FEAD ANNUAL CONFERENCE 2008. Future Challenges for the Waste Management Industry Paris, 19 September 2008. The proposal for a Directive on Industrial Emissions (IED) and its impact on the European waste management business. Carlo Noto La Diega, FISE President, FEAD Vice-President. 1.
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Future Challenges for the Waste Management Industry
Paris, 19 September 2008
Carlo Noto La Diega, FISE President, FEAD Vice-President
FEAD feels strongly that the consultation procedure on the IPPC review did not allow an adequate exchange
Deadline for implementation of the current IPPC Directive for existing installation was just 30 October 2007
FEAD would have preferred a proper assessment of the existing IPPC directive until 2010 instead of proposing IED in 2007
Dir 1999/13/EC: "VOC Solvents Directive"
COM(2007)844: “Ind. Emission Directive (IED)"
Dir 96/61/EC: "IPPC Directive"
Dir 78/176/EEC, Dir 82/883/EEC, Dir 92/112/EEC: “TiO2 Directives”
Dir 2001/80/EC: "LCP Directive"
Dir 2000/76/EC: "Waste Incineration Directive (WID)"Re-cast procedure
amending only essential elements (grey part)
in some cases substantial changes were made but not identified as such
(i.e. biomass definition)
FEAD advocates for the creation of a level-playing field for installations in EU but warns against the impacts of extending the scope to all waste management operations
Thresholds as indicated in Annex I, pt. 5 are acceptable
Extending it to all WM operations could become problematic for small and medium enterprises (the same level of compliance is required but in a more simplified way)
Dir 96/61/EC (IPPC):
Sevilla process and the integrated approach
need to be maintained
BATs and BREFs
BATs and BREFs
permit conditions should be reconsidered only if major changes take place and NOT each time a BREF is revised
- problematic for the planning reliability
reconsider permit conditions each time an applicable BREF is updated
- would neglect the role of investment cycles
- would affect several industry sectors at the same time (horiz. BREF)
- constant updating of general binding rulesMaking BREFs binding andplanning reliability for investments
stability and certainty in the permits
(emission limit value given in the annex of the WID directive)
ELV reduction due to BATAEL (may be 0)
ELV derived from BATAEL
(BAT Associated Emission level): average of the operational emission level
ELVs vs. BATAELs
A guide is required to explain how to derive ELVs from BATAELs
The existing WID provides legal certainty to allow investments in good quality infrastructure
No significant problems which could justify a comprehensive change to the WID
the implementation of the Waste Incineration Directive (WID) is a success
WID should be integrated into the IED without substantial modifications
foresees an extensive use of the Comitology procedure for implementing the future directive
Respect of the subsidiarity principle
Involvement of interest groups in the procedures needed, i.e. industry experts,
Right of the Compentent Authorities in the Member States to make the final decision
Possibly severe impact of the Comitology procedure on the Sevilla process
FEAD welcomes efforts to limit the use of the Comitology procedure
contains a number of provisions on site closure and remediation
FEAD considers these provisions can be excessive; a risk-based approach in line with the future use is more sensible
FEAD thinks that the proposed provisions on site closure and remediation should be tackled in a separate directive on soil as this has never been considered in the existing BREFs
FEAD welcomes the provisions on access to information for the public
Access to information must be guaranteed in line with the provisions of the Arhus Convention on access to information, public participation in decision-making and access to justice in environmental matters
FEAD is in favour of cutting red-tape
IED should not create an additional burden for the industry without generating environmental benefits and taking into consideration the investment cycles
for your attention!