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‘ORA-CLE’ Eighth Edition February 28, 2020
Page 1 of 29
‘ORA’ the Original Recycling Association for a Cleaner Living Environment
‘PFO’ – the PRICE for OIL aka the OIL PRICE
aka THE PRICE is RIGHT?
DAILY Crude Oil prices shown in $ per barrel from 1987 to February 2020.
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Page 2 of 29
Would it be misleading to tell a story about the workings of the UK waste oil market
since the late 1970s? Such a story may not be fake news but would it be old news? To
avoid this story ending abruptly in February ‘2020’, perhaps it would make more sense
to look at this ending sometime in the recent past, by describing the waste oil market
that may have existed up to 2015? Whenever this look back into history ends, the story
would not be complete without providing an insight into how things may change in the
new imagined order, i.e. the climate change political world.
Crude Oil Price History
West Texas Intermediate (WTI) signifies light sweet low sulphur crude that is favoured
for producing petrol, which is perfect for the US market. Original Brent crude was not as
sweet as WTI and more suited for producing diesel for the European market. Today’s
Brent crude blend of 15 different North Sea crudes is still not as sweet as WTI but now
also good for producing petrol.
1973 was not the first time that OAPEC had tried to use oil for political leverage but it
was the first time that it succeeded in creating a real oil price crisis. The first attempt
being in 1963 (Suez Crisis) and the second attempt in 1967 (Egyptian / Israeli War).
The second oil crisis came in 1979 in the wake of the Iranian Revolution and although
global supplies only dropped by 4%, there was major global panic (UK motorists queued
for hours for petrol rations as they had in 1973) and within 12 months the crude oil price
doubled to $39.50 a barrel. The Iran / Iraq War followed and the oil price remained
unstable until the mid-1980s.
Then the Japanese led the way with multi valve engines and fuel injectors replacing the
thirstier carburettors, which resulted in the late 1980s oil glut and a subsequent 20 year
decline in the oil price which dropped below $10 a barrel in 1998.
WTI prices have been reported since
January 1986; Brent prices have
been reported since May 1987.
During the 1970s there were two oil
crises. The first crisis started in
October 1973 when the Organisation
of Arab Petroleum Exporting
Countries “OAPEC” (not to be
confused with OPEC) proclaimed an
oil embargo on all nations seen to be
supporting Israel during the Yom
Kippur War. The embargo lasted for 6
months and the crude oil price
increased by 400%, from $3 a barrel
to $12 a barrel.
Page 3 of 29
Waste Oil Values
On a Net Present Value basis, waste oil prices were at their highest during the period
from 1979 to the mid-1980s and then again during 2012-13. In theory, waste oil prices
should have hit an all-time high in 2008 when crude oil prices peaked at $144 per barrel,
but this period came off the back of the 2007 OSS v Environment Agency court case,
when apart from OSS, other PFO producers were still getting their ducks in a row. The
strong £ (peaking over $2) also mitigated some of the oil price increase.
When considering the impact that historical crude oil prices and oil commodity prices
have had on the UK waste oil price, it is important to consider that other key variable –
the £ to $ exchange rate.
When the DAILY Exchange Rate data is overlaid with the DAILY Brent crude price data a
different picture emerges:
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In $ terms, the 2008 crude oil price went higher than 2012-14, but in £ terms, the 2012-
14 crude oil price was higher than in 2008, when it hit record levels.
In addition to the £:$ exchange rate, it is also necessary to consider the elasticity of
crude oil to the price of various oil commodities:
During the collapse in the crude oil price to below $10 a barrel in 1998, bulk waste oil
prices were still £45 to £65 per tonne and apart from periodic fluctuations during 2005-
07, this position remained fairly stable until the 2008 crude oil price spike. However,
average 2008 waste oil prices remained relatively low compared to 2013 when waste oil
prices peaked at £280 per tonne, i.e. nearly 60% of the crude oil price.
Page 5 of 29
A TYPICAL LIFE CYCLE ANALYSIS?
Those who believe in the recycling of waste will often cite a Life Cycle Analysis that is
supportive of the recycling of a particular waste, versus the use of that waste as a fuel.
Likewise, those who believe in the recovery of waste for use as a fuel will make
reference to some other Life Cycle Analysis that favours that approach.
The word ‘Recycling’ has always been part of ORA’s name but that does not mean that
all of ORA’s Full Members recycle waste. In fact, during the last 22 years, the number of
members that do recycle waste has waxed and waned. Proximity to the waste arising is
an obvious consideration and the answer varies in each case. Life Cycle Analyses always
make assumptions about the proximity of waste to a particular waste recovery / waste
recycling process and this proximity principle is also enshrined in EU law.
Therefore, in addition to the Waste Hierarchy being an imagined order, the Circular
Economy is also an imagined order and just like religion, politics and climate change, an
individual’s beliefs and desires about those imagined orders will depend on their own
particular circumstances.
The recycling process that is known as the hydrological or water life cycle is probably the
simplest life cycle analysis of all, but it is certainly not simple. In very simple terms it is
the journey that water takes as it moves from the land to the sky and back again.
However, just describing this as a sequential process of evaporation, condensation and
precipitation misses out the complexity of the various options that prevail after the water
falling as rain, hail or snow has returned to the land.
During the next 15 years, through to 2035, in
the purported run up to ‘peak oil’, it remains
to be seen whether the market will continue
to hedge for crude oil / waste oil price
elasticity or decide that the situation is
inelastic. At some stage between now and
2050, large amounts of waste oil will continue
to be produced for 10 to 15 years after the
drop in demand for oil products. This must
mean that, at some stage; waste oil
collectors, processors and recyclers will price
waste oil as a hazardous waste rather than an
oil commodity. This may mean the price will
become inelastic or the elasticity will be
virtually non-existent, i.e. not increasing with
crude prices but decreasing in line with crude
prices. Even a squirrel prepares for winter,
but blind squirrels only find a nut now and
again. If common sense prevails, the future
market will not be a mirror image of the past?
Page 6 of 29
There are many different routes for water to take on land before the water evaporates
and returns to the land:
As rainfall, producing surface run-off, it may immediately collect in lakes or rivers
before returning to the sea or it may infiltrate the land accumulating as
groundwater and recharging aquifers before eventually reaching the sea. Aquifers
may store water for a very long time.
