Tuesday 31 March 2015

Volume III - E. Environmental Criteria - continued

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III  AIR POLLUTION

1. DESCRIPTION OF AIR POLLUTION

1.1 Definition of Air Pollution

In every day life we are conscious of the air
we breathe. We are conscious of odours, fumes
smoke and dust. We are also conscious of invisible
substances suspended in the air we breathe which
makes 'city air’ very different from 'country air'.
As urban dwellers, we have all had the experience
of breathing country air deeply, and exclaiming
that in some mysterious way it was ‘different' and
‘better'.

Are we deluding ourselves? Is there such a thing
as "fresh air”? If we are not mistaken in
perceiving a difference between 'city air' and
'country air' or between 'polluted air’ and 'fresh
air', what is the explanation? To what extent do
motor vehicles contribute to that pollution? What
measures can be taken to minimise air pollution?
Is the construction of any one of the options
consistent or inconsistent with the stated objective
of "improving air quality" (76).

1.2 'Normal Clean Air'

Air pollution can be defined "as the act of causing
air to contain concentrations of foreign matter in
excess of ‘normal values’ (77). What are normal
values? ‘Normal clean air’ is a mixture of gasses
estimated to consist of:-
  • nitrogen           78.09%
  • oxygen              20.9%
  • argon               0.93%
  • carbon dioxide      0.03%
  • other gases less than 0.01%

76. Joint Study Report, page 7.
77. Professor Morris B. Jacobs, Associate Professor
    of Occupational Medicine, Columbia University
    quoted in the Fifth Report of the Royal
    Commission on Petroleum, page 552.

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The other gases include:-
  •  nitrous oxide
  • nitrogen dioxide
  • ozone
Water vapour is also present in 'normal air' and
varies from 1-3% of the total volume.

There are also certain natural pollutants such as
sea salt, dust, pollens, bacteria and even smoke.

As a by-product of 'civilisation', there are a
number of man-made pollutants and these include
pollutants emitted from motor vehicles.

1.3 Classification of Pollutants

Our concern is with man-made pollutants. They may
be classified as either primary or secondary
pollutants.

Primary pollutants are particles or gases emitted
directly into the atmosphere. Having been emitted,
they chemically react with one another in some
circumstances to form secondary pollutants. The most
common and notorious secondary pollutant is photo-
chemical smog.

1.4 Primary Pollutants

Primary pollutants may be either visible or invisible.
The term embraces gases and particles which are
traditionally seen as polluting the atmosphere: smoke,
soot, fumes and various odours. They have a direct
impact upon the area where they are released.
The ‘air’ in an industrial suburb 'feels' and smells
different to that of a residential area with abundant
trees.

In addition, there are a number of invisible primary
pollutants including:-

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  • carbon monoxide
  • nitrogen oxides
  • hydrocarbons
  • lead compounds
Pollutants will either remain localised or will
disperse according to the weather and wind conditions.
They may also be redistributed by traffic itself (78):-

"Traffic disturbs and recirculates
particulates (i.e., heavy particles)
and in doing so produces concentrations
of these sorts of pollutants in excess
of the proportions emitted from
original sources. Heavily trafficked
areas such as South Sydney and
Alexandria are particularly affected
by this mechanism."

On winter mornings Sydney is often shrouded by a
brown haze. This is widely believed to be photochemical
smog. It is the subject of investigation by the
Commonwealth scientific and Industrial Research
Organisation at the present time (79). Whatever its
precise chemical composition, primary pollutants are
directly involved. The following appears in the
S.P.C.C. Annual Report, 1979:- (80)

"The occurrence of high oxides of
nitrogen values on clear winter
nights is due to meteorological
factors. Low wind speeds within
low level temperature inversions
are conducive to the build-up
of primary pollutants, including
oxides of nitrogen, hydrocarbons
and particulates, which contribute
to the grey to brown haze seen
in Sydney on winter mornings."

78. C.I.A. Air Pollution Study, page 6.
79. S.P.C.C. Annual Report 1979, page 103.
80. S.P.C.C. Annual Report 1979, page 116.

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1.5 Photochemical Smog

Primary pollutants are released into the
atmosphere from various sources. Once released,
they may remain chemically inert or they may
react with other pollutants. Photochemical smog
is the product of such a reaction. It is a
chemical transformation of two pollutants,
nitrogen oxides and hydrocarbons, which occurs in
the presence of sunlight.

Ozone is the major constituent (approximately 90%)
of photochemical smog (81). Concentrations of
ozone are used, therefore, to indicate the
severity of 'smog'. Quite often the terms
'photochemical smog' and 'ozone' are used
interchangeably even though there are many other
chemicals, some more toxic than ozone, present in
photochemical smog (82).

1.6 The Vulnerability of Sydney to Photochemical Smog

Sydney is especially vulnerable to photochemical
smog. Its vulnerability arises from:-
  • its climate
  • the phenomenon of temperature inversion
  • its topography
  • the pattern of its winds
Sydney is fortunate to have a sunny climate.
That sunshine however aids the process of photo-
chemical smog formation.

Sydney experiences the phenomenon of temperature
inversion. It occurs when the air near the ground
is cooler than the air above. The ground is heated
by the sun. It gives off warmth to the surrounding
air. The warm air rises and in the process convection

81. Cooks River Environment Survey and Landscape
    Design, page 34.
82. An Assessment of Photochemical Smog in the
    Sydney Region, S.P.C.C., page 7.

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currents are formed. The air near the ground is
replaced by air drawn from higher altitudes.

In the ordinary course pollutants emitted at ground
level are dispersed and diluted with clean air.
Winds are generally faster at greater heights. The
convection currents aid the process of cleansing
the atmosphere by bringing the faster upper winds
back to ground level.

At night the ground becomes cooler than the
surrounding air. It cools the lower layers of air.
The lower layers of air can become colder than the
upper layers. The cold air near the ground is then
heavier than the hot air above, and convection currents
are stopped. Wind speeds near the ground are generally
very low. This process is called temperature inversion.

The inversion is broken when the ground is warmed
by the sun the following day. Convection currents
then begin to form and the process of mixing the
upper and lower layers of air can begin again.
Inversions occur "almost every night in winter and
almost 50% of nights in summer" (83). When they occur
pollutants may be trapped, and the natural process of
cleaning and renewing the city's air is impeded.

The topography of Sydney also operates to inhibit
wind speeds. Sydney is surrounded by hills on three
sides. In the North and South the hills are
approximately 150 metres high and in the west 700
metres high (83). In consequence pollutants are not
moved quickly across the Sydney basin, and winds are
often not strong enough to break up the temperature
inversions which themselves operate to inhibit wind
speeds.

83. Cooks River Environment Survey and Landscape
    Design, page 33.

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The pattern and direction of winds can aid the
process of photochemical smog formation (84).

"The concentrations of precursors and
of resultant photochemical smog are
greatly dependent on weather conditions.
Windy weather will disperse these
pollutants, diluting them in the process.
Heavily overcast conditions reduce the
amount of sunlight available and thereby
slows the photochemical reaction. On the
other hand, prolonged periods of sunny
weather and low wind speeds will permit
accumulation of the precursors and their
photochemical products. A smog "episode"
can then occur. It is also possible for
changing wind directions to recirculate
photochemical smog back into the Sydney
basin on the following day. The polluted
air will thus receive sun irradiation over
two days, enhancing its ability to attain
high-ozone levels."

The Urban Transport Study Group in its examination
of air pollution in the Central Industrial Area,
described a wind typical in Sydney:-

"One common wind pattern is described as:
air moving from the coast, passing above
both the City and the Central Industrial
Area regions, collecting NOX (nitrogen
oxides) and NMHC (Non-Methane Hydrocarbons)
air masses and then continuing in a south-
west direction towards the Campbelltown
region."

2. CAUSES OF AIR POLLUTION

2.l Classification of Pollutants

It is again necessary to distinguish between primary
and secondary pollutants. The source of primary
pollutants can be traced and the problem confronted
once the cause is known.

With the secondary pollutant, photochemical smog,
the quest is no different. We know that photochemical
smog is the product of a chemical reaction between
nitrogen oxides and hydrocarbons. The question

84. An Assessment of Photochemical Smog in the
    Sydney Region, S.P.C.C., Page 12.

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becomes, therefore, what are the sources of nitrogen
oxides on the one hand, and, of hydrocarbons on the
other.

2.2 Is the Motor Vehicle to Blame for Air Pollution?

Although, on any view, the motor vehicle plays a
significant part in the production of the primary
pollutants, it would be wrong to give the impression that
it is wholly to blame. There are three main sources
of air pollution:-
  •  motor vehicles
  • industry
  • combustion of fuels
The impact of each will very much depend upon the area.
Naturally, industrial processes within an industrial
area make a contribution to air quality. An important
traffic corridor will likewise make a significant
contribution. Regrettably, there are areas (for instance
the Central Industrial Area) with concentrations of
both industry and traffic.

The Sydney Area Transportation Study (85) provided an
estimate of the contribution made by motor vehicles to
the pollutants circulating in Sydney. The estimate
was: -
  • 90% responsibility for carbon monoxide
  • 65% responsibility for non-methane
    hydrocarbons
  • 65% responsibility for nitrogen oxides
    emitted into the atmosphere

Accordingly, the motor vehicle was seen as being
primarily responsible for photochemical smog.

85. SATS Volume 2, Chapter IV, page 19.

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The matter was examined by the Royal Commission on
Petroleum. Its figures do not differ materially
from those in the Sydney Area Transportation Study.
It thought that motor vehicles were responsible for
55% of nitrogen oxides rather than 65%.

The Urban Transport Study Group examined the
problem in the context of the Central Industrial Area.
Within that area, it saw the contribution of
motor vehicles to ‘smog-causing gases' as being
approximately 43% (86).

