Peak Oil? 

Clearly I don't have enough work to occupy me, as I was recently reading up on the topic of 'Peak Oil'.  This is the theory that there will come a time when, globally, we hit the maximum achievable extraction of oil reserves, and thereafter everything will go into a pronounced decline.  You've probably read about this - Hubbert's original paper on the subject dates back to 1956, and when I was studying Biology and Natural Resources in University, this kind of theory was all the rage and formed a kind of doom-laden backdrop to my contemplation of what adult life might be like.  After all these years, it is still difficult to shake off the mental picture of living in a hovel on some remote Welsh hillside, having to defend my last few drops of fuel oil against concerted attacks from ragged bands of natives straight out of a Zombie Apocalypse movie.

Hubbert Peak Oil Plot
Hankwang at English Wikipedia [GFDL (, CC-BY-SA-3.0 ( or CC BY 2.5  (], via Wikimedia Commons

Hubbert originally predicted that US oil production would peak in the 1970s, and it is certainly the case that the number of discoveries of new reserves has been in sharp decline.  As you would expect within the kind of community that loves to utter prognostications about such things, there is some variation of opinion as to when we will hit Peak Oil - but a sort of consensus has coalesced around the idea that it will be around 2030.  I therefore feel justified in moderating my dystopian tendencies with a reasonable dose of agnosticism on the subject.  Perhaps the UK's obesity epidemic may come to our rescue, after all?

Some kinds of resources give rise to stress and speculation, not to mention provide the ground for impending crisis, because they are finite in nature.  Others cause very similar difficulties because of exactly the opposite characteristic.  This week, I have been studying the EU's new Insurance Distribution Directive, which has been repapered by the FCA and is due to hit us straight between the eyes on the 1st October.  In the course of my studies, it seemed natural to take a look at the EU's site, detailing the new regulations, in order to help me understand the innumerable changes that are occurring to the FCA Handbook.  This stuff is not for the faint-hearted.  The EUR-Lex website appears to have been designed quite specifically to intimidate, to imprint a model of bureaucracy simply through a combination of impenetrable structure and sheer volume of words.  The IDD alone amounts to 41 pages of verbiage, wrapped in jargon and delivered in the usual robotic fashion that is at the core of the EUR-Lex publishing system.  This is material which has been designed, from the ground up, to reinforce your second-class status within a grander scheme of things.

What the FCA then does with this is the interesting part.  As far as I can see, a significant part of the processing of EU Directives is simply to repaper them.  I found a great deal of the text simply copied and pasted, with no attempt at interpretation or application - so the probability of yet more MiFID II nonsense is high.  That's not a great place to start, but next what appears to happen is that the widest possible range of sections within the FCA Handbook simply get altered, to bring them into line with the IDD.  I don't want to test your patience, so I will restrict my list to the main Handbook sections:  Glossary, PRIN, SYSC, COND, FIT, TC, GEN, FEES, MIPRU, IPRU, COBS, ICOBS, CASS, PROD, SUP, DISP, COMP, CREDS and PROF.  And a whole new pile of sections get added to the existing Handbook - with electronic publishing tools, and a certain kind of motivation, there is no limit to the size of this thing.

That is to say, on 30/09/2018, vast swathes of the Handbook will change overnight.  You thought you knew it?  Now you don't.  Actually, you didn't know it - the sheer scale of the thing makes that an impossibility.  But those bits that you thought you knew, well you'd better just start all over.  Which is kind of what we do at ValidPath:  this is the ultimate Forth Bridge repainting exercise, except that every time we restart the process we find we need more paint, because the bridge just grew a little bit more.  Over the next few weeks, we'll be reviewing each of those updated sections in the Handbook, but in the meantime for ValidPath Members, there's a quick introductory page to the subject.

It could be that, globally, we are now approaching 'peak oil'.  There is absolutely no sign that we might be anywhere near 'peak regulation'.

Kevin Moss, 17/08/2018