Consultation outcome

Summary of responses and government response

Updated 21 February 2020

1. Executive summary

Domestic burning through wood burning stoves and coal fires now makes up the single largest contributor to our national emissions of particulate matter (PM). The tiny particles in smoke can enter the bloodstream and enter internal organs, causing long term health issues as well as having more immediate impacts on some such as breathing problems or asthma attacks.

Defra consulted on the cleaner domestic burning of solid fuels and wood between August to October 2018. The proposals in this consultation included:

• restrictions on the sale of wet wood for domestic burning
• phasing out the sale of traditional house coal
• applying sulphur standards and smoke emission limits to all manufactured solid fuels

These proposals are in line with Defra’s Clean Air Strategy, which was published in January 2019. This sets out our strong commitment to achieving our National Emissions Ceiling targets. The targets cover five key emissions: nitrous oxides (NOx), sulphur dioxide (SO2), fine particulate matter (PM2.5), ammonia (NH3) and volatile organic compounds (VOCs). With domestic combustion being identified as the single largest contributor to PM2.5 emissions it is essential that we make changes in this area to enable us to make steps towards our targets on this pollutant, and this policy is key to this. This work also supports the Clean Growth Strategy, which sets out our commitment to phasing out high carbon fossil fuels in the future.

The World Health Organisation (WHO) recommends that countries should progressively cut public exposure to particulate matter as well as recommending against the residential use of coal. The actions set out in this government response are designed to deliver on these national and international air quality obligations, recommendations and commitments. The proposals are aimed at protecting human health, the environment and the climate by phasing out the most polluting fuels used for domestic combustion in England and encouraging a transition to less polluting fuels.

The key actions outlined in the response are as follows.

1.1 Coal

We propose a ban (with a year to use up stocks) for all pre-packaged traditional bituminous house coal (i.e. that sold through retailers, supermarkets, DIY stores). The ban will apply one year from publication of the government response. This ban will apply to loose sales direct to customers via coal merchants two years later. This will give residents time to transition to other fuels.

Concerns raised during consultation included the impact this might have on households in fuel poverty who are reliant on coal as their primary source of heating. Government was concerned that any intervention should not have an adverse impact on vulnerable groups including those in fuel poverty. As such we carried out research to assess relative costs of different fuels when taking into account energy density.

Our research found significant regional variation in prices but that manufactured solid fuels are in fact cheaper to burn on an energy density basis. Government understands that it is important that householders are provided with this information and supported in making a change which may save them money over the longer term. To deliver this, 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 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 during the transition period.

We have considered exemptions to this policy, and have decided that the Forest of Dean freeminers will be allowed to sell coal because of the volume involved, the unique nature of this tradition, and its reliance on local domestic sales.

1.2 Wood

We propose that wood sold in single units under 2m³ (loose stacked) must have a moisture content of 20% or less. Wet wood sold over these volumes will be required to come with advice on how to dry it ready for burning. Retailers will be required to store seasoned wood in such a way as to keep it dry. This will come into effect one year from publication of the government response with small foresters being given an extra year to come into compliance.

Burning wet wood can result in more than twice the amount of smoke emissions than from seasoned/dry wood. The heat output from burning wet wood is significantly reduced, and chemical buildup on the inside of the stove and chimney can increase the risk of chimney fires. Wood sold in smaller quantities is more likely to be used immediately and not dried at home, therefore we propose to limit the sales of wood sold in smaller sizes of packaging to dry wood only.

Our proposals are designed to capture net bags of logs sold by retailers such as DIY stores and garden centres for immediate use. We want to ensure occasional stove users who buy small volumes of wood for convenience are not unwittingly burning wet logs that produce high levels of smoke.

Some small foresters expressed concern that our proposal would be difficult for them and may result in them needing to invest in kilns or storage sheds, or being bought out by the bigger suppliers, leading to unnecessary transportation and kiln drying of wood. We propose to give smaller foresters an extra year to comply, and will work with them to support them in coming into compliance, for example through advice and guidance on how to store and season wood.

1.3 Manufactured solid fuels

For manufactured solid fuels, we propose to introduce a nationwide requirement (currently applying in Smoke Control Areas only) requiring a certified controlled sulphur content, (maximum 2%), and a smoke emission limit. This will be effective one year from publication of the government response.

2. Introduction

The Clean Air Strategy 2019 (“the Strategy”) states that air pollution is the top environmental risk to human health in the UK. We often think of air pollution as being caused by transport, energy production (particularly from burning of fossil fuels) or industrial processes. As the emissions from these sources have decreased through various aspects of government regulation and initiatives, the relative contribution of emissions from other sources has increased. The Strategy is clear that we now need to tackle these other sources of air pollution, including emissions caused by heating our homes, in order to continue to improve the air we all breathe.

Following publication of the Strategy for consultation in May 2018, the government announced that it would take forward the proposal to phase out the sale of the most polluting fuels and consult on measures to promote the cleaner domestic burning solid fuels and wood. The intention of this policy is to transition householders away from the most polluting fuels to cleaner alternatives.

This is the government response to that consultation (launched in August 2018) which gave more detail about the proposals set out in the Strategy, focusing on the domestic use of solid fuel in England. As well as the overall impact of domestic burning on air quality for everyone, we are concerned about the health impact this can have on individuals who use solid fuel, their families and neighbours.

The consultation considered what further steps can be taken to encourage households to make a change from dirtier to cleaner fuels. It considered a range of options focusing on phasing out the sale of the most polluting products and enabling consumers to switch to less polluting alternatives. The proposals in the consultation included:

• restrictions on the sale of wet wood for domestic burning so that it can only be purchased in volumes over a specified cut-off point
• applying sulphur standards and smoke emission limits to all manufactured solid fuels for domestic burning
• phasing out the sale of bituminous or traditional house coal for domestic burning

Note that as powers on air quality are devolved, the consultation related only to proposals for England.

3. Consultation activity

Defra undertook an 8 week consultation that ran from 17 August to 12 October 2018. This was available on Citizen Space (an online survey platform). Key stakeholders were emailed to announce the consultation. The consultation was also promoted by a press release.

4. Respondents

4.1 Questions 1 – 5 of the consultation questionnaire

1. What is your name?
2. What is your email address?
3. What is your organisation?

• Academic
• Distributor, e.g. retailer
• Fuel supplier, less than 10 employees
• Fuel supplier, 10 – 49 employees
• Fuel supplier, 50 employees or more
• Householder/individual
• Industry body
• Local authority
• NGO – Industry
• NGO Environmental
• Other – please specify

1. Would you like your response to be confidential? Yes/No
2. What is your location?

In total, we received 500 responses to this consultation.

276 organisations and 224 individuals responded. The organisations included fuel suppliers, distributors, industry bodies, local authorities and non-governmental organisations.

5. Wood

5.1 Question 6 of consultation

We are considering a cut-off point for the sale of wet wood to householders. In line with feedback from the Call for Evidence, we are proposing that this is set at 2m3, but we are inviting your views on this point. Please indicate what limit you think a cut-off point should be set at.

• Bags/nets only
• Up to 0.5m3
• Up to 1m3
• Up to 2m3
• All wet wood
• Other

Please provide reasons or evidence to support your answer.

