Thank you for the opportunity to respond to this important consultation, which is of great significance to Small Woods members, most if not all of whom source and use wood fuel for their own use and many also supply it to others.
Overall, we would want to stress the major positive role that local woodfuel supply has in promoting sustainable woodland management and in rural economies and livelihoods. The development of local woodfuel markets has led to a significant improvement in woodland management, as the income it has provided and the enterprises it has supported has led to an increase in resources for and skills available to undertake sensitive woodland management. Not only businesses, but also significant conservation bodies across the UK are funded in part through woodfuel supply, for example Worcestershire Wildlife Trust. It is critical that as this regulation is developed that Defra do have the unintended consequence of stifling this really important sector by introducing regulations, licencing and charges that will make it impossible for small suppliers and producers to operate. We would be happy to assist Defra in the further development of this legislation.
Income from wood fuel is often invested back into the sustainable management of our native woodlands. And the ability to sell wood fuel relatively easily to local markets is part of a cycle of sustainable market that is benefiting biodiversity and local economies. Better managed woodlands are better able to facilitate improved health and well being benefits. The vast majority of small woodfuel producers exclusively serve local markets and the link between the increased demand for wood fuel and sustainable woodland management should be more fully acknowledged.
We would for example challenge the rather simplistic infographic on Page 5 of the consultation document as simply being misleading. The infographic simply estimates the PM2.5s at the point of burning, and not the whole supply chain, which for generated electricity and for gas are also dirty. The supply chains on which gas and electricity depend, involve transporting crude oil and gas long distances by sea in diesel burning tankers, which themselves play a significant role in polluting fragile marine environments. The information presented directly understates the advantages of stimulating short supply chains for well seasoned woodfuel and says nothing of its positive role in the woodland management cycle.
Local woodfuel is one of the few examples of a growing local market, where Britain is becoming increasingly self-sufficient. In the light of current events, we would not want to see systems that led to an increase in imported wood fuel just to meet the needs of accreditation or to fill the gap left by small producers pushed out of the market. For example, the small woodland sector is not well served currently by the accreditation bodies, due to the cost and complexity of accreditation. Currently, Small Woods is working with FSC and others to help address this deficiency, in order to develop an appropriate standard for small woodlands, but there is no guarantee when this will emerge, or even if it will emerge at all.
We also work closely with the woodfuel sector more broadly and have good working relationships with organisations such as HETAS, Woodsure and Grown in Britain. SWA have been meeting members and owners at rural shows and wood fairs around the country this year and it is clear this is an area of concern for many small producers and we have encouraged participation in the consultation. However, we would assess that there is universal agreement that burning seasoned wood below 20% is the right approach and we have been advocating this for some time, as the article in our Summer magazine demonstrates.
Consumer awareness of the issue is low and there should be minimum requirements for point of sale information, as well as improved information online. For example, it is very hard to find out information about the location of Smoke Control Areas, whereas previous smokeless zones were well known and well publicised.
Notwithstanding, the Small Woods Association is very much in support of the overall direction of the policy initiative and wholeheartedly supports the objectives to:
• Legislate to prohibit the sale of the most polluting fuels.
• Ensure only the cleanest stoves are available for sale by 2022.
• Update outmoded legislation on Smoke Control Areas to bring these into the 21st century with more flexible, proportionate enforcement powers for local government.
• Work with industry to identify an appropriate test standard for new solid fuels entering the market.
• Ensure that consumers understand what they can do to reduce their impact from emissions from domestic burning
Small Woods Association