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THIS CONSULTATION IS NOW CLOSED.  BELOW ARE THE DETAILS OF THE GUILD’S OFFICIAL RESPONSE

We have prepared a response for you to use in the government fuel consultation. We have prepared a letter to send to your MP. Download them here –

Defra Fuels Response

MP Fuels Letter

Or you can view and copy them at the end of this post.

  • What is happening?
  • Why your response makes a BIG difference.
  • Act now – what to do.

The Guild has worked hard to produce a suggested response for you to submit to the government fuels consultation. The Government is finalizing policy ahead of new legislation on fuels and in particular on wood.  This is the final opportunity (closes next Friday) to provide your expert opinions on fuels. Your responses will inform and influence the legislation. The government are keen to hear from as many of us as possible, if we don’t tell them what we think, they will still act but it may not be in the interests of you or your customers.
A good response from sweeps will make a big difference to the power of our voice with government and within our own industry. If you don’t say something, the government won’t even know you exist. Please do it NOW. The consultation closes on Friday 12th Oct.

We won’t get the opportunity to do this again.

The response mostly covers possible legislation on wet wood which we feel won’t work and could cause multiple unforeseen problems. You can send any response you wish but the most important thing is that you actually respond.

What to do.
There are 3 things to do: We have made it easy for you.

• Send the response to Defra.
• Send the letter to your MP
• Spread this message to local log suppliers and installers

Sending to Defra
Use this link – DEFRA FUELS RESPONSE  download the response. It is also reproduced at the end of this post so you can copy it from here. Then insert your name, address etc. and email it to Defra at cleanair.consultations@defra.gsi.gov.uk

Or

Go to the consultation questionnaire at https://consult.defra.gov.uk/airquality/domestic-solid-fuel-regulations/consultation/intro/ Fill in your details and copy the prepared response in to the answer box for question 6. Answer any other questions you like and submit it to Defra.

Sending to your local MP
Your local MP may know little or nothing about this consultation. Use this link –  MP FUEL LETTER to find your local MP and send them the letter. Every letter counts.

Sending to others
Please forward the link to this information to the local small log dealers you recommend and to the installers you recommend / work with. Most of them are unlikely to even know there is a consultation happening let alone the possible changes that may affect their work.

The consultation ends next Friday 12th Oct. Please act now to make a permanent difference.

If you have any questions please send them to info@guildofmasterchimneysweeps.co.uk

 

Suggested consultation response – copy and send this to Defra using the email details above.

Your name
Your Address
Your occupation

Dear Local Air Quality Team,

Thank you for giving me the opportunity to respond to the consultation on cleaner domestic burning of solid fuels and wood.

While broadly welcoming the recommendations and emerging policy, I feel that the proposed ‘ban’ on wet wood below a certain volume is misguided, and would urge DEFRA abandon any such moves in this area.

First and foremost, it is important to understand that as a sweep, I have no vested financial interest in whether legislation covering the sale of wet wood is brought in or not as I do not sell wood. It would not affect my businesses – chimneys would still need to be cleaned.
Sweeps have an over-arching view of the industry. Uniquely within the industry, as individuals we will attend hundreds (some over 1000) appliances and chimneys per year. Also uniquely, many visits will be to repeat customers allowing for ongoing observation and comparison of the fuel / appliance / user interactions that contribute to unnecessary air pollution. We continually observe the “real life” situations. Professional sweeps tend to belong to trade associations where formal training, mentoring and ongoing learning are encouraged and common. The issues of inefficient burning, air pollution and consumer advice are a common topic of conversation. We are also commonly organised in to informal online “self help” forums for the sharing of information and ideas. Our concerns come from a purely independent standpoint, based on the massive collective experience of our industry over several decades.

I am concerned that any legislation regarding the sale of wood will simply not work to effectively reduce emissions. Even well-meaning legislation may have unintended consequences which could hinder the main goal; to reduce pollution.
As such I view legislation as unnecessary and possibly even counter- productive. All wood starts out life as wet. It’s not the fuel itself which is the issue, it’s the way it is used. The driest wood is highly polluting when burned at lower temperatures. This is a common problem. Focusing on wet wood with legislation runs the real risk of masking the greater issue, with consumers still left unaware of the pollution problems concerning appliance operation, fuel mixing, stove design, maintenance etc.
I would like to make you aware of the points below.

