UK Clean Air Strategies and domestic burning

Work on implementing clean air strategies across the UK remains a high priority for the government and devolved administrations. We have already seen legislation passed in England for domestic solid fuels through The Air Quality (Domestic Solid Fuels Standards) (England) Regulations 2020 and can expect further changes to legislation over the coming years.

The HETAS team has pulled together the latest status across the UK to keep you up to speed with developments.

Air Quality Strategies and The Environment Bill

The Clean Air strategy was launched back at the start of 2019, a key document in tackling air pollution, making our air healthier to breathe, protecting nature and boosting the economy. The strategy looks at a range of actions to reduce emissions/pollution, including Transport, The home, Farming, Industry and Clean growth and innovation.

The strategy stated government will:

• legislate to prohibit the sale of the most polluting fuels
• ensure that only the cleanest stoves are available for sale by 2022
• make changes to existing smoke control legislation to make it easier to enforce
• give new powers to local authorities to take action in areas of high pollution
• work across government to look at opportunities to align our work on air quality, clean growth and fuel poverty in future policy design
• develop a dedicated communication campaign targeted at domestic burners, to improve awareness of the environmental and public health impacts of burning
• work with industry to identify an appropriate test standard for new solid fuels entering the market

Linked to The Clean Air Strategy, government will create a legislative framework for tackling air pollution at national and local level, tying this into the development of the new environmental principles and governance framework to be outlined in the Environment Bill.

Progress on The Environment Bill

The Bill has been progressing slowly, held up by Brexit and elections, but has gained momentum in recent months. We have previously discussed the Environment Bill following it’s mention in the state opening of parliament back in October 2019. The Environment Bill is currently in the House of Commons and on the 19th March there was a Committee debate but due to current circumstances the sittings of the Committee have been suspended until further notice. MP’s voted against adding an amendment to the Environment Bill that would enshrine the World Health Organisation (WHO) guideline for fine particulate matter (PM2.5) in law. Prior to the Bill being first published, there was an expectation that it would include a legally binding target for PM2.5 in line with WHO guidelines. The Bill has, however, committed to setting a target before October 31 2022.

Separately, but in support of The Environment Bill, government consulted on cleaner domestic burning of solid fuels and wood. This consultation ran between August and October of 2018. 

As we know, legislation on domestic fuels is now in place through The Air Quality (Domestic Solid Fuels Standards) (England) Regulations 2020. HETAS was recently appointed by Defra to run Ready to Burn scheme for manufactured solid fuels. Similarly, Woodsure was also announced as the body to run the Ready to Burn scheme for firewood.

 Any changes to SCAs or additional powers will be the subject of a separate consultation.

So what are the next steps?

The Environment Bill has some way to go to reach Royal Assent. Once a bill has completed all the parliamentary stages in both Houses (Lords and Commons), it is ready to receive royal assent. This is when the Queen formally agrees to make the bill into an Act of Parliament (law). After receiving royal assent the legislation within the bill may come into effect immediately, after a set period or only after a commencement order by a government minister.

The Bill was started in the House of Commons and is currently at reporting stage, the fourth of five stages required, the next being the Third Reading before then heading to the House of Lords.

Clean Air Plan – Wales

Only last week we saw the publication of the White Paper on a Clean Air (Wales) Bill. This consultation sets out the potential provisions for a Clean Air (Wales) Bill. The proposals aim to reduce air pollution and its impacts. The proposals consist of measures which are directly implemented through primary legislation and, at the same time, establish frameworks to design and implement secondary legislation.

HETAS has summarised the key points of the White Paper in a separate article. Click here to find out all about the consultation.

Cleaner Air for Scotland 

In October, Scotland published it’s Cleaner Air for Scotland 2: consultation. This consultation looks at draft new air quality strategy for Scotland, taking into account the recommendations arising from the independent review of the Cleaner Air for Scotland strategy.

The consultation is structured around 10 chapters which largely reflect the high level recommendations arising from the independently-led CAFS review undertaken between November 2018 and July 2019. 

