RIAs - Regulatory Impact Assessments or Results In Advance?

The Adam Smith Institute blog pointed to the new publication on Regulatory Impact Assessments (RIAs) from the Centre for Policy Studies (CPS) a couple of days ago, but this is a sufficiently important issue that I didn't want to simply let it go past because I hadn't had time to comment immediately.

All proposed legislation and regulation nowadays comes with an RIA attached. They are supposed to weigh up the costs and benefits of the proposals, to ensure that those proposals are not unduly burdensome.

The CPS publication entitled "RIAs: why don't they work?", prepared by Keith Boyfield for submission to the new Business Council for Britain, assesses RIAs and finds that they have failed in their objective. This will be no surprise to those who have suffered the effects of most legislation and regulation enacted since RIAs were introduced. It would be hard to argue that the burden of the state has fallen more lightly on the shoulders of its citizens in recent years.

Mr Boyfield provides an accurate diagnosis of many of the causes of the ineffectiveness of RIAs. They could be summarised as "no one in government wants anything more from them than a fig-leaf behind which to hide any flaws in a pre-determined set of measures". They are exercises in self-justification, not critical analysis.

Sadly, Mr Boyfield's prescription is to try to improve the process by which RIAs are prepared, rather than simply to scrap them. My objection is not that efficiency in government isn't important - it is vital - but that asking government (or its sub-contractors) to measure in advance the effectiveness of its own proposals is bound to end up with skewed results, however many refinements you introduce. Better to aim for clarity on the actual (rather than predicted) costs and impacts of government, and then let voters judge every five years or so whether they are getting value for money.*

BBC - The Broadcasting Bollocks Corporation

Chinese recycling
Photo courtesy of

In Radio 4's Home Planet today, Dr Lynn Dicks, pronouncing on the relative merits of recycling and landfilling, in terms of energy-consumption and carbon-footprint, said:

"Various people have looked at this from the point of view of greenhouse gas emissions, and again there are various different estimates from different people, but one particularly academic piece of research that I found was a full Lifecycle Assessment of the greenhouse gas or the CO2 emission from waste - either disposal of paper, including manufacturing of new paper and disposal to landfill, or recycling paper [Presenter interjects: And the lorry-loads that would be involved in that because that's something that Phil mentioned] and including taking the waste to the recycling facilities, disposing the residual waste after recycling... This was done by a consortium of people at UEA (University of East Anglia) and University College, London in 1995. It was all based on Milton Keynes, and what they found was that... oh well, I'll give you the figures - recycling paper produced about 50 kg of CO2 per tonne; if you disposed of it in landfill and made new paper, 550 kg of CO2 per tonne. So, it's much better to recycle."

1995! Our information and waste disposal techniques haven't improved since 1995? Oh well, if this is what the recycle-nuts want to hang their hats on, let's have a look at it. You can download it from here.

Take this, from p.11:

A second problem that occurs at the manufacturing stage is the scarcity of data, particularly with regards to the manufacture of products using secondary plastic materials. Whilst information concerning energy use is sometimes available, data for the remaining environmental inputs and outputs is either commercially sensitive or simply unreported. In this exercise, the process data (emissions arising directly from the process) has been taken as being identical for both primary and secondary plastics, but an energy saving (and thus the associated emissions of generation) of 77% is obtained by using secondary materials, as suggested by White, Franke and Hindle (1995).

Or to put it more succinctly, "we don't know how much energy is used in production of items from recycled feedstock, so we're going to assume it's 77% less than in the same processes using raw materials." That's how to get the "right" result. Use assumptions that make sure you get the desired outcome.

Even more questionably, from p. 13:

For each average tonne of waste which is disposed of to landfill in the UK, 81% by volume of the gaseous emissions are released to the atmosphere, 13% are flared, and 6% are used in landfill gas generating schemes (Williams, 1994 and Bellingham et al, 1994). This paper uses this average data when calculating the amount of electricity recovered. The electricity generated will displace emissions from old coal-fired power stations, and this study gives credit for these.

This probably wasn't even true in 1993 (the most recent year for which the Williams and Bellingham papers are likely to have had data). As I have mentioned before, I ran (until recently) the company that sold many of the flarestacks used on British landfills, so I know that a lot more flares went into landfills before 1993 than is usually assumed in government studies aiming to maximize the claimed reductions in landfill-gas emissions since then (which undermines the Government's claims that we are on target to meet our Kyoto obligations, but that is another story).

Whatever the case in 1993, nowadays this is absurd. The usual figure quoted for the capture-rate of methane from landfills over the lifetime of a modern, engineered landfill is about 85%. This is the figure used as standard in the government-approved model (GasSim) for estimating emissions from landfills. During the period when the gas is contained (i.e. after the phase has been "capped") and being converted (i.e. until the gas quality falls so low that it can no longer be flared), the capture rate is probably close to 100% in modern, engineered landfills. The 85% represents an allowance for emissions from the uncapped phase being tipped at any one time (the usual source of any odour), and slow seepage of the tail-end gas once it is no longer possible to flare it, by which time you are talking low volumes and low percentages of methane. Given sensible incentives, it would be possible to further reduce these emissions so that the overall capture-rate was over 90%, but let's take 85% as a reasonable average. Of that, provided that sensible incentives are maintained for its utilisation, the vast majority will be converted to electricity.

The impact on the LCA of assuming 19% capture, of which 6% utilisation, rather than the current figures of 85% capture of which perhaps 80% utilisation, is enormous. Methane (CH4) has a Global Warming Potential 23 times higher than carbon dioxide (CO2). If you assume that most of the carbohydrates in your waste are converted into landfill gas (roughly 50:50 CH4 and CO2), that most of that gas gets out, and that very little of it is used to displace fossil-fired generation, the comparison between landfill and any other form of waste disposal will be a no-brainer. Of course landfill is the worst technique if it's simply belching methane into the sky.

But this is bollocks. Methane isn't belching out of modern landfills - it is being captured and used to provide the largest single source of new renewable electricity in the country. Last year, landfill-gas generators produced nearly 4 TWh of renewable electricity. Onshore wind projects produced 2.8 TWh, offshore wind less than 0.7 TWh, while co-firing of biomass with coal, and refurbished hydro plants produced almost 2 TWh each.

The authors of the paper carefully ensured that it was not possible to trace their calculations from their assumptions to their conclusions. So it is not possible to reconstruct their calculations with more accurate assumptions. But even where they state their results, without showing how they were calculated, further errors intrude. On p.17, it is assumed that 13,000 grammes of methane are released per tonne of plastic landfilled (around a quarter of the methane emission-rate of paper). Ah yes, that famous putrescible plastic. This is such a beginner's error, that you have to wonder whether the authors had ever set foot on a landfill, or spoken to a waste-disposal operator.

And there is more. Landfilling of aluminium is assumed on the same page to produce 206.5 kilogrammes of methane per tonne of aluminium. Biodegradeable aluminium joins biodegradeable plastics in these academics' parallel universe. And thanks to what I can only assume is a labelling error, it is magnified by a factor of one thousand - not 206.5 g/t, but 206.5 kg/t in their scheme, or four times as much methane as is released from landfilling paper.

This study is so wrong that it isn't even in the right ballpark and so obfuscated that it is impossible to correct. And yet it is on studies like this that recycle-nuts like Dr Dicks rely to justify their brain-washed mantra of "reduce, reuse, recycle". That may be the right approach, in some circumstances, but where appropriate (as indicated by relative costs), not as a rule. The current EU Directives on waste disposal, the Government's dirigiste waste strategy (in compliance with the EU), and councils' complex collection schemes (in compliance with the Government's strategy), are based on nothing more than incompetence and distortion.

A record breaking exam year! (Again)

In just a couple days the nation's sixteen year olds will be receiving news of how they have done in their GCSEs and the following week it will be the turn of A-level students.  It is traditional, therefore, this time of year to tell all the kids it was much harder in my day and they are, effectively, a bunch of numpties who have been given straight As on a plate.  But is that fair?  In part, I'm afraid, it seems it is.  The numpties part is unfair, granted, but the dumbing down, easy to get an A grade bit is not.  From the criticism that flies about, you would get the impression ch

DfT logic

The Department for Transport is to publish a consultation report it commissioned on cutting the death toll amongst younger drivers in the autumn. The major proposal is increasing the age limit for gaining a full driving licence to by a year to eighteen. To do this they will impose a 12-month training period for new drivers, in effect preventing 17-year-olds from holding a full licence. According to DfT research a 12-month learning period would save up to 1,000 deaths and up to 7,000 serious injuries a year. All very well, but I don't really understand the logic entirely.

LibDem magic - it will be so because we say so

Last Friday, the LibDems launched "new transport polices to create a zero carbon transport system by 2050." And no one noticed. Not even their website, which carried the press release, but doesn't seem to carry the document, Towards Carbon Free Transport.

We are given a few hints how they might achieve this mighty ambition, but are otherwise left to speculate. The hints are:

  • Introducing a distance charge on road freight, related to weight and emissions, as an incentive to shift freight to rail, raising at least £600m a year
  • Establishing a new 'Future Transport Fund' to fund a programme of investment on our railways; removing bottlenecks, providing more trains and reopening lines
  • Backing new North-South and East-West high-speed rail lines to the best European standards to replace internal flights
  • Toughening new legal limits on the average emissions of new cars sold in the EU, to be reinforced with a steadily declining total that reaches zero by 2040
  • Introducing a new 'Climate Change Charge' on internal flights, except life-line routes, starting at £10 per ticket to help fund the 'Future Transport Fund,' which will generate at least £150m a year

So we will still be using trains, planes and automobiles, but they will somehow magically become zero-carbon vehicles. I'm looking forward to discovering how the full document explains how they will achieve this miracle.