Many respondents felt that all wet wood should be banned from sale to ensure that consumers purchasing wood were only burning dry wood. However others felt that it was important for rural households to retain the option of seasoning their own wood. Many felt that 1m³ was a more appropriate limit as some households and boat dwellers would not have the space to store 2m³ of wood. Some felt that 2m³ was an appropriate cut-off point

Many chimney sweeps felt that education was key, and that burning wet wood was an unpleasant experience. People would switch to dry wood and find that it is much easier (and more pleasant) to use in a domestic appliance.

Some respondents felt that all wood sales should be banned in smoke control areas or urban areas. Some concerns were raised around how any limit would be enforced and it was suggested that wet wood came with a warning ‘not suitable to be burnt without appropriate drying’. Other suggestions raised included the proposal that all wood sellers should be registered to ensure they are selling wood that is suitable as a fuel and informing their consumers of what they need to do if it is not yet ready to be burned.

5.2 Question 7 of consultation

Do you consider that suppliers and retailers should be given a transition period to use up existing stocks of wet wood or allow time for it to air-dry?

• No transition period
• Transition period of 1 year
• Transition period of more than 1 year

Please provide reasons or evidence to support your answer

The majority of respondents either felt that the transition period should be a year or more than a year. The general consensus was that it should be long enough to enable foresters to season logs ready for sale. It was felt that this was less relevant for larger scale retailers or those in urban areas who should be able to comply immediately. Some felt that, given the health impacts from wood burning and to get immediate benefit from the policy, there should be no transition, or as a transitionary measure wet wood could be sold to those with the facilities to dry it.

5.3 Question 8 of consultation

Do you consider that smaller suppliers and retailers should be given a longer transition period?

• Yes
• No
• Don’t know/don’t have an opinion

The majority felt that smaller suppliers and retailers should not be given a longer transition period. There was concern that differentiated implementation dates would create market distortion in a highly competitive market. Whilst urban areas have a greater air quality problem the point was made that particulate matter could easily blow from rural to urban areas, so it was important that legislation covered rural areas too.

It was suggested that perhaps much smaller businesses could request an extension if they have evidence that they are moving towards compliance.

5.4 Question 9 of consultation

We are proposing that suppliers selling wet wood in volumes larger than the agreed cut-off point should be required to provide clear instructions to their consumers about how long the wood should be “seasoned” before it is burnt. Do you agree or disagree with this proposal?

• Agree
• Disagree
• Neither agree nor disagree
• Don’t know/don’t have an opinion

The vast majority agreed that seasoning instructions should be given with any sales of wet wood. Some suggested that this should include advice to help consumers decide whether they could indeed season their own wood.

Some respondents suggested that an advice sheet should be provided with every sale/delivery of wood.

5.5 Question 10 of consultation

Do you agree or disagree that wood fuel suppliers should be required to be members of a certification scheme that provides assurance (via testing and auditing) that the wood is of a moisture content of 20% or less?

• Agree
• Disagree
• Neither agree nor disagree
• Don’t know/don’t have an opinion

The majority agreed that wood fuel suppliers should be members of a certification scheme. Some respondents felt that this had to be proportionate so that small suppliers were not unduly burdened.

5.6 Question 11 of consultation

Do you agree or disagree that retailers selling wood should be legally required to store the wood in such a way that it will not become wet?

• Yes
• No
• Don’t know/don’t have an opinion

The majority felt that retailers should be required to store the wood in such a way as to keep it dry. Several clarified that this should apply to dried/seasoned wood only and not wet wood. One representative organisation felt that it was down to the wood suppliers to ensure packaging was watertight.

5.7 Question 12 of consultation

In order to comply with the proposal to require all businesses selling wood in volumes under 2m3 to ensure that it is dried to below 20% moisture, what adjustments, if any, would your business need to make? Please select one of the following.

• Purchase a kiln to dry wood
• Buy other equipment to season wood
• Wouldn’t need to adjust
• Other

The majority of respondents suggested that they wouldn’t need to make adjustments to their business in order to comply. A small percentage felt that they would either need to invest in a kiln or other equipment to season wood and felt that government support should be available to help the transition.

Some raised the issue of planning permission within woodlands, which can be hard to get but would be required for dry storage sheds. Others felt that seasoning down to 20% would be challenging especially in the cooler parts of the country, and that 25% was more realistic. Even wood supplied at 20% might not stay at that moisture content during a damp winter. Certification could be prohibitively expensive for small foresters, and could put some of these out of business. Others raised concerns that the 20% moisture requirement might lead to increased kiln drying of wood fuel with increased carbon dioxide impacts.

5.8 Question 13 of consultation

Would you like to provide any further comments or evidence on our proposals or the questions in this section?

Various concerns were raised in this section, including the possibility of increased costs, and difficulties around enforcement, in particular related to current difficulties enforcing Smoke Control Areas. Some respondents suggested that Smoke Control Areas should be better enforced to reduce the impact of domestic burning.

Other comments included differentiation between urban areas where burning of wood was seen as largely a “nice to have” rather than in rural areas where it is perceived by some as an essential component of heating. Some suggested that there was no place for wood fuel in urban areas where most householders have easy access to much cleaner alternatives. For rural areas, respondents were concerned about those in fuel poverty and felt that support should be available to them.

Councils are required to look into complaints about smoke from premises that could be considered a statutory nuisance. Chimney smoke from houses in Smoke Control Areas are not covered by statutory nuisance laws. In those Areas, residents are not allowed to emit smoke from a chimney unless they are burning an authorised fuel or using an exempt appliance. Some respondents highlighted that smoke nuisance can occur even when exempt appliances were being used.

Many respondents raised the sale of waste wood and the burning of painted or treated wood as potentially more harmful and in need of addressing. In addition some respondents cited suppliers who market wood as dry when it is not. They felt that this legislation would not tackle these areas. As a result they felt that all wood suppliers should be approved and signed up to a code of practice along the lines of the Approved Coal Merchant Scheme.

There was a strong call for education on domestic burning with many suggesting mandatory information at point of sale of stoves and fuels, by those installing an appliance, and through chimney sweeps. It was felt that this should cover key issues such as fuel quality, storage, how to properly use a stove and the danger of self-installations. On this latter point it was suggested that stoves should only be installed by qualified competent installers or that they should require planning permission prior to installation.

Boat dwellers responded with concerns that as boats are generally small they represented a small part of the problem and that seasoning their wood was hard due to lack of space. Any changes would need time to embed for them to adjust.

6. Coal

6.1 Question 14 of consultation

Do you agree or disagree that government should phase out the use of traditional house coal for domestic combustion?

• Agree
• Disagree
• Neither agree nor disagree
• Don’t know/don’t have an opinion

While most respondents who answered this question agreed with this proposal, a sizeable minority did not agree that the use of traditional house coal (referred to as “coal” in the rest of this section) for domestic combustion should be phased out.

6.2 Question 15 of consultation

If you agree, what would be the most appropriate end date for phasing out the use of traditional house coal for domestic combustion?

