An updated proposal from IrBEA to regulate the moisture content of firewood for sale in Ireland

The Irish Bioenergy Association (IrBEA) has previously submitted an outline proposal to the Department of Communications, Climate Action and the Environment for the regulation by the Department of the moisture content of firewood for sale for domestic combustion. This document updates the previous proposal and suggests a pathway and timeline for regulation of the moisture content of firewood for sale.
The objectives of the proposal to regulate the moisture content of firewood for sale are:

  • To contribute to improving air quality in Ireland in the context of the developing Clean air
    Strategy, the recent EPA report Air Quality in Ireland 20181, and the CAFE Directive, and
  • To enable the continued use of sustainable firewood fuel in domestic heating as a replacement
    for fossil fuel and thereby contribute to climate change mitigation.

Read the full document here

IrBEA responds to consultation on the Draft National Air Pollution Control Programme

IrBEA responded to the Department of Environment, Climate Action and Communication  consultation on the draft National Air Pollution Control Programme (NAPCP) before the January 22nd deadline. The main points raised in the IrBEA response were as follows:

  • The draft NAPCP recognises proposals for roll out of a large number of heat pumps in domestic homes over the next decade. IrBEA highlighted that heat pumps will only be able to partially decarbonise our economy considering the cost of retrofit, availability of labour and age profile / energy efficiency of the housing stock across the country.
  • The decarbonisation of heat will need to include wood fuel systems in domestic houses, particularly in larger and older houses and those in rural areas.
  • Less than half of Irelands heating requirements are at temperatures suitable for heat pumps.
  • Any heating above 60OC will need to be decarbonised using a technology other than a heat pumps and bioenergy has a major part to play at all temperatures.
  • The use of properly designed appliances for wood fuels have a dramatic impact on particulate emissions
  • The draft NAPCP notes that solid fuels have traditionally been a source of particulate matter. In the report, it notes that from 1990 to 2018, air quality control measures have resulted in a reduction of particulate matter from residential heating by 73%. It noted that in the same period of time all other sources have reduced their emissions by approximately 30%.
  • To date firewood is not regulated and the market contains large quantities of wet firewood.
  • We highlighted that IrBEA is calling for the regulation of firewood to ensure that only dry firewood is sold on the market. We envisage significant reductions of emissions if firewood is regulated.
  • The draft NAPCP includes additional measures. IrBEA noted that the measures listed do not include some measures which have a significant impact in reducing particulate matter and other harmful emissions to air from solid fuel combustion. We propose that additional measures include:
  1. Regulation of wood fuels in Ireland to meet European standards.
  2. Regulation of firewood ensuring that no firewood may be placed for sale where the moisture content is above 20%.
  3. Regulations ensuring that only Eco-design appliances may be offered for sale in Ireland.
  • Specifically, we noted that section 4.2.2.3 listed wood as a major source of harmful emissions. We propose that this be altered to describe wet or unseasoned wood as being the major source of harmful emissions. We ask that the document recognise the positive aspects of properly dried wood fuel on air emissions.
  • We noted that fossil gas fuel is described in the document as a clean fuel. While in terms of localised air emissions fossil gas may be considered “clean”, we propose that the document recognises that fossil gas is not clean in the global context neither in terms of its point of extraction nor in terms of its overall impact on the climate
  • We object to the document proposing that fossil gas be considered as an ongoing or future solution to air emissions.

For further details on the IrBEA submission please contact IrBEA Technical Executive, Noel Gavigan at noelgavigan@irbea.org.

Full submission can be found here

UK Retailers Could Face Limit on Sales of Wet Wood

Retailers could face restrictions on selling wet wood as a fuel for household heating, under plans announced by UK government this week (17 August) to tackle particulate air pollution. This is among the measures set out in a call for evidence, outlining further plans for legislation on the burning of solid fuels like wood and coal, following on from the launch of the government’s Clean Air Strategy this summer. According to Department of Environment Food and Rural Affairs, UK (DEFRA), the burning of wood and coal in the home is the largest single contributor to particulate matter pollution – and has been identified by the World Health Organization as the most damaging air pollutant. Domestic burning contributes 38% of particulate matter pollution, compared with 16% from industrial combustion and only 12% from road transport, it is claimed.
The consultation proposes a series of measures aimed at reducing particulate matter emissions from domestic fuel combustion, including restricting the sale of wet wood for domestic burning, applying sulphur standards and smoke emission limits to all solid fuels and phasing out the sale of traditional house coal. The government has said it will also ensure that “only the cleanest stoves” are available for sale by 2022.

Related links
-Air Quality News article in full here

Consultation on cleaner domestic burning of solid fuels and wood