Introduction Industrial Emissions Directive - Targeted ...Industrial Emissions Directive - Targeted...
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Introduction Industrial Emissions Directive - Targeted stakeholder survey The Industrial Emissions Directive 2010/75/EU (IED) is the primary instrument in place at the EU level to control and mitigate the environmental and human health impacts arising from industrial emissions in the EU. The IED regulates around 50 000 of the largest industrial installations covering a wide range of agro-industrial sectors (as defined by Annex I of the IED). These include: power plants, refineries, and production of steel, non-ferrous metals, cement, lime, glass, chemicals, pulp and paper, food and drink as well as waste treatment and incineration and the intensive rearing of pigs and poultry. The general objective of the IED is to prevent, reduce and eliminate as far as possible emissions into air, water and land arising from industrial activities. The IED aims to ensure that industrial emissions are dealt with in an integrated way and minimised. Permits must be issued for these installations by national authorities with conditions based on the use of Best Available Techniques (BAT). To ensure a comparable EU approach, sectoral BAT Reference Documents (BREFs) are produced through an EU level techno-economic assessment carried out by a Technical Working Group of the Commission, Member States, industry and civil society. The BAT Conclusions are adopted as Commission implementing decisions. The IED is now undergoing an evaluation against the following five key evaluation criteria: effectiveness, efficiency, relevance, coherence and EU added-value. The evaluation is supported by a series of stakeholder consultation activities, including an Open Public Consultation (OPC) and this more detailed and targeted online survey aimed at stakeholders actively involved in the implementation of the IED. Your responses provided to this questionnaire will be analysed and will feed into the overall IED evaluation process. The roadmap of the evaluation process can be found here . Ricardo Energy & Environment is supporting the European Commission with the evaluation, including stakeholder engagement activities. If you have any questions, please do not hesitate to contact us at[email protected]
Transcript of Introduction Industrial Emissions Directive - Targeted ...Industrial Emissions Directive - Targeted...
Introduction
Industrial Emissions Directive - Targeted stakeholder survey
The Industrial Emissions Directive 2010/75/EU (IED) is the primary instrument in place at the EUlevel to control and mitigate the environmental and human health impacts arising from industrialemissions in the EU. The IED regulates around 50 000 of the largest industrial installationscovering a wide range of agro-industrial sectors (as defined by Annex I of the IED). These include:power plants, refineries, and production of steel, non-ferrous metals, cement, lime, glass,chemicals, pulp and paper, food and drink as well as waste treatment and incineration and theintensive rearing of pigs and poultry. The general objective of the IED is to prevent, reduce andeliminate as far as possible emissions into air, water and land arising from industrial activities.
The IED aims to ensure that industrial emissions are dealt with in an integrated way and minimised.Permits must be issued for these installations by national authorities with conditions based on theuse of Best Available Techniques (BAT). To ensure a comparable EU approach, sectoral BATReference Documents (BREFs) are produced through an EU level techno-economic assessmentcarried out by a Technical Working Group of the Commission, Member States, industry and civilsociety. The BAT Conclusions are adopted as Commission implementing decisions.
The IED is now undergoing an evaluation against the following five key evaluation criteria:effectiveness, efficiency, relevance, coherence and EU added-value. The evaluation is supported bya series of stakeholder consultation activities, including an Open Public Consultation (OPC) andthis more detailed and targeted online survey aimed at stakeholders actively involved in theimplementation of the IED. Your responses provided to this questionnaire will be analysed and willfeed into the overall IED evaluation process.
The roadmap of the evaluation process can be found here.
Ricardo Energy & Environment is supporting the European Commission with the evaluation,including stakeholder engagement activities.
If you have any questions, please do not hesitate to contact us at [email protected]
This survey
Industrial Emissions Directive - Targeted stakeholder survey
This survey is intended to gather feedback for the IED evaluation from stakeholders who areinvolved in the implementation of the IED. The survey includes questions grouped in to 10 keythemes relevant to the IED that will be considered as part of the evaluation. The questions aretailored depending on whether you are representing a Member State authority (at any level ofadministration and IED implementation), industry (individual company or trade body) or other typeof organisation (e.g. NGO, research body). Therefore, it is important that you indicate below whichtype of organisation you are representing.