• 2019
• 2020
• 2021
• Other
• Don’t know/don’t have an opinion

Please provide reasons or evidence to support your answer

It should be kept in mind that this question was framed to be answered by those who agree that the use of coal for domestic combustion should be phased out. Views were mixed, and there was no clear consensus about whether this should happen sooner or later. The most popular option was to set an end date outside of the three suggested years, ie a longer timescale. The next most popular option was to set 2019 as the end date, ie the shortest possible timescale.

A number of respondents who suggested a longer timescale used this question to express their concerns about the cost implications of switching from coal to manufactured solid fuels. These said that many people using coal do so because it is cheaper, and phasing out coal could impact on those who are most financially vulnerable. Some said that anthracite and manufactured solid fuels are very expensive and the proposals will mean a lot of people cannot afford to heat their homes. One respondent said they would give coal up tomorrow if there was an affordable alternative. However, some respondents argued that there was not a significant difference in cost between coal and manufactured solid fuels. These said that smokeless fuel is readily available, more environmentally friendly, and not significantly more expensive, and a 2-year phasing out period gives plenty of notice.

A key reason provided by some respondents who wanted to end the sale of coal sooner rather than later was that the pollution it caused was affecting the environment and people’s health. One respondent suggested that the public health benefit of ending the sale of coal outweighed any justification for delay, and another said that bituminous coal is clearly toxic. A number (including some boat-dwellers) suggested that alternatives to coal are readily available, and some suggested that there is no significant difference in cost. One respondent argued that it has been illegal to burn coal in most urban areas for a very long time, and suggested it was time to get rid of it completely. A number of respondents said government should ensure that mechanisms are in place to help those in fuel poverty.

A number of respondents considered that the use of coal should not be phased out as proposed at all. They gave a number of reasons, including suggesting that the amounts burnt for the purpose of domestic heating are not significant in terms of national coal consumption, and that government should be targeting industry instead. Some said that the amount of coal burned domestically is very low compared to burning wood. One also suggested that coal is used by poorer people with less alternative options, and wood is used by the more affluent as a lifestyle choice.

There were also concerns about the impact this would have on the coal industry. Some respondents argued that the coal industry is seeing a natural decline in coal use for domestic heating and that indigenous coal production will not continue after 2025. A number argued that the proposal would have a severe impact on those in fuel poverty (including rural households, pensioners and those off the gas grid). Some boat dwellers argued that they need to use coal given their low incomes and reliance on a single solid fuel stove. One respondent suggested that lower sulphur alternatives should be offered to the consumer which are comparable in price to coal.

Of those who agreed that the use of coal should be phased out, but to a longer timescale, many considered that householders (particularly those in fuel poverty) would need time (and perhaps financial assistance such as a scrappage scheme) to make adjustments, such as replacing their stoves with multifuel or wood burning stoves. Some considered that industry (particularly smaller businesses) would need time to adjust. One respondent suggested that manufacturers of smokeless products will see an increase in demand and will need to invest in new machinery, for example. Others were concerned about the impact on small businesses. Some asked for exemptions for those in rural areas or off the gas grid, or for specific groups such as freeminers in the Forest of Dean.

A number of respondents considered that this was not a straightforward issue. Some suggested that coal should only be phased out in urban areas. Others suggested that coal merchants in rural areas could help educate their customers and encourage them to switch to cleaner fuels. Some suggested that 2022 would be the right time to phase out the sale of coal, as this harmonised with the timescale for changes to requirements affecting Ecodesign ready stoves. One respondent suggested that an advice sheet should be provided with every sale/delivery of coal giving health warnings of the health and environmental consequences of burning coal (similar to messaging on cigarette packets).

6.3 Question 16 of consultation

In phasing out the use of traditional house coal as a domestic fuel, what do you consider is a reasonable transition period to allow industry and householders to use up existing stocks?

• No transition period
• Transition period of 1 year
• Transition period of 2 years
• Don’t know/don’t have an opinion

There was more of a consensus here, with a transition period of 2 years being the most popular option, followed by a transition period of 1 year. Few respondents considered that there should be no transition period.

6.4 Question 17 of consultation

In phasing out the use of traditional house coal as a domestic fuel, government is minded to apply this to all businesses because of the health and environmental benefits of this approach. We acknowledge this may be harder for some businesses that others. Do you agree or disagree that this approach should apply to all businesses?

• Agree
• Disagree
• Smaller businesses should be given a longer transition period
• Neither agree nor disagree
• Don’t know/don’t have an opinion

Again, there was no clear consensus here. Around half the respondents who expressed an opinion agreed with this proposal and around a third disagreed with it. Around a quarter considered that smaller businesses should be given a longer transition period.

6.5 Question 18 of consultation

If you disagree, which of the following should apply? Please select all the options you believe should apply.

• Small and micro businesses to be exempt, e.g. corner shops, independent garages, small merchants
• Other businesses to be exempt
• Coal to only be sold through authorised coal merchants
• Don’t know/don’t have an opinion

Please provide detail of which businesses should be exempt and your reasoning

Three options were provided. The most popular option was that coal should only be sold through authorised coal merchants. The next most popular option (but second by some margin) was that small and micro businesses should be exempt, for example corner shops, independent garages, small merchants. Relatively few respondents considered that other businesses should be exempt.

Respondents were given the opportunity to add detail about which businesses should be exempt. Some respondents stated that there should be no exemptions, recommending that having one set of rules keeps things simple, exemptions create loopholes and confusion, and allowing some to continue to sell highly polluting materials does not deal with the basic problem. Others used this question to make clear their opposition to phasing out the use of coal by stating that everybody should be able to sell and use coal.

A number of those who considered that authorised coal merchants should be exempt argued that the members of the current voluntary approved merchant scheme are signed up to a strict code of practice and must be able to satisfy a panel of industry peers that their customers will be able to rely on good service. Some stated that retailers have no such code of practice and will sell coal in Smoke Control Areas. Others argued that approved coal merchants know what to sell and provide a service, advising customers how to use the fuel most efficiently and also on the appliance best suited to their needs.

One of the respondents who considered that small and micro businesses should be exempt said that these are the lifeblood of local communities, especially in rural areas. Another said that many customers do not have much storage space, so being able to buy small amounts when they want from their local corner shop or garage makes sense. However, another respondent said that most coal selling businesses fall within the small or micro bracket, and exempting them would hamstring this policy.

Some respondents expressed concern about the impact this policy could have on the supply of coal for heritage steam railways, pointing out that these bring money into the economy, and that the type of coal suitable for this field is quite limited. However, others were concerned that this industry creates pollution, and wanted them to be required to take steps to mitigate this. Another stated that they wanted the current small scale distribution network available for the sale of Forest of Dean freeminer coal to be maintained given the contribution this makes to local identity and the low volumes of coal sold. A small number argued that people supplying boat dwellers should be exempt.

6.6 Question 19 of consultation

In phasing out traditional house coal as a domestic fuel, government is minded to apply the phase-out nationwide across England. Do you agree or disagree?

• Agree
• Disagree
• Neither agree nor disagree
• Don’t know/don’t have an opinion

The number of respondents agreeing with this proposal was slightly higher than the number of respondents who disagreed. A significant proportion of respondents considered that coal sales should be phased out in urban areas only.

6.7 Question 20 of consultation

Would you like to provide any further comments or evidence on our proposals or the questions in this section?

