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Observations and Feedback

Relating to the Development and

Implementation of PAS 2050-1

Supplementary Requirements for

the Application of PAS 2050 to

Horticulture Products

October 2012

www.erm.com

DEFRA

Observations and Feedback

Relating to the Development and

Implementation of PAS 2050-1

Supplementary Requirements for

the Application of PAS 2050 to

Horticulture Products

October 2012

Reference 0143690

Prepared by: Saori Smith

This report has been prepared by Environmental Resources Management the trading name of Environmental Resources Management Limited, with all reasonable skill, care and diligence within the terms of the Contract with the client, incorporating our General Terms and Conditions of Business and taking account of the resources devoted to it by agreement with the client. We disclaim any responsibility to the client and others in respect of any matters outside the scope of the above. This report is confidential to the client and we accept no responsibility of whatsoever nature to third parties to whom this report, or any part thereof, is made known. Any such party relies on the report at their own risk.

For and on behalf of

Environmental Resources Management Approved by: Simon Aumonier Signed:

Position: Partner Date: 31 October 2012

OBSERVATIONS AND FEEDBACK RELATING TO THE DEVELOPMENT AND

IMPLEMENTATION OF PAS 2050:2011 SUPPLEMENTARY REQUIREMENTS

1.1 INTRODUCTION

PAS 2050 is a publically available specification that provides a method for assessing

the potential greenhouse gas emissions (GHG) occurring across the life cycle of

products. It can be used by organisations of all sizes and types, in any location, to

assess the climate change impact of the goods and services that they supply.

PAS 2050 is generically applicable to a wide range of goods and services and does not

include requirements relating to particular product or service categories. An

important addition to the recent revision of the PAS (PAS 2050:2011) was the

introduction of principles promoting the development and use of ‘Supplementary

Requirements’ for different products or sectors. It is expected that these will be used

in conjunction with the PAS 2050, where available, with the intention of providing

greater clarity and specificity on aspects of the PAS 2050 that are open to choice.

The ‘Horticulture Trials Summary Report’ provides background to the grower trials

for the recently published ‘Supplementary requirements for the cradle to gate stages

of GHG assessments of horticultural products undertaken in accordance with PAS

2050’ (PAS 2050-1:2012). This following report provides a summary of the feedback

and observations from the trials relating to the development and use of the

Horticulture Supplementary Requirements and its relationship with PAS 2050:2011.

1.2 OVERVIEW OF PAS 2050 SUPPLEMENTARY REQUIREMENTS

PAS 2050:2011 provides for the development and use of specific product category

guidance, referred to as Supplementary Requirements. PAS 2050 does not prescribe

that Supplementary Requirements be from a particular source, but it does specify

that they must align with the principles of PAS 2050:2011.

To date, PAS 2050 Supplementary Requirements have been developed for two

product categories: Horticultural products (PAS 2050-1:2012); and Sea Fish products

(PAS 2050-2:2012). PAS 2050-1:2012 has been published and is available on the

British Standards Institution (BSI) website. PAS 2050-2 is currently under

development and is expected to be available on the BSI website in the near future.

The process for the development of PAS 2050-1 and PAS 2050-2 has involved key

stakeholders, comprising practitioners, users and industry associations. The

objective was to produce specific product category guidance to supplement PAS

2050:2011 by addressing issues for which PAS 2050 allows choice and to provide

guidance for its application to specific products.

1.3 OBSERVATIONS AND FEEDBACK ON PAS 2050 SUPPLEMENTARY REQUIREMENTS

Based on the development and preliminary use of PAS 2050-1 and PAS 2050-2, it has

been observed that their intended use as a supplement to PAS 2050 was not always

clear to the user. Less experienced users had difficulty in using the two documents in

parallel and were not comfortable with the idea that the method is essentially split

between the two. For more experienced users, who have an understanding of key

terminology and technical aspects of the product life cycle, the supplementary

requirements provided much needed clarification on issues specific to the product

category that are not fully addressed in PAS 2050.

1.3.1 General feedback relating to development and use of supplementary requirements

Scope

The scope of PAS 2050 supplementary requirements is to provide additional guidance

for the assessment of GHG emissions relating to the particular product category

specified in the document. The additional guidance provides clarification on how to

address issues that are of relevance to the life cycle of the product category.

Clarification and further guidance might be required on some issues as they are not

covered in the specific context of the particular product in PAS 2050:2011.

