CENTRAL EUROPE ENERGY PARTNERS, AISBL POSITION PAPER ON THE REVISION OF THE LCP BREF

CENTRAL EUROPE ENERGY PARTNERS, AISBL POSITION PAPER ON THE REVISION OF THE LCP BREF

Central Europe Energy Partners, AISBL (CEEP), as a representative of the energy sector and energy-intensive companies from Central Europe, is always supportive of new measures, which can help to improve the EU’s energy security, whilst preserving the environment in a cost-effective manner.

The Directive on Industrial Emissions (IED) is the main EU instrument regulating pollutant emissions from industrial installations. The review of its related Best Available Techniques reference document for Large Combustion Plants (LCP BREF) currently underway, should allow for further limitation of emissions from industrial installations in the future. However, as the consequences of this technical document go beyond the energy sector, and tackles the energy intensive sector as well, it is important that the BAT should be fully justified, to ensure the best possible use of resources, in an attempt to improve the EU’s environment further.

The IED Directive aims to achieve a high level of protection of human health and the environment, taken as a whole, by reducing harmful industrial emissions across the EU, in particular through better application of Best Available Techniques (BAT). Around 50,000 installations conducting the industrial activities, listed in Annex I of the IED Directive, are required to operate in accordance with a permit (granted by the authorities in the Member States). This permit should contain conditions set in accordance with the principles and provisions of the IED Directive.

Bearing in mind the above, CEEP believes that the current IED Directive and reference documents, could establish an effective framework for Member States, competent authorities and industry, to ensure that environmental goals will be met in the most effective way. Therefore, the stakeholders, Member States and operators, should be given a chance to find cost-effective solutions, which respect environmental needs, along with practical, social and economic factors.

On this basis, CEEP has some concerns regarding the Commission’s proposal for a revision of the Industrial Emissions Directive:

  1. The new standards set by the LCP BREF (Large Combustion Plants BAT REFerence document) will be extremely challenging and costly for industry. For example, as concerns power plants, LCP BREF could lead to the closures of many of these. For the energy sector (electricity) the possible closures of some power plants is only one of the main problems, but, what is even more dangerous, is that the security of the continuous operation of the synchronous connected European power system will be endangered (i.e. in transition time and after), and such a risk has to be taken into account as a factor (not only “economic and market factors”).
  1. The proposed measures will result in a decrease of the competitiveness of the EU’s industry. There are no such obligations in countries outside the EU, therefore, EU industry should have a sufficient protection period to adapt to the newly-proposed measures.
  1. According to the European Commission’s Communication on “Better regulation for better results - An EU agenda”[1], all important implementing acts are subject to Impact Assessment outlining the full environmental, economic and social consequences of the new legislative measures. We wish to highlight that Chapter 10 of the LCP BREF will provide a basis for the Commission’s implementing decision on BAT Conclusions, and because of its significance to the EU energy sector and energy intensive sector, it should be subject to in-depth Impact Assessments, with the aspects of energy security and competitiveness, included.

European Industry is among the world leaders, in terms of control of environmental emissions. Maintaining European competitiveness in the face of these ambitions, requires that all environmental measures are carefully weighed up, and that the most cost-effective solutions are pursued. CEEP believes that this goal could be achieved by a positive dialogue based on economic and market factors.

[1] COM(2015) 215 final