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Clean Air Regulation for Stationary Sources: Best Available Techniques as Innovation in Countries with Emerging Economies BAQ, 7 December 2004, Agra, India Pia Denzin Environmental Lawyer (GTZ). What is BAT How to implement the BAT approach

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Clean Air Regulation for Stationary Sources: Best Available Techniques as Innovation in Countries with Emerging EconomiesBAQ, 7 December 2004, Agra, IndiaPia Denzin Environmental Lawyer (GTZ)

What is BAT

How to implement the BAT approach

Enforcement and other requirements in Clean Air Legislation

Benefits of BAT

what is bat
Different approaches for air pollution control:

General limit values: Limit values are quite general and not very strict

Ambient air: Emission of air pollutants from industrial facilities is allowed as long as ambient air quality is satisfactory

BAT:Industrial facility is required to limit emissions according to sector specific limit values achievable with technical measures and good housekeeping

Best solution: Combination of all!

What is BAT
what is bat1
Best Available Technique

Approach to control emissions from stationary sources

of European Origin

Integrated approach by regarding emissions in all sectors (air, water, soil) and energy consumption

No prescription of certain technology

Instead reflected in stricter sector specific emission standards for industries

What is BAT
bat implementation
Choose the more relevant and polluting industries for BAT application

Implementation by setting sector specific limit values for the identified industries

Setting of limit values requires survey of state of the art control technology available and affordable in the country (support from e.g. universities required)

As reference, the BREF (BAT Reference Documents) of the EU can be used (available at

Regulation could be supplemented by BAT guidance documents (following BREF example) to describe available techniques

BAT Implementation

BAT Implementation

  • Guidance documents on Best Available Techniques:
    • Not legally binding guidance to supplement the Regulation
    • Idea of Guidance Documents derives from European context but can be adjusted to the country’s needs
    • Describes options of Best Available Techniques in industry regarding air pollution control measures (prevention, best practices, good housekeeping, end-of-pipe measures)
  • Training for control officers essential

BAT Implementation

  • Holistic approach: As a rule, approval is required for the whole facility, not just for the erection of a single fuel burning equipment or chimney
  • Multi level approach: Legal requirements differ according to the facilities’ potential to emit pollution:
    • All facilities and fuel burning equipment have to comply with limit values on smoke
    • Most facilities: Approval, general limit values, periodic measurements
    • BAT facilities: additionally: BAT limit values, continuous measurement for certain pollutants

Monitoring Requirements

  • Periodic measurements: has to be conducted for all major pollutants as specified in the conditions to the approval
    • Initial measurement after construction or substantial change
    • Periodic measurement once a year
    • Carried out by accredited/designated laboratories
  • Continuous measurements: some more polluting BAT industries have to conduct continuous measurement for selected pollutants
  • Reports on measurement results have to be submitted to the competent authority

Other Requirements

  • Emission Declaration: Data required for the Emission Inventory
    • The declaration has to cover all relevant pollutants indicated as their annual mass flow
    • The annual mass flow can be determined by measurement, calculation, mass balance considerations or emission factors
    • Should be submitted every 2 or 3 years

Benefits of BAT

  • Comprehensive provisions allow the prescription of concrete, detailed and sector specific technical standards, limit values and best practices
  • BAT limit values are based on modern, internationally accepted limit values but adjusted to the country’s need and specialties
  • Requirements and administrative burden differ according to the industries’ potential to pollute
  • More guidance for the control officer and industry due to supplementary BAT guidelines and other guidelines (training of officers essential!)
  • Enforcement is facilitated through periodic and continuous measurement requirements

Thank YouPia DenzinContact:Office: 0060 (0)3 - 8944 2819Mobile: 0060 (0)12 - 9764 025Email: