Earlier this week the Government put out its response to the House of Commons Environmental Audit Committee report on the role of carbon markets in preventing dangerous climate change.  The Government’s paper directly responded to the 19 conclusions/recommendations that the EAC put forward earlier this year.

To summarise the contents of the 14 page response very simply, The Government:

• Welcomed the EAC’s overall endorsement of the importance of global carbon markets in tackling dangerous climate change. Like the EAC, the Government supports a vision of a global carbon market, and considers that future linking of emissions trading systems may provide emissions reductions at lower cost and accelerate the scale of innovation.

• Considers the EU Emissions Trading Scheme (ETS) an effective system at reducing emissions, but argues that a deeper 30% EU emissions reduction target is required to help bring on the low carbon investments needed, especially in the UK power sector – A position EEF strongly rejects without comparative international action.

Going forward the Government will publish proposals in the autumn to reform the climate change levy to provide more certainty and support to the carbon price. Subject to this consultation, in which EEF will play an active role, the Government will bring forward relevant legislation in Finance Bill 2011.

Despite its shaky start there remains strong international support for a carbon market; support which is only set to swell.  Whilst currently receiving little press attention at the moment, the approaching November meeting of the United Nations Framework Convention on Climate Change (UNFCCC) is likely to reignite the debate about a global climate change agreement. 

Chief amongst these discussions is likely to be the role of a global carbon market.  While unlikely to generate the same level of hype and fanfare that surrounded the UNFCCC meeting in Copenhagen last year, the meeting is an important milestone which could mark a bright future for a global carbon market.  Watch this space….

Come the 30 November will chemical substances be withdrawn from the European market causing massive disruption to manufacturing supply chains, or will the deadline pass uneventfully as was the case back in 2000 when the Y2K bug was set to wreak havoc across industry?  Quite simply, I don’t know.  Unfortunately, neither does the rest of industry, nor, possibly more importantly, the European Chemicals Agency (ECHA) who have the unenviable task of administrating and regulating the chemicals regulation REACH. 

Why is this?  Well REACH requires chemical substance manufacturers/importers to register each individual substance they place on the market.  However, the registration process does not require these importers/manufacturers to declare their intention to register, or not, a particular substance. 

It is this process flaw which is proving extremely worrying for manufacturers of aerospace, automotive, domestic, electrical and electronic products for example. They approach the deadline with the very real risk of not knowing whether certain substances they procure, and the specific uses in which they are applied, have been registered or not until after the deadline. 

The problems surrounding REACH are not limited to a handful of obscure chemicals.  ECHA remain unclear as to the fate of approximately 2000 chemical substances.  Those 2700 substances for which ECHA is aware of a ‘lead registrant’, and therefore a predicted registration, are listed in its website; however the specific industrial uses are not.

Part of the problem with REACH is that is a large and complex piece of legislation.  Whilst the objective it sets out to achieve is fully supported, it is nonetheless proving a difficult beast to manage.  ECHA have been beset by criticisms from the outset, whether for the guidance it produces or the IT systems it has introduced.  Just recently the UK government voiced its criticism of ECHA’s engagement strategy, arguing that “…better routes of entry and closer relations are needed with member states being seen as included partners”.

To avoid the potential withdrawal of business critical substances from the EU unnecessarily, and the subsequent collapse of related supply chains, EEF are coordinating industry sector activity and are writing to the environment and the business departments of Government to strongly encourage their support of our proposal for a 12-month delay of these substances from registration.  This action would permit downstream users to obtain necessary registration data from the European Chemicals Agency (ECHA), and subsequent action to prepare separate registration dossiers, source alternative suppliers, etc. This will ensure that existing manufacturing processes will not be sourced outside the EU.

Considering myself an optimist I am hopeful that come the deadline we will all be able to breathe a sigh of relief as was the case back in 2000.  To enjoy this moment of contentment will require an intelligent and practical interpretation of the REACH text to be agreed, and we still have some way to travel before this is realised.

The Government’s overarching approach to waste is to work towards a zero waste economy. Part of the work of the DEFRA Review of Waste Policies is to define more closely what this means, setting clear measurable objectives, and potentially accompanying this with targets in the short, medium and longer terms.

However, from the outset, the Government has made it clear that a zero waste economy is not where no waste is produced. The Government envisages that amongst others, the zero waste economy will have the following characteristics:

·         resources are fully valued – financially and environmentally.

·         one person’s waste is another’s resource.

·         over time, we get as close as we possibly can to zero landfill.