A number of respondents used this question to reiterate their support or opposition to these proposals. The following views were expressed in response to this question.

Issues in rural areas

Rural areas present no health impact on anyone so imposing a coal ban on them is unfair. Government should focus on urban areas where air quality is poorest, and measures will have greatest beneficial effect

Infrastructure doesn’t allow people reliant on coal fires to move easily to alternative fuels – mains gas may be unavailable. Gas suppliers need to be incentivised to extend their pipe networks to housing outside towns.

Government should allow coal burning in some rural areas for transitional period.

Electricity cuts happen often in winter due to inclement weather, and oil supplies rely on road networks which can be impassable in winter. Coal is needed in case of oil boiler breakdown or failure of oil delivery supplies.

Several respondents made it clear that they oppose an exemption for people in rural areas, arguing that people will simply buy coal in a “rural” area and then burn it back in their city. Some argued that legislation should not open up loopholes.

Fuel poverty

A number of respondents expressed concern about the increased cost of moving from coal to smokeless products, and the effect this would have on people in fuel poverty. Several argued that coal should remain available in areas that are off-grid, because of the impact this would have on fuel poverty.

People on limited incomes should be given greater access to insulation and solar schemes.

Government should provide grants/scrappage schemes/incentives to the financially vulnerable to encourage them to change from old coal fires to more efficient stoves.

A few respondents argued that switching from coal to cleaner fuels would not have the impact some people feared. House coal may appear to be cheaper by weight but burns faster than smokeless fuel so there is little saving overall.

A call to go further

Several respondents felt that government should go even further on solid fuel burning because of the risk it poses to health and the associated burdens on the NHS. One argued that much of the coal burned domestically has travelled a long way to get to the UK, and there are negative environmental impacts associated with this.

No need for legislation

At the other end of the spectrum, several respondents considered that government should educate people about the impact of domestic burning, but this level of regulation was not acceptable. There was some concern that phasing out coal will lead to availability issues or price increases for other fuels.

Impact on heritage steam sector

Some felt that fuel supply for this sector (steam railways and steam road engines) is only viable if there is a market for coal for domestic burning.

Boat dwellers

A number of respondents argued that boat dwellers should be exempt, given their low incomes and reliance on coal, and the relatively small contribution they make to air pollution. It was argued that boat dwellers need coal to keep warm through the night (coal provides slower, longer heat than wood) – their only method of heating their homes is usually a solid fuel stove.

Don’t include exemptions

Some argued that government should learn from past mistakes. The Clean Air Act has been undermined by exemptions, making enforcement almost impossible and costing lives.

Small businesses should be given a transition period.

Allow coal to decline naturally

The lower overall level of pollution caused by domestic burning of coal is minute in comparison to domestic burning of wood and burning coal in power stations, means regulatory action should not be necessary.

A number of respondents suggested that the use of coal in domestic settings is naturally reducing (with house coal sales reducing 10 – 15% a year). Legislation is unnecessary, and a transition period would not be needed if coal was allowed to decline naturally.

Restaurants

One respondent suggested that the use of charcoal in restaurants, and the impact this has on air quality, should be considered.

7. Manufactured Solid Fuels

7.1 Question 21 of consultation

Do you agree or disagree that government should introduce a standard for all manufactured solid fuels which confirms they are below 2% sulphur and meet a smoke emission limit of 5g /hr?

• Agree
• Disagree
• Neither agree nor disagree
• Don’t know/don’t have an opinion

A considerable majority of respondents agreed that all manufactured solid fuels should conform to a test confirming they are below 2% and emit less than 5g smoke per hour.

7.2 Question 22 of consultation

In introducing a sulphur and smoke emission standard, do you consider that there should be a transition period for suppliers and retailers?

• No transition period
• Transition period of 1 year
• Transition period of more than 1 year

Please provide reasons or evidence to support your answer

The majority of respondents recommended a transition period of more than 1 year, with a considerable number suggesting two years. Some supported no transition period at all. Many of those suggesting a longer transition period said businesses would need longer for their stocks to be sold, and those suggesting no transition period said that the environmental and climate benefits of a ban outweighed the impact on business.

7.3 Question 23 of consultation

Do you agree or disagree that, over time, the 2% sulphur limit should be further reduced to 1% sulphur?

• Agree – 1%
• Agree – some other percentage (please state below)
• Disagree
• Neither agree nor disagree
• Don’t know/don’t have an opinion

There was no clear consensus here. The number of respondents who agreed with this proposal was very similar to the number of respondents who disagreed with it.

7.4 Question 24 of consultation

Do you agree or disagree that government should introduce a clear labelling requirement to demonstrate that fuels meet the standard?

• Agree
• Disagree
• Neither agree nor disagree
• Don’t know/don’t have an opinion

The vast majority of respondents agreed that there should be a labelling requirement on solid fuel.

7.5 Question 25 of consultation

In order to comply with the proposal to phase out traditional house coal and apply sulphur and smoke emissions standards to all solid fuels, what adjustment, if any, would your business need to make? Please select one of the following.

• Would need to reformate our products
• Wouldn’t need to adjust
• Couldn’t adjust
• Other

Again, there was no clear consensus on this question. The majority of respondents who answered this question indicated that they would not need to make any adjustments to their business. However, a number advised that they would not be able to adjust in response to this proposal.

7.6 Question 26 of consultation

Would you like to provide any further comments or evidence on our proposals or the questions in this section?

Responses to this question were mainly about costs to householders and businesses of the proposals, about the impact of the proposals on those living on houseboats, on the impact of the proposals on the heritage sector, and on the feasibility of enforcement of the proposals.

8. Carbon reductions

8.1 Question 27 of consultation

Do you agree or disagree that government should, over the longer term, introduce a requirement that all manufactured solid fuels have a minimum 30% biomass content?

• Agree
• Disagree
• Neither agree nor disagree
• Don’t know

There was no clear consensus here, with a considerable number of respondents disagreeing with the proposal and suggesting there should not be a minimum biomass content for manufactured solid fuel. A smaller number agreed that there should be a minimum biomass content, with the most common suggestion being 50% biomass - other suggestions ranged from 10% to 100% biomass.

8.2 Question 28 of consultation

For businesses: If government mandated a biomass content how long would it take you to adjust?

• We wouldn’t need to adjust
• 1 year or less
• 2 years
• 3 years
• 4 years or more
• We wouldn’t be able to adjust.

A wide range of views were expressed in response to this question. Around a third of respondents who replied to this question considered that no adjustment was needed to their business. However, the number of respondents who said they would not be able to adjust at all was only slightly lower. A considerable number of the other respondents said it would take them 4 or more years to adjust.

8.3 Question 29 of consultation

Would you like to provide any further comments or evidence on our proposals or the questions in this section?

Most responses to this question were critical of including biomass in manufactured solid fuels. The criticism either focused on the possibility that growing biomass would take away space and resources for growing food, or on the efficiency of using waste biomass in these products, as the quantity of domestic supplies may not be sufficient, and imports will be required.

9. Exemptions

9.1 Question 30 of consultation

We are interested in your views on how government should support those in fuel poverty with this transition away from high-carbon fossil fuels.

