Public Consultation on the development of new Solid Fuel Regulations for Ireland

In response to: https://www.gov.ie/en/consultation/5de58-public-consultation-on-the-development-of-new-solid-fuel-regulations-for-ireland/


I give my thoughts on the topic below:


1. Are you in favour of a national regulation on solid fuels, and if so, why?

Yes. Because air quality is extremely important to the public's health, particularly childrens', and the use of solid fuel for heating or any other purpose worsens our air quality. There is no need to differentiate across the country, or based on being in a large town or not - the localised risk is still the same.


2. What solid fuels should be subject to regulation and why?

All of them. As they all generate Particulate Matter. The extent of regulation should be based on whether there is a domestic source of fuel or it has to be imported.


3. What standards or specifications should/could be applied to each type of solid fuel?

Will it's combustion produce local particulate matter in excess of any of the 1 hourly EU limit figures where people are in the vicinity on a still day: https://ec.europa.eu/environment/air/quality/standards.htm ? If so, it should not be permitted.


4. What do you believe are the most appropriate, implementable and enforceable regulatory approaches for each type of solid fuel?

In the first instance, it is best to look at the reasons why people are using the solid fuels in question to understand what regulatory approaches are appropriate - is it for heat or due to a custom / "hygge"? Are there barriers to switching to using another heat source, like inertia due to capital costs or disruption to their homes to retrofit? A nudge based approach should then be applied to route people away from needing to or wishing to use solid fuels. SEAI grants are good, plus a bounty for people that decomission permanently their solid fuel burning apparatus (like blocking up chimneys).

And for enforcement, the best way to assess compliance is to garner data on air quality, and react in a targeted manner across the country when air quality is seen to drop to enforce regulations. The EPA already has a network of air quality of high accuracy sensors available (https://airquality.ie/) however this should be expanded massively to garner more local data, possibly using cheaper kits like the low cost EU funded SmartCitizen kit (https://smartcitizen.me/) for example mounted outside every school in the country. The EPA should expand it's enforcement activities to focus on areas with poor air quality, as seen especially during heating season on degree days. Pethaps suspected offenders could have their emissions assessed through the erection of an air quality sensor down wind of their dwelling?

Coal: Dirtiest fuel. Stop permitting it's import. Enforce this policy with the same approach applied to tobacco products import. Design a just transition scheme to help people involved in the sale of it at the moment (with their infrastructure, maybe they could pair up with gardening centres, as they have yards & trucks to deliver to neighbourhoods?).

Peat: Stop harvesting it on an industrial scale, as has been done with Bord na Móna ceasing activities. Don't permit it's import. This will be an emotive topic, so the consultation document's approach sounds reasonable to move people away from it's use over time.

Wood: Stop importing any wood for combustion. Make it free to dispose of waste wood in recycling centres. Stop permitting the sale of wood burning stoves. Negatively grade these appliances in BER certificate assessments, far beyond what they already are presently graded for energy efficiency. Much wood burning is due to lifestyle choices rather than absolute necessity, and this is due to image of "hygge" as espoused in much of the media.


5. How can a transition to less polluting fuels and more efficient heating systems be supported? (Building upon the measures already set out in the Climate Action Plan)

Aggressive furthering of the SEAI Retrofits programme.

Placing tariffs on the sale of solid fuel in the near to medium term.

Cessation of charging the Public Service Obligation levy on electrical supply for people using it as their heat source, comensurate with decarbonisation of the grid.

Engage the public with the process, by teaching it in schools as to the importance of air quality - can be supported by provision of low cost SmartCitizen (https://smartcitizen.me/) type air quality sensors in each school

Engage with media organisations like RTE, their main content producers etc. to cease showing or glamourising solid fuel combustion, stoves etc.

Report on predicted air quality in main towns and cities as part of the weather forecast on broadcast media

Prevent through the building regulations the use of solid fuel heating sources.

Prevent the advertisement of solid fuel products & their buirning apparatuses, similar to the restrictions place for tobacco products ( https://www.tobaccocontrollaws.org/legislation/country/ireland/summary )


6. What do you think is an appropriate timeframe for the implementation of a national regulation of solid fuel?

Next few years. Draw up a roadmap, comunicate it clearly that people need to make changes in the summer to their heating solution, and assess constantly air quality throughout heating season.


7. What timeframe should be applied to the inclusion of new solid fuels into legislation to allow for the necessary transition, including the phase out of existing stocks?

Next few years, in order of most polluting to least polluting fuel.


8. Should suppliers and retailers be given a transition period to use up existing stocks of solid fuels not meeting emission standards and, if so, how long?

Yes, should expire at the end of  a heating season (i.e. springtime)


9. Are there particular challenges in terms of the enforcement of regulations applying to solid fuel burning, and how might these be best addressed?

Political will in face of conservative voters, which can be helped by bringing the public representatives up to speed with the unsustainable costs to society of addressing the externalities of solid fuel combustion. And perhaps in tourist areas special grants can be extended to a wider brand like "Green Ireland" which encourages local residents to reduce their emissions.


10. Do you have any further proposals to reduce air pollution from residential heating?

At present, the BER certificate is required for sale, and states what energy rating a dwelling has at a given time, when the dwelling is sold. In some juristictions globally, i.e. Finland, for a dwelling to be sold to a residential purchaser rather than someone to renovate, it needs to be compliant with the present day building regulations. I propose Ireland ought to adopt a similar approach. This onus to ensure buildings are compliant with modern day standards at time of sale would dramatically increase their energy performance and thereby reduce their pollution, paricularly if solid fuel appliances are precluded in building regulations. It would also encourage people to take a longer term view of their building's maintenance, to help overcome inertia to upgrade.


11. What performance standards, certification methods or quality schemes should/could be used to reduce air pollution caused by burning solid fuels?

https://www.iso.org/standard/17043.html


12. Would broadening the application of the 10 gram smoke per hour to all solid fuels be appropriate?

Sure


13. Are there any additional or different emission standards which could be applied to the broader range of fuels?

See answer to question 3 - we ought to focus on the impact in the vicinity.


14. Is it appropriate to use moisture content as a standard for the application of regulations to wood and, if so, at what limit should the moisture content be set?

I don't have the knowledge to comment


15. What limit should be set as a cut-off point for the sale of wet wood?

 Bags/nets only;

 Up to 2m3 ;

 All wet wood; or

 Other- please provide reasons or evidence to support your answer.


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