·         a new public consciousness in our attitude to waste.

DEFRA’s Call for Evidence is the first step in developing these ideas into something more holistic with clear and measurable outputs. As always your comments to this debate would be welcome.

The UK has long been labelled ‘the dustbin of Europe’ because it far exceeds its neighbours in the amount of rubbish it sends to landfill.  The UK ‘truck and dump’ attitude to waste is very different to many other European countries whereby efforts to recover energy from waste and recycling had been pursed.

Whilst the UK approach to waste has been different to many of our northern European neighbours, this criticism is a little unfair.  One needs to put into perspective that conditions in the UK are more favourable to landfill than in other European nations, making it the most cost-effective waste management option.  For example, UK soils have a heavy clay content making it a suitable landfill liner (reducing the risk of leechate).  The UK is also not exposed to low lying areas (subject to flooding).  As a result European nations exposed to these risks have had to resort to alternate waste management systems.

The UK’s historic dependence on landfill does mean it now has the furthest distance to travel to ascend the European Commission’s Waste Hierarchy, which cites landfill as the least preferred waste management option and prevention as its preferred (landfill>energy from waste>recycling>reuse>prevention).  And which is now a priority order contained in the soon to be transposed revised Waste Framework Directive (rWFD).

The UK has had some success weaning itself off landfill, not that it could be argued it’s had much choice.  The management of waste is a European community issue which was first laid down in the original 1975 waste framework directive.  This has resulted in a number of European waste directives being introduced to limit waste airings.  Failure to comply with these directives, and the targets laid down in them, would result in infraction proceedings against a member state resulting in significant fines and national embarrassment. 

As a result of government activity to implement various waste legislation progress has been made over the past ten years.  Indeed a significant number of landfill facilities have had to close as a result of the impacts of this legislation - There are now around 450 landfill sites compared with 1,200 in 2001.  The move away from landfill has created new recovery and recycling markets.  However, EEF remains critical that the UK still lacks the necessary infrastructure and correct policies to divert significant quantities of waste from landfill cost effectively.

The new government clearly sees an improved role for waste management in the UK and the Secretary of State for Environment recently announced that DEFRA would perform a waste review for England.  

Why only England you might ask, well waste is a matter for each of the devolved administrations and is thus managed at national level.  However, the strategy is a bold and ambitious project whose results will no doubt impact each of the devolved government’s future policy strategies.

Waste has consistently eclipsed climate change as the priority environmental issue for manufacturers in EEF’s environment surveys.  This is in part down to the fact that waste is a clear and visible environmental issue impacting manufacturers on a daily basis and with direct financial consequences.  As a result EEF has established itself as a central figure on this issue with government and plays a critical role influencing a number of waste related stakeholder groups. 

We will make a formal response to DEFRA’s strategy review to ensure that waste continues to be diverted from landfill and that improved mechanisms are put in place quickly, to ensure that resources inherent in waste are extracted.  Your views on this issue would be most welcome.

Things are hotting up ahead of both, the deadline for CRC registration and government reviewing the scheme.

I hear that despite both DECC and the Environment Agency (EA) going all out to make sure that all organisations that should be registering for Carbon Reduction Commitment (CRC) Energy Efficiency Scheme, are signing up, less than half have already done so.

As well as this, my concern is that there are still organisations that consider that there is no need to register, because either the organisation is in a Climate Change Agreement, or they believe the organisation, as a whole, does not qualify.

All this registration confusion is taking place at the same time that government is considering what to do with this highly complex scheme. There is talk of a fundamental review, with some organisations calling for the cap-and-trade phase of the scheme, due to start from 2013, to be scrapped.

With government looking to simplify the UK climate change policy landscape, I can’t see that CRC will be left unscathed when DECC sets out details of the future of climate change policy in the ‘autumn’.

As for mopping up the organisations that have yet to register ahead of the 30th September deadline, I understand that the EA has an army of people phoning round organisations it believes should be registering. It shows how committed the Agency is to ensuring the scheme starts well. It may be too committed though, as it has phoned organisations that have already registered.

A welcome position from the EA is the message, “Do not delay registration even if your information is not fully accurate. We urge all organisations to register as soon as possible before the 30th September. We will work with you to resolve any errors in the information you supply.”

A word of warning, is that a number of registrants have lost the information they have entered due to not using the “save” button in the registration process. The Agency is advising that you regularly save your registration as you go through it. The registration is saved on the system for 30 days from when you last saved it.

One thing is for sure, this is not the last word on both registration and significant policy reform.