Electronic Supplmentary Supplementary Material
1 Summary of the use of LCA in England
1.1 Approach
To illustrate the application of LCA in England, Heiskanen’s (1999) categorisation of the definitive, conceptual and facilitative application of LCA has been used. The definitive application of LCA is to find a definitive answer to a policy problem, to find an authoritative justification for a policy measure, to find the superior alternative, to identify environmental hot spots in the life cycle, and to identify product groups of high environmental impact (Dalhammer 2007; Heiskanen 1999). The conceptual application attempts to involve stakeholders by providing LCA to facilitate a greater understanding of environmental priorities. Thus, LCA helps to change the way actors view environmental problems. The facilitative application of LCA looks to stimulate LCA activities, such as eco-design and life cycle management, in companies. This is done by the provision of life cycle data, methods and tools. Through using LCA it is suggested companies may ultimately change business practices (Dalhammer, 2007).
1.2 Background
Among the European Member States, the UK has led the regulatory push for LCA to be used as a tool to inform waste management decisions and support waste policy. The definitive application of LCA is best illustrated through the statutory requirement to complete LCA as a part of the Best Practicable Environmental Option[1] (BPEO) concept. The 1995 waste strategy for England and Wales announced the commencement of a research programme into LCA for waste management, where it would be integrated into the BPEO concept for waste management decisions. The BPEO became a core component of the Waste Strategy 2000 (DETR 2000a, 2000b). The strategy required LCA to be used as a part of the determining the BPEO: “to find an overall, optimal, environmental solution for managing waste, without the risk that our decision will result in a worsening of the overall impact, we need to adopt a life cycle approach” (DETR 200b:30). To facilitate the use of LCA, the WISARD[2] software tool was developed by the now defunct Wastes Technical Division of the Department of the Environment. This facilitative application would enable competent authorities to conduct LCA studies in-house or via the engagement of external consultants. Competent authority waste management strategies developed during this period had a statutory requirement to conduct LCA as part of their justification of a BPEO (definitive application). A second LCA software tool, WRATE[3], was developed by the Environment Agency to replace WISARD due to intellectual property right issues related to the upgrade of WISARD (see Section 3).
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A large portion of LCA work was and is subcontracted to consultants to undertake LCA, as many competent authorities lack the internal expertise or budget to justify development of such expertise. However, some competent authorities do undertake in-house LCA work using the WISARD or WRATE models provided by the Environment Agency. In July 2005, DEFRA removed the requirement to determine the BPEO (see (DEFRA 2005)), following recommendations from a national review of waste management. This was replaced through plan led-strategies requiring local authorities developing municipal waste management strategies to undertake a Strategic Environmental Assessment (SEA).
1.3 Competent Authority level
Local authorities mentioned their use of the WRATE tool, either in–house or via the engagement of consultants, in the development of their waste management strategies. Additionally, there is a current obligation to utilise LCA in relation to obtaining Privately Financed Initiative (PFI) credits. WRATE is recommended by the Waste Infrastructure Delivery Programme as a tool to assess the environmental impacts of options at the Outline Business Case (OBC) stage of obtaining PFI credits (DEFRA 2008).
The Mayor of London and the Greater London Authority (GLA) have utilised LCT in the latest waste strategy for London, London’s wasted Resource: The mayor’s municipal waste management strategy (GLA 2011), and the ‘Mayor’s preferred approach’. Whilst the strategy is technology neutral, LCT has been used to set the targets within the strategy, the objectives of the strategy, and it has been introduced as the metric for determining general conformity with the Mayor’s strategy with regards to energy from waste. The strategy introduces a carbon intensity floor (CIF) in order to determine whether a waste technology is in conformity with the strategy. The CIF compares energy-from-waste technologies with combined cycle gas turbine (CCGT), the UK’s marginal source[4] of electricity generation. The carbon intensity of CCGT by per megawatt hour of energy produced is approximately 400 grams of CO2 per megawatt hour. Any new energy-from-waste facilities must achieve a carbon intensity floor, better than 400 grams of CO2 per megawatt hour of energy produced (definitive use). A Greenhouse Gas Calculator tool[5], based on the WRATE tool, facilitates competent authorities assessing if their waste management strategies meet the requirements of the mayor’s municipal waste management strategy.