Following the consultation, an analysis report will be published at https://consult.gov.scot. 

Chapter 7 of the consultation deals with the issue of tackling Non Transport Emissions Sources. The consultation also looks at indoor air quality, addressing the fact that urban populations in the UK spend around 90% of their time indoors.

The main pollutants of concern arising from domestic combustion are PM10, PM2.5, nitrogen dioxide and sulphur dioxide. The continuing uncertainty over emissions levels from domestic burning means that setting precise reduction targets is difficult. Further research into the proportion of emissions attributable to domestic burning, as well as assessment of type and source of emissions, is required.

A further complicating factor is that around 50% of local ambient concentrations can relate to long-range transboundary transport from outwith Scotland.

This is an issue HETAS addressed through the scientific research undertaken in 2019 and available to view here.

The consultation identifies that 79% of households using solid mineral fuel in Scotland as their primary fuel type are in rural areas69 and that around half of households (46%) using solid mineral fuels in Scotland are fuel poor compared to the national average of 25%. Emissions from burning wood depend on the type of appliance and the dryness of the wood. Other factors include the way the householder burns the wood and uses any appliance. Maintenance of the appliance and the chimney also have an impact. Burning practices have an important influence. For solid fuel, the amount of sulphur released depends on the sulphur content of the fuel.

Also addressed in the consultation are the issues of the outdated Clean Air Act, challenges with enforcement and appliances that fall outside smoke control areas. 

The consultation addresses the forthcoming Ecocdesign Legislation, which only addresses new appliances installed  and suggests a concerted effort is needed to encourage householders to replace their open fires and upgrade their existing stoves, given the significant emissions reductions that this will achieve (90% for open fires and, depending on the age of the appliance, up to 80% for stoves).

For fuels, additional support for local authorities can be provided by enforcing standards at point of sale rather than at point of use. Enforcement through trading standards in this way would mean retailers facing significantly greater scrutiny and detection of infringements. This approach can be further enhanced by restricting or banning the sale of the most polluting fuels, and ensuring that remaining fuels are used in such a way that emissions are minimised. Reducing the moisture content of wood for burning is especially important in this context, with dried wood (less than 20% moisture content) having around 80% lower emissions than wet wood.

Woodsure, the UK’s woodfuel accreditation scheme, launched the Ready to Burn scheme in 2017 which provides a certification mark to woodfuel suppliers who can demonstrate that the moisture content of their product is below 20%. Woodsure was recently appointed by Defra to run Ready to Burn certification scheme in England.

The work in Scotland also has a focus on biomass installations, whereas other regions have a focus on stoves and also in the example of Wales, outdoor burning. 

The Chapter concludes with proposed actions and suggest government will: 

•  Encourage uptake of Ecodesign stoves through Ecodesign Ready and other initiatives, along with consideration of how best to address widespread replacement of pre Ecodesign appliances.
• Work with business and industry to support educational schemes such as Woodsure and Ready to Burn, including manufacturers, suppliers and users of both fuels and appliances.
• Take forward, working with businesses that may be affected and other interested parties, potential measures to control the supply of the most polluting domestic fuels – including a ban on house coal, restricting the sulphur content of smokeless fuels to 2% and prohibiting the sale of wet wood.
• In taking forward this work, we are mindful that any new measures would require to be implemented over a period of time, such as a transitional period during which businesses could adapt to the new requirements without disproportionate costs.
• In developing policies and programmes to support households and businesses in transitioning to low-carbon heating solutions, we will consider the needs of those affected by any ban on house coal and wet wood.
• Consider with local government what changes are needed to the current permitted development rights for flues for woodburning stoves and biomass boilers.
• provide further evidence on Work with local government and SEPA to consider revision of the Clean Air Act 1993.
•  Commission work to provide further evidence on the proportion of PM emissions and other key pollutants attributable to domestic burning in Scotland, together with geographic and demographic distribution of domestic

HETAS will provide further updates as plans across the UK develop further.