For example, in the case of PAS 2050-1, which provides supplementary requirements

for the assessment of GHG emissions from the life cycle of horticulture products,

there are specific requirements related to data collection. Due to the nature of the

life cycle of horticulture products, further consideration than is provided for in PAS

2050:2011 is required to ensure that representative data are gathered for the

assessment.

The PAS 2050 supplementary requirements that have been developed to date relate

specifically to PAS 2050:2011. In terms of structure and language, the PAS 2050-1

and PAS 2050-2 documents align with the PAS 2050:2011 document. In terms of

approach, although the supplementary requirements provide additional guidance on

how to address specific issues for a particular product category, there is still a focus

on alignment with PAS 2050:2011. As they are documents that are used in parallel

with PAS 2050:2011, this is entirely appropriate. However, in the wider context of

the supplementary requirements documents being useful for the assessment of GHG

emissions in general, this suggests that they might also be appropriate as a

supplement to an alternative product carbon footprint method (e.g. the Greenhouse

Gas Protocol Product Standard).

In order to continue to be useful, it would be advantageous for supplementary

requirements to align, and to be accessible for use, with one of the increasing

number of alternative product carbon footprint standards. It is recognised that

achieving such alignment presents its own challenges, including whether it is feasible

and, if so, to which alternative standard(s) they should align. Therefore, it is

recommended that discussion regarding the development of any future SR

documents should include consideration of the feasibility of such a concept,

potentially with input from the developers of other product carbon footprinting

standards.

Structure of document and relationship with PAS 2050:2011

As PAS 2050 supplementary requirements are intended to be used in parallel with

PAS 2050:2011, the text of PAS 2050:2011 is not repeated in the supplementary

requirements. Rather, references to specific clauses are made when required. At a

practical level, this means that both PAS 2050:2011 and the supplementary

requirements documents are needed.

For more experienced users, who are already well versed in PAS 2050 method and

product carbon footprinting principles, the need to reference two documents is not

likely to be of particular concern. In this case, the supplementary requirements will

be used as intended, to supplement PAS 2050:2011 on specific issues that are of

relevance to the particular product category. However, for less experienced users,

who are less likely to be comfortable with the requirements of PAS 2050 method and

product carbon footprinting principles, the need to reference two documents might

prove to be burdensome and result in confusion. In short, the need to switch

between the two documents means that the process is less straightforward to follow

and consequently it is likely to be more difficult for the user to understand.

Content

The PAS 2050 supplementary requirements describe technical aspects of product

carbon footprinting and use relatively complicated ‘jargon-heavy’ language. The

supplementary requirements address some especially complex issues and therefore

it can be expected that the language is technical by nature. However, this means

that less experienced users are likely to have difficulty in understanding the issues

and in following how to address them. For more experienced users of product

carbon footprinting methods, such language will be commonplace and there is a

greater likelihood that the document will be understood in full. Nonetheless, it is

likely that some issues will only really be understood by experienced practitioners

(e.g. the way the approach for allocating N2O soil emissions is described in the

Horticulture supplementary requirements will need at least some knowledge of how

to calculate N2O soil emissions before attempting to undertake potentially

complicated allocation calculations).

It is noted that Horticulture and Sea Fish represent product categories that are

associated with particularly complicated or problematic technical and practical

issues. This is why they were the first product categories selected for the

development of supplementary requirements. Therefore, it is recognised that

supplementary requirements for other product categories might not require such

complicated technical content.

Intended users

The intended users of PAS 2050-1 and PAS 2050-2 are stated in the document scopes

to be organisations which operate within the product category sector (i.e. for

Horticulture, the growers; and for Sea Fish, the aquaculture processors). Typically,

these are not groups of individuals that have experience in calculating product

carbon footprints and would almost certainly fit into the category of less experienced

users. Indeed, it is most likely that horticulture growers and aquaculture processors

will have no experience in calculating a product carbon footprint.

As observed above, the language, content and structure of PAS 2050-1 and

PAS 2050-2 do not lend themselves to a less experienced user. Where several new

terms and concepts are being introduced, along with complicated carbon

footprinting manipulations, the language used and the need to refer to two or more

documents presents an overly burdensome and complex process. More experienced

users and practitioners are not likely to experience the same difficulty. However, in

this sense, the supplementary requirements are not likely to be accessible to the

intended users stated in the scope of each document.