UPDATE: They have now (Monday, 8th August) provided a link to the report. As expected, it is a mixture of the sound and the fantastic. Detailed analysis is provided in the Comments.

Sun King Ken

Molly and City Hall

SUMMARY: Ken Livingstone's solar panels for City Hall are nearly ready to switch on. They cost something over half a million pounds, and could reasonably be expected to deliver around 75 MWh a year (not enough for 20 typical houses). For the same money, you could get over 2,000 MWh from a wind turbine, maybe 8,000 MWh from conversion of waste to energy, and yet more carbon-savings if invested into renewable heat or insulation improvements for London houses. Or he could simply have let taxpayers keep their money and make their own decisions about what to do with it. What follows is an examination of whether there are any rational grounds for this sort of wasteful expenditure, or whether this is a classic example of the triumph of style over substance.


Demos recently published a booklet called The Disrupters, on the subject of low-carbon innovation. There's a lot of nu-speak, and not much consideration of hard economics, but it's not a bad publication - some of the examples cited are genuinely interesting, and some of the lessons taken from their experiences are the right ones. It provides the jumping-off point for this post not because of the publication itself, but because of a picture that they casually used today to promote their podcast on the subject.

It is a picture of City Hall, home of Ken Livingstone and the Greater London Authority, in which solar panels can just be seen being installed. I hadn't realised they were going solar at the GLA, but, photovoltaics (PV) being the least economic of all renewables, I thought I'd look into it a little to see what we could learn from this case.

The most detailed information available comes from the London Climate Change Agency (LCCA), which states that they are installing 70 kW of panels, which will generate "3.1million kWh of renewable electricity over their lifetime". This, they say, "will reduce the CO2 emissions of City Hall by 3,000 tonnes in its lifetime – enough to fill 3,000 hot air balloons". Elsewhere, we find the Authority scaling this down to 1,000 tonnes of CO2-savings over a 20-year lifetime, though still filling 3,000 balloons. 3,000 tonnes is quoted on another site. Let's assume the intended figures are 3,000 tonnes and 20 years. How does that stack up?

The Carbon Trust

If you had a load of money you wanted to invest in a project, how would you go about ensuring that you made as much return for as little risk as possible?  Chances are you'd seek some sort of professional advice.  Now suppose that someone forced you to hand over your own money and they told you that they would invest it for you - you wouldn't be very happy.  You'd even less happy if they told you that they were just going to have a punt with it rather than treating it like they had something to lose.  This, in a nutshell, is what the government is doing with our hard earned mone

Junior doctor change over runs smoothly/was a complete shambles

So, depending on who you believe - yesterday's changeover at the NHS was either a smooth transition with no problems whatsoever or it was a complete shambles.  My cynical money is on the shambles.  Fortunately, I was not hit by a car nor had some other freak accident so managed to keep myself out of hospital yesterday.  As such I have no first hand evidence of what it was all like.   The BMA, however did and said that hospitals were encountering "a catalogue of problems" as they rushed to fill hundreds of junior doctor posts after the appointment system was plague

One man and (not) his dog

This isn't the most critically important story I've ever posted about, but it does demonstrate the knee-jerk mindset of our legislators and government agencies.  It is reported today in the times that Animal Health, the agency responsible for the state veterinary service, has banned vets and other staff from taking their dogs in cars on visits to farms or other premises when on official business.  This will also affect private vets on government contracts.  That’s right, the government is telling vets how to look after animals.  Incredible. 

You, the customer, the loser

Two government bodies - Ofgem (the electricity and gas regulator) and the Energy Savings Trust (EST) - are consulting simultaneously on what to do about green electricity tariffs, those electricity-supply deals, like NPower Juice or Scottish & Southern RSPB fund, which allow you to think you are being green. Both Ofgem and EST are interested not in the fundamentals of whether these tariffs really are green, but how best to maintain the fiction that they are. I have sent the following email to both of them in response to their consultations:


Our company is a leading generator of renewable electricity. We commissioned our first plant in 1987, and last year generated over 300 GWh of renewable electricity.

It is not our intention to reply in detail to your consultations on Developing Guidelines for Green Supply and Accreditation of Green Tariffs, because we believe that it is not practical to sell genuinely green electricity to customers in the current UK market, and that all the tariffs being described as green are perpetrating a fraud on their customers. It is meaningless to debate which form of the fraud is more or less green, and how they might better be administrated.