containing
ensure the velocity of the particles or liquid droplets. Purely gaseous pollutants do not need
gas entering the probe is the to be sampled isokinetically. Isokinetic sampling can add
same as the velocity of the substantially to the difficulty and cost of testing.
gas passing the probe—
Many of the tests for toxic pollutants (e.g. metals, dioxins,
hence the term iso ( = the
polyaromatic hydrocarbons) may involve isokinetic testing since
same) + kinetic (= moving).
some of the pollutants will be present in particulate, aerosol or
If the sample is not taken in droplet form. Also, if the gases are very hot or contain much
this way, it will not be moisture, it may be necessary to use a heated probe for the testing
representative of the gas (to avoid condensation on the probe).
being sampled.

Analysis of particulates extracted

The sample gases withdrawn from the stack are passed through an efficient filtration system and the
particles collected weighed and analysed as required. The results are corrected to conditions
corresponding to dry gas at 0 C and standard atmospheric pressure. If the test is made on a boiler or
incinerator the result must also be corrected to 12% carbon dioxide, so a representative carbon dioxide
test must also be carried out during the test.

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Testing location
An important factor is to position the testing location in a section of the duct or stack which has
relatively even flow distribution. Ideally this is 10 stack diameters downstream from a bend or fan
outlet, but this ideal sometimes has to be compromised.

What to look out for

There are pointers for local government officers to look out for when tests are being conducted. If the
testing contractor does not appear to be following sound procedure the testing and results can be
questioned and a second opinion sought.
The methods are fully specified in AMSAAP and tests should only be carried out by accredited and
experienced testers. The testing team should be fully familiar with the requirements of the Regulation
and Standard and the situations in which the various techniques should be applied.

The key factor to appreciate is that if local government officers specify particulate testing, the
inherent methodology of in-stack measurement of particles is relatively difficult and requires
considerable time and effort to organise and carry out.
Thus stack tests for particulate emissions or requiring isokinetic sampling should only be specified
when there is a clear justification.
Typically a one-off test can cost from $5,000 to $30,000 depending on the set-up costs involved
(e.g. stack openings, platforms, access ladders, etc.).

Continuous particulate measurement

The technique and instruments used for measuring opacity for compliance (the ‘transmissometers’
described in section 1.7 ‘Calibrated in-stack measurement’) can also be used for indirect continuous
measurement of particulate concentrations.
There is not a simple relationship between the mass of particulate matter present in a gas being
discharged and the light interference properties of the particles, thus a correlation has to be made for
each situation before mass emissions of particulates can be reliably monitored. However, once such
site-specific relationships are established—that is, the instruments are calibrated to the situation—
continuous monitoring can be a valuable adjunct to managing environmental performance, especially
for a process which is inherently variable.

Continuous gaseous measurement

Local government will only rarely have to consider gaseous monitoring of pollutant emissions, but
should be aware that there are many well-developed techniques for monitoring gaseous pollutants both
on a specific-testing basis and continuously.

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Typical gases which can be monitored continuously include:

• nitrogen oxides
• sulfur dioxide
• volatile organic compounds (as hydrocarbons)
• acid gases
• hydrogen fluoride
• carbon monoxide
• carbon dioxide
• oxygen.

Further discussion about the nature, trends and impacts of gaseous pollutants is contained in Module 1
section 3.

More detailed technical information about the principles and operations of the instruments now
available for these measurements is easily found using an internet search engine.

Odour emission testing

Odour testing is discussed
There is no reliable method of directly measuring odour by
further in section 3 of this
scientific instruments. The best odour detecting instrument
Module.
remains the human nose. Odour tests involve taking samples of
The guidelines in Module 3 air at the point of emission and quickly transferring the samples to
address particular premises a panel of carefully selected odour observers. The panel determines
or activities where odour essentially the degree of dilution of the odour required to reach the
problems typically arise. point of non-detection.
There are several methods for this type of testing and it is highly
specialised, and therefore also relatively expensive. Even then
significant differences persist between the various methods used to
measure odours.
For relatively minor problems careful field assessment of the
odours might be more practical and effective than calling for
expensive odour testing.

Local government officers should be aware of the uncertainties

and expense involved in odour testing which usually needs to
be interpreted in terms of atmospheric dispersion modelling—
another expensive component of the assessment.

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2 Meteorology and air quality

2.1 Atmospheric stability

For managing air quality it is helpful to have some qualitative understanding of how atmospheric
conditions change with time of day or night and with wider weather conditions—in other words how
the atmosphere ‘works’ at the local and regional scale1.

The main causes of changes in atmospheric stability are heating of land surfaces by the sun
during the day and cooling of the surfaces by the radiation of heat at night.

Neutral stability
With a moderate to strong wind in moderate sunshine or
Atmospheric stability
an overcast sky the atmosphere will be in a state of
‘neutral stability’. This condition depends on the The idea of atmospheric stability is
physical properties of the air and water in the complex and can sometimes be
atmosphere. In neutral stability the temperature of the air confusing.
decreases uniformly as we go upwards, at about 10C per The atmosphere is said to be
100 m. This uniform temperature gradient continues up ‘stable’ when conditions inhibit the
to about 10 km above the earth’s surface. However, the vertical motion of air and the
region of most interest for pollution is the lowest two resulting turbulence that causes
kilometres. mixing and dilution of pollutants.
During conditions of neutral stability a parcel of air In an ‘unstable’ atmosphere
moved to a different height will have the same density turbulence is enhanced by the
after moving as the surrounding air at that height. So conditions and so there is an
there is no density difference, or buoyancy, tending to increase in mixing and dilution.
move it back again.
A ‘neutral’ atmosphere neither
This explains the term ‘neutral’. Also pollutants are inhibits nor enhances air
mixed readily and predictably in the wind in neutral turbulence.
conditions. So they disperse and dilute as they are blown
downwind from the release point. It is an interesting fact that the
atmosphere can be very unstable
By applying meteorological science to the conditions we under some low wind conditions
can predict fairly accurately what the concentration of but at other times neutral, even
pollutants will be at different locations away from the with high wind speeds.
source.

1
This discussion of meteorology is not intended to provide a general introduction to meteorological
science, but rather to introduce in practical terms those aspects of the atmosphere which are likely to
be of immediate interest to local government officers.

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Altitude →

0
1 C / 100 m Inversions
When the air temperature increases (rather than decreases)
with height this is called a temperature inversion.
During the day the ground is heated by incoming solar
Temperature → radiation. After sunset, when there is no incoming solar
Neutral stability – mild day radiation, the ground loses energy and cools. The air
immediately above the ground is also cooled and becomes
0 denser. The thickness of the cold layer of air extends upwards
Altitude →

1 C / 100 m
as the night draws on. The air below is now cooler than the air
above.
Inversion
So, somewhere above the ground there is now warmer air than
Cooling from
ground at the ground. This is called a ‘radiation or nocturnal
inversion’. If the term ‘temperature inversion’ is used
Temperature →
without any qualification it usually refers to this type of
Stable, inversion – night
inversion. The lower atmosphere is now said to be ‘stable’
because the higher warm layer restricts vertical mixing of air
and any pollutants in it.
0
1 C / 100 m
There are other types of inversion but the radiation inversion is
Altitude →

the most important when considering dispersion of pollutants

Inversion emitted near to the surface.
aloft
Heating from A stable atmosphere and a temperature inversion have some
ground important effects on pollution released:
Temperature → • The stable atmosphere is less turbulent and the pollution is
Breaking inversion – morning less mixed. Both horizontal and vertical mixing are
restricted. That is, the concentrations downwind are less
diluted.
Altitude →

• The temperature inversion can trap warm pollution closer to

0
1 C / 100 m

the ground than during the day when its heat would carry it
higher into the air, so with reduced height the downwind
concentration is again less diluted.
Temperature → • In some circumstances a temperature inversion can stop
Neutral stability restored – day elevated pollution from reaching the ground.

Instability
Altitude →

0 During a hot, still day, when the sun beats down strongly, the
1 C / 100 m
ground can become very hot and heats the air at the surface.
Strong heating
The hot less dense air rises rapidly and results in large eddies
from ground (convection) causing an unstable atmosphere. The turbulence
created generally results in better mixing of pollutants in the air
Temperature → but can also bring pollutants discharged at height to the
Unstable – still, hot, sunny day ground.
Contrary to popular belief, very windy weather—the sort that
blows our umbrellas inside out—is not meteorologically
unstable. It is entirely ‘neutral’, just very turbulent.

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Katabatic or ‘down-slope’ air movements

Stable cool air, formed near the ground at night, has
important consequences for pollutant dilution and dispersion
in valleys or land depressions. When it forms on high land
such as hills or mountains, this cool air becomes denser and
flows down over the sloping land surfaces into the valleys
where it can accumulate in low-lying depressions. The
technical term is a ‘katabatic’ flow (from the Greek words
kata = down and batikos = able to go).

Nocturnal ‘drainage’ flow Because these drainage flows depend on

the cooling and heating of the land they
Katabatic flow coupled with inversions can play a are not usually important when it is
significant role in pollutant dynamics over regions such as heavily overcast or rainy.
the Sydney Basin. The Sydney Metropolitan Area is like a
huge basin with mountains to the west and hills to the north Under such overcast or rainy conditions
and south, but with the east side open to the ocean. Cold, the atmosphere stays ‘neutral’ day and
stable air formed at night over the Blue Mountains and the night, the temperature varies less from
Hornsby and Sutherland plateaus flows down into the basin day to night and pollution disperses in the
and makes its way steadily eastward towards the ocean. This wind in the normal way.
is sometimes referred to as the nocturnal ‘drainage’ flow.

Large scale air flows and

pollutants in the Sydney Basin
(Based on an original drawing done by Rod Bashford of
Macquarie University for a paper by E. Linacre and
C. Edgar presented at a Clean Air Conference.)

The mass of cold, stable air is also under a temperature

inversion and traps and suppresses the dispersion of the
pollutants emitted by the city—the origin of the
characteristic brown haze over Sydney on winter mornings
and the white haze on summer mornings.
As the sun heats the ground it warms the air above it and
begins to break down the temperature inversion and restore
the air to a neutral stability. Mixing improves and the
Slope flow and valley flow—this sort
pollution disperses until it is usually no longer visible by of effect is evident along the
late morning. Dumaresq River in Armidale

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It is the temperature inversion that traps the emissions, the

Inversions coupled with katabatic or
drainage flow then transports the pollution—often quite
‘down-slope’ drainage flows of cold air at
effectively across a large region.
night trap and exacerbate pollution in
The same sort of effect is also evident in the Hunter Valley regions such as Sydney, the Hunter
and on a smaller scale in Armidale. Valley and in localities like Armidale.

When sea and land meet

There is another important effect whenever land and water meet. The temperature of a large body of water
changes very little over the diurnal cycle of night-to-day and day-to-night. By contrast the land experiences
much larger diurnal changes in temperature. Thus the air over the water tends to stay at a reasonably
constant temperature day and night. But as we have seen above, the temperature of the air over the land
does change quite markedly between day and night. This difference significantly impacts on the atmospheric
movements where bodies of water like the ocean or large lakes adjoin land masses.

Sea breezes
The dynamics of air movement are such that this difference
results in a sea breeze in the mid morning as the air over the
land heats up, rises and is displaced by cooler air from the
ocean. If it is not removed by more widespread ‘synoptic
flows’ associated with high or low pressure regions, the hot
air goes out to sea aloft, is cooled above the water, then
settles and flows back over the land again. That is, a
circulating cell may be set up and a sea breeze is created
from the ocean to the land.
There are two effects on pollution in places like Sydney.
The first is beneficial in that the sea breeze can bring in
clean air from out to sea. The second is a detrimental effect,
the accumulated pollution of overnight and early morning
emissions caught in the drainage flow is blown back over
the land by the sea breeze from mid morning to mid
afternoon—Sydney then gets a double dose of its own
pollution!

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Smog in Sydney
As we will see in section 3 of this Module, the sea breeze Of course there are also emissions from
plays an important role in the formation of photochemical the Sydney CBD that contribute to the
pollution in the Sydney Basin, which usually needs about mixture. Sometimes the emissions from
three to four hours for the ingredient pollutants to ‘cook’ the previous day are also re-circulated by
and form photochemical ‘smog’. By the time they reach the combination of the sea breeze and
south-western parts of the basin in mid to late afternoon, drainage flows.
emissions from the whole city, including from the western
and north-western suburbs in the morning, are well cooked
and can deliver a peak dose of ‘smog’.

The overnight drainage flow and the sea breeze interact to

influence pollution in Sydney, especially during summer
when photochemical smog forms.

