Criteria for identifying key environmental issues for the review of BREFs
At the 19 October 2015 meeting of the IED Article 13 forum, the Commission presented its discussion paper on "Criteria for identifying key environmental issues for the review of BAT reference documents under Article 13 of the IED", with the aim of triggering a discussion on improving the environmental effectiveness of the exchange of information by targeting efforts on the key environmental issues (KEI).
During the subsequent discussion, the importance of a more focused approach and of frontloading of the work on the BREF reviews were strongly supported.
In view of the upcoming BREF reviews and related frontloading exercises, the undersigned sectors have developed their position on the content of the discussion paper and on the criteria for identifying KEI.
We generally welcome the discussion paper presented by the Commission and agree with the fact that the KEI, although not explicitly defined so far, refer to those issues for which the application of BAT conclusions have the highest likelihood of resulting in noteworthy additional environmental benefits.
We support the "focused approach" that can be achieved by building on the existing BREFs and updating only those parts required for deriving BAT conclusions, while targeting a manageable (i.e. limited) number of KEI through sound data collection and processing.