The Environment Agency is pressing ahead with plans to require major industrial sites to report annually on how efficiently they use materials, energy and water.
The idea first appeared in the Agency’s corporate strategy for 2006-11, Creating a Better Place, which stated that by 2011 a new resource efficiency index, or scoring system, would be created to show industry how to use resources more efficiently. It also promised the Agency would publish resource efficiency league tables.
It aims to have the system in place in time for companies to submit 2008 data in early 2009. But the Agency’s tight budget – which is expected to shrink further over the next few years – could cause delays.
The Agency wants to introduce the mandatory reporting of resource efficiency data – using a common, electronic format – for all sites that it regulates under the pollution prevention and control (PPC) regime.
For some years these have reported data on waste sent off-site, which, together with emissions data, has been used to compile the Agency’s pollution inventory. But research for the Agency in 2004 found the regime was not doing enough to promote resource efficiency (ENDS Report 354, p 45 ). The latest data show waste leaving such sites is steadily increasing.
As well as allowing companies to benchmark their performance against competitors, resource efficiency data would be used “to inform government decisions on product policy by identifying the product streams that cause the greatest environmental damage”.
Both of these uses are potentially far reaching. Although most PPC permits require the operator to report on performance measures, only those on energy use are usually explicit, while reporting metrics are inconsistent and sites submit data using both paper-based and electronic systems. And while the government is beginning to grapple with waste minimisation, efforts to understand the national picture and devise policy are crippled by the paucity of data on resource use in different industries.
The Agency’s guess is that publishing a resource efficiency inventory will drive improvements over and above those derived from companies’ benchmarking their performance internally. “We’re fairly sure that emissions from PPC sites represent best available techniques (BAT)”, said Richard Clarke, Agency policy manager for industrial regulation, “but we’re less sure if the total amount of resources they are using represents BAT. Until we monitor it, it’s difficult to know.”
Work on developing the resource efficiency index is being conducted by Atkins, which also carried out the research for the Agency three years ago. The index has two parts: one lists the physical quantities of water, energy and materials used by the site per unit of output over a particular year. Sites using only a few materials would report data for each separately, while those using many different materials would report the total tonnage.
The other part measures the site’s resource use management, based on a questionnaire which asks questions such as whether the site has water, energy and materials usage targets; whether it monitors performance against targets; and who data is reported to. The index will also allow firms to enter the amount spent on resources and get an indication of potential savings.
Unlike the pollution inventory, which provides data for sites and for major sectors, such as food and drink manufacturing, different reporting metrics will be set for each subsector, such as baking or soft drinks manufacturing. The total number of subsectors will be substantial, possibly approaching 100, and will provide a more useful overview of which parts of the industrial economy offer the best opportunities for reducing resource use.
But data may not be published for individual sites if this would allow competitors to estimate a firm’s production rates. If this were the case, site-specific data would be published but the sites’ identity withheld. This would prevent the Agency from ‘naming and shaming’ particular sites or firms, but would still show the spread of performance and, over several years, subsector trends.
The Agency has yet to decide whether it would be cheaper and less bureaucratic to add resource reporting requirements to the existing reporting system for emissions and waste, or to develop a separate system. It may also produce a separate voluntary index and reporting tool for sites it does not regulate, such as schools and hospitals.