submission on the “better fuel fo r cleaner air” discussion paper · 2018. 11. 21. ·...

!

!

Submission on the “Better fuel for cleaner air” discussion paper

Robyn Schofield, Clare Walter, Jeremy Silver, Michael Brear, Peter Rayner and Martin Bush

March 2017 !

!

Statement'of'authorship'This!paper!was!written!by!Robyn!Schofield1,!Clare!Walter2,!Jeremy!Silver1,!Michael!Brear3,!Peter!Rayner1!and!Martin!Bush1!on!behalf!of!the!Clean!Air!and!Urban!Landscapes!Hub!and!the!Melbourne!

Energy!Institute.!!

It!should!be!cited!as!Schofield,!R.,!Walter,!C.,!Silver,!J.,!Brear,!M.,!Rayner,!P.,!and!Bush,!M.!(2017),!

‘Submission*on*the*“Better*fuel*for*cleaner*air”*discussion*paper’.!Melbourne:!Clean!Air!and!Urban!Landscapes!Hub/Melbourne!Energy!Institute!!

1!! School!of!Earth!Sciences,!University!of!Melbourne!

2! Department!of!Respiratory!Medicine!&!Sleep!Disorders,!The!Royal!Melbourne!Hospital!

3! Melbourne!Energy!Institute,!University!of!Melbourne!

About'the'Clean'Air'and'Urban'Landscapes'Hub'The!Clean!Air!and!Urban!Landscapes!Hub!(CAUL)!is!a!consortium!of!four!universities:!the!University!of!

Melbourne,!RMIT!University,!the!University!of!Western!Australia!and!the!University!of!Wollongong.!The!CAUL!Hub!is!funded!under!the!National!Environmental!Science!Programme!of!the!Australian!

Government’s!Department!of!!the!Environment.!The!task!of!the!CAUL!Hub!is!to!undertake!research!to!support!environmental!quality!in!our!urban!areas,!especially!in!the!areas!of!air!quality,!urban!

greening,!liveability!and!biodiversity,!and!with!a!focus!on!applying!research!to!develop!practical!solutions.!

www.nespurban.edu.au*

About'the'Melbourne'Energy'Institute'The!University!of!Melbourne!is!a!national!leader!in!energy!research,!with!over!300!experts!engaged!

across!science,!technology,!economics!and!policy!of!energy.!The!Melbourne!Energy!Institute!provides!a!focal!point!for!the!University’s!energy!researchers!and!government!and!industry!partners.!Since!the!

Institute!launched!in!2010,!it!has!developed!many!interdisciplinary!research!programs!across!economics,!engineering,!health,!the!humanities,!law!and!the!sciences..!

energy.unimelb.edu.au*

Note'on'online'version'This!is!a!version!of!the!submission!lodged!with!the!Department!of!the!Environment!and!Energy!in!

March!2017!on!behalf!of!the!Clean!Air!and!Urban!Landscapes!Hub!and!the!Melbourne!Energy!Institute.!This!version!contains!additional!formatting,!including!this!page,!and!thus!may!appear!

different!to!any!version!published!on!the!Department!of!the!Environment!and!Energy!website.!!The!main!content!of!this!document!is!unchanged!from!the!lodged!version.!

The!original!discussion!paper,!“Better*fuel*for*cleaner*air”,!to!which!this!is!a!response,!can!be!located!at!www.environment.gov.au/protection/fuel?quality/better?fuel?cleaner?air?discussion?paper?2016!

! !

!

Overview

The Clean Air and Urban Landscapes Hub and the Melbourne Energy Institute welcome the opportunity to comment on the ‘Better fuel for cleaner air’ discussion paper, and the proposed changes to the Fuel Quality Standards Act 2000 and associated legislation.

These two groups have expertise in several areas that are relevant to this paper: air quality, public health, energy policy and resource economics and vehicle fuels and emissions. We would therefore welcome further discussion with the Department should this be of interest.

Our submission first considers the motivation of this Paper. While Australian air quality conforms to international standards, recent research1 shows that significant health impacts still occur at pollution levels experienced in Australia. The costs of air pollution to society have been put on a par with smoking and obesity. Air pollution due to vehicle emissions is estimated to have caused 1715 deaths in Australia in 20152, larger than the national road toll of 1205 in 20153. Appendix A to this submission contains a detailed discussion of these health impacts.

We submit that a review of the Fuel Quality Standards Act 2000 and associated legislation should therefore prioritise this cost of the health impacts of vehicle emissions. To this end this submission primarily addresses Question Sets 1 and 6, and the Questions relating to the fuel, automotive and marine diesel standards.

While making specific recommendations relevant to the Fuel Quality Standards Act 2000, we also submit that the comprehensive package of measures should contain additional regulations, at both Australian Government and state government levels, concerning energy infrastructure, motor vehicles and other engines, and driver behaviour. Furthermore, additional government action directed towards increasing public awareness and supporting better collection of air quality data are important.

!

!

!

!

!

!

Submission contents

Summary!of!recommendations!....................................................................................................!v!

QUESTION!SET!1.!Questions!in!relation!to!the!fuel!standards!......................................................!1!

Health!costs!associated!with!vehicle!emissions!.......................................................................!1!

Reduction!of!maximum!sulfur!content!to!10!ppm!...................................................................!2!UltraDfine!particles!....................................................................................................................!2!

Additional!questions!.....................................................................................................................!4!

Continuous!improvement!and!bestDpractice!standards.!..........................................................!5!Improved!airDquality!data!.........................................................................................................!6!Raising!public!awareness!..........................................................................................................!7!AntiDidling!legislation!................................................................................................................!7!Filter!point!sources!of!vehicle!emissions!..................................................................................!8!Regulation!of!bowser!emissions!...............................................................................................!8!

QUESTION!SET!3.!Questions!in!relation!to!the!Fuel!Quality!Standards!Regulations!2001!...........!9!

Shipping!....................................................................................................................................!9!Airports!.....................................................................................................................................!9!

QUESTION!SET!6.!General!questions!regarding!the!approach!!for!assessing!the!policy!alternatives!.................................................................................!10!

Health!costs!associated!with!vehicle!emissions!.....................................................................!10!Cost!implications!....................................................................................................................!10!Reduction!of!maximum!sulfur!content!to!10!ppm!.................................................................!10!Removal!of!mercury!...............................................................................................................!11!

Questions!relating!to!the!automotive!diesel!standard!...............................................................!12!

Health!impact!stakeholders!....................................................................................................!12!Shipping!emissions!.................................................................................................................!12!

