Waste exemptions

UPDATE:

Following a detailed examination of the new legislation and a long discussion with the EA today, Catherine was able to confirm that, contrary to what I had written below, if you used to have an exemption 27 you no longer need to register. It now falls under one of the non-waste framework exemptions which do not need to be registered. In effect, with these exemptions, it is taken that you have an automatic exemption.

We mentioned the new waste exemptions a few weeks ago. The Environment Agency has a really useful page about it explaining the details, listing the new exemptions and giving a link to register your exemptions.

The new exemptions come into effect on 6th April 2010. From this date you will be able to register by following the link here.

Full information on these changes including guidance can be found here.

Resource issues

There have been a number of discussions recently about resource issues. It is constantly in the news but never anywhere near the top level. During the various courses we run, particularly waste awareness courses, we look at resource efficiency and speak about fossil fuel (the UK's natural gas production has been declining since 2004), water (the south east of England is officially water-stressed) rare earth depletion and food security issues.

Peak Oil, something that has been causing some concern for a while, has finally caused Lord Hunt, the energy minister, to meet industrialists to calm rising fears over peak oil. According to the Guardian's report 'the government has agreed to undertake more work on whether the UK needs to take action to avoid the massive dislocation that could be caused by the early onset of 'peak oil'.' This follows on from a taskforce report in February which warned that Britain is unprepared for [peak oil and recommended packages including legislation, new technologies and behaviour-change incentives.

Peak Oil is a fairly well-known threat. Less well known resource issues have been raised by Sciencebloggers. Ethan Siegel is fascinating about helium, why we have any at all on Earth, why we need it and why it is a non-renewable resource. Dr Isis writes about 'why your medical care depends on weapons grade uranium'.

Business Week reports on further developments in China's management of various important metals including the rare earth elements so important in our modern technology and the Times updates us on the potential for phosphate depletion, a potentially disastrous issue that has been creeping up on us for some time now.

Finally, information about food security in the UK has been very nicely summarised in a one page document by DEFRA which the BBC publicised last year.

I don't have any particularly cheery words to say about any of the above other than to say that DEFRA seems to be more optimistic than I feel, and I really hope they are right.

UK may be fined for air pollution

The Independent reports on the failure of the UK to cut local air pollution in line with the requirements set by the EU. As a result of air pollution more than 50,000 people die sooner than they might. The report mentions nitrogen oxides (NOx), particulates and ozone as the most damaging pollutants. Much of the pollution is transport related. We are told that our air quality is 'shameful'. Although health messages about obesity, passive smoking and alcohol have been well-funded, the issue of air pollution, which costs the NHS a similar amount, has hardly been mentioned. The government is expected to ask for more time to meet the limits. A similar request to give Greater London more time to meet the targets was rejected by the EU in December after DEFRA was unable to prove the city had worked hard to meet the target. In the meantime the potential for pollution related chronic illness remains.

Generating the Future

There is a new report out from The Royal Academy of Engineering which aims to identify 'UK energy systems fit for 2050'. 2050 is, of course, the date by which the government wants us to have achieved an 80% reduction in carbon dioxide generated by the UK. It is also expected to be well past peak oil and heading quickly towards peaks for the various other types of fossil fuels worldwide. The UK is already past peak for our own oil and gas, as we have become aware over the last couple of years of bad winters when there has been increased concern over whether we have sufficient gas storage. Last July the Department of Energy and Climate Change produced the UK Low Carbon Transition Plan which can be downloaded from a link at the bottom of the page here. That was big picture, looking at why we needed to change our behaviour and outlining what different energy using sectors would have to do. This new paper looks a little deeper at possible energy generation systems necessary to achieve the targets set by the Climate Change Act.

It is no surprise that they comment that demand reduction will be essential and that all low carbon energy supply technologies will need to be used including nuclear, renewables and carbon capture and storage. It is also unsurprising that as a fundamental restructuring of the whole of the UK's energy infrastructure will be unavoidable, that the scale of the engineering challenge is massive. They note though, that as the last major investment in our electricity infrastructure was in the 70's and is reaching the end of its service life, investment in renewal would be required anyway which gives us the opportunity to develop an energy system that is 'state of the art'.

