Chapter 11
Working Group Summary and Round Table Discussion

The final symposium session presents results of working group discussions that focus on weaknesses of current life-cycle methodologies, data needs, inherent biases of methodologies, and application considerations. In addition, round table panel participants provide insight on issues of forest products certification, development of international standards, and policy implications of life-cycle concepts.

Working Group Discussion Summary

Working Group Leaders:

David Briggs, University of Washington

Sergio F. Galeano, Georgia-Pacific Corporation

Dana Harmon, Wood Reduction Clearinghouse

William J. Nicholson, Potlatch Corporation

W. Ramsay Smith, Louisiana Forest Products Laboratoy

Questions about life-cycle assessment methodology are posed to symposium participants, who work in small groups to identify answers. Working group leaders, appointed to document their working group discussion, provide summary reports. Questions and summarized responses from working groups are provided below.

1. What are data needs for assessing the environmental implications of using wood as a raw material?

There is a need to gather data on forest inventory and biomass in general, through coordinated efforts. Other needs include updating the data on a regular



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Chapter 11 Working Group Summary and Round Table Discussion The final symposium session presents results of working group discussions that focus on weaknesses of current life-cycle methodologies, data needs, inherent biases of methodologies, and application considerations. In addition, round table panel participants provide insight on issues of forest products certification, development of international standards, and policy implications of life-cycle concepts. Working Group Discussion Summary Working Group Leaders: David Briggs, University of Washington Sergio F. Galeano, Georgia-Pacific Corporation Dana Harmon, Wood Reduction Clearinghouse William J. Nicholson, Potlatch Corporation W. Ramsay Smith, Louisiana Forest Products Laboratoy Questions about life-cycle assessment methodology are posed to symposium participants, who work in small groups to identify answers. Working group leaders, appointed to document their working group discussion, provide summary reports. Questions and summarized responses from working groups are provided below. 1. What are data needs for assessing the environmental implications of using wood as a raw material? There is a need to gather data on forest inventory and biomass in general, through coordinated efforts. Other needs include updating the data on a regular

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basis, improving methods of dissemination and transfer of data, and expanding the scope of data collected to include effects over time. A systematic approach for data collection could be developed and more complete data on solid wood, as opposed to pulp and paper, and natural versus planted forests, are needed for life-cycle analyses. A method to determine data relevance, or weighting of data, would be useful as it is incorporated into assessment methodologies. Within life-cycle analyses it also is important to have adequate and appropriate definitions of impacted areas. Impacts on areas outside the United States might be considered as assessment methodologies are developed and implemented. An update of the information contained in the 1976 National Research Council report, Renewable Resources for Industrial Materials is needed that focuses on environmental impacts and includes data for all materials substitutes (National Research Council, 1976). Needed improvements to life-cycle methodology expand beyond enhanced data gathering and management. Methodologies must account for biologic aspects and impacts of forests, as well as spatial and temporal differentiation of impacts. Methods tend to focus on physical aspects of systems; economic and social aspects are not factored into the analyses. Questions remain about how to measure and incorporate values such as biodiversity and aesthetic satisfaction into environmental assessment methodologies. Boundaries of current life-cycle methodologies that begin with the harvested wood and end with the finished product could be broadened to include information on the tree in its environment and perhaps include assessments that consider post consumption impacts. Reference National Research Council. 1976. Renewable resources for industrial materials. Washington, D.C.: National Academy Press. 2. How can modifications be made to life-cycle analysis methodologies to allow for unique local and market conditions? Life-cycle methodologies could be modified to allow for differences in land types and management options including: natural generation, plantations, public lands and management objectives, private lands and management objectives, and tropical versus temperate landscapes. While there are some common principles involved in life-cycle analysis methodologies that could be applied to many different situations, it is important

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to recognize that no single model fits all situations. For instance, various economic, regional, and societal needs could be accounted for in these analyses. Native American forested lands and lands devoted to special uses such as recreation are two examples of land types that might not be managed in the same manner as industrial forests; therefore, methodologies need to be flexible to handle various economic and social aspects of different land types. Ecosystem values and effects associated with timber, ores, oil extraction may involve greater differences in assessment methodologies than in subsequent product evaluations. There is also a need to look at how alternatives are objectively laid out for policy making and how comparisons among alternatives are conducted. 3. What are the biases that are inherent in developing life-cycle methodologies? Life-cycle analysis and life-cycle inventory methodologies are only partially useful in the forest sector and therefore should be recognized for their biases and limitations. Current tools, such as life-cycle methodologies, are biased toward the North American and European style systems and cultures; they do not reflect the cultures and systems of developing countries. Life-cycle assessment methodologies and results tend to have a bias in favor of durable goods. Biases likely will be inherent in these analyses and therefore should be recognized as such and identified from the outset. Standards or guidelines are necessary to deal with these biases and these standards, as well as the methodologies, should have a scientific basis. 4. How should consumer, environmental, and industry interests be considered and factored into all aspects of assessment? The process of environmental impact assessment needs to involve all stake-holders. Outreach programs could be developed to facilitate the opportunity for everyone to have input. A common set of values that is representative of all factions could be identified and applied to the life-cycle assessment process, while keeping the valuation process separate from the scientific data gathering process. As consumer, environmental, and industry interests are factored into assessments, there should be assurance that only scientific principles are used. Round Table Discussion Round table discussion rapporteurs provide perspectives on key issues related to the application of life-cycle methodologies today and in the future. Aspects of certification, international standards, consumer acceptance, and questions about the adequacy of methodologies for use as regulatory tools and in policy making processes are addressed.

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Seventh American Forest Congress Rapporteur's Perspective William Bentley Salmon Brook Associates Granby, Connecticut I provide a few notes from what we learned at the Seventh American Forest Congress in February 1996. These comments might be useful and are presented in the context of our discussions during this symposium. Clearly, most participants of this symposium do not have an in-depth understanding of the issues at hand. This lack of broad knowledge suggests that more work is needed, and the results must be clearly transmitted to a wide variety of critics concerned with America's forests. The Seventh American Forest Congress met February 20–24, 1996 in Washington, D.C. Some 1500 participants, drawn from a wide variety of interests, experiences, and locales, considered 13 vision elements and 60 principles to guide America toward its vision for forests. Over 90 percent were in agreement on one element, over 80 percent were in agreement with 5 elements, over 70 percent were in agreement with 8 elements, and over 50 percent were in agreement with 12 elements. A similar review of the 60 principles yielded the following results: 80 percent or more agreed on 6 principles, over 70 percent agreed on 11 principles, and over 50 percent agreed on 29 principles. These levels of agreement are remarkable, as is the breadth of the vision elements and the principles; they clearly demonstrate respect and strong support for: diverse ownership and user values, private ownership rights and responsibilities, rule of law, ideal of open dialogue and political process, science-based information and strong research systems with ties to all stakeholders, and long-term learning and effective education about forests. Interestingly enough, the one vision element that stimulated an ambiguous response dealt with reducing consumer demand and using recycling (and did not include increased productivity). Some of the ambiguous response was due to omitted words and ideas, but more importantly, the ambiguity centered around complexity and lack of information and understanding. The results of the Forest Congress reinforce the concerns presented during this National Research Council meeting. The process of addressing these concerns about better understanding environmental effects of wood used as a raw