Land breezes and anabatic flows

The reverse of a sea breeze is a land breeze at night. At
night the air over the ocean remains warmer than the air
over the land due to the faster cooling of the land compared
to water. The colder heavier air over the land then flows
offshore to replace the warmer air above the water. A
circulating cell that is the reverse of the daytime one may be
set up, although the offshore land breezes are typically much
weaker than the onshore sea breezes.
If the offshore flow is supported by a katabatic drainage
flow, as it is in Sydney, then this tends to strengthen the
flow of air from the land to the ocean at the shore. Similar
effects can occur over other water bodies, notably lakes and
dams, depending on their depth and capacity to hold heat.

Up-slope flow near steeply rising land

As there is a reverse of the sea breeze so there is a reverse of
the katabatic flow, namely an anabatic flow (from Greek
ana = up). This is usually only experienced in the vicinity of
steeply rising land, such as the cliffs and mountains adjacent
to the Illawarra coast.
The morning sun heats the cliff faces or mountain sides and
this in turn heats the air next to it which rises rapidly. This is
less important for air quality than the katabatic flow.

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2.2 Pollution discharge and dilution

A ‘plume’ is a trail of pollution issuing from
Pollution is moved as a plume by wind from a chimney or a localised source that spreads out as the
stack into the environment where it changes the quality of trail travels downwind.
the air. The change in air quality depends essentially on two
factors:
• the amount of pollution discharged, and
• the way in which the air moves in the atmosphere.
There is a simple relationship between the amount of
pollution released from a source and air quality. Double the
pollution discharge and the concentration of pollutant on the
ground downwind also doubles, all other things staying the
same.
In general the faster the wind speed the more the dilution
of the pollution from a stack and the lower the
concentration. This is also a simple relationship—double the
wind speed and halve the concentration, all other things
staying the same.
The further from the source the greater the dilution of the The effective height of discharge is
pollution, with a few important exceptions explained below. composed of the physical stack height
But this is not a simple relationship—doubling the distance plus the plume rise due to its buoyancy
generally more than halves the concentration. and exit velocity.
The effective height of discharge also influences the Thus the temperature, the volume and the
concentration of pollution at ground level. Generally the velocity of the gas being discharged are
higher the effective height of discharge the less the important factors determining ground
maximum concentration of pollutant at ground level. But level pollutant concentration.
again this is not a simple relationship.
However, the most significant factor for
Dilution of pollution in the air, or ‘dispersion’ is quite most premises that are regulated by local
complex and is understood through the science of government will be the height of the
meteorology. The capacity of the atmosphere to dilute stack in relation to its surroundings.
pollution is also dependent on the mixing properties of the
air blowing over the surface of the ground or water. This is
the already described ‘stability’ of the atmosphere.

The concentration of pollution in the atmosphere downwind from a source depends on:
– rate of pollutant discharge
– wind speed
– distance downwind from the source
– effective height of the discharge
– stability of the atmosphere, and
– ground surface features (e.g. vegetation, trees and hills).

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Of course all of the above relationships only apply to the

dilution process alone. If pollutants are reacting in the
atmosphere, such as in the case of photochemical pollution,
then the concentration of an undesirable pollutant such as
ozone may increase with distance from the source.

2.3 Behaviour of pollution plumes

The way the plumes disperse
Pollution released from a source, typically a stack from an depends on:
industry or business, moves in a plume. In days gone by
– the meteorology
visible pollutants could be observed moving in a plume.
Because of more effective removal of particles from – the topography
industrial and vehicular emissions, much pollution is now
– the surrounding buildings, and
invisible but is still very real.
– the emission characteristics.
As described above, the wind, the atmospheric stability and
the effective height of release (that is, the stack or chimney
height plus plume rise) essentially govern the way the plume
disperses in ideal circumstances. However, circumstances
are rarely ideal and some examples will show how the first
three factors can interfere with ‘ideal’ dispersion.

Trapping by or above an inversion layer

If the plume becomes trapped in an inversion layer aloft,
the pollution can be transported, sometimes a large distance
from its source and then fumigate to ground level. If the
emissions are above the stable inversion layer the
phenomenon called ‘lofting’ occurs. In either case, when the
pollution moves to ground level, it can be difficult to trace
its source.

Nearby hills
If there are medium to large hills or mountains near sources
the plumes can impinge on this higher ground causing
higher levels of pollution than would be the case in the
‘ideal’ situation. This effect is likely to be more important
under stable atmospheric conditions.

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Nearby buildings
Most stacks that release pollutants are near or on buildings.
These buildings affect the normal air flow around them. We
become aware of this in windy weather when we can be hit by a
blast of air on coming around the corner of a building. The
effect on pollutant plumes in all wind conditions is to cause
some ‘downwash’ of the plume and higher concentrations
closer to the source than would occur for ‘ideal’ dispersion.

2.4 Predicting pollution effects

Several well proven air dispersion models that take account of all these factors are described in section
2.6 of this module. They require specialist expertise in air sciences and computing. Such services are
best contracted as required for accurate predictions.

Air pollution concentrations can be predicted by accurate modelling by dispersion experts.

However, a practical knowledge of the factors affecting plume dispersion can address simple
small-scale problems without the need to resort to expensive modelling.

2.5 Two practical examples

Two examples of relevance to local government air quality management are described below. They
illustrate how a practical, qualitative understanding can be a useful guide when assessing premises
or activities.

Domestic wood smoke in a valley

Near steeply rising ground, simply raising the height of the chimney on domestic wood heaters to the
‘regulation height’ above the roof line is not likely to be entirely effective.
In windy weather the plumes from lower houses will impinge on houses at higher levels.

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On still nights the emissions from higher houses will be caught in the katabatic flow and tend to
accumulate in the gullies below.

Understanding these sorts of situations and achieving satisfactory solutions can be achieved by
applying the qualitative meteorological principles described above, without the need for expensive
quantitative modelling.

Stacks on seafront food shops

Fast-food shops are often located on the sea front in many coastal towns and suburbs. If the stacks
were to be positioned on a low roof on the ocean side of a block of flats, food odours are likely in the
flats whenever the sea breeze blows in mid-morning to early afternoon—that is, during lunch time.

The left hand photograph shows three fast- Rather than three small stacks, each the
food shops in front of a multi-storey block of ‘regulation height’ above the shops’ roofline,
flats and over the road from the seafront at the local council has required all three to be
Bondi Beach. serviced by a single large stack that is behind
the flats and ‘the regulation height’ above the
roof line of the block, as shown in the
photograph on the right.

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2.6 Air quality modelling

Air quality modelling is the prediction of pollutant concentrations
in the area affected by a source or sources of air pollution. It takes
account of meteorology, topography and the built environment or
the area. It relies on:
• the physics and chemistry of dispersion and reaction of pollutants
in the atmosphere, and
• mathematical formulations of the physics and chemistry being
translated into computer programs for ease of carrying out the
multiple calculations required.
Pollutants have traditionally been assumed to disperse in a
Gaussian fashion in the atmosphere. This means that if a set of
concentration samples were taken simultaneously across the
direction of movement of a pollutant plume, then a plot of
concentration against cross-wind distance would look like the
characteristic ‘bell-shaped’ curve of a normal statistical
distribution, the Gaussian curve. The peak concentration would be
at the centre of the plume.
Gaussian mathematics is used to predict the concentration of a
pollutant at any point in space downwind of the pollution source.
A computer can then calculate the downwind pollutant
concentrations for a source across the full range of situations
corresponding to the weather variations at the location—that is,
wind speeds, wind directions and atmospheric stability. It is usual
to apply hourly data for a year—that is 8,760 meteorological
variations. When there is no local meteorological data, files of data
typical for the region are used.
The computer can also calculate concentrations for multiple
sources of pollution or area sources.

Isopleths
The resultant predicted concentrations are then added together by
the computer and analysed as frequencies of concentrations
experienced at various locations. The results are usually plotted as
concentration isopleths on a map around the source. An isopleth
is a line joining points of equal predicted concentration.
It is possible to produce concentration isopleths for time
periods corresponding to the averaging periods in different air
quality goals. For example, for sulfur dioxide, figures could be
drawn separately to show isopleths for any or all of the predicted
10-minute, 1-hour and annual average concentrations.

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Background air quality

In undertaking an assessment, consideration must also be given to the existing air quality of the region,
the so-called background concentrations due to the diverse range of activities operating, most of
which will not be included in the dispersion modelling. Often information on existing air quality will
not be available and it must be estimated from nearby, or similar, areas. In areas with high background
concentrations the addition of a new emission source may result in unacceptable predicted air quality
impacts, requiring the consideration of mitigating measures.

AusPlume
The Australian version of the Gaussian model is the AusPlume model. It has been developed and
maintained by the Victorian Environment Protection Authority over a period of more than three
decades. (See www.epa.vic.gov.au/Air/EPA/pub391.asp)
It is generally adopted in most Australian jurisdictions and has a good record of reliable prediction, if
applied with sound judgment and experience. However, there are many models derived from this basic
Gaussian dispersion assumption. The US EPA’s ISC model, also a Gaussian model, is widely used,
giving similar results to AusPlume.

Puff models
In some situations, due to complex terrain or the need to accurately predict short-term concentrations,
a more complicated type of model can be used. This assumes the dispersing pollutant behaves like a
set of discrete ‘puffs’ or expanding clouds of pollutant in the atmosphere, rather than a continuous
plume as in the Gaussian model.
These so-called ‘puff models’ require more complex meteorological inputs and are more difficult and
expensive to run. One commonly used in Australia is CALPUFF, a model approved by the US EPA
for assessments involving complex meteorological situations.

TAPM
CSIRO’s Air Pollution Model (TAPM) eliminates the need to have site-specific meteorological
observations. Instead, the model predicts the three dimensional flows important to local-scale air
pollution, such as sea breezes and terrain induced flows, against a background of synoptic-scale
meteorological analyses.
The model is also able to account for differences in vegetation and soil properties across the region.
The air pollution component of TAPM uses the predicted meteorology and turbulence from the
meteorological component, while the Plume Rise Module is used to account for plume momentum
and buoyancy effects for point sources.
TAPM is also able to model chemical processes, such as the formation of photochemical smog.
More information can be found at www.dar.csiro.au/tapm/.

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TAPM modelling uses a significantly different approach from the Gaussian plume models.
In Gaussian modelling the rate of dispersion of the plume is expressed as a mathematical function
of atmospheric stability and distance from the source. Thus it requires site-specific wind data as
well as a methodology for determining atmospheric stability.
TAPM on the other hand solves the fundamental equations of atmospheric motion and plume
dispersion. It calculates the wind-fields and the motion and dispersion of plumes directly.
Features such as sea breezes and thermal internal boundary layers, which require specific
methods for Gaussian models, are calculated naturally as part of TAPM.

Using modelling in the local government context

The experience and background of the modeller are critically important to achieving useful results.
Predictions made by even the most experienced modellers should be treated as broadly indicative of
the likely outcome.
The reliability of modelling results should not normally be pressed beyond about ± 20% for typical
applications likely to be encountered in local government situations. Computer models are only as
good as the information put into them and the soundness of the assumptions made when using
them.

Local government officers need to be able to make sensible judgements as to when modelling is
called for in the context of air quality issue and the comparative cost of mitigation measures.

Guidelines for both specifying and interpreting the reports from this type of specialist consulting
service are set out in the introduction to Module 3 of the Toolkit.