Potable water drawn from aquifers and drinking water from reservoirs may
become contaminated through use, passing through industrial processes, human
beings and animals before discharge as trade effluent or sewage to water
treatment works that discharge to rivers or direct to the sea.
Water consumed by plants may transpire to the atmosphere or be consumed as
food by humans or animals.
Freshwater reaching lakes and rivers may evaporate before it reaches the sea.
Freshwater flowing into the sea from rivers will mix with the seawater before it
evaporates. At first, the less dense freshwater will float on top of the denser
saltwater before eventually mixing with the seawater and creating convection
currents. In some cases, e.g. glacial melt, this mixing process can take ‘000s of
years.
Water falling as rain, hail or snow may freeze on reaching land and form ice. The
ice may not return to water for ‘000s if not a million years.
Some ice may sublime straight to water vapour and return to Earth’s atmosphere
without flowing into a river, i.e. sublimation cuts out the middleman.
ALL PART OF THE CYCLE OF LIFE
When water evaporates, it takes up
energy from its surroundings and cools
the environment. When it condenses in
cloud formations it releases energy and
warms the environment. The
evaporation purifies the water which
then replenishes the land with fresh
water. The flow of water and ice
transports minerals across the globe,
reshaping Earth through a process of
erosion and sedimentation. The water
cycle is essential for all life and
ecosystems.
Page 7 of 29
As water vapour is less dense than the nitrogen and oxygen in Earth’s atmosphere, the
natural buoyancy drives the humid moisture laden air higher in the atmosphere. As
altitude increases, air pressure decreases and the temperature falls. The lower
temperature causes the water vapour to form tiny water droplets that are visible as
clouds. As the droplets increase in size they return to Earth unless they are recycled
back to the higher atmosphere by rising warmer air.
Groundwater can spend over 10,000 years beneath Earth’s surface before finding its way
to the surface and eventually evaporating. After water evaporates it typically spends 9
days in the atmosphere before returning to land.
On average, water forming as ice in Antarctica will remain as ice for 20,000 years but
some of the ice is 800,000 years old. In contrast a glacier will only last between 20 and
100 years but when a river or glacial melt reaches the ocean; it will remain there for
more than 3,000 years before it evaporates.
Approx. 97% of the world’s water supply is stored in the oceans and the oceans supply
90% of the evaporated water that goes into the water cycle. If the water takes longer to
return to the oceans or the water returns more quickly than normal, the ocean levels rise
or fall. During the last ice age, when glaciers covered more than one third of Earth’s land
mass, the oceans were more than 120 metres lower than they are today. Just imagine
that amount of water stored on the land as ice. No wonder the Earth’s crust rises and
falls as the ice balance changes. Equally, during the last major global warm spell more
than 120,000 years ago, the oceans were 6 metres higher than they are today and three
million years ago they were up to 50 metres higher than today.
When ocean levels fall, the salinity of the oceans increases and when ocean levels rise
the salinity decreases. The changes in ocean temperatures and salinity change the
ecosystems. Without the water cycle supporting life and ecosystems and without the
evaporation of water cooling the planet, Earth’s surface temperature would be above
67oC and there would be no life.
Life cycle analyses for some waste streams are probably more complicated than the life
cycle analysis for water but the waste life cycle analyses are rarely / probably never
given the time and attention they require in order to make sense of them, to be factually
accurate and to be of any real value. Whether that means they are more or less
interesting than water is another question, but it is doubtful that life will depend on
them.
Page 8 of 29
THE TIDE IS HIGH (follow up to ‘Head Above Water’1)
The February 2020 Storm Ciara and Storm Dennis downpours raised the same issues
that were covered in the last soothsayer edition of ORA-CLE – ‘Head Above Water’.
With so much reliance on computer models rather than common sense, flood defences
erected in one town may save that community but by raising a column of water by a
metre or more only serves to increase the water levels further downstream. New river
level data fed into the computer then delivers the conclusion that more flood defences
are required further downstream……and on the story goes!
Furthermore, too many temporary flood defences only result in someone making a
judgment call about whether one town or one part of a town should be a sacrificial lamb
to protect another. There are many examples of this – Tunbridge Wells, Xmas Eve 2013
and more recently in Bewdley, Worcestershire during the beginning of Storm Dennis.
Why is it that major ports like Southampton; at the confluence of the rivers Test, Itchen
and Hamble, are able to carry out regular maintenance dredging to make sure that
approach channels and berths always have a safe depth of water for access for 64,000
annual commercial and recreational vessel movements, BUT the Environment Agency is
unable to dredge smaller inland rivers, just like their predecessors did before 1996?
The Agency cites the Water Framework Directive’s protection of sites with a high nature
conservation interest, as being their excuse, BUT the same directive also applies to port
authorities like ABP in Southampton. This does not add up!
The article in the The Telegraph quotes former Environment Secretary (2012-14) Owen
Paterson who accused the Environment Agency of using climate change as a "cop out".
He said "It has always rained in the UK in winter. The trick is to get it [the rivers] to go
down again. You have to manage the countryside and you have to manage the rivers. It
is a complete cop out to blame it all on climate change."
1 ORA-CLE 7TH Edition – December 2019
As reported in The
Telegraph after the storms
on the 17th February –
‘Don’t expect to be
protected from flooding,
Environment Agency to
warn’, is this a sign the
Agency is going to concede
that tinkering with flood
defences does not work?
Page 9 of 29
Innes Thomson, the chief executive of the Association of Drainage Authorities, claimed
the flood risk in some areas would be "massively reduced" if silt was removed from
swollen rivers.
"The Environment Agency has been hiding behind EU rules supposed to protect wildlife,"
he said. "But the technology exists to safely remove silt, and the EA knows it. It's
happening in some places, but not nearly enough."
As detailed in ‘Head Above Water’, it is simply not the case that the UK is experiencing
unprecedented levels of rainfall. If river levels are at unprecedented levels in flood
conditions, is that simply due to tinkering with flood defences? If a property owner’s
garden flooded because a neighbour diverted surface water into their garden, they would
be quick to point out that the problem is their neighbour’s fault but when the
Environment Agency diverts water no one thinks to ask why?