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material, will lead to much higher levels of agreement and to new principles. The answers also will help link forests and forest-based values to broader social and environmental concerns of Americans. Certification and Standards Rapporteur's Perspective Frederick W. Cubbage North Carolina State University This volume concerns certification of forest products, the ISO 14000 standards, life-cycle analysis, and related concepts. The use of wood as a raw material has energy and environmental implications, and many advocates note that wood is an energy efficient, renewable natural resource commodity that has very little impact on the environment and is in fact often beneficial. Proponents of other nonrenewable resources advocate the benefits of other commodities, and suggest that alternative materials have less impact on the environment, especially on a broad-area basis. Critics of intensive forestry also tend to believe that forest practices can be harmful and should be monitored. These diverse concepts come together in the proposals for life-cycle analyses and the environmental standards of the International Organization for Standardization (ISO), which would measure the entire environmental and energy impacts of the use of raw materials for construction or other development purposes. This chapter contains brief reactions to the proposals presented elsewhere in this volume. The comments in this section are provided from the perspective of a forestry professor and department head with a background in forest policy and economics, a researcher in nonindustrial private forestry, and a southern nonindustrial private forest landowner. Comments from industry and trade group representatives are contained in the other two sections of this chapter. In general, my comments are intended to be critical, but constructive, suggestions about the merits of the volume's proposals. I do not personally ascribe to all the beliefs I recapitulate here, but I do believe that as an observer of southern forestry and politics, some potential problems bear mentioning. Regulatory Concerns The first question I address here has to do with whether the proposed implementation of certification, standards, and life-cycle analyses would cause concern that they might become regulatory. Yes. There is great concern in the South that such initiatives will become regulations. For example, best management practices in several states started as voluntary approaches and later became required. Requirements for certified wood might easily follow voluntary provision of certification.

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The President's Commission on Environmental Quality (1993) listed several of the concerns about efforts and regulations to improve biodiversity, which remain relevant to certification efforts. Guidelines (or regulations) might limit or halt profitable land uses, or at least increase costs; reduce our ability to meet the nation's needs for commodity goods and services; pose difficulty for measuring results or direct benefits; lead to conflicts among regulatory approaches; or ''elevate'' the baseline level of regulation or "guidance," so that stricter measures would be required later. The recent and deep-seated private property rights movement also might hinder acceptance of the certification-standards approaches. Many landowners in the South oppose any perceived infringements on their property rights. Forest landowner and farm interest groups stridently oppose most regulations, or guidelines that could become regulations. Conservative legislators and Congress members would gleefully oppose this further involvement of big government, and even big business (paper companies and others) are subject to some criticism these days. Standards will be seen as one more extension of the camel's nose in the property rights tent, and they will be opposed strongly. Administrative implementation of voluntary standards will be extremely difficult and expensive as well. For example, one proposal suggests that certification require a management plan, site inspections by a certifier, and a landowner interview. Studies we performed in Georgia suggest that less than half of the nonindustrial private forest (NIPF) land area in the South receives any formal forestry advice before harvesting (Hodges, 1988); surely a much lower percentage of landowners receive advice. Probably less than 10 percent of the NIPF landowners or area have formal management plans (Hodges and Cubbage, 1990), and only a few states perform any formal site inspections. There are about 5 million landowners in the South, and 9.9 million in the nation (Moulton and Birch, 1995). Certification and inspection of all these sites before harvest is far too difficult to achieve, even with all the industry and state and consulting programs. My employer, North Carolina State University, would be pleased to find this much more work for our forestry school graduates. NIPF landowners, however, might not be so pleased about the red tape and expense required. Methodological Adequacy The next question to consider is whether the methods described for use in certification, life-cycle analyses, or standards are adequate. Assume that this refers to their environmental adequacy for forest management, based on scientific knowledge. The short answer is no. The methods that seem to be used to date can be pretty sophisticated, but their mathematical elegance far outstrips their scientific or practical bases. It looks as though few, if any, of these approaches have been through scientific review and have been published, either as individual studies or as integrated rating and scoring systems. Few of the approaches look