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3 Air pollutants

‘Air pollution’ can be said to be occurring when substances

The six ‘key air pollutants’ are also
that have a detrimental effect on the environment are present
called ‘criteria air pollutants’. They
in the air in greater than natural amounts.
are:
In 1998 Commonwealth, State and Territory governments
sulfur dioxide (SO2)
established national standards for six key air pollutants.
This section deals with these and other pollutants commonly carbon monoxide (CO)
encountered in urban and rural areas, including their nitrogen dioxide (NO2)
chemical and physical properties and recent trends in their
occurrence in NSW. Particular emphasis is given to the ozone (O3)
pollutants which are most commonly managed and regulated lead (Pb)
by local government
particles less than 10 μm.
For the purposes of management air pollutants can be
conveniently grouped into four broad categories:
• gases
• particles Ozone is one of several
‘photochemical oxidants’ that are
• odours
formed when a mixture of other
• toxics.
pollutants in the air are exposed to
These four categories are neither strictly ‘scientific’ nor are sunlight to form the smog that is
they based on the key air pollutants, but they help to explain familiar in urban areas like Sydney.
the occurrence and impacts of air impurities.

carbon
3.1 The normal atmosphere dioxide
0.03%
The atmosphere is made up mostly of gases with other
microscopic liquid and solid particles (aerosols) dispersed in
oxygen
them. In ‘normal’ air the most abundant of the gases is 21%
inert
nitrogen (N2) making up about 78% of the volume. It is gases
chemically unreactive at normal temperatures. The next 1%

most abundant gas is oxygen (O2) at about 21%. Oxygen is a nitrogen

basic necessity for most living organisms and is the gas that 78%

supports combustion. Water vapour makes up a small,

variable fraction of air (from 1%–3%). Evaporation and
condensation of water play a significant role in atmospheric Volumes of gases that
make up ‘normal’ air
dynamics. Carbon dioxide (CO2), a contributor to the
greenhouse effect, makes up only 0.03% of the volume. This
is less than the inert gas argon, which with other inert gases Water vapour is the gaseous phase of
makes up nearly 1%. Water vapour also plays a significant water. It should not be confused with
‘greenhouse’ role in the normal regulation of the earth’s mist or clouds which are made up of
temperature. small droplets of condensed liquid
water.
In addition, ‘normal’ air contains trace levels (that is, less than
0.002%) of gases that when present in larger concentrations are
regarded as impurities or pollutants. Examples are sulfur
dioxide (SO2), carbon monoxide (CO), nitrogen oxides (NOx),
ozone (O3), ammonia (NH3) and methane (CH4).

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3.2 Gaseous impurities

Sulfur dioxide (SO2)

Carbon monoxide (CO)

Nitrogen oxides (NOX)

Volatile organic compounds (VOCs)

Ozone (O3)

Sulfur dioxide
Sulfur dioxide (SO2) is a colourless gas with a sharp, nasty smell, but it is usually noticed as a salty
chemical taste in the mouth before being smelled. It is one of the six key air pollutants for which
national goals have been set.

Sources of SO2
Globally, human activities contribute over 100 million tonnes of SO2 each year, mainly from the
combustion of coal and fuel oil, with some contribution from the processing of mineral ores.
Significant amounts of SO2 are also emitted in volcanic eruptions. For example, it is estimated that the
1991 explosion of Mt Pinatubo in the Philippines blasted from 15 to 30 million tonnes of sulfur
dioxide into the air, as well as huge quantities of particulate matter.

Indicative Top Sour ces of SO2 emissions Top Sources of SO2 emissions in
over all of NSW in 2003 / 2004 Sydney in 2003 / 2004
Sydney, New castle, Wollongong Regional NSW

Thousand tonnes
0 100 200 300
Motor
Vehicles
Electr icity Supply
4200
tonnes Petroleum
Basic Non-Fer r ous Metal Refining
Manufactur ing
6400
tonnes
Ir on and Steel Manufactur ing

Petr oleum Refining

Motor Vehicles
Sulfur dioxide data from
the National Pollutant Inventory

In NSW by far the largest contribution is from coal-fired power stations located outside of Sydney.
In Sydney itself SO2 is also present in motor vehicle emissions but this is now a less important source
because national standards have already significantly reduced sulfur levels in fuels and will do so
more in the future.

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Impacts of SO2 on human health Acid deposition

The effect of SO2 on human health is to irritate the nose, throat and This refers to the deposition
airways so as to cause coughing and shortness of breath. It aggravates of aqueous acids, acid gases
asthma and chronic bronchitis and increases susceptibility to and acid salts from the
respiratory tract infections. The molecules can attach themselves to atmosphere.
particles and if these are then inhaled they can cause more serious
It has two components:
effects such as emphysema from long-term exposure.
‘wet deposition’ (or ‘acid
A concern with SO2 is people’s short-term exposures to high
precipitation’ or ‘acid rain’—
concentrations in the near vicinity of activities that emit significant
although all rainfall is slightly
amounts of the gas, which under some meteorological conditions may
acidic due to dissolved CO2)
be brought to ground level in high concentrations. Infrequently, high
concentrations may also occur due to abnormal conditions within a ‘dry deposition’ of gases
facility—through industrial accidents or breakdown of poorly and particles.
maintained equipment.
In parts of the world where
While SO2 is the principal sulfur compound that is introduced into the ecosystems are sensitive and
atmosphere through human activities, it is only one of several sulfur acid deposition is high, the
compounds that participate in a global sulfur cycle. Others are problems include:
hydrogen sulfide (H2S, ‘rotten egg’ gas), dimethyl sulfide (CH3)2S and – the death of fish and other
sulfur trioxide (SO3). These all participate in complex chemical aquatic fauna
reactions in the atmosphere.
– a reduction in forest and
These reactions can result in the oxidation of sulfur dioxide to sulfate crop productivity
ions in rainfall, a component of acid deposition. Another chain of – leaching of heavy metals
reactions results in the formation of sulfate salts as fine particles that from soils and sediments.
contribute to haze and may play a role in climate change.
Other problems may include:
– dissolution of metals in
water pipes
– the corrosion of exposed
metal
– dissolution of surfaces of
limestone buildings.

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Trends in ambient SO2 levels

Monitoring data for ambient levels of sulfur dioxide for the Sydney region, the Illawarra and lower
Hunter are shown below.

Annual maximum 1-hour sulfur dioxide concentration

0.30
Sydney NEPM
St andar d:
SO2 concentration (ppm)

0.25 Illawarra 0.20 ppm

lower Hunter
0.20

0.15

0.10

0.05

0.00
1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004
Monitor ing r ec ommenc ed in Sydney and lower Hunter in 1992

The National Pollutant Inventory

The National Pollutant Inventory (NPI) gives information on the types and amounts of pollutants
being emitted to the Australian environment.

There are three main ways that data are obtained for the NPI database:
– medium to large industrial facilities measure and/or estimate and report their emissions to the
government
– State and Territory governments estimate generically the emissions from smaller facilities
– State and Territory governments estimate emissions from mobile and non-industrial sources
(such as emissions from activities like driving to work and mowing the lawn), and other sources
of pollutants.
NPI data can be useful for an overall view of the types of sources responsible for pollutant
emissions in a particular area, and the differences between the large urban centres and regional
areas. However, caution is required in using NPI data for air quality assessments. In
assessing potential impacts, consideration must be given to the location and manner in which
pollutants are emitted as well as the actual quantity of pollutant emitted. Also, the quality of the
data recorded in the NPI is unavoidably variable.

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Carbon monoxide
The overall levels of carbon monoxide
Carbon monoxide (CO) is another of the key air pollutants for
are now below the NEPM standard,
which national goals have been set. It is a colourless and
with most of the emissions being from
odourless gas.
motor transport.
Sources of CO
CO is a product of the incomplete combustion of organic
material and its main natural sources are volcanoes and
bushfires. Sources associated with human activities are motor Top Sour ces of CO emissions in Sydney, New castle
vehicle emissions, some industrial activities such as steel and Wollongong in 2003 / 2004 (tonnes / year )

making, and stubble burning. Tobacco smoke is one of the main

sources of exposure indoors. The greater part of total CO Solid fuel
burning
emissions is from motor vehicle usage and this is predominantly (domestic)
31,000
Lawn Mowing
24,000
Basic Non-
in large urban centres. Ferrous Metal
Manufacturing
72,000
Impacts of CO
High levels of CO are poisonous to humans, affecting both Iron and Steel
Motor
Vehicles
Manufacturing
healthy and unhealthy people alike. It acts by combining with 530,000
800,000

haemoglobin, preventing normal uptake of oxygen and so

reducing the oxygen carrying capacity of blood. This means that
at high CO levels vital bodily organs may be deprived of oxygen
and therefore cannot function properly. Fortunately the effects Carbon monoxide data from
the National Pollutant Inventory
are reversible when the person is no longer exposed to the gas.
People with cardiovascular disease are particularly susceptible
to exposure to high carbon monoxide levels.

Trends in ambient CO
In most Australian cities and towns the levels of CO in air are
now below those that are hazardous to human health. The
NEPM goal of less than 9 ppm set for 2008 was achieved by
2000 through implementing catalytic vehicle emission
standards. The highest levels of CO are likely to be experienced
in the ‘canyons’ of city streets and nearby busy roads.

Annual maximum eight-hour carbon monoxide concentration

in a 'street canyon' in the Sydney CBD
30
CO c onc entr ation (ppm )

25
NEPM
20 standard
9 ppm
15

10

0
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004

Inc omplete sampling 1996-2000

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Nitrogen oxides
The two nitrogen oxides that are important air pollutants are nitric oxide (NO) and nitrogen dioxide
(NO2), collectively called NOx. NO is a colourless, odourless gas and NO2 is a brownish, highly
reactive gas with a nasty acrid smell when in very high concentrations. However, it is normally neither
smelled nor visible in the atmosphere.
NO is the primary form in which NOx is emitted, but it is usually converted relatively rapidly in the
atmosphere to the more reactive NO2 which is one of the six key pollutants included in the Air NEPM.
Nitrogen oxides are important pollutants because they contribute to the formation of photochemical
smog which can have significant impacts on human health. This is treated in more detail in the next
section.

NO x emissions in NSW: Sources of NOx

2003 to 2004 (tonnes/yr)
Some NO is formed naturally in the atmosphere
Iron and Steel Cement, Lime,
Manufacturing
by lightning and some is formed biologically.
Plaster and
8,000 Concrete Product
However these natural sources contribute only
Coal Mining Manufacturing about 1% of the NO2 found in urban air.
13,000 7,000
When both urban and regional areas in NSW are
added together, according to the NPI, coal-fired
power stations supplying the electricity grid
(46%) and motor vehicles (40%) contribute the
Motor
Vehicles* majority of NOx across the State.
120,000
Electricity However, there are significant differences
Supply
140,000 between the large cities and rural areas. Sydney,
Newcastle and Wollongong account for
virtually all of the State aggregate from motor
vehicle emissions. These emissions contribute
Top Sources of NO2 emissions in Sydney,
63% of NOx in these urban areas.
Newcastle and Wollongong in 2003 / 2004
(tonnes / year)
In rural areas motor vehicle emissions are
All other s insignificant and the main sources here are
Iron and Steel 12,299
Manufacturing electricity generation (80%) and coal mining
8,000
(11%).

Elec tr icity The major impacts of NOx are:

Supply
50,000 Motor – reaction with volatile organic compounds
Vehic les (VOCs) to form photochemical smog.
120,000
– direct impact on human health as NO2.

Nitrogen dioxide data from

the National Pollutant Inventory

The reaction of NOx with volatile organic compounds to form photochemical smog is considered in
the next section.

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Impacts of NOx
Acute exposure to NO2 is harmful to human health. Fatalities have been reported due to gases
containing NO2 being inhaled when celluloid is burning. Also, in the case of ‘silo fillers disease’, NO2
poisoning has occurred because fodder containing nitrate has fermented and produced NO2.

Trends in NO2 levels

Monitoring data for regional areas in NSW and other States shows that the maximum values are low
by comparison with the Air NEPM. The graph shows data for the Sydney, Hunter and Illawarra
regions.

Annual maximum one-hour nitrogen dioxide concentration

0.30
NO2 concentration (ppm)

Sydney *
0.25 Illawarra
NEPM
Hunter
0.20 Standar d
0.12 ppm
0.15

0.10

0.05

0.00
1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

* The Sydney data does not include data from Sydney CBD site (a peak site which
d it i NO2 i 2000 & d t t th NEPM it i f NO2)

Volatile organic compounds

Volatile organic compounds (VOCs) enter the atmosphere from many diffuse sources including petrol
vapour from unburned fuel from motor vehicles, service station pumps, spills from lawn mowers and
evaporation of solvents in industrial activities. Their significance in the generation of photochemical
smog and ground level ozone is described in section 3.4 below.

3.3 Particulate matter

Particulate matter is the term used to describe the particles that remain suspended in the air for periods
longer than about a minute because of their small size. The particles may be solid or liquid and as haze
over a region or city are one of the most obvious forms of air pollution.

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Size and shape of airborne particles

Particles emitted from air pollution sources and formed by natural
processes have many different sizes and shapes, and a range of
densities, from that of water (1 g/cm3) to more than that of rocks
(about 3 g/cm3). Unlike the other criteria pollutants which can be
unambiguously defined in terms of their chemical composition,
‘particles’ can be composed of a diversity of elements and
compounds which may be of natural or anthropogenic origin.
In managing air quality involving particulates it is necessary to
use a definition of particle size that relates directly to how the
particles behave in moving and still air, and so how they penetrate
into the lungs. The idea of ‘aerodynamic diameter’ has been
developed to provide such a definition. It takes account of the
particle’s physical size, its density and its shape.
Particles of different shapes and densities can have the same
Adapted from the website of the US EPA
aerodynamic diameter and so be grouped in the same size
category. In the same way, particles that look very similar in size
under a microscope may be in different size categories.

