Gareth's Blog

News & Views From the Front Line

Wednesday, 29 July 2009

Glen Bennett, EAE Ltd



Yesterday I interviewed Glen Bennett, founder and MD of EAE Ltd, a Scottish leaflet marketing business. This video, made by young people as part of a wider project, shows some of the achievements he has made on his objective of making the company zero carbon.

What the video doesn't show is the trials and tribulations Glen went through. The wind turbine took them 2½ years to get installed - they had to work with 22 different organisations to do it. Many were clearly not up to the job - one planner asked what ‘kWh’ stood for, another tried to kill the project at the last minute for (unnecessary) noise testing.

Then, as soon as it was installed, EAE were hit with a business rate increase as the turbine counted as a business improvement! That levy has now been removed, but only after Glen ran a media campaign to point out the stupidity of the situation. Excess electricity from the turbine is simply dumped onto the grid for free as the current set up for charging would cost more than it would generate.

Why is this not easier? Why should pioneers like Glen have to go through the modern day equivalent of the 12 tasks of Hercules to cut his company's carbon footprint? The recent Government strategies will lower some of these bureaucratic barriers, but Glen's story shows that it ain't always easy being green.

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Friday, 31 October 2008

New Product Carbon Footprinting Standard

The BSi, along with the Carbon Trust and DEFRA, have just released the PAS2050 carbon footprinting standard for goods and services along with a guide to its use. You can download it for free from the BSi website.

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# posted by Gareth Kane : 06:07  0 Comments

Wednesday, 15 October 2008

Low Carbon Business Strategies White Paper

You can now download our new Low Carbon Business Strategies white paper for free from the resources page. This tells you what to do once you have calculated that carbon footprint and are unsure of how to tackle it. Strategies range from simple carbon management through to developing low carbon business opportunities.

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# posted by Gareth Kane : 10:13  0 Comments

Friday, 12 September 2008

Low Carbon Products & Services Seminar - 22 October 2008

I'm giving another seminar on developing, marketing and selling low carbon products and services next month, this time in lovely Harrogate. The seminar is part of the Low Carbon Innovation Exchange event which is certainly the best of its kind that I've ever attended.

At my midday seminar you will:

  • learn the business case for going beyond compliance.

  • discover what makes a product or service a low carbon product or service.

  • find out which markets are booming and why.

  • learn how to market and sell low carbon products & services.

  • identify the risks, and how to avoid them.


  • Plus you will benefit from all the other seminars, panel sessions, one-to-one meetings and round table discussions in the Exchange. Oh, and there's a great lunch included.

    Here's The Deal

    If you register for my seminar, you will also get:

  • The reduced entry fee of £295 + VAT for the whole event.

  • A FREE copy of my eBook "The Green Business Bible" (RRP £24.95+VAT).

  • A FREE 30 min telephone coaching session (normally £150.00+VAT).

  • 50% discount on my full day "Building a Low Carbon Business" Seminar (full price £295.00+VAT).

  • A Certificate of Attendance for CPD purposes.


  • But, to get these offers, you must register via this link. You can see the whole programme for the day here, but you must use this registration link to get the freebies.

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    # posted by Gareth Kane : 13:53  1 Comments

    Monday, 8 September 2008

    New Resources - Free White Papers

    We've just started publishing a series of white papers for organisations, environmental consultants and students. The first, A Quick Guide to Carbon Footprinting, can be downloaded now from the resources page. More are under development and will come on-line in the next few weeks.

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    # posted by Gareth Kane : 13:00  0 Comments

    Wednesday, 9 July 2008

    The unrecognised recycling sector

    On Monday I gave a seminar on carbon footprinting and carbon management (using the Terra Infirma brainstorming tool) at the Association of Charity Shops Annual Conference in Keele. I learnt a lot, as I always do in this trade (I've worked with everyone from multi-national pharmaceutical companies through to a crazy golf course - you pick up all sorts of weird factoids). The sector is a huge, professionally run, and very competitive retail operation, a huge chunk of the reuse industry and a huge source of materials for recyclers. This was not lost on the three recycling companies who sponsored the event.

    The seminar went to plan and was well received - despite some shock when we spent half the time actually doing some work. Solutions we generated included checking tyre pressure of vehicles, better use of steamers, buying translucent kettles and even screwing down the thermostat dials. The big contentious issue is open/closed door. As with all shops, open door = more sales but massive energy loss. We didn't resolve this one, but if anyone can think of a solution, post it in the comments.

