Weighting - what it does, and why it matters.
Climate Change NASA 2023 https://climate.nasa.gov/
This is the basis of an in-person presentation that I delivered, as a guest of Natural Fiber Connect in Biella, Italy, on September 28, 2023.
The presentation itself was not commissioned and was written pro-bono.
I should perhaps have added to the title of today’s presentation “and what we need to do about it”. Because the aim of this presentation is precisely to encourage each and every one of you to go home and to take action.
We only have 30 minutes so I am going to cover this pretty swiftly. The base draft will be on my website within the next day or two, should you wish to check anything after the event.
Today I am going to make 3 points:
1. The weighting of the European Union’s (EU) Product Environmental Footprint, or PEF, is wrong.
2. We must focus on climate change
And
3. Not all climate emissions are equal. Climate impact must be weighted - and not just in the PEF, but in all LCAs - whilst water and land probably should not be.
A quick aside here, Baptiste Carrier-Pradal and others will tell you that the PEF is not finalized, that the documentation that I am considering is from the previous version, and that a new one is coming soon. I am sure that is correct, but it makes no difference. No new studies appear to have been commissioned - in which case, we are talking about tweaking at best. A radical change in weighting is most unlikely - and that’s what is urgently needed.
As I said, we only have 30 minutes, so let’s get started.
Why the PEF Weighting is Wrong
As I carry on speaking, I would like you to look at the images on the screen behind me. They were all captured this year - 2023 - the first 4 images come from the BBC, and cover the month of July. The second series of 4, starts with Maui, covers the month of August, and comes from Quartz. The latest images are from this month, two images capture when extraordinary storm conditions caused 2 dams to burst in Libya, killing thousands. And the final image is of Death Valley - one of the driest and hottest places on earth - which was closed due to too much water.
How does this relate to the PEF? Because a picture speaks a thousand words and these images and the news reports that go with them, tell us unequivocally that Climate Change is here. And that it trumps all else - and by a considerable margin.
I quote United Nations Secretary General António Guterres. Speaking in New York, just last week, he said:
“Humanity has opened the gates to hell. Horrendous heat is having horrendous effects. Distraught farmers watching crops carried away by floods. Sweltering temperatures spawning disease…”
“Climate action is dwarfed by the scale of the challenge,” he added, warning that if nothing changes we are heading: “towards a dangerous and unstable world…..We are decades behind. We must make up time lost to foot-dragging, arm-twisting and the naked greed of entrenched interests raking in billions from fossil fuels.”
If we care about water use, land use, particulate matter, human toxicity, and all the rest - and the PEF does - then first and foremost, we must deal with climate change.
But that is not what the PEF says.
The PEF actually has 16 impact categories, including the 4 just mentioned. These must all be combined into a single score. One way to do this would be to assign an equal weight of 1/16th - or 0.06 - to each variable. Another - the sensible option when some impact categories are clearly more important than others - is to assign different weights to each category in descending value, according to their perceived order of importance. And this is what the PEF does.
We see immediately then, that what we are talking about here is a subjective judgment. Somebody has to decide what the relative importance, and so weight assigned, to each category should be. The higher the weight, the more important the variable is perceived to be, and so the greater the impact that it will have on the final score.
But who should decide this and how?
Well for the PEF, the weighting was developed in association with the London School of Economics over the period 2015-17, through a series of questionnaires addressed to both the general public (in 6 countries) and to “experts in the LCA field” (from 48 different countries); and through LCA ‘expert’ workshops.
What they came up with is shown in the chart on the screen now. It comes from the 2018 JRC weighting Report.
And as far as I know, this is the weighting currently used in the PEF.
https://op.europa.eu/en/publication-detail/-/publication/6c24e876-4833-11e8-be1d-01aa75ed71a1/language-en
The scores on the right hand side are expressed as percentages: Climate Change carries a weighting of only 21%! If we sum the weightings assigned to ‘Land Use’, ‘Water Use’, and ‘Particulate Matter’ it comes to 25.4%. If we throw in toxicity it goes up to 29.4%.
Seriously? Those three or four together are more important to global survival than climate change? We know they’re not.