The survey is deliberately detailed to cover all of the main aspects of the IED and evaluation.However, it is recognised that for some stakeholders, certain questions will not be relevant, or youwill not be in a position to respond to them. In these instances, you can simply select “Do notknow” or ”Not applicable”.
Whilst the questions refer to the IED, it is recognised that the Directive has been transposed intonational legislation so many of you will be more familiar with the details of these. Where relevant,please respond based on your experience and understanding of implementing the legislation thathas transposed the IED into national law.
Finally, a number of questions refer to how things have changed with the implementation of the IEDrelative to the situation under the Integrated Pollution Prevention and Control (IPPC) Directive andother sectoral Directives. This is typically referring to the situation around 10 years ago before theIED was adopted.
The deadline for responses to this survey is Friday, 6 September 2019, although we wouldappreciate responses as soon as possible so that we can start building in your feedback. You canonly take the survey once (one response per computer). You can save the progress you have madefilling out your survey and complete it at a later time - once you open the link to the survey on thesame computer (and in the same browser) you will be directed to the same page of thequestionnaire where you left, with your previous responses saved.
About you
Industrial Emissions Directive - Targeted stakeholder survey
Please provide the following details about yourself.
Your personal data provided for the survey (name, organisation name, email address and country of residence) will not bepublished. Information on the type of stakeholder group you are representing will be used for statistical analysis.
The provision of personal data is not mandatory. However, if you do not provide your personal data, we will not be able to contact youwith additional information to follow up your response to the survey.
Further information on how we process your personal data is available here.
Name
Name of organisation or institution
E-mail address
Country of residence
Stakeholder type*
Member State authority
Industry
Other (please specify)
Follow up
Industrial Emissions Directive - Targeted stakeholder survey
After completing this questionnaire, are you happy to be contacted for any clarifications, a follow-upinterview and/or further updates on the evaluation?
*
Yes
No
1. General
Industrial Emissions Directive - Targeted stakeholder survey
1.1 To what extent do you think that the IED has contributed to reducing and (as far as possible)eliminating pollution arising from industrial activities:
*
Strongly agree
Agree
Neither agree nor disagree
Disagree
Strongly disagree
Do not know
Strongly agree Agree
Neither agreenor disagree Disagree
Stronglydisagree Do not know
Consumption of naturalresources
Energy use
Waste generation
1.2 To what extent do you think that the IED has contributed to reducing the following for agro-industrialactivities:
*
Yes Maybe No Do not know
Consumption of naturalresources
Energy use
Waste generation
1.3 In your opinion, is the IED the appropriate instrument for controlling the following for agro-industrialactivities:
*
Strongly agree Agree
Neither agreenor disagree Disagree
Stronglydisagree Do not know
The most relevantenvironmental impacts
The most relevantpollutants
The most polluting agro-industrial sectors
1.4 To what extent do you think that the IED addresses the following*
1.5 Please provide further details to justify your answers including any supporting evidence.
2. Scope - sectors, pollutants, thresholds, environmental media
Industrial Emissions Directive - Targeted stakeholder survey
If yes, please indicate which ones and provide any supporting evidence.
2.1 Are there any agro-industrial activities that fall outside of the scope of the IED (partially due to thethresholds in Annex I of the IED or fully) which generate high levels of pollution?
*
Yes
No
Do not know
If yes, please indicate which ones and provide any supporting evidence.
2.2 Are there any pollutants that have been omitted or fall outside of the scope of the IED which, in youropinion, should be captured?
*
Yes
No
Do not know
Please provide further details to justify your answer including any supporting evidence.
2.3 To what extent do you think that the IED contributes to the reduction of hazardous substances(persistent organic pollutants, heavy metals)?
