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115 December 2020ED13995Public© Ricardo plc 2020
• Welcome and housekeeping
REVISION OF THE INDUSTRIAL EMISSIONS DIRECTIVE AND E-PRTR
REGULATION
FIRST STAKEHOLDER WORKSHOP
15 DECEMBER 2020
Morning session – Overview and IED revision
215 December 2020ED13995Public© Ricardo plc 2020
Housekeeping
You can submit questions or comments in writing at any time during the Live Event via
the Q&A panel, to the right of your screen.
➢ Just click on the ‘Ask a question’ button to write and submit you comment/question.
Use question bubble icon to
expand or collapse Q&A panel
315 December 2020ED13995Public© Ricardo plc 2020
• Asking questions
– Submit in the “Ask a question” box
– All questions will be logged, but not all will be published in the meeting
– In the meeting we will publish questions that we address in the Q&A sessions
– After the meeting we will also publish and address FAQs
– At the start of your question, please can you add:
• Your organisation name
• The number of the related “Problem area”
• After the meeting
– Slides
– Recording
– Available at https://ee.ricardo.com/industrial-emissions-directive-revision-
stakeholder-workshop
Housekeeping
Revision of the Industrial Emissions Directive (IED)
First Stakeholder Workshop
15 December 2020
Michael BENNETTEuropean Commission
DG Environment - Industrial Emissions Unit (C.4)4
Today’s Meeting
▪ To inform you of the “state-of-play” of both Impact Assessments
▪ Signpost the way in which the studies are being undertaken, with the appropriate information on baselines and evidence.
▪ AM = IED
▪ PM = E-PRTR (NB different internet remote meetings platform –see separate invitation and details)
▪ Both IAs – within overview remit of the EU Green Deal, and the Zero Pollution Action Plan
▪ Timetable to produce the Commission’s proposals for both initiatives is end-2021, for deliberation with the co-legislators
5
Opportunities to contributeYour views on IED issues and solutions/ Our Outline Timetable:
• Open Public Consultation (OPC). Joint E-PRTR & IED. Starts this week –open until mid-March 2021
• Targeted Stakeholders’ Survey [TSS] (web survey) – New Year to mid-March 2021
• Interviews, focus groups) – Q1/Q2 2021
• Final stakeholder workshop – Q2 2021
• Adoption of Commission legislative proposals – Q4 2021
What we would like from you:
• Tell us if you would like to contribute
• Respond to the Open Public Consultation (expert part for expert attendees)
• Please take the time to also respond to the TSS
• Encourage input from other stakeholders (industry, NGOs, the public)6
Contacts / more information
E-PRTR IED
European Commission
Desk Officer: Alex RADWAY Desk Officer: Michael BENNETT
Management: Aneta WILLEMS / Chris ALLEN
email [email protected] [email protected]
Evaluation & Revision webpage
https://europa.eu/!uD47Kd https://europa.eu/!QB86dV
CIRCABC https://europa.eu/!cy64Wu https://europa.eu/!nY63hc
Better Regulation
Portal
https://europa.eu/!MR96xJ https://europa.eu/!dY73wT
Supporting contract
RPA Europe consortiumMarco [email protected]
Trinomics consortiumTim [email protected]
7
Thank you for your attention!