The most authoritative and recent statement is that
by the S.P.C.C. in the publication "An Assessment
of Photochemical Smog in the Sydney Region
" (12th
May, 1980). The publication summarises the views
of the Sydney Oxidant Study Group (a group examining
the problem of photochemical smog for some years).
The publication includes a table which identifies
the respective contributions from various sources.
It estimates the likely contribution from various
sources in 1985 after certain controls have been
introduced.

86. UTSG "Central Area Industrial Study" Chapter
    4 (findings), page 30.

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TABLE 9.
Emissions of Hydrocarbons in the Sydney Region
(After allowing for controls gazetted for introduction
in 1981 and 1982)




2.3 Factors Affecting the Production of Pollutants

First, the contribution made by cars is different
to that made by trucks. Secondly, it is necessary
to distinguish between operating conditions.
The pollutants emitted whilst idling are different
from those emitted whilst accelerating, or cruising,
and different again from those emitted upon
deceleration.

Reproduced below is a table taken from an English
publication. The technology, in terms of exhaust
control, is different overseas, in some case, to
that available in Australia (87).

87. See Occasional Paper 30, Bureau of Transport
    Economics "Vehicle Driving Patterns and
    Measurement Methods for Energy and Emissions
    Assessment” by Dr H.C. Watson, 1978

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It is a very general guide to the respective
contributions of petrol engines and diesel engines
under various operating conditions.

TABLE 10.

REPRESENTATIVE COMPOSITION OF EXHAUST GASES
PARTS/MILLION BY VOLUME



Source: Watkins L.H., "Urban Transport and
        Environmental Pollution" T.R.R.L. Report
        LR455, 1972, Crowthorne, U.K.

Thirdly, it is necessary to identify the source of the
particular air pollutants. Once identified, the task of
finding an appropriate 'cure' can begin. Hydrocarbons are
important because of the part they play as a precursor
to photochemical smog. The sources have been identified
as:-

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-        60% originating from the engine exhaust
-        20% originating from the crank case
-       
20% originating from evaporation of
   petrol in the carburettor and fuel tank.

Carbon monoxide, nitrogen oxides and lead, on the
other hand, originate exclusively from the exhaust.

Fourthly, certain primary pollutants are exclusively
or predominantly produced by one sort of engine
rather than another. Carbon monoxide (over 90%) is
emitted from the exhaust of petrol-driven motor
vehicles. Likewise, lead emissions are almost
exclusively the product of the petrol-driven motor
vehicle because of lead additives in petrol itself.
Lead in petrol has excited a good deal of public comment.
It was the subject of many submissions to the present
Inquiry. Because of its public importance, it will be
addressed separately below.

Nitrogen oxides are emitted by both petrol-driven
engines and diesel engines. Once emitted nitric oxides
change slowly to nitrogen dioxide in the atmosphere.
Nitrogen dioxide is itself a pollutant. It has an
important role, moreover, in combination with hydrocarbons,
in producing photochemical smog.

Finally, the state of repair or disrepair of the
vehicle can play an important part in determining the
extent of pollution emissions. Diesel engines, can
emit ten times as much smoke and particulate pollution
than a motor car (especially if not properly maintained,
and more especially when operating under high load
conditions). These are the fumes and smoke which
give trucks a bad name in the community. Certainly
they are obnoxious, though surprisingly they may be the
least harmful of all vehicle emissions.

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3. THE DEGREE OF EXPOSURE

3.1 The Relevant Variables

The effects of air pollution will depend upon:-
  • concentrations which occur
  • the duration of exposure
  • the sensitivity of the individual
  • the nature of the pollutants

3.2 The Concentration of Pollutants

In the context of traffic, the concentration of
pollutants will be subject to:-
  • the traffic volume
  • the average vehicle speed
  • the percentage of heavy vehicles
  • the amount of pollutants emitted from
    each vehicle
  • the atmospheric conditions prevailing
    at the time
3.3 Dispersion of Pollutants

Nor does the matter end there. The concentration
of air pollutants will also depend upon the extent
to which they are then dispersed. That in turn
depends first, upon the extent to which the area
might be described as turbulent so that there is
a mixing of atmospheric conditions and, secondly,
the direction and strength of the prevailing
winds.

Certain experiments have been conducted by the
Urban Motorways Project Team in the United Kingdom.
These suggested that traffic-induced smoke
concentrations in the atmosphere dispersed very
quickly. The statistics were:-
  • traffic-induced smoke fell by roughly
    25% ten metres from the source;
  • by 50% twenty metres away;
  • concentrations at fifty metres were
    negligible;
  • concentrations at sixty metres were
    too low to measure.

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The experiment also suggested that lead in the
air followed a similar pattern “with levels falling
to background levels within a distance of one-
hundred-two hundred metres" (88).

3.4 The Influence of Topography

Topography obviously plays an important part in wind
patterns. One side of a hill may be sheltered. The
other side may be buffeted by the prevailing winds.

The topography may even be man-made. The Sydney
Area Transportation Study
, made the following comment
in relation to the Central Business District and its
‘topography':- (89)

"...In some areas, such as the Central
Business District, where "canyon effect"
of tall buildings tends to slow the
dispersion of pollutants, restriction
of vehicle access should be considered.”

It was said by many people to this Inquiry that the
particular and peculiar features of the Cooks River
Valley and the Wolli Creek Valley are important in
the context of pollution. The Community Resources
Centre at Bardwell park, in its submission, made a
comment which is typical of many submissions:- (90)

"The Wolli Creek and the Cooks River
act as funnels for pollution which is
moved about by wind. On calm days,
the smog will build up in the valley,
increasing asthma attacks and respiratory
ailments.”

Mr. Arnett on behalf of the Marrickville Municipal
Council made the following observation:- (91)

88. Report of Urban Motorways Project Team, page 62.
89. S.A.T.S., Volume 3, Chapter II, page 10.
90. Community Resources Centre submission S.K/C 950.
91. Transcript 3rd October, 1979, page 42.

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"ARNETT: I would like to draw attention
to...the particular nature of the Cooks
River Valley itself. Its a basin and it
is an unusual basin...Most river systems
widen as (they) proceed towards (their)
conclusion. The Cooks River System is
constricted into two quite distinct
systems or two quite distinct hills or
cliff systems. Undercliffe gets its name
from the location. It was a very...narrow
constricting of the valley formation
between Illawarra Road and Bayview Avenue.
This.. (particularly with) the westerly
winds system which prevails in the area
in the wintertime, would have the effect
of (creating) an air pollution reservoir,
in that the pollution, if it was a
relatively still day with only gentle
breezes, will be forced into this location
and could have lengthy periods (with
inversion) of one day or two days. You
would have quite a high concentration of
air pollution at the eastern end of the
valley and I would submit that that is
a factor which should be closely looked
at in the consideration of a road proposal
because (the road) itself will be a
concentrator of traffic in that location."

In the Wolli Creek Valley it was said that the geographic
and climatic features would accentuate air pollution
introduced into the valley. Mr. Colin Taylor, a
resident of Turrella, gave the following evidence:- (92)

"TAYLOR: The valley tends to run generally
east-west. In winter, when there is not
a great deal of wind, one always finds a
smoke pall hanging in the valley from
domestic fires. Not an objectionable one.
Just a wood-smoke pall. Not a strong one.
When there are fogs, I have known it to
take to well after mid-day for the fog to
clear, when the surrounding area has been
cleared by 8.30, 9.00."

3.5 The Sensitivity of the Individual

The effects of air pollution will depend in part upon
the sensitivity of the individual.

92. Transcript 26th November, 1979, page 22.

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This is likely to depend, to a large extent, upon
his or her genetic make-up. Certain groups are
vulnerable. In an article entitled "Health Effects
of Urban Pollution
" recently published (September,
1979) in the Journal of the American Medical Association,
the authors state:- (93)

"Susceptibility to the adverse effects
of Urban Air pollution is greatest
among premature infants, the new born,
the elderly, the infirm, those of chronic
lung and heart diseases, certain
asthmatic persons, and those who
habitually inhale tobacco smoke”

3.6 Local and Regional Significance of Pollutants

Some pollutants are more toxic than others. Some
(carbon monoxide, lead compounds) have local
significance. Their effect will be confined to those
persons in the near vicinity of the source.

Other pollutants are of regional significance.
Photochemical smog, once formed, can be transported
many miles. Particular areas, remote from the source,
may be subjected to the outpourings of some other
area, simply because they lie in the path of the
prevailing winds. The S.P.C.C. in the context of Sydney,
makes the following statement:- (94)

"The westerly drainage flow down the
Liverpool and Parramatta Valleys in the
morning and the opposing sea breeze in
the early afternoon cause the central,
southern and western parts of Sydney to
experience the highest concentrations of
ozone
. Ozone is carried with the seabreeze
to Wentworthville, Warwick Farm, Campbelltown
and beyond. The most significant source regions
now are the Parramatta River Valley, the central
business district and the Botany Bay Region.
Increasing development in the western and south-
western suburbs will make these areas important
source regions as well as receptor regions.”

93. "Health Effects of Urban Air Pollution" Roger
    S. Mitchell and Others, J.A.M.A. (September 14,
    1979), Volume 242, No. 11.
94. S.P.C.C. "An Assessment of Photochemical Smog in
    the Sydney Region”, 1980, page 12.

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We will separately deal with the effects of
exposure to each of the pollutants for which the
motor vehicle is responsible, or for which it
shares responsibility.

3.7 Land Uses Exposed to Air Pollution

The distinction between local and regional
pollutants is important when considering the effect
upon various land uses.

Regional pollutants, by their nature, are widespread.
The path of regional pollutants (determined by
prevailing wind conditions), should arguably
influence land use planning. Major developments
should not be planned in areas which are continually
exposed to heavy concentrations of photochemical
smog.

Land uses exposed to localised pollution must also
be considered. Care should be taken to ensure that
land exposed to concentrations of air pollution are
not sensitive to pollution. Certain land uses are
more sensitive to pollution than others, such
as schools, hospitals and residential areas (as
opposed to industrial areas). When considering the
road options it is necessary to examine the nature
of the pollutants, whether regional or local.
Sensitivity to pollution, may suggest some other
path should be chosen.

