Appendix 3: Draft Air Quality (Domestic Solid Fuels Standards) (England) Regulations 2020
Additional information from the Department for the Environment, Food and Rural Affairs
Q1: The EM states at para 7.3 that the “princip[al] change is that we will be phasing out the supply of traditional house coal, wet wood sold in units up to 2m³, and introducing sulphur and smoke emission limits for manufactured solid fuels”. How will this be achieved and from when?
A1: There will be a phased approach to restricting the sale of the three fuels mentioned above;
- Traditional house coal (aka Bituminous coal) will be phased out from sale for use in domestic combustion as follows;
- From 1 May 2021 it will no longer be possible to sell bituminous coal in bags, it will only be possible to sell bituminous coal loose via an approved coal merchant.
- From 1 May 2023 it will no longer be possible to sell bituminous coal for using in a domestic setting.
- Wet wood sales for domestic combustion;
- From 1 May 2021 it will no longer be possible to sell wood that is not certified as having a moisture content of 20% or below in volumes of less than 2m3
- From 1 May 2021 it will still be possible to sell wood in volumes of 2m3 or more that has moisture content above 20% that can be dried at home by the consumer. It will be a requirement that suppliers provide guidance to consumers on how to dry wood at home to ensure it is not burnt until it is sufficiently dried.
- Sulphur and smoke limits for Manufactured Solid Fuels (MSFs);
- From 1 May 2021 it will no longer be possible sell MSFs that exceed a sulphur content of 2% and have smoke emissions of 5g or more per hour.
Both Wood in volumes of less than 2m3 and all MSFs will need to be certified to enable them to show they meet the restrictions and are therefore legal to be sold. The restrictions set out above apply in England ONLY.
Q2: Para 10.4 refers to a mandatory certification scheme—are provisions made for this in this instrument? Can you explain how this new scheme will operate?
A2: There are provisions in the instrument for the certification body for both wood and manufactured solid fuels.
The full details of how the scheme will operate are contained within the instrument (part 2, regulation 5 and part 4, regulation 11) certification will be required it enable small volumes of wood (below 2m3) or MSFs to be sold in England. The packaging of these fuels will carry the approved logo for the certification body and provide the certification no. of the supply and name. This will enable for easy identification for consumers and enforcement.
Q3: The same para refers to a year’s delay before the certification scheme is implemented—when will this new scheme start?
A3: The scheme will come into effect from 1 May 2021, the years delay refers to the time between the Government response being published announcing our policy intent (published 21 February 2020) and the legislation coming into force. This has been extended to the 1 May 2021 to come into force at the end of the burning season rather than part way through.
Q4: The same para also refers to an extra year for smaller suppliers—is that on top of the year’s delay referred to previously and who qualifies as a “smaller” supplier? From when will smaller suppliers have to comply fully?
A4: A small supplier or small forester is a person who for the purposes of these regulations supplied less than 600 cubic metres of wood for the period of one year ending 30th April 2021. Small foresters will be required to comply with the legislation fully by 1 May 2022, which would give them an extra year from the initial enforcement date of 1 May 2021.
Q5: Para 10.7 states that “We have carried out analysis which shows that manufactured solid fuels are actually cheaper to burn than coal when energy efficiency is taken into account”. Can all burners that use traditional house coal operate using manufactured solid fuels? Could you provide a summary of the analysis that the Department carried out in relation to the expected impact of the proposed measures on those in fuel poverty and could you set out its key findings please?
A5: We commissioned a report looking a heat outputs of six different fuels, the full report can be found here but I have provided a high level summary below.
We have considered the financial impact on households switching from coal to manufactured solid fuels and commissioned research into the associated costs. The test results indicated that, whilst on face value (i.e. price per bag of fuel) manufactured solid fuels (MSF) are more expensive, they burn more efficiently than coal. This means that the cheapest MSFs, which are available in all areas of England, are in general less expensive on a heat output basis than coal.