Appendix!A:!Health!costs!of!vehicle!emissions!...........................................................................!13!

Underestimated!mortality!rate!...............................................................................................!13!Established!Health!Impacts!.....................................................................................................!14!Cardiovascular!&!Cerebrovascular!..........................................................................................!14!Lung!Cancer!............................................................................................................................!14!Asthma!and!Lung!Function.!....................................................................................................!15!Emerging!health!impacts!........................................................................................................!16!Summary!.................................................................................................................................!16!

References! !...............................................................................................................................!17!

! !

!

!

!

! !

Page!1!

QUESTION SET 1. Questions in relation to the fuel standards

Policy alternatives outlined in this paper

1. Can you provide evidence of the costs and/or benefits of any of the listed policy alternatives (A, B, C, D or E)?

Health costs associated with vehicle emissions

We acknowledge the discussion paper’s consideration of the considerable health costs associated with vehicle emissions but submit that these costs are significantly understated. The cost of premature deaths due to outdoor air pollution in Australia in 2015 is estimated to be up to $A17.8 Billion2, compared with the 2010 estimate of $A7.7 Billion4 provided in the discussion paper. Costs to the Australian economy of air pollution via welfare losses and foregone labor output are roughly $4.5 billion AUD annually.5

The discussion paper’s cost-benefit analyses acknowledge some of the likely underestimations, however, we remain concerned the sensitivity analysis and associated figures underrepresent the due precedence of public health in this consultation. Emerging evidence points to a wider range of health impacts than those considered in the cost benefit analysis. These additional impacts are presently unquantifiable; however they point to trends that warrant judicious consideration.

A discussion on health impacts omitted from the cost benefit analysis is provided in Appendix A to this submission. The key points to be considered from this discussion are:

• Health costs associated with NOx are not included in Australian mortality costs

• The health cost of supporting increases in diesel emissions not quantified

Health costs apply to the community at large (especially sensitive subgroups of the population, such as growing children and the elderly), but are borne intensely by some occupational groups. For instance, those working in and around traffic (e.g. professional drivers, hospitality workers on suburban high streets), around off-road vehicles (e.g. in construction, aviation, diesel trains, shipping or mining) or in businesses located next to emission hot-spots (e.g. on busy streets next to traffic lights, beside bus stops) are exposed to much higher than average levels of particulate and gaseous pollutants, and this results in worse long-term health outcomes.6,7 As such, air pollution should feature amongst occupational health and welfare considerations, which have improved considerably during recent decades, with associated reductions in accident-related morbidity and mortality.8

!

Submission on ‘Better fuel for cleaner air’ discussion paper Clean Air and Urban Landscapes Hub and the Melbourne Energy Institute!

Page!2!

Reduction of maximum sulfur content to 10 ppm

The health benefit associated with reducing sulfur content in petrol from 30 ppm to 10 ppm in the US is determined by the US EPA to return $13 in health benefit for every $1 spent.9 This can be viewed as a minimum net health benefit associated with choosing options B, C or D over A (BAU: 91 RON maximum sulfur of 150 ppm) or E (91 RON with maximum sulfur of 50 ppm).

We support the reduction of a maximum sulfur content in petrol to 10 ppm in the proposed standards. The reasons for this are further discussed in Question Set 6 below.

2. Do you have a different alternative which is not covered in this paper? 3. Are there any changes which would improve or clarify the operation of the

fuel standards?

Ultra-fine particles

The consideration of ultra-fine particulate matter in the development of standards is currently inadequate. Although these particles are difficult to measure, and will remain so for some time, evidence increasingly suggests that the health effects of these particles are significantly detrimental. The most significant regulatory action to limit the production of ultra-fine particulate matter concerns diesel. Additional measures would address sulfur content of fuels, octane rating, combustion efficiencies, catalytic converter efficiency, and driving behaviours.

Health studies examining particulate matter used in the cost benefit analysis have used the coarse or fine fraction of particulate matter (PM10 and PM2.5) due to the ease of measurement and availability of historical records.

The majority of vehicle emissions, and in particular diesel emissions, are ultrafine (PM1.0). Larger fractions are a mix of natural air borne particulates (pollens, salt spray, dust) and anthropogenic particulates (vehicle emissions, wood and coal burning).10 Natural particulate matter has a different chemical composition, making it less detrimental to public health compared to the smaller carbonaceous particles produced by combustion. Due to its larger size the natural particulate matter can heavily influence particulate matter measurements (which are mass measurements).

Evidence to date suggests compared to the larger fractions, ultrafine particles have a greater potential for adverse health impacts.10 Vehicle emissions, particularly diesel emissions are predominantly ultrafine (PM1.0). When measured by number, rather than mass, vehicle emissions make up 90 percent of total particle numbers at busy road sides.11 They remain airborne for longer and travel further than the coarse (PM10) and fine fraction (PM2.5) particles.

! !

Page!3!

When inhaled, their tiny size allows them to deposit throughout the lungs and translocate into both the bloodstream and central nervous system and ganglia, thus reaching the brain, heart and other organs via the circulatory system. They can also penetrate the skin then distribute via uptake through the lymphatic system. Additional to their ability to reach throughout the body, their large surface area confers a greater biological activity compared to larger particles of the same substance.12

The introduction of Euro standards has reduced the absolute particulate emissions (by weight), but at the same time has resulted in increased emissions of ultrafine particles.13

To date, health studies on the impact of ultrafines are limited due to the lack of available data. Whilst quantifying and costing the impact is not yet feasible, the emerging evidence suggests there is cause for concern particularly in light of the rapid growth of public exposure to diesel emissions in Australia. Diesel vehicle ownership has experienced a 60% increase from 2011 to 2016 and diesel powered vehicles now constitute 20.9% of the total fleet.14

Reducing sulfur content in fuel has been shown to decrease human exposure to ultrafine particles.15

!


Page!4!

Additional questions

5. Can you provide evidence of the extent to which the current fuel standards limit the adoption/ importation of existing technologies and models that meet higher specifications?

We make 3 points in response to this question.

1. The regulated sulfur content of Australian petrol should be consistent with regulation across the EU, Japan, South Korea and the United States, and thus become 10 ppm as soon as possible. We discuss this further later in this submission, and this will become an increasing issue since all Australian vehicles will shortly be imported.

2. A fuel standard for natural gas as a road vehicle fuel should be established, making use of equivalent standards from other jurisdictions. Without this standard, the benefits of using natural gas as a transport fuel cannot be fully realised, nor can best-practice regulation of the resulting pollutant emissions.