2. We must focus on Climate Change
As the PEF itself admits, and I quote the final report:
“…any weighting scheme is not mainly natural science based but inherently involves value choices that will depend on policy, cultural and other preferences and value systems. No “consensus” on weighting seems to be achievable. This situation does not apply only to weighting in a LCA or EF context, but seems inevitable for many multicriteria approaches. However, weighting is seen as essential to further aggregate information with the objective to provide better support in complex decision situations.”
So, we can’t expect a consensus on what the ‘correct' weighting should be. But do we think that the current weighting is even remotely accurate? In considering environmental impact, should Climate Change only count for around 20%? Are land and water use more important?
In all fairness to the PEF, the first thing that we should note is that the weighting discussions took place in 2015-17. Greta Thunberg burst onto the scene at the end of 2018. Remember the images you just saw. The reports that you have read on everything from collapsing ice shelves to turbulence. You may not have heard this, but scientists at Reading University found that on a typically busy North Atlantic route flown by airlines, severe turbulence increased 55% between 1979 and 2020, as a result of changes in wind speed at high altitudes, due to warmer air from carbon emissions.
Our flights are about to get a whole lot bumpier. Every one of us is affected. Apparently Canadians used to be relatively complacent about climate change, imagining its primary impact would be to make their frigid climate more balmy. I imagine the average Canadian’s feelings about climate change are very different today than they were this time last year - let alone in 2015.
As for ‘Particulate Matter’ and ‘Human Toxicity’, I quote the Washington Post’s coverage of this years climate change induced Canadian wildfires:
“Smoke brings a warning: There’s no escaping climate’s threat to health….
….The acute public health threat posed by the fumes, which carry dangerous gasses and fine particles that can embed in people’s lungs and bloodstream,”
And we have some nice images of just what that smoke looked like on the screen behind me now:
And when it comes to health in general, recent analysis by the Washington Post showed that by 2030, climate change will expose 500 million people around the world to extreme heat for at least one month of each year.
“By 2050, the number of people suffering from a month of inescapable heat could further grow to a staggering 1.3 billion.”
Climate change will have - is already having - a far greater impact on virtually all the metrics included in the PEF, than the contribution of any one industry. So surely, when evaluating the environmental impact of apparel purchases the most important consideration by a considerable margin must be that product’s contribution to climate change.
Indeed, as far as fashion is concerned, should we even be looking at the other variables? Eunomia reports that EU battery regulation will focus solely on the carbon footprint, because analysis by that sector found that other impact categories were either of little relevance to batteries, or not sufficiently robust. Should the same apply to textiles and apparel? As that Eunomia report observes:
“We might reasonably expect other impacts (such as toxicity and water scarcity) to be more relevant for the A&F sector than for batteries, however policy makers might still learn from this approach of focussing on certain metrics based on materiality and scientific robustness.”
Take another look at the PEF weighting that I just showed you. Look at the second column - B Robustness Factors. The only categories whose measurement was deemed scientifically robust were Climate Change and Particulate matter - each scored 0.87 or 87%. The measurement of land and water use isn’t even rated 50% - for most of us, 50% is a standard pass mark - less than 50%, a fail.
What I conclude from all of this is that the PEF should focus on climate change - and probably climate change alone. I would be interested to hear your thoughts at the end of this presentation, but first, a further, vital wrinkle in the analysis.
3. Not all climate emissions are equal.
Climate impact must be weighted - and not just in the PEF, but in all EFs and in all LCAs.
Not all climate emissions are equal. But that is not all, unlike say land or water use, and we shall have more on that in a minute, whether they are generated in Brazil, Belgium, Benin, or Bhutan, all GHG emissions affect everyone. This means that there is a clear justification and authority for the EU to rule unilaterally, that European consumption - and so global trade - should be determined, at least in part, by GHG emissions in production. But the EU must do this within the framework of its global commitments - or not at all.