• For the Keynote Speech, over to:
• Ms Veronica Manfredi, Director, ENV Directorate C, Quality of Life
8
915 December 2020ED13995Public© Ricardo plc 2020
IED revision
Keynote: Overview of the Potential of
the IED Sectors for the EU Green Deal
Veronica Manfredi, Director, Quality
of Life EC DG ENV C
First workshop
© Ricardo plc 2020
Stakeholder workshop, 15 December 2020
Assessment of options for the
revision of the Industrial Emissions
Directive
1115 December 2020ED13995Public© Ricardo plc 2020
• IED Impact Assessment – Overview (Tim Scarbrough, Ricardo)
• Summary of problems and policy options being considered for revision of
the IED – 7 short presentations
• Impact assessment steps and consultation methodologies used
(Tim Scarbrough, Ricardo)
• Q&A
• AOB/ wrap up/ close (DG ENV)
Meeting aims and agenda
Primary aims of this workshop are to:
• Explain the impact assessment process for revision of the IED
• Present the problems being considered in the impact assessment, together
with current options being considered
• Introduce the consultation activities
Agenda
1215 December 2020ED13995Public© Ricardo plc 2020
• IED Impact Assessment – Overview
• Summary of problems and policy options being considered for revision of
the IED – 7 short presentations
• Impact assessment steps and consultation methodologies used
(Tim Scarbrough, Ricardo)
• Q&A
• AOB/ wrap up/ close (DG ENV)
1315 December 2020ED13995Public© Ricardo plc 2020
IED
eva
luati
on
fin
din
gs
• Under the European Green Deal, the European Commission is committed to review
the legal framework of Directive 2010/75/EU on industrial emissions (the IED).
• The review aims to support the European Green Deal goals on zero pollution, climate
neutrality, biodiversity and a cleaner, more circular economy.
• An evaluation of the IED was completed in 2020
– Concluding that it largely works well
– Improvements could be made in its design and implementation
– Several IED sectors still contribute significant overall pressures on the environment
• The impact assessment to examine revisions to the IED was launched in 2020
Context to the IED impact assessment
Works well
✓ BREF process
✓ Permitting
✓ Reduced distortion of competition
✓ Reducing industry emissions
(especially to air)
✓ Cost-effectiveness
✓ Promotion of BAT
Works less well
❑ Emerging techniques
❑ Clarification of legal requirements
❑ GHG emissions / decarbonisation
❑ Reducing resource use / supporting circular economy
❑ Availability of data
❑ Implementation of BAT conclusions in permits
❑ Access to information
❑ Public participation in the permitting procedure and access to justice
1415 December 2020ED13995Public© Ricardo plc 2020
• The overall purpose of the study is to assist the Commission in carrying out an impact
assessment in line with the requirements of the European Commission’s Better
Regulation Guidelines and its Toolbox
• The contractor team will work with the Commission to
– define the problems to be tackled
– identify and develop a range of options to address them, and
– assess the impacts of those options
• Analysis to be based on quantitative and qualitative evidence, and contributions from
stakeholder consultation (collecting additional evidence)
• The evaluation of the IED identified a number of broad areas where the operation of the
legislative framework might be improved. The Inception Impact Assessment published
on the Better Regulation Portal set out some specific aspects.
• Supporting study to the official impact assessment – will provide the necessary
analytical background to the Commission’s impact assessment
• Contractor team: led by Ricardo and supported by Wood, Vito, E3M and Trinomics
Objectives of the impact assessment study
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IA support studyCommission timeline
Revision of the IED impact assessment policy process with
support study adhering to the better regulation guidelines
Define and clarify problem definition
Identify possible EU level actions (long list)
Develop baseline scenario
Develop policy options (shortlist)
Assess impacts of options
Compare options to identify preferred option
2019-2020
Evaluation of the IED→ Commission Staff Working Document
SWD(2020)182 final
Co
nsu
ltati
on
sand r
esearc
h
2020-2021
Impact Assessment of the IEDMar 2020 - Inception Impact Assessment
Jul 2020 to Jul 2021 – Support study
Dec 2020 to Apr 2021 – Consultations
~End 2021
Legislative proposal
for revision of the IED
Consultations
Support study
1615 December 2020ED13995Public© Ricardo plc 2020
1a
The environment is polluted (zero pollution ambition)
1b
The environment is polluted(non-toxic environment)
2
Climate crisis is happening (carbon neutrality at EU
level)
3
Natural resources are being depleted
(circular economy)
4
State-of-the-art techniques cannot respond in a satisfactory manner
(deploy breakthrough technologies)
5
Public access to information
(empower citizens, etc.)
