The above signatories have signed a proposal for the development of a systematic approach for deriving suitable BAT1-AEL2s ranges, submitted to DG Environment of the European Commission.
The legal obligation for permitting authorities to set the emission limit value for a given pollutant at a level that ensures that, under normal operating conditions, emissions do not exceed the BAT-AEL, has far-reaching consequences. BAT-AELs have to be implemented as ELV3s and industrial installations have to comply with those. A systematic approach to derive the BAT-AEL as a result of the BREF review process and the data collection performed in that context is therefore a must. A robust and transparent approach will secure consistency for stakeholders throughout the BREF review process, as well as for regulators and operators at permitting level. Based on both the Guidance published in the Official Journal of the EU in March 2012 and on our combined industrial experience, we have outlined in this paper an approach which should help deriving both ends of the BAT-AEL range systematically. This is crucial if one wants to preserve the integrity of IED implementation through appropriately-designed and truly applicable BAT conclusions, technically achievable and economically viable BAT-AELs.
1. Best Available Techniques
2. Associated Emission Levels
3 Emission Limit Values
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