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as though they would ever be accepted for publication in scientific journals, and some do not even seem like more than educated guesses based on gray literature and pseudoscience. The weakness of these approaches shows promise for uniting landowners and scientists for the first time in forestry—in opposition to their implementation. The scientists surely would like to increase the science behind these approaches, however, and probably would be willing to perform applied research if reasonable funding were provided. Consumer and Industry Acceptance The concept of wood or forest environmental certification clearly has potential for acceptance by consumers and by the forest industry. Citizens consistently express their beliefs that we should do more to protect the environment, and "green" products are generally accepted as desirable. The degree to which this general belief can be translated into widespread acceptance of requirements for green labeling, and whether American consumers will actually pay more, is moot. Anecdotal information from the United States and Europe suggests that standards will be received gladly. On the other hand, there is some indication that there is little willingness, at least in the United States, to pay more for labeled products. Furthermore, many consumers are too busy or indifferent to spend a lot of time, let alone a lot of money, to figure out and preferentially purchase "green" products. Green labeling and certification also raise consumer equity considerations. These efforts will probably raise prices for consumer products, which will be differentially borne by poor people who spend more of their disposable income on shelter and paper products. As mentioned, NIPF landowners, who are producers of wood and environmental benefits, as well as consumers of certification services, might not accept these guidelines or requirements graciously. The forest products industry also could view certification with ambivalence. Their costs might increase and profits decrease because of certification programs, but if the costs can be passed on to consumers, or if certification allows them to gain market share in the United States or abroad, their objections might dwindle. If the guidelines or standards affect trade and become nontariff barriers to wood sales, neither industry nor NIPF owners will be pleased. The potential of the standards to discriminate against the use of fast-grown plantation wood, which is becoming more profitable and popular in all of the Americas, is undesirable to most U.S. forest landowners. Large increases in the management costs also are not desired. There could be some merits of environmental certification and standards for NIPF landowners and for the forest industry, other than just market share concerns. The President's Commission on Environmental Quality (1993) addresses these issues. First of all, employees and forest landowners do want to protect the environment and act as good stewards of their forests. Good feelings and goodwill can result from positive environmental action. This can extend to good

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neighbor and community relations, and to good public relations as well. Participation in certification programs can help build trust with regulators and consumers. In some cases, good stewardship practices might lead to operating cost savings if they prompt better means of performing actions or help protect long-run site productivity. The degree of exhortation or coercion will also influence the view of producers and consumers in certification programs. Voluntary or exhortatory programs are more likely to be well received than are coercive or regulatory programs. Providing producers the option to participate will make their responses more attuned to market benefits and less of a command-and-control demand. Given the rather shallow scientific bases and potential for biases in current certification efforts, a voluntary approach certainly seems preferable. This could be likened to the opportunity to buy organic food. Environmentally certified wood will gain a share of the market based on its merits, but not all consumers will be forced to pay more for the implicit benefits, which will vary among buyers. Market Issues The various types of forest certification and standards for environmental protection can be viewed as an extension of market economics, or an interference in market economics, depending on their application and the degree of coercion applied. A single-sector (forestry) standard—such as the International Organization for Standardization's document—would obviously tend to discriminate in the market against forestry and wood products to the benefit of other renewable or nonrenewable resources. Forestry criteria that favor or mandate natural stand management and longer rotations excessively will penalize market responses to wood scarcity and thus cause forest landowners to lose profits. Certification programs should involve consumers, environmentalists, and forest landowners to avoid biases against market resource allocation. To date, all of the forest certification standards and approaches ignore economic factors such as costs, prices, profits, or employment. And the assessment of community benefits proposed by some certification programs has considerable potential for arbitrary measurement and application. The biocentric orientation for certification and life-cycle analyses could be a return to forestry's roots in European management paradigms, but it hardly seems like a good prescription for wise or efficient natural resource use in times of increasing resource scarcity. It will lead to less wood being available and to more use of alternative, energy-intensive resources. Another concern is the impact on nonindustrial private forest landowners and markets. Timber markets consisting of NIPF owners (sellers) and forest industries (buyers) have a tenuous balance of power already. Timber buyers, who purchase wood all the time, know much more about timber measurement techniques and prices. Adding a new factor of certified wood and forestry into the equation will make this already fragile power balance tip even more toward