Atmospheric particulates are Whenever a particle ‘size’ is specified in air quality

microscopic, so a very small unit of management it refers to the aerodynamic diameter of the
length is needed to indicate their size. particle.
In the metric system the unit that is The ‘aerodynamic diameter’ of a particle of any size, shape
the right size is the ‘micrometre’ which and density is the diameter of a spherical particle with a
is one millionth of a metre and has the density of one g/cm3 which behaves the same way in air.
symbol ‘µm’

It used to be called the ‘micron’ and

this name still appears in many
documents.

1 µm = 1 micron = 10 – 6 m

Particle size terminology

The terminology used to describe and categorise particles of concern for air quality management is
somewhat complex. The US EPA uses two classification schemes that break up the wide range of
particle sizes into smaller categories that relate to their potential impact on human health.
A descriptive categorisation is given in the table below:

US EPA description Particle size

Supercoarse 10 μm–100 μm
Coarse 2.5 μm–10 μm
Fine 0.1 μm–2.5 μm
Ultrafine less than 0.1 μm

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In addition to this descriptive categorisation there is a regulatory categorisation based on how

particulate matter is regulated and tested for under the NEPM. These categories also relate to how far
they typically penetrate the human respiratory system and so have potential health impacts.

Category Description

All particles from 0.1 µm up to about 100 µm or more in diameter—in

TSP (total suspended
practice the major contribution to TSP is from particles significantly less
particulate matter)
than 100 µm.

PM10 (particulate matter All particles with an aerodynamic diameter less than or equal to 10 µm
less than 10 µm) (sometimes called ‘inhalable’ particles).
PM2.5 (particulate matter All particles with an aerodynamic diameter less than or equal to 2.5 µm
less than 2.5 µm) (sometimes called ‘respirable’ particles).
These can be clusters of as few as 20 to 50 individual molecules but
Particles less than 0.1 µm
tend to agglomerate rapidly to larger particles.
Condensable Formed by chemical reactions and physical condensation within a few
particulate matter seconds of emission from a stack.

Distribution of particles in the atmosphere

The graph below shows an idealised size distribution of ambient atmospheric particulate matter that
relates the two classification schemes (adapted from the US EPA Basic Concepts in Environmental
Sciences). In practice the size distributions can overlap to a greater extent, depending on the type of
sources.

TSP
PM1

PM2.5

Ultrafine Fine Coarse Supercoarse

particles by mass
Percentage of

0.002 0.01 0.1 1.0 10 100 1000

Particle diameter (μm)

The larger PM10 particles stay in the air for minutes or hours and travel as little as 100 metres or
as much as 50 kilometres.
The smaller PM2.5 particles persist in the air for days or weeks and can travel for hundreds of
kilometres.

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Sources of particulate matter

Some typical sources of PM10 and PM2.5 are summarised in the table below:

PM10 PM2.5

Smoke Secondary formation from gaseous

pollutants, e.g. photochemical smog
Dirt and dust
Motor vehicle emissions (diesel)
Factories, farming, roads
Inefficient burning
Construction sites
Smelting and purifying metals
Mould, spores and pollens
Crushing and grinding rocks and metals

Processes and particle size

The range of particle sizes that are formed in any process
largely depends on the sort of particle formation mechanisms
that are present in the process. The significant mechanisms in
air pollution sources are:
• physical abrasion (attrition) and mechanical dispersion
• combustion particle burnout
• nucleation (homogeneous and heterogeneous) and chemical
reaction
• droplet evaporation.

Grinding wheel showing The general size range of emission particles is

exhaust ducting (US EPA) characterised by the particle formation mechanisms in the
process being evaluated and managed.

Physical abrasion or attrition occurs when two hard surfaces

rub together. Examples that may be encountered in premises or
activities within a local government authority’s responsibility
are dust from vehicular abrasion and construction sites, metal
grinding and tertiary stone crushing.
The dust particles formed in these sorts of operations range
from less than 10 μm to almost 1000 μm with little in the PM10
category. Thus physical attrition generates predominantly
moderate to large-sized particles that have short retention times
in the air and typically only travel several hundred metres in
moderate wind conditions. Their impacts are mostly restricted
to the immediate vicinity of the premises or activity.

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Pulverizing or atomizing of fossil fuels are both done to

For any given amount of
increase the surface area of fuel that is exposed to the
pulverized or atomized fuel, a
oxygen in air to enhance combustion at high temperatures.
decrease in particle diameter by
In most cases these processes take place in premises
a factor of ten results in a 1000-
regulated under DECC licences.
fold increase in the number of
Combustion particle burnout is the term used to describe particles, and a ten-fold
the process whereby a fuel is burned leaving only the increase in the total surface
incombustible ash and char particles. These particles are area of all of the particles.
typically in the 1 to 100 μm size range and will be emitted in
the exhaust of wood-fuelled domestic heaters as well as
furnaces or boilers that use fossil fuels such as oil or coal,
and from motor vehicles. If the combustion is incomplete
then other particulate matter will also be emitted, a problem
associated with woodsmoke from domestic heaters.
Nucleation is the conversion of materials in the vapour
Each vapour phase material
phase to particulate form as the vapour-containing gas
has a different temperature at
streams cool to temperatures low enough for each to become
which it becomes liquid or solid.
liquid or solid. This may occur due to condensation alone or
Thus some materials nucleate
may be as a result of chemical reactions between pollutants
in relatively hot gas zones while
in the atmosphere.
some remain as vapour until the
Homogeneous nucleation is the formation of new gas stream is cold.
particles composed almost entirely of one compound
from the vapour-phase material.
Heterogeneous nucleation is the accumulation of vapour-
phase material on the surfaces of existing particles so that The two main types of vapour
the resulting particulate matter is made up of more than phase materials that can
one compound. nucleate in air pollution source
gas streams are organic
compounds and inorganic
metals or metal compounds.

Wood-fired domestic heaters provide an example of the

importance of both combustion burnout and nucleation for
the management of air pollution.
When operating properly, the wood both burns directly to
form incombustible ash and volatilises to organic vapours
that are substantially oxidised completely to carbon dioxide
and water. However, if the combustion process is
incomplete, a portion of these organic vapours and their
partial combustion products remain in the gas stream, as
well as the particles from the unburned matter entrained in
the stream.

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Droplet evaporation may occur if water containing solids is used to cool gas streams. The cooling
water is ‘atomised’ and as the small droplets evaporate, the suspended and dissolved solids are
released as small particles, typically with sizes between 0.1 and 20 μm.
The diagram below (adapted from the US EPA) summarises the ranges of particle sizes arising from
the four different processes.

Particle attrition
(10 – 1000 μm)

Combustion burnout
(1.0 – 10 μm)

Droplet evaporation
(0.1 – 20 μm)

Nucleation
(0.1 – 1.0 μm)

0.01 0.1 1.0 10 100 1000

Particle size (μm)

A simple summary of particles and sources

Particle size Activities

Coarse particles Crushing
Grinding
Quarrying
Fine particles Combustion
Smelting
Process industries
Traffic

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The impacts of particulate matter

Health effects
The human respiratory system in a healthy person normally is able to deal with most inhaled particles
without long-term effects or undue stress. However, in cases of extreme exposure and more generally
for sensitive individuals, the presence of airborne particles is associated with increased rates of
respiratory illnesses and symptoms.
When particulate matter is breathed in it then travels into the respiratory system. Generally the smaller
the particles the further they penetrate into the lungs and the worse their effect.
If the smaller PM2.5 particles contain more toxic substances like trace metals and carcinogenic
organic compounds, then these may be carried deeper into the lungs than the normal bronchio-
pulmonary defences would allow—with adverse effects.
Epidemiological studies have shown that exposure to particulate matter leads to increased use of
medication, more visits to doctors or hospital outpatient services and more deaths of medically-at-risk
individuals.
The known health effects of exposure to particulate matter include:
• coughing, wheezing and shortness of breath
• aggravated asthma
• damage to the lungs that results in decreased function
• lifelong respiratory disease such as chronic bronchitis and emphysema
• premature death in people with existing heart or lung conditions.

Asthma: this is caused by the periodic constriction of the bronchi and bronchioles making
breathing more difficult. It is triggered by airborne irritants and chemicals.
Chronic bronchitis: any small particle reaching the bronchi and bronchioles in the lungs
stimulates increased secretion of mucus to try and remove the irritation. In chronic bronchitis these
air passages become clogged with mucus leading to a persistent cough.
Emphysema: when very small PM2.5 particles penetrate deep into the lungs they are trapped and
cause the delicate walls of the alveoli to break down. This progressively reduces the gas exchange
area of the lungs which in turn forces the heart to pump ever larger volumes of blood to the lungs
in order to satisfy the body's needs. The added strain can lead to heart failure. Emphysema is now
mainly a result of cigarette smoke.

Other effects
Particulate matter in the air can cause a range of damage to surfaces and materials, as well as being a
significant nuisance problem. The simple requirement for more frequent cleaning and the associated
abrasion of surfaces by dust particles can speed up deterioration. Over the years many car yards
adjacent to dust-generating premises have been badly impacted leading to costly reparation.
Additionally, if the particles are themselves corrosive or have other pollutants, such as SO2/sulphate,
attached to them, they may corrode sensitive surfaces (paint work, duco, etc.) to which they adhere,
especially if there is overnight condensation on the particles lying on the sensitive surfaces.

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In coastal areas wind-blown suspended sea salt particles are corrosive. They usually require particular
attention to exposed metal surfaces such as external plumbing in roof gutters and other structures.

Local government can help manage particles by:

– making sure premises within their control are operating and maintaining their air pollution
control devices satisfactorily
– managing woodsmoke from domestic heaters
– strategic planning for the location of new industrial and commercial facilities within their area—
in relation to local roads, residential areas and schools

– consent conditions on emissions for new premises and activities

– consent conditions on developments to influence motor vehicle use associated with new
developments.

Trends in ambient concentrations of PM10

Twenty-four hour PM10 in the Sydney region

Maximum 6th highest NEPM Standard

300

250
PM10 c onc entr ation ( μ g/m3 )

200

150
NEPM
St andar d
100 50μg/m 3

50

0
1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004

Events where concentrations of PM10 exceed the NEPM standard can occur in the Sydney region as
can be seen in the figure below.
Concentrations of PM10 near to or exceeding the NEPM standard are widespread in the Sydney region.
The more moderate of these generally occur during the cooler months of the year with the highest
concentrations observed during the early evening and early morning. They tend to be associated with
stable atmospheric conditions that are conducive to clear cold nights and the development of
inversions and drainage flows which can result in the trapping of pollutants close to the surface and
their transport within the Sydney region.

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Extreme episodes of particle pollution are generally associated with large-scale hazard reduction
burning or wildfires. These sorts of events account for most of the exceedences of the PM10 standard
in the Sydney region.
The distribution of elevated concentrations of PM10 during these events is governed by the location of
the fire and the prevailing winds on that day. The combination of these two factors has meant that on
different occasions, all of the monitoring stations in the Sydney region have recorded elevated
concentrations of PM10.
Severe dust storms can also contribute to particulate pollution.

Trends in ambient concentrations of PM2.5

With the growing understanding of the health impacts of the smaller respirable particles in the PM2.5
category there is an increasing emphasis on managing their emissions. The figure below shows recent
trends in PM2.5 concentrations in Sydney.
Bushfires, hazard reduction burning and dust storms in recent years are also believed to have
contributed to the observed very high levels of PM2.5.

Twenty-four hour PM2.5 in the Sydney region

Maximum 6th highest NEPM Advisor y Repor ting Standar d

120
PM2.5 c onc entr ation ( μ g/m3 )

100

80
NEPM
Advisor y
60 Repor ting
Standar d
25 μg/m
3

40

20

0
1996 1997 1998 1999 2000 2001 2002 2003 2004

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3.4 Ozone and photochemical oxidants

Ozone
Ozone is important at two levels in the atmosphere: in the
troposphere (the air layer next to the earth’s surface) and in the
stratosphere (a higher air layer, above the troposphere).
In the troposphere high concentrations of ozone are
detrimental to health, vegetation and materials. It is the main
constituent of photochemical air pollution and is a very
reactive gas causing deterioration of all types of organic
materials it contacts. Gaseous ozone is the measured indicator
of photochemical air pollution and is used to set the ambient
standard for this type of pollution in the Air NEPM goal.
In the stratosphere high concentrations of ozone are
beneficial for health, biota and materials. It shields the earth’s
surface from damagingly high levels of ultraviolet radiation
from the sun. Ozone is also a greenhouse gas.
Upper-level (stratospheric) ozone is destroyed by the release of ozone-depleting substances such as
chlorofluorocarbon refrigerants. The release of these materials is internationally controlled under the
Montreal Protocol and locally controlled in NSW under the Ozone Protection Act 1989.
Ozone is an ephemeral gas at both the tropospheric and stratospheric levels, being continually formed
and destroyed by dynamic, photocatalysed reactions. The concentration at any time depends on the
competing rates of destruction and formation. It is more difficult to measure accurately than most
other gaseous pollutants, since standard calibration gases cannot be stored.