3. Increasing the minimum octane requirement for ULP from 91 reduces fleet-wide greenhouse gas emissions as engines that can exploit a higher octane fuel become widespread. Given the multiple means by which higher octane gasoline can be made, including through use of added ethanol, reasonable increases in octane are likely to be affordable for consumers and therefore a cost-effective form of abatement.

6. What changes to the fuel standards would best reduce emissions, ensure engine operability and facilitate new engine technologies?

As discussed above, ULP should have 10ppm sulfur and likely higher octane and a natural gas fuel standard should be introduced.

7. What changes to the fuel standards do you believe will be required if the Australian Government mandates Euro 6 emissions standards for light vehicles?

The issue of ‘real-world’ driving emissions versus certified laboratory based driving emissions continues to be problematic for regulators as well as fuel and vehicle manufacturers around

! !

Page!5!

the world. Defining ‘real’ emissions over ‘real’ driving conditions is very complex given the massive variation in individual vehicle use and driver behaviour. At the same time, it is well known in the automotive community that laboratory testing consistently underestimates real-world emissions of greenhouse gases and other pollutants. We therefore have a complex problem that can’t be solved simply.

We therefore recommend that the inclusion of real-world emissions into any future standard needs further thought by the Federal Government, likely acting on the advice of health, environmental and technical specialists. The authors of this report consider themselves to be one such group of specialists.

8. Each fuel standard includes required test methods for analysis of fuel samples. Do you have any comments on the test methods specified in the fuel standards?

9. Are there any other issues you would like to raise in relation to the fuel standards?

We recommend the comprehensive package of measures to reduce motor vehicle emissions that harm human health and contribute to greenhouse gas emissions, of which this discussion paper forms a part, goes beyond vehicle emission and fuel efficiency standards and include consideration of a broader range of strategies designed to meet the primary policy objective of reducing the adverse effects of vehicle emissions on air quality, human health and environment. Accordingly, several additional measures should be considered under the operation of the Act or related legislation.

Continuous improvement and best-practice standards.

Australian policy to date has lagged international best practice.16 This presents the opportunity to examine international strategies emulating successes, and avoiding decisions which have proven costly.

There is no safe level beyond which health is not impacted and even in the cleanest parts of Australia, air pollution is taking a toll.17 Discussions should be shifting the focus from thresholds to a reducing framework as whatever the value, pollution reductions will result in gains for public health.

!


Page!6!

Improved air-quality data

While general air quality in Australia is considered good, our monitoring and reporting systems are not sufficiently geared to provide an accurate account of the air quality experience by the general Australian public.

There are ‘hot spots’ across Australia where air quality thresholds often do not meet regulatory thresholds.18 The air quality models used in the analysis were a large grid/limited resolution designed to reflect regional air quality rather than road side air quality conditions. Yet, much of the population of the modelled cities (Sydney and Melbourne) experience a considerable amount of time being exposed to road side pollution. Personal exposure studies show highest daily exposures occur during commute by road.19

Schools and childcare centres are often placed on or near busy roads exposing a particularly vulnerable subset of our population to daily pollution concentrations much higher than those reflected by the regional air shed.20

Many of the health risks calculated from international epidemiological studies utilise air quality data obtained from networks with superior spatial resolution, allowing a more accurate account of public exposure. If we extrapolate hazard ratios established internationally, and then apply domestic air quality data we risk underestimating the health impacts in Australia.

Better real-world data is essential for setting standards. The Volkswagon (VW) emissions scandal highlighted to the world the difference between laboratory emissions and real life emissions. The occurrence however, is not unique to VW.21 The European Joint Research Centre has released data that suggests real life NOx emissions of Euro5 diesel cars are 4 times higher than threshold limits suggest.22

The modelling used for the cost benefit analysis makes the assumptions that vehicle technology is performing as expected and that fuel content meets regulatory values. In reality, when lower quality fuel is used (such as is available in Australia) the performance of vehicle technology degrades resulting in increased emissions.

We strongly endorse improvements in testing methodology for vehicles but also an improvement in exposure-relevant measurement of air quality, particularly in cities. This is needed to verify whether any measures we implement are having the desired effect. Appropriate levels of research support should be provided by government to this end.

!

! !

Page!7!

Raising public awareness

“A public awareness campaign would be the single most important tool in improving air quality”23

The Vehicle emissions RIS correctly notes “there is limited incentive for manufacturers to improve the noxious emissions performance of vehicles, as these emissions do not have a high profile in the minds of new vehicle consumers (unlike safety).”

A 2007 review of air quality education recommended a concerted and strategic approach be adopted to community education around air quality, including national leadership and coordination between various levels of government.24 A targeted, multi-sector public health education program used to raise public awareness is required. Targeted messaging is particularly important for vulnerable sub-populations, including parents of asthmatic children, and people who work in occupations or industries where there is a high risk of vehicle emission exposure.

Increasing awareness improves acceptance of consumer costs and enables the public to take appropriate actions to reduce their personal exposure. The use of simple measures such as reticulating vehicle circulation while driving or choosing a quieter route when out walking or running, opting to take the train rather than drive, have been shown to make a large difference in the total daily black carbon exposure of individuals.25

Anti-tobacco campaigns started in the 1970s in response to several decades of evidence pointing to profound health consequences of smoking. The benefits of those campaigns are evident today. There is now several decades of evidence demonstrating the profound health consequences of vehicle emissions. Addressing this starts by raising public awareness.

Anti-idling legislation

Anti-idling legislation has been one of the successful strategies implemented by the Californian EPA and across the States. A quick review of the many anti-idling resources available online elucidates:

• Based on a 1.8 car average per household, eliminating just 5 minutes of idling per day per family would save 400-800 lbs of CO2 from being released into the air over the course of a year.

• The average American idles for 8 min per day

• 10 sec of idling wastes more fuel than restarting

• Even in cold weather engines only need 30 sec to warm up

• Turning your car off is better than leaving your engine running

• Since electric ignition became universal in the 1980s restarting your vehicle does not result in significant fuel loss

• 2 minutes spent idling is equal to one mile of driving


Page!8!