Nevertheless, the content of PAS 2050-1 and PAS 2050-2 is comprehensive and

provides much needed clarification on specific issues relating to Horticulture and Sea

Fish products that are open to choice in PAS 2050:2011. It is also widely accepted

that simplification to an extent that it can be understandable by all, irrespective of

experience or education, although desirable, can undermine the effectiveness of the

standard or guidance. In this sense, they are best suited for users who are

experienced in product carbon footprinting and who have a good base understanding

of PAS 2050:2011. In order for them to be accessible and usable by less experienced

users, there is a need for more practical and stepwise guidance that relates to

product carbon footprinting in general, as well as the specific context of the product

category assessed.

1.3.2 Specific feedback relating to development and use of PAS 2050-1

The growers were asked to provide comments and observations relating to several

aspects of the PAS 2050-1 document, as well as the product carbon footprinting

process in general, focusing on specific areas such as:

• Is the document user friendly?

• Can it easily be used in conjunction with the PAS 2050?

• Can a footprint reasonably be undertaken using only these sources?

• Is the information provided clear?

• Is the information provided sufficient?

• Does it make the assessment of horticulture products easier?

• Does it provide a more accurate and consistent assessment?

• Does it remove the potential for misinterpretation?

• Does it provide a practical approach?

Limited feedback was received from the growers, which consequently provides a

general overview of their experiences, rather than detailed commentary on specific

aspects. It is not considered that the limited feedback received is a reflection of the

level of enthusiasm of the growers in the trials. Rather, they were less able to

provide significant feedback on aspects of the process that required ERM’s assistance

or on technical aspects which they were not able to understand.

The growers were each provided with copies of PAS 2050:2011, the most recent draft

of PAS 2050-1 and The Guide to PAS 2050. Following initial review of these

documents, it is not likely that the growers attempted with much vigour to make

sense of what was required to undertake a Horticulture product carbon footprint.

Instead, they allowed ERM to explain what was required of them at a practical level.

None of the growers requested clarification on specific aspects of PAS 2050:2011 or

PAS 2050-1, and none made any reference to the documents when discussing the

product carbon footprinting process with ERM. This is considered to be due to a lack

of understanding associated primarily with the content of the documents, but also

with the relationship between them. The response displayed by the growers to the

PAS 2050 documents is likely to be a relatively typical response amongst less

experienced users. All of the growers expressed difficulty in understanding the

documents which it was necessary for them to review as a part of their normal

working day.

The growers who participated in the PAS 2050-1 trials provided positive feedback

and identified beneficial experiences from being involved in the product carbon

footprinting process. These are summarised below.

• The data collection process and detailed examination of the product life cycle

identified areas that affect carbon usage and flagged areas of concern or that

require improvement.

• The general process, in particular the detailed examination of the data, was

identified as a good discipline for all departments in the organisation involved,

as it provides a very thorough examination of the business.

• The detailed examination of data enabled an understanding of consumption

and metrics in a different way than is normally expressed at a company level.

In addition, the growers participating in the PAS 2050-1 trials provided the following

comments.

• The product carbon footprinting process (comprising scoping, data collection

and calculation) was initially considered to be overly complicated. It was

suggested by growers that a simplified, user-friendly, template with clear

instructions on how to complete it would assist in capturing the information

required.

• The growers expressed difficulty in following the process through from start to

finish. This is considered by ERM to reflect the limited experience of the

growers in the product carbon footprinting method and process.

• The growers believed the PAS 2050 documents to be not to be user-friendly

and they did not believe that the average horticulture producer or grower

would be able to undertake and to complete a product carbon footprint on

their own initiative.

• The growers did not find it straightforward to interpret the results. Even with

assistance from ERM in developing summary tables, breaking down the impact

by life cycle stage and by key contribution, the growers had difficulty in

understanding what they meant. They expressed a need for further guidance

and possibly templates for interpreting the product carbon footprint results.

Thus, in practice, the Horticulture growers who participated in the PAS 2050-1 trials

were not able to use the supplementary requirements document alongside PAS

2050:2011 in order to calculate a product carbon footprint. They expressed difficulty

in understanding PAS 2050:2011 and even more so the more complicated technical

issues covered in PAS 2050-1 (e.g. N2O emissions from soil). Based on the feedback

received from growers, it was noted that there is a need for basic guidance on what

is required to assess a product carbon footprint, setting out step by step instructions

on exactly what needs to be undertaken. Only once users are more experienced in

the process and the concepts of carbon footprinting can they be reasonably be

expected to be able to use PAS 2050:2011 and PAS 2050-1 in parallel, as is intended.