The paper concludes that this will require 'nothing short of the biggest peacetime programme of change ever seen in the UK'. They state that this transcends political ideology and call for a strategy informed by a high degree of whole systems thinking and be underpinned by critical evaluation of the economic, engineering and business realities of delivery across a system.

I would recommend having a look at the paper, it is very accessible. These are things we should be thinking and talking about now.

Drowning in junk mail

There have been a lot of articles in the papers recently about junk mail. It used to be that we all wrote letters. These days there are not so many letters but we still want the option of having our Mothering Sunday cards delivered (trip out at lunchtime planned for Catherine and me to buy cards!) and this won't happen unless there is a nationwide service. It feels like unsolicited mail has increased perhaps because in a recession, companies need to get information on their products out to us. In the three years I have been in the house I have only once bought something from unsolicited mail so that is an awful lot of trees cut down to make instant recycling.

From my personal point of view the increase will just mean I put out the paper recycling bin twice as often. I have a canvas bag hanging on the back of my door which I sort junk into directly and I transfer this to my wheelie bin every other week. My issue with it is the amount of needless waste produced that my council then have to deal with, and the stupid use of resources to produce something that I regard as a nuisance.

There are some things that can be done and over the last three years I have cut down the unwanted material that comes through the door. You need to be aware that junk comes in different varieties.

The unsolicited mail that comes from the Royal Mail and can be stopped is unaddressed. If there is no address on the mail or it is addressed to 'the occupier' then you can contact Royal Mail and opt out. The details of how to do it with all the warnings about the information you might miss can be found at their website.

If you are getting junk addressed to you, either by name or to 'the occupier' followed by your address then Royal Mail is obliged to deliver it. It is, in fact, unlawful for them not to deliver it. In those circumstances you can contact the mailing preference service who will warn you about the great opportunities you might miss but give the option of, again, opting out of receiving their junk. On the same website you can find a telephone and an email opt out as well. This will cut down a lot of unsolicited mail although companies that you have bought goods from will continue to send their catalogues. This site will also allow you to stop advertising mail to former occupants of your house.

The third thing to do is to contact the people sending you unsolicited mailings directly. I have done this successfully with a number of companies. Usually I send a polite email asking the company not to send me any more catalogues. This works for companies I buy from too. I ask for an email catalogue rather than a paper one, not least because I am more likely to buy online from catalogues than send a hard copy of an order but also because I can delete anything that I am not interested in. This does not work for business addresses sadly or the ECUS paper recycling bin would be a lot more empty.

Yet another thing I do is to return mail for the people who lived here before me to the sender. I am never likely to buy a BMW. There is no point the garage sending out regular invitations to the former occupant. This has worked well.

The final thing is to put a notice on your door asking people not to deliver unsolicited mail. Apparently this works rather well. Stop Junk Mail will sell you a letterbox sticker or you can do your own. I am going to do my own so that I can say no to commercial leaflets and to free newspapers but yes to community information.

I suppose one more thing to think about. Maybe we should think about writing letters again. The immediacy of email is great but I've got two computer stacks full of no longer accessible emails and even if I eventually get them back, emails tend not to be things you treasure or even place a lot of importance on. You can see this in the weighting given to letters over emails in the 'real world'. I have sent many emails to my MP and my Prime Minister over the years but the only reply from the PM was when I composed a letter, printed it out, put it in an envelop, put a rather nice stamp on it and posted it. I've received very few replies to my emails to my MP.

I'm quite happy with the move to email catalogues and two sentence emails but I love to receive letters. Perhaps I should think about sending some.

More on methane...

There have been a number of blogs picking up the methane release story I referred to last week. Real Climate has a useful article which puts it into a scientific context. If you do not know about Real Climate you should. It is a website run by real climate scientists. They provide a great service by making the scientific research accessible to the layperson. Whenever there is an overhyped climate story, in either direction of hype, I check this site out to gain a better and more realistic understanding. In the meantime, have a look at their piece on the accelerating methane release.

