Welcome for IAQ-focused measures, but calls for more ambiton to transform domestic emissions strategy
The government’s new Clean Air Strategy - the long-awaited cross-sector response to rising international concern about the health issues from poor air quality - has been launched to a mixed reception not least from the HVAC sector, for whom it has potentially wide ranging consequences.
While some welcomed the new focus on indoor air quality, reducing domestic pollutants such as wet wood and VOC-emitting products, others criticised the lack of ambition in its proposed restrictions and its apparent overlooking of key high-volume sectors such as NOx in boilers.
The strategy sets out the action required to meet the international targets in five pollutants – fine particulate matter (PM); ammonia; nitrogen oxides; sulphur dioxide and non-methane VOCs – along with what it calls ‘tough new goals’ to cut public exposure to particulate matter pollution and new England-wide powers to control major sources of air pollution.
Another key new element is the creation of new local powers for local authorities to take action in areas with air pollution problems and the complimentary creation of clean air zones, backed up with ‘clear enforcement mechanisms.’
The government concedes that the current legislative framework has not driven sufficient action at a local level. Giving authorities new powers to tackle PM2.5 emissions from fuel burning are among the strategy’s proposals.
The strategy also seeks to tackle a range of the most significant sources of pollution, namely: transport; emissions in the home; farming; and industry; with a range of controls and technology approaches.
A new element in the latter is the £19.6 million ‘Clean Air: Analysis and Solutions’ programme, launched to enable development of new technologies, in partnership with the umbrella body UK Research and Innovation.
But it is the section on ‘tackling emissions in the home’ - namely IAQ - that has prompted most reaction from the HVAC industry: understandably, since the proposals address issues for both the heating and ventilation sectors.
The strategy acknowledges that previous air quality discussion has focused heavily on outdoor pollution (a criticism that has been levelled consistently at government by the HVAC industry), but points out that as outdoor sources are reduced, then inevitably indoor sources become comparatively more significant - noting that up to 90 per cent of the day is spent indoors and that levels of some air pollutants are often far higher than those outside.
In a move that will be welcomed by the ventilation sector, it says: “The government’s objective is to raise awareness of the potential impacts of air pollution at home and ensure that consumers are armed with reliable information, enabling them to make informed choices to protect themselves, their families and their neighbours.”
One of the strategy’s proposals, for instance, is a voluntary labelling scheme that would rate a product’s VOC emissions in the same A-G format as used under the Ecodesign regulations – a label scheme currently used in France.
At the same time, it also confirmed that Part F of the Building Regs, dealing with ventilation, will go out for consultation in spring. This, together with the general focus on IAQ has been welcomed by those involved with ventilation.
Mark Taylor of filter manufacturer Camfil said: “Camfil welcomes its recognition of the effect of IAQ on people’s health…Notable mentions include: Confirmation that the National Institute of Health and Care Excellence (NICE) is currently working on forthcoming guidance on IAQ; news that the government wants to raise public awareness of the potential impacts of indoor air pollution; and confirmation of [consultation] on changes to standards in Part F of the Building Regulations.”
Simon Birkett, from Clean Air London, who works with Camfil to improve air quality in the Capital, addded: “It is marvellous to find more than 20 mentions of indoor air quality…The strategy helpfully identifies the sources of many different indoor air pollutants and says that plans will be forthcoming to reduce them… The Strategy makes an encouraging start on indoor air quality but must be followed through quickly with meaningful action. For example, Building Bulletin 101 (BB101), which sought to improve indoor air quality in schools, was published with out-of-date standards for air filtration. Producing corrected guidance in 2019 must be a priority.”
Mr Taylor added, “The UK is the first major economy to adopt air quality goals based on WHO recommendations, going far beyond EU requirements. Let’s hope this document marks the start of real action to improve the air we breathe both outside and inside our buildings.”
The headline-grabbing proposal in tackling domestic emissions is to restrict the burning of solid fuels for heat, which the authors say now accounts for 38 per cent of national PM emissions.
The government says that it will ‘legislate to prohibit the sale of the most polluting fuels, but adds that it will issue its detailed response to a consultation on wood burning in ‘early 2019’ - amongst the proposals are restricting sale of wet wood for domestic use and phasing out house coal.