1.4 RECOMMENDATIONS FOR ADDITIONAL SUPPORTING MATERIALS

One of the key observations resulting from the Horticulture Supplementary

Requirements grower trials is that, for the less experienced user, PAS 2050:2011 and

the supplementary requirements document (PAS 2050-1) alone are not likely to be

sufficient to enable calculation of the product carbon footprint. As a consequence of

this, guidance documents entitled ‘Footprinting First Steps’ were developed for

different types of horticulture systems, as follows:

• Protected and Climate Controlled Products;

• Annual Field Crop Products; and

• Perennial Field Crop Products.

These guidance documents were developed based on feedback from the growers

and from ERM’s specialist that, whilst the Horticulture Supplementary Requirements

provides a sound technical framework for undertaking a carbon footprint, there is a

need for practical non-technical guidance to enable growers to take the first steps in

calculating the carbon footprints of their products. The guidance documents were

developed to provide a stepwise approach to the data and calculations required to

estimate the main GHG emissions from the production of the horticulture product.

Furthermore, the following additional materials could be useful in assisting less

experienced users to undertake product carbon footprints. Currently, these

materials do not exist as standalone documents, although the information is

available as part of other guidance (e.g. The Guide to PAS 2050). However,

standalone documents will enable the user more easily to select the relevant

information and limit the need to search through lengthier documents. The exact

scope of these documents is relatively flexible, but it is recognised that the number

of different guidance documents made available should be limited to avoid

confusion. Generic guidance intended for all users, that provides some examples for

specific sectors or product categories, is potentially a good option. The additional

materials are intended to accompany PAS 2050:2011, supplementary requirements,

The Guide to PAS 2050 and the Footprinting First Steps documents:

• Guide to sourcing secondary data, including suggested sources and a list of

publicly available processes and materials;

• Guide to undertaking data quality appraisals;

• Case studies of different organisations that have completed a product carbon

footprint, including how they tackled specific challenges; and

• Guide to interpreting results, identifying hotspots and approaches for reducing

emissions.

1.5 RECOMMENDATIONS FOR DEVELOPMENT OF FUTURE SUPPLEMENTARY REQUIREMENTS

Based on the observations and feedback obtained from the Horticulture

Supplementary Requirements grower trials, the following key recommendations are

identified for the development of future supplementary requirements documents.

• The structure, approach and language should be developed to be applicable to

product carbon footprint assessments for the relevant product category in

general, rather than specifically aligned to PAS 2050:2011. With the increasing

number of product carbon footprinting standards that are emerging, it will be

important for the supplementary requirements to maintain some flexibility if

they are going to remain relevant in the future. For example, future

Supplementary Requirements could be developed to align both with

PAS2050:2011 and with the WRI/WBCSD Greenhouse Gas Protocol Product

Standard.

• The relationship between the ‘parent’ document and the Supplementary

Requirements (SRs) document(s) should be better explained in the SRs

themselves and further effort could be made to provide an explanation of the

relationship between the documents in supporting media (e.g. the BSI PAS

2050 website).

• The benefits observed and identified by growers and experts in relation to the

process of product carbon footprinting (e.g. detailed examination of

operational data; and identification of areas to focus on for reduction) could

be included in the Supplementary Requirements documents.

• By nature, supplementary requirements address more complicated issues that

are specific to a certain product category and which therefore cannot be

included in the general PAS 2050:2011 document. Consequently, there is a

need for the supplementary requirements to be comprehensive in its approach

to dealing with these issues. It does not make sense to over-simplify the

language in order to make it more understandable or accessible to less

experienced users. However, the horticultural growers’ experiences indicate

that the language acted as a deterrent and limited their attempts to

understand the issues in the document. A comprehensive document that

includes the technical detail is important. Therefore, it is recommended that

this be supplemented with more simple guidance documents (e.g. Footprinting

First Steps). These can provide straightforward stepwise actions, without

confusing the user with complex technical issues that might be excessive for

the intended purpose (e.g. as a first attempt, the user might be more

interested in understanding the product supply chain and where the hotspots

are, rather than undertaking a full product carbon footprint). The more simple

guidance documents are not intended to act as a substitute for supplementary

requirements, which contain necessary category specific technical guidance.

However, simple stepwise actions can encourage and assist first time users to

attempt high level product carbon footprint calculations, potentially as a

precursor to more detailed assessment. Therefore, the availability of more

simple guidance for less experienced users alongside the more detailed

supplementary requirements would be preferential. The mechanism for

provision of these documents is flexible.

• Further to the previous point, although it is important that the supplementary

requirements documents are comprehensive and include sufficient technical

detail, it is likely that the language could be made more ‘user-friendly’. The

text could be re-written to be more easily digestible and understandable

without removing any of the technical content.

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