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BATNEEC

BATNEEC. 1990 EPA IPC Application Environment Agency (HMIP) and SEPA Consent to Discharge B est A vailable T echniques N ot E ntailing E xcessive C ost. BATNEEC. BAT (not just technology) NEEC Excessive OED “too much; too great more than is normally necessary”.

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BATNEEC

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  1. BATNEEC • 1990 EPA • IPC Application • Environment Agency (HMIP) and SEPA • Consent to Discharge • Best Available Techniques Not Entailing Excessive Cost

  2. BATNEEC • BAT (not just technology) • NEEC • Excessive • OED “too much; too great more than is normally necessary”

  3. Implementation Requirements • Need to identify explain “excessive” • Need to compare costs and benefits of environmental improvements • Require a consistent metric • Robust methodology

  4. NEEC in theory • At what point do costs become excessive? • Where the costs of additional expenditure are greater that the benefits? • Diminishing returns for expenditure.

  5. Cost Per Unit Reduction • Cost Per Unit Reduction (CPR) Total reduction in Loading = CPR Cost of making reduction Reduction in total loading to meet obligations Cost of most efficient approach to meeting obligations = CPR bench • Equitable and Transparent • Limited use for localized effects.

  6. IPPC • EC Directive 96/61/EC “IPPC Directive” “different approaches to controlling emissions into the air, water or soil separately may encourage the shifting of pollution between the various environmental media rather than protecting the environment as a whole”

  7. IPPC in the UK • 1999 Pollution Prevention and Control Act • 31 August 2000 • most polluting industries • consent to discharge • Best Available Techniques (BAT) • No NEEC!

  8. Determining BAT • Best • most effective techniques • Available • economically and technically viable • Techniques • technology, design, installation, operation, decommissioning.

  9. Determining BAT • Environmental Assessment • direct and indirect impacts • qualitative • Economic Analysis • Best is usually BAT • onus on operator to argue otherwise

  10. BAT in practice • European Commissions • exchange of information • BREF notes • UK Position • guidance notes • Obtaining a Consent to discharge • consent, ammend, reject

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