Written evidence submitted by Clean Air in London (DHH0042)





  1. Clean Air in London (CAL) submits this memorandum to the Business, Energy and Industrial Strategy (BEIS) Committee’s (BEISCOM’s) inquiry into Decarbonising heat from homes which closes on 4 December 2020.  Thank you for inviting submissions.  BEISCOM’s announcement of the inquiry can be seen here:






  1. CAL’s mission is to achieve, urgently and sustainably, full compliance with the World Health Organisation’s (WHO’s) air quality guidelines throughout London and elsewhere.  CAL is a not for profit company limited by guarantee, registered in England and Wales, with number 7413769.  Further details about CAL can be found at https://cleanair.london.


  1. CAL is independent of any government funding, has cross-party support and a large number of supporters, both individuals and organisations.  CAL provides a channel for both public concern and expert opinion on air pollution. 


  1. CAL would be pleased to give oral evidence if invited to do so.


Executive Summary


  1. CAL is responding to all Questions of the Inquiry.  We make the case for a new Clean Air Act before COP26, the full text of which we intend to publish in November 2020.


  1. Air pollution is the largest environmental health risk in the UK.  Climate change caused by greenhouse gases poses an existential threat to our way of life and millions of people. Homes and buildings are responsible for producing approximately 78 per cent of greenhouse gas emissions in a city like London (paragraph 9.2.1 of the ‘Intend to Publish’ version of the London Plan). 


  1. It is vital that ‘air’ or the ‘atmosphere’ (i.e. air pollution and greenhouse gases) is considered holistically if we are to avoid and tackle the problems of diesel, wood burning and combined heat and power plants in cities and towns.  We need to achieve zero air emissions from buildings.


  1. BEIS announced a £3 billion plan to upgrade the nation’s buildings on 30 September 2020 and yet Roger Harrabin, BBC Energy and Environment Analyst, tweeted on 5 November 2020: “I couldn’t get an installer to answer the phone”:






BEIS announced a Green Jobs Taskforce, as part of its ambition to create two million green jobs by 2030, on 12 November 2020. 



  1. The Clean Air Act 1993 desperately needs to be updated for modern fuels, technologies and circumstances.  A great deal of work was done between 2011 and 2013, as part of the Red Tape Challenge to determine how it should be updated.  Little further analysis is needed now.  See:








Four Select Committees called jointly for a new Clean Air Act in March 2018:




  1. The Government and the general public desperately need a ‘big idea’ to mobilise political leadership, technology and lifestyle change to rapidly decarbonise heat (and cooking) in homes (and other buildings) to net zero.  In CAL’s view, the obvious answer is a new Clean Air Act before COP26 that would: update the Clean Air Act 1993 for modern fuels, technologies and circumstances; mobilise every Mayor of a Combined Authority and every local authority (as the UK did so successfully in 1956); and inspire the world.


  1. BEIS is the best department to lead such a new Clean Air Act, not Defra, because of its focus on energy, building, climate change and COP26 and its financial and other resources. 


  1. Everything to points to the Government needing to introduce a new Clean Air Act before COP26.


Question 1: What has been the impact of past and current policies for low carbon heat, and what lessons can be learnt, including examples from devolved administrations and international comparators?


  1. The Clean Air Act 1956 (and its successors in 1968 and 1993) did what needs to be done again.  In essence, it decarbonised heat in homes and achieved myriad other benefits, not least a vast improvement in public health.  We need laws and regulation to provide the framework for action and innovation.  Let’s not reinvent the wheel!


Question 2: What key policies, priorities and timelines should be included in the Government’s forthcoming ‘Buildings and Heat Strategy’ to ensure that the UK is on track to deliver Net Zero? What are the most urgent decisions and actions that need to be taken over the course of this Parliament (by 2024)?


  1. The forthcoming Buildings and Heat Strategy and other BEIS strategies should pledge to introduce a new Clean Air Act before COP26.  The first Clean Air Act allowed seven years to achieve the full fuel switch in Smoke Control Areas. No longer period should be taken now given the climate and health emergencies.


Question 3: Which technologies are the most viable to deliver the decarbonisation of heating, and what would be the most appropriate mix of technologies across the UK?


  1. CAL’s proposal is technology neutral – it is focused on achieving zero air emissions from buildings.  This should be achieved through a wide range of energy efficiency measures and zero air emission energy sources e.g. heat pumps, electrification and on-site renewables.


Question 4: What are the barriers to scaling up low carbon heating technologies? What is needed to overcome these barriers?


  1. The biggest barrier is the need for a ‘big idea’ that would: inspire people, build upon their understanding of air pollution and desire to protect themselves and reduce pollution for themselves and others; and mobilise every local authority and Mayor of a Combined Authority.


Question 5: How can the costs of decarbonising heat be distributed fairly across consumers, taxpayers, business and government, taking account of the fuel poor and communities affected by the transition? What is the impact of the existing distribution of environmental levies across electricity, gas and fuel bills on drivers for switching to low carbon heating, and should this distribution be reviewed?


  1. BEIS has the money and determination to create ‘green jobs’. The resources are available.


Question 6: What incentives and regulatory measures should be employed to encourage and ensure households take up low carbon heat, and how will these need to vary for different household types?


  1. A new Clean Air Act would update the Clean Air Act 1993 for modern fuels, technologies and circumstances and focus on the full decarbonisation of heat (and other energy e.g. cooking) from homes and other buildings.  There are at least two detailed private members bills in front of Parliament at the moment (from Baroness Jones and the London Councils) and another in the last Parliament:








  1. CAL’s solicitors are currently drafting the full text of a new Clean Air Act.  We would be pleased to share it with BEISCOM.


Question 7: What action is required to ensure that households are engaged, informed, supported and protected during the transition to low carbon heat, including measures to minimise disruption in homes and to maintain consumer choice? 


  1. A new Clean Air Act before COP26.


Question 8: Where should responsibility lie for governance, co-ordination and delivery of low carbon heating? What will these organisations need in order to deliver such responsibilities?


  1. BEIS is the obvious department to introduce the new Clean Air Act, not Defra, because of because of its focus on energy, building, climate change and COP26 and its financial and other resources.


  1. Local authorities (and Mayors of Combined Authorities), which currently have to rely solely on the planning system to reduce emissions from buildings (because the Clean Air Act 1993 is no longer fit for purpose), would lead the practical implementation of the new Clean Air Act as they did so successfully in 1956. 


  1. There is widespread political support for a new Clean Air ActThe Labour Party, Green Party and Liberal Democrats manifestos for the 2019 General Election all included a commitment to introduce a new Clean Air Act.  Simon Birkett’s policy pitch at the Conservative Policy Forum’s session on the main stage of the (virtual) Conservative Party conference in October 20202 was voted 2nd of four pitches (that had been selected out of some 500 submitted).





November 2020