*
Strongly agree
Somewhat agree
Neither agree nor disagree
Somewhat disagree
Strongly disagree
Do not know
3. Cross-Cutting Themes
Industrial Emissions Directive - Targeted stakeholder survey
Significant
improvementSome
improvement No impact Some reductionSignificantreduction Do not know
EnvironmentalSustainability
Social Sustainability
Economic Sustainability
If relevant, please provide further information and supporting evidence for your response.
3.1 In relation to the industry/sector you represent, and compared to the previous situation under the IPPCDirective and the sectoral Directives, what impact do you think the IED has had on the following:
*
If relevant, please provide further information and evidence supporting your response.
3.2 In relation to the industry/sector you represent, what impact do you think the IED has had on thecompetitiveness of the EU industry?
*
Significant benefit
Some benefit
None
Some disadvantage
Significant disadvantage
Do not know
3.3 To what extent do you think that the regulation of environmental impacts through the IED anddevelopment of BREFs and BAT Conclusions has stimulated innovation in the prevention and control ofpollution from industrial activities?
*
Strongly agree
Somewhat agree
Neither agree nor disagree
Somewhat disagree
Strongly disagree
Do not know
Significant driver
Some positiveimpact
Neither positivenor negative
Some negativeimpact
Significantbarrier Do not know
Requirements forinstallations to hold apermits
Monitoring and reportingrequirements
Enforcement
BAT Conclusions
Emerging techniqueschapter of the BREF
3.4 Which elements of the IED and BREF process have the greatest impact on driving innovation in theprevention and control of pollution from industrial activities?
*
3.5 Please provide further details to justify your answers and any supporting evidence.
If not, what prevents it from being fit for purpose? Please elaborate to justify your answer and provide details and any supportingevidence.
3.6 Does the IED remain relevant in view of the need for industry to rapidly adapt to a zero-carboneconomy by 2050?
*
Yes
Partially
No
Do not know
4. Procedure for the drawing up and reviewing of BAT reference documents (BREFs) - theBREF process
Industrial Emissions Directive - Targeted stakeholder survey
Strongly agree Agree
Neither agreenor disagree Disagree
Stronglydisagree Do not know
The most relevantenvironmental impacts
The most relevantpollutants
The most polluting agro-industrial sectors
4.1 To what extent do you think that the process to draw up and regularly review best available technique(BAT) reference documents (BREFs) addresses the following?
*
4.2 To what extent do you think that the BREF process identifies the best available techniques that are themost effective techniques for achieving a high level of environmental protection?
*
Strongly agree
Somewhat agree
Neither agree nor disagree
Somewhat disagree
Strongly disagree
Do not know
4.3 Is the definition of Best Available Techniques (BAT) as set out in the IED appropriate for identifying thetechniques that are the most effective for achieving a high level of environmental protection?
*
Yes
Partially
No
Do not know
Strongly agree
Somewhatagree
Neither agreenor disagree
Somewhatdisagree
Stronglydisagree Do not know
A high level ofenvironmental protection
Protecting human health
4.4 To what extent do you think that the BREF process identifies the most appropriate associated emissionor performance levels for achieving the following?
*
4.5 Please provide further details to support your answers to the four questions above and any supportingevidence.
Yes Neutral No Do not know
For identifying keyenvironmental issues fora sector
For identifying BAT
For developing effectiveBAT Conclusions
To help stimulateinnovation
If neutral or no, please provide further evidence to support your answer e.g. how could the composition change to better stimulateinnovation?
4.6 Is the composition of the Technical Working Group (TWG) established for each BREF appropriate forthe following:
*
Significant
improvementSome
improvement No changeSome
deteriorationSignificant
deterioration Do not know
Identification of keyenvironmental issues
Information exchange
Identification of BAT
Development of BATconclusions
4.7 How do you think that the following elements of the BREF process have changed under the IED(compared to under the IPPC Directive) and are in line with the guidance set out in CommissionImplementing Decision 2012/119/EU?