4. COMMUNITY CONCERN WITH AIR POLLUTION

4.1 Introduction

The Industrial Revolution brought a great many
benefits. People were immediately conscious of
those benefits. They were also conscious of the
dirt and grime. Charles Dickens immortalized that
consciousness and the community’s concern. It
would be wrong, therefore, to suggest that the
community has only recently begun to concern itself
with air pollution. What is recent, is the

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universality of that concern, and the fact that
it is now vocalized. Perhaps this is simply a
manifestation of the community's perception that
the problem is growing.

4.2 Previous Manifestations of Public Concern

The Sydney Area Transportation Study (95) made the
following bold statement:-

"The most significant environmental
and sociological aspect of transportation
systems, is the impact that motor
vehicles have on the quality of air."

They recognised the community's concern with the
problem of air pollution and they endeavoured,
according to their lights, to deal with it.

The Urban Transport Study Group, in its investigation
of the Central Industrial Area (96), conducted a
number of interviews, and carried out research aimed
at identifying problems of concern to the community.
Air pollution was one such problem.

The Planning and Environment Commission undertook
research in the Botany Sub Region to determine the
issues important to residents within that region.
A questionnaire was distributed and surveys were
conducted. In all cases, air pollution was identified
as the most significant aspect of the environment (97).

In December, 1977 the State Pollution Control
Commission commenced the operation of its pollution

95. S.A.T.S., Volume 2, Chapter 4, page 19.
96. Central Industrial Area Study, 1977.
97. P.E.C. "Planning Report, 1978” "What you Said"
    page 7.

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index. That index has since been adopted by
the media as part of the standard presentation of
weather information. The media is simply
reflecting the interest and concern of the
community with the quality of the air it breathes.

4.3 Submissions to the Inquiry

Almost every submission made to the Inquiry (some
1429) mentioned pollution as a problem which
should be addressed by the Inquiry. It was used
in some cases by those arguing for a particular
option. It was used in other cases by those
arguing against the same option, or against all
options. The validity of these arguments will be
examined elsewhere in this Report. There can be
no doubt, however, that it is a matter of grave
concern to the community.

Is the community mistaken? Does pollution, in one
form or another, affect the health of the persons
subjected to it?

5. THE EFFECTS OF AIR POLLUTION

5.1 Classification of Pollutants

Again it is necessary to distinguish between
different pollutants. They each have different
effects and their effects in combination (as in
the case of photochemical smog) can be different
to their effects in isolation.
The motor vehicle is responsible for the following
pollutants: -
  • dust and dirt
  • carbon monoxide
  • hydrocarbon
  • nitrogen oxides
  • lead compounds

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It is convenient to deal with the effects of
lead compounds separately. We will examine below
the effects of each of the other pollutants as
well as the secondary pollutant, photochemical
smog.

5.2 Exposure to Dust and Dirt

Exhaust emissions include particulate matter
(i.e., heavy particles). In broad terms there are
two categories:-
-        deposited matter such as dust, grit
   and ash
-        and suspended matter such as smoke
   which consists of fine carbonised
   particles.

During low speeds much of the particulate matter
is retained within the exhaust system. It is then
expelled upon acceleration.

The relative differences between diesel engines and
petrol engines have already been the subject of
comment. Diesel engines emit approximately ten
times as much smoke and particulate pollution as
do petrol engines. It is irritating and distressing
to other road users and especially pedestrians. It
is the focus of much complaint. However, it is not
seriously toxic (98).

The importance of this pollutant can be appreciated
from a survey which was conducted in the United
Kingdom after the construction of a motorway
(i.e., an expressway). The motorway passed
through an industrialised town. There was an
expectation on the part of those conducting the
survey that the population would not complain of dust
and dirt because the atmosphere was already heavily
polluted through local industry. They were wrong.

98. Trucks in Suburbs, page 21.

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A great many complaints were made. It appeared
that the road surface acted as a "collecting
platform" for the industrial dirt which was then
re-distributed by the movement of vehicles and
by wind (99).

The design of the highway is important. The
Options each include elevated sections of road.
Experience would suggest that those living below
elevated roadways or bridges would be subjected to
air pollution, and especially dust and dirt (100).
A survey conducted in the United Kingdom by the
Urban Motorways Project Team disclosed that 80%
of respondents to the survey complained that they
were adversely affected by pollution. Within
20 metres of the route the nuisance was felt
severely. The effects diminished to negligible
proportions within about 60 metres of the route.

5.3 The Effects of Carbon Monoxide

It will be remembered that carbon monoxide is
emitted almost exclusively by motor cars (as
opposed to trucks). It is significant as a local
pollutant rather than as a regional pollutant.
Areas subjected to traffic can expect high
concentrations of carbon monoxide.
It is a colourless, odourless gas. Its toxic
effect is related to its affinity with
haemoglobin. Haemoglobin is the oxygen-carrying
component of the blood. This affinity reduces the
blood's ability to carry oxygen to the tissues.

99.  Social Surveys: Technical Paper No. 2,
     Department of Environment, U.K., October,
     1974, page 10.
100. Report of the Urban Motorways Project Team,
     page 62.


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The World Health Organisation has an established
goal for carbon monoxide exposure. It is the
same as that established by the U.S. Environmental
Protection Agency in its air quality standard (1).
The standard is:-
  • 9 ppm for 8 hours
  • 35 ppm for 1 hour
(ppm: parts per million measured by volume)

This standard is not met in various parts of
Sydney. Carbon monoxide has been monitored in the
Queen Victoria Building of Sydney over a number of
years. The results are not encouraging. In the
years 1970, 1971 and 1972 (2) the World Health
Organisation standard was exceeded on 318 days on
average each year. In 1977 (3) the average
reading taken at George Street over the 8-hour day
was 30 ppm (to be contrasted with 9 ppm) and over
1 hour 47 ppm (to be contrasted with the standard
of 35 ppm).

City buildings play a part in trapping pollutants
and preventing dispersal. In tunnels and cuttings
one is sometimes conscious of the air "thickening".
Where winds can disperse the pollutants quickly,
carbon monoxide is unlikely to be damaging.

What health effects attend exposure to excessive
carbon monoxide? Carbon monoxide can have lethal
effects in high concentrations, where there is
prolonged exposure. In the ordinary traffic stream,
one does not encounter concentrations of that kind.
However, carbon monoxide exposure has been reported
as having been responsible for a decrease in motor

1. S.A.T.S., Volume 2, Chapter IV, page 20.
2. S.A.T.S., Volume 3, Chapter X, page 3.
3. Kyeemagh-Chullora Route Study Air Pollution
   Impact Assessment, page 32.

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performance, headache, lassitude and diminution
of visual perception (4). The effects of carbon
monoxide may be more sinister than supposed.
The S.P.C.C. in its publication, "Handbook of
Environmental Control in New South Wales
" (5),
makes the following comment:-

"...Although the clinical research
results have been conflicting, the
postulation that exposure to this
gas (i.e., carbon monoxide) may be
a factor in traffic accidents and
heart disease cannot be ignored.”

The same theme finds expression in the Sydney Area
Transportation Study
where it is stated:- (6)

“...Exposure to carbon monoxide
concentrations in the order of 50
parts-per-million may result in
temporary impairment of judgement
and motor performance - an effect
that is certainly not favourable
to peak driving performance.”

5.4 The Effect of Nitrogen Oxides

There are in fact six nitrogen oxides including:-
  • nitrous oxides (N20)
  •  nitric oxides (NO)
  • nitrogen dioxide (NO2)
In discussions of pollution control, the nitrogen
oxides are generally referred to as Nox.

The nitrogen oxides emitted from motor vehicles
mainly consist of nitric oxide.

The most important effect of nitrogen oxides is
the role they play in the formation of photochemical
smog. The effect of photochemical smog upon health
will be dealt with below.

4. Perris, 1978. Referred to on page 10,
   Kyeemagh-Chullora Route Study Air Pollution
   Impact Statement.
5. S.P.C.C., June, 1975, page 23.
6. S.A.T.S., Volume 1, Chapter III, page 41.

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As primary pollutants, brief exposure to high
concentrations (25 ppm) of nitrogen oxides, or
prolonged exposure to as little as 3 ppm, is
extremely irritating to the small airways and
alveoli (7). The World Health Organisation
standard over one year annual average exposure is
5 pphm.

Distinguishing between the various nitrogen
oxides themselves, nitric oxide has little or no
direct health effect in the concentrations found in
the atmosphere (8) whereas nitrogen dioxide in
concentrations averaging 0.08, 0.15 ppm (annually)
causes "slight increases in respiratory illnesses
and bronchitis morbidity and a slight decrease in
pulmonary function” (8).

5.5 Hydrocarbons

Hydrocarbons in the exhaust are caused by incomplete
combustion of fuel.

There is some controversy as to the effect of
hydrocarbons as primary pollutants. On the one
hand the Planning and Environment Commission in the
Air Pollution Impact Assessment(9) makes the
following statement:-

"Hydrocarbon emissions are not pollutants
of concern by themselves. However, in
conjunction with nitrogen oxides under
strong sunlight conditions, they produce
photochemical smog and oxidants.”

The Health Commission, on the other hand, in its
submission to the Inquiry (10) makes the following
statement:-

7.  Roger S. Mitchell et al "Health Effects of
    Urban Air Pollution", J.A.M.A., Volume 242,
    No. 11, (14.9.79).
8.  Cooks River Road Air and Noise Pollution
    Study, page 8.
9.  P.E.C. "Air Pollution Impact Assessment
    page 9.
10. S.K/C 342, page 6.

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"Several hydrocarbons are known to be
carcinogenic (i.e., cancer producing)...
while reliable epidemiological data on
the link between hydrocarbons emitted
by motor vehicles and (the) incidence
of lung cancer is still unavailable,
the evidence of correlations between
ambient benzpyrene (and other pollutants)
and lung cancer emerging from six
separate studies cited by Harris (1979)
indicates an urgent need for further
research (Open University, 1975, page 25).”

