Although ProRail developed the CO2 Performance Ladder, it did not take long before other contracting authorities in the Netherlands, such as the Ministry of Infrastructure and Water Management, also wanted to use it. This was possible, but under two important conditions. First, the CO2 Performance Ladder had to be brought in line with European procurement legislation. Second, the instrument should be managed by an independent foundation.
Independent scheme management: an art in itself
Why was setting up a foundation so important in the first place anyway? Vastbinder explains: “ProRail wanted to roll out the CO2 Performance Ladder more widely and make it available to the whole market, but if the Ladder remained ProRail’s tool, that became more difficult. It is not their core business to manage such a system and you can’t do that on the side. Scheme management is an art in itself. To guarantee the quality of the CO2 Performance Ladder, an independent organisation was needed that would focus entirely on managing and developing the instrument.
Therefore since March 2011 SKAO has been the owner and manager of the CO2 Performance Ladder. SKAO is an independent foundation without financial or political interests, but with an enormous drive to make a positive impact.
Third-party verification: the importance of accreditation
Shortly after SKAO was founded, the decision followed to have the CO2 Performance Ladder certification scheme accredited by the Dutch Accreditation Council (RvA). “How can you trust that a CO2 footprint or a claim of climate neutrality is correct? Is an in-house assessment sufficient? We don’t think so. Decarbonisation – the reduction of harmful emissions – is too important to just be able to make big claims, especially if the certification is accompanied by award advantage in tenders,” says Vastbinder. “What you want to avoid at all costs is that clients and contractors start doubting the quality of the data and the usefulness or functioning of the CO2 Performance Ladder.
“Third-party verification ensures that a certificate holder is assessed every year by an expert and independent organisation”
“By accrediting a certification scheme, you have secured the quality and process of assessment. Accrediting literally means: giving confidence.” In a nutshell: the CO2 Performance Ladder certification scheme is accredited by the RvA. Certificate holders are assessed each year by an independent auditor, employed by one of the 14 certifying bodies (Conformity Assessment Bodies). The National Accreditation Body (the RvA in the Netherlands and Belac in Belgium) in turn supervises those institutions. This creates a layering of checks and balances, thus guaranteeing the quality and independence of (and confidence in) the CO2 Performance Ladder.
Verifiable and traceable
But accreditation brings more benefits. “When you are accredited, you have a lot of things settled right away. I am talking about both the CO2 Performance Ladder scheme and the scheme manager SKAO,” says Termeer. “What it comes down to (in a general sense): you can have all kinds of great ideas to get the market moving, but for the CO2 Performance Ladder to work really well, every requirement must be testable and its control traceable.”
“To give an example: we can ask companies to communicate regularly about their CO2 reduction efforts, but what does ‘regularly’ mean?” adds Vastbinder. “Is that weekly? Annually? You have to specify that, otherwise it is not verifiable. Then you run the risk of companies being assessed differently by each auditor, while a level playing field is indispensable.” In other words, certification should be fully testable. Accreditation helps to ensure this in advance and to prevent encountering problems or ambiguities in practice.
Termeer: “Auditors have to be able to show why they approve something, that’s what it’s all about. That was sometimes quite difficult for us. After all, SKAO stands for things like ambition, sustainability, CO2 awareness. To translate those ideas into something that is fully verifiable and traceable, without losing its ‘soul’, is no easy task. That has been a very steep learning curve, but we succeeded together with all our partners.”
All stakeholders represented
Independent scheme management requires that all stakeholders are represented and have a say in the development of the Ladder. SKAO approaches this in different ways, both formally and informally. Firstly, the foundation has an independent board, responsible for SKAO’s strategy, organisation and finances. The Central College of Experts (CCvD), consisting of both contracting authorities and contractors, is also responsible for operational scheme management and the development of the Ladder and requirements in the CO2 Performance Ladder Handbook. The Technical Committee is made up of auditors from certifying bodies and advises the CCvD in turn on the interpretation of the Ladder and the method of certification. Last but not least: the Procurement Advisory Board, consisting of representatives of major contracting authorities, advises on procurement law.
In this way, all stakeholders are represented, such as certificate holders, contracting authorities and experts. This is important for several reasons, says Termeer: “You want the CO2 Performance Ladder to connect seamlessly with the certificate holders’ everyday realities. You can only achieve that with extensive involvement from the market. We can come up with all kinds of ideas, but what do they mean in day-to-day practice? In order to address that, it is indispensable that the market is closely involved in the development of the Ladder.”
In addition, that involvement helped enormously in creating support for the CO2 Performance Ladder, adds Vastbinder: “Stakeholders are allowed to give their opinions on the content of the Ladder and they are really listened to.”
“The instrument really came about in consultation. As a result, acceptance of the Ladder was very high right from the start and we were able to roll it out much faster”
After the accreditation process, SKAO was rock solid as an organisation. But of course there was no question of sitting back. After all, the foundation is also responsible for the growth and (substantive) development of the Ladder. And that’s no easy task, says Termeer: “We are constantly monitoring what could be improved, through all kinds of channels. Every year, for instance, we organise roughly thirty meetings with stakeholders to discuss possible improvements. And we investigate within our own organisation what possibilities there are. But external factors, such as policy developments, also play a role. Time and again, this produces a huge list of areas for improvement.”
“We test these – what are the ’must-haves’ and the ‘nice to haves’? – and submit them to our stakeholders,” Termeer continues. “That may sound like a challenge, but in the entire history of SKAO, almost all changes have been implemented with consensus from all stakeholders in the Central College of Experts. It only came to a vote once. We are quite proud of that.” SKAO then implements the chosen changes and, after a while, tests the waters again. “In this way, we hope to establish a watertight and future-proof system,” says Termeer. “The trick here is to stay just ahead of the crowd. After all, you want to stimulate companies to get moving. But your ambitions shouldn’t be too far ahead of the market, or people will just drop out.”
That recurring process of improvement has already produced several versions of the CO2 Performance Ladder Handbook over the years. Version 1 laid the important foundation of five levels and four perspectives (insight, reduction, transparency and participation). Version 2 marks the important step to a fully-fledged CO2 management system, in line with European procurement legislation. With Version 2.1 came the independent accreditation (by the RvA) under ISO 17021 (for management systems). Version 3 brought the Ladder further in line with international (ISO) standards and turned its focus on more ambitious emission reductions in supply chains (scope 3 emissions). Version 4 of the handbook is (expected) to be published in 2024, with the most important development being the mandatory focus on organisations’ carbon neutrality, in line with the Paris Climate Agreement.
The power of scheme management
Another important task for SKAO is sharing knowledge about the CO2 Performance Ladder with the market on a constant basis. For example, by means of events, webinars, research and best practices. “Precisely because we have built a track record of professionalism, the market demands and expects a lot from us,” explains Vastbinder. “That’s a big positive. I am incredibly proud of what we have achieved within a relatively short time. Very few people find scheme management interesting, but if you get it, you can achieve an awful lot with it,” she concludes. “You can make an important contribution to that as a scheme manager.”
“The CO2 reduction measures that companies take, the collaborations and initiatives that emerge in the supply chain”