Fead annual conference 2008
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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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FEAD ANNUAL CONFERENCE 2008

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Fead annual conference 2008

FEAD ANNUAL CONFERENCE 2008

Future Challenges for the Waste Management Industry

Paris, 19 September 2008


Fead annual conference 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


Overview

1

Overview

  • Consultation process and stakeholder involvement

  • Re-cast procedure

  • Scope of the proposed directive

  • Sevilla process - integrated approach

  • Making BREFs binding and planning reliability for investments

  • ELVs vs. BATAELs

  • Integration of the Waste Incineration Directive (WID)

  • Comitology

  • Provisions on site-closure and remediation

  • Access to information

  • Cutting “red-tape”


Consultation process and stakeholder involvement

2

Consultation process and stakeholder involvement

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


Re cast procedure

3

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

COM(2007)844:

amending only essential elements (grey part)

FEAD:

in some cases substantial changes were made but not identified as such

(i.e. biomass definition)


Scope of the proposed directive

4

Scope of the proposed directive

In principle,

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)


Sevilla process and integrated approach

5

Sevilla process and integrated approach

Dir 96/61/EC (IPPC):

COM(2007)844 final:

EC

Member States

Industries

NGOs

?

EC

Member States

Industries

NGOs

Sevilla process and the integrated approach

need to be maintained

BATs and BREFs

descriptive

BATs and BREFs

binding

PERMITS


Making brefs binding and planning reliability for investments

6

FEAD

permit conditions should be reconsidered only if major changes take place and NOT each time a BREF is revised

- problematic for the planning reliability

COM(2007)844:

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 rules

Making BREFs binding andplanning reliability for investments

stability and certainty in the permits


Fead annual conference 2008

Max ELV

(emission limit value given in the annex of the WID directive)

ELV reduction due to BATAEL (may be 0)

ELV derived from BATAEL

Safety margin

Fluctuation margin

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


Integration of the waste incineration directive wid

8

Integration of the Waste Incineration Directive (WID)

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

FEAD

the implementation of the Waste Incineration Directive (WID) is a success

WID should be integrated into the IED without substantial modifications


Comitology

9

Comitology

Concerns:

COM(2007)844:

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


Provisions on site closure and remediation

10

Provisions on site-closure and remediation

COM(2007)844:

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


Access to information

11

Access to information

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


Cutting red tape

12

Cutting “red-tape”

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


Fead annual conference 2008

Thank you very much

for your attention!


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