Svar till Europeiska kommissionen angående konsultation om indikatorer för resurseffektivitet

Jernkontoret's (The Swedish Steel Producers' Association) contribution to the Consultation of the European Commission: Options for Resource Efficiency Indicators. Register ID: 76331988454-11

The Swedish Steel industry welcomes the principles of resource efficiency since this gives a holistic view on environmental, energy and climate policies. Steel industry, as such a energy- and material-intensive sectors, already ensure that they use their resources efficiently – for economic reasons.

Steel is highly adaptable for various applications, the products has long lifetime and can be endlessly and easily recycled at the end of their service lives without losing its inherent properties. All these characteristics being important for a resource efficient society.

Swedish Steel Industry has since many years had a strong focus on innovation and research with the aim to improve efficiency in production and products. This has resulted in specialized products which gives added value to the customer in term of resource efficiency.

With regard to the sustainable use of resources, it is the task of policies to support every activity that can contribute to resource efficiency. In the opposite, policies should not intervene into the economic sound competition of materials and industrial sectors. Eco-balances that take into account the production, the whole lifetime of a material or product and all life-cycles of a material should be supported, as they will support resource efficiency within an integrated approach.

1) What are the key issues that need to be addressed by indicators to support resource policy?

The Commission proposes indicators on a national level. Such indicators may be used to monitor development in various areas related to resource efficiency. The perfect indicator will never be found and it is therefore relevant to have a set of indicators to follow different areas. Using a set of indicators can be a “framework of thoughts” and give the Member States an indication of what needs to be improved in each country. Each indicator could be analyzed by Member states to build understanding of which factors that affects the indicator and which priorities that are important for each country. Long term use of the indicators can give an indication of trends and development over time within a Member State.

However, many of the indicators are not, according to our view, suitable for comparison between member States. As the indicators are influenced for example by the industry structure, climate etc in the specific country, they cannot show which member State is most resource efficient – e.g Member States with industries like steel and mining will consume more raw material and energy and also generate more waste than those with an economy more based on services. It is important that indicators are based on accepted, representative and transparent data. Development of new indicators which needs new data should be thoroughly thought-out not to create a large administrative burden on business and the rest of society.

It is also of outmost importance that the use of indicators does not lead to suboptimization which might be a risk if there is a focus on only one indicator.

2) Are there other indicators that we should be using to monitor the economic and environmental impacts of resource efficiency policies by 2013 and for the future?

More specifically:

a) Is the proposed lead indicator, GDP/DMC, an appropriate indicator to measure resource efficiency? Are there any better alternatives that should be considered?

Jernkontoret do not believe that the proposed lead indicator will be a proper tool for policy makers and opposes that one lead indicator should be used as the basis for policy decisions. The indicator has several shortcomings and is clearly not suitable for comparing countries or setting targets. The conditions in countries are diverse and the methodology does not take this into account. The proposed lead indicator ignores the structural differences between countries, giving advantage to those countries that focus on services and imports of manufactured goods. In addition the environmental impacts of economic activity outside a country´s borders are not taken into account.

There is a severe risk that the proposed lead indicator will lead to wrong conclusions regarding environmental and economic development. It does not directly measure impact decoupling, and tells us little about the environmental pressure that economic activity exerts. The proposed DMC also leads to wrong conclusions for industrial policies since it underestimates the resource use of imports and exports. As mentioned above, a single indicator will not be of any great use in the endeavour towards resource efficiency. As part of a set of indicators the DMC still has to be adjusted in such a way that the above mentioned criticism is remedied.

b) Are the appropriate indicators included in the dashboard of macroindicators?

Are there any alternatives that should be considered? The artificial land or built-up area is an ambiguous indicator not having a clear link to what environmental aspect it is suppose to measure. It would show better results for big countries with low population or great not used/not useable areas for whatever useful purpose. An alternative might be an indicator that evaluates industrial wastelands - abandoned areas that have been used industrially but are neither used any longer nor recultivated / renaturated. Water scarcity might be an appropriate indicators for some countries to indicate their priorities. GHG emissions are a global topic and not suitable to evaluate single regions or countries without taking into account the specific circumstances. Nevertheless, this value is part of other legal regulations, such as the emissions trading system, and therefore should not be used twice in the context of resource efficiency.

c) Are the appropriate indicators included in the third tier of thematic indicators? Are there any other indicators that should be considered?

Total waste generation is an indicator also highly affected by industrial structure and geographical conditions and therefore is not an unambiguous value. Municipal waste is a more relevant indicator.

Recycling rate for municipal waste may be relevant to monitor effects of waste policies.

Recycling rate on other kind of waste or material is difficult to calculate and does not give useful results for policy making. For materials the important property is recyclability and conservation of inherent material properties but this cannot be accounted for by these kind of indicators.

d) Are the appropriate indicators included in the Scoreboard? Are there any other indicators that should be considered?

3) Which indicators would be best suited for potentially setting targets, by 2013 and for the future?

We believe that target setting is not an appropriate way of making use of a set of indicators which are each non-perfect. Member state may for their own development appoint targets on their priority areas.

4) Any other comments?

In chapter 5 of the consultation paper the possible development of indicators are discussed which we would like to comment.

The development of an indicator ‘environmental footprint of products’ is leading in the right direction, where more than one single parameter is assessed by taking into account the wide range of environmental effects including the full lifecycle plus recycling. However, still there is methodological development to be done.

Optimally a holistic examination will include not only the effects directly caused, but also the contribution that an industry and its products – and especially product innovations – make to the required emissions savings in other sectors. Studies within our research program The Steel Eco-Cycle, an environmental research program that comprehends the entire life cycle of steel, show that the use of innovative steel products and a closed loop for metal flows in society can result in substantive reduction of emissions, increased energy efficiency and use of natural resources in a life cycle perspective, as illustrated below. The core of the program consists of technically strategic research inputs that serve to strengthen the steel eco-cycle.

5.1.3 and 5.1.4
Although there might be a general wish to be able to aggregate different environmental impact it has to be realised that the methodologies to evaluate environmental impact from several impact categories is not fully elaborated.

Indicator for energy and materials intensive sectors are mentioned. If this will be an area of development we would like to be closely involved in this work. As mentioned above the use of materials including the aspect of quality, durability and life cycle properties has to be considered to avoid sub optimization.

Concerning environmentally harmful subsidies the need is primarily to define what is included in this concept.