Roger S. Mitchell et al (11) make the following
statement: -

"These chemicals are currently not well-
monitored, and their long term effects
on human health are still poorly under-
stood. "

It may be, therefore, that hydrocarbons, as such, are
damaging to human health. Certainly, as a precursor
to the formation of photochemical smog, they cannot
be ignored.

5.6 The Effects of Photochemical Smog

5.6.1 Introduction

Professor A.J. Haagen-Smit published in 1952 a classic
paper on the formation of the notorious Los Angeles
photochemical smog (12). Some twenty years later in
another journal he wrote about the way in which he
made the discovery:- (13)

"I had just finished isolating and
identifying the odours of the pineapple
when I opened the window and smelled
what we now call 'smog’. I passed the
smoggy air through the cold traps that
had served me faithfully in collecting
the vapours of the fruits. Three hundred
cubic feet of air (equal to the amount of
air we breath everyday) went through the

11. Roger S. Mitchell et al ibid., page 1167.
12. Industrial and Engineering Chemistry, Volume 44,
    1952, pages 1342-6.
13. Quoted in "The War Against Exhaust Pollution"
    R.W. Bilger (Chapter 7, Environmental Problems
    in Australia).


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traps, resulting in a glass filled
with an evil-smelling water! That
dirty glass of water made a deep
impression on me. It was water that
anyone would refuse to drink. Yet we
inhale it, and the lungs are efficient
in assimilating impurity. This glass
of water should have found a place
in the Smithsonian as a warning to
everyone to be careful about what you
breath. "

Sydney has been likened to Los Angeles in both its
sunny climate and its geography (14). Los Anqeles has
been given the undistinguished title of ‘Smog Capital
of the World’. One must lament, as does the State
Pollution Control Commission, that Sydney is not far
behind:- (15)

"Sydney’s experience with photochemical
pollution parallels, in many respects,
experience in Los Angeles and Tokyo.
Peak concentrations in Sydney and Tokyo
are not as high, and high concentrations
there do not occur as frequently as in
Los Angeles during the worst period in
the '60s and the early '70s. Nonetheless,
all three cities record ozone levels that
are higher than elsewhere in the wor1d."

That bitter pill is not sweetened when one learns that
concentrations in Los Angeles and Tokyo are being
reduced because of stringent emission controls, whereas
in Sydney the trend is still “upward” (16).
Four questions arise for consideration:-

  • First, what are the effects of exposure
    to various levels of photochemical smog?
  • Secondly, having regard to those effects,
    what standard should be set for Sydney?

14. S.A.T.S. Volume 3, Chapter X, page 4.
15. S.P.C.C. “An Assessment of Photochemical Smog
    in the Sydney Region”, page 5.
16. S.P.C.C. Annual Report, 1979, page 79. The trend
    may have moderated. It is suggested that any
    improvement is due more to climatic conditions
    than the success of emission control.

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  • Thirdly, how often, at present,
    does Sydney fail to meet that standard?
    How bad is the photochemical smog problem
    in Sydney?
  • Fourthly, what can be done to achieve
    an acceptable standard?

5.6.2 Effects of Smog Upon Health

There can be no doubt that photochemical smog can
adversely affect health. The debate is confined,
first, to whether or not photochemical smog can
induce long term effects and if so precisely what
those effects are; and secondly, what is the level
of exposure required to induce either short term
(reversible) or long term (irreversible) effects?

Dealing first with the long term, the State Pollution
Control Commission (17) accepts that there is no
evidence linking exposure to photochemical smog
with an increase in human mortality. The available
evidence is inconclusive. The Health Commission of
New South Wales, on the other hand, refers to a
number of cases in which photochemical smog was said
to be implicated in accelerating the death of persons
who are already suffering from lung disease (generally
chronic bronchitis).

There is evidence that photochemical smog does
irreversibly damage certain sensitive plants such
as petunias (18). Experiments carried out with
animals would suggest that exposure to photochemical
smog lowers resistance to bacterial infection. It
is thought likely that the same occurs in humans (19).

Mrs. Kortvelyesy appeared before the Inquiry on 5th
October, 1979, as a member of the Earlwood Branch
of the Australian Labour Party. She tendered in

17. An Assessment of Photochemical Smog in the
    Sydney Region, page 8.
18. U.T.S.G. "Central Industrial Area Study"
    Air Pollution, page 3.
19. S.P.C.C. ibib, page 9.

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evidence a recent publication entitled “The
Quick and the Dead - a Biomedical Atlas of Sydney

by John B. Gibson and Arne Johansen. The book was
prepared from data gathered by the Medecheck
Referral Centre which had, between 1971 and 1975,
examined and tested some 40,000 people.
Statistics were compiled according to postcodes.
Chapter Five of the book deals with “Lung
Performance, Effects of Smoking, Air Pollution and
Respiratory Disease
". Now, the mere coincidence
of two phenomena within the one geographical area
does not prove that one is caused by the other.
To prove that there are high concentrations of
pollution, for instance, within a particular area,
and that persons within that area have a high incidence
of respiratory disease or dysfunction, is not to prove
that the pollution causes the respiratory ailment.
In the nature of things it is difficult to exclude
other possibilities. A person who lives in one area
more than likely works within another. Who is to say
that the other area does not play some part causally,
or that some other factor altogether is the
explanation for the diagnosis.

Yet, having made that concession, there are some
striking correlations. The Authors state:- (20)

"...The general pattern, with the highest
prevalence of respiratory disease systems
in the South and West of the Sydney basin,
parallels to some extent (certain other
maps in the book) where the lung function
of non-smokers was worse than it should
have been and where also.....we found that
air pollution was likely to occur.”

Applying the same technique to deaths from pneumonia
and influenza, and deaths from bronchitis and
emphysema, the following conclusion is drawn:- (21)

20. Page 92.
21. Page 96.

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"In summary, the maps of this chapter
clearly illustrate that as far as the
respiratory health of the population
is concerned, the South and the near
West of the Sydney basin provide cause
for deep concern."

This Inquiry echoes that concern. Proof of a
casual connection between air pollution and compromised
lung function may never be forthcoming. The number of
possible explanations for the geographical coincidence
of these two phenomena may be endless. Whatever view
is taken, prudence demands that the problem of
photochemical smog should be addressed, and addressed
at once. The population ought not be subjected to the
spectacle of a debate of the type raised in the 1950s
concerning the connection between smoking and ill-
health. Proof of that connection beyond reasonable
doubt took considerable scientific ingenuity. It also
took a great deal of time. The population in the meantime
was effectively deprived of the process of re-education.
And whilst the matter was being debated, those who did
smoke, if asked, had little doubt in their own minds
that their coughing and spluttering was in some way
connected with their smoking habit.

It is evident from the many submissions made to this
Inquiry that people have come to feel the same way
about air pollution. Their conclusion is likely to be
derided by scientists. It falls far short of the
rigors of scientific method. In time, as with smoking,
their perception may nonetheless be validated. Caution
demands that steps be taken in the meantime to reduce
levels of air pollution.

Whatever the truth about long term irreversible
effects of exposure to photochemical smog, there can be
no doubt as to its short term effect. These can be
induced experimentally, and the levels at which people
react to photochemical smog determined.

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The following is a rule of thumb:- (22)

"Ozone concentrations on the earth’s
surface range from 1 pphm or less,
to over 30 pphm in extremely polluted
regions
. Concentrations in Sydney...
range up to 38pphm
.” (emphasis added)

The United States Environmental Protection Agency,
in a review of the evidence concerning photochemical
smog, recently concluded as follows:-
  • Ozone concentrations of 15 to 25 pphm
    cause airway resistance to be increased
    and compromises, to a greater or lesser
    degree, the capacity of the lungs.
  • The effects are greater upon persons with
    hyper-reactive airways, such as asthmatics.
  • The effects are more noticeable to individuals
    who are exercising.
  • Concentrations in the range 15 to 25 pphm
    can cause headaches and eye irritation.
  • Where ozone concentrations reach about 25
    pphm an attack may be triggered in certain
    sensitive asthmatics.
  • There is limited evidence to suggest that
    inhalation of 20 to 25 pphm for thirty
    to sixty minutes has an effect upon blood
    cells. This suggests an acceleration of
    the ageing of cells and, therefore, an
    acceleration of the ageing process.
An incident occurred on the 19th March, 1976 at the
Sylvania High School. The incident attracted a
good deal of publicity. It appears that sixty boys

22. S.P.C.C. ibid., page 8.

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aged approximately 13 years were playing football
and basketball on a hot and humid day in which
there was a slight southerly breeze (23). Within
thirty minutes thirteen boys developed chest pains
and shortness of breath. It persisted for
approximately two hours even though they were resting
(at the Sutherland Hospital) for one and half hours
of that time. The sports master also complained of
eye-irritation.

By chance the S.P.C.C., as part of the Sydney Oxidant
Study, had determined the ozone level on that day
comparatively close to the school. A high reading
(29 pphm) (23) was taken. The symptoms experienced
by the school-boys were consistent with photochemical
smog exposure. Other hypotheses were excluded.
Doctor W. Allen Crawford concludes:- (24)

"It is reasonable to conclude that symptoms
experienced by thirteen school boys were
associated with photochemical oxidant
pollution."