6
Excessive burden may affect efficiency of policy (ensure proportionality of
EU law)
Problem areas under consideration in the impact assessment
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• IED Impact Assessment – Overview
• Summary of problems and policy options being considered for revision of
the IED – 7 short presentations
• Impact assessment steps and consultation methodologies used
(Tim Scarbrough, Ricardo)
• Q&A
• AOB/ wrap up/ close (DG ENV)
1815 December 2020ED13995Public© Ricardo plc 2020
Presentations and Q&A
Tim Scarbrough, Ricardo
Rob Whiting, Wood
Toon Smets, Wood
Dirk Nelen, Vito
Alfredo Lopez, Ricardo
Harry Smith, Ricardo
Tim Scarbrough, Ricardo
Questions
Questions
Questions
Questions
1915 December 2020ED13995Public© Ricardo plc 2020
• A.i. Not all agro-industrial activities that are polluting the environment are covered by the IED
• A.ii. BAT-AELs are not achieved
• A.iii. Lack of clarity and guidance for permitting processes
• A.iv. Varied interpretation of enforcement and insufficient guidance
• A.v. Varied interpretation and not using latest techniques for monitoring and reporting
• A.vi. Agro-industrial activities continue to contribute to transboundary pollution
A. Overview of problem area
Area #1.a: The environment is polluted (zero pollution ambition)
2015 December 2020ED13995Public© Ricardo plc 2020
Issue Options
B.i. Expansion of scope of the IED and
revision of capacity thresholds
• Adding new activities such as intensive farming, mining/quarrying
industries including extractive waste, upstream oil and gas
industries (extraction), more complete coverage of battery
production and recovery
• Revising capacity thresholds for IED activities 1.1, 2.3 (b), 5.2, 5.3
b, 5.4, 6.2, 6.6
• Widening of activities for cold rolling, forging presses, shipyards
• A tailored permitting framework might be worth considering for
intensive rearing of animals
B.ii. Revisions to increase restrictions • Amending/ tightening conditions in Article 15(4); delete flexibilities
in Article 15(3); stricter regime for indirect releases of waste water;
and clarification to Article 18 concerning emission to water when
standards aren’t met
B.iii. Clarification and guidance for permit
process
• Clarifying and providing guidance on articles 16, 22, 23;
harmonising definition of co-incineration
B. Main issues being investigated
Area #1.a: The environment is polluted (zero pollution ambition)
2115 December 2020ED13995Public© Ricardo plc 2020
Issue Options
B.iv. Revisions to improve enforcement • Amending Article 23 to allow competent authorities to close non-
compliant plants, and elaborate Article 79 on penalties for
infringements; implementation support services
B.v. Improvements on monitoring and
reporting
• Integrating new technologies (e.g. real time monitoring, remote
sensing data, etc.)
• Extending the scope of monitoring/ reporting with installations
granted Article 15(4) derogations
B.vi. Improvements in transboundary
cooperation
• Amending Article 26 for greater cooperation and harmonisation
between MS
B. Main issues being investigated
Area #1.a: The environment is polluted (zero pollution ambition)
2215 December 2020ED13995Public© Ricardo plc 2020
• Characterising the status quo, incl.
environmental pressures, barriers preventing
effective implementation, harmonisation and
cooperation, the use of existing guidance
• Exploring views on additional legal
requirements and EU inspector body
• Gathering evidence of potential impacts on
opex, capex, and admin costs;
competitiveness and trade; the environment/
pollution
• C.i. Multiple choice questions
• C.ii. Open text feedback
C. Method of inquiry
Area #1.a: The environment is polluted (zero pollution ambition)
2315 December 2020ED13995Public© Ricardo plc 2020
• A.(i) Inconsistencies between IED and closely related legislation may be acting as a barrier for the
EU to achieve the zero-pollution targets under the EU’s Green Deal
– Insufficient coverage of chemicals of concern (SVHC, POPs) in BREFs and BAT Conclusions
– New SVHCs added to REACH are not being captured or managed within IED production
processes
– Lack of alignment between IED and the Water Framework Directive - alignment needed
especially for priority substances and atmospheric deposition.