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    # posted by Gareth Kane : 09:32  0 Comments

    Wednesday, 5 March 2008

    Greenwash Abounds!

    I finally got around to reading the February edition of the ENDS report yesterday and was disappointed, but not surprised, to find four major stories on Greenwashing.

    - Two of these (mastic asphalt companies and British Gas) were claiming that their products had no carbon footprint as they were offsetting their carbon emissions. While I (somewhat controversially) believe in offsetting as a CSR strategy, it is very unwise to use it as a claim in this way. In my book, you can say "we offset our carbon emissions", but not "our products have a zero carbon footprint". Obviously the Advertising Standards Authority agrees with me.

    - Another is a compost company, William Sinclair, putting a 'cradle to gate' carbon label on their peat products. This is a bit naughty as peat is a fossil fuel and will decompose in use to produce 5 times as much carbon dioxide as the figure on the label. A bit like saying petrol has a carbon footprint of X as long as you don't actually use it.

    - The last story is about 'ethical' investment funds. These have been found to be sort-of ethical in that they avoid certain industries (such as the arms industry) but some only have 1% of their stocks in 'green' industries, despite the image they portray.

    All of these examples show that green claims are a minefield and that you're better not doing it at all if you're not going to do it properly. As my primary school teacher used to say, you're only cheating yourself, you know...

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    # posted by Gareth Kane : 06:06  0 Comments

    Friday, 15 February 2008

    How not to employ an Environmental Consultant...

    I recently requested tender documents from a large organisation who wanted a carbon footprint. They had a huge raft of different properties, a big fleet of vehicles and a complex supply chain. When I read the tender I was aghast. They wanted:

    - a "comprehensive report" on their carbon footprint.

    - 3 ways they could reduce this by a stipulated amount.

    - all this within 4 weeks (the same time they had given themselves to evaluate the tenders).

    - the consultant to quote a daily rate.

    I wrote back and told them this was unrealistic. I didn't explain why in detail, but here are the reasons:

    - Daily rate: if you pay by the hour/day then frankly you are paying for the consultant to type slowly or hang around your premises chatting. It's the only way consultants can make any money out of selling their expertise by the hour, other than lying to you about the hours they've put in. The tight timeframe just encourages a larger team of consultants to work even more inefficiently - team meetings rack up those hours.

    - Prescriptive methodology: if the person writing the tender has expertise in environmental consultancy, why don't they do it themselves? If not, and they need an expert, why not let that expert suggest their own methodology?

    - 3 ways: what happens if it is 2 or 4 or 6?

    - Comprehensive report: they must have some space on the dust collecting shelf to fill. Of course, given the daily rate, you'll make the slow typing consultant happy!

    - 4 weeks: how does the client know how long a good piece of work will take? Will the client really be able to provide all the information in this timescale? Will all key staff be made available? Would a better study in 8 weeks not be, well, better? Given the complexity of the problem, it will take a reasonable amount of chronological time (as opposed to billable hours) to build an organisational model, collect data, interpret it, interview staff and develop solutions.

    How about this as an alternative:

    - Fixed fee: the incentive is for the consultant to work efficiently, not rack up billable hours.

    - Flexible methodology: I like to engage the client's staff in solution development as a. they know much more about the business than I will learn in a few weeks, and, b. the recommendations are much more likely to be implemented if the staff have ownership. There was no scope for this in the Tender above as the client probably hasn't thought of it. I'm not expecting them to have either - I'm the one who's meant to know what I'm doing!

    - Appropriate deliverables, discussed and agreed between consultant and client.

    - Unless there is a very good reason for the tight timeframe, why not let the consultant suggest how much time they will need to deliver the project (the engagement strategy I mentioned above will take more time to organise).

    This is not a rant against that one organisation - virtually every tender I look at has a similar approach. Which is one reason I've ditched tendering for work except in a few special circumstances. If I were buying consultancy I would ask consultants to send in a project proposal to address the highest level requirements (we want to cut our carbon footprint by X%) the way they think is best, shortlist and interview before appointing.