Below is data taken from the report commissioned and shows that MSFs are consistently cheaper across England when compared to coal. When fuels where brought in bags MSF 2 was cheaper overall than both coal and MSF 1, when brought in bulk MSF 1 was cheaper than both house coal and MSF 2.
These tests were carried out on an open fire as it is not recommended that coal is burned on appliances other than open fires.
|
Region |
Purchase Cost (£/kg)–Fuel brought in bags |
|||||||||||
|
Average |
Maximum |
Minimum |
Heat output cost (£/useful kWh output) |
|||||||||
|
House Coal |
MSF 1 |
MSF 2 |
House Coal |
MSF 1 |
MSF 2 |
House Coal |
MSF 1 |
MSF 2 |
House Coal |
MSF 1 |
MSF 2 |
|
|
NE |
0.36 |
0.56 |
0.48 |
0.37 |
0.73 |
0.56 |
0.35 |
0.31 |
0.39 |
0.16571 |
0.17414 |
0.16193 |
|
NW |
0.39 |
0.46 |
0.43 |
0.46 |
0.60 |
0.56 |
0.32 |
0.31 |
0.33 |
0.17802 |
0.14507 |
0.14386 |
|
M |
0.37 |
0.43 |
0.44 |
0.39 |
0.49 |
0.54 |
0.35 |
0.31 |
0.39 |
0.17076 |
0.13382 |
0.14916 |
|
SE |
0.45 |
0.62 |
0.54 |
0.50 |
0.75 |
0.64 |
0.40 |
0.34 |
0.42 |
0.20883 |
0.19519 |
0.18283 |
|
SW |
0.37 |
0.40 |
0.39 |
0.37 |
0.50 |
0.39 |
0.37 |
0.31 |
0.39 |
0.17030 |
0.12606 |
0.13176 |
|
Region |
Purchase Cost (£/kg)–Fuel brought in bags |
|||||||||||
|
Average |
Maximum |
Minimum |
Heat output cost (£/useful kWh output) |
|||||||||
|
House Coal |
MSF 1 |
MSF 2 |
House Coal |
MSF 1 |
MSF 2 |
House Coal |
MSF 1 |
MSF 2 |
House Coal |
MSF 1 |
MSF 2 |
|
|
NE |
0.36 |
0.33 |
0.35 |
0.37 |
0.38 |
0.35 |
0.35 |
0.28 |
0.35 |
0.15010 |
0.10383 |
0.11825 |
|
NW |
0.39 |
0.31 |
0.35 |
0.46 |
0.34 |
0.36 |
0.32 |
0.28 |
0.35 |
0.13296 |
0.09740 |
0.11993 |
|
M |
0.37 |
0.39 |
0.37 |
0.39 |
0.47 |
0.40 |
0.35 |
0.28 |
0.35 |
0.16418 |
0.12173 |
0.12585 |
|
SE |
0.45 |
0.45 |
0.45 |
0.50 |
0.64 |
0.53 |
0.40 |
0.31 |
0.38 |
0.18311 |
0.14157 |
0.15286 |
|
SW |
0.37 |
0.28 |
0.35 |
0.37 |
0.28 |
0.35 |
0.37 |
0.28 |
0.35 |
0.15561 |
0.08864 |
0.11825 |
Q6: Given the vulnerability of many people in fuel poverty—will the Department rely on coal merchants to inform their customers of the new rules or will there be an information campaign targeting those in fuel poverty?
A6: Loose sales of traditional house coal sold direct to customers via coal merchants will be given an extra 2 years to come into compliance. This transition period will enable government to work with coal merchants through the Approved Coal Merchants’ Scheme to advise and educate direct delivery customers with a view to switching them from coal to manufactured solid fuels. As stated in the Clean Air Strategy, we will develop a dedicated communications campaign targeted at domestic burners. This will explain the new requirements and encourage people to burn better and reduce harmful emissions. In response to requests for local education to help householders understand their responsibilities, we will develop plans for providing training for local authorities to help them provide advice to residents in their local areas.
21 August & 1 September 2020