Wet Wood – Literally A Non-Starter
The issue of wet wood is, in my view, a red herring in this debate. Firstly, wet wood is difficult to ignite. Those who try to use wet wood are disappointed by the result and the heat produced and tend not to persevere. Modern efficient stoves simply don’t light properly or stall and go out if wet wood is used. Additional issues of blacking of stove glass and physical problems with deposits in the chimney mean that users rarely proceed far with using wet wood. In my work I highlight cost, safely and pollution issues to consumers with regard to wet wood and find that this generally works well.
I believe that any legislation on wet wood would be accompanied by powerful consumer messages from authorities and from private companies who supply fuel. I are concerned that such messages could lead many consumers to believe that as long as they use dry “regulated” wood, then they are doing all that is necessary to cut pollution, which is certainly not the case. I believe this could weaken or confuse the more important combination of fuel / appliance / control messages which deal with the majority of the unnecessary pollution.

I am are aware of concerns over the moisture content of wood sold in “small nets” or “small bags”, typically from petrol filling stations, DIY stores, garden centres etc. These “small bags” can typically be lifted in to the back of a car by the average person. Customers purchasing these products tend to be less aware of what they are buying and they will generally try to use these products straight away. I believe these consumers are more likely to live in towns and cities. I believe they constitute a small percentage of all wood fuel burned.

Dry wood – the “hidden” problem
The issue of air pollution caused by burning dry wood at lower temperature is a much bigger but largely hidden problem. As a sweep I base my information on collective observations of thousands of real life situations. The majority of wood is now burned in closed appliances – stoves. The driest of wood becomes a highly polluting fuel if the air supply to the stove is reduced too much because the burning temperature drops too low. By design, the large majority of over 1 million stoves already installed are capable of being turned from a relatively clean burning and efficient appliance in to a highly polluting appliance at the “flick of a switch”. Stove users are often unaware that simply by moving the air control to “turn down” their stove, they are now wasting their fuel and creating unnecessary air pollution. The amount of pollution will vary with the degree to which the air is reduced and the burning temperature drops. The worst offenders with an average stove can load up with e.g. three kilos of dry wood, close off the air to slow everything down and easily emit a kilo or more of unburned fuel and particulate from the chimney. Regulating the sale of wet wood will have no effect on the way that users operate their stoves and therefore will not solve the main issue. I believe that consumer education and awareness is the most effective and cheapest way to address this main issue.

Professional sweeps find that sound consumer advice regarding the benefits of dry wood and the problems associated with burning wet wood are well received. I also find that good consumer fuel sourcing and storage advice helps in moving a wet wood user to good habits. I attend many of my customers annually and am able to offer additional best practice advice on an ongoing basis. I find this works well.

Effect on Small to Medium Sized businesses
There are many businesses delivering a valuable service providing locally-sourced and locally processed logs to local customers. Often these businesses are virtually “invisible”. Some are simply a phone number which is passed by word of mouth. Sweeps tend to know all the good local log dealers because our customers often ask where they can source fuel. Their logs are generally ready to use or if not, the advice will be to “season” / further dry at the consumers home. Such businesses may be small / medium farmers, ‘farm gate’ enterprises, e.g. a tree surgeon, groundcare or gardener. Others may be small family businesses with two or three employees. I are concerned that the extra costs/red tape of a mandatory regulatory scheme may affect the viability of their log business. Additionally, if their log business is affected this could increase the cost of supplying their core services to customers. Local volunteer/community based services could also suffer along with conservation groups and recreation providers. Golf clubs, woodland charities, conservation bodies, angling clubs, country parks, etc must all undertake essential tree management. The sale of logs from this management can generate a small income or help with the costs of the management. This type of small scale situation is repeated in thousands of locations around the country. Regulation of their activity could seriously affect the ability of these producers to source, process and sell a good local product to local consumers. In this instance their supplementary income and contribution to their local community may be lost for ever. I would wish to be able to continue to refer my customers to the best local dealers but fear that any regulation would significantly reduce their numbers.