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    # posted by Gareth Kane : 06:50  0 Comments

    Monday, 10 December 2007

    Bleak News from Bali

    UK political orthodoxy has two main tenets when it comes to climate change: "yes, we can fix it, if only the Americans/Chinese/this month's scapegoat do their bit" and "technology will be the answer". The first of these has been holed below the water by two eminent sources:

    1. At the Bali conference, the UK's Chief Scientific Advisor David King saying that some climate change is inevitable as we have acted too late.

    2. A study has shown that the UK's Carbon footprint is much bigger and rising faster than the Government has claimed. This is because much of our footprint is from overseas sources providing for our lifestyles which the Government doesn't count.

    Neither of these should be a shock. Almost every national climate change strategy recognises that adaptation (to the effects) is as important as mitigation (stopping the next lot happening). Issues such as flood defences/drainage, health provision and emergency response plans come under the adaptation banner. On the second point, I've been banging on about this for a long time - just because we've offshored most of our dirty industries and much of our leisure industry, doesn't mean we can neglect their carbon emissions. I've personally made this point to a number of top politicians including David Milliband (when he was Environment Sec), Chris Huhne and John Gummer.

    As for technology, we need some immediate step changes in take up to make any difference.

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    # posted by Gareth Kane : 09:25  0 Comments

    Monday, 26 November 2007

    CBI Members Make Climate Change Commitments

    The Confederation of British Industry (CBI) has released "Climate Change: Everyone's Business" the report of its Climate Change Task Force. The task force consists of representatives of BT, Shell, npower, Barclays, Ford, bp, Tesco, Corus, British Airways, Rolls Royce and loads of other big businesses.

    Most of the findings of the task force are pretty run of the mill, but there are three things which make this report interesting:

    • The CBI has traditionally taken a reactive approach to the environmental agenda, seeing itself as a defender of business against restrictive environmental legislation. This is a significant shift to a more proactive, forward looking agenda.
    • The task force acknowledges that the UK's carbon footprint is larger than the 2% of global emissions coming directly from the country. The misleading 2% figure has been used by many people (including leading politicians) in the last year to justify inaction and point the finger at China amongst others.
    • The task force members are pledging to take action themselves, including working with their 2m employees to help them reduce their total carbon footprint - at home and at work. Businesses are usually reluctant to use their influence any further than the factory gate.

    These three factors suggest a quantum leap in intention, understanding and, hopefully, action from the CBI, and by extension, UK industry.

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    # posted by Gareth Kane : 10:07  0 Comments

    Monday, 19 November 2007

    Uncertainty over Carbon Intensity of Electricity

    Like the rest of the carbon accounting/footprinting industry, we've always used DEFRA's published figure for the carbon intensity of electricity of 0.43 kgCO2 per kWh. DEFRA has now released figures showing that the actual carbon intensity of the UK's electricity is about 0.53 kgCO2 per kWh. Some members of the Association for Environmentally Conscious Building think the figure should be even higher at about 1.0 kgCO2 per kWh.

    Why is this an issue? Well if you are comparing, say a Ground Source Heat Pump to a gas fired condensing boiler, and if the Heat Pump is working at a co-efficient of performance of 3.5 (that's 3.5 units of heat out for each unit of electricity in), then, under the new DEFRA figures, the GSHP will produce 70% of the carbon dioxide of the boiler, whereas under the old figures it would be just 58%. That's quite a difference and could seriously affect a decision on whether to spend the extra cash required for the Heat Pump.

    So why did we use 0.43? Well, we always try to source our data from reliable, published and transparent sources and this was the industry accepted figure. DEFRA is going to continue to use 0.43 until 2010, but from now on we'll be using 0.53 and be keeping an eye on the debate over 1.0.

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    # posted by Gareth Kane : 09:07  0 Comments

    Monday, 12 November 2007

    UK Commits To Legally Binding Carbon Reductions

    In last week's Queen's Speech, Prime Minister Gordon Brown made a commitment to legally binding carbon emissions targets for the UK - a 60% cut by 2050. Leaving aside the arguments over whether 60% is 'enough' or what "legally binding" actually means in practice, getting anywhere close to this target will require a huge shift in policy - particularly given the lack of action to date.

    Up until now the Government has relied on providing support to businesses and consumers to reduce their carbon emissions through quangos such as The Carbon Trust, Envirowise, The Energy Savings Trust and WRAP. However the type of support provided by these organisations, while worthwhile, is unlikely to deliver 60% reductions in any one company. Therefore, if the Government is serious about this target, we can expect more and bigger sticks to back up these carrots, for example:

    - The Renewable Transport Fuels Obligation (RTFO) is coming in 2009.