Some of the penalties across America:

• Utah: A first-time idling violation brings $1000 fine and/or up to six months prison • New York state: A first-time violation can bring a fine up to $15,000 • Las Vegas: $10,000 maximum fine • Hawaii: 3 minutes of idling will cost you $25 to $2,500 • Denver: 10 minutes of idling in an hour will bring a fine of $999 and/or one-year

imprisonment • Virginia: 10 minutes of idling in a residential or commercial zone carries a fine up to

$25,000

Recommendations to establish anti-idling policies in Australia have been made in the 2013 Senate enquiry into the health impacts of air pollution and in subsequent government submissions by Australian health and academic experts.26,27The consumer costs are negligible for those who comply, and the public health benefits are numerous, reducing health impacts and simultaneously raising public awareness and changing polluting behaviour.

Targeting schools with ‘anti-idling zones’ is a natural starting point reducing acute exposures to children during their commute to school and exploiting the co-benefits of linkages to climate policy and education around sustainability for our next generation with the aim to roll out into federal legislation.

Filter point sources of vehicle emissions

As traffic networks increase, long road tunnels are likely to become increasingly utilised. Such tunnels have the capacity to significantly increase the concentration and hence the pollution exposure of tunnel users. There are proven examples of successful use of filters to reduce health impacts from pollution created and retained in long road tunnels internationally (for example the Calle 30 tunnel in Madrid, Spain).28 With the exception of the M5 East tunnel in Sydney, tunnels in Australia are not fitted with filtration systems and despite technological advancements they are currently not considered in the planning for future road tunnels. In addition to reducing the exposure of tunnel users, emerging technology also makes it possible to capture emissions from tunnels before they are added to the general air shed. Where appropriate, health risk assessments of large infrastructure projects should review the option of filtration of point sources in their cost benefit analyses.

Regulation of bowser emissions

Fuel bowsers are a significant source fugitive emissions of volatile organic compounds into the urban environment. Consideration should be given to the monitoring and regulation of the performance of commercial bowsers in order to limit these fugitive emissions.

! !

Page!9!

QUESTION SET 3. Questions in relation to the Fuel Quality Standards Regulations 2001

12. Have you identified any issue with the Regulations that you would like to draw to our attention?

13. Is the definition of ‘fuel’ adequate to enable all relevant standards to be made? For example, should the definition of fuel be expanded to cover marine diesel, synthetic diesel, methanol-based fuels, etc to enable standards to be made for these fuel types?

Shipping

Around ports, the local contribution of shipping to emissions of SOx and NOx can be considerable29. For the Sydney Greater Metropolitan Region in 2010/11, ~ 1.9% of the region-wide total PM2.5 annual loading was attributable to ship exhaust, and up to 9.4% at suburbs close to ports. This is associated with ~220 years of life lost by people who died in 2010/11 as a result of ship exhaust-related exposure. By reducing sulfur in ship fuels to 0.1% would result in a 25% reduction in PM2.5 (a gain of 390 life years over 20 years) at berth and a 56% PM2.5 reduction (a gain of 920 life years over 20 years) if a low sulfur zone of 300km of Sydney was created.30

When ultra-low sulfur diesel was introduced in the UK in 2007 a 30-60% reduction in total number of particles was experienced.31 At the Port of Dover the air quality improvement was notable due to the decrease in the sulfur content in marine fuel in most European waters in 2006.32 Restricting the sulfur in heavy fuel oil in 1990 in Hong Kong decreased death rates by 2-4% (all-cause, cardiac and respiratory).33

14. Currently, aviation gas (avgas) is explicitly excluded from the petrol standard. Do you believe avgas should be covered by a fuel standard?

Airports

Internationally, airports have been shown to have a significant local impacts on air quality and health outcomes.34,35 This is partly due to emissions from aircraft themselves, but also from the range of trucks, buses, vans and other motorized vehicles used at these sites, which often run on diesel fuel. There are major residential areas nearby or surrounding airports in many of the Australian state capitals. Questions of equity arise in this regard, since land prices are typically lower near airports (partly due to concerns over noise).


Page!10!

QUESTION SET 6. General questions regarding the approach for assessing the policy alternatives

21. Do you have any comments in relation to whether all likely costs or benefits have been identified?

22. Can you provide information that may improve the reliability of the cost and benefit estimates for any of the policy alternatives?

Health costs associated with vehicle emissions

The considerable health costs associated with vehicle emissions are significantly understated in the discussion paper. The cost of premature deaths due to outdoor air pollution in Australia in 2015 is estimated to be up to $A17.8 Billion2, compared with the 2010 estimate of $A7.7 Billion4 provided in the discussion paper. Emerging evidence points to a wider range of health impacts than those considered in the cost benefit analysis. These additional impacts are presently unquantifiable; however point to trends which warrant judicious consideration. The costs of air pollution to society have been put on a par with smoking and obesity.

A detailed discussion of these health costs is provided in Appendix A. The key points to be considered from this discussion are:

• Health costs associated with NOx are not included in Australian mortality costs

• The health cost of supporting increases in diesel emissions are not quantified

Cost implications

25. What are the associated issues, costs and benefits of reducing the sulfur parameter in petrol to 10 ppm?

Reduction of maximum sulfur content to 10 ppm

Ten ppm of sulfur is already legislated in petrol sold in the US, EU, Japan and South Korea. The case for refiners not being able to do the same locally and in an affordable manner is therefore manifestly weak; all Australian refiners are multinational and are operating in these other jurisdictions.

The US EPA has also presented substantial evidence arguing that there is a strong technical and health case for this change.36 This is because any reduction in sulfur content enables the catalytic converter to perform better over a given period, or at a given level of performance for longer. All of the regulated gaseous pollutant emissions (CO, NOx, and UHCs), as well as many of those that are not regulated, are then reduced, achieving health benefits as

! !

Page!11!

previously discussed.

Finally, the cessation of Australian car manufacturing will mean that all new vehicles sold into the Australian market will be imported and therefore very likely designed for a 10 ppm sulfur limit. This will encourage Australian harmonisation to this international sulfur standard in the near future because of concerns related to vehicle warranty.

Clearly, therefore, the case for reducing sulfur to 10ppm has strong health, economic and technical merit and should be implemented as a priority.

27. What, if any, are the costs in making the changes proposed under the five alternatives? Is there an alternative more cost effective approach that would produce better environmental and health outcomes?

As we have stated in our response to the previous question, the case for refiners not being able to makes these changes locally and in an affordable manner is manifestly weak, since all Australian refiners are multinational and are operating in other jurisdictions where 10ppm sulfur gasoline is already mandated and affordable.

