Impact of the IPPC and BAT on the work and competitiveness of industry Hans-Roland Lindgren Swedish EPA

My presentation will be based on: Experiences from integrated permitting based on BAT in Sweden since 1969 Experiences from other countries I have worked in EU-evaluations, reports and seminars

Conclusions from workshop in Brussels,16 May 2002, organised by DG Enterprise There is no magic one size-fits-all formaula to assess the impact of BATon the economic viabilty of industry Several factors as market structure, industry structure, resilience, BAT costs of total costs and speed of implementation are important Timing and investment cycles are key factors Read more on:

European industry view on IPPC The integrated appoch is the rigth one Effective allocation of abatement/prevention investments Collaboration between IEF members outstanding positive experience BREF is a technical practical reference Authorities must base decision on ELV taking into accout local environmental situation and site-specific factors Trade-off judgements must be made locally As presented by Union of Industrial and Employers´ Confedaration of Europe

Conclusions from study funded EU`s, Joint research centre BAT plants are plants with high environmental standards, high productivity and low energy use BAT plants are profitable and have no problems to implement IPPC Companies at risk from IPPC have much lower productivity and efficiency than the average Environmental improvements arise primarily from the ”front end” of the process, followed by development of the process itself The Impact of Best Available Techniques on the Competitivenss of Euroopean Industry

Swedish experiences Only one company, I know of, has since 1969 blamed the environmental requirements for the closure of the plant For the sectors with highest environmental costs the environmental investments is below 20% of the total investment The effect on the product price of the environmental investments is lower than 1% True environmetal investments cost should include also benefits normally not included in company calculations Industries normally over-estimate the environmental investment costs in their permit applications. The real environmental investments Have shown to be 40% lower then suggested by industries in their applications

What are the benefits for industry to use BAT compared with traditional end-off-pipe standards? Timing of investments could be linked to the business cycle Energy efficient processes could be used Raw material savings and less use of chemicals Less waste for disposal Savings in water costs Better product quality Savings on maintenance and operational costs

Examples 1 on benefits from the use of BAT (Swedish smelter) Plant for production of liquid SO 2 was built to reduce SO 2 emissions. Investment 70 million SEK. Pay-back time 3,5 year. Reduced SO 2 emission roughly t/y Investment (20 million SEK) in a new SO 2 gas collection system to obtain more concentrated gases to the H 2 SO 4- plant to increase S recovery from off-gases. Result: the company could stopp buying elemental S for 6 million/y and SO 2 -emissions was reduced by about 10000t/y Both investments were considered as environmental investments because only investments with a pay-back time of less then 3 years were considered as productive investments

Example 2 Algerian chlor-alkali plant Exchange of production process from the Hg- process to membrane process Investment cost over $100 Environmental benefits: no air and water emission of Hg - no Hg containing waste Benefits for the company Energy savings 30% Product without Hg increased the market Savings on maintenance costs Reduced labour costs Estimated Pay-back time 4 years

Example 3 Estonian electroplating plant Constructed according to Soviet specifications for 400m3/day of wastewater Real water use before application of BAT principles 2 500m3/month After BAT investments EEK the water consumption was reduced to 800m3/month Savings on the water bill EEK per /y