Impacts of tropospheric (low-level) ozone

Ozone is a very strong oxidising agent. It causes damage to sensitive tissues of the body, such as in the
lungs and their airways and the eyes. It is used as a surrogate for other products of the oxidant
reactions, including polyacetyl nitrates (PAN) and fine particles.
The health effects appear as shortness of breath and chest pains, especially in people exercising or
working hard in the open, increased incidence of asthma and eye irritation. Fine particles and aerosols
are also created during the formation of photochemical smog and have an impact as particles on health
and visibility.
It is difficult in health studies to isolate the effects of ozone gas from the other constituents of the
smog. PAN, for example, is probably the main promoter of eye irritation. While the effects of ozone
exposure tend to be short-term, laboratory studies of animals have also shown effects on lung tissue
for longer-term and repeated exposures.
The strong oxidising capability of ozone also causes damage to vegetation. Some commercial and
ornamental plant species are particularly sensitive to ozone damage. Likewise many modern products
exposed to the atmosphere such as rubbers and polymers suffer deterioration when exposed to the
oxidants of this smog.

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The Air NEPM set the goal for ozone exposure at 0.1 ppm for Consideration is being given
a 1-hour exposure and 0.08 ppm for a 4-hour exposure, to the introduction of an 8-
neither to be exceeded more than once per year. hour standard for ozone.

Photochemical air pollution

Photochemical oxidants are products of the reaction of volatile organic compounds (VOCs) and
nitrogen oxides (NOx) in the atmosphere. The reaction is promoted by exposure of the mixture to
strong sunlight. It is a seasonal phenomenon, since concentrations of ozone and oxidants only reach
levels of concern in summer, when the sun’s radiation is strongest.
Photochemical oxidant pollution was first studied as an urban problem in Los Angeles, where it
became famous as photochemical ‘smog’. The term tends to be identified primarily with car and
vehicle pollution, but there is a significant contribution from industry and other urban activities, both
commercial and individual.

Oxides of nitrogen
Oxides of nitrogen are released from motor vehicles
and industry. The largest proportion comes from motor
vehicles.
As discussed earlier in section 3.2 ‘Gaseous
impurities’, the two forms occurring in the atmosphere
are nitric oxide (NO) and nitrogen dioxide (NO2). Fresh
emissions are mostly in the form of nitric oxide. This is
oxidised to nitrogen dioxide in the atmosphere as part
of the photochemical process. The photochemical
reactions between the two oxides of nitrogen occurs
naturally in sunlight, but does not result in levels of
ozone being formed above concentrations of concern
if no significant concentrations of VOCs are
present.

Emission of VOCs in urban areas

In urban and industrial atmospheres VOCs are emitted
in large quantities from many sources, including motor
vehicles, and consequently high concentrations of
ozone can be generated in these situations. But the
reactions usually take 3–4 hours for the concentrations
of oxidants (as indicated by ozone) to build up to
troublesome concentrations. So smog is only formed on
days with appropriate meteorological conditions, such
as morning trapping of NOx and VOC pollutants,
relatively light air movements and strong sunlight.

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Smog in the Sydney basin

The outstanding example in NSW is the accumulation of VOCs and NOx from the morning traffic
peaks in Sydney, especially in the western areas of the basin where the overnight inversion drainage
flow traps and transports the reactant pollutants to the east over the city. When the mid-morning sea
breeze pushes this brew of pollution back over the urban land, peak oxidant concentrations tend to be
formed in the south-western regions of the basin from early to late afternoon.

Monitoring ozone
Care is needed in monitoring ozone. If the monitors are located too close
to concentrated sources of nitrogen oxide emissions, such as heavy
traffic lanes or near large industrial combustion sources or in CBDs, then
NO + O3 → NO2 + O2
low values are likely to be measured. This is because the dominant form
of nitrogen oxides from combustion is nitric oxide (NO), as discussed
above. This reacts very rapidly with ozone already formed to convert it
to oxygen. In the longer time needed for full development of oxidants
this effect passes and a realistic concentration of ozone will be measured
relating to the emissions.
This was the main cause of an unfortunate prediction about
photochemical air pollution made in the late 1960s, namely, that even
without any control of vehicle air pollution in Sydney, Los-Angeles-type
smog was not likely to be a problem until 1997. When measurements
were taken well away from the Sydney CBD in the early 1970s, high
ozone values quickly made it apparent that there was an urgent need for
control.

Control of photochemical oxidants

There are possibilities for controlling the VOC and NOx precursors to greater or lesser extents to
achieve desired ozone outcomes. Throughout Australia and in NSW an approach of controlling both
NOx and VOCs has been adopted:
• Motor vehicle emissions are regulated nationally for both NOx and VOCs, the latter from both
tail pipes and evaporative emissions. Modern catalyst-equipped vehicles using lead-free petrol are
the cornerstone of this control. This regulation is on a vehicular basis; that is, the amount of
pollutant for a kilometre travelled is limited, not the distance the vehicle travels in a day.
• Evaporative emissions of VOCs from distribution of petroleum products and some solvents is
controlled in large storage facilities.
• Combustion emissions of NOx from large industrial facilities and power plants are controlled by
POEOCAR.

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Traffic management
To the extent that local government has an influence on traffic congestion and generation, it can have a
significant impact on the potential for ozone and oxidant pollution within the air basin in which it is
located. But the pollution effect may not be a local one for the particular local government area in
which the control is undertaken.

Traffic generation and congestion can be influenced by planning for walking and cycling facilities;
and by planning to reduce local trips—e.g. for shopping or schools. These can all contribute to the
reduction of vehicle kilometres travelled (VKT) in the air basin.
Emissions of the ingredients of photochemical smog in one local government area have regional
impacts and will impact on the air quality in other local government areas.

Small to medium-sized sources

There are thousands of small to medium-sized sources which are not specifically controlled for NOx
and VOCs as such, although such activities may be controlled to achieve clean combustion and to
minimise organic emissions so as to reduce impacts of odours or air toxics.
Under the POEO Act local councils are the ARA for most of the small to medium-sized sources which
remain to be controlled. Specific action to tighten controls on ozone precursors from these sources
may be required in future.

Present levels of ozone pollution

While significant improvements have been achieved in the Sydney, Illawarra and Lower Hunter air
basins following early vehicular and industrial controls, and the introduction of catalyst equipped
vehicles and lead-free petrol in 1986, the AAQ NEPM standard is still exceeded in Sydney and the
Illawarra more often than allowed under the goal.

Annual maximum one-hour ozone concentration

0.25
Sydney
Illawarra
Ozone c onc entr ation (ppm)

0.20 lower Hunter

0.15

0.10

NEPM
st andar d:
0.05
0.10 ppm

0.00
1980
1981
1982
1983
1984
1985
1986
1987
1988
1989
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
2000
2001
2002
2003
2004

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3.5 Odours
The community complains about odours more frequently than any other type of air pollution. The
majority of the air quality problems associated with local-government-controlled industries and
businesses relate to odours. There is great subjectivity associated with odour assessment. These facts
make odours a significant problem for local government.

The sense of smell

Certain volatile substances and mixtures stimulate the olfactory nerve in the nose so as to produce a
sensation of odour or smell.

The olfactory
epithelium (Yale
University Medical
School website)

Odours are transported from source to nose by air movement, the wind. Many odours are not toxic at
readily detectable concentrations. Each citizen is equipped with a sensitive detector. So the primary
issue is amenity.

Easily recognisable odours

Some substances have distinctive odours as the pure compounds, such as hydrogen sulfide (H2S, or
‘rotten egg’ gas), acetone (or nail polish remover) and hypochlorous acid (from swimming pool
chemicals). These are quite familiar to many people even if they do not know their chemical names.

Most odours, both pleasant and unpleasant, result from mixtures of many compounds.

That odours come from mixtures of many compounds is especially true of the food and waste
treatment industries where biological processes characteristically generate families of odorous
compounds rather than one or two such compounds. Most rotting material contains hydrogen sulfide,
although it is not recognisable as such in the mixture. Surprisingly, hydrogen sulfide is also found in
small quantities in pleasant odours, such as coffee.

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Human sensitivity to odour

To complicate matters further, human sensitivity to odour perception varies widely. So odours are
difficult to measure reliably.
Where only one compound is present the chemical concentration can be determined and related to
odour strength as defined below. When multiple compounds are present, the more common situation,
one cannot simply add up the odour strengths of the individual components to arrive at the strength of
the mixture.

Odours:
– are pure compounds or mixtures of compounds which stimulate the olfactory nerve causing a
sensation of smell

– are not easily defined as chemical compounds

– are transported by air from source to nose
– are detected with differing sensitivities

– impact on amenity, and

– are often not toxic at the strength they are detectable (even if a ‘nasty smell’).

Measurement of odour
Odour strength is usually measured by quantitatively diluting a sample
of odorous air with non-odorous air and presenting it according to set
protocols to a panel of representative subjects, or ‘sniffers’.
The mean or average dilution value at which the panel just detects
the presence of the odour is called the threshold value.
Panel response may be either to the detection threshold or the
recognition threshold.
Measured odour concentrations can vary by an order of magnitude
depending on how the test is conducted. Some of the variations in the
results from odour testing include:
• Forced choice versus yes/no response—the panellist is asked to
choose the strongest of multiple odour dilutions presented to them
versus the panellist’s ability to smell anything in the dilution
presented.
• Dynamic versus static exposure—the panellist is exposed to a
continuous flow of odour dilutions versus being exposed to discrete
parcels of odour dilutions.
• Recognition versus detection threshold—the panellist can detect
a recognisable smell versus any smell sensation.

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There can also be variations in the method of panel selection. Most panels are selected to be
representative of the ‘typical community’ and to be reliable in their response to varying odour
dilutions. They should not be dominated by panellists on the extremes of the range of sensitivity or
insensitivity.

The number of odour units in a sample is the number of dilutions required for the sample to reach
the chosen threshold of detection.

There are Australasian (AS/NZS 4323.3:2001) and European (CEN:/TC264/WG2/N222/e(OM-7))

standards for odour measurement by dynamic olfactometry, both of which are recommended by
DECC for odour assessment.
Sampling for odour measurement is a difficult and specialised process because of the tiny quantities of
odour material involved—the ‘odour’ can end up being stuck to the sampler walls.

Factors in odour assessment

The key factors which have been identified as determining community
responses to an odour are:
• Frequency of exposure
• Intensity of exposure
• Duration of exposure
• Objectionableness of the odour (the so-called ‘hedonic tone’)
• Circumstances in which the exposure occurs (work, relaxing at
home, attempting to sleep).
F I D O C is the acronym.

No reliable means of scientifically measuring O or defining C has been developed. Thus many odour
assessment techniques involve a compromise of specifying FID, which can be assessed scientifically,
and either not assessing OC or assuming it is loosely related to FID. This tends to be a ‘safe’
approach, in that it assumes no odour is preferable to any odour, even a normally pleasant one, in most
circumstances.
Despite these shortcomings, considerable progress has been made in odour assessment and control.
The DEC draft policy, Assessment and management of odour from stationary sources in NSW (2001),
provides extensive guidance for odour assessment and control.

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Assessment of odour
In essence the assessment technique relies on three
things:
• measurement (sampling and testing) of odour
strength by dynamic olfactometry
• prediction of ambient concentrations at sensitive
receptors using dispersion formulae or air quality
models
• assessment of the predicted strength against
odour exposure criteria.

Size of the population exposed

To allow for the likelihood of more sensitive
individuals being present in larger populations, the
DEC draft criteria take account of the size of the
population exposed. They are based on a 0.1 to 1
second averaging time, the typical response time of
the olfactory nerve to a stimulus. They also assume
that the ambient odour exposure criteria are met for
99% of the time.

Recommended odour levels

The recommended odour concentrations range from
two odour units per cubic metre (2 ou/m3) for urban
areas with a population of more than 2,000 people
exposed, to 7 ou/m3 for a single dwelling.

