An environmental politics and ethics blog, for: genuine prosperity; a circular economy; health & wellbeing; respecting environmental capacities; optimum efficiency; renewability; fairness & equality for current & future generations, the world over; empowered, resilient local communities; a safer, more secure, sustainable world.
Environmental Permitting Regulations (2010) bring into England and Wales one
permit and a common procedure to replace separate controls (mostly 2007
regulations) on waste, pollution, water discharge, groundwater activity,
radioactive substances, and various directives including on mining.
running ‘regulated facilities’, typically industrial, waste, intensive
farming..., are required to hold a valid permit to legally conduct their
bringing a multitude of controls together EPRs aim for more efficient and
effective organisation, cutting complexity, reducing rigidity, cutting
ambiguousness and getting rid of unneeded bureaucracy, resulting in a more
economic system that encourages best practice, centring on medium and high
are enforced by sending out enforcement, suspension or revocation notices and
ultimately criminal prosecution can be pursued.
a regulated facility has no permit, has breached conditions on a permit or has
not responded as required to a previous notice an enforcement notice may be
sent stating: the regulators view, describing the breach, what has to be done
and by when (enforcement notices may be withdrawn and/or other notices sent as
regulatorsare the relevant local authority, such as Bristol City Council (pictured above)
or the Environment Agency.
in the regulators view there is a risk of serious pollution then a suspension
notice is sent out, suspending the permit, spelling out what the risks of
serious pollution are, what steps need to be taken and the timescale of action
(suspension notices may be withdrawn and indeed have to be when the regulator
is confident that the steps spelled out have been taken).
the sending out of notices alone is insufficient then criminal prosecution can
be pursued (though those operating/owning a regulated facility can appeal to
the Secretary of State).
found guilty in a Magistrates Court can result in a fine of up to £50,000
and/or a prison sentence of up to 12 months, whilst being found guilty in a
Crown Court can result in an unlimited fine and/or a prison sentence of up to 5
possible in court include: emergency action was needed; all reasonable steps
were taken; the owner/operator is someone else.
the methods that could be used by the construction industry to mitigate and
adapt to climate change? The construction sector at its best is adapting to climate change
by making the adjustments required due to the impacts of carbon already
emitted. It is also contributing to the mitigation of climate change by cutting
emissions to reduce future climate change. The construction sector is a big
user of energy and thus emitter of carbon, in its own offices and other
buildings, on its construction sites and through the total impacts of what is
constructed - it therefore needs to act in a wide range of areas.
to deal with mitigation of climate change. Best sustainability practice in the UK
construction industry currently means: helping to implementUK Strategy for Sustainable Construction 2008; liaising with the Building Research Establishment
(BRE) over its environmental assessment method (the BREEAM Standard) for
refurbishment and BRE's Green Guide to construction materials and components; liaising with the Centre of Refurbishment Excellence (CORE).
The best construction companies are assisting fully in the implementation of
the Code for Sustainable Homes 2006, supporting the UK government target that
all new homes will be zero carbon from 2016 and all new non-domestic buildings
by 2019 and the contents of Building Regulations Part L 2008 leading to these.
Existing buildings are the vast majority of buildings,
therefore best practice means: refurbishing to improve all insulation; reduce energy use
through use of natural light; use low-energy lighting; use more efficient
appliances; change to CHP and renewable energy sources; and reduce water use.
Best practice sustainable construction means using one’s own buildings and
sites sustainably eg ensuring energy and water are conserved well(working with the Carbon Trust and
Energy Saving Trust
on this helps). See the Carillion example here. Secondly
to deal with adaptation to climate change, so far as it allows us to do so. It’s
important that there is a wide ranging contribution to industry forums, working
groups, workshops and so on, to identify best practice and opportunities for adaptation in
the built environment. This helps in achieving a full, concerted response to
Defra's Climate Change Risk Assessment 2012 the first official report on the
risks of climate change specifically to the UK (see BBC report here). Getting
wide involvement of stakeholders in the built environment in the process of
adapting to climate change helps generate more and better solutions. Increased summer
temperatures, such as those recently experienced in the UK, can mean overheating inside buildings and around them, so to avoid
adverse effects on people’s health, concentration and productivity appropriate
measures to cool and shade buildings and spaces are required, such as: judicious placement
and use of trees; covered areas with open sides.
flood risk, increased risk of drought and more severe storms means making
greater use of sustainable drainage systems such as: green roofs; rainwater
harvesting; permeable pavements; infiltration trenches; filter drains; swales;
basins; ponds and wetlands. Increased pressure on water supplies means water
conservation and efficiency at all levels. It’s important to design and
construct buildings with adaptation to climate change as a planned high
Good advice on more sustainable construction from the Environment Agency here.