There has not been any other dramatic incident of
this kind. That is not to say that photochemical
smog pollution is not having an effect upon the
population. It is likely that susceptible asthmatics,
whose attacks are aggravated on high smog days, would
not associate the attack with the elevated ozone levels.
In this context the remark of Mrs. Kortvelyesy
(Earlwood Branch of the Australian Labour Party) (25)
is of interest:-

"KORTVELYESY: Further, a local medical
practitioner, recently told my colleague,
Barbara O’Rourke, that in the past, on
days when there was an inversion temperature

23. Dr. W. Allen Crawford ibid., page 10; Dr. Allen
    Bell "Photochemical Smog and Health Effects"
    Clean Air Society of Australia and New Zealand
    Conference. 20-30th October, 1979, page 5.
24. Dr. W. Allen Crawford ibid., page 11.
25. 15th October, 1979, page 30. (Transcript)

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she and her husband could be certain
that they would spend a long and arduous
night answering calls throughout the
valley (the Cooks River Valley) particularly
along Riverview Road, from patients with
asthma attacks. Since the advent of
drugs, such as intal which asthma sufferers
administer themselves, the demand for this
service has reduced, but not the incidence
of requiring relief from symptoms, so costly
remedies are required and the financial
cost to the individual, directly
attributable to air pollution, is a further
burden for residents.”

5.7 What is an Appropriate Standard for Photochemical
    Smog Exposure?

In 1972 the World Health Organisation recommended
6 pphm as a World-wide long-term goal.

Japan's air quality standard is 8 pphm.

It is suggested that these standards are too
stringent and were based upon limited evidence (26).
The matter has since been examined by U.S.
Environmental Protection Agency and a standard of
12 pphm (1-hour average, not to be exceeded more
than once per year on a statistical basis) has been
recommended. The same concentration, 12 pphm, has
also been adopted by Australia's pre-eminent medical
authority, The National Health and Medical Research
Council.

The Victorian Environmental Protection Agency, on
the other hand, published a draft State Environmental
Protection Policy
in June, 1979 in which the acceptable
level of ozone was fixed slightly lower at 10 pphm.

Dr. Allen Bell was for a great many years a director
of the Division of Occupational Health and Radiation
Control of the Health Commission of New South Wales.

26. Dr. W. Allen Crawford ibid., page 12.

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In a paper entitled "Photochemical Smog and
Health Effects
" he poses the following question:- (27)

"It is inevitable that the community
must accept some risk no matter at
what level the standard is set, unless
it is zero.

What degree of risk?...If society did
not agree in general that in everyday living
inevitably we have to accept some risk-
and sometimes a high one - then
legislators would invent laws to prevent
us from crossing streets and playing
sport etc. Accordingly, in my opinion
it may not be reasonable to set an ozone
level which protects everybody, including
the "most sensitive" persons, and particularly
if that level has important consequences
for the majority of the community."

The important social consequences are presumably
the deprivation of finance from other worthy causes.
Doctor Bell then recommends a level of 20 pphm as
an appropriate goal for our capital city. At that
level, certain asthmatics and others whose respiratory
system is some way compromised, may experience
breathing difficulties and other symptoms. Dr. W.
Allen Crawford expresses a similar view (28).

Certainly risks are a part of everyday living. The
risk which must be accepted, surely, is the risk
that exposure to even small quantities of photochemical
smog (less than 12 pphm) will damage one's health.
To condemn, as an act of policy, an appreciable
section of the community (asthmatics and others whose
lung function is compromised) to discomfort is
unacceptable. Certainly one must be practical and
certainly this is a question of priorities. However,
the view taken by this Inquiry is that nothing less
than the standard adopted by National Health and
Medical Research Council (12 pphm) will do.

27. Dr. Allen Bell "Photochemical Smog and Health
    Effects".
28. Dr. W. Allen Crawford ibid., page 12.

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5.8 How Bad is the Photochemical Smog in Sydney?

The seriousness of the problem can be gauged
from the following statistics:-
  • On approximately 140 days each year the
    World Health Organisation Standard (6 pphm)
    is exceeded.
  •  On approximately 59 days each year the
    recommended Victorian Standard (10 pphm)
    is exceeded.
  •  On approximately 28 days each year the level
    at which symptoms can begin to manifest
    themselves (15 pphm) is exceeded.
  •  On 10 days each year the level of 20 pphm
    is exceeded
  • In 1977 a reading of 38 pphm was recorded.
The figures tell a sorry tale. The community has
every right to be concerned.

5.9 Control of Photochemical Smog

The control of photochemical smog must be tackled
in the wider context of the control of air pollution
generally. It is convenient to deal with it below
in the exposition on the avenues available to combat
air pollution.


6. EFFECTS OF EXPOSURE TO LEAD POLLUTION

6.1 Why is Lead Used in Petrol?

There are two reasons for the use of lead in petrol.
First, the refining process involves the use of a
great deal of energy. If lead is not used it is
necessary to refine it 'more severely’ which "involves
the consumption of a significant additional (amount)
of energy in the refinery". (29) The cost is

29. National Energy Advisory Committee "Motor Spirit
    Octane Ratings and Lead Additives”, February,
    1978, page 7.

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greater to the refinery and, therefore, ultimately
to the consumer.

Secondly, the refining process is undertaken to
achieve a certain octane rating. There is a
difference between the octane rating of premium grade
(super) petrol (98 octanes) and standard (89 octanes).
Engines with a higher compression ratio require a
higher octane fuel. Such a fuel has improved
combustion characteristics, the most important of
which is the "anti-knock property". Knocking is
caused by the detonation of portion of the fuel-air
mixture instead of their being a controlled combustion.
Prolonged knocking can damage engine components.

The suggestion is made that more severe refining will
produce petrol without the same anti-knock
characteristics as leaded petrol. The Australian
Environment Council, in its position paper on the
Reduction of Lead in Petrol, refutes that suggestion:- (30)

"When West Germany reduced lead levels
to 0.4 grams per cubic litre, it was
alleged that this (high speed knocking)
would arise. Subsequent advice received
through O.E.C.D. indicates that the
problem was not very apparent at all and
the few vehicles affected were corrected
by slight reduction in compression ratio
and timing."

Further, there are certain undesirable consequences
for the engine if lead-additives are used in petrol.
It is necessary to add chemicals, called ‘lead
scavengers', to the mix to prevent the lead accumulating
in the engine. Some of the lead, nonetheless, remains
in the engine. Most is expelled into the atmosphere.
It is estimated by the State Pollution Control
Commission that 1,000 tonnes of lead are emitted into

30. Position Paper "The Reduction of Lead in Petrol",
    Australian Environment Council, page 3.

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the atmosphere over Sydney each year.

The "sediment” which remains in the engine as a
result of the lead additives and the scavenger, has
an effect upon the engine itself. It increases "fouling
of spark-plugs, it reduces the life of exhaust pipe
mufflers, contaminates sump-oil and possibly also
increases engine wear, particularly piston-rings". (31)

6.2 The Effects of Lead Poisoning

Lead is a poison. It is a poison which accumulates
in the body when ingested. It has no useful
biological function.

At one time it was widely used in the manufacture of
household utensils, children's toys, water-pipes
and paint. Because of its toxic characteristics,
and its tendency to accumulate in the body, its use
has been substantially discontinued. The one important
exception is petrol.

Lead poisoning can lead to permanent brain damage
(encephalopathy), chronic kidney disease and even death.
Children are more susceptible to the effects of lead
than adults, due to their rapidly developing
physiological and neurological functions. (32)

The Royal Commission on petroleum in its Fifth
Report
(33) reviewed the medical literature then
available (1976). It concluded:-

"One thing does stand out, despite massive
studies and many reviews, in the entire
literature No Single Case of clinical
lead poisoning has ever been demonstrated
to be due to automotive emissions of
airborne lead."

31. S.P.C.C. Annual Report 1979, page 92. See also
    excellent pamphlet by the S.P.C.C. entitled "Petrol
    in Lead - The Questions and Answers."
32. V.P. Garnys, Freeman and L.E. Smythe 1979, “Lead
    Burden of Sydney School Children”, page 9.
33. Royal Commission on Petroleum, Fifth Report
    "Towards a Refining Policy", page 604.

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To say there have not been cases of lead poisoning
is not to exonerate lead emissions. The question
becomes whether lead emission are deleterious
to health, even though they might not cause the
classical signs and symptoms of clinical lead
poisoning.

6.3 The Effects of Low Concentrations of Lead
Three separate issues must be addressed:-
  • First, to what extent is exposure to low
    concentrations of lead (from whatever
    source) harmful or undesirable?
  • Secondly, to what extent can accumulations
    of lead detected in the body be attributed
    to the lead expelled from car exhausts?
  • Thirdly, to what extent is lead
    harmful to health?
A great deal of controversy surrounds each issue.

Doctor Graham Peak, the Assistant Secretary of the
Beverly Hills Progress Association, prepared a
paper entitled "The Effects of Lead Pollution on
the Psychological Development of Children
" as part of
the presentation of that Association. Dr. Peak
is a clinical psychologist with extensive qualifications.
Strictly speaking, as he acknowledged in his evidence (34)
the subject is outside his field of expertise.
It nonetheless provides a valuable review of the
more recent medical literature. That literature
certainly does not speak with one voice.
Experiments have been conducted which support the
proposition that exposure to low levels of lead can
cause a number of effects especially in children
including "reduced intelligence, reduced ability to
concentrate, an inclination to non-adaptive classroom

34. Transcript 31st October, 1979, page 40.

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behaviour and hyperactivity." (35)

There are, on the other hand, a number of authors
who express a contrary view. In many cases the
experiments are open to criticism on the basis
of methodological shortcomings, and a failure to
exclude other plausible hypotheses (36). Dr. Peak
concludes his review with the following statement:-

"In summary, the weight of evidence
from empirical research suggests that
low level of lead exposure can lead to
neurological and psychological impairment
in children in the absence of overt
signs and symptoms of toxicity.”

There seems to be little doubt that lead exposure
can be harmful to health even whilst falling short
of clinical lead poisoning. The quibble seems
rather to be the level of which neurological and
psychological impairment may arise. (37)

6.4 The Link Between Lead Concentrations and Traffic

Where lead concentrations are detected in the body,
it is essential to establish their origin. In
broad terms, there are three possible sources:-
  • the air we breathe
  • the water we drink
  • the food we eat
With children, exposure to ‘abnormal sources’ may
also be of some importance because of the habit of
eating pica (i.e., non-food substances) such as
paint-flakes, certain Asian cosmetics, lead-sinkers
and so on (38).