A key theme raised by a number of respondents was that those in fuel poverty should be provided with financial help, mainly to move them towards more efficient and less polluting appliances. Relatively few respondents suggested that people in fuel poverty should be exempt from the requirements. One respondent argued that any exemptions would undermine the policy as they would allow the continuing supply of the most polluting fuels. Other key points raised in response to this question were that insulation could play a positive role in reducing bills and pollution, people need to be connected to the gas grid wherever possible, and that financial help should be available to private landlords, as well as homeowners and tenants.

A considerable number of those who responded to this question suggested that grants or incentives should be provided so that those in fuel poverty could upgrade to cost effective low carbon heating. Others suggested that the costs of manufactured solid fuel should be subsidised (so that it was not more expensive than coal) so that those in fuel poverty could afford to use it. Some suggested that grants should be provided to subsidise the cost of insulating homes effectively.

Respondents mainly considered that any subsidy should be provided through government grants (which should also be available to landlords), although some suggested that suppliers should provide a cheaper, less polluting product. One respondent said that the energy companies should provide the subsidy and then recoup the extra money through the charging system for their remaining customers – they would be prepared to pay a little more to help someone else stop using more polluting fuels as both would benefit. Another suggested that a measure similar to the boiler scrappage scheme should be used to help people move to cleaner sources of energy (where individuals with older, less efficient boilers received a voucher from the independent Energy Saving Trust to help them upgrade to a cleaner model). One respondent considered that a grant should be offered under a similar scheme to the Mayor of London’s Warmer Homes scheme, whereby people on benefits, or their landlords, can apply for up to £4,000 worth of improvements, including improved heating systems, insulation and draught proofing. Another suggestion was that the Winter Fuel Allowance should be extended to people in fuel poverty.

One respondent argued that subsidies were not necessary as smokeless fuels and seasoned wood provided more heat output per kilogram than smoky coal and wet wood, and were actually a more economical option – they could also be burnt on existing appliances with no modifications required.

Relatively few respondents argued for exemptions, and most of those who did wanted the exemption to apply to boat dwellers, arguing that they are usually on low incomes, they did not use much coal to heat their boat, but they would not be able to keep warm without it.

9.2 Question 31 of consultation

Would you like to provide any further comments or evidence on this section?

Several respondents flagged that the government needs to remember the impact burning wet wood and coal has on people’s health when considering the impact regulations will have on those in fuel poverty. One stated that they agree that those in fuel poverty should be supported to move away from fuels that are damaging, not only to the wider environment, but to their health and that of their neighbours. Another said that a holistic approach was needed, improving the heating system of those in fuel poverty, and also making their homes more energy efficient. They pointed out that people in fuel poverty could be living in homes with damp and mould as well as poor heating, which can be linked to respiratory conditions exacerbated by the indoor pollution caused by solid fuel heating.

A number of respondents flagged up specific difficulties in rural areas, such as not having the option of using gas. One advised that local, small scale firewood producers are part of the community, and they can supply people in fuel poverty with a good product for a reasonable price.

A number of options for helping people in fuel poverty were suggested. These included:

• clean fuel needs to be available at a cost that can compete with coal
• insulation would help those in fuel poverty use less fuel (with positive health and financial consequences), and also have a positive impact on their neighbours and on regional air pollution – an extensive home insulation programme would be in line with recent recommendations from the Committee on Climate Change
• scrap the National Concessionary Fuel Scheme as this does not incentivise a move away from solid fuel. Use the money to offset against a replacement appliance
• have an extended transition period to allow more time for those in fuel poverty to adjust, and give time for manufactured solid fuel manufacturers to develop their products and lower prices

One respondent said that most houses in the Forest of Dean have coal fireplaces, and stopping supply from the local freemines would have a considerable impact on them.

10. Implementation

10.1 Question 32 of consultation

What do you think would be an appropriate level of fixed penalty related to the sale of domestic burning products?

• £300
• £500
• Other

Of those who responded to this question, there was a fairly even split between those who thought £300 would be an appropriate level, and those who thought that £500 would be appropriate. However, the majority suggested other penalty levels. Key suggestions included that the penalty should be proportionate to the size of the business or the scale of the offence, and penalty levels should increase for repeat offences. A number of respondents expressed concern about how the proposals would be enforced. A small number suggested that penalties should not be applied when the legislation is breached.

10.2 Question 33 of consultation

Do you consider that local authorities should be required to use any funds received through fixed penalties related to the sale of domestic burning products for a specific purpose?

• Yes – please specify below
• No
• Don’t know/don’t have an opinion

More respondents considered that local authorities should be required to use any of these funds for a specific purpose, compared to those who did not (although not by a significant margin). A number of respondents put forward suggestions for how the funds could be utilised – these were mainly focused on providing additional education at all levels, from suppliers to end users of products.

Other suggestions included provision of funds for improving housing energy efficiency, and local amenity improvements such as repairing roads and tree planting initiatives.

10.3 Question 34 of consultation

Do you agree or disagree that this will deliver our objective of establishing a clear and straightforward enforcement policy, minimising burdens for Local Authorities?

• Yes
• No
• Don’t know/don’t have an opinion

Please suggest any alternative proposal that you consider to be more effective in delivering our objectives.

The number of respondents who agreed this would minimise burdens for local authorities was almost identical to the number who disagreed.

Concern was expressed by a number of respondents about the capacity of local authorities or trading standards officials to fully enforce any new legislation given other pressures on time and resources. Some local authority respondents expressed frustration that the current Smoke Control Area legislation did not enable them to take action - householders can defend their use of unsuitable fuels by arguing that they are using an exempt appliance. They suggested that this legislation should be tightened.

A number of individuals/organisations highlighted the need for additional education programmes to raise consumer awareness about fuel use as well as encouraging use of better quality stoves. There was some support for industry-led enforcement via accreditation schemes.

A small number of respondents suggested that the idea of introducing legislation should be dropped. However there were a number of individuals that suggested that the proposals did not go far enough to address air quality issues.

10.4 Question 35 of consultation

Government will provide advice and guidance to retailers selling domestic burning products. What format should this take?

• Leaflets
• Point of sale displays
• Social media
• Information provided with the product
• Other (please specify)

Of the respondents who provided an answer a significant number said that advice and guidance should be given in a number of different formats (particularly leaflets and point of sale displays) as opposed to just one information source in order to convey the message. A considerable number agreed that information should be provided with products at the time of sale as a direct message to consumers. Respondents also suggested radio and TV messaging could be an effective tool for putting points across.

11. Communications

11.1 Question 36 of consultation

What information do you think would be helpful to enable householders to reduce their impact form domestic burning?

Respondents suggested a variety of information which they felt would help consumers reduce their impact. Overall there was strong support for education of consumers on all aspects of domestic burning from appliance installation and use to fuel selection and maintenance. Many chimney sweeps who responded felt that education would be more effective than legislation. The comments received can broadly be set out in the following categories.

New users

A number of respondents considered that comprehensive information is needed which could be provided through stove installers at point of sale/installation about which fuels their appliance is designed to burn, what to burn, what to avoid and how to store it. The information could also cover how to operate the appliance effectively including how to light a fire to get up to temperature quickly, use of the air controls (some suggested that manufacturers should limit how far the air can be closed off), and maintenance requirements (frequency of sweeping)/what to look out for when finding an installer and chimney sweep. Those moving into houses with a stove would also need this information.

