Transcript No Slide Title

The European IPPC Bureau
Institute for Prospective Technological Studies (IPTS)
Seville, Spain
Internet http://eippcb.jrc.es,
E.mail : [email protected]
Don Litten - Head of EIPPCB
Role of Energy Efficiency in
the BAT Reference Documents.
European Council Directive 96/61/EC
concerning integrated
pollution prevention and control (IPPC)
of 24 September 1996
• a framework directive aiming at a high
level of protection for the environment as
a whole - all environmental media
• operating permits for industry with
conditions to be based on “best available
techniques” (BAT) - NB also to meet EQS
• provides for an exchange of information
on BAT - Article 16(2)
From Article 9(4) - Directive 96/61/EC
… permit conditions must, without prejudice to
compliance with environmental quality
standards, be based on the best available
techniques, without prescribing the use of any
technique or specific technology, but
• taking into account the technical
characteristics of the installation concerned;
• its geographical location; and
• the local environmental conditions.
From BREF to Permit condition
BAT (in BREFs)
Descriptive
+
Local considerations
according to Article 9(4)
MS right to choose how
BAT-based permit or
GBR (Art 9(8))
Legally binding
IPPC on Energy
• Article 2(11) : BAT relates to impact on the environment
as a whole.
• Article 2(2) mentions direct and indirect emissions which
may cause harm to human health or environment.
• Article 3(d) : energy to be used efficiently.
• Annex IV lists energy efficiency as one consideration to
be taken into account when determining BAT.
BUT – IPPC permit relates to one or more installations (or
parts of) on same site and same operator.
• IPPC Directive amended to take account of the EU
emission trading scheme for greenhouse gases.
Energy in BREFs
• Efficient use of energy within the process.
• Inevitability of energy loss due to technical
characteristics of process (e.g. cement kilns, steam
cycle in electricity generation).
• Possible energy penalty when considering if a
particular technique is BAT (potential “cross
media” conflict).
Generic energy efficiency document foreseen.
BAT and Energy
• Optimum “economic” energy efficiency may not be
optimum “environmental” solution.
• To introduce energy saving measures with a neutral or even
positive net cost may still be economically feasible.
• Sometimes the true cost and benefits of energy saving
measures are not well assessed.
• Energy saving can mean less fuel cost plus more product to
sell (less waste) plus less maintenance and downtime
(reference 2004 European Lime conference, Krakow).
• True cost of waste is cost of waste disposal or treatment plus
cost of lost raw materials plus cost of processing.
BREFs and Energy
• Detailed and comprehensive energy data generally not
available as part of BAT information exchange.
• Precise energy data can be commercially sensitive.
• How to value the environmental benefit of energy saving?
• Generally, energy saving must be a positive environmental
factor not negative (unless there is cross media trade-off).
• Potential for energy saving is often highly dependent on
local factors such as customers for low grade heat.
• General principles and specific energy saving techniques
may be BAT subject to local conditions.
BREFs and Energy
BREFs can and do (where information was available):
• Consider energy in the determination of BAT.
• Highlight which energy saving techniques are most
appropriate to the BREF industry sector(s) – information
to operators which may in particular help SMEs.
• Clarify inevitable energy required to carry out process.
• Provide some benchmarks of energy efficiency.
• Highlight lack of available energy data or difficulty in
expressing relevant energy efficiency indicators for
industry sector(s).
BREFs and Energy
BREFs cannot:
• Address every local situation in detail.
• Make up for lack of available data on energy.
• Force implementation of energy saving measures until they
are used to determine legally binding permit requirements.
• Address energy saving achievable through infrastructural
changes, non-IPPC installations, possible collaboration
between different enterprises, alternative products etc. –
because IPPC is one valuable tool but not THE only tool!