1. LCAs and policymaking: The good, the bad, and the ugly Dr Michael Warhurst, Friends of the Earth

2. Contents The good… The bad… The ugly… What can we do? An alternative approach Conclusions

3. The good In theory, LCA allows you to.. –Evaluate all environmental (& other) impacts of a product/process –Compare different products/processes –Make ‘science based’ decisions based on this information The reality is rather different…

4. The bad (i) A simplification too far? –LCAs attempt to turn complex and uncertain reality into a simple answer –Risk assessment and (regulatory or environmental) impact assessment also try to do this E.g. the interaction between risk assessment and LCA –It is possible to have years of debate on the risk assessment of one chemical - e.g. Diethylhexyl phthalate (DEHP), but still have unresolved areas, partly because scientific understanding is never perfect E.g. new data from China suggesting DEHP exposure leads to reduced serum free-testosterone in men –An LCA involving a product that contains DEHP should take into account DEHP toxicity. Yet the toxicity is subject to uncertainty, and the LCA magnifies that.

5. The bad (ii) It’s not only chemical risk assessment that is a problem for LCAs. Other big areas of uncertainty include: Climate change, e.g. What is the cost of one tonne of CO 2 ? What’s the difference between biogenic and fossil fuel derived CO 2 ? Sequestration of carbon - is landfilling plastic a good thing? What about compost? What source of power, or method of transport, or efficiency of equipment? Will this change in the future? Resources, e.g. What will be the per-capita available land in the future? How equally should - or will - this be distributed? What are the limits? How will competition for land between people, food, biodiversity, fuel and feedstocks develop?

6. The Ugly He who pays the piper calls the tune LCAs have enough complexity to make it possible to prove almost anything Why is it that LCAs commissioned by trade associations always back their case?

7. What can we do? Accept that the idea of the perfect life cycle assessment technique, that will create ‘scientific’ results, is unachievable –Too many variables, too many uncertainties, too many decisions have to be made What is the impact of one tonne of CO 2 on the world? If LCA is to be used at all, it must be totally transparent, and point out all assumptions, simplifications and omissions –Independent review will increase the usefulness of the results It will always be difficult or impossible to create policy (regulations) based on an LCA approach – e.g. Integrated Product Policy - lots of talk, little action –It will be even more difficult to enforce LCA- based measures.

8. An alternative approach? Is old style, issue by issue, regulation so bad? –It is proven to improve environmental performance and promote innovation –It is easy to apply and enforce But what about unintended consequences? –Often not as big an issue as is claimed, particularly if you look at the long term impacts –Can have a procedure for exceptional situations: E.g. No landfill or incineration of reusable, recyclable or compostable, unless there is unequivocal evidence from a high quality, openly available and independently reviewed LCA that landfill or incineration is better. Possible model? - The Energy Using Products (EUP) Directive –Product groups selected on basis of energy use –Procedure allows incorporation of other environmental considerations –Should move into action in 2007 When will Integrated Product Policy start making a real impact?

9. Conclusions LCA sounds great in principle, but is very complex - and easy to manipulate - in practice LCA is easiest to apply within organisations, where you have agreement on methodology, weighting and approach to uncertainty Policy approaches and legislation based on LCA (like IPP) are hard to establish, and even harder to enforce A more workable approach is likely to be to continue with issue-by-issue legislation (e.g. EUP) and simple policy approaches (e.g. waste hierarchy) –Perhaps with an allowance for ‘exceptional circumstances’ through unequivocal LCA.