Three-tiered exposure assessment

The DEC draft method allows for a three-tiered
exposure assessment (illustrated here on the left)
using simple dispersion calculations at the initial
assessment level, and increasingly sophisticated
emission inputs and dispersion modelling techniques
at the higher levels.

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Council officers should also be aware that measuring emission rates from diffuse sources such
as smelly solid or liquid surfaces is problematic.
This is a serious qualification to general application of the methodology, since diffuse sources are
fairly common in many industries with an odour problem.

Even at the initial assessment level this technique is difficult and demanding to apply, and it is
unlikely that council officers would attempt it directly.

Responding to odour from existing premises

In response to a complaint of odour from existing premises, council officers may specify in a
Prevention or Clean Up Notice that an assessment be undertaken according to the methodology. In so
doing they should be aware of the following:
• the likely expense—a study involving both odour testing and dispersion modelling could cost more
than $20,000 per assessment
• the qualifications on the accuracy of the sampling and analysis
• the difficulty of accounting for diffuse sources
• the limitations on modelling in the sort of topography and building interference often encountered
in urban situations.

Another way of assessing some odours

A lower cost option is available under the DEC Odour Policy and Approved Methods for Modelling
and Assessment of Air Pollutants in NSW for certain odorous chemicals. For over 20 years Victoria
has used a set of design criteria for the ground-level concentrations (glc) of a number of chemical
compounds. These criteria were formulated on the basis of providing protection against exposure to
toxicity and avoidance of odour. They have been adopted as the NSW methods and provide a means of
modelling without the need for odour testing for those compounds listed. However, this method can
only be used for odorous materials which are not mixtures. This is not the situation typically
encountered in local government.

A practical approach to odour management for local council officers

A practical approach is recommended as the first step for local council officers, especially for small-
sized installations. Careful use of documented odour observations by officers and others, coupled with
an analysis of the suspect process and complaint patterns, can sometimes lead to practical solutions at
a cost comparable to the cost of a scientific assessment. This approach is explained further in
Module 3.
Ambient monitoring of odours is not practicable since assessment panels have difficulty in assessing
low concentrations of odour. In addition, the sampling itself is problematical. It is possible that
odorous compounds can be lost entirely from the sampled air through adsorption onto the container
walls before the sample reaches the panel.

Much progress has been made on odour assessment over the last 50 years. However, there is still
not the same degree of consensus on managing this frustrating aspect of air quality as that which
exists for most other forms of air pollution.

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3.6 Toxic air pollutants

Of the air pollutants currently prescribed under the Ambient Air Quality NEPM, only lead and carbon
monoxide are considered to be ‘toxic’. However, there is long-standing concern about toxic pollutants
in the atmosphere.

Two general types of impact are addressed under the category of ‘air toxics’:
– directly toxic air pollutants

– carcinogenic air pollutants.

The Commonwealth Government has published several documents under its Air Toxics Program
including the State of knowledge report on air toxics and indoor air quality. NEPC released an
Information bulletin and an Impact statement for the National Environment Protection (Air Toxics)
Measure (2003).

Air Toxics NEPM

The EPHC issued an Air Toxics NEPM in 2004 addressing five
individual or sets of air toxic compounds:
• benzene
• formaldehyde
Benzo(a)pyrene
• benzo(a)pyrene as a marker for polycyclic aromatic
hydrocarbons (PAHs)
• toluene
• xylenes (as a total of ortho, meta and para isomers)

While the NEPM sets monitoring investigation levels for these toxic compounds, it has not set
goals. In anticipation of setting goals it has prescribed a monitoring regime with a view to setting
goals by 2012.

The Environment Protection and Heritage Council (EPHC) has also identified other air toxics which
it has prioritized for further investigation at a later stage:
• 1,3 butadiene • nickel and compounds
• acetaldehyde • styrene
• arsenic and compounds • tetrachloroethylene
• cadmium and compounds • trichloroethylene
• methyl ethyl ketone • polychlorinated biphenyls (PCBs)
• methyl isobutyl ketone • polychlorinated dioxins and furans.

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Dioxins and furans Dioxins and furans are families of

Dioxins and furans have been an issue of public cyclic organic chemicals. The toxic
concern in Australia for some time. Dioxins and furans ones contain chlorine and in popular
are an extensive family of cyclic organic chemicals usage the term ‘dioxins and furans’ is
containing varying amounts of chlorine. There are applied in the environmental context
hundreds of different members of the family, to the many chlorine-containing
depending on chemical structure. compounds in these families.

Dioxins have been shown to be extremely toxic to

Cl Cl
humans, but they are only found in the environment in
very small (trace) quantities. The concentrations
usually found are a million or more times less than Cl Cl
other common air pollutants in the atmosphere. The
toxicity of the many isomers varies widely and so test
TCDD—the
results are converted to a toxic equivalent (TEQ) most toxic dioxin
value, based on accepted ratios of toxicity of the
family members to the most toxic member: 2,3,7,8
tetrachloro dibenzo-p-dioxin (usually called simply Cl Cl
‘TCDD’). The corresponding furan is ‘TCDF’ or
2,3,7,8 tetrachloro-dibenzo-furan. Cl
Cl
Research on sources of dioxins and furans
Research in the last 20 years has revealed that TCDF—the
most toxic furan
polychlorinated dioxins and furans can be formed in
many combustion processes where organic materials
and chlorine containing materials are present. Given
Biomass bur ning
the ubiquitous distribution of these materials in nature,
Wood heater s
it is not surprising that trace quantities of dioxin can
Metallur gy
be found in many situations involving traditional
Waste bur ning
forms of burning. The first cave dwellers were almost
Power Plant s
certainly exposed to dioxins.
Environment Australia funded and published a series
of 12 reports as part of the National Dioxins Program
between 2001 and 2004. These addressed many issues
related to dioxins and furans in Australia, including a
useful inventory of emissions from all sources.
Burning of biomass such as in bushfires, metallurgical
processing (ferrous and non-ferrous) and burning of
wastes and accidental fires emerge as the three largest
categories of dioxin emissions in Australia. For local
government domestic wood burning for heating and Sources of dioxin
cooking, and operations such as cremation, are dioxin emissions in Australia
sources warranting close attention.

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Addressing dioxins in Australia

The EPHC has recently issued a draft National Action Plan for Addressing Dioxins in Australia (July
2005). This Plan is intended to address Australia’s obligations under the Stockholm Convention 2004
for management of persistent organic pollutants (POPs).
On the basis that dioxin levels in Australia appear to be low, emphasis is placed on the following
management strategies:
• enshrining the widely used emission standard of 0.1 ng TEQ/m3 as a national combustion emission
limit.
• reducing emissions from burning of wood fuels
• better understanding emissions from bushfires (the major source in Australia)
• adopting the Stockholm Convention best practice guidelines for assessing proposals for new and
upgraded facilities in Australia.

ng is the nanogram; that is, 10 – 9 gram or just one thousandth of a microgram.

Local government and toxic air pollutants

Local councils will not often be required to make decisions about or to regulate emissions of toxic air
pollutants other than those already covered by the existing AAQ NEPM, or those in relation to
minimising odours or smoke emissions (e.g. from spray painting, coating or domestic wood burning).
On the few occasions that this is required, the design criteria specified in Approved methods for
modelling and assessment in NSW (2005) can be adopted for any assessment.

It would be wise for local councils to consider obtaining expert advice if they need to consider an
emission involving toxic pollutants.

Ambient design criteria for some air toxics

A Victorian list of ambient design criteria for air toxics has existed since 1980. The latest revision of
this list has been adopted in NSW. It covers 90 chemicals and related substances, both inorganic and
organic. [See Approved methods for modelling and assessment of air pollutants in New South Wales
(2005).]
These are relevant to the assessment of all sources of air pollution in NSW, including non-scheduled
premises.

Emission limits for some toxic chemicals

Emission limits have also been set for 39 toxic chemicals in the POEOCAR. However, there are no
emission limits for toxic pollutants applicable to non-scheduled premises in NSW.

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Further information on air toxics

Detailed information on air toxics can be found in the following sources:
• Impact assessment criteria for principal toxic air pollutants (Victoria, 2001)
• Approved methods for the modelling and assessment of air pollutants in NSW (2005)
Table 7.2 (lists design criteria for 90 toxic materials)
• NEPM (Air Toxics) Impact Statement (2003)
• National Environment Protection (Air Toxics) Measure (2004):
benzene, benzo(a)pyrene, formaldehyde, toluene, xylenes
• National Dioxins Program:
12 reports (2001–2004)
• National Action Plan for Addressing Dioxins in Australia (2005) pursuant to the Stockholm
Convention on Persistent Organic Pollutants.

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4 Management of air quality

4.1 General management of air quality

Management framework
The ideal air quality management objective is to avoid all air pollution and maintain pristine air
quality. Such a goal is not feasible in the presence of human activities relying on energy from fuels
and involving biological and manufacturing processes.
Our practical objective becomes to manage air quality to the best level
possible and to ensure that pollutants are kept at or below acceptable Management

levels. In pursuit of this overall objective we use various tools or

Legal
instruments:
General management tools ensure that we pursue our objectives
Scientific
systematically and efficiently. Technical
Legal instruments are the primary compliance tools governments use to
achieve air quality outcomes. These instruments are reviewed in detail in
Module 2. Our secondary objective, within the overall management
framework, is to use our legal instruments effectively.
Scientific and technical understanding serves the tertiary objective of
providing the physical means by which air pollution is controlled and the
legal and management objectives are attained.
These three objectives can be viewed as a conceptually nested
framework within which we pursue our management role in
government, whether at the national, state or local level.

National level Air quality is historically

and constitutionally the
Under the Australian Federal Constitution air quality was originally the sovereign responsibility of
sovereign responsibility of each State. However, issues such as needing States and Territories.
a consistent response to protecting health, a uniform requirement for
controlling vehicle emissions and addressing global pollution have Since 1994 the
necessitated a national approach. Commonwealth, States
and Territories have
The National Environment Protection Council (NEPC) was formed designated NEPC to set
by agreement between the Commonwealth Government and the eight ambient air quality
State and Territory governments in 1994 to set standards for standards as goals for the
environmental quality and for motor vehicle emissions. The standards whole of Australia.
are set as ambient concentration goals to be complied with by a
nominated future time. NEPC is now under the general aegis of the
Environment Protection and Heritage Council (EPHC) of
Environment Ministers.
NEPC establishes National Environment Protection Measure (NEPMs)
for the environmental standards and goals it sets. There are several
NEPMs for air quality as outlined in the introductory section of this
Toolkit.

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Controlling emissions
Except for the unique case of motor vehicles—which is the preserve of
the Commonwealth Government—agreed national policy leaves
controlling emissions to achieve the national ambient air quality goals to
the States and Territories.
Control of greenhouse gases such as carbon dioxide and methane is
also guided at a national level by the Commonwealth Government.
However, in varying degrees, State and Territory governments, and in
some cases local councils, have taken significant initiatives in this area.
Responsibilities for managing greenhouse gases are not yet well
defined.
In contrast, the stratospheric ozone depleting gases are regulated in an
agreed manner by the Commonwealth, States and local government in
pursuance of Australia’s national responsibility under the Montreal
Protocol for Ozone Protection.

State level
Each State continues to carry the responsibility for managing the release State environmental
of air pollutants in its jurisdictional territory. planning legislation
governs the location of
This is achieved through planning legislation in terms of new industry and business.
developments. The Environment Planning and Assessment Act 1979
(EP&A Act) is the relevant planning law in NSW. The recently updated Location, in turn, affects
EP&A Act and Regulations provide tools for managing the location of the impacts of air
polluting sources. pollutants.

Pollution control is achieved through environment protection

legislation by regulation of emissions. The Protection of the
Environment Operations Act 1997 (POEO Act) is the relevant law in State protection of the
NSW. environment legislation
Through this legislation and its derivative regulations, the States and regulates all emissions,
Territories control emissions of air pollution to achieve the national except emissions from
ambient goals in their jurisdictions. motor vehicles.

Air pollution controls at the State level

Air pollution controls at the State level often go beyond the defined
NEPC goals. In fact, a wide range of pollutants are defined for control Goals and emission limits
at the State and Territory level because legal responsibility for air for many air pollutants not
quality management rested at this level until the last decade. covered by the national
NEPM goals are set in
For example, there are State limitations and guidelines for a wide range
State and Territory laws,
of toxic air pollutants (including mercury, dioxins and cadmium etc.),
regulations, policies and
for pollutants where damage to vegetation is more important than
guidelines.
impacts on health (for example fluorides) and for odours, for which
there is no national position.

