“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 Secretary General Nadine De Greef says.
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.
“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”, De Greef points out.
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, we support 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.