*
4.8 How appropriate is the duration of the process for developing and reviewing BREFs - which is set out inguidance as Commission Implementing Decision 2012/119/EU - for the production of effective BATconclusions?
*
Too short
About the right length
Too long
Do not know
Not applicable
4.9 Please provide further details to support your answers to the two questions above and any supportingevidence.
4.10 Does the BREF process sufficiently consider the compliance and operational costs associated withtechniques when identifying the best available techniques?
*
All of the time
Most of the time
Some of the time
Rarely
Never
Do not know
4.11 Does the BREF process sufficiently consider the benefits (e.g. emission reductions, improvements inresource use, reduced waste generation) associated with techniques when identifying the best availabletechniques?
*
All of the time
Most of the time
Some of the time
Rarely
Never
Do not know
4.12 Does the BREF process sufficiently consider cross-media impacts (i.e. impacts on otherenvironmental issues) in identifying the best available techniques?
*
All of the time
Most of the time
Some of the time
Rarely
Never
Do not know
4.13 Please provide further details to support your answers to the three questions above and anysupporting evidence.
Please provide further information to support your answer, where relevant, with specific examples e.g. where emerging pollutantsand/or environmental impacts have been identified during the BREF process but could not be captured in the BAT Conclusions.
4.14 To what extent do you think that the BREF process has been flexible and fast enough to respond tonew or emerging environmental issues?
*
Strongly agree
Agree
Neither agree nor disagree
Disagree
Strongly disagree
Do not know
Not applicable
5. Permitting including derogations
Industrial Emissions Directive - Targeted stakeholder survey
5.1 Has the IED and BAT Conclusions enabled Member States to implement BAT-based permitting?*
Yes
Neutral
No
Do not know
5.2 How has the situation changed relative to that under the IPPC and sectoral Directives?*
Significant increase in BAT-based permitting
Some increase in BAT-based permitting
No change
Some reduction in BAT-based permitting
Significant reduction in BAT-based permitting
Do not know
5.3 Based on your experience, are emission limit values (ELVs) in permits typically based on upper orlower BAT-AELs (emission levels associated with BAT) or levels in between?
*
Upper BAT-AELs all of the time
Upper BAT-AELs most (more than 75%) of the time
Both upper and lower BAT-AELs
Lower BAT-AELs most of the time (more than 75%)
Lower BAT-AELs all of the time
Other levels (please describe below)
Do not know
5.4 Where relevant, please provide further information and evidence to support your answers, to the threequestions above.
5.5 The achievement of emission levels associated with the best available techniques as described in BATconclusions could potentially lead to disproportionately higher costs compared to the environmentalbenefits. Article 15(4) of the IED allows for the setting of less strict emission limit values as a derogationfrom Article IED 15(3).
If relevant, please provide details as to how and why this Article has been used/useful for yourinstallation(s) or sector and whether it provides for the flexibility required in the permitting process.
Please provide further explanation as to why this Article has been used/useful and whether it provides for the flexibility required in thepermitting process.
5.6 Has the flexibility afforded by Article 15(5) been utilised for installations in your sector to allowcompetent authorities to grant temporary derogations from BAT-based permitting requirements to allow forthe testing and use of emerging techniques?
*
Yes
No
Do not know
6. Monitoring, reporting and enforcement
Industrial Emissions Directive - Targeted stakeholder survey
If neither agree nor disagree or disagree, please provide further details.
6.1 To what extent do you think that the BAT conclusions are explicit and clear on monitoring requirementse.g. averaging periods:
*
Strongly agree
Agree
Neither agree nor disagree
Disagree
Strongly disagree
Do not know
Please provide further details, if relevant.
6.2 To what extent do you think that industry reporting activities have been simplified under the IEDcompared to the situation under the IPPC and sectoral Directives?
*
Strongly agree
Agree
Neither agree nor disagree
Disagree
Strongly disagree
Do not know
Strongly agree Agree
Neither agreenor disagree Disagree
Stronglydisagree Do not know
BAT conclusions
Permits
Enforcement
Access to information
Access to justice
Please provide further details to justify your answer and any supporting evidence.