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timber buyers. Although it might serve as a means to increase timber prices for desirable wood, the lack of certification could be used as bargaining chip (or club) against less knowledgeable owners to depress the prices they were paid, whether it actually was the case or not. Timber buyers have been reported occasionally to scare NIPF owners into selling cheaply by intimating that insects or disease might kill an owners' trees. The same ploys could be used for uncertified wood. Even in cases when uncertified wood really was worth less, the cost surely would come out of the stumpage price paid to the NIPF owner, not out of the profits of the forest products companies. In addition, large companies will be better able to perform practices and audits that will allow their wood to be certified. This could contribute to a two-tier price structure favoring large companies and penalizing small timberland owners. The chain of control issues and costs will exacerbate the already difficult problems with NIPFs and possible reductions in their stumpage costs. If landowners do not perceive or receive adequate returns from timber investments, we may well have not only less timber, but also less overall management and environmental protection. There is some latent resentment against large forest products companies in some communities and by some landowners already. Having large companies act as timber certification and buying judge and jury at the same time will not create goodwill and might discourage landowners from making timber investments. The role of consultants or small companies that provide forest certification or inspections could significantly affect market outcomes. At the very least, these concerns will become another player in market transactions. They will provide a service, probably at a significant cost, and either generate no more wood production or actually reduce wood production. More consultants and inspectors will be good for forestry schools and bureaucracies, but at some cost to society. At best, the environment will be better protected but landowners will receive slightly less return. At worst, landowners will have to pay large sums to certify environmental compliance, and perhaps even spend a significant amount of their own time in doing so, and receive much lower financial returns. The selection and implementation for sustainable forestry criteria and standards also has considerable potential for arbitrary and capricious rules that are based on bad science and will probably discriminate against growing and harvesting timber cheaply to promote unquantifiable environmental benefits. This concern again argues for truly voluntary programs, where only the landowners who want to will participate, and thus they alone can capture any gains that are available from certification. If everyone participates in certification, it will just raise costs without providing any benefits of market segmentation. Conclusion Forest products, life-cycle analyses, standards, certification, and labeling are excellent concepts that help ensure environmental protection and enhance market

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share in selected countries and for selected owners. These concepts should be approached through reasonable, voluntary, market-based mechanisms and applied to all industrial sectors—not just forestry. As this review indicates, however, there certainly are hazards involved with certification and strict standards for forest environmental protection. My role here is to serve as a critic of these concepts to prompt improvement. There is no shortage of advocates for life-cycle analyses, standards, certification, and green labeling. Indeed, this area promises to be the largest current growth industry in forestry consulting and management services. It also offers intriguing opportunities to mix market incentives for environmental protection with landowner desires to provide environmentally friendly management, for an incremental profit. However, to realize these potential Pareto-optimal outcomes, certification must rely on voluntary methods and responses as much as possible. Heavy handed or mandatory implementation of these methods, for all owners, will create huge market distortions, cause a loss of interest and investment in forestry, and shift production to other, more energy-wasteful activities. There remains important work for the government in providing good information about the subjects of standards, life-cycle analysis, certification, and green labeling. Federal scientific and policy organizations should help analyze, plan, and develop means to establish good scientific efforts to measure the status and health of forest ecosystems, the merits of wood and other resources, and the means to dispassionately assess the relative merits of various resources for use. We need better information about resource use and protection, the effects of various certification programs on resource management and economics, and the integration of sound science into policy recommendations. These charters should provide considerable challenges but will be crucial in achieving the goals of sustainable economic development of all our forest resources. References Hodges, Donald G. 1988. Evaluating southern forest management research: An analysis of resource allocation and innovation diffusion. Ph.D. dissertation. University of Georgia. Hodges, Donald G., and Frederick W. Cubbage. 1990. Nonindustrial private forest management in the South: Assistance foresters' activities and perceptions. Southern Journal of Applied Forestry 14(1):44–48. Moulton, Robert, and Thomas Birch. 1995. Nonindustrial private forest landowners in the South. Forest Farmer 54(5):44–46. President's Commission on Environmental Quality. 1993. Biodiversity on private lands. Washington, D.C.: Executive Office of the President.