And when I say ‘global commitments’, I am talking about the the Paris Agreement, the Kunming-Montreal Global Biodiversity Framework, and the Sustainable Development Goals,
If the EU is to honor those commitments, then in measuring environmental impact, it must weight GHG emissions to reflect whose consumption patterns impose the greatest burden on planetary boundaries, and whose, the least. The EU - and all the rest of us - must acknowledge that GHG consumption emissions are closely related to income. It is the rich whose carbon emissions must fall. The emissions of the poorest must actually increase.
What am I talking about? Let’s take a look at the data.
It will come as no surprise to any of us that the average per capita carbon consumption footprint in the global north is well above the level consistent with the goal of holding global temperature rise by 2030, to 1.5⁰C.
Oxfam has calculated that on a consumption basis, to be consistent with this target, each and every one of us is entitled to no more than 2.3 tonnes of CO2 equivalents (CO2e) per capita, per annum.
But - as you can see from the screenshot behind me - Our World in Data estimates that 2020 per capita consumption emissions were roughly 18 tonnes of CO2e in Saudi Arabia, around 15 tonnes in the USA and Belgium,14 tonnes in Australia. They averaged 13 tonnes in Luxemburg and somewhere around 9 tonnes per capita in Japan, Germany, and Austria. China, UK, and Italy averaged 7 tonnes per capita. Whilst consumption emissions in Peru and India were around 2 tonnes Co2e per capita. And those in Benin and Burkina Faso were well below one tonne per annum per capita.
https://ourworldindata.org/grapher/consumption-co2-per-capita?tab=chart&country=USA~GBR~CHN~IND~AUS~BEN~BFA~AUT~DEU~SAU~LUX~BEL~FRA~ESP~PER~ITA~JPN
What does this mean? Well, obviously that nothing consumed by the average European, American, or Australian, can possibly be called ‘sustainable’ on environmental grounds - because, per se, it isn’t. Sustainability is not a marketing tool, and sustainability claims are not a human right. Any responsible brand should stop asserting otherwise.
But there is an even more important aspect to all this, that for reasons that I cannot understand, has been totally overlooked and neglected. Around 45% of the global population live in the rural areas of developing countries, and they depend primarily on small, family farms for their income and sustenance.
The UN Sustainable Development Goals (SDGs) are based on decades of work by member governments of the United Nations, and the 17 SDGs agreed in 2015 define sustainability.
SDGs 1 & 2, so, the most important - not to say vital - indicators on the list - are: No poverty and No Hunger. The World Bank estimates that 2 billion people - approximately one-fourth of the world’s population - live below their respective poverty lines. Many of these people are not just poor. They do not have regular access to safe, nutritious, and sufficient food. As of 2022, the FAO estimates that between 691 million and 783 million people were undernourished. Whilst the WHO claims that around 22% of all children under the age of 5 were stunted. Some 45 million children were affected by wasting - some 13.7 million suffering in its most severe form. For the 21st Century, these are horrendous statistics - yet No Poverty & No Hunger are not the priority of any major sustainability effort in the fashion value chain.
It is self-evident that the only way smallholders will ever have the income to fulfill the SDGs and increase their consumption in line with global justice, is by selling more produce. To treat the production emissions of smallholder cotton, wool or silk producers as if they were exactly the same as those of Saudi Aramco or BP is not only unethical. It’s unscientific, because it clearly runs counter to globally agreed sustainability targets, as enshrined in The Sustainable Development Goals, The Paris Agreement, and The Kunming-Montreal Global Biodiversity Framework.