Methane time bomb?

Some rather worrying news in the newspapers a week or so ago. Sorry for the delay in posting. This is reports following the significant rise in methane in the atmosphere for the third year in a row. Details can be found in the Daily Telegraph.

Why is it a worry? The theory is that large quantities of methane, a greenhouse gas approximately 23 time more powerful than carbon dioxide, are trapped in the permafrost in the arctic circle. As the world warms and permafrost melts there is the potential for this gas to be released in ever increasing quantities, maybe leading to a positive feedback loop. The scientists are reluctant to confirm the causes for this increase at present but it is something to keep an eye on.

Alison on sustainability

If I could have a 'Frequently Asked Questions' list from having been in this job for 15 months, it would include the following:

- What does 'being sustainable' really mean?

- Why do Councils in the UK all collect different materials for recycling and why are the bins different colours?

- Is it more sustainable to use a hand-dryer or paper towels when drying your hands?

- If I got rid of my car and just used taxis and public transport would that a) be cheaper? b) be kinder to the environment?

- How do you get people to change their behaviour and switch off lights/equipment?

- Why am I being held back from making our company more sustainable by the grey-haired people in our boardroom who won't be around to worry about it in 20 years?

- Diesel or petrol engines?

- When does a waste stop being a waste?

- If something has a value is it still deemed to be waste if I'm throwing it away?

- Is Climate Change really happening?

And have I answered those questions? Well, in some cases the answers are a little more black and white, and in others the truth is I simply don't know. All I do know, is that we are still making our minds up about which activities in our lives ARE sustainable and those which are not.

I think being sustainable is 1/3 common sense, 1/3 having accurate baseline information from which we can clearly assess the issue and take informed decisions, and 1/3 hindsight. Which means 66.6% of it is something we can act upon now, and the remaining 33.3% we will learn with time. I guess the aim is to reduce the element of hindsight over time and hope that we act quickly enough to prevent long term damage to our planet.

The Glorious Leader has left. Long live the Glorious Leader

So, Danielle Taylor has left us, heading for an undoubtedly illustrious career as Sustainability Manager for South Yorkshire Police. As the head of the Environmental Management Department she did an excellent job and we all loved the ‘chocolate and bubblebath bonus’ method of management (hint). We’ll know that she has changed the world when the uniform becomes locally sourced, environmentally sound and pink! In the meantime I’m expecting that she will help the local police focus with the sustainability of all their operations and will do a grand job for them. We gave her a jolly good send off, as can be seen in the photo of Danielle looking sad, and all the team and many of the company blubbed copiously.

Sad though we are that Danielle has left, we are thrilled that Alison Fanshawe has taken on the role. Ali is a very good manager and, having come from a financial background, has a solid grasp of the financial bottom line section of the triple bottom line of sustainability. She is a talented trainer, very organised and we, the team, are very pleased that she has agreed to be our new Glorious Leader. I have asked her to write a little something about herself but in the meantime, here are her (summarised) thoughts on sustainability. There will be more information on each topic over the next few weeks.

Practical EMS issues or The Thermostat Wars!

In the world of Carbon Reduction Commitments and huge energy spends our little organisation might seem to have insignificant issues. The impact of our carbon footprint is as nothing compared to that of the metals industry in Sheffield or the power generation facilities in Yorkshire or even Sheffield City Council. However, our energy use is a significant aspect under our 14001 system, our energy spend is a significant part of our outgoings, we are an environmental consultancy and, as noted in an internet funny that eased its way though the firewall, no single raindrop believes it is to blame for the flood. We spend a lot of time helping clients focus on their environmental impacts and, as a point of principle, we make the time to focus on our own.