Given that the
Met Office has issued a heatwave "Level3" warning for the south-east of England it is appropriate to give
some thought to how and why the conditions are particularly hot in cities, like
London.Heatwaves are prolonged periods of excessively hot
weather compared to the usual weather in the area and to temperatures normal
for the season, so they are relative phenomenon.
Cities are warmer than the
surrounding countryside due to human activities: the Urban
Heat Island Effect (see the temperature map of London below to see why the term island is used). This effect happens because:
•Vertical structures behave like canyons,
cooling winds and convection are reduced, slowing the heat transfer awayfrom built-up areas.
•Heat absorbed during the day by concrete
buildings, road surfaces…is released during the night, in the same way a storage heater does its job
•Heat is emitted directly from the large
numbers of homes, workplaces and vehicles into comparatively small areas
Urban areas also dry very quickly, with drainage rapidly
taking water away. This and having few green areas means less heat is lost by
evaporation or transpiration by plants than in the countryside. Note Richmond
Park’s effect in the images below (below, bottom left is a cooler purple area corresponding to the park, whereas the pattern either side is a belt of warmer area colour coded green).
We can observe that the bigger the city generally the
bigger the urban heat island effect.It
is most apparent on clear and calm days and nights, particularly at night This
is exactly the conditions that occur in hot weather. A clear, calm summer London night is typically
6 °C warmer than in the surrounding countryside.
Air pollution factors compound problems. These days urban
air pollution is associated with dry, hot sunny days in spring and summer (see image of LA below),
rather than in winter (like the old London smogs were).
The main pollutants are now ozone, nitrogen dioxides and
particulates and the main cause is now emissions from cars, lorries and other
forms of transport that burn fossil fuels.Ground-level ozone is produced when the chemical
emissions react in sunlight and in warm weather over several hours (see image below).
Ground-level ozone can be blown across large areas of the
country and is not just in cities. Today, the most damaging pollution episodes
occur during hot, dry, sunny weather and often accompany heatwaves. Pollution
health impacts make heatwave health impacts much worse – and the biggest
impacts are on the elderly and those with existing heart, lung and other health
You can find advice on staying safe in the sun here.
Impact Assessment (EIA) can be used to increase environmental sustainability by
marking out all larger developments and those likely to have bigger impacts. Size
of development, however one measures that, may well not be the same as the size
of the environmental impact though. Where the authorities set the boundary
between where a development has impacts that are accounted for and impacts that
are not accounted for can often have no basis in reason. For example the
planning process in Bristol took little or no account of where the fuel for a
proposed biofuel power station came from and really only considered very local
impacts (see here and the palm oil plantation that replaced a forest in the image).
have by law to make key information publicly available. Best practice says this
should be done at an early stage, with good quantity and quality information
and plenty of opportunities for consequent broad-based public participation.
This is often not what happens in practice, with developers and councils much
more in the know, at both earlier and later stages, than the general
public.For instance raising with
planners the relevance of the UNECE Convention
on Access to Information, Public Participation in Decision-making and Access to
Justice in Environmental Matters, usually known as the Aarhus Convention, in relation to the biofuel
power station proposed for Bristol in the end did little more than cause some
slightly confused discussion at the planning meeting (see here).
possible impacts rather than waiting for them to happen, acting as a preventive
mechanism, identifying and requiring the avoidance, reduction of or
compensation for high impacts. This can be a stimulus to good design. This is a
very good thing, though if you don’t re-examine and reassess periodically you
may remain unaware of physical, biological and socio-economic changes. Narrow
definition of impacts might also mean that designers are not fully informed and
thus designs may be deficient.
environmental impact statement from the EIA process is there to be scrutinised
and accounted for in the planning process. Public participation is facilitated
at several stages and ideally results in cooperative working and ‘ownership’ of
developments - a good contribution to social sustainability. Opportunities for
public participation often come too late though and lack of early availability
of information impedes participation.
process ideally involves a wide range of disciplines, organisations and
individuals – and thus skills available for more effective and informed
decision making. The range of involvement can at times be narrow however and
inter-disciplinary working still has some way to go.
