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:
- Regulation of wood fuels in Ireland to meet European standards.
- Regulation of firewood ensuring that no firewood may be placed for sale where the moisture content is above 20%.
- Regulations ensuring that only Eco-design appliances may be offered for sale in Ireland.
- Specifically, we noted that section 18.104.22.168 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 firstname.lastname@example.org.
Full submission can be found here