A. Overview of problem area
Area #1.b: The environment is polluted (non-toxic environment)
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B. Main issues being investigated
Area #1.b: The environment is polluted (non-toxic environment)
Issue Options
B.i. Alignment with REACH, Water
Framework Directive and POPs
• Prohibiting the manufacture and use of SVHCs within
industrial settings where BAT identifies safer alternatives.
• Requiring operators to move to safer chemicals
continuously, as part of the operator’s ‘resource efficiency
and circular economy plan’
• Including POPs in the BREF process
B.ii. Need for Chemical
Management Systems (CMS)
• Obligation for operators to have a chemical management
system to track, quantify and manage hazardous
chemicals, including developments under related
legislation.
• The CMS should as a minimum include SVHCs, POPs,
priority substances and substances added to the Watch
List under the Environmental Quality Standards Directive.
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• Characterising the level of use of CMS,
ECHA’s risk assessment tool, etc.
• Exploring impacts of measures on opex and
admin costs, pollution from toxic substances,
competitiveness, trade, employment, prices
• Seeking suggestions for legislative alignment,
understand status quo e.g. treating waste
water, etc.
• C.i. Multiple choice questions
• C.ii. Open text feedback
C. Method of inquiry
Area #1.b: The environment is polluted (non-toxic environment)
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Questions
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A. Overview of problem area (1/2)
Area #2: Climate crisis is happening (carbon neutrality at EU level)
GHG emissions by main sector, EU-27+UK (source: EEA, 2020)
• Since 1990, GHG emissions
in the EU have been steadily
declining, with emissions in
the EU-27 falling to 24%
below 1990 levels in 2019.
• The largest decrease in
emissions in absolute terms
occurred in energy supply and
industry
• In spite of the good progress in
reducing GHG emissions and
decarbonising the EU economy,
substantial reductions will be
needed for the EU to become a
climate neutral economy by
2050.
2815 December 2020ED13995Public© Ricardo plc 2020
• IED implementation has not been effective in contributing to GHGs emission mitigation (not its
primary objective). However, identifying GHG emissions abatement and energy efficiency
techniques is within the scope of the IED for all sectors and a number of BAT and BAT-AEPLs on
energy efficiency have been established.
• Drivers:
– GHG emissions from installations within the EU ETS are not regulated under the IED -
exemption under Article 9(1)
– Energy efficiency BAT-AEPLs set in BREFs and BATC are not interpreted as mandatory
– Though indirectly covered (through energy efficiency), GHG emissions and mitigation are
typically omitted from BREF reviews (among Techniques, Emerging Techniques or in BAT-AEL
setting)
• There has so far been little investigation into the potential of the IED to support industry
decarbonisation and this merits further reflection (IED evaluation). Little attention has been given
to date to the synergies that may be achievable through decarbonisation techniques other
than those related to energy efficiency.
A. Overview of problem area (2/2)
Area #2: Climate crisis is happening (carbon neutrality at EU level)
HLG on energy-intensive industries:
“The IED permitting process should
be adapted to support GHG
abatement measures in energy-
intensive installations throughout
the transition.“
• In the medium/long-term, avoiding interaction between ETS and IED
will become impossible: future breakthrough technologies will
contribute to both carbon neutrality and pollutant emission reduction.
Once viable, such technologies would qualify as BAT, and IED would
foster their roll-out and promote a level playing field.
2915 December 2020ED13995Public© Ricardo plc 2020
B. Main issues being investigated (1/2)
Area #2: Climate crisis is happening (carbon neutrality at EU level)
Issue Options
Expansion of scope of the IED • Include additional industrial and agro-industrial activities
generating GHG emissions in the IED scope (e.g. cattle,
mining, full coverage of landfills, including methane
recovery) (links with Problem 1a)
Promoting synergies to deliver
pollution abatement and GHG
emission reduction
• Establishing a trade-off/compensation mechanism to
promote technological and investment synergies to
deliver pollution abatement and GHG emission reduction.