Fuel choice

Many respondents considered that clear information at point of sale on which are the better fuels, which is the best alternative to coal, and whether different fuels are better for different appliances. Some suggested information on the source of the wood and distance travelled would be helpful. A list of fuels and their particulate emissions would help people understand the direct correlation between fuel and effect. Several respondents suggested that people should stop burning anything other than fuels that have a clear logo, although others made clear that fuel doesn’t have to be pre-packaged to be high quality. Some suggested that wood burning should not be allowed at all in Smoke Control Areas (it is currently allowed in Defra-exempt appliances) or should be confined only to rural areas.

Wood seasoning

A number of respondents wanted information to be provided on how to season and store logs at home, best fuels to burn in terms of species and moisture for better heat production and soot reduction. Some suggested that a guide should include pictures on what seasoned wood should look like, whilst others suggested that moisture meters should be used to help householders check the moisture content of their wood.

Bonfires

Some suggested that bonfires should be stopped but good guidance on what can and cannot be burned would be helpful along with an explanation that composting of green waste is more environmentally friendly, along with information on garden waste services.

Treated waste wood

There was a feeling that awareness of this issue was quite low, and that the burning of treated waste wood was quite prevalent. Clear guidance and safeguards to ensure treated waste wood is not used as a fuel would be helpful.

Open fires

There should be a strong push to encourage a shift away from open fires which are significantly more polluting than modern efficient stoves

Health

A number of respondents supported clear messages setting out the health issues associated with domestic burning, in particular to those who are more vulnerable such as asthmatics. Information should also emphasise that domestic burning has a knock-on impact on everyone’s health, in particular domestic burners’ immediate neighbours. Advice should also be provided on carbon monoxide.

New legislation

Respondents wanted clear guidance on what the changes are, when they come into effect, why they are being made and the benefits (more heat for your money), what the new responsibilities entail and the potential penalties. In addition it was suggested that really clear guidance on what fuels can and cannot be used under existing regulations should be provided.

Local education

A number of respondents commented that this is needed to ensure householders understand their responsibilities when burning to avoid nuisance and ensure they are burning cleaner fuels in a cleaner appliance installed by a competent person, and they know how to operate it efficiently. Information delivered with council tax bills was suggested along with a list of trusted suppliers in the local area.

Other points were raised around fuel poverty, suggesting that if householders had no alternative source of heat then information will not help - whilst cheap waste fuel is still available many people will continue to buy it irrespective of any consumer information.

11.2 Question 37 of consultation

What do you consider would be the most effective way of communicating information to householders?

• Through retailers
• Appliance manufacturers
• Fuel suppliers
• Chimney sweeps
• Press
• Charities
• Social media
• Doctors surgeries
• Mail shots
• Advice with council tax
• All of the above
• Other (please specify)

Around half of all respondents to this question felt that retailers and fuel suppliers were key to providing information to householders. Just under half felt that appliance manufacturers and chimney sweeps were important and around a third felt that press, social media and council tax communications were useful routes. There was less support for communicating information through charities, mail shots and doctors’ surgeries. A third of all respondents considered that a mix of communications is likely to be most effective.

11.3 Question 38 of consultation

For householders: Where do you buy your fuel? (tick all that apply).

• Petrol stations
• DIY stores
• Supermarket
• Garden centres
• Local suppliers
• Coal merchant
• Farmer
• Online
• Other (please specify)

Around a third of respondents to this question said that they bought their fuel from a local supplier and about a quarter indicated that they bought from a coal merchant. Around 10% of respondents bought their fuel from a farmer, a similar number bought their fuel on line, and a smaller percentage bought from petrol stations, DIY stores, supermarkets and garden centres. A quarter of respondents advised that they got their fuel through other suppliers which ranged from specialist arboriculturist supplier, self supply, parks/forests, tree surgeons, supply from friends/relatives, free mines, fuel delivery boats and marinas to taking scrap wood from building sites. It should be kept in mind that the urban/rural split of respondents to this consultation may not be representative of the urban/rural split of solid fuel and wood burners across the country.

12. Additional suggestions

12.1 Question 39 of consultation

Do you have any additional comments/views that you wish to provide on the content of this consultation?

A number of respondents reiterated comments and views provided in response to other questions in this consultation. These comments are not repeated in this section.

Key additional points raised include:

• I support the proposals, but I am concerned that they will be watered down in response to opposition from users and suppliers – industry lobby groups will be looking to make a profit at government and consumers’ expense
• A prominent NGO advocated a complete prohibition on wood burning in urban areas
• I oppose the proposals, as these infringe on preferred household heating methods
• The focus of policy is wrong - government should focus on people burning waste, fence panels etc, or industry or transport
• Government should enforce existing legislation applying in Smoke Control Areas rather than introducing more
• Focusing on fuel masks the real problem - it is not the fuel which causes the problem, it is the way it is used, for example, dry wood is highly polluting when burned at lower temperatures
• Chimney/stove inspections/sweeps should be mandatory when a resident moves into a home with this type of appliance
• Set up a register of households that have solid fuel burning appliances
• Often offenders do not have to suffer the effects of their burning – they pass it downwind to their neighbours, meaning they are not motivated to change
• Government should require retailers to sell appliances only once they are notified of the approved installer
• Proposals may stop small suppliers from selling wood - this could have a negative impact as owners of small woodlands often use this income to restore habitats or establish new woodland; timber and wood left to rot in woodland emits methane
• Many small suppliers do not have the facilities to store wood under cover to achieve less than 20% moisture content
• One organisation representing small wood sellers recommended a phased introduction of the wet wood ban to take account of the extra storage space and time required to air dry timber; they also requested that any certification scheme should be affordable, taking into account the turnover of the businesses affected.
• People who gather firewood locally are not covered by the proposals
• One organisation representing the coal industry suggested that the growing wood market is far more of a problem than coal - they suggested that even dry wood was more polluting than coal on an energy density basis; they also consider that the data related to coal used in Defra’s Impact Assessment significantly overestimates the amount used domestically.
• People receiving free coal under the National Concessionary Fuel Scheme will experience hardship if they are no longer able to use this fuel. Funding under the current Energy Company Obligation should be diverted to households currently using coal so they can install alternative systems. The NCFS £600 pa grant (alternative to free coal) should then cover their energy bills.
• Existing clean air legislation exempts boat owners – this exemption should apply under these proposals
• Using alternative fuels is not practical for boat dwellers. Bottled gas heating is expensive because of the small-sized bottles required, there are fumes and a greater risk of carbon monoxide poisoning. Electric heaters are energy intensive and would have a negative air pollution impact.
• Historic houses may not be able to replace fireplaces etc without harming that which makes them noteworthy

13. Next steps – what the government plans to do as a result of the consultation

13.1 Wood

Burning wet wood can result in at least twice the amount of smoke emissions than that produced when seasoned or dry wood is burned. When wet wood is burned, the heat output is significantly reduced, and chemicals build up on the inside of the stove and chimney, which increases the risk of chimney fires. We want to reduce the use of wet wood without preventing people seasoning wet wood at home. Wood sold in smaller quantities is more likely to be used immediately, ie without being dried at home. We proposed to limit the sales of wood sold in smaller sizes of packaging to dry wood only.