Removal of mercury

Where the government considers supporting refineries to transition to low sulfur petroleum, exploration of technologies that simultaneously remove mercury will provide concurrent benefits in meeting commitments under the Minamata convention for mercury. Australia is signatory to this convention and yet to ratify, but it is expected that the convention will come into force in late 2017. While vehicle and refinery emissions of mercury are small relative to coal combustion and gold refining, all reductions in mercury, a neuro-toxic global pollutant have significant health and environmental benefits.


Page!12!

Questions relating to the automotive diesel standard

41. What would be the effect of reducing carbon residue limits in diesel on industry and other stakeholders?

Health impact stakeholders

Given the significant health impacts of emissions described in this submission and detailed in Appendix A, we submit that public health stakeholders should be considered as stakeholders in this process. While broadly construed this includes all of the general public, we specifically recommend that the Department of Health be included as a formal stakeholder in this and associated review processes.

42. Should the standard apply more broadly to all diesel engines, including ships operating around the Australian coast?

Shipping emissions

The emissions of ships are significant, as described under Question Set 3 above. For this reason these standards should apply to all ships operating in Australian waters.

!

! !

Page!13!

Appendix A: Health costs of vehicle emissions

Underestimated mortality rate

The annual air pollution mortality figure of 1500 is used throughout this consultation. This figure was taken from a 2014 OECD report estimating the health and economic impacts of particulate matter and ozone.37 NOx was not included in this report.

The annual UK mortality attributed to Particulate matter is 29,000.38 When NOx is added in the estimation, the figure increases to 40,000.39

The Australian Institute of Health and Welfare (AIHW) estimated 3056 annual deaths attributable to urban air pollution in Australia in 2003.40

Since the AIHW report:

• Nitrogen Dioxide emissions have decreased, however Ozone and Particulate matter levels have not declined.41

• Population exposure has increased with the increasing urbanisation of Australia.

• The proportion of vulnerable society members exposed has increased due to our aging population

The most dominant pollutant for health impacts is particulate matter. There is no safe threshold and the relationship with the health impacts is linear.42

As there have been no policy interventions for PM2.5 it’s reasonable to expect the trend in air pollution related deaths (68% increase between 2005-2010) has continued to the present day and that 1500 deaths per year is a significant underestimation of the current mortality rate.

!


Page!14!

Established Health Impacts

Cardiovascular & Cerebrovascular

Cardiovascular impacts comprise the largest proportion of disease attributable to urban air pollution in Australia and are of notable import given our aging population. A 10µg/m3 increase in PM2.5 has been associated with a 76% increase risk in death from cardiovascular disease in post-menopausal woman.43

As further research emerges associated risks can augment. The Global Burden of disease study 2013 found that nearly a third of strokes are attributable to air pollution, leading researchers to conclude “The most alarming finding was that about a third of the burden of stroke is attributable to air pollution. Although air pollution is known to damage the lungs, heart, and brain, the extent of this threat seems to have been underestimated”.44

Lung Cancer

In Australia, lung cancer remains the leading cause of cancer related mortality.45 Particulate matter largely contributes to excess mortality from lung cancer in both smokers and nonsmokers.46 Lung cancer contributes 21 per cent of the health burden attributable to urban air pollution.47 Reductions in cigarette smoking have reduced the incidence of squamous-cell lung cancer; however lung adenocarcinoma is increasing and affecting a growing proportion of ‘never smokers’.48 Currently 20% of lung adenocarcinoma patients are classed as ‘never smokers’.49

The health impact analysis used in this consultation has calculated the lung cancer risk based on the American Cancer Society Cancer Prevention Study II. Published in 2002, this study linked data from 500,000 adults to metropolitan air pollution throughout the United States. A 10µg/m3 increase in PM2.5 was associated with an 8% lung cancer risk after 8 years. Lung cancer has a long lag period from exposure to disease presentation (15 – 30 years) so when the follow up period doubled to 16 years, the risk had increased to 14%.50 In 2013 the European Study of Cohorts of Air Pollution Effects (ESCAPE) published a much higher associated risk of 18% with a 5 µg/m3 increase of PM2.5.51 The ESCAPE study also examined the major subtypes of lung cancer and reported a 55 per cent increase in life time risk of adenocarcinoma with a PM2.5 increase of 5 µg/m3 .

A meta-analysis pooling the Cancer Society Study and ESCAPE cohorts along with fifteen other large epidemiological studies reported a 40% increase in lung adenocarcinoma with PM2.5 increase of 10 µg/m3.52 The risks were highest for former smokers, followed by never smokers and lowest for current smokers (thought to be due to reduced lung deposition and competitive activation of the Poly Aromatic Hydrocarbons PAHs from multiple sources).53

Respirable elemental carbon (REC) is a more specific predictor of combustion related PM2.5.

! !

Page!15!

Environmental exposures of REC in areas with heavy amounts of diesel exhaust can be expected to be in the range of 2 to 6 µg/m3. Extrapolating the risk factors from the Diesel Exhaust in Miners Study,54 this level of exposure accumulated over a lifetime (e.g. 60 years), approximates to a 50 percent increase in lung cancer risk.55

There is evidence that the DNA damage and mutations caused by diesel pollution also occur in sperm,56 which may give rise to subsequent generations inheriting the mutagenic impacts of diesel vehicle emissions.

Asthma and Lung Function.

Starting with exposures in-utero, vehicle emissions adversely affect lung function across the full spectrum population increasing emergency department visits and hospitalisations for respiratory diseases.57,58 Children living within 75m of a major road had a 29 per cent increased risk of lifetime asthma.ref Vehicle emissions near homes and schools are also associated with a 1.5 fold increased risk of new-onset asthma.59

Over the past two decades, the Californian EPA has instigated a range of policies and worlds best practice measures to improve the air quality and reduce children’s exposure to near road pollution.60 These improvements have been associated with significant health improvements. The Southern Californian Children’s Health Study measured annual lung function in 3 cohorts of children (n= 2120) corresponding to the time periods 1994 – 1998, 1997 – 2001 and 2007- 2011. Declining levels of nitrogen dioxide and PM 2.5 and PM10 were associated with significant improvements in lung function growth and persisted after adjustment for potential confounders. Improvements were noted in children both with and without asthma. Children with clinically low lung function declined from 7.9% to 6.3% to 3.6% across the time period as air quality improved (p = 0.001).61

The benefits of improved lung development in children extend throughout their lives. A healthy lung function in adulthood has been associated with a reduced risks of cardiovascular disease62 and a lower mortality rate.63

“We have shown that improved air quality in southern California is associated with statistically and clinically significant improvement in childhood lung=function growth. The pollutants we found to be associated with lung-function growth nitrogen dioxide, PM2.5 and PM10 are products of primary fuel combustion and are likely to be at increased levels in most urban environments. These pollutants were amoung those effectively reduced through targeted policy strategies. If we made the not-unreasonable assumption of causality, the magnitude of the effects we observed and the importance of lung function over the course of the human lifetime justify the efforts that have been made to improve air quality”

In Australia, metropolitan school children’s highest daily particle exposures are experienced during the commute to school and outdoor school activities.64 The City of Maribyrnong in Melbourne’s Inner west is situated between the port and container yards. It records 21,000 trucks per day, the majority of which travel on residential streets, stopping and starting at multiple traffic lights in close proximity to a number of school outdoor play areas and childcare centres. The reported asthma incidence of children in this area is double the national rate.65


Page!16!