1.4 National level
At the national level, LCA is used with more emphasis on its conceptual capacity. Actors such as WRAP have identified the environmental impacts of various waste treatment options for the municipal waste stream or individual product/material waste streams, via the use of meta-studies drawing on existing life cycle studies (such as WRAP (2006) and WRAP (WRAP, 2010)) and their own LCA studies of individual waste streams (such as LCA of Management Options for Mixed Waste Plastic (Shonfield and WRAP 2008)). In terms of plastic waste management, such studies have been used to identify the optimum markets for recycled materials and making technological improvements to improve virgin material substitution ratios.
The Waster Strategy 2007 shows a move from the definitive application of LCA (as implemented in the Waste Strategy 2000) to the conceptual application of LCT. There has been a move in England to use LCT to support the structure of waste policies; "Policies to reduce the environmental impacts of products, materials and sectors should be targeted at the most significant points in the life cycle.” (DEFRA 2007:31). LCT has been used to inform policy in terms of identifying priority waste streams (those waste streams with a high environmental impact during their end of life treatment). There has also been a shift toward a voluntary approach for the use of LCA, as opposed to the pervious stance (evident in the Waste Strategy 2000) of mandating the use of LCA for waste planning decisions.
2 Historical account of the Role of LCA in the Best Practicable Environmental Option
The Best Practicable Environmental Option (BPEO) originates from the Fifth Report of the Royal Commission on Environmental Pollution, in 1976, extending the ‘Best Practicable Means’ concept which was used as a concept in air pollution control since the Alkali Act of 1874 (RCEP 1976). The concept, for a given waste stream, was defined as “...the optimum combination of available methods of disposal so as to limit damage to the environment to the greatest extent achievable for a reasonable and acceptable total combined cost to industry and the public purse.” The Twelfth Report of the Royal Commission on Environmental Pollution (RCEP 1988), in 1988, entitled Best Practicable Environmental Option, developed this concept which is commonly quoted as
the outcome of a systematic, consultative and decision-making procedure which emphasises the protection and conservation of the environment across land, air and water. The BPEO procedure establishes, for a given set of objectives, the option that provides the most benefits or the least damage to the environment as a whole, at acceptable cost, in the long-term as well as the short-term. (RCEP 1988:5)
The BPEO promoted the identification of options which provided the optimum balance of emissions to land, air and water, in order to minimise harm, ensure protection of the environment, whilst taking into consideration affordability and practicality.
The assessment of the BPEO stressed the need to involve the analysis of alternative options and also reflection of both long and short-term impacts. The RCEP placed strong emphasis that the BPEO be justifiable by a thorough and transparent assessment of the impacts of alternatives. The BPEO was introduced into UK legislation via Part I of the Environmental Protection Act 1990, relating to prescribed processes regulated under Integrated Pollution Control (IPC). The IPC applied the BPEO to pollution emissions from sites and was closely related to the concept of Best Available Techniques Not Entailing Excessive Cost (BATNEEC):
The objectives shall… include the objective of ensuring that the best available techniques not entailing excessive cost will be used for minimising the pollution which may be caused to the environment taken as a whole by the releases having regard to the best practicable environmental option available as respects the substances which may be released. (Environmental Protection Act 1990, p. 7)
Under IPC, the BPEO concept was not applied beyond the scope of specific sites. It did not apply to waste management strategies covering a range of sites and activities. However, the application of the BPEO in this context was practical demonstration of the need to balance the consequence of different activities in order to identify those delivering the greatest benefit (ERM 2003).
The BPEO was first introduced to waste policy in the 1995 strategy Making Waste Work (DoE, 1995) as a way to determine the preference between the options of the waste hierarchy. Although several reverences were made to the BPEO it was never clearly placed in a clear context (Eunomia Research and The Open University 2004). This is the first instance where was introduced to life cycle assessment (LCA) in English waste policy. The strategy notes that “The Department of the Environment has begun a programme of research into life cycle assessment, which is hoped will result in a systematic means of assessing the BPEO for many wastes”; its aim, to “result in a systematic means of assessing the BPEO for many wastes” (DoE 1995, p. 6).
