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Development of guidance for each activity covered by the VOC Solvents Emissions Directive (1999/13/EC) N.B. This presentation reflects the initial proposal by the contractors and should not be taken as the view of the Commission. The project team has still to meet with the Commission for a formal Inception meeting to finalize the project requirements, methodology, and precise deliverables. The project will support the Commission’s ongoing efforts to introduce improved reporting mechanisms in the current revision of the Monitoring Mechanism[1] (MM), that are compatible with reporting requirements of other air and climate change instruments. These mechanisms, if replicated elsewhere would harmonize reporting procedures and guidance time frames etc., addressing known weaknesses, improving data quality and minimizing burdens on Member States. [1] Decision 280/2004 and its implementing provisions 2005/166 There are a number of instruments under review (including the MM, NECD, EU ETS, IPPC [E-PRTR]) that have emission reporting requirements there is the danger of incompatibility in: definitions or terminology temporal and spatial scales reporting methodologies for related pollutants/gases[1] reporting deadlines etc. [1] The UNFCCC and EU MM mention “gases”, LRTAP and NECD “pollutants”. There is a window of opportunity to propose common data reporting provisions in revised directives. It should be possible to establish a structure for reporting emissions data that not only reduces the burden of reporting to all stakeholders but also maximizes the user value of data Institute for Environmental Strategies ENV.C.4/FRA/2007/0011
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Project team Mike Woodfield, Neil Passant Contact: Institute for Environmental Strategies Christian Tebert, Dirk Jepsen Contact: Dr. Reinhard Joas, Sonja Bauer Contact:
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Time schedule Project start: 21 December 2007
Draft final report: 21 September 2008 Project end: 21 December 2008
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Target group of the guidance
Authorities Permitting and enforcement authorities (national, regional, local) Focus on => identification of best available techniques and => emerging techniques, => VOC substitutes Operators Especially small and medium sized companies Special focus on => activities not covered by BREFs and => identification of new substitutes under development
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Limitations of the guidance
Individual implementation of the Directive in Member States NOTE will be included: national legislation has to be considered Legal aspects No legal advice for implementation Restricted to practical examples for VOC reduction Competition aspects No naming of individual companies/providers 5
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Structure of each guidance (draft)
Activity description, VOC thresholds, VOC limit values Use of solvents in the activity Solvent consumption and emission levels Key environmental and health issues Sector specific information regarding compliance with VOC directive Possible substitutes, process improvements with key parameters influencing the substitution Practical examples Emerging techniques and substitutes under development Literature, links, references 6
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Main information sources (1)
BREFs and TWG information BREF documents (STS, Leather) Background information by Technical Working Groups EUROPA website on VOC substitution Documents Web links Information of AEA, BiPRO, ÖKOPOL Experts’ experience Publications, best practice documentation Web based information Sector reports Case studies
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Main information sources (2): stakeholders
Associations, institutions (technical groups, research) Existing guidance, case studies Contacts to sector experts Contacts to companies applying best available techniques Operators Practical examples Consumption and emission levels Suppliers (machinery, auxiliary equipment, chemicals) Best performing techniques Low-VOC or non-VOC products References Emerging techniques 8
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First results of data collection
BREF documents best source of information sometimes difficult to summarize (information in different chapters) EUROPA website Several documents are not very recent, few practical advices Web links are very useful Web information Documents are often only available in national language => translation may be possible if most important parts are indicated Stakeholders Few specific guidance for VOC reduction measures available Very open for co-operation, willing to deliver information Difficult access to case studies (protection of client names) 9
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Assessments for first guidance documents
Heatset web offset printing Comprehensive information is gathered for the guidance Leather coating VOC is not a major issue in the sector (mainly water based products) => Little data on total emissions provided (and TAN BREF is poor) Wood impregnation Surface cleaning Many types of application in very different sectors => guidance has to be general/can not be specific for sub-sectors BREF information is not differentiated enough Risk phrase related emission data is difficult to collect 10
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Contribution of Member States
Ministries, Environmental Agencies, Inspectorates Provision of existing information / guidance => technical information: VOC reduction with certain products, techniques, good housekeeping, limitations of implementation => performance data (VOC emission data: fugitive, controlled) Provision of case studies (VOC reduction, performance data) Contacts to sector experts Contacts to outstanding best practice examples Sectors with little information available so far Leather coating Footwear manufacturing Wood and plastic lamination Lamination associated to a printing activity Manufacturing of pharmaceuticals Vegetable oil and animal fat extraction 11
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Deadlines for delivery of information (1)
# Annex II A Activity name in Annex II A of the Directive Guidance title Deadline for info delivery 1 Heatset web offset printing Printing: heatset offset 30 April 2008 4 Surface cleaning 5 Other surface cleaning 12 Wood impregnation 13 Coating of leather 6 Vehicle coating and vehicle refinishing Coating of vehicles (serial) 6 June 2008 Coating of vehicles (non-serial) 10 Coating of wooden surfaces Coating of wood/furniture 11 Dry cleaning Dry textile cleaning 14 Footwear manufacture 16 Adhesive coating 17 Manufacture of coating preparations, varnishes, inks and adhesives 20 Manufacturing of pharmaceutical products Manufacture of pharmaceuticals 12
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Deadlines for delivery of information (2)
# Activity name in Annex II A of the Directive Guidance title Deadline 2 Publication rotogravure Printing: publication rotogravure 5 Sept. 2008 3 Other rotogravure, flexography, rotary screen printing, laminating or varnishing units rotary screen printing on textile/cardboard Printing: packaging rotogravure Printing: flexography Printing: rotary screen printing laminating or rotary screen printing on textile/cardboard Laminating or varnishing units 7 Coil coating Coating of coils 9 Winding wire coating Coating of winding wire 8 Other coating, including metal, plastic, textile, fabric, film and paper coating Coating of metal pieces Coating of plastic pieces Coating of textile, fabric, film and paper 15 Wood and plastic lamination 19 Vegetable oil and animal fat extraction and vegetable oil refining activities 18 Rubber conversion # Annex II A Activity name in Annex II A of the Directive Guidance title Deadline for comments 1 Heatset web offset printing Printing: heatset offset 30 April 2008 4 Surface cleaning 5 Other surface cleaning 12 Wood impregnation 13 Coating of leather 6 Vehicle coating and vehicle refinishing Coating of vehicles (serial) 6 June 2008 Coating of vehicles (non-serial) 10 Coating of wooden surfaces Coating of wood/furniture 11 Dry cleaning Dry textile cleaning 14 Footwear manufacture 16 Adhesive coating 17 Manufacture of coating preparations, varnishes, inks and adhesives 20 Manufacturing of pharmaceutical products Manufacture of pharmaceuticals 13
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Next steps Time schedule
Draft final report available end September 2008 Will be presented during VOC Committee Meeting in October Will be sent for comments to all stakeholders involved Publication of the guidance is scheduled for end of 2008 Any of your contribution is welcome Please do not hesitate to contact Sonja Bauer/BiPRO: Christian Tebert/ÖKOPOL: Thank you for your co-operation! 14
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