Emerging health impacts

Research is beginning to show associations to an even wider range of health impacts that are as yet unquantifiable.

Some of these impacts may be epigenetic (e.g. Poly Aromatic Hydrocarbons attached to vehicle particulates have been associated with changes in DNA methylation))66,67 creating a negative health legacy passed onto future generations.

In utero exposures to traffic emissions may adversely affect birth outcomes. Between 12-24 per cent of pre-term births have been associated with anthropogenic PM2.568 giving rise to survival and subsequent adverse outcomes particularly in terms of brain and respiratory system development.69 Traffic related air pollution is also associated with low birth weight at term, which is also associated with subsequent health impacts at birth and thereafter.70$In utero exposure to heavy metals attached to fine and ultrafine particles could also lead to neurodevelopmental harm, resulting in reduced cognitive function, lower IQ and ADHD.71

The health impacts continue to broaden as evidence mounts. To date, associations have been made with the following health impacts:

• Exacerbation of respiratory infections in young children72 • Air pollution is classed as a ‘possible carcinogen’ for bladder cancer.73 • Effects on growth, intelligence, and development of the brain and coordination • New onset type 2 diabetes • Obesity • Alzheimer’s disease

Traffic emissions are also implicated in the exacerbation and possible initiation of allergic disease.74

Vehicle emissions and pollens are both known to cause asthma in their own right; evidence now suggests a supra-additive impact from duel exposure. Reactive diesel particles are ideal carriers for the pollens into the respiratory system and also appear to have a synergistic action with pollens increasing their allergenicity. 75,76 Inhalation of diesel exhaust at environmentally relevant concentrations has been shown to augment allergen-induced allergic inflammation in the lower airways of atopic individuals.77

Summary

The health impacts and associated costings examined in the cost benefit analysis are likely to be significantly underestimated. The risks for established cardiovascular and cancer related impacts are trending up as newer evidence emerges.

Additional to this are the many emerging health impacts. Collectively they sign post to far greater impacts and costs than those reflected in this discussion paper. Reducing public exposure to vehicle emissions in Australia is critical to public health and economy and should be at the forefront of decisions made by policy makers.

! !

Page!17!

References

!

1 Barnett A. (2014) ‘It’s safe to say there is no safe level of air pollution’. Australian and New Zealand Journal of Public Health. 2014; 38:5: 407-408

2 Health Effects Institute (2017), ‘State of Global Air 2017’ (online database), www.stateofglobalair.org. (Accessed 08/03/2017) PM+ Ozone mortality: Australia - 3430 deaths (2015 global burden of disease x $A5.2M the 2010 value of statistical life)

3 Bureau of Infrastructure, Transport and Regional Economics (2017), ‘Australian Road Deaths Database’ (online database), https://bitre.gov.au/statistics/safety/fatal_road_crash_database.aspx (Accessed 08/03/2017)

4 OECD 2014. The Cost of Air Pollution: Health Impacts of Road Transport, Brussels, 21 May 2014. http://www.oecd.org/env/the-cost-of-air-pollution-9789264210448-en.htm PM+ Ozone mortality: Australia - 1483 deaths (2010 global burden of disease x $A5.2M the 2010 value of statistical life)

5 World Bank and Institute for Health Metrics and Evaluation (2016), ‘The Cost of Air Pollution: Strengthening the Economic Case for Action’. Washington, DC, https://openknowledge.worldbank.org/bitstream/handle/10986/25013/108141.pdf: Table B1, Page 92 (using the current exchange rate of 1 AUD = 0.752605 USD as a reasonable estimate of the historical average)

6 Torén, K., Bergdahl, I.A., Nilsson, T. and Järvholm, B., (2007), ‘Occupational exposure to particulate air pollution and mortality due to ischaemic heart disease and cerebrovascular disease’. Occupational and environmental medicine, 64(8), pp.515-519.

7 Lai, C.H., Liou, S.H., Lin, H.C., Shih, T.S., Tsai, P.J., Chen, J.S., Yang, T., Jaakkola, J.J.K. and Strickland, P.T., (2005), ‘Exposure to traffic exhausts and oxidative DNA damage’. Occupational and environmental medicine, 62(4), pp.216-222.

8 OHSIntros (2015), ‘30 years of OHS in Victoria 1985-2015: Is it time for a celebration?’ http://www.ohsrep.org.au/__data/assets/pdf_file/0018/171126/30th-anniversary-of-Victorian-OHS-system-2015.pdf

9 https://www.epa.gov/sites/production/files/2015-09/documents/tier3.pdf

10 Zereini, F., & Wiseman, C. (2010). Urban airborne particulate matter origin, chemistry, fate and health impacts. Heidelberg ; New York: Springer Verlag.

11 P. Kumar, P. Fennell, R. Britter, (2008), ‘Effect of wind direction and speed on the dispersion of nucleation and accumulation mode particles in an urban street canyon’. Sci Total Environ, 402 (2008), pp. 82–94


Page!18!

