In December 2007, the EU Commission issued a Directive proposal on industrial emissions. In addition to the regulations of the old IPPC Directive, the recast IE Directive includes proposals for pollution from large combustion plants (LCP) and waste incineration plants, titanium oxide industry and the industrial use of organic solvents.
The proposal contains very substantial new demands on industry. It is estimated that implementation of the proposed Directive would cause costs up to hundreds of millions of euros to the Finnish forest industry over the next permit validity period. According to a study, the new emission limits imposed on large combustion plants would alone call for €55 million in new investments by the Finnish forest industry and its on-site combustion plants.
Emission restrictions tightening
A central issue for the IE Directive is making the Best Available Technique (BAT) reference documents more binding than they now are in the environmental permit application process. The forest industry considers it important that Member States are allowed justifiable derogations from the emission levels determined in the BAT reference documents. The possibility of taking into account local and site-specific differences must be retained in permit considerations especially for existing installations.
Additional measures such as the introduction of the "European Safety Net" should not be introduced. This regulatory model does not take into account the key principles of the IPPC directive, namely best available technologies, local conditions and an integrated approach, under which the emissions of industrial facilities are assessed as a whole.
The emission limit values of large combustion plants will be tightened as part of the recasting of the Directive. It is important that the emission limits imposed on certain boilers of large combustion plants are made sufficiently flexible. Furthermore, industrial processing equipment, such as the pulp industry’s recovery boilers and lime kilns, should be excluded from the scope of the large combustion plant provisions, since their primary function is the recovery and production of process chemicals.
Furthermore, demands placed on soil remediation at cessation of activities should be based on risk assessments.
Aiming for constant improvement
The forest industry has cut its emissions substantially over the last 15 years. The industry’s emission reductions have been achieved most effectively without norm control. The key factor has been the consideration of the facilities as a whole as well as consideration of their location and surrounding environment. The environmental legislation, taxation and other steering methods should be functional, cost-effective and should encourage new innovations.
The IED proposal is currently undergoing the co-decision procedure in the European Parliament and Council. The directive is expected to be adopted by the end of 2010. After this, it will be implemented into Finnish legislation through a revision of the Environmental Protection Act.
Fredrik Blomfelt, Senior Advisor (Environment)
Tel. +358 40 705 7389