A key element of the plan is the proposal to apply "best available techniques" (BAT) described in EU guidance more rigidly. It would still be permissible for member state regulatory authorities to deviate from BAT when determining permits but they would have to justify their decisions and make them public. The European Commission argues that this proposal is based upon the current disparities in national BAT application.
Another of the proposals objectives is to merge IPPC with six other laws on large combustion plants (LCPs), waste incineration and co-incineration, solvents and titanium dioxide emissions.
To achieve objectives in the CAFE (Clean Air for Europe) thematic strategy on air pollution the proposal sets stricter emission limits for LCPs and installations producing titanium dioxide, other changes to the six laws mainly consist of clarifications and simplifications.
The ‘option’ for member states to develop trading schemes for sulphur dioxide and nitrogen oxide emissions between installations was removed from the proposals text. Industry and non-governmental organisations both campaigned against this proposal. However, despite this initial victory, the commission says the idea is not yet off the table.
The proposal also extends to scope of IPPC to include other industry sectors (e.g. combustion plants between 20 and 50 megawatts). It also recommends minimum EU standards for plant inspections and permit reviews. In addition, reporting and monitoring requirements for plant operators would be streamlined to reduce unnecessary costs.
EEF is a strong supporter of IPPC and its basic principles (namely an integrated approach to pollution, continuous environmental improvement based on best available techniques, and a pragmatic and practical approach to determine permit conditions).
We believe the inherent strength of IPPC lies in its consideration of the cross-media effects of a given technique, rather than focussing narrowly on ‘end of pipe’ sources of pollution. This integrated approach delivers good environmental outcomes cost-efficiently and, if properly administered, can potentially take into account all dimensions of sustainability.
It is for these reasons that we believe IPPC to be the best tool to regulate industry and will, therefore, continue to campaign, both at national and European level, on the fair and equitable application of this directive.