    - We can expect tougher Building Regulations to push new houses up the levels set out by the Code for Sustainable Homes.

    - I wouldn't be surprised if the Climate Change Levy is replaced by a tougher Carbon Tax and that obligations are made on waste heat to encourage its use in district heating.

    To avoid being clobbered by such sticks, industry and businesses need to start planning a low carbon future now. Reducing energy expenditure is never a bad idea.

    Measuring the carbon footprint of a business is an essential first step before reduction plans can be developed. At Terra Infirma we follow footprinting with the backcasting approach to develop low carbon future scenarios before tracing reduction pathways for a business to follow. This gives more radical solutions cutting right across the business, rather than simple quick fixes.

    But, whichever way a company wishes to address the problem, it will pay to have a headstart.

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    # posted by Gareth Kane : 10:25  0 Comments

    Monday, 29 October 2007

    Whose Carbon Is It Anyway? Part II

    When carbon footprinting, the allocation of carbon between different companies is a tricky issue as we've discussed before. Does the carbon produced by a gas-fired power station 'belong' to the power generator, or the power consumer?

    Well, the British Standard Institute (BSi) has just released a draft of their forthcoming PAS 2050 carbon footprinting standard and it is interesting to see how they approach the problem. The standard is based roughly on the Life Cycle Assessment (LCA) methodology to estimating the environmental impact of products, rather than taking a company by company approach. This means that if your company is part of a supply chain, your products' embodied carbon will count against you and your customers' products, rather than being divvied up between you. So in the example above, carbon emissions from the power station would count against the generator and the consumer. This is a sensible approach as long as everyone understands there is double counting involved - and no-one adds them together to get a 'total'.

    Many of the criticisms I've levelled at LCA apply here too. In particular, it will be interesting to see how rival companies' footprints compare and what assumptions they use to get there. I'm sure there will be some robust debates!

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    # posted by Gareth Kane : 13:45  0 Comments

    Wednesday, 24 October 2007

    1 in 6 SMEs know their carbon footprint?

    The 2007 SME Climate Change Survey found that 1 in 6 Small & Medium Size Enterprises (<250 employees) have measured their carbon footprint, but that 40% intend to do it rather soon. I must say I'm slightly suspicious of these figures, not just because I had some trouble tracking down a website for Explomarket, the PR company that carried out the research (these surveys are often done for marketing purposes rather than scientific endeavour). Few, if any, SMEs I have visited in the last couple of years could quote you their energy bill, never mind a carbon footprint.

    I recently did a footprint for Leaf Hairdressing, an independent salon, which gave some interesting results and lead to some employees changing their mode of transport. Katie, the owner, is both committed to the environment and sees being an "eco-salon" as a business differentiator. Certainly I struggled to find any other hairdressing salon or chain, including all the big names, who even mentioned the environment on their websites. It will be interesting to see if it makes a difference over the coming months.

    Today I'm talking at the Environmental Technology Transfer Club (ETTC) at the University of Teesside about this and other carbon footprinting projects we have been involved with. If footprinting is as big as the survey suggests, I fully expect to be inundated with offers of lucrative work...

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    # posted by Gareth Kane : 06:55  0 Comments

    Monday, 22 October 2007

    I'm now "The Carbon Coach"

    One of the more interesting projects I'm involved with at the minute is 'acting' as "The Carbon Coach" for two Tyneside teenagers for a DVD on climate change for schools. The DVD is being produced by Digital Voices for Communities, a Tyneside based Social Enterprise. I like to think I'm the Trinny & Susanna of the low carbon economy, but in truth my performance is hardly going to trouble the BAFTA judges.

    What is remarkable is the enthusiasm of Grace and Ryan, the two youngsters. They're ordinary kids, not stage school overachievers, yet their understanding outstrips that of most adults.

    My role is to set them two challenges: to look at where their food comes from and to collect their food packaging for a week. I'll keep you up to date with how we get on.