35. S.P.C.C. Annual Report, 1979, page 93.
36. See for instance the criticisms of Dr. R.D. Wilson
    "Review of Lead and Health Effects on Children"
    Clean Air Society of Australia and New Zealand
    Conference, October, 1979, pages 3-5.
37. S.P.C.C. Annual Report, 1979 page 93; also Dr. R.D.
    Wilson ibid., and the quotation appearing on page 6.
38. Dr. R.D. Wilson ibid., page 7.

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The National Health and Medical Research Council
in October, 1979 accepted that twenty percent of
the total body lead burden would be attributed to
lead in the air, particularly in areas subject to
heavy pollution. Can we assume that the lead in
the air is, in turn, attributable to motor vehicles?
Dr. J.R. Harry of the State Pollution Control
Commission suggests we can:- (39)

"Lead emitted (from the burning of
petrol) is a widespread pollutant
and has been stated to account for
as much as 98% of all lead in the
atmosphere of the United States. A
similar relationship can be expected
to apply in Australia."

6.5 The Effects Upon Health of Lead in the Air

What, then, is the evidence that lead in the air
can have harmful effects upon health? There are
three relevant studies. They are referred to by
Dr. Peak in his paper (page 1).

In 1974 Caprio et al found a relationship between
proximity to major arterial roads (in Newark, New
Jersey) and lead absorption by children. Children
from households close to the roadway had higher
blood-lead levels than children further away.

The second study was that of Mencel and Thorp in
1976 (40). The study contrasted blood-lead levels
of persons travelling by train with those travelling
by car. The car travellers were higher. The authors
state:-

"A reasonable explanation seems to be
the assumption that subjects travelling
by car during peak-hour traffic would
be exposed to a greater atmospheric
lead concentration than rail commuters

39. Royal Commission on Petroleum Fifth Report,
    page 607.
40. Mencel and Thorp "A Study of Blood-Lead Levels
    in Residents of the Sydney Area” The Medical
    Journal of Australia. 25/5/76.

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who are generally isolated from traffic
congestion....The evidence given in
this survey supports the conclusion
that involvement with environments of
high traffic density can be associated
with higher blood levels of lead. The
results also indicate that present levels
of air-borne lead in the Sydney area
make a significant contribution to the
blood-lead level."

Most recently, the matter has been extensively
investigated by Garnys, Freeman and Smythe (1979) (41)
The question was posed in these terms:- (42)

"Of current concern is the effect of
small, regular doses of lead, taken
via involuntary exposure over lengthy
periods. Such a situation exists
where children live in areas of high
traffic density which gives rise to
high levels of ambient lead and increased
amounts of lead in dust and soil.

However, these small regular doses of
lead obtained by breathing polluted
air and ingesting city auit- probably
do not produce overt clinical symptoms
of toxicity. With increased exposure,
the body burden of lead is increased
as it accumulates in the blood, bones and
soft tissues."

Blood samples were taken from school children attending
a school at Gardners Road, Mascot and at Mosman as well
as certain other areas of Sydney. The survey was made
in spring and repeated in autumn. The results were:-

  • Of Sydney school children in the spring survey,
    11.5% had a brood-lead level above 30 ug percent.
  • The Gardners Road School at almost twice that
    number (22%) had blood-lead levels above 30 ug
    percent.
  • In Mosman 10% of children had blood-lead levels
    above 30 ug percent in the spring survey.

41. Garnys, Freeman and Smythe 1979, ibid.
50. Garnys et al ibid., page 4.

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The same relativities were found in the autumn
survey. On the basis of their study the authors
conclude:- (43)

"A wide variety of factors have been
examined which may contribute to
increased lead burden of school
children as measured by P.b-B (blood
lead). P.b-air (lead in air) was the
only casual factor which showed a
strong association with P.b-B (blood
lead) and with school. The other
casual factors showed either weak or
insignificant association with P.b-B
(blood-lead), although they were often
strongly correlated between each other.

These findings indicate that increased
levels of P.b-air directly cause
substantial increases in the levels of
lead in the blood of Sydney primary
school children."
    (emphasis added)

The methodology and the conclusions have been
criticised (44). It is suggested that attention should
be directed, instead, to other sources such as
food and water.

Two things must be said in respect of that suggestion.
First, insofar as absorption of lead is a problem,
as it seems to this Inquiry it is, lead in air can
be more immediately and completely controlled (45).
Secondly, having regard to the susceptibility of
young children, and the possible consequences if
nothing is done, the community and Parliament are
entitled to act on something less than strict
scientific proof, and something which may approximate
(to borrow a legal phrase) 'proof on the balance of
probabilities'. A strong prima facie connection
does exist between lead in air and the impairment of
health.

43. Garnys et al ibid., page 339.
44. Dr. R.D. Wilson, the Chief Medical officer, Mobil
    Oil Australia Limited and the Chairman of the
    Health Committee of the Australian Institute of
    Petroleum. His Paper. "Review of Lead and Health
    Effects on Children” ibid.
45. State Pollution Control Commission Annual Report
    1979, page 93.

-167-
The conclusion reached by the Royal Commission into
Petroleum (46) was not very different. The
conclusion was:-

"The Commission has concluded that there
is no direct clinical evidence that
air-borne emissions of lead arising from
automotive exhausts directly represent
a health hazard, but in view  of the
generally toxic nature of lead, it would
appear imprudent to allow the continuation
of uncontrolled and increasing quantities
of lead into the atmosphere.”

In reaching that conclusion the Royal Commission had
regard to the statement issued by the United States
Environmental Protection Agency
(47) which was in the
following terms:-

"The resulting new health issue paper
concluded that air-borne lead can
either be directly absorbed through the
lungs as people breathe or settle out
of the air to contaminate dirt which
can be consumed by children. Strong
evidence existed which supported the
view that through these routes air-
borne lead contributes to excessive
exposure in adults and children. In
the light of this evidence, the
Administration concluded it would be
prudent to reduce preventable lead
exposure.”

6.6 Is There an Appropriate Standard for Lead Exposure?

As further research is carried out the standard has
been modified and progressively lowered. A
matter of ten years ago 80 micrograms of lead per
one hundred millilitres of blood was commonly regarded
as the minimum level before individuals could be
regarded as being at risk (48). The United States
Surgeon General, thereafter, reduced the level from 80
to 60, from 60 to 40 and then from 40 to 30 micrograms
per one hundred millilitres.

46. Royal Commission into Petroleum, Fifth Report,
    page 608.
47. ibid., page 607.
48. S.P.C.C. Annual Report, 1979, page 93.

-168-

Recently the United States Environmental Protection
Agency has recommended 30 micrograms per one
hundred millilitres as the maximum individual level.

The National Health and Medical Research Council
in October, 1979 (49) concluded:-

"Having considered extensive Australian
and overseas data, Council recommend
that 30 ug lead per one hundred millilitres
of blood in the Australian population be
taken to represent a level of concern
.
The maintenance of blood-lead levels
below this figure would ensure adequate
protection for the potentially harmful
effects of lead, particularly in the
more susceptible groups such as children
and pregnant women."
                              (emphasis added)

Expressing that blood-lead standard (30 micrograms
of lead per 100 millilitres of blood) in terms
of atmospheric concentrations of lead, the National
Health and Medical Research Council states that
concentrations should not exceed 1.5 micrograms per
cubic metre, averaged over three months.

6.7 Ambient Lead Levels in Sydney

In 1978 the three month average level in the central
business district of Sydney was as follows:-
  • January to March, 2.3 micrograms
    per cubic metre
  • April to June, 3.1 micrograms per
    cubic metre
Both figures, therefore, were well above the recommended
standard (1.5 micrograms per cubic metre). Several
suburbs experienced concentrations which were also above
the recommended standards (50).

49. Report of the 88th Session 25th to 26th October,
    1976.
50. State Pollution Control Commission pamphlet
    "Lead in Petrol".

-169-

More recently the study conducted by Garnys, Freeman
and Smythe (see above) provided some insight into the
extent to which the blood levels of Sydney school children
(especially in certain areas) exceed the recommended
maximum.

6.8 What is Being Done Overseas

The Royal Commission into petroleum examined in
some depth the policies being pursued overseas for
the removal or reduction of lead in petrol. It
considered (51) the experience of the United States,
West Germany and Japan to be of direct relevance
to any proposed Australian programme. The comparative
lead phase-out schedules (as anticipated in 1976 when
the report was written) is set out in the table below:-

TABLE 11.

COMPARATIVE LEAD PHASE DOWN SCHEDULES
Lead Content of Petrol, grams/litre

COUNTRY
1975
1976
1977
1978
1979
1980
1985
U.S.A.
0.45
0.37
0.26
0.21
0.13
0.13
0 
West Germany
0.4
0.15
0.15
0.15
0.15
0.15
0.15
N.S.W.
0.64
0.64
0.45
0.45
0.45
0.40
0.40
Victoria
0.60
0.60
0.50
0.50
0.50
0.45
0.45

The European Common Market proposed a standard of
0-4 grams per litre the introduction of which was
postponed until the 1st January, 1977, and thereafter
a further reduction to 0.15 grams per litre to be
introduced on 1st January, 1978.


51. Fifth Report ibid., page 601.




-170-




The necessity to reduce lead in petrol appears to
be universally accepted. Programmes, more or less
stringent, have been devised to that end. The ‘energy
crisis’ has in some cases, caused the postponement
of certain stated goals, but not their abandonment.



6.9 Alternative Proposals in Australia


6.9.1 Introduction



During the life of this Inquiry, controversy
surrounded the proposed reduction of lead in petrol.
It was suggested by the Federal Government, and
certain States, that the policy was unnecessary,
impracticable, and, in the context of an energy crisis,
irresponsible.


The New South Wales Government nonetheless reaffirmed
its determination to proceed with the proposed
reduction. This Inquiry, having witnessed the concern
of the community, and having reviewed the arguments for
and against, has no doubt that a policy of reducing
the lead content in petrol is to be applauded.