Waste Strategy 2000 (DETR 2000a, 2000b) acknowledged that determining the ‘right way’ to treat particular waste streams was not a simple task and introduced the BPEO as a core aspect of the strategy; “Decisions on waste management, including decisions on suitable sites and installations for treatment and disposal, should be based on a local assessment of the Best Practicable Environmental Option.” (DETR 2000a, p. 40).
When determining the BPEO consideration was given to the waste hierarchy, the proximity principle and the self-sufficiency principle, as well as international obligations (such as the Landfill Directive), national policy framework, and policy guidance at the regional and local levels. The Waste Strategy 2000 highlighted the waste hierarchy as a conceptual framework acting as a guide to the framework that should be considered when assessing the BPEO. The proximity principle is linked to the BPEO and the waste hierarchy, in that when considering options towards the lower end of the waste hierarchy, decision makers should consider both the financial and environment costs of transport. The BPEO relates to the self-sufficiency principle where waste planning authorities and the waste management industry are encouraged, where practicable, to aim for regional self-sufficiency in waste management.
A stepwise approach for assessing the BPEO was set out in the Waste Strategy 2000:
1) set the overall goals for making the waste management decision, subsidiary objectives and the criteria against which the performance of different options will be measured
2) identify all the viable options
3) assess the performance of these options against the criteria
4) value performance
5) balance the different objectives of criteria against one another
6) evaluate and rank the different options
7) analyse how sensitive the results are to variations in the assumptions made or the data used
In relation to the guidance on the assessment of the BPEO, the Waste Strategy 2000 recommends that LCA be adopted as a methodology to provide a basis for strategic decision making through finding the overall, optimal, environmental solution for managing waste. The WISARD software tool (see Box 1), developed by the Environment Agency, was suggested as a way of assessing the environmental performance of waste management strategies (DETR 2000b).
In March 2001, the DETR published the Guidance on Municipal Waste management Strategies (DETR & HMSO 2001) which provided guidance on the development on non-statutory strategies of waste management for all English authorities. In May 2001, the Office of the Deputy Prime Minister (ODPM) took over responsibility for planning.
In 2001, several criticisms were made of the use of LCA as a requirement of the BPEO. The House of Commons Select Committee on Environment, Transport and Regional Affairs Fifth Report (House of Commons 2001a) criticised several aspects related to the use of LCA. There was concern over the weighting of environmental impacts and the application of WISARD, noting that “it is particularly important that WISARD is not used as a dogmatic tool to 'prove' that one option is better than another but rather as a general guide for decision makers. This becomes particularly important when one considers the opening words in the definition of BPEO: "the outcome of a systematic and consultative decision-making process...” (House of Commons 2001a).
There was a fear that the increasing use of tools such as LCA would lead to public consultation being overlooked. In 1998, the House of Commons Select Committee on Environment, Transport and Regional Affairs recommended that WISARD be made available free of charge in order allow interested to probe the outcomes of the use of WISARD. However, the Environment Agency noted that the software was developed under contact and that WISARD was provided to local authorities, academia, the public and NGOS at a subsidised price of £1,000 + VAT, compared to the unsubsidised cost of £10,000 + VAT (House of Commons 2001b). Furthermore, Select Committee emphasised the fact that “no model can ever provide the solution to a complex and partly judgement-based process such as determining BPEO”. There was a concern that the BPEO would become a technocratic process used in isolation of interested parties that could be used to “steamroller a sceptical public into options which they dislike or distrust”, all in the name of a consultative decision-making process (House of Commons 2001b).
In November 2002, the Waste and Emissions Trading Act was passed into law enshrined the obligation for most two-tier waste authority areas to produce a Municipal Waste Management Strategy, as expressed in the Waste Strategy 2000. In the same month the Prime Minister’s Strategy Unity publish the report Waste not, Want not: A Strategy for tackling the waste problem in England (ODPM 2002). This highlighted barriers to the implementation of sustainable waste management, but reified “using the waste hierarchy as a guide to environmental benefits and applying the BPEO to make decisions” (ODPM 2002, p. 43).