The strategy highlights the government-backed Ready to Burn standard from Woodsure, which guarantees a wood fuel moisture content of 20 per cent. This, together with the Stove Industry Alliance’s Ecodesign Ready label, which guarantees the wood burning appliance complies with 2022 levels, are seen as best practice by the government.
It also says that it wants to encourage innovation and will work with industry to identify a suitable test standard for new low emission solid fuels.
A key weapon in the government’s armoury will be to enforce smoke control legislation, within the forthcoming Environment Bill and also to give local authorities more power to require upgrades to ‘inefficient and polluting heating appliances’.
Bruce Allen, ceo of wood fuels body HETAS said: ”We welcome Defra’s 2019 Clean Air Strategy and are already working with them to bring about changes to existing smoke control legislation. Reducing particulate emissions from wood burning is an issue that the industry is working together on to ensure that the right stoves and the right fuel are part of the solution for air quality, not the problem…Stoves are only as good as the fuel you burn and our message is simple – don’t burn wet wood. If homeowners are choosing to burn wet or poor-quality wood this will increase levels of PM2.5 particulates in their emissions.”
The environmental credentials of wood-burning stoves were emphasised by the sector. Jeremy Fry, chairman of Specflue said the Ecodesign Directive would help eliminate the lowest performing wood-burners from the market. ”The upshot is that the latest wood burning stoves are helping to mitigate the impact of fossil fuels and create cleaner air…Wood is a sustainable, renewable energy source that is virtually carbon neutral. Indeed, the official government software used to measure the energy efficiency of homes (SAP) shows that it beats electricity, oil and gas on environmental performance.”
However, while the strategy highlights the recent rise in use of open fires as a contributing factor to particulate matter levels, it falls short of further legislating - seen by some in industry as a shortcoming.
Allan Wilson, test engineer with industry research body BSRIA said: “BSRIA and its members are working hard and fast to reduce emissions in wood burning stoves…Much improved appliances are already being produced that meet the high standards coming in 2022. The strategy makes a good start and heads in the right direction [but] BSRIA calls on government to reach deeper into the causes of pollution and continues to press forward in making real reductions to encourage sustainable clean combustion. The bigger problem produced by open fires and the old stock of solid fuel stoves…is yet to be addressed.”
RHI and Biomass
Part of the Strategy’s focus is to ‘drive clean growth and innovation’ and this, the government promises, will see efforts to minimise the air quality impacts of the Renewable Heat Incentive, including tackling non-compliance. This includes new rules on submitting evidence that RHI applications meet air quality standards at local and national level.
Biomass is also under the spotlight – the government recently consulted on whether to ban new biomass RHI applications if they are in urban areas and already on the gas grid. At the same time, it proposed mandatory maintenance checks on all existing RHI-funded biomass installations. The results of this consultation are expected soon.
The Strategy has also created waves with its emphasis on emissions from VOCs in the home, such as from formaldehyde, cleaning chemicals and air fresheners – an issue that IAQ experts have also frequently drawn attention to.
The government recognises that along with substituting for alternative products, the management of VOCs requires appropriate ventilation measures, and so the Strategy authors promise that domestic ventilation standards will be reviewed within Part F of the consultation.
A further criticism of the Strategy was that it hasn’t addressed the contribution of emissions from the high-volume gas boiler sector. Peter Thom, MD of Green Heat said: “Surprisingly there is no mention of either NOx or carbon emissions from older gas boilers. Is the HHIC still talking with the government on these matters, as there is a real opportunity here to get momentum for another national boiler scrappage scheme - but it needs the industry to get mobilised again.”
The Strategy was given a tepid welcome by the Mayor of London, who has introduced a commercial boiler scrappage scheme for the Capital, amongst a raft of air quality measures. Mayor Khan said: “Whilst the government has finally accepted that toxic air pollution is a national health crisis, this strategy lacks the ambition required to clean up our air.”
He added: ”Air pollution increases the risk of dementia and asthma, harms children’s lung development and hurts the poorest communities the most. The hard-hitting measures we’re taking in London are already starting to make a difference - from cleaning our bus and taxi fleet to school audits and the introduction of the world’s first Ultra-Low Emission Zone in central London this April.”
Mayor Khan called for government support for what he stressed was a public health crisis: “We still desperately need a nationwide scrappage fund to take the most polluting vehicles off our streets and additional powers in a new Clean Air Act so that city leaders can tackle all sources of air pollution.”