!12 Oberdorster G, Oberdorster E, Oberdorster J. (2005), ‘Nanotoxicology: An emerging

discipline evolving from studies of ultrafine particles’. Environmental Health Perspectives. 2005;Vol. 113, No. 7 pp. 823-839

13 P. Kumar, A. Robins, H. ApSimon, (2010), ‘Nanoparticle emissions from biofuelled vehicles — their characteristics and impact on the number-based regulation of atmospheric particles’. Atmos Sci Lett, 11 (2010), pp. 327–331

14 http://www.abs.gov.au/ausstats/[email protected]/mf/9309.0

15 P. Paasonen, A. Visshedjik, K. Kupiainen, Z. Klimont, H.D. van der Gon, M. Kulmala, et al. (2013), ‘Aerosol particle number emissions and size distributions: implementation in the GAINS model and initial results’. IIASA interim report (2013)

16 http://envirojustice.org.au/major-reports/clearing-the-air-why-australia-urgently-needs-effectivenational-air-pollution-laws

17 Barnett A. (2014) ‘It’s safe to say there is no safe level of air pollution’. Australian and New Zealand Journal of Public Health. 2014; 38:5: 407-408

18 http://www.npi.gov.au/

19 Williams R, Knibbs L. (2016) ‘Daily personal exposure to black carbon: A pilot study’. Atmospheric Environment, May 2016, Vol.132, pp.296-299

20 Mazaheri, Mandana ; Clifford, Sam ; Jayaratne, Rohan ; Megat Mokhtar, Megat Azman ; Fuoco, Fernanda ; Buonanno, Giorgio ; Morawska, Lidia (2014), ‘School children's personal exposure to ultrafine particles in the urban environment’. Environmental science & technology, 2014, Vol. 48(1), pp.113-20

21 CARS21: Cars21 High level group on the competitiveness and sustainable growth of the automotive industry in the European Union. Final report, 6 June 2012. 2012. http://ec.europa.eu/enterprise/sectors/automotive/files/cars-21-final-report-2012_en.pdf

22 Cames M, Helmers E. Critical evaluation of the European diesel car boom – global comparison, environmental effects and various national strategies. Environmental Sciences Europe. 2013, 25:15 http://www.enveurope.com/content/25/1/15

23 www.publications.parliament.uk/pa/cm201012/cmselect/cmenvaud/1024/102408.htm

24 Skamp K, Bergmann I, Taplin R, et al. (2007), ‘A Review of Air Quality Education’. Australian Research Institute in Education for Sustainability; Sydney. 2007

25 Williams R, Knibbs L. (2016). ‘Daily personal exposure to black carbon: A pilot study’. Atmospheric Environment, May 2016, Vol.132, pp.296-299

26 ‘Report: Impacts on health of air quality in Australia’. 2013. Chapter 5, pg 49

27 ‘Clean Air. Less Cancer. Working towards a National Clean Air Agreement’. Peter MacCallum Cancer Centre, Lung Foundation Australia. 2015

! !

Page!19!

!28 http://www.aignertunnel.com/upload/content/Referenzen/

aigner_tunnel_referenz_madrid.pdf

29 Goldsworthy, L and Galbally, IE. (2011) ‘Ship engine exhaust emissions in waters around Australia - an overview’. Air Quality and Climate Change, Vol. 45, No. 4, Nov 2011: 24-32

30 Broome, R. A. et al. (2016), ‘Environment International’. Environment International 87, 85–93 (2016).

31 Jones AM, Harrison RM, Barratt B, Fuller, G. (2012), ‘A large reduction in airborne particle number concentrations at the time of the introduction of ‘sulphur free’ diesel and the London Low Emission Zone’. Atmos Environ, 2012; 50:129–38.

32 Atkinson RW, Fuller GW, Anderson HR, Harrison RM, Armstrong B. (2010), ‘Urban ambient particle metrics and health: a time-series analysis’. Epidemiology 2010; 21:501–11.

33 Hedley AJ, Wong CM, Thach TQ et al. (2002), ‘Cardiorespiratory and all-cause mortality after restrictions on sulphur content of fuel in Hong Kong: an intervention study’. Lancet 2002; 360:1646–52.

34 M.E.J. Stettler, S. Eastham, S.R.H. Barrett (2011) ‘Air quality and public health impacts of UK airports. Part I: Emissions’. Atmospheric Environment. V. 45, 5415-5424

35 S.H.L. Yim, M.E.J. Stettler, S.R.H. Barrett (2013) ‘Air quality and public health impacts of UK airports. Part II: Impacts and policy assessment’. Atmospheric Environment. V. 67, pp. 184-192.

36 https://www.gpo.gov/fdsys/pkg/FR-2014-04-28/pdf/2014-06954.pdf, accessed 10th March, 2017

37 OECD (2014). ‘The Cost of Air Pollution: Health Impacts of Road Transport’. Brussels, 21 May 2014. http://www.oecd.org/env/the-cost-of-air-pollution-9789264210448-en.htm

38 Committee on the Medical Effects of Air Pollutants, (2010). ‘The mortality effects of long-term exposure to particulate air pollution in the United Kingdom’. London: Health Protection Agency, 2010. www.gov.uk/government/publications/comeap-mortality-effects-of-long-term-exposure-to-particulate-air-pollutionin-the-uk

39 Committee on the Medical Effects of Air Pollutants, (2015). ‘Nitrogen dioxide: interim view on long-term average concentrations and mortality’. London: Health Protection Agency, 2015.

40 Begg S, Vos T, Barker B, et al. (2007). ‘The burden of disease and injury in Australia 2003’. Australian Institute of Health and Welfare, Cat. no. PHE 82, Canberra (2007), p234

41 http://www.environment.gov.au/science/soe/2011-inbrief/atmosphere


Page!20!

!42 Liuhua Shi, Antonella Zanobetti, Itai Kloog, Brent A. Coull, Petros Koutrakis, Steven J.

Melly, Joel D. Schwartz. (2015) ‘Low-Concentration PM2.5 and Mortality: Estimating Acute and Chronic Effects in a Population-Based Study’. Environmental Health Perspectives, 2015; DOI: 10.1289/ehp.1409111

43 Miller K, Siscovick D, Sheppard L, Shepherd K, Sullivan J, et al. (2007) ‘Long-Term Exposure to Air Pollution and Incidence of Cardiovascular Events in Women’. N Engl J Med 2007; 356:447-458

44 Feigin, Valery L., et al. (2016), "Global burden of stroke and risk factors in 188 countries, during 1990–2013: a systematic analysis for the Global Burden of Disease Study 2013." The Lancet Neurology 15.9 (2016): 913-924.

45 https://canceraustralia.gov.au/affected-cancer/cancer-statistics

46 Thun MJ, Hannan LM, Adams- Campbell LL et al. (2008), ‘Lung canceroccurrence in neversmokers: an analysis of 13 cohorts and 22 cancer registry studies’. PLoS Med 2008; 5: e185.

47 Begg S, Vos T, Barker B, et al. (2007), ‘The burden of disease and injury in Australia 2003’, Australian Institute of Health and Welfare, Cat. no. PHE 82, Canberra (2007), p234

48 Gabrielson E. (2006), ‘Worldwide trends in lung cancer pathology’. Respirology 2006; 11:533-38

49 Couraud S1, Zalcman G, Milleron B, Morin F, Souquet PJ. (2012), ‘Lung cancer in never smokers--a review’. Eur J Cancer. 2012 Jun;48(9):1299-311. doi: 10.1016/j.ejca.2012.03.007. Epub 2012 Mar 28.