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Life-Cycle Assessment and Certification Rapporteur's Perspective Bob Glowinski American Wood Council of the American Forest and Paper Association I present my opinions here as a representative of the wood products manufacturers. I see a multidimensional matrix for the life-cycle analysis issue. There seem to be several components. There are the tools we need for inventory and impact analysis. We also have data needs that those tools will ultimately require. The matrix can be divided into the components in the full life-cycle in which it will be used, those that occur in the forest, and those that occur from the manufacturing of the product. It seems that we have a range of capabilities that could be placed within that matrix for completing those tasks. I think we are progressing toward having inventory tools for the product, but I see very little, or hear very little, that persuades me to believe we have any kind of tools available for going back into the forest, to do the kind of analysis that life-cycle studies will eventually require. Similarly, we have good data in some areas, bad data in others, no data in still others. It strikes me that projects like a follow up to the National Academy of Sciences 1976 report of the Committee on Renewable Resources for Industrial Materials (National Research Council, 1976) could go a long way toward filling some of the gaps in my matrix. Industry generally fears regulation—not because regulation cannot be good or might be bad—but because regulations can be developed without sound underlying principles. That is the particular fear concerning the adoption of life-cycle analysis as the basis for regulatory control of the industry. Moreover, we would be concerned that voluntary regulations would quickly become mandatory—if it's regulatory it cannot be voluntary. The tools so far developed to implement any type of regulation have not been developed in an open and transparent process, so little is known about how they work. It seems that there is not even agreement about whether the methodologies are based on sound science or whether they are more appropriately ascribed to "pseudoscience." To the extent that any type of regulatory implementation will result in increased costs, those costs will be borne by all of us—manufacturers and consumers alike. And if we are going to increase costs, it seems we ought to have a strong understanding and good reasons for any regulation that would be adopted. Certification, which has been discussed in this volume as an undertaking, can act as de facto regulation. To the extent that we would adopt a voluntary implementation process, it seems it would be possible only when we all come to agreement that the underlying science and that the tools and analysis that underpin it

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have also been embraced and supported by those who can take advantage of it. Certainly, the International Organization for Standardization (ISO) certification process, which is perhaps being developed in more of an open and transparent system, must be watched carefully, because different groups obviously come to ISO with causes they wish to advance. There are trade-offs and complexities. Life-cycle analysis cannot be reduced to a single number. The statement, "My product is better than your product," does not seem to fit well with the purpose of life-cycle analysis. As an industry, however, I believe our manufacturers would embrace some kind of analytical capability, whether life-cycle analysis or life-cycle inventories or something else altogether. It gives us, as manufacturers, the opportunity to develop better products. If we develop better products, the marketplace will react as a self-regulator. Better products generally rise to the top, and if we could use these tools to develop better products, we would see the opportunity to have a marketplace advantage. Reference National Research Council. 1976. Renewable resources for industrial materials. Washington, D.C.: National Academy Press. Implications of Life-Cycle Concepts Rapporteur's Perspective Joseph Fiksel Battelle Memorial Institute I would like to begin by addressing a question posed in this volume. Is there a concern that life-cycle analysis (LCA) methodologies will become regulatory tools? The answer is a resounding yes. There is a second question. Are they adequate for use in regulation and policy making? The answer is a qualified no. My opinion, based on my observation of this field, is that existing methodologies for life-cycle assessment are immature; they do not adequately address the full range of issues reviewed in this volume. In particular, they are inadequate to assess environmental impacts such as ecosystem stability, sustainability, aesthetics, and biodiversity. The current generation of life-cycle methods is well developed for a limited range of applications. We can do mass and energy balances fairly well, but we do not have very good methodologies for translating these mass and energy inventories into consequences or impacts on the environment. In fact, there is no scientific consensus on such methods; they are just beginning to be explored. The field is still somewhat embryonic—as mentioned in several of the presentations. As an example, the discussions presented in Chapter 8 and Appendix 1,