For example: grant longer deadlines for the
implementation of pollution abatement BAT, if GHG
reducing technologies are also being implemented.
Integrating BAT on GHG and setting
GHG emission and/or energy
efficiency minimum requirements
IED permit conditions to include
GHG ELVs and/or energy efficiency
standards
• See next slide
3015 December 2020ED13995Public© Ricardo plc 2020
B. Main issues being investigated (2/2)
Area #2: Climate crisis is happening (carbon neutrality at EU level)
Issue Options
Integrating BAT on GHG
and setting GHG
emission and/or energy
efficiency minimum
requirements
IED permit conditions to
include GHG ELVs
and/or energy efficiency
standards
• Deleting the provision that exempts (agro-) industrial plants from setting GHG
ELVs in permit conditions if they are regulated by the EU ETS (IED Article 9(1)).
• Identify GHG as mandatory key environmental issues (KEIs), so that GHG
emissions are considered when identifying BAT for decarbonisation
• Identify decarbonisation BATs and set BAT-AELs for GHG emissions, so that BAT-
based GHG ELVs are set in permit conditions
• Set directly binding GHG emission limits and/or energy efficiency standards in the
IED, with a long-term view, in line with EU climate neutrality targets adopted as
part of the Green Deal
GHG as KEIs
Decarbonisation BAT
BAT conclusions / BAT-AELs
for GHG emissions Permit GHG ELVs / energy efficiency
standards (BAT based or general)
3115 December 2020ED13995Public© Ricardo plc 2020
C. Method of inquiry
Area #2: Climate crisis is happening (carbon neutrality at EU level)
Multiple choice questions
Open text feedback
• Added benefit of the IED for further GHG emission reductions by setting mandatory ELVs
• Exploring impacts of measures on:
• GHG emissions and energy efficiency (added value of identifying BAT and BAT-AELs /
setting ELVs)
• investment requirements - how future investments related to decarbonisation will impact
the necessary investments required to fulfil BAT (environmental pollution)
• Competitiveness, trade, consumer prices
• administrative activity and costs
• Seeking additional evidence on the significance of the impacts and/or the status quo
3215 December 2020ED13995Public© Ricardo plc 2020
Questions
3315 December 2020ED13995Public© Ricardo plc 2020
Break
3415 December 2020ED13995Public© Ricardo plc 2020
• A.(i) The IED has not been very effective in addressing resource efficiency and circular economy
aspects
– Quantitative resource efficiency BATs that are expressed as BAT-AEPLs, not binding in some
Member States
– IED does not require monitoring of plant-level measures for improvement of resource efficiency
in the value chain
– BREFs currently do not consider sufficient information that allows for mutual/ reciprocal benefits
from cross sector effects, outputs and inputs (Industrial Symbiosis)
A. Overview of problem area
Area #3: Natural resources are being depleted (circular economy)
3515 December 2020ED13995Public© Ricardo plc 2020
B. Main issues being investigated
Area #3: Natural resources are being depleted (circular economy)
Issue Options
B.i. Making resource efficiency
BAT-AEPLs binding
• Revisions to make resource efficiency BAT-AEPLs binding
in the same way as BAT-AELs
• Considering mandatory and binding energy efficiency
BATs and BAT-AEPLs in BAT Conclusions, regardless of
whether a plant is covered by EU-ETS
B.ii. Introducing reporting
obligations for resource efficiency
and circular economy
• Establishing an operator ‘Resource Efficiency and Circular
Economy Plan’ through BAT 1 on EMS of BAT
Conclusions; aimed at organising and strengthening
provision to promote/ require the continuous improvement
of resource efficiency at the plant level
B.iii. Promotion of industrial
symbiosis
• Revisions to: (i) promote industrial symbiosis through
national plans; (ii) to support EU guidance on good
practices and information included in BREFs
