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 CO2? • What’s the difference between biogenic and fossil fuel derived CO2? • 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 CO2 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.