Alternatives have been suggested. First, a lead-
filter can be fitted to a motor vehicle's exhaust.
Secondly, it is suggested a policy should be pursued in
which people are weaned off higher octane super-grade
petrol (of which Australians use a disproportionate,
and quite unnecessary amount) to a regular or standard
petrol with a somewhat high octane rating (52).

6.9.2 Lead Filters

A number of lead-filters have been developed (53).
However, there are many objections to the introduction
of this technology. First, how effective would the
lead-filters be in trapping lead particles? Certain

52. National Energy Advisory Committee, “Motor Spirit
    Octane Ratings and Lead Additives” February, 1978.
53. Developed primarily by Associate Octel, the
    Ethyl Corporation and Du Pont see National Energy
    Advisory Committee ibid., page 9.

-171-

exaggerated claims have been made by the
manufacturers reciting their own laboratory tests.
A rather more independent assessment was made by
the Transport and Road Research Laboratory in the
United Kingdom (54). In respect of the octel device,
its efficiency was measured at approximately 40-45%.
Secondly, lead filters have not been adopted
anywhere in the world. It is therefore unproven
technology. It may or may not work in practice.

Thirdly, the introduction of a lead-filter is
administratively clumsy. The paraphernalia of
regulation would have to accompany its introduction.
It would have to be tested, inspected and its
efficiency would have to be maintained. The
accumulation of lead particles would inevitably cause
the filter to become inefficient. Inefficiency may
cause 'excessive back pressure' in the exhaust system
which, in turn, would reduce engine efficiency with
the penalty of substantially increased petrol
consumption.

Finally, the Australian Environment Council (55)
anticipates a problem in disposing of the lead-
filters once they are spent. Occupational health
problems may arise and "special precautions may
be needed to avoid excessive discharge of the more
volatile lead compounds from furnaces during re-
cycling."

In short, the introduction of lead-filters cannot
be viewed as a substitute for a policy directed towards
the removal of lead itself from petrol.

6.9.3 Inducing People to use Lower Grade Petrol

The second alternative is aimed at the way in which
the Australian consumer gravitates towards high
octane petrol when something less is required. The

54. The assessment of a Lead Trap for Motor Vehicles
    Report, 1974
55. The Australian Environment Council Position
    Paper on the Reduction of Lead in Petrol.

-172-
Royal Commission on petroleum drew attention to
Australia's unique position (56):-

"Australia consumes premium (98 octane)
standard grade (89 octane) in the ratio
of 85:15, almost an inverse of the
consumption pattern of most other
countries."

The National Energy Advisory committee is naturally
concerned about greater expenditure of energy in
the removal of lead additives from petrol. The
solution it proposes, however, involves a great
many difficulties, not the least of which is consumer
inertia.

They propose that the octane rating of regular petrol
be increased to make it more attractive to motorists
who could get by without using the high-grade, 98
octane premium. They suggest a public education
programme should accompany any such increase, and
that lead levels should be carefully monitored so that
lead-filters can be introduced if the need arises.

Under this proposal one may be worse off if those
who ordinarily use premium continue to do so, and
those who use regular petrol use a higher octane
grade. Substantial defections from premium grade
to higher octane regular would be necessary to make
an impression upon the total lead emissions.

A policy directed towards the reduction of lead emissions
through the reduction of lead content seems to this
Inquiry more soundly based.

6.10 The Use of Catalytic Convertors

Perhaps the greatest mischief perpetrated by lead
additives in petrol, is the fact that they deny the
community the use of catalytic convertors.

56. The Royal Commission on Petroleum, Fifth Report,
    page 601.

-173-

Catalytic convertors are an emission device,
widely used in the United States of America,
Canada and Japan. They reduce emissions from
vehicles by 80% (57). The catalyst in these
devices, however, is 'poisoned’ by even the smallest
trace of lead in the exhaust gases. Vehicles fitted
with catalytic convertors must be fuelled by lead-
free motor spirits. In the United States of
America, where there is a commitment to emission
control, regulations have been introduced which
require the production of both lead-free petrol
and petrol in which the lead content is progressively
being phased out over the period until 1985.

The State Pollution Control Commission in its
excellent pamphlet Lead in Petrol suggests that the
elimination of lead in petrol offers three solutions
in one. First, it will eliminate the health risks
which accompany lead in air. Secondly, it will pave
the way for the introduction of technology which
is already available and proven overseas, namely
catalytic convertors, and they, in turn, will deal
with the other primary pollutants and the photochemical
smog which develops from their uncontrolled emission.

Thirdly, the catalytic convertors themselves are
fuel efficient and will conserve fuel supplies.
The following statement appears in the same
pamphlet: -

"One leading Australian car manufacturer
estimates fuel economy will improve by
l2% if catalytic convertors are introduced
into this country."

Whilst this claim is disputed in some quarters,
the attractiveness of this technology in dealing with
the total pollution problem makes the continued

57. S.P.C.C. Pamphlet Lead in Petrol

-174-

presence of lead in petrol the more unacceptable.

6.11 The Relevance of Lead to Evaluation

Lead compounds emitted from motor vehicles exhausts
are a primary pollutant. As such they are
substantially of local rather than regional
significance. Their effect will be confined to
people living and working in the near vicinity
of the major traffic arteries.

This Inquiry must examine each option and its
effect upon the community through which it passes.
Are there land uses (such as schools) in the near
vicinity which are sensitive to lead pollution?

More than this, it is necessary to examine precisely
where congestion is likely to be caused or relieved
by the various options including the option of
"doing nothing".


7. THE MEASUREMENT AND PREDICTION OF AIR POLLUTION

7.1 The Measurement of Air Pollution

The measurement of air pollution does not offer the
same technical problems as arise in the measurement
of noise. Techniques are available to measure and
monitor each of the pollutants emitted from motor
vehicles.

7.2 The Modelling Procedure to Predict Air Pollution

As with noise prediction, there are mathematical
formulae (called models) which are available to
predict air pollution levels in particular locations.

The variables which can effect the location of
primary and secondary pollutants have already been
listed (58). The prediction and measurement of any

58. See page 135.

-175-

one of these factors poses problems of considerable
technical complexity. The source of emissions
will depend, for instance, upon the traffic flow,
the mix of heavy vehicles, the emission rate of
each vehicle, and the average speed. To predict
the traffic flow, and the proportion of heavy
vehicles, the air pollution model is dependent upon
traffic models. It is necessarily infected, therefore,
by such limitations as exist within the chosen
model. One limitation suggested by professor M.E.
Beesley (59) is that the traffic models themselves
are capable of assessing broad corridor movements but
cannot be relied upon with any degree of assurance
to simulate traffic conditions upon each individual
link.

The problems do not end there. The emission rates
used in the models are based upon a local adaptation
of an overseas formula. The adaptation was based
upon a sample of vehicles available in Australia.
The Planning and Environment Commission in its
submission (60) expressed concern as to the
validity and accuracy of the equation which was used.

Further, the model is not capable of reproducing
the emission rate which will vary with the topography. (61)
Various options, for instance, are elevated at
one time or another. The need for vehicles to change
into lower gears to negotiate the climb will affect
the emission rate.

7.3 The Dispersion Model

Having predicted the concentrations of air pollutants
at source, it is necessary to judge the degree to
which the pollutants will then be dispersed.

59. Professor M.E. Beesley Annexure 2 Volume II.
60. Transcript of Planning and Environment Commission,
    16th November, 1979, page 17.
61. Planning and Environment Commission Transcript
    16th November, 1979, page 27.

-176-
Only then can one gauge the effect of each option
upon the local community.

In the Cooks River Air and Noise Study by Dr.
Mudford the dispersion model is described. The
assumptions which underpin the model are stated (62).
Again the matter is exceedingly complex. Dispersion
will depend upon the location of the road, the
average wind speed and direction and the "stability
class" (the rate of turbulent mixing in the
prevailing atmospheric conditions). There are guides
available "Work Book of Atmospheric Dispersion"
1970 (63). One may select one of six 'stability
classes’ ranging from "very stable" through "neutral"
to "unstable".

The deficiencies of the model were to some extent
overcome in the calculations made by Dr. Mudford
by assuming the "worst case" (64). The worst case
could be expected to occur in times of light winds
and a stable atmosphere. In those circumstances
there would be little mixing and, therefore, little
dispersion of pollutants emitted.

Even assuming that each one of the variables can
be accurately predicted, the concentration of
pollutants will depend upon the precise location,
its physical character and man-made structures.
The only account apparently taken of this aspect
is in the selection of an appropriate classification
of wind conditions and stability (65).

7.4 Predicting Levels of Photochemical Smog

The process of photochemical smog formation is
imperfectly understood. The chemical transformation

62. Cooks River Air and Noise Pollution Study, page 20.
63. P.E.C. "Kyeemagh/Chullora Route Study; Air
    Pollution Impact Assessment”, page 18.
64. Dr. Mudford Report ibid., page 22.
65. Mr. C. Stafford, Cooks River Valley Association
    transcript 8/10/79, page 33.

-177-

of the primary pollutants (nitrogen oxides and
hydrocarbons) takes place over several hours. At
the same time the pollutants may be transported
by the prevailing winds. No models are available
capable of accurately predicting the location and
extent of photochemical smog formation. At best,
if one accepts the modelling procedure, predictions
can be made of the primary pollutants which may or
may not combine to form photochemical smog, depending
upon the availability of sunlight and the prevailing
winds.

7.5 Reservations concerning the Modelling Process

Three matters create misgivings in the Inquiry
concerning the modelling of future levels of air
pollution.

First, air pollution is primarily a function of
traffic flow and specifically the proportion of
heavy vehicles. Traffic flows can be predicted
according to a complex modelling procedure to
which we have already referred. To employ that
procedure it is necessary to make a number of
assumptions. The procedure itself has a number of
limitations. Those assumptions, and those
limitations, form the foundation upon which air
pollution is then predicted.