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    # posted by Gareth Kane : 05:23  0 Comments

    Friday, 28 September 2007

    Big Businesses Tackle Carbon Emissions

    The Carbon Disclosure Project (CDP)'s fifth annual report into the carbon emissions of FTSE 500 companies shows that 76% of those who responded to its survey have put emissions reduction schemes in place, compared to just 48% last year. This is significant as the 383 companies who did respond are responsible for greenhouse gas emissions totalling almost 7bn tonnes per year - 14% of the global total. US businesses didn't fare so well, with only 29% of respondents reporting reduction schemes.

    While this massive increase has to be welcomed, it doesn't reflect how effective these carbon reduction schemes are in practice. It still shocks me how much energy is needlessly wasted in industry - asking a production manager how often compressed air lines are checked, or whether he has a motor management procedure usually results in an red faced shuffle of the feet and a mumbled list of excuses. This is easy money to save - it is much harder to bring in additional sales to cover wastage costs.

    In the UK, if you use more than £50k pa's worth of energy, the Carbon Trust may give you a free audit. They reckon they can save most businesses about 20% on their bill. Not bad for nothing.

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    # posted by Gareth Kane : 11:00  1 Comments

    Monday, 10 September 2007

    Whose Carbon Is It Anyway?

    There was an interesting piece in the Observer about Tesco being attacked for under-stating their carbon footprint by Christian Aid. The supermarket giant has come up with a figure of 4m tonnes CO2 equivalent per annum (more than Mauritius). Christian Aid say that if you include consumers driving to/from supermarkets and the activities of suppliers, Tesco's footprint could be up to twelve times this.

    This is a very interesting question: whose carbon is whose?

    A consumer can choose whether to drive to an out of town supermarket, or cycle to their high street. On the other hand, the out of town shopping centre was a fundamental part of the 'stack 'em high, sell 'em cheap' business model that lead to the supermarket boom in the 1980s and the decline of independent high street shops. So does that carbon belong to the consumer or the supermarket? Do we halve it between them or double count it?

    I think the supplier issue is more clear cut - the choice of produce is a clear choice of the supermarket buyers who have a legendarily iron grip on their supply chain. By making low carbon choices, Tesco could make a huge difference to the food industry (which translates into about a sixth of your own carbon footprint). But there still remains the issue of allocation - if Tesco admits responsibility for the emissions, does that let the supplier off the hook?

    This problem scales up to the global level as well. The UK Government is keen to state that the UK's carbon footprint is only 2% of the world's total, but, as we outsource much of our manufacturing, agriculture and tourism to other parts of the world, is that the full picture? China may be building huge numbers of new power stations, but the average Joe in China is not driving a 4x4, or sitting under a patio heater, eating imported food - China is manufacturing products for the rest of the world, including us.

    We urgently need better allocation methods to reflect both production and consumption, or we'll never have a clear idea of where responsibility lies.

    Note: apologies for the lack of posting on Friday - I had another great video for you, but ended up mired in sweary HTML hell. Will try to get it sorted for this week.

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    # posted by Gareth Kane : 10:09  0 Comments

    Tuesday, 17 July 2007

    How low (carbon) can we go?

    During this month's Live Earth concerts (remember them?), Al Gore was asking for pledges to reduce carbon emissions by 90% in an unspecified timeframe. This matches George Monbiot's target in Heat: for a 90% reduction by 2030. And the Centre for Alternative Technology (CAT) has published "zerocarbonbritain" - a blueprint for a 100% reduction by 2027. These targets make the UK Government's climate change target to reduce carbon emissions to 60% of 1990 levels by 2050 rather pedestrian, but the big question is, can it be done?

    The gurus above claim to show that it is technically feasible to meet these targets, but the big question is whether it is feasible on a practical basis. For example the UK's Sustainable Development Commission has estimated that 85% of buildings in 2050 currently exist - so even if the 15% of new build homes are completely carbon neutral, the vast majority won't be. When we moved into our 'Victorian Villa' in 2000, it had holes in the walls, no insulation in some roofs, precious little in the rest and terrible single glazing. We've fixed most of these since and put a solar hot water panel on the roof to boot, but we're still a long way from being low carbon, never mind carbon neutral.

    CAT addresses this issue using Tradable Emissions Quotas for individuals (you get a set amount you can emit and after that you have to buy more TEQs from someone with lower emissions). This would incentivise consumers to improve their carbon footprint by addressing their homes, transport etc. While the Government have been looking into quotas recently, it is debatable whether the public is ready to accept them (cf the fuss over bin collections during this year's local elections). So while sustainability is certainly feasible, there is a huge amount work to do to make it practical.