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concerning labeling and, more particularly, stress effect networks, reflect a body of thought that is still in its infancy. Therefore, we must be cautious about promulgating such methodologies for use in a regulatory context. On the other hand, the use of life-cycle concepts to guide regulatory policy is highly appropriate and can lead to more flexible, sensible regulations. The field brings to mind the early days of risk assessment. I was involved 20 years ago in developing methodologies for assessing chronic human health risks associated with carcinogens and other substances in the environment. We started with science and we ended up with pseudoscience. Toxicology is a science, epidemiology is a science, but risk assessment, as practiced today, is not a science. It is a set of methodologies that is laden with uncertainties and assumptions, and the results cannot be verified because they predict such low incidences of effects that it would be impossible to statistically discriminate those effects in human populations. So we are dealing with an unvalidated theory. And yet, we see these methodologies aggressively promulgated and adopted by regulatory agencies, with the full support of Congress. The result is often a politicization of science involving acrimonious debate between various parties who have different interests with regard to the distribution or release of given products or substances. It would be a shame to take the field of life-cycle assessment and repeat this pattern. There are other questions addressed in this volume, concerning how the use of life-cycle concepts could affect trade and consumer acceptance, among other areas. There are many concerns about having a "level playing field" in the debate over ISO 14000 and other international standards. Some nations may seek to impose more stringent criteria, thereby limiting imports of goods and favoring their own industries. Such protectionist trade policies could be exacerbated by the accelerated adoption of life-cycle analysis. One can envision criteria that might not be scientifically defensible, but would be convenient for certain interest groups or nations. The potential for abuse exists both on the regulatory front within the United States, and on the international front in terms of use of LCA for ecolabeling. Jacques Besnainou's chapter on the European methods (Chapter 4) discusses the limitations of life-cycle analysis for broad generalization and the problem of spatial and temporal resolution. One problem he does not include is that life-cycle analysis does not treat the science of economics at all. In fact, the approach of life-cycle assessment was deliberately developed without consideration of economic impacts. So its seems that if you try to use it as a policy tool, half of the equation is missing. Some of the most important effects of stating preferences for different kinds of materials or for making judgments about acceptability of products and processes are economic. And they are highly visible—on employment, on productivity, on gross domestic product. There is tremendous potential for abuse when tools that aggregate subjective judgments are put together with quasi-scientific results and are used to justify one approach

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over another—especially when economic effects are deliberately excluded. We live in a dynamic market system and we must understand how markets will respond to these kinds of products. Another question: What will be consumer acceptance? Most industries have found that consumers are by-and-large indifferent to "green products." There's a small segment of the marketplace—perhaps less than 5 percent—that is more responsive. But many manufacturers have found they cannot charge a premium for green products. If all else is equal, consumers might favor a green product over another, but in general they are somewhat vague about why. Therefore, the language of LCA is more useful for initiating dialogue between government and industry than it is for purposes of communications with the marketplace. Consumers are primarily interested in the performance and price of products—and most prefer to trust government to sort out some of the more complex issues regarding environmental impacts. Unfortunately, there is a good amount of mistrust today, and that is why many consumer groups are suspicious of scientific methods endorsed by government or industry. I believe that the average consumer would rather have someone else do the work to create adequate policies and regulations that protect against truly harmful effects. In conclusion, it seems that there is a logical next step. There should be a broad study to pull together the diverse research in this field in order to better explain "industrial ecology" and the broad consequences of materials production and processing, and to establish sound scientific principles both for directing the development of methodology and for critiquing proposed methodologies that might arise in different contexts. A framework could then be identified to support a variety of research projects in different disciplines, including ecology, biology, economics, and environmental sciences. Such a study could also identify ways to bridge the gaps and bring together the results of those research efforts within a coherent framework. This could accomplish for LCA what the National Academy of Sciences has done in the area of risk assessment, in its attempt to bring some reasoned scientific perspective into the synthesis of science with subjective values.

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APPENDIXES

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