Governments don’t think twice about excavating 2 metres below ground level to widen a
motorway to create an un’SMART’ motorway or digging down 5 or 10 metres to build a
new road or create a railway cutting through a hillside for HS2. If excavations up to 10
metres deep are okay along 150 miles of new track for HS2, why is it not okay to dredge
and remove 1 to 2 metres of silt from a problematic 5, 10, 20………..mile stretch of a
river?
Dropping a river level by 1 or 2 metres in dry conditions surely provides an extra 1 to 2
metres of river capacity during heavy rainfall conditions, so that a river that normally
floods to a 5 metre height only rises to 3 metres, thereby making temporary flood
defences redundant.
Owen Paterson accused the EA
of having a mentality that
dredging was "a bad idea".
"What these people have
unwittingly done with their
idiotic views, they have
delivered an environmental
catastrophe of the first
order," he said.
Page 10 of 29
The following Annual Rainfall graph now shows this in more detail:
However, annual rainfall figures for the 42-year period since the end of 1977 do not
paint the complete picture. For example:
June 2007 was Sheffield’s wettest month but 2012 was the wettest year
October 2000 was Cardiff’s wettest month and 2000 was the wettest year
December 2006 was Glasgow’s wettest month but 2015 was the wettest year
For the first 20 years after the Intergovernmental Panel on Climate Change (IPCC) was
formed, the IPCC used to argue that global warming would cause droughts. During the
last 10 years the argument has switched from global warming to climate change, which
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Annual Rainfall (mm) from 1978 to 2019
Cardiff
Sheffield
Glasgow
In ‘Head Above Water’, a
summary of the historic
rainfall DATA for Cardiff was
compared with the DATA for
Glasgow and Sheffield.
Page 11 of 29
causes heavier downpours not droughts. At first glance, the Annual Rainfall graph
appears to show the UK having its wettest years in the last 20 years, thereby implying
that everything is getting out of control. However, as rainfall memories fade with age,
this requires further scrutiny.
Analysing Statistical Data
All annual rainfall data can be analysed using statistical techniques. Provided there are at
least 25 data sets, the results can be used to determine whether the entire data set is
part of the same normal distribution curve or circumstances have changed part way
through. When data moves out of control, i.e. outside of the normal distribution curve,
this may be proof that something has changed.
This can either be done using the annual rainfall data or by using all the January data
over 42 years or all the February data etc. If the charts show that all the data is within +
or – 3 standard deviations then the second test is to check that there are no trends of 7
consecutive data points or more, above or below the average line. If this test is met, the
third test is used to check that there are not 7 data points as upward or downward
trends that cross over the average line.
If 99.7% of the
measured data is within
+ or – 3 standard
deviations of the mean
value, it is possible to
determine whether the
data is representative
and what the likely
minimum and maximum
values will be over time.
In order to do this using
25 or more datasets, it
is necessary to show the
data using statistical
charts.
Page 12 of 29
The Historical Situation in Sheffield
For the 42-year period from September 1977 to January 2020 there are 509 monthly
data sets. The monthly rainfall data is shown below:
The statistical control chart shows:
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SHEFFIELD
Monthly Rainfall mm
Average Monthly Rainfall
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Average Annual Rainfall mm
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Over the 42-year period, the top 5 wettest
months were (only 2 in the last 20 years):
1. June 2007 – 286mm (30% of 2007)
2. June 1982 – 225mm (27% of 1982)
3. Dec 1978 – 208mm (25% of 1978)
4. Nov 2019 – 200mm (19% of 2019)
5. Oct 1998 – 198mm (21% of 1998)
42-year monthly average – 70mm 42-year monthly max – 286mm
42-year annual average – 837mm 42-year annual max – 1146mm
Results
None of the data is outside of
the +/- 3 standard deviations
and there are no trends of 7 plot
points or more either above or
below the mean and there are
no upward or downward trends
of 7 points or more. Although
June 2007 was the wettest
month, 2007 was not
exceptionally wet. This chart
suggests that annual rainfall
could reach 1,229mm, which is
7% higher than the 1,146mm
recorded in 2012. None of the
last 42 years would appear to
have been unusual. There is
also some evidence that 3 of the
last 20 years have been
exceptionally drier than the
previous 20 years.
Page 13 of 29
The Historical Situation in Cardiff
For the 42-year period from September 1977 to January 2020 there are 509 monthly
data sets. The monthly rainfall data is shown below:
The statistical control chart shows:
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CARDIFF
Monthly Rainfall mm
Average Monthly Rainfall
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Average Annual Rainfall mm
Mean + 3 std devns
Mean - 3 std devns
Over the 42-year period, the top 5
wettest months were (3 in the last 20
years):
1. Oct 2000 – 268mm (18% of 2000)
2. Aug 1997 – 251mm (20% of 1997)
3. Dec 1993 – 250mm (22% of 1993)
4. Oct 2019 – 236mm (17% of 2019)
5. Jan 2014 – 235mm (17% of 2014)
42-year monthly average – 97mm 42-year monthly max – 268mm 42-year annual average – 1165mm 42-year annual max – 1504mm
Results
None of the data is outside of the +/-
3 standard deviations and there are
no trends of 7 plot points or more
either above or below the mean and
there are no upward or downward
trends of 7 points or more. October
2000 was the wettest month and that
year was exceptionally wet but still
within 3 standard deviations. This
chart suggests that annual rainfall
could reach 1,643mm, which is 10%
higher than the 1,504mm recorded in
2000. None of the last 42 years would
appear to have been unusual. There is
some evidence that 3 of the last 20
years have been exceptionally drier
than the previous 20 years.
Page 14 of 29
The Historical Situation in Glasgow
For the 42-year period from September 1977 to January 2020 there are 509 monthly
data sets. The monthly rainfall data is shown below:
The statistical control chart shows:
The above chart suggests that annual rainfall could reach 1,773mm, which is 10% higher
than the 1,603mm recorded in 2015. None of the last 42 years would appear to have
been unusual. There is some evidence that 3 of the last 20 years have been
exceptionally drier than the previous 20 years.
So, Everything Must be Alright Then? There is Nothing to Worry About?