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    # posted by Gareth Kane : 08:40  0 Comments

    Monday, 9 July 2007

    Industry not exploiting carbon reduction business opportunities

    A report by the Economist Intelligence Unit has found that industry is not yet exploiting the business benefits of carbon reduction. The conclusions of the report are:

    ● Business is not keeping up with the changing public mood. 50% have no intention in reducing their carbon emissions in the next 3 years.

    ● Business is reacting to reputational risk, not exploiting business opportunities.

    ● Companies do not expect the costs to be high - most expect measures to have no or a low net cost.

    ● Companies starting out on carbon reduction face a steep learning curve.

    ● Government regulation is the single largest factor in shaping how companies address carbon issues.

    Given all the coverage climate change has had recently, these are worrying results. They suggest that despite the opportunity for quite a bit of gain for relatively little pain, industry still needs to be forced into reducing their carbon footprint. Simply aiming for mere regulatory compliance like this is a very expensive hobby as legislation will continue to tighten for the foreseeable future. The alternative is the sustainable business mantra of "beyond compliance" but this message obviously isn't getting through yet.

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    # posted by Gareth Kane : 14:46  0 Comments

    Thursday, 21 June 2007

    The Carbon Footprint of Offices

    While there has been exhaustive analysis of the energy use of the manufacturing and transportation industry, there has been relatively little light shone on the service sector, despite the fact that it appears to contribute about a sixth of UK carbon emissions. Now Chris Goodall, author of 'How To Live a Low Carbon Life' (see my review here), has published a review of the carbon footprint of the service sector.

    Goodall found that the average office based worker is responsible for about 2.26 t CO2 pa while at work. This is slightly more than the average British person emits lighting and heating their own home (2.21 t CO2 pa), despite the fact they only spend a quarter of their time at work. The main culprit is air conditioning - offices with aircon have twice the carbon footprint of offices without. The popularity of aircon is growing despite the fact that passive ventilation is cheaper both in terms of capital cost and (obviously) running costs.

    This week I was contacted by the owner of a small business (SME) who wanted to make their offices 'green'. His frustration was that, like many small operations, they had little or no control over the services management in their workspace. This ruled out about half my standard 'quick wins', despite the fact none of them involved anything more substantial than changing a lightbulb. As the vast majority of companies are SMEs and few own their offices, this problem is widespread.

    So while it is relatively easy to specify a low energy office new build (you just have to ask for "BREEAM Very Good" or "BREEAM Excellent"), the difficultly lies in all the existing blocks, and, importantly, influencing the person who has their hand on the temperature control.

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    # posted by Gareth Kane : 08:02  2 Comments

    Wednesday, 20 June 2007

    Eco-Labelling: What Does It Mean?

    Yesterday I was looking for the carbon footprint of shampoo for a client project and found that Boots were now using the Carbon Trust's new(ish) carbon label (right). One bottle of shampoo is apparently responsible for 148g of carbon dioxide. The other product that has been labelled in this way is Walkers Cheese & Onion Crisps - 75g a packet. While this is very useful for those of us who need this sort of information to calculate carbon footprints, it left me wondering what it will mean to the shopper in the aisle of their local hypermarket. Is 75g a packet high or low? Is 148g a bottle good or bad?

    The main advantage seems to be pressure on the manufacturers. Walkers claim that they have reduced their footprint by a third before the label was published.

    The EU Ecolabel (left) does show the average punter whether or not a particular product (ranging from mattresses to campsites) actually meets best environmental practice. But have you ever actually seen one on a product? And would you choose, say, your new shoes based on this label?

    I also worry that the logo is a bit weak and fluffy - one of the basic principles of marketing a 'green' product to the mass market is to avoid anything that even hints at treehugging.

    The most effective label is undoubtedly the A-G rating on white goods. These have transformed the market: the market share of A-rated white goods sold has risen from 0% in 1996/97 to 74% in 2005/06. There has long been talk of extending this scheme to consumer electronics such as TVs and DVD players and a similar scheme has started for windows. The label is bold, clear and the consumer knows exactly what they are getting - and who would want a product with a big 'D' on it?

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    # posted by Gareth Kane : 08:19  0 Comments

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