1. Consultant: CMDC Joint Venture Application of BAT in IPPC/EIA Experience in EU Member States Per Ponsaing COWI

2. Consultant: CMDC Joint Venture EIA and BAT applications EIA applicationIPPC application BAT assessment Are the roles of BAT different in EIA and BAT?

3. 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.

4. 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.

5. 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.

6. Consultant: CMDC Joint Venture Simplifying the permitting system in Denmark 1974 - 1991 Integrated permits Single media permits or by order 1991 - 2004 Single media permits or by order Integrated permits Branch regulations Simplified integrated permits Single media permits or by order 2004 - Branch regulations

7. Consultant: CMDC Joint Venture Integrated IPPC and EIA procedure

8. 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”

9. Consultant: CMDC Joint Venture Cement plants investigated in Europe CountriesBATMiddlePoorAll plants Germany2518 Italy617 Spain145 UK145 Poland134 Total313 29

10. Consultant: CMDC Joint Venture Cement: 3 most important competitive disadvantages ImportanceGermanyItalySpainUKPoland FirstLabour costs Environ- mental costs Labour quality LocationAge of plant SecondEnviron- mental regulation Age of plant LocationAge of plant Size of plant ThridEnviron- mental costs Labour costs Quality of raw material Size of plant Manufac- turing costs

11. 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.

12. Consultant: CMDC Joint Venture Non- ferrous metal plants investigated in Europe Metal producedNo of plants in EUNo of plants visited Primary copper44 Secondary copper65 Secondary aluminium5017 Secondary lead3011 Salt slag107 Waelz oxide74

13. Consultant: CMDC Joint Venture Secondary aluminium – strength of BAT vs. yield

14. 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.

15. Consultant: CMDC Joint Venture Pulp & paper plants investigated Location →EUCanadaBrazil Environmental performance ↓ PulpPaperWLCPulp A mills53511 B mills52532 C mills13 Total no of mills1151073

16. Consultant: CMDC Joint Venture Pulp & paper economy vs. environment Perfor- mance → Economic: Good Environmental: Good Economic: Poor Environmental: Good Economic: Good Environmental: Poor Economic: Poor Environmental: Poor Kraft pulp 6025510 White Line Chipboard 30104515 Copy paper 453510

17. 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

18. 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

19. 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

20. Consultant: CMDC Joint Venture Example: Organic chemicals production “Horizontal” BREFs: BREF Emissions from storage of bulk or dangerous materials (2 nd draft) BREF Common waste water and waste gas treatment and management systems in the chemical sector (final BREF) Energy efficiency (no BREF yet)

21. 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 (2 nd draft)