The most important thing is that statistical data should only ever be interpreted using
statistical control charts. It is a mistake to look at a chart and make a casual observation
that values appear to be ‘low’ or ‘high’. As the normal distribution curve shows, 68% of
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Glasgow
Monthly Rainfall mm Average Monthly Rainfall
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Annual Rainfall mm Average Annual Rainfall mm
Mean + 3 std devns Mean - 3 std devns
Over the 42-year period, the top 5
wettest months were (2 in the last 20
years):
1. Dec 2006 – 299mm (21% of 2006)
2. Dec 1999 – 297mm (20% of 1999)
3. Sep 1985 – 288mm (22% of 1985)
4. Oct 1995 – 280mm (23% of 1995)
5. Nov 2015 – 278mm (17% of 2015)
42-year monthly average – 104mm
42-year monthly max – 299mm 42-year annual average – 1249mm 42-year annual max – 1603mm
Results
None of the data is outside of
the +/- standard deviations and
there are no trends of 7 plot
points or more either above or
below the mean and there are
no upward or downward trends
of 7 points or more. December
2006 was the wettest month but
2006 was not exceptionally wet.
Page 15 of 29
data will lie within 1 standard deviation from the mean and 95% is within 2 standard
deviations. The 3 standard deviation lines can be used to predict the worst-case
positions for 99.7% of occasions.
This valuable information should be used to prepare for the worst-case drought years
and the worst-case wet years? It is simply no use trying to measure the worst-case wet
weather conditions by reporting that a river’s level is at a record high. When the river
has not been dredged for nearly 25 years and flood defences have been put in place
upstream of the previous record level then of course river level records will be broken.
The situation in Cardiff & Glasgow has been ‘business as usual’ for the last 42 years but
Sheffield’s rainfall has become more variable? If it has, it is still much drier than Cardiff
& Glasgow. Why is that? Does that mean that Sheffield’s rainfall has increased or that
wind patterns have changed?
The Met Office’s records for Sheffield go back to 1883, so it is possible to extend the
date range to see if there are any different conclusions. The following statistical shows
the situation for the last 62 years:
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Sheffield 1958 to 2019
Annual Rainfall mm Average Annual Rainfall
Mean + 3 std devns Mean - 3 std devns
What would the great engineers such as Isambard
Kingdom Brunel and Joseph Bramah make of the
makeshift approach to temporary flood defences,
that start to move whenever the river levels reach
the top of the barrier and risk a mini tsunami if
they collapse?
Why are memories and experience lost in the
annals of time, why is there no ‘heavy lifting
anymore’?
Would Brunel have been a better engineer if he’d
had a computer?
Page 16 of 29
This demonstrates the point made earlier, that a casual observer looking at the data
from 1978 to 1990 may incorrectly conclude that the data was less variable than the
period after 1990. However, including the period from 1958 to 1977 now changes that
perspective.
This chart does show that there was a trend of 7 points below the mean from 1970 to
1976 but during the 12 years prior to that, from 1958 onwards, the wet weather years
were no different to the period from 1995 to 2007. The rainfall data for the period from
1970 to 1976 is not statistically ‘normal’ for the 62-year period shown in the chart.
Something caused that 7-year trend to prevail (known as a ‘special cause of variation’)
and that 7-year dry period ended with a severe drought, i.e. the famous summer of 76.
During the early 1990’s Her Majesty’s Inspectorate of Pollution and other parties, used to
issue reports about the long trail of acid gas emissions from UK coal-fired power stations
that extended across the North Sea and into continental Europe & Scandinavia causing
damage to woodlands and forests. It was also claimed that this blanket of acid gases had
a localised cooling effect on the UK’s climate, which caused drier weather. The Large
Combustion Plant Directive has forced many high SOx emitting power stations and large
industrial combustion processes to close or install flue gas abatement systems to reduce
the acid gas emissions. Therefore, in that regard, the UK’s atmosphere is now much
cleaner than it used to be. However, no party with any authority refers to the fact that
lower acid gas emissions means less cooling and warmer wetter weather. It is much
easier to blame the problem on a 150 parts per million increase in the concentration of
carbon dioxide in the atmosphere.
It will always be the case that in any locality (variances across one town or city can be
huge) heavy rainfall over several days, weeks or months can be the real problem, i.e.
the cumulative effect. When the rolling cumulative 3-month charts are plotted for the
42-year period shown above, the wettest cumulative 3 month periods stand out as
follows:
Sheffield – May to July 2007: 482mm or 51% of the annual rainfall
Cardiff – Oct to Dec 2000 and Nov 2015 to Jan 2016: 636mm or 42% to 53% of the
annual rainfall
Glasgow – Nov 2006 to Jan 2007: 785mm or 65% of the annual rainfall!
Most of this peak rainfall eventually escapes to the sea, and within any 12-month cycle,
during a 3-month dry period, the Environment Agency inevitably declares a drought and
water companies think about hose pipe bans.
If he was alive today, what would Isambard Kingdom Brunel2 do about this? Would he
blame climate change? Or would he conclude that if the peak loadings have been higher
2 Isambard Kingdom Brunel FRS was a British civil engineer who is considered "one of the most ingenious and
prolific figures in engineering history", "one of the 19th-century engineering giants", and "one of the greatest figures of the Industrial Revolution”, [who] changed the face of the English landscape with his ground breaking designs and ingenious constructions. He built under rivers and through hills, creating the longest tunnels, the biggest bridges and the speediest ships the world had ever seen. He astonished Britain by proposing to extend the Great Western Railway westward to North America by building steam-powered, iron-hulled ships.
Page 17 of 29
during the last 20 years then something should be done about it? Without a computer he
would probably seize control of his slide rule, a book of logarithmic tables, a sheet of
paper and a pencil.
If he had a computer, he would probably search the internet for where the largest 50
reservoirs are located and he would see that the total storage capacity is 1.7 billion
cubic metres of water but these reservoirs were built during the 100 year period from
1888 onwards and the last one was built in 1989. He would no doubt consult with
Thomas Hawksley (the engineer who designed the first reservoir at Lake Vyrnwy, Wales
to supply water to Liverpool) and he would surely conclude that the UK needs more
reservoirs and bigger reservoirs, strategically located so as to intercept rills, channels,
tributaries and streams.