We do have a number of problems when we look at minimising energy use. We lease our splendid old listed building. It is lovely in the summer when we can open the huge sash windows and let cooling breezes into the rooms. The ceilings are gracefully high, and the windows and doors provide astonishing amounts of ventilation. Even in the depths of winter. The boiler is not state of the art and none of the pipework has been relagged since the old asbestos lagging was removed. Oh yes, and the cellar is still contaminated with asbestos dust so we're not going to go down and put foam lagging around the pipes. Even worse for our measuring and monitoring, the meters are in the cellar. The leasor will be sorting out the asbestos issue when it's warm enough to turn the heating off for a few days. Not right now.

So working within this set of constraints there are still some things we can do to cut down on our energy use. We turn off the heating in the areas of the building not in use. The radiators in the meeting room are turned off at the end of each meeting. It's one of our little rituals. The corridors are not heated, except by the pipes between radiators. The radiator in the kitchen is turned off and the single thermostat for the building is kept low. The thermostat is in the building entrance hall which, given the drafts from the front door, means it will still keep the heating turned on even when set to ten degrees (C). It's supposed to be set at fifteen. I have been amused over the last few months to see what it is actually set at at various different times of day. Up to twenty five degrees on occasion. As I understand it you could set it to 100 and it would not heat the building up any better than when set to 15 which is why I don't particularly care that is being moved but it does give me some cause for thinking that we haven't got the energy minimisation message across.

There are always issues to consider when putting together an energy policy. You need your staff to understand and agree with what you are doing. Keeping the building uncomfortably cold means that people are going to sneak in electric heaters. This has health and safety implications because of the requirement to check the safety of equipment. It is also the least efficient way to heat a building, and expensive. If you need to 'police' your heating you are on to a loser; the policer is one person against many. We've seen this recently in the kitchen. As this tiny room is only used to make drinks and heat an occasional soup it has been designated an area where the radiator is kept off. We're in there for five minutes at most. Over the last couple of weeks it has been difficult to know whether to wrap up warm before going in or to strip off. I'm longing for the day when I go in and find one or other of the combatants under the worktop turning the valve on or off.

On the other hand, people who want to work in their shirt sleeves and want to heat a building to make it comfortable for that style of dress might be persuaded to consider a cardigan. I have an elusive memory that the National Trust had a 'Cardi' Policy, though I haven't been able to find reference to it on the internet, but I'm a firm believer in the 'don't turn up the thermostat, put on a jumper' message. I may be biased. Being a woman of a certain age and well padded to boot I often find it uncomfortably warm when my slender young colleagues are sitting huddled in their fleeces. As I have pointed out to them on occasion, they can put on a jumper but I can't respectably take any more clothes off.

So the moral of this story is that we need to reassess our approach and have a discussion where we all reach a consensus on our policy rather than just impose it. This may not be something that can work in a massive organisation but in our company, where we all know each other, it is something we can address. But in the meantime I'm also going to think about how to stop 20% of monitors being left on over the weekend. That's a waste from which no-one benefits.

You need to know this - Waste Legislation from Catherine

When Yvonne first mentioned she was going to start an ECUS Environmental Management blog, I thought it was a great idea, although I knew full well it was only a matter of time before she coerced gently persuaded me into writing something. As I’m one of those sad people who finds environmental legislation really interesting, what could be better I thought, than to write about the forthcoming Environmental Permitting (England and Wales) (Amendment) (No. 2) Regulations?!

Exemptions are required for waste management activities that have a fairly low environmental impact but still require a certain element of control from the regulator. The activities covered range from simply storing waste on site, to crushing it, to more complex activities such as spreading agricultural waste on land. What most businesses probably don’t realise is that they automatically have a waste exemption under Schedule 3, Part 2 of the Environmental Permitting (England and Wales) Regulations 2007. Exemptions in this Part are ‘unregisterable’ and pretty much every business producing waste will automatically fall under the paragraph 52 “temporary storage of waste on the site where it is produced” exemption.