Environmental Impact
I have been made aware that large wood fuel companies are “desperate” to locate small wood producers and log suppliers in order to secure their raw material as wholesale product. I believe that any regulation on wood will remove many of the small local suppliers due to cost and red tape. If many small suppliers can no longer legally sell logs in smaller volumes then their product is likely to become waste or wholesale.
Waste is just that – somehow disposed of without further use and possibly at some cost. Wholesale – it seems that the wood will be collected by large companies, shipped to large, kiln drying factories (by road – creating emissions), dried out in kilns (again creating emissions) and then transported to the end user (creating yet more emissions). Cost of the end product to consumers would be likely to rise. It is highly unlikely that large scale suppliers would find it economical to have wood onsite to ‘dry out’, and if they did the associated costs would inevitably push up prices. These situations may impact on fuel poverty. Although we are not discussing carbon footprint, it also does not make sense to increase the carbon footprint of wood fuel in this way.

Consumer value / fuel poverty
I feel that any regulation is likely to increase the cost of wood fuel to consumers due to increased costs / red tape for suppliers and a likely reduction in the number of small local suppliers.
Some consumers deliberately seek to buy wet wood in order to store and dry it for future use. This product is usually sourced locally from small suppliers at a significantly reduced price. I would not wish to see the supply of this product become illegal.
Some small suppliers have limited storage space and it suits them to sell their product at a reduced price to consumers seeking to process / dry it further. In this instance I am concerned that any regulation will render the product as waste or wholesale.
It is useful to refer my customers to local suppliers who can provide wet wood for storing. I would not wish to see these suppliers and their product disappear due to regulation.

How would legislation be enforced?
DEFRA has indicated that local councils would have the power to enforce any new legislation on wet wood sales. The reality is though that enforcement of any kind is difficult to police and very resource-intensive. I am concerned about the burning of unauthorised fuels on open fires in Smoke Control Areas (mostly house coal, wood logs). There is already legislation to cover this misuse of fuel but it appears it is difficult to enforce. Consumer awareness messages regarding fuels used on open fires in Smoke Control Areas have been virtually non-existent over the last 20 years. I believe that good consumer awareness messages in this regard can provide good results.

Conclusion
Legislation on the sale of wet wood is, unnecessary, difficult and costly to enforce and may actually create more harm – environmentally, economically and politically – than envisaged. It is also possible that it actually masks the main causes and hinders progress. The delivery of consumer messages and advice concerning efficient combustion and air quality issues are a simple matter for a professional chimney sweep as they align perfectly with all our other useful consumer information on saving money, safety etc. Education has been at the heart of government policy for years. It has worked in the past and it can work again.

The answer to cutting emissions from our existing stock of domestic fires is education, not legislation.

Yours sincerely

Your name here

 

MP fuels letter 

Your local MP may know little or nothing about the fuels consultation. Please forward them this letter to make them aware of some of the issues.

To find your local MP contact details, please visit www.theyworkforyou.com and enter your postcode.

Copy and send this letter to your MP

Dear (insert your MP’s name here)

I am writing you as my local Member of Parliament on a matter which, if passed into law, would have directly negative impact on local residents, businesses and the environment.

As you may be aware, the Government is currently consulting on cleaner domestic burning of solid fuels and wood.

While broadly welcoming the recommendations and emerging policy, I feel that the proposed ‘ban’ on wet wood below a certain volume is misguided, and would urge DEFRA abandon any such moves in this area.

First and foremost, it is important to understand that as a sweep, I have no vested financial interest in whether legislation covering the sale of wet wood is brought in or not as I do not sell wood. It would not affect my businesses – chimneys would still need to be cleaned.
Sweeps have an over-arching view of the industry. Uniquely within the industry, as individuals we will attend hundreds (some over 1000) appliances and chimneys per year. Also uniquely, many visits will be to repeat customers allowing for ongoing observation and comparison of the fuel / appliance / user interactions that contribute to unnecessary air pollution. We continually observe the “real life” situations. Professional sweeps tend to belong to trade associations where formal training, mentoring and ongoing learning are encouraged and common. The issues of inefficient burning, air pollution and consumer advice are a common topic of conversation. We are also commonly organised in to informal online “self help” forums for the sharing of information and ideas. Our concerns come from a purely independent standpoint, based on the massive collective experience of our industry over several decades.

