FEAD comments on BREF: Economic feasibility of BAT conclusions to be assessed

Source: FEAD

Brussels — The BAT conclusions – as defined in Chapter 6 of BREF, the Best available techniques Reference document – will become the binding reference for national authorities to set permit conditions for waste treatment installations. So this document is of crucial importance to the sector. It lays down requirements for the monitoring of pollutants to air and to water and defines emission levels (so-called “BAT-AELs”: Associated Emission Levels linked to the use of Best Available Techniques). FEAD has now submitted its comments on the first draft of the Waste Treatment BREF, presented by the European IPPC Bureau (EIPPCB) on 18 December 2015.

FEAD Secretary General Nadine De Greef explained: “Our members are concerned that the emission levels set in the current draft do not seem based on a representative sample of plants. Overall, it is unclear how the BAT-AELs have been derived from operational data. Moreover, the high monitoring frequencies proposed would require monitoring of pollutants to water on a daily basis and of pollutants to air every three or six months for specific treatments. This would significantly increase operational costs without any added environmental benefit.”

FEAD would like to stress the fact that whereas a number of countries, in particular from Southern and Eastern Europe, did not contribute to the data collection, they will also have to fulfil the new requirements. Landfill diversion in these countries will become extremely difficult if the proposed requirements would be adopted, putting at risk the EU’s transition to a circular economy. Nadine De Greef: “We ask the EIPPCB to assess the economic feasibility of the BREF requirements. FEAD’s members are committed to applying Best Available Techniques but their implementation should not generate additional costs without providing significant environmental benefits.”

Due to the technical complexity of the document and the significant number of comments to be expected, FEAD calls upon the EIPPCB to seriously consider the circulation of a second draft. In addition, FEAD supports the organisation of a data assessment workshop in the coming months to assess the accuracy and representativeness of the data collected for the revision process.

Source: European Federation of Waste Management and Environmental Services (FEAD)