Review of the Integrated Pollution Prevention
and Control (IPPC)
and National Emission Ceilings (NEC)
Directives
Marianne Wenning
DG ENV, Head of Unit, Industrial Emissions and Protection of the Ozone Layer
in collaboration with DG ENV Unit on Energy&Environment
EPRG, 23 April 2007
1
Thematic Strategy on Air Pollution
(SO2, NOx, particulate matter, VOC, NH3)
Objectives: improvement by 2020 relative to 2000
Life Years lost from particulate matter
47%
Premature mortality from ozone
10%
Ecosystem forest area exceeded by acidification
74%
Ecosystem freshwater area exceeded by
acidification
39%
Ecosystem area where critical load is exceeded by
eutrophication
43%
Forest area exceeded by ozone
15%
2
Thematic Strategy on Air Pollution
Air quality, health and nature protection objectives
National Emission
Ceilings
Stationary
Sources
-IPPC
- LCP, VOC
etc.
Mobile Sources
- Euro 5 and 6
- Euro VI etc.
Gothenburg
Protocol of the
Convention on
Long Range
Transboundary
Air Pollution
Other sources
and legislation
3
Further measures needed to meet the objectives
of the Thematic Strategy on Air Pollution
Total emission reductions in 2020 beyond the NEC (2010) ceilings through
current legislation and additional measures
0%
10%
20%
30%
40%
50%
60%
70%
80%
SO2
NOx
PM2.5*)
VOC
NH3
Full implementation of
current legislation
Industry and power
generation
Transport
Other
4
First analysis of benefits and costs
of the revised NEC in 2020
Health benefits 5-17
times higher than
costs
Additional benefits
of reduced
eutrophication,
acidification etc.
The impacts of
energy and climate
package not
included. Likely to
reduce costs and
increase benefits.
120
100
80
60
40
20
0
Costs
Health benefits
Source: Working Group on National Emission Ceilings and Policy
Instruments 29-30 March 2007
5
Industrial Emissions
Integrated Pollution
Prevention and Control
(IPPC) Directive
Waste
Incineration
Directive (WI)
Solvents
Directive (SE)
Large Combustion
Plants Directive (LCP)
Titanium Dioxide
Directive (TiO2)
European Pollutant Emission Register (EPER)
European Pollutant Release and Transfer Register (E-PRTR)
6
IPPC: important tool to achieve
air pollution targets


Contribution of industrial activities (mainly IPPC)
to total EU emissions in 2005: 55% CO2, 88%
SO2, 36% NOx, 50% particulate matter, 55%
VOC
Compared to implementation of current legislation
in 2020, need for further industrial emission
reductions to meet Thematic Strategy 2020
targets :
-
30%
35%
24%
17%
for
for
for
for
SO2
NOx
PM2.5
VOC
7
Shortcomings in implementation
and enforcement
Problems:



Complexities in current legal framework
Insufficient reduction of emissions due to lack of progress
towards BAT
Lack of transparency on the application of the criteria
related to flexibility (technical characteristics, geographical
location and local environmental conditions)
Effects:



Incorrect implementation (e.g. sectoral Directives used as
default) or difficulties in interpretation (e.g. scope,
definitions)
Lower level of environmental protection
Possible distortion of competition
8
Shortcomings in implementation,
some examples from case studies
Case study of 30 installations: only half had all permit
conditions clearly based on BAT as determined in the BREFs
Sector
BAT Associated
Emissions Levels
(BREFs)
Permit conditions: Emission Limit Values
(ELVs)
Cement
NOx
200-500 mg/m3
3 out of 4 installations : 800 mg/m3 (Waste
Incineration Directive)
No apparent consideration of BAT
Non ferrous
metals plant 1
SO2
50-200 mg/m3
ELV: 800 mg/m3
Not possible to identify rationale behind
difference
Non ferrous
metals plants
2 and 3
Dioxins
<0.1-0.5 ng/m3
No ELV
No monitoring data available
Pulp mill
Various pollutants
to water
No permit conditions for releases to water
Chemicals
plant
Benzene
5 mg/m3
ELV: 2500 mg/m3 (500x than BREF)
9
Estimated Potential Emissions Reduction
from BAT Introduction in the LCP sector
NOx in all countries - 354 facilities
SO2 in all countries - 354 facilities
900 000 000
2 000 000 000
Gap filled
Gap filled
1 800 000 000
800 000 000
EPER Reported
700 000 000
Calculated BAT,
less strict
1 600 000 000
Calculated BAT,
less strict
Calculated BAT,
strict
1 400 000 000
Calculated BAT,
strict
600 000 000
EPER Reported
1 200 000 000
500 000 000
1 000 000 000
400 000 000
800 000 000
300 000 000
600 000 000
200 000 000
400 000 000
100 000 000
200 000 000
-
-
Coal
Oil
Gas
Coal
Oil
Gas
10
Source: EEA Topic Center on Climate Change and Air, 2001 EPER data
Impacts of progress towards BAT
Impacts of progress towards BAT: environmental
benefits expected to exceed compliance costs
Example for large coal power stations:


NOx abatement annual costs €150-450m for 60200kt emission reduction
Health benefits of €210-1700m
11
Main options to address current
shortcomings
BAT-based permitting and role of the BREFs


Role of the BREFs: more prominent or binding
Possible deviation from BAT/BREFs: more
transparent according to criteria set in the Directive
(technical characteristics of installation concerned,
geographical location, local environmental conditions)
12
Main options to address current
shortcomings
Streamlining and reduction of
administrative burdens
EU level:

New Framework Directive integrating IPPC and sectoral
Directives => increase legal coherence, transparency and
clarity

Streamline MS reporting => save administrative costs
~€1-10 million/year
MS level:

Most actions at MS level to reduce administrative burden
(eg combined permitting, monitoring and reporting from
operators) => save administrative costs ~€10-60 million/year
13
Use of NOx and SO2 emission trading (ET)





IPPC and NEC are barriers/obstacles to NOx and SO2 ET within and
between MS
ET can be a cost-effective and predictable instrument for MS to reduce
emissions and achieve environmental objectives
IPPC and NEC revisions could foresee the possibility for MS to opt for NOx
and SO2 ET
If MS wish to use ET, they would need to follow specific future EU-wide
rules (e.g. emissions cap, trading rules, geographical scope, local
environmental protection) to ensure environmentally sound, compatible
and enforceable schemes
Such EU-wide rules would be subject to a specific Proposal (not part of
IPPC/NEC packages)
14
Key questions to the EPRG
1. NOx and SO2 emission trading
Valuable additional cost-effective instrument to reach 2020 ceilings
subject to EU-wide rules to ensure environmentally sound,
compatible and enforceable schemes?
2. BAT implementation
Support for more consistent permitting by placing the BREFs as the
foremost point of reference or giving them a binding nature to make
greater progress towards BAT and a more level playing field?
3. Streamlining interactions IPPC & other legislation
Support a single Directive on industrial emissions?
15