I am concerned that any legislation regarding the sale of wood will simply not work to effectively reduce emissions. Even well-meaning legislation may have unintended consequences which could hinder the main goal; to reduce pollution.
As such I view legislation as unnecessary and possibly even counter- productive. All wood starts out life as wet. It’s not the fuel itself which is the issue, it’s the way it is used. The driest wood is highly polluting when burned at lower temperatures. This is a common but almost completely overlooked problem. Focusing on wet wood with legislation runs the real risk of masking the greater issue, with consumers still left unaware of the pollution problems concerning appliance operation, fuel mixing, stove design, maintenance etc. I hope you will take the points below into account.

Wet Wood – Literally A Non-Starter
The issue of wet wood is, in my view, a red herring in this debate. Wet wood is difficult to ignite. Those who try to use wet wood are disappointed by the result and the heat produced and they tend not to persevere. Modern efficient stoves simply don’t light properly or stall and go out if wet wood is used. Additional issues of blacking of stove glass and physical problems with deposits in the chimney mean that users rarely proceed far with using wet wood. In my work I highlight cost, safely and pollution issues to consumers with regard to wet wood and find that this generally works well.
I believe that any legislation on wet wood would be accompanied by powerful consumer messages from authorities and from private companies who supply fuel. I are concerned that such messages could lead many consumers to believe that as long as they use dry “regulated” wood, then they are doing all that is necessary to cut pollution, which is certainly not the case. I believe this could weaken or confuse the more important combination of fuel / appliance / control messages which deal with the majority of the unnecessary pollution.

I am are aware of concerns over the moisture content of wood sold in “small nets” or “small bags”, typically from petrol filling stations, DIY stores, garden centres etc. These “small bags” can typically be lifted in to the back of a car by the average person. Customers purchasing these products tend to be less aware of what they are buying and they will generally try to use these products straight away. I believe these consumers are more likely to live in towns and cities. I believe they constitute a small percentage of all wood fuel burned.

Dry wood – the “hidden” problem
The issue of air pollution caused by burning dry wood at lower temperature is a much bigger but largely hidden problem. As a sweep I base my information on collective observations of thousands of real life situations. The majority of wood is now burned in closed appliances – stoves. The driest of wood becomes a highly polluting fuel if the air supply to the stove is reduced too much because the burning temperature is now too low. By design, the large majority of over 1 million stoves already installed are capable of being turned from a relatively clean burning and efficient appliance in to a highly polluting appliance at the “flick of a switch”. Appliance users are often unaware that simply by moving the air control to “turn down” their stove, they are now wasting their fuel and creating unnecessary air pollution. The amount of pollution will vary with the degree to which the air is reduced and the burning temperature drops. The worst offenders with an average stove can load up with e.g. three kilos of dry wood, close off the air to slow everything down and easily emit a kilo or more of unburned fuel and particulate from the chimney. Regulating the sale of wet wood will have no effect on the way that users operate their stoves and therefore will not solve the main issue. I believe that consumer education and awareness is the most effective and cheapest way to address this main issue.

Professional sweeps find that sound consumer advice regarding the benefits of dry wood and the problems associated with burning wet wood are well received. I also find that good consumer sourcing and storage advice help in moving a wet wood user to good habits. As I attend many of their customers regularly, I am able to offer additional best practice advice on an ongoing basis. I find this works.

