Llais y Goedwig Consultation advice note – Clean air plan for Wales – Healthy Air, Healthy Wales

Posted on March 6, 2020 by

Llais y Goedwig Consultation advice note

Clean air plan for Wales – Healthy Air, Healthy Wales

We’ve put together some notes and tips on filling in the relevant bits of the latest Welsh Government consultation. Follow the link below for the consultation document and please do let us know what your responses are – email policy@llaisygoedwig.org.uk – deadline for responses is 10th March!

Webpage for full consultation document and response form: https://gov.wales/clean-air-plan-wales

The Welsh Government is consulting on it’s plans to improve air quality in Wales. Of course, we all want clean air! But responding to public consultation is not just something to do when we object to what is being proposed but also to support and shape good ideas.

Air and noise are issues which affect all life in many, many ways so it is unsurprising that the consultation document runs to 123 pages and poses 41 specific questions. This is a lot to wade through… especially given the way air quality concerns intersect the complex web of legislation (e.g. Wellbeing and Future Generations Act, Environment Act and National development framework), commitments on pollution targets (UK emission reduction commitments) and those related to public health (WHO guidelines on permissible levels of aerial pollutants).

However, our interests as woodland folk are a sub-set of the issues raised and a more manageable number of questions. Here we point you at issues you may wish to support and some you may wish to ameliorate. This mixed response is because trees can filter pollutants from the air which is a great incentive for more urban tree planting but we also burn wood to heat our homes which is a source of pollution. The complex and at times antagonistic roles of woodland in the climate change, biodiversity and human health agendas will be explored in another blog piece. For now, we can deal more simplistically with the proposals out for consultation in the Clean air plan.

PM2.5 pollution and wood burning

Particulate matter in the air has risen up the ranks of worst pollutant as levels of more toxic compounds such as sulphur dioxide have fallen. Particulate matter (PM) is very fine solid material – a lot of it incompletely burnt carbon – think a very, very fine soot. PM below 2.5 μm (PM2.5) is very damaging if inhaled and exposure is linked to respiratory and cardiovascular illness and mortality (page 15). Although PM2.5 levels are generally lower in Wales than in the UK as a whole there are pockets of higher concentrations and the Welsh Government wish to meet or be lower than the WHO guidelines for PM2.5 concentrations. A study was done to examine where levels were highest and the source of the pollutants. This showed that concentrations are highest along the north coast and in urban areas of south Wales and has also showed that much of this comes from domestic burning of wood. However, PM2.5 isn’t all soot and is also derived from cars (e.g. rubber from tyres), industrial processes and natural particulates such as sea salt and dust. The contribution from wood burning contributes the biggest single source of PM2.5 amounting to 23% of the total. As such domestic wood burning has been singled out for particular consideration in the Clean air plan.


That wood smoke is toxic should not be a surprise to anyone and modern wood burning stoves are designed for efficient burns which reduce emissions of pollutants including PM2.5. However, the stated intent of the Clean air plan is “to reduce, and in time eradicate, all emissions from domestic sources including through burning of solid fuels.” However, this is moderated by the fact that many households still rely on solid fuels as the sole form of heating. So short term goals are “things we can do to drastically reduce domestic emissions without moving to an immediate, unmanageable and unsustainable all out ban of domestic burning”. The proposals for tackling domestic PM2.5 are:

  • Legislating to prohibit the use and sale of the most polluting fuels throughout Wales.
  • Ensuring that only the most efficient and least polluting appliances are available for sale by 2022.
  • Changes to smoke control legislation to make it easier for local authorities to proactively and effectively enforce and modernise the approach it takes to ensure it deals with the problems as they now stand.
  • We will work with industry and other devolved administrations to identify appropriate test standards for new solid fuels entering the market.
  • Consider whether outdoor solid fuel burning appliances and the fuels they use should be subject to regulation if purchased for use within a Smoke Control Area or throughout Wales. (E.g. barbecues, chimineas, pizza ovens, outdoor fireplaces and firepits).
  • Amending legislation to allow Welsh Ministers to publish an online list of fuels and appliances, moving away from the method of updating through Statutory Instruments.

Some of these may have little impact in rural areas which do not have Smoke Control Areas. But there is a clear intent to restrict domestic wood burning wherever it occurs. Work on firewood in Wales sponsored by Llais y Goedwig[1] identifies some key characteristics of domestic heating in Wales: dependency on firewood for heating is highest in remote communities without access to mains gas, that about half of all firewood is sourced locally via social networks rather than formal markets and that many people consider the use of local firewood as a ‘green’ alternative to the use of fossil fuels while for others it is the cheapest means of heating the home. The proposed interventions do not accommodate much of this reality. There are especially difficult trade-offs that maybe needed between the benefits of local firewood as a cheap renewable fuel and the disbenefit of wood smoke. This perhaps suggests that a more nuanced approach is needed and that it will not be quick, easy or perhaps even desirable to prohibit domestic wood burning. There is no easy answer to this – so respond letting the government team know how these proposals will affect you and your plans for the future – both positive and negative.

More on pages 54-59. Respond by answering questions 6 and 7.

Tree and hedge planting to support air quality improvements

Trees filter the air and can remove pollutants and are beneficial in both rural and urban areas though they are not a solution to city-level pollution. Woodland is most beneficial planted close to agricultural or industrial buildings, urban or transport corridors and improvements to air quality will be a significant benefit arising from government targets to increase woodland area.

The adoptions of an aspirational culture of ‘Stop, Grow, Change for Environmental Growth’ is to be applauded but this is something that goes beyond what can be legislated, regulated or go into government incentives but requires commitment from everyone. What do you think needs to happen to realise the goal of a cleaner, healthier Wales for us and nature?


Stop the decline in nature: This could include a range of activities including reducing air pollution, reducing pesticides and fertilizers, reducing litter and reducing single use plastic.


Grow nature: this could include growing a National Forest, increasing renewable energy, greening public sector estates, growing the circular economy, creating allotments/community gardens, restoring Natura 2000 sites and increasing urban green spaces.


Change by removing barriers to, and encouraging an ethos of ‘doing the right thing’. This could include redefining outcomes for economic contracts, promoting a move from the car to active travel and use of public transport, future farming policy, planning policy, procurement practices and grant conditions. Behaviour change communications are essential to support new approaches to delivering environmental growth.



More on this on pages 83-85.  Respond to questions 25 – 27.

[1] http://llaisygoedwig.org.uk/wp-content/uploads/2013/12/Wales-Domestic-Firewood-Survey-20121.pdf

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