It will be
very interesting to see the extent to which new and updated EIA regulations
account for the need to: set boundaries on an informed, reasonable basis; make
a good quality and quantity of relevant information available to the general
public at an early stage; ensure plenty of opportunities for well informed and
supported public participation; define impacts in a more broad-based, inclusive
way; ensure that the practice of iteration is a very firm expectation; enable a
wide range of people, organisations and disciplines to be involved in EIA;
enhance interdisciplinary working.
Integrating an Environmental Management System (EMS) into your business gives you a structured framework for managing its significant environmental impacts. Other than improved
environmental performance an EMS can provide
a business with many other benefits too. Improved health, safety and quality management are
likely to result from implementing an EMS because of the plan, do, check and act process of seeking continual improvement one goes
through and the similarity with health, safety and quality
systems (see image above and links below). General management and efficiency improvements cut waste of resources, save energy and improve
transport logistics, with consequent financial savings and optimisation of
A formal system ensures better compliance with the
law, is backed up by regulators and cuts uncertainties – all of which cuts
risks and so cuts insurance costs.
An EMS demonstrates
organisational commitment and enables good relationships with stakeholders to
be built, strengthened and maintained. This is good for the activities of the
organisation as a whole eg in general relationships with the public, local
authorities and the media, when seeking additional business, seeking funds,
The concept of iteration/cycles is very important in both
educational and environmental senses. The reflection stage in learning and environmental
management cycles is particularly important because it can lead to highly
beneficial re-exploration and ongoing progress. Cycles are found throughout the
natural world of course: the carbon cycle; water cycle; nitrogen cycle; various geological cycles; and
indeed life cycles. Cycles are less common in modern, industrialised societies
but they are catching on: we recycle; we go through experiential learning
cycles; we build iterative, cyclic approaches into laws, regulations and
standards (see image of the Plan, Do, Check, Act cycle, sometimes called the
Deming or the Shewhart cycle).
Good teachers and good managers are sensitive to
their experiences and adjust what they do accordingly. We’ll know we have made
real progress towards a sustainable society when the idea of a cyclic economy
is commonplace (see image below).
Iteration is about repeating stages in a process in a cyclic
fashion and is a key concept in systems thinking. It is valued because of the
opportunities provided for improvements to be made due to re-exploration,
review and reflection…on environmental effects or learning needs and acting on
feedback to revise what is proposed and done.
Experience can provoke
thinking – and thinking can enable decisions. Taking decisions can lead to
actions. Reflecting on feedback from actions generates further experience and
so the cycle continues and goes forward with inputs altered (see image of the
experiential learning cycle).
Stages in human decision cycles may include: exploration; formulating problems,
opportunities and systems of interest; identifying feasible and desirable
changes; and taking action aimed at improving the situation; in addition
and use of a variety of conventional and innovative tools and techniques
may occur at any stage.
ISO 14001, which lays out what is needed in an EMS
(environmental management system), has iteration as a central feature (see
image above): policy leads to planning; plans are put into effect and monitored
against a standard, with appropriate corrective action; good management
practices are sensitive to the state of play, respond to feedback, review the
current system and make appropriate policy changes to spiral the environmental
management system around and forwards.
Of course, what we are talking about here is best practice –
and that is not always what happens. Best practice EIA (environmental impact assessment) is
cyclic/iterative. It is often much more of a straight line process than the
ideal portrayed in the image below however and this is part of the reason why the
European Commission are making substantial changes to their EIA Directive.
Systems thinking means seeing situations in total ie as a
whole, accounting for interactions, interrelationships and interdependencies
between parts. Its joined up thinking, recognising and forming networks, loops and cycles. It is the opposite of reductionist thinking, where an
explanation or solution is sought by breaking situations down into smaller
components. Systems thinking is constructivist or connectivist, attempting to
shed light on events that appear to be distinct by mapping linkages. In this
way complex events are understood better by seeing the whole, often
establishing that a system in total is different from what one would expect by
just looking at individual parts or by adding the parts together. It is often
the case, as Aristotle said in Metaphysics, that ‘the whole is greater than the sum of the parts’.