A large river may be referred to as a 10th order stream, i.e. the first order stream is met
with a second stream to become a second order stream that meets another stream to
become a third order stream etc. When flooding occurs, higher order streams take
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longer to build up to flood stage than lower order streams and longer for the flood to
subside.
The River Severn is the longest river in Great Britain – 220 miles long, with a catchment
area of 4,400 square miles and with a typical flowrate of 60m3 per second and 600m3 a
second in flood conditions (measured at Bewdley, Worcestershire).
Therefore, intercepting the lower order streams on higher ground prevents the higher
order streams from reaching flood conditions. Such reservoir projects could even be
used to support hydro-electricity schemes that produce renewable electricity,
even when the wind does not blow!
Geologists have spent decades studying why streams flood. An increase in the rainfall
loading is not the real issue, it is the increase in urbanisation. Changes to the land in the
drainage area of a stream, such as the addition of buildings and roads, can change how
a stream floods. Buildings and pavements that cover the ground prevent infiltration and
cause increased surface water run-off. Increased stream runoff means smaller amounts
of rain will cause the stream to reach flood stage than before alterations to the land took
place. The stream will flood more frequently. For the same amount and rate of rainfall
that caused flooding prior to building, the stream will reach flood stage quicker and the
flood will be deeper. After urbanisation, the stream reaches its peak flood level quicker
and rises to a higher level than before urbanisation. Unless countermeasures are
engineered and installed, an urbanised area will flood more frequently and severely than
the same area that existed before.
The Victorians were well aware of this and knew that as the human population increased,
urbanisation increased, and more reservoirs were required to provide water for industrial
and residential use. By building reservoirs to solve a water supply problem this also
eliminated major flooding.
The Environment Agency is also well aware that reservoirs are the
answer to the problem
In November 2016, the Environment Agency published a 188-page report titled
“Delivering Benefits Through Evidence – Design, operation and adaptation of reservoirs
for flood storage”.
The Intro states – “This report is the result of research commissioned by the
Environment Agency’s Evidence Directorate and funded by the joint Flood and Coastal
Erosion Risk Management Research and Development Programme”.
The report’s Concluding Remarks state – “The use of storage reservoirs to provide flood
protection is now well established in the UK [i.e. up to 1989], with many hundreds of
such structures in operation. As the need for flood protection increases in light of climate
change, population growth and industrial development, it is clear that many more flood
storage reservoirs will be required in the future”.
Well, what are we waiting for then? Another 3 years have passed by!
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It is no coincidence that no new large reservoirs have been built since 1989 when the 10
Regional Water Authorities were privatised for £7.6 billion. Just like HS2, building new
reservoirs are a major infrastructure project. It is a nonsense to suggest that people
should become accustomed to their riverside properties flooding much more often in the
future and that the Environment Agency cannot protect everyone. Spending small
amounts of money on ‘soft engineered solutions’, i.e. flood defences (£4 billion) is not
the answer. Hard engineered solutions are the answer, whatever the cost? If
Government is unwilling to commit to this, homes and businesses should not be allowed
permission to build on flood plains?
Perhaps Brunel would want to name a series of projects like this – ‘HS2’ or something
like that! Or perhaps he would just take the literal meaning of his name - Iron Bright or
Iron Axe. The very thing that should be used on some of the ‘soft’ flood defences and the
Agency’s computer flood modelling system when new reservoirs have been built.
Page 20 of 29
NEW ENVIRONMENT BILL3
Structure
The Bill is split into eight Parts, with Part 1 containing three separate chapters. Part 1
concerns Environmental Guidance, Part 2 Environmental Governance in Northern Ireland,
Part 3 Waste and Resource Efficiency, Part 4 Air Quality and Environmental Recall, Part 5
Water, Part 6 Nature and Biodiversity, Part 7 Conservation Covenants and, last but not
least, Part 8, the ever exciting, Miscellaneous and General Provisions.
It looks like a fairly comprehensive piece of legislation, although it has only been through
its first reading in the House of Commons, so its contents might change.
The Government certainly thinks its comprehensive. When it was published, environment
secretary Theresa Villiers said that it formed part of the ‘pitch to be a world leader on
the environment as we leave the EU’, with it setting ‘a gold standard for
improving air quality, protecting nature, increasing recycling and cutting down
on plastic waste’.
Environmental targets
The Bill requires the Secretary of State to introduce long term targets for priority areas
of air quality, water, biodiversity, resource efficiency and waste reduction. These targets
are set for 15 years in the future and the Secretary of State is under an express duty to
endure that the targets are met.
There is to be a review of these targets by 31 January 2023 and subsequent five yearly
reviews. The purpose of the review is to consider whether the targets would significantly
improve the natural environment in England. The purpose of the review is not to see
whether or not the targets are on course to be met, nor does the Bill specify any
corrective action if it is evident that targets are or are likely to be missed.
Progress is to be reported annually in a report to be laid before Parliament. However, it
is important to remember that, for example, the Natural Capital Committee has been
scathing in its criticism of recent ‘Progress Reports’ against the 25 Year Environment
Plan. The net effect? Put simply, the Bill doesn’t yet require meaningful progress reports.
Does that mean that the “targets” are arguably misleading? Is their effect to essentially
delay the urgency and necessity of environmental improvements to a date 15 years in
the future? If there is no continuing public system of review to see whether we are ‘on
target’, there is always the risk that the Bill simply kicks the can down the road. But
surely that cannot be the intention?
There is a power to either revoke or lower targets. This can be done if the Secretary of
State is satisfied that ‘meeting the existing target would have no significant benefit
compared with not meeting it or with meeting a lower target’ or ‘because of changes in
circumstances since the existing target was set or last amended the environmental,
social, economic or other costs of meeting it would be disproportionate to the benefits.’
3 Analysis courtesy of 6 Pump Court Chambers
Page 21 of 29
This raises the potential prospect that the Government will exercise a discretion to
license heavily polluting projects on the basis they make economic sense. For example,
can Heathrow be justified on the basis of its economic benefit, despite the potential
environmental cost? Lowering the target requires a change in circumstances, but there
doesn’t appear to be any materiality threshold that must be reached, only that the
Secretary of State must consider that the ‘cost’ of meeting the target is disproportionate
to the benefits. That ‘cost’ could include a lost opportunity cost or a loss of predicted
economic benefits resulting from a major infrastructure project.