In other words, if the global north wishes to be true to its international commitments, the PEF and sustainable fashion in general, must focus - possibly solely and entirely - on carbon emissions. And carbon emissions must be weighted according to the source of the emission. (please see footnote 1)
The poorest producers - cotton farmers in Benin and Burkina Faso, indigenous alpaca farmers in Peru and Bolivia, cashmere herders in Mongolia - should all have their production emissions either ignored - by which I mean weighted zero - or weighted less than one. There should be a sliding scale - which it is certainly not for me to decide - that reflects climate justice. And this should not be determined by the EU or the global north alone. The global south must be included in these discussions. (please see footnote 2)
There is no reason for the EU, brands, or indeed LCA providers, to have any reservations about this. There is precedent. And a precedent that is both far less just, and less robust than measuring and weighting carbon emissions would be. I am talking about weighting for water scarcity. For the past decade at least, the global north has had no compunction whatsoever, about weighting water in evaluations of environmental sustainability. Both the PEF and the Worldly Higg MSI use AWARE, a methodology that appears to have been developed by a number of LCA providers and Unilever, and that, as some of you may have read in Amplifying Misinformation, weights water consumption remarkably heavily. For example, Australian researchers found that whilst actual farm consumption of water in milk production in SE Australia varied from 9.1 to 313 liters of water per liter of milk, AWARE converted this to an average of 6,616 liters of water per liter of milk! That’s a multiple of between 21 and 727! As a quick example of the impact this has, Euric published a study at the beginning of this year. Using PEF data available at the time, that study found that a polyester tee had a 5% higher climate impact than a cotton one. But once the water scarcity was factored in, the PEF score for the cotton tee was close to double that of the polyester version.
Surely we don’t want people to buy clothing that has a higher climate impact, because of a subjective, and by the PEF’s own admission, less than robust, assessment of water scarcity?
It could moreover be argued that the EU has no moral authority whatsoever, to rule on what constitutes an appropriate use of water in Mali, Pakistan, or Laos. Furthermore, there is no impact justification for interfering in the sovereign use of such resources. Whether Cambodia choses to irrigate silk, or India chooses to irrigate cotton, has absolutely no impact on the water resources available to citizens of the EU, the USA, or Japan. For the EU, or anyone else, to rule on ‘water scarcity’ using such a clearly subjective measure as AWARE is doubly questionable. And whilst I do not have access to LANCA, it would appear that identical reservations apply to the measurement of ‘land use’.
Under the circumstances then, the EU should have no reservations about weighting carbon emissions in line with its global agreements, as this is both plainly within its authority, and would be arrived at using globally agreed, and so less subjective metrics.
Conclusion
The point that I am making here is not that the subjective weighting decisions taken by the PEF in 2015-17 were wrong, per se, at the time. They may have been, but it really doesn’t matter. The point is: they are clearly wrong now.
If the global north wishes to be true to its word, the PEF and sustainable fashion in general, should stop weighting water and land- or at the very least consider alternatives to AWARE and LANCA.
We should, moreover, focus - possibly entirely - on carbon emissions. And carbon emissions must be weighted in line with global commitments, as directed by the SDGs and elaborated by COP 27, and Kunming-Montreal.
Certainly as far as fashion is concerned, at present the north appears to pass resolutions, only to fail to incorporate them into policy and legislation. As Christiana Figueres, former executive secretary of the UN Framework Convention on Climate Change, pointed out just this month (September 2023):
“Any business plan, if it just stays on the shelf, then it is good for nothing. The Paris Agreement is good for nothing if it is not financed and executed."
It is pointless, not to say dishonest, for The European Union to sign up to global agreements at the front end, only to ignore them at the back end, when framing actual legislation.
If the EU is to honor its commitments to the Paris Agreement, the Kunming-Montreal Global Biodiversity Framework, and the Sustainable Development Goals, it must address these goals in any and all sustainability legislation.
To be honest, I am surprised that nobody else has called this out. Since January this year we have seen a proliferation of organizations and initiatives claiming to offer advice on compliance with EU regulations. But surely nobody should comply with regulations that don’t make sense?
As currently conceived, the EU PEF is not fit for purpose - nor is the current methodology by which climate emissions are evaluated in sustainability calculations. So, complain to your diplomats and/or MEPs. Tell the European Commission that their proposed regulations will contribute nothing positive either to global warming or to global justice. Do this as soon and as powerfully as you can.
Thank you for your time.
Footnote 1: Heinz Zeller suggests that emissions should be weighted by the societal benefit of the impacts.
Footnote 2: Baptiste Carriere Pradal raises the valid concern that if some emissions are weighted zero or less than one, this could mislead consumers into believeing that they can shop impact free. This is easily avoided by allocating the emissions of the poorest - the emissions that have the greatest societal benefit - a weight of one, with the weighting rising progressively, and increasingly steeply, thereafter.