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majority of the buildings are blocks of offices, most of which have central heating plants using
coke or oil fuel. There are, however, a considerable number of old office blocks which have no
central heating but have ordinary domestic coal-burning grates in the individual offices. There
are others which have central heating on the lower floors, but individual heating by coal fires on
the upper floors. Even in the centrally heating blocks certain rooms have coal-burning grates,
often more for appearance than for heating purposes. All these coal fires produce a domestic
smoke type of nuisance, which is rendered more obvious by the fact that they are mainly in the
older buildings of three or four storeys which are surrounded by more modern, much higher
buildings, so that the smoke never gets away.
The Corporation came to the conclusion that it would be futile to attempt to define zones
within the City which should be declared smokeless zones, and decided to make the whole City
of 667 acres one smokeless zone.
The Act states that as from a date to be fixed by the Corporation, which shall not be
before the 1st October, 1955 "no smoke shall be emitted from any premises in the City". The
penalty is a fine not exceeding £10 and a daily penalty not exceeding £5.
There is no general defence on the grounds that the "best practicable means" for the
prevention of smoke under existing circumstances, have been used. There are provided, however,
two lines of defence, one in relation to the burning of an authorised fuel, and the other to the
burning of any fuel which has been approved by the Common Council as suitable for the particular
appliance, and burnt in accordance with approved conditions and during such period as has been
approved.
In regard to the first of these lines of defence, an authorised fuel is defined as "coke,
anthracite or any other fuel from time to time approved as being an authorised fuel by resolution
of the Common Council", and it is a defence to prove that the smoke emitted arose solely from
an appliance suitable for burning an authorised fuel and properly maintained and used, and so
arose either by burning that authorised fuel therein, or by burning any other type of fuel because
the authorised fuel was not available at the time and could not, by reasonable care and foresight,
have been made available.
It is reasonable to provide this defence, because it is the intention of the Corporation to
limit the authorised fuels to those generally recognised as smokeless fuels, and they may not
be available at all times; and moreover it is possible that there may be a brief emission of a little
smoke even with a smokeless fuel, when lighting up or stoking up.
The second of the two lines of defence is designed to provide that if an occupier has sought
the advice of the Corporation in regard to the type of heating appliance he should install, the
type of fuel he should use, and the precautions he should take by means of instruments or
otherwise to check the emission of smoke, and if he has followed the recommendations of the
Corporation, he shall not be liable to a penalty if smoke is emitted occasionally. This is an
encouragement to occupiers to seek prior approval of heating installations, and accordingly the
Section of the 1946 Act, under which the Corporation may make bye-laws in regard to prior
approval of heating arrangements, is repealed. Even if an occupier has done everything humanly
possible to ensure that the heating appliances in his premises are smokeless in operation, there
may be an occasional emission of smoke through some unexpected failure in the apparatus, the
fuel or the operator. The occupier has then contravened the law, but it would be unreasonable
to impose the penalty which the law prescribes for such contravention.
The Act enables the Corporation to exempt premises from the application of the provisions
of the "smokeless zone" section, or to postpone their application to any particular premises; and
to contribute the whole or part of the expense necessarily incurred in the execution of works for
the purpose of complying with the section; though, so far as I am aware, there are no premises
which should be exempted permanently or temporarily, and in my opinion anybody who can
afford to occupy premises in the City of London should be able to afford to install smokeless
methods of heating. The section also lays down the means by which disputes between occupier
and owner as to responsibility for the cost of necessary works shall be settled.
Raihvay locomotives are specifically exempted from the application of the Act.
As regards the implementation of the powers, I am of the opinion that there should not be
any serious difficulty so far as the open fires in the older offices, or what I may call the "amenity"
fires in the modern offices, are concerned. The cost of conversion to gas or electric fires or to
modern grates or stoves capable of burning any type of smokeless fuel will not be a serious
matter, and the greater efficiency will result in lower fuel costs, so the capital outlay on conversion
will soon be repaid. There will be no objection from the Corporation to the burning of
smokeless fuels of the coalite type in the existing grates, but from the occupier's point of view
it would be more economical to install an approved modern appliance.
The burning of bituminous coal and of oil in central heating plants will need more care than
it has received in the past, but the difficulties are not insurmountable. We have had quite a
lot of trouble from coal-fired plants, even with automatic stoking, in modern buildings. In some
cases at least this has been due to the variable quality of the coal supplied, though of course it
has, since the war, become usual to blame the quality of the coal whenever there is complaint
about the emission of smoke.
The petitioners against the Bill pressed us to include oil as an authorised fuel but we refused
to do so, because an oil-fired plant can make the most filthy smoke. I am inclined to think that
the manufacturers of oil-firing plant have not yet tackled the problem of absolute smokelessness.
They have felt that they could keep well within the legal limits for smoke emission, but, so far
as the City of London is concerned, they will in the future have to achieve a standard of no
visible smoke at any time. There seems to be a problem in relation to commercial buildings
which are centrally heated by oil-fires plants. Over the week-end the buildings are unoccupied
and therefore the heating is cut down. During this period there is an accumulation of oily soot
in the flues, and when full heat is turned on on Monday morning this is blown out and falls in
the vicinity like black snow. This is perhaps not atmospheric pollution in the strict sense and