One welcome addition from a previous draft is the introduction of a two-yearly review of
“significant developments in international legislation on the environment” that will then
be “factored into the Environmental Improvement Plan and environment target setting
process.” Whilst this doesn’t guarantee alignment (expressly ruled out by the current
Government in the context of the UK-EU relationship) it does keep our place on the
world stage closely under review.
Environmental principles
The Secretary of State must prepare a policy statement on environmental principles,
explaining how the principles should be interpreted and proportionately applied by
Ministers of the Crown when making policy.
The environmental principles have been reduced to just 5. These are:
(a) the principle that environmental protection should be integrated into the making of
policies,
(b) the principle of preventative action to avert environmental damage,
(c) the precautionary principle, so far as relating to the environment,
(d) the principle that environmental damage should as a priority be rectified at source,
and
(e) the polluter pays principle.
A Minister of the Crown is now required to “have due regard” to the policy statement on
environmental principles currently in effect. This is a slight change in wording from the
previous draft, that only required Ministers to “have regard to” the environmental
principles.
This raises the question as to what “due regard” actually means. It’s arguably a step up,
potentially introducing a more objective element into the legal test to be applied. Due
regard implies a degree of weight behind the decision-making process that was
completely absent before. However, it is a long way from the establishment of an
overarching environmental objective which a number of commentators actively
campaigned for.
This legal framework is also a considerable distance from current EU law, which
enshrines environmental principles in a constitutional treaty as a legal requirement, with
a direct impact on all areas of EU policy that link with environmental protection.
Page 22 of 29
Article 11 of the Treaty on the Functioning of the European Union reads:
“Environmental protection requirements must be integrated into the definition and
implementation of the Union’s policies and activities, in particular with a view to
promoting sustainable development.”
Article 191 of the TFEU begins with:
“1. Union policy on the environment shall contribute to pursuit of the following
objectives:
- preserving, protecting and improving the quality of the environment,
– protecting human health,
– prudent and rational utilisation of natural resources,
– promoting measures at international level to deal with regional or worldwide
environmental problems, and in particular combating climate change.”
Part of the difference is that EU law has at its heart that overarching objective to
improve the quality of the environment. The current draft of the Environment Bill sets
out a method of influencing policy, but only where it is not considered disproportionate
and apparently yielding little by way of result if the Minister of the Crown decides, after
“due” consideration, that the proposed policy should not be restricted by an
environmental concern.
The Office for Environmental Protection (OEP)
The Environment Bill creates the OEP, whose principle objective will be to contribute to
environmental protection and the improvement of the natural environment.
The OEP will have to prepare a strategy that sets out how it intends to exercise its
functions and how it intends to avoid any overlap between itself and the Committee on
Climate Change (CCC). The relationship between the OEP and the CCC is likely to be
particularly important, not least because the CCC appears to be concerned that the OEP
will have the effect of forcing it to dilute its environmental message.
The same strategy must also set out the OEP’s enforcement policy, in particular that sets
out how it will determine whether failures to comply with environmental law are serious.
And it appears to be envisaged that the OEP will uphold environmental standards
predominantly through direct engagement and formal notices. Don’t expect the OEP to
take many cases to Court.
The Government has committed to having the OEP up and running by 1 January 2021
but there is a huge amount of work to do. One key area is on the implementation of
environmental law. The European Commission has historically looked not only at the
extent to which law was transposed but also how it operated in practice. In theory,
developing closer relationships with local authorities may yield quicker environmental
results. However, the emphasis on local authorities may also pose a problem. Taking air
quality as an example, if the principal obligations on tackling air quality are to fall on
local authorities and their already stretched budgets, is the existence of the OEP likely to
spur them to action?
Page 23 of 29
And the Bill doesn’t address those concerns that have been raised about the
independence of the OEP and its funding. So much of this is going to depend on how the
OEP develops in practice.
The excluded matters
Matters that remain excluded from the scope of the Bill are disclosure of or access to
information, the armed forces or national security and taxation, spending or the
allocation of resources within government.
This has already been the subject of much criticism. In addition, there is no non-
regression clause. However, Ministers must make a statement that, in their view, new
Bills will not have the effect of reducing the level of environmental protection provided
for by any existing environmental law or a statement that the Minister is not able to take
that view.
Some specific highlights
There are powers to impose producer responsibility obligations under Schedule 4;
Financial penalties will be able to be imposed for the emission of smoke in smoke-
controlled areas in England, up to £300;
The Environmental Protection Act 1990 is amended to allow for regulations to be
introduced that will establish an electronic waste tracking system.
The Verdict
The Bill is a step in the right direction in terms of providing a much-needed update on
the legislative framework for the environment in the UK. However, there are real
concerns about the efficacy of the Office for Environmental Protection; but we’ll have to
wait and see how that develops. It’s also worth mentioning that the Bill of course
contains the usual statement that the Minister, in this case Theresa Villiers [now
changed to George Eustice], is satisfied that the provisions of the Bill are compatible
with the European Convention on Human Rights – after the success of Urgenda in the
Netherlands, this raises the prospect of similar human rights challenges against the
finalised Act.
Critically, because net zero is now enshrined in law, policy and practice going forwards
have to promote environmental objectives, otherwise in just a few years’ time the UK
will have to implement a wall of legislation, bringing with it serious potential economic
costs. It may be easy to point out certain arguable flaws in the drafting of the Bill but
ultimately there can be only one direction of travel.
BIO-DIVERSITY NET GAIN
The new Environment Bill will mandate a measurable 10% Biodiversity Net Gain for most
new developments in England. Once mandated, biodiversity net gain will move to a more
quantitative, measurable and transparent based assessment using the DEFRA
biodiversity metric tool to quantify biodiversity losses and gains in terms of ‘biodiversity
Page 24 of 29
units’. The DEFRA biodiversity metric tool can be used to calculate the ecological baseline
value of a site pre-development and the predicted ecological value of a site post-
development using detailed design proposals. It is essentially an evolving process that
involves regular communication between project managers, designers, landscape
architects etc.