6.3 To what extent do you think that the provisions of the IED on the following have led to more effectivecontrol of the environmental impacts of large industrial installations relative to the situation under the IPPCand sectoral Directives (i.e. prior to the adoption of the IED)?
*
7. Costs and benefits
Industrial Emissions Directive - Targeted stakeholder survey
Strongly agree
Somewhatagree
Neither agreenor disagree
Somewhatdisagree
Stronglydisagree Do not know
Clarification of theprovisions
Simplification of theprovisions
7.1 By bringing the [permitting, monitoring, reporting] requirements of previously separate Directivestogether into one instrument, to what extent do you think that the IED has achieved the following relative tothe previous regime:
*
7.2 Has the implementation of the IED led to a reduction in unnecessary administrative burden forindustrial installation operators?
*
Yes
Neutral
No
Do not know
7.3 Please provide further information and evidence to support your answers, where relevant, including anyestimates of administrative burden for your installation or sector.
7.4 Are there significant differences in IED and BATC implementation between Member States for yoursector?
*
Yes
No
Do not know
7.5 For any identified differences in IED implementation between Member States for your sector, pleaseprovide further information on the root causes for these differences and any quantified information on howthey affect the costs borne by your sector's installation operators or impacts on environmental pollution.
If relevant, please provide further details and evidence to support your answer.
7.6 To what extent do you think that the IED has contributed to achieving a level playing field in the EU foryour sector(s) by aligning environmental performance requirements for industrial installations (compared tothe previous legislative regime of the IPPC Directive and sectoral Directives).
*
Strongly agree
Agree
Neither agree nor disagree
Disagree
Strongly disagree
Do not know
7.7 Please provide evidence of the compliance, administrative, monitoring and reporting costs, and of thebenefits, for your installation and/or sector that are associated with implementing the IED’s requirementswhich go beyond those that would have occurred under the previous legislative regime of the IPPCDirective and the sectoral Directives. Please provide quantitative evidence where possible, separating outdifferent cost or benefit contributions. Please exclude time spent on the BREF process (covered inseparate question). Benefits may include monetary and non-monetary benefits e.g. changes in emissions,resource use or waste generation. Please specify the geographic level to which your response refers (i.e.regional, national or EU).
Please provide further information and supporting evidence.
7.8 To what extent do you think that the benefits that the IED has achieved have been achieved in a cost-effective manner.
*
Strongly agree
Agree
Neither agree nor disagree
Disagree
Strongly disagree
Do not know
Not applicable
If yes, please provide further details and supporting evidence.
7.9 Could the IED have been implemented more efficiently whilst still delivering its overall objectives andminimising unnecessary costs?
*
Yes
No
Do not know
Common Waste Wasterand Waste GasTreatment/ ManagementSystems in the ChemicalSector (CWW)
Common Waste GasTreatment in the ChemicalSector (WGC)
7.10 For your sector, please confirm which BREF(s) development/ reviews(s) if any, you are involved in.For these, please estimate the staff time (i.e. number of person-days in Full Time Equivalent) spent by yourcompany or association (please specify) including external support by a third-party, on contributing to theinformation exchange for each BREF.