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State controls, requirements and objectives are set out in regulations,

When using State laws,
policies and guidelines. For example, in NSW they are set out in:
regulations and guidelines
• Protection of the Environment Operations (Clean Air) Regulation in the local government
2002 (POEOCAR) context it is important to
• Action for Air (1998) avoid confusion between
• Approved methods for sampling and analysis of air pollutants in controlling pollutant
NSW (2005) emissions and meeting
ambient air quality goals.
• Approved methods for modelling and assessment of air pollutants in
The two are related but are
NSW (2005)
regulated differently.
• Draft Policy: Assessment and management of odours from stationary
sources in NSW (2001)

Local government level

The EP&A Act and its instruments designate the responsibility for The EP&A Act & its
granting consents to new industrial and commercial developments. In instruments designate the
general local government is the consent authority, but other authorities responsibility for planning
may be designated for important situations, such as the Minister for and location of air pollution
Planning, advised by the Department of Planning (DoP), for any ‘State sources generally to local
Significant Development’. Local government also has a key role in government, but with other
locating sources of air pollution through its powers under the EP&A Act authorities, including the
to make Local Environment Plans (LEPs) within the context of State Minister under the Act,
and Regional Environmental Plans (SEPPs and REPs). designated in important
situations.
The POEO Act defines responsibility for environment protection,
including control of air pollution, through a schedule of industrial
activities with a potential environmental impact (see Schedule 1 of the
POEO Act). The schedule to the POEO
The list of activities includes thresholds for activity size, above which Act divides responsibility
the activity is licensed by the EPA and below which the activity is the for controlling air pollution
responsibility of local government. The responsible body is called the from sources between the
Appropriate Regulatory Authority (ARA). This delegation of power State agency (DECC in
under the POEO Act makes local government the ARA responsible for NSW) and local
managing the environmental performance of most small to medium- government.
sized businesses and industries in NSW.
Local government is therefore one of the agencies required to
participate in meeting the national goals for air quality. In NSW, Local councils have a
although the Minister for Planning/DoP and DECC take responsibility significant responsibility for
for most major pollution sources, local councils in fact manage most of meeting the national goals
the planning and control relevant to emission sources. This is because for air quality—since they
they have responsibility for many more factory and business sites than control most of the air
the Minister for Planning/DoP and DECC. They also significantly pollution from small to
influence the disposition and flow of traffic and hence the impacts of medium industry and have
motor vehicle air pollutants on the environment. some influence over road
traffic and hence vehicular
emissions.

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Responsibilities for air quality management according to level of government

Level of
Direct responsibility Influence
government

National/Federal Ambient goals

Fuel standards

Commonwealth Motor vehicle emissions Sustainability

Greenhouse policy
Ozone-depletion policy
Air, shipping and national highway
deployment and patterns

State/Territory Emissions from large polluting Sustainability

industries
Greenhouse policy
Ozone-depleting emissions
Some ambient goals, not regulated
nationally
Regional traffic deployment and
patterns

Local government Emissions from small-to-medium sized Sustainability

industries
Greenhouse policy
Ozone-depleting emissions
Local traffic deployment and patterns

4.2 The management cycle and air quality

Examining the management cycle for air quality can help to illustrate what might be realistically
achievable at local government level.
The 5-step management cycle is represented in simple terms in the diagram below.

Five-step cycle
The five key steps are:
• defining the problem
• exploring options for its solution
• deciding on a solution by analysis—including costs and benefits
• implementing the chosen solution
• checking and, if necessary, reviewing the outcome.

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What is the
issue or
problem?

Does it work What are the

or need options?
changing?

How is it What is the

implemented? solution?

Defining the management problem

The first step is problem definition: what is the issue or problem from a
management point of view?

Regional and local impacts

A key consideration in defining the management issue from a local
government perspective is whether the impact of the air pollution is local,
regional or global—or a combination of these—as this will influence the
degree of control a local council has over managing the issue.

Global? Local?

What is the
issue or
problem?

Regional?

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If the issue is to manage air quality comprehensively in the local government area to meet the NEPM
standard or goal, then this may be beyond the capacity of many councils acting alone. For example,
few local councils in large metropolitan areas can possibly manage all the factors which contribute to
air quality in their local government area. There are two reasons for this:
• air pollutants cross council boundaries, and
• not all pollution sources in a local government area (LGA) are under the council’s regulatory
control.
Conversely, councils in rural areas may be in a position to effectively achieve this outcome because
their areas are larger and most sources tend to be council-controlled.

Air pollution comes from many sources, and the multitude of small sources make a major
contribution to the regional air quality problem in cities like Sydney. Therefore councils almost
always have some part to play with the State and Commonwealth governments in the
management of regional air quality.

Global impacts of emissions

Many councils have adopted policies aimed at reducing ‘greenhouse gas’ emissions in their LGA,
from council activities and from the industries, businesses and dwellings under their control and
influence.

See Module 2 for information on Cities for Climate Protection and other initiatives.

Councils and regional air quality

The extent of council involvement in addressing regional air quality problems will depend on:
• the extent of the sources which council controls in its area (that is, for which council is the ARA
under the POEO Act)
• any partnerships between councils and DECC in air quality management
• the resources available to council to manage air pollution from sources, through legal instruments
and technical tools.

Some regional air quality issues, such as photochemical smog, can be significantly influenced by
sources which are located throughout the region and are regulated by individual local councils.

Impacts separated from pollution source

An example where the impacts of pollution are experienced some distance from the source is the
emissions of volatile organic compounds (VOCs) from many small sources. These react with
emissions of nitrogen oxides (NOx) in the presence of strong sunlight over a period of several hours to
form a brew of photochemical oxidants, measured as ozone (O3), and commonly called
photochemical smog.
Because of the time delay in the reaction, air carrying the reacting mix of pollutants can travel many
kilometres from the source of emissions before forming the smog. Some local government areas
contributing significantly to the problem may only rarely experience the effects. Yet many of the
sources, of VOCs for example, may be small local industries, such as car smash repairers, which are
subject to local government control.

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Another example would be domestic wood fires in the north west of the Sydney air basin or parts of
the Southern Highlands or Northern Tablelands. Fine particles and aerosols from wood fires are
trapped in the early-morning winter drainage flow in Sydney, Armidale and the Southern Highlands.
They accumulate in the stable air moving slowly eastwards, exposing the suburbs it crosses to high
levels of particulate air pollution.

Local air quality impacts

For local impacts caused by activities for which council is the ARA, council often has effective
control over all parts of the management loop. For example, an industry or activity causing a local
odour or dust problem where council is the ARA is a management issue for council alone.

Exploring options
There are usually many ways of reducing air pollution. Module 3 of the
Toolkit outlines some of the important techniques for the types of
industries commonly controlled by local government.
In general the management options fall into three categories:
• changes to practices
• changes to materials used
• changes to equipment.
Often a combination of two or even three of these categories can be used together.

Changes to practices
Changes to practices might be, for example, ensuring paper or carbon filters are changed regularly in
food preparation establishments. This will mean their containment capacity does not become
overwhelmed, rendering the removal of fatty and smelly aerosols ineffective. Another change to
practice might be applying adequate water to dusty surfaces on a construction site or within industrial
premises.

Changes to materials
Changes to materials might be, for example, substituting an effective but less odorous or low solvent-
content surface coating for a more odorous high solvent-content one in a smash repair shop, or on a
white goods finishing line. This would reduce both odours and VOC contribution to photochemical
smog. Another example would be ensuring wood used for domestic combustion is well seasoned and
dry.

Changes to equipment
Changes to equipment might involve, for example, using high-pressure
low-volume applicators in the car repair trade to minimise overspray, or
installing a catalytic oxidiser on the exhaust of a coffee bean roaster.
Another common equipment change is to raise the height of the exhaust
point of the pollutant in the interests of better dispersion. While this can
give real relief locally, it is ineffective for regional impacts.
However, even to achieve the local benefits, the change in height has to
be enough to overcome building and topographic effects. It is not
uncommon for these factors to defeat the purpose of raising stacks at
small to medium sources that are surrounded by other high buildings and
hills.

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Practice? Materials?

What are the

options?

Equipment?

Deciding on a solution
Once a range of options has been developed to address the issue, the
options are analysed, quantitatively if possible, to determine the
optimum solution. The analysis should look at:
• costs
• effectiveness
• acceptability.
Options may not be easy to assess in situations where there has been
extensive or prolonged public disquiet and solutions have been difficult
to find.
The guidance notes in Module 3 provide a range of detailed solutions to specific types of industries
which present problems for local government.

The cost of a solution

The cost of options is the most readily defined of the three factors. This task belongs to the person or
organisation managing the pollution source, although care should be taken to make sure the costs
claimed are reasonable.

The effectiveness of a solution

Effectiveness can sometimes be assessed quantitatively using Approved Methods for the Modelling
and Assessment of Air Pollutants in NSW (2005). However, the modelling prescribed in this guideline
is expensive to carry out and for small-to-medium enterprises may not always be warranted. Also, in
some situations, the results (predictions) may not provide enough certainty on which to base a
management decision. Furthermore, it may not be appropriate to incur this cost simply to provide
comfort in decision-making when exercising a fairly obvious judgement would suffice.
In some situations, an expert judgment (without expensive modelling) may be adequate to guide the
decision-making process and make a recommendation about likely effectiveness for smaller
installations, especially where the cost of a modelling study could become a significant component of
the total cost of the solution. This Toolkit, and the associated training, aims to help council officers

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develop this expertise. An additional option, always available to councils, is to require the businesses
in question to provide expert reports addressing the issues of uncertainty.

Acceptability of a solution
Council must determine which of the possible solutions to the problem is the most acceptable, based
on the consideration of the costs, the effectiveness and the benefits associated with each option.
Some exercise of practical judgment is usually warranted, especially for dealing with amenity
impacts which may be a significant proportion of complaints to council. The amenity of the people
affected by the pollution may need to be weighed against the capacity of the neighbouring source of
air pollution to pay for the mitigation measures.
Acceptability will be more difficult to assess, especially for amenity pollutants such as dust and
odour.
For example, it is not uncommon for complainants against odour sources to become so sensitised to
the odour over a period that a significant improvement, even to the level of industry best practice, will
not satisfy them. Putting up with a smell for a considerable time can leave an emotional scar which is
not easily healed. Added to this, political factors can sometimes become entwined in the problem.

Effectiveness? Cost?

What is the
solution?

Acceptability?

Implementation
The tools and resources needed for implementation of the chosen solution
need to be carefully assembled and applied. Depending on the nature of the
problem or issue different tools will be required.
Essentially there are three tools used in implementation:
• legal instruments
• technical resources
• education.
In many cases problems can be avoided in the development assessment process by anticipating
impacts and using siting or the incorporation of appropriate controls at that stage.

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To manage an emission source that is presenting problems (external to council’s own operations), the
solution will generally require the management of the polluting source to undertake the work.
The legal instruments available for imposing these requirements are outlined in Module 2. They are
generally Prevention or Clean Up Notices under the POEO Act. Occasionally variations to or
enforcement of planning consent provisions or measures under the LG Act may be used.
The technical information needed can be generated by or elicited from the source factory or business,
either voluntarily in response to council recommendations, or in response to a Prevention or Clean Up
Notice.

Persuasion
The preferable way to implement change is by persuading
Even when a solution is developed
the factory or business management that they need to solve
voluntarily by a business, it is
the problem, since development undertaken willingly is
advisable for a council to issue a
always more likely to succeed than development undertaken
notice to formalise any agreement
by constraint. There can also be problems for council
with the occupier of the premises
officers in drafting technical notices in terms which avoid
or business.
the risk of the recipient of the notice evading its purpose.
An issued notice should clearly set out any requirements
relating to the investigation of a problem, monitoring or
operational changes and the timeframe for completion of
each step, so that all parties know where they stand. A
realistic time is needed for compliance with equipment
design and installation. A notice which is unrealistically
short, i.e. a standard ‘30 days to comply’ typically used with
domestic premises and shops, may render the notice
ineffective if the actions required involve designing
equipment, specialised installation or raising capital. For
longer processes it might be appropriate to set milestones.

Community education campaigns

On the other hand, a council campaign aimed at reducing a
widespread local problem (for example), requires a different
approach to implementation. An example might be a
campaign to reduce woodsmoke from domestic premises.

Council would need to make sure the technology is

applicable and practical in the situation, that
enforcement is feasible if necessary and that financial,
personnel and expert resources are available for
promoting and implementing the campaign.