In the present Inquiry certain predictions were
made. They were based upon certain traffic flows.
The traffic flows were derived from what we have
termed Trip Table A. Trip Table A was found to be
inaccurate. It was superseded by Trip Tables B, C
and finally Trip Table D. The Planning and
Environment Commission indicated that no reliance
should be placed upon predictions which appear in the
Air Pollution Study prepared by the Commission for
this Inquiry.

-178-

Secondly, the air pollution predictions are
themselves the result of a further modelling
procedure. It is clear from this exposition that
air pollution is a result of a great many variables.
Many of them are difficult to predict. We would
endorse the comments made by the State Transport Study
Group in its air pollution paper prepared in
connection with the 'Central Industrial Area Study':- (66)

"Despite the importance of localised air
pollution at a perceptual level, methods
which model road-air quality environments
were found to be inadequate. Models do
exist and can approximate concentrations
of pollutant under special circumstances,
but they do have major limitations; a
prohibitive amount of physical information
would have been required, such as details
of wind speeds and building locations. "

The problem really is one of building uncertainty
upon uncertainty. It is difficult enough to predict
on a corridor basis traffic conditions in 15 years
time. Yet the air pollution models require more
than this. They would require a level of accuracy
on individual link-loadings which is beyond the
capacity of the models to deliver. These loadings
are used as a spring board from which a further
prediction is made (introducing its own simplifications)
of the level of pollutants which can be expected in
the future. Uncertainty is stretched to breaking-
point. Wouldn’t one be just as well off, at the end of
the day, to simply look at the corridor figures
and predict that pollution overall, would be
proportionately better or worse, depending upon the
predicted traffic flow?

Thirdly, the danger of the elaborate and intricate
modelling procedures is that they dissipate the time

66. U.T.S.G. (now STSG) Technical Appendix No. 3
    Air Pollution": Central Industrial Area
    Stundy, page 6.

-179-
and energy of those who must assess and evaluate
various options. The road builders and the planners
each know that the community is concerned with
air pollution. They feel, rightly, a need to
demonstrate the same concern. They discharge
that obligation, in their own eyes, by elaborate
modelling procedures. They focus minute attention
upon particular concentrations of particular
pollutants along particular roads when this is but
one aspect of but one option which may be available.
There is the risk that other avenues, rather more
pedestrian, are left unexplored.


8. THE WAYS OP COMBATING AIR POLLUTION

8.1 Introduction

If the exclusive focus is upon the pollution
engendered by introducing one or other of a number
of different options the impression may be created
that the objective of “improving air quality” is
served by choosing the option which causes the
least air pollution or confines pollution to areas
where it matters less. That conclusion may be
wrong.

Whilst it is important to know the effects on air
quality of a particular option, the impression should
not be given, as was done to some extent in this
Inquiry, that building one of the options or not
building at all, are the only two courses open if one
is dedicated to the objective of ‘improving air
quality’.

There are other options and they may be better.
Certainly they should be assessed. In broad terms the
options for combating air pollution are:-

  • discouraging the use of motor vehicles
  • altering traffic flows
  • introducing a road hierarchy
  •  manipulating land use
 -180-


  • introducing design features into
    the road which inhibit the spread
    of pollutants
  • erecting barriers (or utilising
    barriers erected for other purposes
    such as noise) to intercept pollutants
  • encouraging high occupancy vehicles
  • encouraging the use of other transport
    modes
  • encouraging the use of fuels which
    pollute the atmosphere less (such
    as LPG gas)
  • proceeding towards lead-free petrol
  • introducing catalytic convertors
  • various other emission control devices
    to control pollution at source

Many of these matters have been dealt with in the context
of noise. Very often the principle is the same and
it will not be repeated here. Reference should be made
to the chapter dealing with noise. The exposition which
follows attempts rather to deal with matters peculiar to
air pollution.



8.2 Discouraging the Use of Motor Vehicles


Air pollution, whether local or regional, is very much
the product of the number of vehicles using the roads.
If the number can be limited, the local community and the
region is spared to that extent. Policies aimed at
minimising travel by car will enhance air quality. Such
policies include:-

  • primarily a land use plan which
    encourages less travel rather
    than more.
  •  a policy which judiciously chooses
    which congestion should be eliminated and which
    should be permitted to remain in order
    to discourage further travel within
    a particular area.

  •  policies which encourage high occupancy
    vehicles
  • policies which encourage the use of
    other transport modes (train and ferry)

-181-

Three examples have been dealt with in the course
of this Inquiry. First, it has been suggested
that containers should be diverted to rail and
sent to decentralised depots. That is the subject
of a separate report. Secondly, it is suggested
that cross-country bus routes should be developed
between the tentacles of the radial rail network
to encourage the use of ‘high occupancy vehicles’.
Thirdly, a policy of 'park-and-ride' is being
pursued by the State Rail Authority where parking
facilities are provided at railway stations and
bus interchanges. The second and third matters are
dealt with in the section of this Report dealing with
public transport.

8.3 Options Concentrating on Traffic Flow

Table 12 of this Report clearly demonstrates that
emissions at lower speeds and especially whilst
idling are far greater than at higher speeds. The
eradication or minimisation of congestion, therefore,
will certainly enhance air quality.

However, if the provision of additional capacity within
a network (in the hope of eliminating congestion)
encourages more people to travel by car, the community
is likely to be worse off, in terms of air quality,
than when the road was less capacious and more
congested.

A road hierarchy may effect an improvement in air
quality in areas sensitive to air pollution. Traffic
may be directed away from schools, hospitals and
residential areas. This is a rather less capricious
instrument than the provision of a new road facility.
A new road facility is likely to effect changes
throughout the road network in the immediate vicinity.
The changes will be random, reducing traffic here and
there, based upon criteria which have nothing to do
with the sensitivity of the land uses along the roads
concerned.

-182-

There is one matter referred to in the context
of noise which we will repeat because it is of
some importance. Ordinarily traffic builds up year
by year and the transformation, in terms of air
quality, is gradual though perceptible. It is a
different thing to transform an area not previously
exposed to pollutants in high concentrations into an
area through which a major traffic artery will pass.

8.4 Policy Directed at Encouraging Pollution Free Fuel

Australia is fortunate in having substantial
quantities of liquid petroleum gas (LPG). The
technology for using LPG in motor vehicles is
available. It has been available and used for many
years overseas. Conversion costs range from $600 to
$1,100 depending upon the type of vehicle. Once
converted, the number of outlets where fuel can be
obtained, is limited.

In terms of 'air quality control' the carbon monoxide
and hydrocarbon emissions are very much lower. The
comparison between petrol and LPG emerges from the
following table:- (67)

TABLE 12.

AVERAGE EMISSION TEST RESULTS COMPARING PETROL AND LPG


Operated on
% change with LPG
Petrol
LPG
Carbon Monoxide: g/km
16.6
1.3
92% reduction
Hydrocarbon g/km
1.4
0.9
38% reduction
Oxides of Nitrogen g/km
1.6
1.3
22% reduction
Idle CO (%)
1.8
0.1
95% reduction


67. S.P.C.C. Annual Report 30/6/79, page 91.


-183-

8.5 Emission Control

Strategies designed to minimise motor vehicle use
are clearly not enough. Emission control is
essential. The State Pollution Control Commission
in the publication "An Assessment of Photochemical
Smog in the Sydney Region 1980
" put the matter in
this way:- (68)

"Experience with..measures to reduce
vehicle usage has led environmental
authorities throughout the world to
conclude that, with dispersed
pollution problems, the effective
way of reducing emissions from the
vehicle fleet is to place limits on
emissions from vehicles...Therefore,
although the Commission fully supports
such concepts as improved public
transport, improved traffic flow and
car pooling, it is quite certain that
such measures alone will not achieve
the necessary reductions in emissions
from sources related to transportation
.”
                    (emphasis added)

A start has been made. Standards have been
prescribed i-n State and Federal Legislation. Under
the New South Wales Clean Air Act 1961 As Amended
certain prohibitions have been introduced.

* there is a prohibition on the sale or
  use of any motor vehicle emitting air
  impurities in excess of a prescribed
  standard.

* there is a prohibition on the sale
  or use of a motor vehicle not fitted
  with a prescribed anti-pollution
  device.

* there is a requirement that such
  devices should be properly maintained.

In May, 1979 the New South Wales Government announced
that all motor vehicles manufactured after the
1st January, 1981, for sale in New South Wales, must



68. S.P.C.C. "An Assessment of Photochemical Smog
    in the Sydney Region 1980”, page 17.



-184-
meet lower exhaust-emission limits. The limits
will be implemented through an amendment to
Regulation 22 (1) (f) under the Clean Air Act.

Regulation 22 (1) (f) parallels the national
requirement of Australian Design Rule ADR 27A.
The Design Rule was to be progressively introduced
over three stages. The last stage was to commence
in January, 1979. It was postponed as a result of
lobbying by the car industry. Its adoption has
since been abandoned in several states (69).
New South Wales has steadfastly refused to relent
on this important issue.

Certainly emission control would be rather more
simple if the technology of catalytic convertors
could be employed in Australia. The technology
cannot be employed whilst lead is used in petrol.
The Inquiry applauds the announcement by the New
South Wales Government in July, 1980 (70) that it
will require 92 octane lead free petrol to be
available in New South Wales from 1st July, 1984.
The way will then be open to introduce this
important emission control device. The importance of
the device can be appreciated from the following:- (71)

"Catalytic convertors and lead-free petrol
have been the basis of U.S., Canadian and
Japanese efforts to control car exhaust
pollution in recent years."

It is intolerable that the people of this metropolis
should have to suffer serious pollution when the
technology to deal with the problem is available and
is widely employed overseas.

69. S.P.C.C. Annual Report 13/6/80, page 81.
70. Sydney Morning Herald, 16/7/80.
71. Article Sydney Morning He
rald, 17/7/80.