Effect on Small to Medium Sized businesses
There are many businesses delivering a valuable service providing locally-sourced and locally processed logs to local customers. Often these businesses are virtually “invisible”. Some are simply a phone number which is passed by word of mouth. Sweeps tend to know all the good local log dealers because our customers often ask where they can source fuel. Their logs are generally ready to use or if not, the advice will be to “season” / further dry at the consumers home. Such businesses may be small / medium farmers, ‘farm gate’ enterprises, e.g. a tree surgeon, groundcare or gardener. Others may be small family businesses with two or three employees. I are concerned that the extra costs/red tape of a mandatory regulatory scheme may affect the viability of their log business. Additionally, if their log business is affected this could increase the cost of supplying their core services to customers. Local volunteer/community based services could also suffer along with conservation groups and recreation providers. Golf clubs, woodland charities, conservation bodies, angling clubs, country parks, etc must all undertake essential tree management. The sale of logs from this management can generate a small income or help with the costs of the management. This type of small scale situation is repeated in thousands of locations around the country. Regulation of their activity could seriously affect the ability of these producers to source, process and sell a good local product to local consumers. In this instance their supplementary income and contribution to their local community may be lost for ever. I would wish to be able to continue to refer my customers to the best local dealers but fear that any regulation would significantly reduce their numbers.

Environmental Impact
I have been made aware that large wood fuel companies are “desperate” to locate small wood producers and log suppliers in order to secure their raw material as wholesale product for their log selling businesses. I believe that any regulation on wood will remove many of the small local suppliers due to cost and red tape. If many small suppliers can no longer legally sell logs in smaller volumes then their product is likely to become waste or wholesale.
Waste is just that – somehow disposed of without further use and possibly at some cost. Wholesale – it seems that the wood will be collected by large companies, shipped to large, kiln drying factories (by road – creating emissions), dried out in kilns (again creating emissions) and then transported to the end user (creating yet more emissions). Cost of the end product to consumers would be likely to rise. It is highly unlikely that large scale suppliers would find it economical to have wood onsite to ‘dry out’, and if they did the associated costs would inevitably push up prices. These situations may impact on fuel poverty. Although we are not discussing carbon footprint, it also does not make sense to increase the carbon footprint of wood fuel in this way.

Consumer value / fuel poverty
I feel that any regulation is likely to increase the cost of wood fuel to consumers due to increased costs / red tape for suppliers and a likely reduction in the number of small local suppliers.
Some consumers deliberately seek to buy wet wood in order to store and dry it for future use. This product is usually sourced locally from small suppliers at a significantly reduced price. I would not wish to see the supply of this product become illegal.
Some small suppliers have limited storage space and it suits them to sell their product at a reduced price to consumers seeking to process / dry it further. In this instance I am concerned that any regulation will render the product as waste or wholesale.
It is useful to refer my customers to local suppliers who can provide wet wood for storing. I would not wish to see these suppliers and their product disappear due to regulation.

How would legislation be enforced?
DEFRA has indicated that local councils would have the power to enforce any new legislation on wet wood sales. The reality is though that enforcement of any kind is difficult to police and very resource-intensive. I am concerned about the burning of unauthorised fuels on open fires in Smoke Control Areas (mostly house coal, wood logs). There is already legislation to cover this misuse of fuel but it appears it is difficult to enforce. Consumer awareness messages regarding fuels used on open fires in Smoke Control Areas have been virtually non-existent over the last 20 years. I believe that good consumer awareness messages in this regard can provide good results.

Conclusion
Legislation on the sale of wet wood is, unnecessary, difficult and costly to enforce and may actually create more harm – environmentally, economically and politically – than envisaged. It is also possible that it actually masks the main causes and hinders progress. The delivery of consumer messages and advice concerning efficient combustion and air quality issues are a simple matter for a professional chimney sweep as they align perfectly with all the other useful consumer information on saving money, safety etc. The Burnright campaign (www.burnright.co.uk) has been established and is now being used by sweeps, consumers and stove industry suppliers as the ‘bible’ for how to save money, reduce the risk of a chimney fire and cut pollution. Defra have backed BurnRight in their Clean Air Strategy consultation .The campaign is very new but already successful, particularly given the shoestring budget. The power of this campaign lies in the power of the sweeps to deliver the messages. Education has been at the heart of government policy for years. It has worked in the past and it can work again.

The answer to cutting emissions from our existing stock of domestic fires is education, not legislation.

Yours sincerely
your name here