Although biodiversity net gain is not yet mandatory, many local planning authorities are
already adopting it. Achieving a 10% biodiversity net gain can be difficult and may
involve finding off-site areas in which it is possible to undertake woodland re-planting to
compensate for the loss of biodiversity within the development site. This would involve
producing a report documenting the ecological baseline of the site, and the number of
units generated by the site post-development. The report would state whether the
development achieves the 10% biodiversity net gain, and if not, suggest habitat
creation/enhancement measures both on-site and off-site that could be undertaken to
achieve the 10% biodiversity net gain.
CAN NEW TECHNOLOGIES SOLVE THE PLASTIC
WASTE PROBLEM?
Dow is forming global partnerships to break the cycle of plastic pollution by re-thinking
how plastics are designed, manufactured and recycled. Dow believes that if plastic waste
can be made to be a valuable raw material for producing new plastics, the pollution
problem will be solved. Easier said than done?
Dow claims this thinking is already resulting in a new generation of technologies being
implemented worldwide. A new bio-based solution is being implemented with remarkable
results. One of Dow’s partners is UPM Biofuels in Finland. UPM claims to produce paper
from sustainable forests and Dow has found a way of extracting a bio-based oil as a
residue from the paper pulp production, that can be used as a feedstock to produce
plastic that is suitable for 100% recyclable milk cartons and other types of food
packaging.
Dow have also partnered with Dutch company Fuenix Ecogy to produce an oil from
plastic waste that can be used to produce high quality plastics for use in sensitive
applications such as meat and cheese packaging. They claim that 70% of the waste
plastic ends up as new plastic.
Dow has also launched trademarked AGILITY CE shrink film that can be produced from
waste plastics including used shrink film. Previously, used shrink film could not be
recycled.
The plastic end of life challenge has also been pursued by Procter & Gamble with their
PureCycle Technologies. This revolutionary solvent-based process removes colour, odour
and contaminants from polypropylene plastic waste to transform it into a “virgin-like”
resin that can be used in new plastic products. This works by using additives
manufactured by Milliken & Company and the first commercial scale process is due to be
commissioned in 2021.
Page 25 of 29
Currently only polyethylene terephthalate (PET) and high-density polyethylene (HDPE)
are economically viable for recycling. PureCycle focuses on polypropylene (PP) because it
is the second most used plastic in the world and currently only 1% is recycled. PP is used
for the majority of plastic bottle caps, luggage, carpets, computers, phones and grocery
packaging. However, as it retains pungent smells and contaminants when it is recycled,
it is restricted to things like park benches and car bumpers.
Procter & Gamble claim that the solvent choice plus the specific process steps, allow
them to tailor the PureCycle Process to purify the recyclate in a manner that no one else
has been able to do before. The recycled resin can then be combined with Milliken’s
additives so that the output is not limited to black and grey products. The first
commercial plant will process more than 50,000 tonnes per annum of waste PP. Procter
& Gamble’s ambition is to build 25 plants around the world, each one bigger than the
one before, to PureCycle 10 to 20 percent of all PP.
EU (Withdrawal Agreement) BILL
Government Ministers to decide (new clause 26) if any court or tribunal should be
bound by rulings from European Court of Justice
House of Lords claims this risks leading to “significant legal uncertainty” for
individuals and companies if case law can be reinterpreted at any point
The previous version of the Bill (i.e. pre-General Election) only gave the Supreme
Court and High Court judges the right to reinterpret EU case law.
Retained EU Law can be altered after exit day with courts prone to political
manipulation
How will this impact the OSS v Environment Agency caselaw and the PFO Protocol
Review
How will this impact the legal position with SWOBs
PFO PROTOCOL REVIEW
The first PFO review meeting will take place at Ashorne Hill, Leamington Spa, on the 25th
March.
The review of all 13 Quality Protocols is continuing but there have been a number of
delays including during the election period. There is currently a call for evidence out on
the first three QPs (Compost, Anaerobic Digestate, and Poultry Litter Ash) and the
Agency are hoping the initial review of these will be complete by the end of April. Next in
line for review is the Inert Aggregates QP followed by the PFO QP (hopefully by start of
Summer).
Page 26 of 29
The process will work as follows:
Initial review by Richard Fairweather, EA Senior Advisor (Resources Frameworks)
and Subject Matter Experts within the Environment Agency to determine Pro’s
and Con’s of QP in its current form.
Call for Evidence both internally within the EA, and to external interested parties.
These revolve around general items of clarity and product specifications as set
out in the Briefing Note issued in August 2019. There may also be further
questions that arise from the initial review with the Subject Matter Experts.
Review of evidence to determine if the Agency will continue to support the QP in
its current format or withdraw support with a view to revision.
If the Agency support the QP in its current format it will be reissued as a
Resources Framework and hosted on Gov.uk.
If support is withdrawn, Industry can ask the Agency to work with them to revise
the document so that it meets current standards. In such circumstances the
Agency’s charging scheme will apply at minimum £125 per hour. If any issues
identified in the call for evidence can be overcome an agreed Resources
Framework will be issued and hosted on Gov.uk. It should be noted that in some
cases where the Agency agrees to undertake a revision it may not be feasible to
update the QP. For example, if the end of waste tests could not be met. The
chargeable revision process does not guarantee an updated Resources
Framework can be produced and published.
ORA is registered with the Agency as an Interested Party for the PFO Protocol Review.
ORA’s objective is to reach a members’ consensus by May or June at the latest, so that
ORA is then able to respond to the EA’s call for evidence sometime this summer. The
outcome of this process will have an impact on waste oil recovery operators (PFO &
RFO), waste oil recyclers and waste oil collectors. If the Agency decides not to continue
with the Protocol this may also have ramifications for other End of Waste positions, e.g.
for electrical oils and laundering. Now that the UK Withdrawal Bill is law, government
ministers have the authority to reinterpret EU case law and/or direct UK courts to
reinterpret.
Although the PFO Protocol was successfully defended 7 years ago, the question now
arises whether the actions which were recommended for PFO residual should be the
starting point for this review? If so, what should be the new non-waste comparator in
place of HFO, e.g. MFO or LFO? Furthermore, is the proposed distillate spec from 2016
still fit for purpose? Should different specs apply to inland and marine use? Other
considerations will be debated and explored during the meeting.
