Application of BAT in IPPC/EIA
Experience in EU Member States
Per Ponsaing
COWI
Consultant: CMDC Joint Venture
EIA and BAT applications
EIA application
IPPC application
BAT assessment
BAT assessment
Are the roles of BAT different in EIA and BAT?
Consultant: CMDC Joint Venture
What is BAT?
BAT = Best Available Techniques
Available: Developed to allow implementation in the relevant
industrial sector under economically and
technically viable conditions, taking into account
the costs and advantages, whether or not the
techniques are used or produced inside the
Member State in question, as long as they are
reasonably accessible to the operator;
Techniques: Technology used + the way the installation is
designed, built, maintained, operated and
decommissioned.
Consultant: CMDC Joint Venture
The BAT hierarchy
1. Process design/redesign to eliminate or reduce emissions
to air, water, land, reduce formation of waste and energy
consumption;
2. Substitution of fuel, chemicals, raw materials etc. by
environmentally less harmful ones;
3. Minimisation and reduction by means of process control,
maintenance, end-of-pipe technologies etc.
Consultant: CMDC Joint Venture
Views on what BAT limits for a sector should
represent
• The highest emission levels allowed for any plant in the
sector new or existing;
• The highest emission levels allowed for new plants;
• The emission levels achieved by the best handful of plants
in the world;
• The emission levels achieved by the very best performing
plant in the world.
Consultant: CMDC Joint Venture
Simplifying the permitting
system in Denmark
1974 - 1991
1991 - 2004
2004 Integrated permits
Integrated permits
Simplified
integrated permits
Integrated permits
Branch regulations
Single media
permits or by
order
Consultant: CMDC Joint Venture
Single media
permits or by
order
Branch regulations
Single media
permits or by
order
Integrated IPPC and EIA procedure
Activity/Month
1
2 3 4 5 6 7 8 9 10 11 12 13 14
Screening for EIA
Call-in of ideas and alternatives
IPPC application and EIA report + public announcement of the application
IPPC permit and addendum to physical plan
Hearing of stakeholders including the applicant
Revision of permit and plan
Public hearing
Revision of permit and plan
Political decisions
Complaining period
Consultant: CMDC Joint Venture
Economy of BAT in EU
Are BAT plants viable? Do they suffer disadvantages in the
face of international competition?
How will the adoption of BAT impact on the medium to long
term survival of plants which have not already adopted BAT?
What does the analysis imply for “sectoral viability”
Consultant: CMDC Joint Venture
Cement plants investigated in Europe
Countries
BAT
Middle
Poor
Germany
2
5
1
All
plants
8
Italy
6
1
7
Spain
1
4
5
4
5
1
3
4
13
13
29
UK
1
Poland
Total
3
Consultant: CMDC Joint Venture
Cement: 3 most important competitive disadvantages
Importance Germany
Italy
Spain
UK
Poland
First
Labour
costs
Environmental
costs
Labour
quality
Location
Age of
plant
Second
Environmental
regulation
Age of
plant
Location
Age of
plant
Size of
plant
Thrid
Environmental
costs
Labour
costs
Quality of
raw
material
Size of
plant
Manufacturing
costs
Consultant: CMDC Joint Venture
However...
Nevertheless plant investment is higher in Germany (per tonne
average) than at counterpart plants in other EU countries
sampled. German plants still find it worth investing.
Profitability at German plants owned by 3 major cement
companies was reported to be similar to plants owned by the
same company in other EU countries despite low capacity
utilisation and strong environmental regulation in Germany.
Consultant: CMDC Joint Venture
Non- ferrous metal plants investigated in Europe
Metal produced
No of plants in EU
No of plants visited
Primary copper
4
4
Secondary copper
6
5
Secondary aluminium 50
17
Secondary lead
30
11
Salt slag
10
7
Waelz oxide
7
4
Consultant: CMDC Joint Venture
Secondary aluminium – strength of BAT vs. yield
Consultant: CMDC Joint Venture
Profitability in the non-ferrous metal industry
• It is argued that labour productivity, metal yield and energy
reduction are all closely related to improvements in
profitability;
• Capital costs as measured by technical age are achieved
at low expense provided that improvements are undertaken
progressively;
• IPPC drives to improve efficiency e.g. in terms of use of raw
materials and energy, hence is consistent with improved
profitability.
Consultant: CMDC Joint Venture
Pulp & paper plants investigated
Location →
EU
Canada
Brazil
Environmental
performance ↓
Pulp
Paper
WLC
Pulp
Pulp
A mills
5
3
5
1
1
B mills
5
2
5
3
2
C mills
1
Total no of mills
11
Consultant: CMDC Joint Venture
3
5
10
7
3
Pulp & paper economy vs. environment
Performance
→
Economic:
Good
Environmental:
Good
Economic:
Poor
Environmental:
Good
Economic:
Good
Environmental:
Poor
Economic:
Poor
Environmental:
Poor
Kraft
pulp
60
25
5
10
White
30
Line
Chipboard
10
45
15
Copy
paper
35
10
10
45
Consultant: CMDC Joint Venture
General conclusions
• No evidence that BAT companies were hindered from
remaining competitive both nationally and internationally
• It is important to prioritise environmental initiatives and
time these initiatives carefully. Special consideration is
recommended for those initiatives expected to yield a
positive economic return
Consultant: CMDC Joint Venture
How to determine BAT when there is no BAT
documentation?
Most often the relevant sector will be covered by BREFs or
other BAT documents.
Example: A producer of chemicals falling between
• Large Volume Organic Chemicals (final BREF)
• Organic Fine Chemicals (no BREF yet)
• Polymers (if this is the kind of product – no BREF yet)
We suggest to start with LVOC BREF and supplement with
other BAT information
Consultant: CMDC Joint Venture
Example: Organic chemicals production
Other BAT information to consult:
• UK guidance for the large volume organic chemicals sector
(however not very different from BREF LVOC)
• UK guidance for specialty organic chemicals
• US EPA: Profile of the plastic resins and man-made fibres
industry (if this is the kind of product)
• HELCOM recommendation 23/11: Requirements for
discharging of waste water from the chemical industry
Consultant: CMDC Joint Venture
Example: Organic chemicals production
“Horizontal” BREFs:
• BREF Emissions from storage of bulk or dangerous
materials (2nd draft)
• BREF Common waste water and waste gas treatment and
management systems in the chemical sector (final BREF)
• Energy efficiency (no BREF yet)
Consultant: CMDC Joint Venture
Example: Organic chemicals production
General principles:
• UK EPA: General Sector Guidance (to be used where there
is no IPPC sector-specific guidance)
• BREF Economic and cross media issues under IPPC (2nd
draft)
Consultant: CMDC Joint Venture