1

Review of the Integrated Pollution Prevention and Control (IPPC)

and National Emission Ceilings (NEC) Directives

Marianne WenningDG ENV, Head of Unit, Industrial Emissions and Protection of the Ozone Layer

in collaboration with DG ENV Unit on Energy&Environment

EPRG, 23 April 2007

2

Thematic Strategy on Air Pollution(SO2, NOx, particulate matter, VOC, NH3)

Objectives: improvement by 2020 relative to 2000

Life Years lost from particulate matter 47%

Premature mortality from ozone 10%

Ecosystem forest area exceeded by acidification 74%

Ecosystem freshwater area exceeded by acidification

39%

Ecosystem area where critical load is exceeded by eutrophication

43%

Forest area exceeded by ozone 15%

3

National Emission Ceilings

Stationary Sources-IPPC

- LCP, VOC etc.

Thematic Strategy on Air PollutionAir quality, health and nature protection objectives

Mobile Sources- Euro 5 and 6- Euro VI etc.

Other sources and legislation

Gothenburg Protocol of the Convention on Long Range Transboundary Air Pollution

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Further measures needed to meet the objectives of the Thematic Strategy on Air Pollution

0% 10% 20% 30% 40% 50% 60% 70% 80%

SO2

NOx

PM2.5*)

VOC

NH3

Full implementation ofcurrent legislationIndustry and powergenerationTransport

Other

Total emission reductions in 2020 beyond the NEC (2010) ceilings through current legislation and additional measures

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First analysis of benefits and costs of the revised NEC in 2020

Health benefits 5-17 Health benefits 5-17 times higher than times higher than costscosts

Additional benefits of reduced eutrophication, acidification etc.

The impacts of energy and climate package not included. Likely to reduce costs and increase benefits. Source: Working Group on National Emission Ceilings and Policy

Instruments 29-30 March 2007

0

20

40

60

80

100

120

Costs Health benefits

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Industrial Emissions

Integrated Pollution Prevention and Control (IPPC) Directive

Solvents Directive (SE)

Large CombustionPlants Directive (LCP)

European Pollutant Emission Register (EPER)European Pollutant Release and Transfer Register (E-PRTR)

Waste Incineration Directive (WI) Titanium Dioxide

Directive (TiO2)

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IPPC: important tool to achieve air pollution targets

Contribution of industrial activities (mainly IPPC) to total EU emissions in 2005: 55% CO2, 88% SO2, 36% NOx, 50% particulate matter, 55% VOC

Compared to implementation of current legislation in 2020, need for further industrial emission reductions to meet Thematic Strategy 2020 targets :

- 30% for SO2 - 35% for NOx- 24% for PM2.5- 17% for VOC

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Shortcomings in implementation and enforcement

Problems: Complexities in current legal framework Insufficient reduction of emissions due to lack of progress

towards BAT Lack of transparency on the application of the criteria

related to flexibility (technical characteristics, geographical location and local environmental conditions)

Effects: Incorrect implementation (e.g. sectoral Directives used as

default) or difficulties in interpretation (e.g. scope, definitions)

Lower level of environmental protection Possible distortion of competition

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Shortcomings in implementation, some examples from case studies

Case study of 30 installations: only half had all permit conditions clearly based on BAT as determined in the BREFs

SectorBAT Associated Emissions Levels (BREFs)

Permit conditions: Emission Limit Values (ELVs)

CementNOx200-500 mg/m3

3 out of 4 installations : 800 mg/m3 (Waste Incineration Directive)No apparent consideration of BAT

Non ferrous metals plant 1

SO250-200 mg/m3

ELV: 800 mg/m3Not possible to identify rationale behind difference

Non ferrous metals plants 2 and 3

Dioxins<0.1-0.5 ng/m3

No ELVNo monitoring data available

Pulp millVarious pollutants to water

No permit conditions for releases to water

Chemicals plant

Benzene5 mg/m3

ELV: 2500 mg/m3 (500x than BREF)

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SO2 in all countries - 354 facilities

-

200 000 000

400 000 000

600 000 000

800 000 000

1 000 000 000

1 200 000 000

1 400 000 000

1 600 000 000

1 800 000 000

2 000 000 000

Coal Oil Gas

Gap filled

EPER Reported

Calculated BAT,less strict

Calculated BAT,strict

NOx in all countries - 354 facilities

-

100 000 000

200 000 000

300 000 000

400 000 000

500 000 000

600 000 000

700 000 000

800 000 000

900 000 000

Coal Oil Gas

Gap filled

EPER Reported

Calculated BAT,less strict

Calculated BAT,strict

Source: EEA Topic Center on Climate Change and Air, 2001 EPER data

Estimated Potential Emissions Reduction from BAT Introduction in the

LCP sector

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Impacts of progress towards BAT

Impacts of progress towards BAT: environmental benefits expected to exceed compliance costs

Example for large coal power stations: NOx abatement annual costs €150-450m for 60-

200kt emission reduction Health benefits of €210-1700m

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Main options to address current shortcomings

BAT-based permitting and role of the BREFs

Role of the BREFs: more prominent or binding

Possible deviation from BAT/BREFs: more transparent according to criteria set in the Directive (technical characteristics of installation concerned, geographical location, local environmental conditions)

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Main options to address current shortcomings

Streamlining and reduction of administrative burdens

EU level: New Framework Directive integrating IPPC and sectoral Directives => increase

legal coherence, transparency and clarity Streamline MS reporting => save administrative costs ~€1-10 million/year

MS level: Most actions at MS level to reduce administrative burden (eg combined

permitting, monitoring and reporting from operators) => save administrative costs ~€10-60 million/year

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Use of NOx and SO2 emission trading (ET)

IPPC and NEC are barriers/obstacles to NOx and SO2 ET within and between MS

ET can be a cost-effective and predictable instrument for MS to reduce emissions and achieve environmental objectives

IPPC and NEC revisions could foresee the possibility for MS to opt for NOx and SO2 ET

If MS wish to use ET, they would need to follow specific future EU-wide rules (e.g. emissions cap, trading rules, geographical scope, local environmental protection) to ensure environmentally sound, compatible and enforceable schemes

Such EU-wide rules would be subject to a specific Proposal (not part of IPPC/NEC packages)

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Key questions to the EPRG

1. NOx and SO2 emission trading

Valuable additional cost-effective instrument to reach 2020 ceilings subject to EU-wide rules to ensure environmentally sound, compatible and enforceable schemes?

3. Streamlining interactions IPPC & other legislation

Support a single Directive on industrial emissions?

2. BAT implementation

Support for more consistent permitting by placing the BREFs as the foremost point of reference or giving them a binding nature to make greater progress towards BAT and a more level playing field?