Ferrous Metals ProcessingIndustry (FMP)
Food, Drink and MilkIndustries (FDM)
Intensive Rearing ofPoultry or Pigs (IRPP)
Iron and Steel Production(IS)
Large Combustion Plants(LCP)
Manufacture of Glass(GLS)
Non-ferrous MetalsIndustries (NFM)
Production of Cement,Lime and MagnesiumOxide (CLM)
Production of Clor-alkali(CAK)
Production of LargeVolume OrganicChemicals (LVOC)
Production of Pulp, Paperand Board (PP)
Refining of Mineral Oil andGas (REF)
Surface Treatment UsingOrganic Solvent (includingWood and Wood ProductsPreservation withChemicals) (STS)
Slaughterhouses andAnimals By-productsIndustries (SA)
Smitheries and FoundriesIndustry (SF)
Tanning of Hides andSkins (TAN)
Textiles Industry (TXT)
Waste Incineration (WI)
Waste Treatment (WT)
Wood-based PanelsProduction (WPP)
8. Public access to information and justice
Industrial Emissions Directive - Targeted stakeholder survey
Significant
improvementSome
improvement No change Some declineSignificant
decline Do not know
Granting of a permit
Updating of a permit
Details of permitsgranted and conditionscontained therein as setout in Article 24 of theIED
Environmentalperformance ofinstallations
Derogations
8.1 To what extent has the IED improved public access to information on the following relative to thesituation under the IPPC Directive:
*
8.2 Are permit(s) for your installation / sector easily accessible and available via the Internet?*
Yes
No
Do not know
8.3 Please provide any further information and supporting evidence.
9. Coherence
Industrial Emissions Directive - Targeted stakeholder survey
9.1 To what extent is the IED internally consistent and coherent among its chapters and provisions?*
Extremely consistent
Very consistent
Moderately consistent
Slightly consistent
Not consistent
Do not know
9.2 If relevant, please provide details of any cases of overlaps, contradictions or other inconsistenciesbetween provisions / requirements of the IED.
If yes, please provide further details.
9.3 Are there any inconsistencies, contradictions, unnecessary duplication, overlap or missing linksbetween provisions and activities listed in IED Annex I?
*
Yes
No
Do not know
If no, please provide further details.
9.4 Are the boundaries of the activities in Annex I clear and appropriate?*
Yes
No
Do not know
Significant
positivecontribution
Some positivecontribution No contribution
Some negativecontribution
Significantnegative
contribution Do not know
Air quality
Water quality
Circular economy
Waste management
Sustainable use ofresources
Chemical risks andhazards
Energy
Climate change
9.5 To what extent does the IED contribute to the achievement of the objectives of the following EUenvironmental policy areas:
*
Yes No Do not know
Air quality
Water quality
Circular economy
Waste management
Sustainable use ofresources
Chemical risks andhazards
Energy
Climate change
If relevant, please provide details of any possible overlaps, contradictions and/or inconsistencies as well as any changes that might beneeded to better contribute to these objectives.
9.6 Are there any cases of overlaps, contradictions or other inconsistencies between objectives andprovisions / requirements of the IED and the following EU environmental policy areas:
*
If relevant, please provide details of any possible overlaps, contradictions and/or inconsistencies as well as any changes that might beneeded to better contribute to these objectives.
9.7 Are there any cases of overlaps, contradictions or other inconsistencies between objectives andprovisions / requirements of the IED and Regulation (EC) 166/2006 establishing the European PollutantRelease and Transfer Register (E-PRTR)?
*
Yes
No
Do not know
10. EU added value
Industrial Emissions Directive - Targeted stakeholder survey
Significant
benefit Some benefit NeutralSome
disadvantageSignificant
disadvantage Do not know
To better protect humanhealth and theenvironment
To ensure that nationalcompetent authoritiesaddress industrialpollution
To avoid competition onenvironmental standards
10.1 To what extent do you think that legislation to regulate environmental impacts of large industrialinstallations at the EU level, as opposed to action solely at the national level, helps the following?
*
If relevant please provide further details and evidence to support your answers.
10.2 Do the issues tackled by the IED (for example, preventing, reducing and eliminating as far aspossible, pollution arising form industrial activities) continue to require action at the EU level?
*
Yes
No
Do not know
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Industrial Emissions Directive - Targeted stakeholder survey
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If you have any additional information that you would like to provide to the Evaluation Team that has not been possible to provide inresponse to this survey, then please send it to [email protected].
Furthermore, if you have selected that you are happy for Ricardo to follow up with you directly for any clarifications and/or additionalinformation and to be considered for a potential interview then please ensure that you have provided your contact details in theintroductory section of the survey.
Many thanks for your support!