The new Regulations are due to come into force on April so I spent part of my train journey down to Somerset last week getting clued up on them, and was actually pleasantly surprised. The Environment Agency held a series of consultation workshops last year and I went along to one in Birmingham. The delegates were a mixed bag; consultants, environmental managers and operators. The poor Agency representative got a bit of a grilling as the initial consultations suggested a £50 charge per exemption, to be renewed every year. Operators who used mobile crushers on construction sites were also concerned, as the proposed new limits would mean that many of them would require a standard permit for mobile plant rather than an exemption.

So after numerous consultations, it’s interesting to see the actual outcome, which I will summarise in a few succinct bullet points:

• The two tier system of complex and simple exemptions has been removed – activities will either require an exemption or a standard environmental permit;
• Only exemptions relating to refurbishment of WEEE are chargeable, contrary to the initial proposals;
• Exemptions will need to be renewed every three years and will appear on the Agency’s Public Registers;
• The relevant EWC codes are provided for all waste streams covered;
• Exemptions are split into categories:
• U (use of waste) 1-16
• T (treatment of waste) 1-33
• D (disposal of waste) 1-8
• S (storage of waste) 1-3
  
  

It remains to be seen how successful the amendments are once the new Regulations are in force, but my personal view is that they’re a great improvement on the old exemptions. They’re much clearer and more specific as to the type of activity and waste stream. But the most surprising bit is hidden away in the Part 2 unregisterable exemptions. Whereas previously there were limits on the quantities of waste that could be stored, these no longer exist. The only criteria under the new Regulations is that waste cannot be stored for longer than 12 months and it must be stored in a secure place, and this applies to hazardous waste as well. So that means in theory it’s perfectly acceptable for a company to store over 23,000 litres liquid hazardous waste or waste oil without being regulated for it! Which leads us on to the inadequacy of the Oil Storage Regulations, but that’s another story for another day…

Introducing Catherine

I’d like to introduce you to my colleague, Catherine. She started at ECUS nearly four years ago now as the admin assistant whilst working on her LLM in Environmental Law. Now, of course, she is a key part of our Environmental Management team. We are all very impressed as she dashes off after work to practice with her salsa band, her folk metal band and her ladies recorder group or to various of her gigs. She even finds time to go to see other bands play.

We love Catherine. She is rather quiet when she’s not whistling complicated classical tunes but she is great fun to be around with a wicked sense of humour, an addiction to strong tea and a wonderful ability to make sense of environmental legislation. Even better, she is a completer/finisher. Nothing pleases her more than putting the final touches to a report, PDFing it and sending it off. She’ll even QA my reports for the joy of another piece of work completed. And she looks lovely in turquoise. What’s not to love?

I don’t want to paint too rosy a picture though. Catherine is a music snob. She finds the ‘music’ I listen to offensively banal. I will admit to finding her taste a little too hardcore for my middle-aged ear. When we travel together we tend to compromise on Classic FM.

Anyway, at the end of a very busy week she has promised me that she will write a short piece about the new Environmental Permitting (England and Wales)(Amendment)(No.2) Regulations. How exciting!

(Catherine grumbles that saying she finds my music offensively banal is a little harsh. It's just, she says, not to her taste.

Excuses, excuses!

I haven't disappeared off the face of the earth, I've just being training all week. When I have an early start I find that inspiration has run out by the time I get home. I've got a number of posts coming up though. Any minute now...

Best seatbelt advert ever!

Not an environmental issue at all but a stunningly good 'wear your seatbelt' advert that I came across recently. So much better then the peach and hammer adverts of my youth. Have a look here. From the Sussex Safer Roads Partnership.

But it's cold!

The BBC have been polling people about climate change and have come up with some interesting results. As they say, 'Climate scepticism is 'on the rise'.' Well there have certainly been some disappointing news stories about the science which seem to show, more than anything else, that scientists are human, make mistakes and don't always handle the resulting publicity well. Oh yes, and it's been cold. Really quite cold. In the UK. Despite this I have no doubts myself that the climate is changing, and the causes are predominantly our activities. I occasionally wander over and have a look at 'Climate Denial Crock of the Week' by Peter Sinclair. His recent video is, 'It's so Cold, there can't be Global Warming.' It's well worth a look.