Newsletter Q2 2013

Welcome to our summary of the best of the sustainability and environmental compliance news items that appeared on our website www.environet.ie over the past quarter. We now have over 500 Irish environmental professionals subscribing to our service. This is a free service, issued every quarter. If you wish to unsubscribe please click the link at the end of this mail.

Best Regards

Gerard Kelly

CONTENTS

Sustainability – What can it mean for your business? (25/7/2013)

Industrial Emissions Directive Transposed (26/6/2013)

Closure Costs to Increase Substantially (9/7/2013)

7^th EU Environment Action Programme Agreed (31/7/2013)

App of the Quarter – Kingsoft Office (10/7/2013)

Sustainability – What can it mean for your business? (25/7/2013)

We all want to live sustainably and sustainability has been a buzzword in the business world for a number of years. However its usually been developed as part of a marketing exercise and hasn’t been used to drive the business forward. The concept of sustainability, implemented properly can, at the very least, be a significant driver of savings and, if fully implemented, can become the Business Plan for an organisation.

The best known definition of sustainability comes in the context of ‘sustainable development’ from the UN Brundtland Commission of 1987:

“sustainable development is development that meets the needs of the present without compromising the ability of future generations to meet their own needs.”

The diagram above illustrates the integrated nature of the concept of Sustainability. It brings together the three main impacts of any business, Economic, Environmental and Social. This ability to bring together all aspects of the management of an organisation under one concept is very powerful and allows key business decisions on BAT, suppliers, customers, society, health & safety or investment etc. to have the ‘is this sustainable?’ test applied.

We are helping many successful businesses in Ireland to use the Sustainability concept to drive savings, ensure compliance, increase sales and build value.

For more information on implementing Sustainability for your organisation please contact Gerard Kelly on 058-51155.

Industrial Emissions Directive Transposed (26/6/2013)

It was four months late but in April 2013 Ireland implemented the requirements of the Industrial Emissions Directive through SI 137 of 2013 and SI 138 of 2013. SI 137 is mainly procedural while SI 138 makes some significant changes to the current IPPC and Waste Licensing regimes currently regulated by the EPA. In a previous news item we listed the likely changes to current IPPC/Waste licensing as follows:

• ‘BAT conclusions’ should be the reference for setting permit conditions.
• EU BAT reference documents will be updated at least every 8 years.
• BAT emission levels can be exceeded where there is ‘disproportionately high costs compared to the environmental benefit.’ Such derogations need to be documented by the EPA in the licence issued.
• ELVs (Emission Limit Values) specifically set out in the Directive cannot be exceeded.
• A ‘baseline report’ on soil & groundwater conditions should be prepared for each facility. The Commission will establish guidance on the content of the report.
• Where process effluent is discharged to a municipal wastewater treatment plant, the effect of that treatment can be taken into account when setting ELVs.
• The EPA can grant a temporary derogation to BAT ELVs for a period not exceeding 9 months when a facility is testing emerging techniques.
• Groundwater monitoring must be carried out at least every 5 years.
• Licence conditions must be updated within 4 years of publication of new BAT conclusions.
• The EPA is now required to issue a report to the licensee within 2 months of an inspection/audit taking place.
• With some exceptions, existing installations shall have until 7 January 2014 to comply with the requirements of the Directive.

All of the above requirements have now been implemented and will come fully into force from 7 January 2014. Regarding EPA reports on audits and inspections, not only must these be sent to the licensee within 2 months, they must also be available to the public within 4 months of the visit to the site taking place.

Closure Costs to Increase Substantially (9/7/2013)

The EPA has just released a draft update to their 2006 ‘Guidance on Environmental Liability Risk Assessment, Residuals Management Plans and Financial Provision’. The Financial Provision’ element has not been addressed to any great extent in the current document and will be the subject of a separate guidance document. Our initial comments on the document are given below:

RMP/CRAMP

• The EPA is requesting that closure costs should be calculated assuming that a third party is required to carry out all of the work involved. In other words immediate closure should be assumed with all staff at the facility ceasing to work. Currently many facilities have estimated closure costs based on the closure event being known well in advance. This allows the site to use its resources to manage much of the work involved under the day-to-day running costs of the site. The new approach will add substantially to the estimated costs of closure and is likely to result in unrealistically high cost estimates.

ELRA

• The error in the current guidance document whereby environmental costs are multiplied by the probability of occurrence has finally been addressed. For example, we don’t insure our houses for their value and multiply it by the probability of being destroyed by a fire. We insure for the full value of the house. The EPA is now applying the same logic to site risks. The maximum likely cost associated with all risks should be estimated and a financial provision put in place to cover the worst case risk.
• The ELRA example given in the document refers to a bond being put in place to cover the cost of liabilities under the ELRA. However most sites would expect site insurance to cover these risks. The EPA will need to address the distinction between insurance and bonds in the Financial Provisions document in order to bring clarity to the whole area of how various environmental liabilities can be underwritten.

The draft guidance document can be downloaded here and is open for comment until 30^th August 2013 http://www.epa.ie/pubs/consultation/assessingenv/

7^th EU Environment Action Programme Agreed (31/7/2013)

It’s often difficult to get excited about aspirational documents emanating from the EU. However, since the 1970s, EU Environment Action Programmes have set the agenda for developments in both policy and legislation. The 7^th, titled “Living well, within the limits of our planet" was recently agreed and runs until 2020. Some of the more significant elements are as follows:

• Limit landfilling to non-recyclable and non-recoverable waste by 2020;
• Develop a legally binding framework beyond 2020 to enable Member States and industry to make the necessary investments in emissions reduction, energy efficiency and renewable energy, taking into account the indicative milestones set out in the Low Carbon Economy Roadmap to 2050;
• Address EU soil quality issues including consideration of  a binding legal framework;
• Establish a more coherent policy and legislative framework for sustainable consumption and production;
• Establish an EU-wide quantitative reduction headline target for marine litter;
• Address the combination effects of chemicals and safety concerns related to endocrine disruptors and nanomaterials across all relevant EU legislation;
• Further develop inspection support capacity at EU level, in order to increase the efficiency and effectiveness of inspections. This is intended to contribute towards a more level playing field within the EU;
• Phase-out environmentally harmful subsidies at Member State and EU level;
• Integration of environmental considerations including water protection and biodiversity conservation into land use planning decisions, with a view to making progress towards the objective of no net land take by 2050.

So we can expect that most of the EU, and therefore Irish, environmental legislative initiatives will be based on the above list for the foreseeable future.

App of the Quarter – Kingsoft Office (10/7/2013)

Each quarter we pick one smartphone app which we believe enhances productivity or is particularly useful.

Its always handy to have the ability to view MS Office attachments to emails when out of the office. This free app (originally developed for Android but with an iOS version now available) lets you do that and more. The Android version has the following features:

• Open and edit Word, PowerPoint and Excel files;
• Open PDF files and view full screen;
• Open and edit password restricted files;
• Support for cloud storages such as Google Drive and Dropbox;
• Save a Word Document as a PDF.

We have trialled a number of paid Apps including QuickOffice and Documents ToGo, both costing approximately €10. We have found the interface and flexibility of Kingsoft Office to be better than other similar apps.

Verdict:4/5 Excellent App for Android users. Needs more development on iOS.