Page 27 of 29
APPROPRIATE MEASURES FOR PERMITTED
FACILITIES THAT TAKE CHEMICAL WASTE
(including WASTE OILS)
ORA’s January meeting included details about the phasing out of SGN 5.06 to make way
for new guidance “appropriate measures for permitted facilities that take chemical
waste”. Waste oils are included in the definition for “chemical waste”. This was originally
planned for June last year but then delayed until the clinical waste consultation process
was completed. Further delays then followed with the BREXIT impasse and the general
election.
As predicted in January, the new guidance is now out for consultation (announced 3rd
February 2020), which will close at 11.45pm on 6 April 2020.
This new guidance will also incorporate the relevant requirements of the waste treatment
best available techniques conclusions publication made under the European Industrial
Emission Directive (2010/75/EU).
The preparations for the new Waste Treatment BREF (Best Available Techniques
Reference) were first outlined during ORA’s January 2019 meeting and the BREF Working
Group was formed in August last year. The working group members are Steve Chalupka,
Barry Couzens, Gareth Kelly and Vin Vernon (Neil Holland had to drop out but is trying to
facilitate input from Veolia’s Technical Manager – John Humpage). It is not too late for
this consultation to be handled via ORA’s BREF Working Group and if you would like to
be involved in that process then please get in touch.
REMEMBER that the measures set out in this Guidance will need to be implemented by
2022 (via variations to permits) and unlike the previous SGN 5.06 there are now lots of
“MUST” do requirements.
More details are available from the following link:
https://www.gov.uk/government/consultations/appropriate-measures-for-permitted-facilities-that-
take-chemical-waste
If you do not wish to support ORA’s BREF Working Group to produce a consultation
response, you can still provide your own response via the following link:
https://consult.environment-agency.gov.uk/environment-and-business/appropriate-measures-for-
chemical-waste/
ORA’s AGM – 8th OCTOBER 2020 at ASHORNE HILL
More details will be announced in April when the Early Bird offer tickets go on sale.
Terry Waite CBE will be the After-Dinner speaker at this year’s event.
Terry was born in Bollington, England on the 31st May 1939. He was educated locally
and received his higher education in London.
Page 28 of 29
On leaving college, he was appointed as Education Advisor to the Anglican Bishop of
Bristol, England and remained in that post until he moved to East Africa in 1969.
In Uganda, Terry worked as Provincial Training Adviser to the first African Anglican
Archbishop of Uganda, Rwanda and Burundi and in that capacity travelled extensively
throughout East Africa. Together with his wife Frances and their four children he
witnessed the Idi Amin coup in Uganda and both he and his wife narrowly escaped death
on several occasions. From his office in Kampala, he founded the Southern Sudan Project
and was responsible for developing programmes of aid and development for this war-
torn region.
In 1972, Terry responded to an invitation to work as an International Consultant to a
Roman Catholic Medical Order and moved with his family to live in Rome, Italy. From
this base, he travelled extensively throughout Asia, Africa, North and South America and
Europe both conducting and advising on programmes concerned with Institutional
Change and Development, Inter-Cultural Relations, Group and Inter-group Dynamics
and a broad range of development issues connected with both health and education.
In 1980, he was recruited by the Archbishop of Canterbury and moved to Lambeth
Palace, London where he joined the Archbishop’s Private Staff. In his capacity as Advisor
to the Archbishop, Terry again travelled extensively throughout the world and had
responsibility for the Archbishop’s diplomatic and ecclesiastical exchanges. He arranged
and travelled with the Archbishop on the first-ever visit of an Archbishop of Canterbury
to China and had responsibility for travels to Australia, New Zealand, Burma, USA,
Canada, The Caribbean, South Africa, East and West Africa to name but a few places.
In the early 1980s, Terry Waite successfully negotiated the release of several hostages
from Iran, attracting worldwide attention. In 1983 he negotiated with Colonel Ghadafi for
the release of British hostages held in Libya and again was successful.
In January 1987, while negotiating for the release of Western hostages in
Lebanon (which included the journalist John McCarthy), Terry himself was
taken captive and remained in captivity for 1,763 days, the first four years of
which were spent in total solitary confinement changed to a radiator for more
than 23 hours a day.
Following his release on 19th November 1991, Terry was elected a Fellow Commoner at
Trinity Hall Cambridge England, where he wrote his first book Taken on Trust, which
quickly became an international bestseller. Following his experience as a captive, Terry
decided to make a career change and determined to give himself to study, writing,
lecturing and humanitarian activities.
His second book, Footfalls in Memory, is a collection of selections from books, poems and
prayers, which Waite had read throughout his life and then remembered during his
solitary confinement in Beirut. Published in 1995, it, too, became a bestseller.
Terry has contributed articles to many journals and periodicals ranging from the Reader’s
Digest to the Kipling Journal and has also contributed articles and forewords to many
books. Terry Waite gives audiences a perspective of world affairs founded on open
communication, cooperation and a deep understanding of diverse cultures.
Page 29 of 29
FILL THIS SPACE
MEMBERS’ SPACE
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members, or for publishing a member’s editorial about a particular topic that is of
interest to them, or about a new exciting business development.
For more details email:
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Any member or non-member can use this space to advertise their products or services to
ORA members. Any member may have an existing or new product/service offering that
may be of interest to other members. For more details and to advertise in this space
please email:
ORA-CLE and its contents are confidential, protected by law and legally privileged. Only access by ORA
Members and their professional advisors is authorised. Any liability (in negligence, contract or otherwise)
arising from any party taking any action, or refraining from taking any action on the basis of any of the
information contained in ORA-CLE is hereby excluded. Please do not disclose the contents to any person other
than your professional advisors (subject to them accepting these conditions) or other ORA Members. Do not
copy the information in any medium or use it for any purpose whatsoever. Except where stated otherwise
copyright belongs to the Original Recycling Association Limited and as the author, it asserts the right to be
identified as such and it hereby objects to any misuse thereof.
Original Recycling Association Limited, 6 Abbey Court, High Street, Newport, TF10 7BW
Tel: +44 (0) 1952 306228 www.ora.org.uk
