Industry proposals for improvement of BAT information exchange
The members of the Industrial Emissions Alliance welcome the initiative of the EU Commission, the German Ministry for the Environment and the German Environmental Agency to discuss the BAT information exchange at the workshop in Berlin on 16 and 17 October 2014. This endeavour is well in line with previous contributions of the Industrial Emissions Alliance to further optimise the BREF revision process and the BREF quality.
The Industrial Emissions Alliance represents 17 industrial sectors that are covered by the Industrial Emissions Directive (IED) and for which more than 25 BREFs have been developed under the IPPC Directive framework. Under the IED framework, the members of the Industrial Emissions Alliance have been involved in the revision of about a dozen BREFs and have been actively contributing to the finalisation of seven BREFs. The members of the Industrial Emissions Alliance remain fully committed to providing the necessary extensive input during further development of BREFs under IED.
The suggestions in this document are based on broad experience across multiple industry sectors during BREF revision. The Industrial Emissions Alliance trusts that this document will be helpful to further improve the BAT information exchange. It remains to be seen how BAT Conclusions developed under IED will be transferred into individual permits and the Industrial Emissions Alliance would also welcome an exchange of thoughts on this topic in the future.
The following text is structured in accordance with the topics of the working groups on the second day of the workshop. Thus, the suggestions first elaborate on the BAT information exchange (“the process”) before providing a view on BREFs and BAT conclusions (“the product”).