Our report assessing options for reform of fuel regs was requested by @AsthmaIreland after a national 'smoky' coal ban was delayed in light of previous Attorney General's (Séamus Wolfe) advice to then Minister @Dept_CCAE Richard Bruton

Available at: https://tinyurl.com/yyjghals 

In the report we detail
- development of current legislation
- enforcement issues with zonal approach
- permissible exceptions to EU free movement of goods & competition law
- likely impacts on social justice (fuel poverty & workers in industry), climate, and biodiveristy

We assess 3 options
1. national bituminous coal ban
2. national ban of fuels w/ harmful smoke
(high levels of particulate matter under 2.5 micrometers)
3. progression of current Low Smoke Zones
(where fuel w/ more than 2% sulphur by weight on dry ash-free basis is prohibited)

So far Min @EamonRyan has preferred the approach of his predecessor @RichardbrutonTD i.e. (3) more Low Smoke Zones with a view to achieving (1) national smoky coal ban within lifetime of government

We argue this approach is flawed on several grounds. Most significantly: there is no scientific basis for singlinging out coal - for health or environment benefits

@CRAClabUCC research confirms that peat and wood are responsible for more PM2.5 emissions in many smaller urban and rural areas, often leading to worse air quality than cities

see SAPPHIRE study: https://tinyurl.com/y3n2bqvg 

Prof @johnwenger9 summarises here

Research from @UCDEngArch finds even "smokeless" coal has high levels of PM2.5 pollution, especially when used with firelighters, and confirms peat as the most problematic fuel

see EFDOSOF study: https://tinyurl.com/y2ojru46 

A limited zonal approach to restricting fuels is also highly questionable as air pollution moves, meaning high concentrations can occur in Low Smoke Zones due to weather and geography.