There was a range of views on our proposals to restrict the sale of wet wood for domestic burning so that only dry wood can be purchased in smaller volumes. Many respondents felt that all wet wood should be banned from sale. Some respondents considered that the 2m³ cut-off point was too high, and the limit should be set at 1m³. There was some concern among small foresters that our proposals could result in buyouts by the bigger suppliers, leading to unnecessary transportation and kiln drying of wood

We intend to take forward our proposal for a mandatory certification scheme demonstrating that wood sold in volumes under 2m³ is dry (less than 20% moisture). We intend that this will apply from one year from publication of the government response. From this time, sales of wet wood in volumes under 2m³ will be prohibited

Feedback from small wood producers was that they may struggle to meet the 20% requirement straight away. We recognise the long term nature of forestry and woodland planting and management, and we fully support these activities. Given this, small suppliers will have an extra year to comply. The government is minded to consider small foresters to be those producing less than 600m³ a year, as those producing less than this volume may find it difficult to invest in the equipment necessary for seasoning. This is to give them time to season their wood down to the required level or consider changes to their business model. A proportionate approach to enforcement will be taken, with enforcement agencies working with and educating small foresters to support them in meeting the new requirements. We consider that the 2m³ threshold represents the right balance based on the range of opinions received.

In line with the views of most respondents, we intend that the prohibition should be delayed for one year to allow existing stocks to be used up, seasoning instructions should accompany all sales of wet wood, and these should be accompanied with a warning advising that the wood is not suitable to be burnt without appropriate drying. Retailers will be required to store seasoned wood in such a way as to keep it dry.

Further guidance will be provided in due course.

13.2 Coal

We received a wide range of comments on our proposals to phase out the sale of traditional house coal. Some members of the coal industry argued that this policy would damage the business of the country’s remaining coal producers, and some argued that it is disproportionate.

A number of respondents were concerned that our proposals would have a negative impact on those on low incomes in rural areas who are reliant on coal as a cheap form of heating. Several respondents flagged that the government needs to keep in mind the impact burning wet wood and coal has on people’s health when considering the impact regulations will have on those in fuel poverty. In the accompanying Impact Assessment there is a reference to evidence showing that restricting the sale of bituminous coal in Ireland led to a significant reduction in respiratory problems and premature deaths. One suggested option was to have an extended transition period to allow more time for those in fuel poverty to adjust, and give time for manufactured solid fuel manufacturers to develop their products and lower their prices.

Some respondents referred to the health benefits of phasing out traditional house coal, stating that these benefits outweighed any justification for delay and that bituminous coal is highly toxic.

Defra’s Clean Air Strategy was published in January 2019. This sets out our strong commitment to meeting our legally binding targets to reduce the amount of pollution in our atmosphere and to minimise human exposure to air pollution. The Clean Growth Strategy commits the government to phasing out high carbon fossil fuels. The World Health Organisation (WHO) recommends that countries should progressively cut public exposure to particulate matter as well as recommending against the residential use of coal. The actions set out in our proposals are designed to deliver on both of these recommendations.

Taking all factors and views into account, we intend to introduce a ban on the sale of all bagged traditional house coal. It is the government’s intention that the ban will apply from one year from publication of the government response. For a transitional period, approved coal merchants will be able to sell loose traditional house coal direct to customers. Traditional house coal direct sales will be prohibited two years after this date.

We are not looking to ban the sale of all coal. We want to see a move away from using traditional house coal towards using less polluting fuels in the domestic setting by only allowing the sale of smokeless coal (or anthracite) and low sulphur manufactured solid fuels for the purpose of domestic heating.

Government has taken seriously the concerns around fuel poverty, and considers that people in fuel poverty should be protected from the effects of more polluting fuels as much as everyone else. We have carried out further analysis to assess the impact such a policy will have on those who rely on coal as an important source of heating. Our analysis found that manufactured solid fuels are actually more efficient on an energy density basis. This makes them cheaper to burn than coal.

Government recognises that to support these households make the transition a longer time period is needed. The transition will allow coal merchants to work with their customers to help them identify alternative manufactured solid fuels which might meet their heating needs at comparable cost. A phased transition also gives additional time for the market for smokeless fuel to develop in response to the legislation and for small businesses to adjust.

We recognise that there is a risk of coal users switching to wood. We have commissioned research which indicates that there are complex behaviours related to domestic burning. That is why we are putting in place a package of measures to educate people so they move from traditional house coal to smokeless coal or manufactured solid fuels whichever is most appropriate for them. These measures include the transition period, and education through coal merchants supported by a government-led communications campaign. We should bear in mind that, even if 50% of coal users in fuel poverty switched to wood, our Impact Assessment indicates that the overall benefits of the policy remain overwhelmingly large and positive.

We will work across government to look at opportunities to align our work on air quality, clean growth and fuel poverty in future policy design.

Some representative organisations have requested an exemption for freeminers in the Forest of Dean, given the importance of this activity to local heritage and identity. We intend that the Forest of Dean freeminers will be allowed to sell coal, because the volume of coal sold (and the impact on air quality) is very low, the freemining tradition is unique to the Forest of Dean, and freemining is reliant on local domestic sales (and would become unviable if the exemption was not applied).

Some parties have highlighted their concerns about the impact of our proposals on the heritage rail sector. Since the consultation, some have asked for heritage railways to be exempted from the proposed requirements. The government fully understands the importance of our nation’s heritage industry sectors that use coal as a source of fuel. As set out in the consultation, the proposals relate to fuels used for the purpose of domestic combustion, and will not apply to other uses such as for heritage railways. An exemption is not required for this use to continue.

13.3 Manufactured solid fuels

In line with the views of a considerable majority of respondents, we intend that all manufactured solid fuels for use in domestic combustion should conform to a test confirming sulphur content is below 2%, and that the fuels emit less than 5g smoke per hour. This will be effective one year from publication of the government response. We agree with the views of the vast majority of respondents, who agreed that there should be a labelling requirement on solid fuel to demonstrate that the fuels meet the standard. We intend to introduce this requirement meaning that all manufacturers of solid fuels will need to get their products certified. Detailed guidance will be issued to support manufacturers in ensuring their products are compliant.

We want to encourage a shift from traditional house coal to manufactured solid fuels. Coal releases sulphur to varying degrees depending on where this naturally occurring fossil fuel is mined. It is acknowledged that some coal in the UK does have lower sulphur content than manufactured solid fuels. However, the actual sulphur content of bituminous coal would in practice be difficult to control and enforce. Manufactured solid fuels also contain sulphur, but it is possible to control the amount released by these fuels. A 2% sulphur limit applied to manufactured solid fuels will ensure that the sulphur content is regulated. Setting a sulphur emissions limit encourages industry to use the cleanest base materials during the manufacturing process and avoids unintended consequences resulting from the intended switch in fuels. The Impact Assessment indicates that the package of measures we intend to introduce will have combined PM2.5 and SOx emission benefits year on year.

There was no clear consensus on whether the sulphur limit should be further reduced to 1% over time. The government is minded to review the need for this in the future.