50 Pope III CA, Burnett RT, Thun MJ, et al.(2002), ‘Lung cancer, cardiopulmonary mortality, and long-term exposure to fine particulate air pollution’. JAMA 2002; 287:1132-41

51 Raaschou-Nielsen O, Andersen Z.J, Beelen R, et al. (2013), ‘Air pollution and lung cancer incidence in 17 European cohorts: prospective analyses from the European Study of Cohorts for Air Pollution Effects (ESCAPE)’. Lancet 2013; 14:813-822

52 Hamra GB, Guha N, Cohen A, et al. (2014). ‘Outdoor Particulate Matter Exposure and Lung Cancer: A Systematic Review and Meta-Analysis’. Environmental Health Perspectives 2014; 122:906-91

53 Silverman D, Samanic C, Lubin J, Blair A, Stewart P, et al. (2012) ‘The Diesel Exhaust in Miners study: a nested case-control study of lung cancer and diesel exhaust’. J Natl Cancer Inst. 2012 Jun 6;104(11):855-68. doi: 10.1093/jnci/djs034. Epub 2012 Mar 5.

54 Attfield MD, Schleiff PL, Lubin JH, et al. (2012). ‘The diesel exhaust in miners study: a cohort mortality study with emphasis on lung cancer’. J Natl Cancer Inst 2012; 104:869-83

55 http://www.cancer.gov/newscenter/newsfromnci/2012/DieselMinersQandA

! !

Page!21!

!56 Somers CM. (2011), ‘Ambient air pollution exposure and damage to male gametes; human

studies and in situ ‘sentinel’ animal experiments’. Syst Biol Reprod Med 2011; 57:63-71

57 McConnell R, Berhane K, Yao L, Jerrett M, Lurmann F, et al. (2006), ‘Traffic, susceptibility and Childhood asthma’. Environmental Health Perspectives Vol. 114, No. 5 (May, 2006), pp. 766-772

58 Royal College of Physicians, Royal College of Pediatrics and Child Health. 2016. ‘Every breath we take: The lifelong impact of air pollution’.

59 Chen Z, Salam MT, Eckel SP, Breton CV, Gilliland FD. (2015), ‘Chronic effects of air pollution on respiratory health in Southern California children: findings from the Southern California Children’s Health Study’. J Thorac Dis 2015;7:46–58

60 Over the past two decades, the Californian EPA has instigated a range of policies and worlds best practice measures to improve the air quality and reduce children’s exposure to near road pollution.ref

61 Gauderman WJ, Urman R, Avol E, et al. (2015). ‘Association of improved air quality with lung development in children’. NEJM 2015;372;10:905-913

62 Georgiopoulou VV, Kalogeropoulos Ap, Psaty BM, et al. (2011) ‘Lung function and risk for heart failure amoung older adults: the Health ABC Study’. Am J Med 2011;124:334-41

63 Sin DD, Wu L, Man SF. (2005), ‘The relationship between reduced lung function and cardiovascular mortality: a population based study and a systematic review of the literature’. Chest 2005;127: 1952-9

64 Mazaheri, Mandana, Clifford, Sam, Jayaratne, Rohan, Mokhtar, Megat, Fuoco, Fernanda, Buonanno, Giorgio, & Morawska, Lidia (2014) ‘School children’s personal exposure to ultrafine particles in the urban environment’. Environmental Science & Technology (including News & Research Notes), 48(1), pp. 113-120

65 Australian Atlas of Healthcare Variation. Chapter 6.4 https://www.safetyandquality.gov.au/wp-content/uploads/2015/11/SAQ201_07_Chapter6_v7_FILM_tagged_merged_6-4.pdf

66 Jiang R, Jones MJ, Sava F, Kobor MS, Carlsten C. (2014), ‘Short-term diesel exhaust inhalation in a controlled human crossover study is associated with changes in DNA methylation of circulating mononuclear cells in asthmatics’. Part Fibre Toxicol 2014;11:71. 28

67 Janssen BG, Godderis L, Pieters N et al. (2014), ‘Placental DNA hypomethylation in association with particulate air pollution in early life’. Part Fibre Toxicol 2013;10:22.

68 Malley C, Kuylenstierna J, Vallack H, Henze D, Blencowe H, Ashmore M. (in press) ‘Preterm birth associated with maternal fine particulate matter exposure: A global, regional and national assessment’ Environment International 2017


Page!22!

!69 Ha S, Hu H, Roussos-Ross D et al. (2014) ‘The effects of air pollution on adverse birth

outcomes’. Environ Res 2014;134: 198–204

70 Risnes KR, Vatten LJ, Baker JL et al. (2011) ‘Birthweight and mortality in adulthood: a systematic review and meta-analysis’. Int J Epidemiol 2011; 40: 647–61.

71 Canfield RL, Henderson CR Jr, Cory-Slechta DA et al. (2003), ‘Intellectual impairment in children with blood lead concentrations below 10 microg per deciliter’. New Engl J Med 2003; 348: 1517–26

72 MacIntyre EA, Gehring U, Mölter A et al. (2014) ‘Air pollution and respiratory infections during early childhood: an analysis of 10 European birth cohorts within the ESCAPE Project’. Environ Health Perspect 2014; 122: 107–13.

73 Loomis D, Grosse Y, Lauby-Secretan B, et al. (2013). ‘The carcinogenicity of outdoor air pollution’. Lancet Oncol 14: 1262-1263

74 Brandt EB, Myers JM, Ryan PH, et al. (2015), ‘Air pollution and allergic diseases’. Curr Opin Pediatr 2015;27(6):724-35.

75 Ghiani A, Aina R, Asero R, et al. (2012), ‘Ragweed pollen collected along high-traffic roads shows a higher allergenicity than pollen sampled in vegetated areas’. Allergy 2012; 67: 887–94.

76 Motta AC, Marliere M, Peltre G, et al. (2006), ‘Traffic-related air pollutants induce the release of allergen-containing cytoplasmic granules from grass pollen’. Int Arch Allergy Immunol 2006;139:294–8

77 Carlsten C, Blomberg A, Pui M, et al. (2016), Thorax 2016;71:35–44.

submission on the “better fuel fo r cleaner air” discussion paper · 2018. 11. 21. ·...

Documents