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Education
Education may be the principal means of addressing some problems, either as a broad issue-specific
campaign or on an individual premises level. Planning would need to take account of the need for
sustained advice and follow-up for effective implementation.

Legal? Education?

How is it
implemented?

Technical?

Checking and review

Any management program needs a checking or review step to ensure the
outcomes satisfy the objectives.
This holds whether the program is a broad action, such as reducing
woodsmoke in a local government area over a period of years, or a specific
action, such as reducing odours from the local ‘takeaway chook shop’.

There are two benefits to checking and review:

Firstly, to make sure the action undertaken and the effort expended do in fact achieve their intended
outcomes.
To continue with the example, without some checking it may seem as if the complaints about ‘chook
shop’ odours have gone away, whereas in fact the complainants may have just given up on council
ever solving the problem.

Mere disappearance of the complaints may seem an adequate outcome from an officer’s
perspective. But if this results in an ineffective solution being applied in another situation, the
outcome will not have been satisfactory.

Secondly, reviewing programs leads to continual improvement and is the path to sustainability in
environment protection.
This approach can be adopted for all programs, from the smallest action to a council’s overall
environmental performance.

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The formalised techniques for checking and review are

• monitoring
• auditing
• reporting.

Monitoring
Monitoring can span a full range of actions from checking for odours on a
‘sniff patrol’, through emission testing of a source on completion of its
installation, to ambient scientific monitoring to ensure that air quality
goals have been achieved. The expense increases across this range.
Ambient scientific monitoring, the most expensive, is rarely
warranted in local government situations involving small to medium
Simple air pollution monitors
industries and businesses, even for limited periods.
on a large construction site

Emission or source performance monitoring may sometimes be warranted, although it is also

expensive. For example, an emission test for particles could cost the operator from several thousand
dollars to $20,000 depending on the ease of access and the difficulty of the test. If toxic emissions are
involved such testing may indeed be warranted.
Finally, some sort of physical checking by observation is obviously the cheapest method and is
frequently adequate to confirm performance, e.g. the dust can no longer be seen or the odour can no
longer be smelled.

Consistent pre- and post- monitoring (scientific or by simple observation) is essential for the
adequate assessment and management of new developments and changes to premises.
‘Monitoring’ may be anything from intelligent observation to specialised, scientific measurement.
Wherever it lies on the spectrum it should be:
– systematic
– documented
– subject to careful analysis.

Auditing
Auditing is a systematic and thorough checking of operations and equipment to make sure they are
performing as intended. There are various techniques for auditing which are described on the DECC
and related web sites and in various standards produced by organisations such as Standards Australia
and the ISO standards.
Audits may take many forms. The purpose of an audit might be to address:
• compliance
• program effectiveness
• due diligence.

Audits are most successful when their objectives have been carefully and precisely defined before
any measurements or checks are undertaken.

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Audits may be carried out by accredited or general auditors, or may be independent or internal
to the organisation involved.
The acceptability of these variations will depend on the objectives. For example, for auditing
contaminated land only DECC accredited auditors may be used, whereas there are fewer situations in
which accredited auditors are likely to be required in air pollution situations.
Finally, the term ‘monitoring’ is also applied in a management sense to the overall process of checking
that a program or policy is being implemented satisfactorily.

Reporting of monitored and audited results should take account of who needs to know and who
might be interested in knowing.
The feedback process should also be open, and ideally there should be a willingness to consider
critical comment in order to improve management.

Does it work or
Monitoring? need changing? Auditing?

Overview
This management cycle, widely used for managing many activities in business and government, is
appropriate for local government management of air quality.
The full cycle is shown combined in the following diagram.

What is
the issue or
problem?

Does it work or Global? Local? What are

need changing? Regional? the options?
Monitoring? Practice?
Materials?
Auditing?
Equipment?
Legal?
Cost?
Education? Effectiveness?
Technical? Acceptability?

How is it What is the

implemented? solution?

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4.3 Assessing air quality issues

Some practical techniques that can be used by councils for identifying air quality issues in their local
areas include:
• any DECC or large-industry monitoring in or adjacent to the local government area
• inventories of air pollutants emitted in the local government area from sources such as the
National Pollutant Inventory or DECC special purpose inventories
• GIS data held by council on the spatial distribution of industries with potential for air emissions,
looking especially for clustering of common types, for example, smash repairers
• council-generated data including analysis of complaint patterns relating to ‘hot spots’ and routine
field officer observations.

Monitoring ambient air quality

Collecting and maintaining ambient air quality monitoring data is demanding and expensive. Scientific
accuracy, consistency and continuity are essential for reliable assessment of air quality and trends. It is
not feasible or warranted for DECC to monitor air quality in every local government area.
In the old days of high fallout, deposit gauges were maintained in many local government areas across
the State, but this form of gross pollution monitoring has now been reduced to a typical uniform
minimum across similar areas and is no longer carried out. Processes for monitoring of PM10 or ozone,
for example, are much more sophisticated and complicated.
In polluted air basins, reliable interpolations on air quality can be made between monitoring stations
by using modelling techniques. However, this is rarely critical for local government purposes, since
the nearest air quality monitor within the same air shed will usually give an adequate indication of air
quality in the local government area.

Monitoring by industries
Some industries are required to undertake specific ambient monitoring around their operations and to
make the information publicly available. This can be usefully accessed and reviewed by local
government for general air quality trends, although these large industries are not regulated by local
government.

The National Pollutant Inventory

The National Pollutant Inventory (NPI) provides information on releases of toxic and other key air
pollutants by local government and postcode areas. This can be a useful starting point for developing
priorities for dealing with air quality in a region. However, caution is needed in interpreting some of
the NPI data, especially where reporting is not complete.

GIS databases
Often a council’s own GIS database of its industries and businesses can be a useful starting point in
developing a priority program for air quality management. For example, the location of poultry
operations, small piggeries or mushroom growers in relation to residential areas and likely prevalent
wind directions might provide useful inputs to land use planning and the formulation of Local
Environment Plans (LEPs) and Development Control Plans (DCPs).

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Council-generated information
Complaints usually represent a substantial database in councils, and careful analysis of the complaints
can provide useful pointers for practical management as discussed further below. Skilled observations
by council officers in the course of normal field duties can also provide valuable data inputs.

4.4 Planning
Although regional planning for air quality is primarily the province of DECC and the Department of
Planning, local government planning for local facilities can have significant impacts on air quality. For
example, the development of a new shopping complex has obvious implications for traffic flow and
vehicle emissions and certain types of commercial emissions. Similarly, the development of a new
industrial area can have significant impacts on air quality—both locally and regionally. For example,
the development of marina-based businesses could result in increased emissions of VOCs as a result of
boat maintenance activities.

The best management of the regional and amenity impacts of air pollution is achieved at the
planning stage, in which local government is an active partner with State government.

Local land use planning

At the local level, the air amenity issues most commonly
faced by local government—odour and dust—are best dealt
with initially by separating the sources of air pollution and the
sensitive receptors such as homes, hospitals, schools, etc.
Sensible planning provisions can contribute immeasurably to
maintaining good air quality at the local level.
Some local councils include provisions relating to air quality
management into Local Environment Plans (LEPs) and
Development Control Plans (DCPs), while others rely on
regional air quality planning at the State level and concentrate
primarily on local air pollution issues. This depends on These exhaust stacks are located on a
circumstances, but the need for local government to be relatively new food processing premises.
The dust screen in the foreground is
involved in regional aspects is becoming more relevant with shielding a proposed multi-storey
growth in population and increasing density of housing and residential development. Is this a
traffic. problem waiting to develop?

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4.5 Consents, notices and enforcement

The principal legal instruments available to councils for air quality management at specific premises
are conditions attached to consents granted under the EP&A Act and requirements attached to
notices under the POEO Act.
The legal aspects of these instruments are outlined in Module 2 of the Toolkit. Guidelines for
conditions in various industries are covered in Module 3 of the Toolkit.

Enforcement
Enforcement will be needed from time to time, when industries, businesses or householders are tardy
and recalcitrant in complying with Council’s requirements to control or eliminate air pollution.
Penalty Notices under the EP&A Act and the POEO Act are useful tools for achieving compliance.
Prosecution is a more demanding measure, but one which may be warranted in difficult cases. The
approach taken will depend on circumstances and council policies and attitudes to enforcement.
Clean-Up Notices under the POEO Act where there has been an incident or persistent damage to the
environment can serve both the dual purpose of remediating damage to the environment and being a
costly deterrent to repeat offences.
Warning letters following inspections are used by some councils as the first formal action against
offending premises, before applying the law formally. While this can be effective, it needs to be
publicly demonstrated that more formal legal action will indeed follow if warnings are not heeded.

Industrial or commercial campaigns

Some councils have found that planned campaigns in selected industrial areas have beneficial
effects. Some of the techniques used include:
• Short ‘audits’ by experienced council officers on a ‘walk-though-and-note’ basis, often using
check lists for specific industry types. These may be planned on a precinct or industry-type basis.
Such audits will rarely be confined to air pollution matters alone, since it tends to be an inefficient
use of resources to visit premises only for air pollution where water, noise and waste issues are also
likely to be involved.
• Blitz-type intensive inspections on selected troublesome industries, with widely publicized
follow-up action.
• Development of partnerships with industry groups, e.g. smash-repairers, wherein industry
members participate in campaigns and competitions for best practice with the support and
encouragement of council officers.

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4.6 Complaints and community feedback

Unfortunately much air quality management at the local level tends to be complaint driven. The
officers rarely have time for planning since they are forever chasing down and acting on complaints.
This is a common fact of life in environmental work.
The DECC information and complaints service receives 80,000 calls a year, many of which relate to
local government responsibilities under environmental legislation. The community provides dynamic
and active feedback to its government authorities on the environment!

Using complaints constructively

Rather than bemoaning complaints, a more productive approach is to use phenomenon as an
indicator of community feedback. Members of the public can be enlisted in problem solving by
collecting information on occurrence, times, weather conditions, etc. and even fallout samples.
However, experience has shown that this information should only be supplementary to more definitive
observation and sampling by trained officers.

Long-term experience has shown that public descriptions of smells and fallout are not generally
reliable. What is reliable is that complaints are more often than not an indication that a real
problem of some sort does exist.

Most local government councils have a system for recording and following up on complaints. It is
wise to review this periodically to see if there are patterns of complaints which could be dealt with in
other ways—for example by providing information via council’s website or brochures, and so on.

Persistent complaint patterns may point to a need to make concerted efforts to achieve efficient
solutions for particular premises or industries.

Public exhibition of development applications

Feedback during the consultation and exhibition periods of development applications can be useful in
identifying issues for both the applicant and council. It can also point to the need for community
follow-up to provide assurance that fears and concerns have been addressed in the consent process.

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4.7 Resources
Many council environmental officers have received training at university or college level, and are
generally equipped to understand the basic principles of air quality science without being experts in
the area. However, the air quality issues which arise, even with medium to small installations, can be
quite complex. For example, crematoria, a local council responsibility, emit mercury and dioxins and
complex risk assessment may be needed in their assessment and management.
From time to time, when complex issues arise, councils will need access to more skills than available
through their staff. Consultants can be used to supplement council skills, either employed by council
or by the businesses posing the problems.

Use of consultants
Some councils retain consultants to advise them on specific matters of planning or development
consent assessments. However, this can strain council budgets if the costs cannot be passed on to the
developers.

Existing premises and activities

Dealing with existing industries and businesses presents a real problem in terms of the cost of advice,
since the recovery of costs from issuing notices will not usually be adequate to buy expert advice. A
notice can require industry to obtain the necessary expert advice, but it needs to be carefully drafted to
make sure that the advice obtained is balanced and does not start from inadequate or unsuitable pre-
suppositions on the part of the business. Also, advice from consultants needs to be subject to careful
scrutiny by council officers, taking account of the consultant’s experience and qualifications for
providing the advice.
Ongoing training of council officers is highly desirable. This Toolkit and associated training is a
contribution to such training. It should be regarded as a resource to be developed and adapted to
specific council needs, with the training as a seeding exercise. Council officers should be encouraged
to engage in real, lifelong training such as many professions now require of their members.

In-service training for council officers

Short courses are offered periodically by:
• DECC e.g. the training accompanying this Toolkit
• professional associations, such as the Clean Air Society of Australia and New Zealand, Inc.
• industry associations, such as the Australian Industry Group.
Some professional training providers also offer in-house specialised training for council officers.
Many universities and TAFE colleges offer postgraduate or advanced-certificate training in
environmental science and management which are suitable for council officers.

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