As stated in the Clean Air Strategy, new fuels, such as coffee and olive logs, are entering the market using a variety of waste or recycled products. The government wants to encourage innovation, but customers need to be certain that these products are safe to use and no testing standard currently exists.

Further research is needed to consider the most appropriate standard for these products to ensure that health and environmental impacts are minimised. Government intends to review these fuels with a view to setting any relevant standards. In the meantime, these fuels may continue to be sold outside Smoke Control Areas. They may only be sold in Smoke Control Areas if they meet the smoke and sulphur requirements. Manufacturers of these fuels may apply for certification, and the products will be approved if they meet the sulphur and smoke requirements. .

13.4 Carbon reductions

There was no clear consensus on whether the government should introduce a requirement that all manufactured solid fuels have a minimum 30% biomass content, and we will not be pursuing this option at this stage.

13.5 Implementation

In terms of implementation, the majority of respondents suggested alternatives to the suggested £300 or £500 fixed penalty levels. One key suggestion was that the penalty should be proportionate to the size of the business or the scale of the offence, and penalty levels should increase for repeat offences. The detail on this is being developed and will be included in detailed guidance.

13.6 Communications

A number of respondents highlighted that additional information was required on how to season wood and also on what and how to burn. We have produced a series of leaflets^{[footnote 1]} which are available online and have also circulated these to all local authorities. In addition we have worked with industry sectors who have developed informative guides about good burning practices^{[footnote 2]}. We will also be producing further guidance for manufacturers, retailers, consumers and local authorities to explain the new legislative requirements for solid fuel sales in England which will be published on gov.uk later this year. 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.

14. Annex A – List of organisations

The following organisations responded to the consultation (the list does not include sole traders or those that requested their response be treated in confidence).

• A. W. Mobbs & Co Ltd
• Age UK
• Aldsworth Logs
• Alford Firewood
• Anchor Logs
• Appleyards Chimney Sweeping & Services
• Ash & Embers
• Ash and Embers
• Association of Convenience Stores
• Australian Air Quality Group
• Barnsley Metropolitan Borough Council
• Basingstoke and Deane Borough Council
• Beau Woodworks
• Belper Coal
• Betty Bee Coal Merchants Ltd
• Birmingham City Council
• BL Fuels
• Bradford Council
• British Flue and Chimney Manufacturer’s Association
• British Heart Foundation
• British Retail Consortium
• Brownridge Coal
• Bruce Lindsay Coal
• BSRIA
• Buccleuch
• BurnRight
• C A A Miles
• Calderdale Council
• Calor Gas
• Camden Council
• Canal & River Trust
• Certainly Wood
• Chacombe Chimney Sweep and Services
• Charles Swann (Walsall) Ltd
• Chelmer Chimneys
• City of Bradford Metropolitan District Council
• City of London Corporation
• CJ & J Nicholls
• Clean and Go
• Clean Stove Consultants Ltd.
• ClientEarth
• Clinton Devon Estates
• Coal Merchants Federation of Great Britain
• CoalImP
• Coastal Fuels Limited
• Commercial Hygiene Services
• Confor
• Cornwall Council
• Country Land and Business Association Limited
• Cronkshaw Fold Farm
• Dorset Coppice Group
• Dovre NV
• Dusty Sweeps
• East Suffolk Council
• Eco-Fuels
• Ecuity Consulting
• Elcombe Firewood
• Energy and Utilities Alliance
• Environmental Health Lancashire
• Epping Forest District Council
• F Pritchard Coal Merchants
• F. B. Guest
• Fernwood Group Limited
• fireplace.co.uk
• Five Shires Coppicing
• FlueCube
• Forestry Commission
• Forestry England
• Forever Fuels
• Fountains Forestry
• Frantisek
• Gavin Spittlehouse
• Gemserv
• Greenwood Ecology & Conservation
• Guild of Master Chimney Sweeps
• H Waines & Son Ltd
• Hammersmith & Fulham Council
• Hampshire Coppice Craftsmen’s Group
• Hargreaves Solid Fuels
• Havant Borough Council
• Heritage Alliance
• Heritage Railway Association
• Hexham Chimney Sweeps
• Historic Narrow Boat Club
• Horsham District Council
• ICS
• Institute for Public Policy Research
• J H Aston & Son
• JA Bottomley and Sons
• James Horne Of Limerigg Ltd
• John Drury and Son
• Kernow Chimney Sweep
• Kiwa Ltd
• Lambeth Council
• Lancaster City Council
• Leos Logs
• Little Acorns Firewood
• Logs Direct
• Logs Direct Ltd
• London Borough of Camden
• London Borough of Hammersmith and Fulham
• London Borough of Islington
• London Borough of Waltham Forest
• London Councils
• M&G Solid Fuels LLP
• Mayor of London
• Mole Valley Farmers Ltd
• Morgan Chimney Sweeps Ltd
• Mr Chimney 4 U
• Mr Soot Chimney Sweep
• National Bargee Travellers Association
• National Coppice Federation
• National Traction Engine Trust
• Newton & Sims
• North West Stove Installations
• Northumberland Logs
• Otley Neighbourhood Plan
• Oxbow
• Paul Rogers & Sons Coal Merchant
• R Dewhurst and Son
• Rackhams
• RD Jaggard and Son
• RDI Associates
• Red Horse Fuels and County Suppliers
• Redcar & Cleveland Borough Council
• Redford Tech
• RedHorsevale Ltd
• Richard Dewhurst & Sons Ltd
• Richard Smalley Technical Services
• Rivenwood Coppice
• Royal Borough of Kensington and Chelsea
• Royal Forest of Dean Freeminers Association
• Rugby Borough Council
• Sam Wilkinson Solid Fuels Ltd
• Say it with Wood
• Serious About Soot
• Severn Valley Railway
• Smoky Pistols
• Solid Fuel Association
• Solid Fuel Technology Institute
• South Lakeland District Council
• Southwark Council
• Spelthorne Borough Council
• Step in Time Chimney Services
• Stephen McCarthy Coal
• Stourhead (Western) Estate
• Stove Industry Alliance
• Surrey Air Alliance
• Sustainable Energy Association
• Tees Valley Firewood
• Thanet District Council
• The Agg Arborists
• The Association of Convenience Stores
• The Association of Professional Independent Chimney Sweeps
• The Coal man
• The Federation of British Historic Vehicle Clubs
• The Flueman
• The Heritage Alliance
• The Transport Trust
• Thomas Welch and Sons
• Three Copse Woodland Products
• TL Chimneys
• Toms Chimney Sweep Service
• Tower Hamlets Council
• Transport Trust
• Tree Solutions
• UK Pellet Council
• Wesnet Services Ltd
• West Somerset Railway plc
• Wildlife Trust Beds Cambs and Northants
• Wilson Coal
• Wirral Council
• Wood Heat Association & Renewable Energy Association
• Woodmatters

1. Leaflets include:

   How to get the most from your stove or open fire - a guide to buying, storing and seasoning wood

   Open fires and wood burning stoves – a practical guide

   Smoke Control Areas: Do you know the rules? ↩

2. www.burnright.co.uk

   http://woodsure.co.uk/firewood-ready-to-burn/ ↩