3615 December 2020ED13995Public© Ricardo plc 2020
• Characterising how resource efficiency BATs
are considered in permit conditions;
• Exploring impacts of measures on the use of
resources; opex, capex and admin costs;
competitiveness, employment, consumer
prices
• Primarily to learn about measures promoting
industrial symbiosis
• C.i. Multiple choice questions
• C.ii. Open text feedback
C. Method of inquiry
Area #3: Natural resources are being depleted (circular economy)
3715 December 2020ED13995Public© Ricardo plc 2020
• A.i. Slow uptake of innovation in BREFs & BAT conclusions
– BREF reviews (life cycles) are slow
– BAT-AEL are ‘backward looking’ and set every 10 or 12 years
– BREF reviews focus on existing BATs being used
– There are no/few technology suppliers/developers in the BREF TWGs
• A.ii. IED not promoting innovation sufficiently (Emerging Techniques)
– No evidence of effective action taken by Member States under Art. 27 IED to promote
development and application of emerging techniques; no Commission guidance published
– Art 15(5) derogation used in very limited occasions
A. Overview of problem area
Area #4: State of the art techniques cannot respond satisfactorily to
problem areas #1 to #3 (deployment of breakthrough technologies)
3815 December 2020ED13995Public© Ricardo plc 2020
B. Main issues being investigated
Area #4: State of the art techniques cannot respond in a satisfactory
manner to problem areas #1 to #3 (deployment of breakthrough
technologies)
Issue Options
B.i. IED not promoting Emerging
Techniques
• Current impact of BREFs on innovation
• Revision of IED (Art 15(5)) to facilitate development and testing of
emerging techniques
B.ii. BREF cycles are slow and time-
consuming
• How often permits are/should be reviewed for BAT
• How often BATs are/should be published/revised
B.iii. Considering the feasibility and
opportunity of shorter BREF cycles
or long-term BAT-AELs
• Shorter BREF cycle, e.g. to allow for more rapid deployment of
innovative decarbonisation technologies
• Establish stricter long-term BAT-AELs e.g. 10-year timeframe for
more ambitious environmental performance levels towards
performance at lower BAT-AELs
B.iv. Revisions to avoid “locking-in”
existing good rather than best practice
(best performers)
• Upscale and formalise the Industrial Emissions Innovation
Observatory as a platform monitoring the technology readiness levels
of innovative and breakthrough technologies. Reaching an advanced
TRL would lead to triggering of BREF reviews
• More systematic coverage of emerging techniques in BREFs
• Dynamic BATs and BAT-AE(P)Ls to reflect ‘Best Not yet Available
Techniques’ (BNAT)
B
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• Exploring the level and type of impact of
potential measures (such as long-term stricter
BAT-AE(P)Ls, formalising the Innovation
Observatory, etc.)
• Seeking additional evidence on the
significance of the impacts and/or the status
quo
• C.i. Multiple choice questions
• C.ii. Open text feedback
C. Method of inquiry
Area #4: State of the art techniques cannot respond in a satisfactory
manner to problem areas #1 to #3 (deployment of breakthrough
technologies)
4015 December 2020ED13995Public© Ricardo plc 2020
Questions
4115 December 2020ED13995Public© Ricardo plc 2020
• Aspects within the IED could be enhanced to improve public access to information and
public participation.
– (A.i) Heterogenous approaches between and within Member States when providing public
access to information, various formats making identifying relevant information potentially
challenging.
– (A.ii) Currently, there is insufficient information made publicly available to monitor the impact of
Art. 15(4) derogations.
– (A.iii) Insufficient public access to information on emissions monitoring, with respect to Article
24(3) of the IED, enhancing the links between the IED and the E-PRTR could enhance public
access to information of emissions.
– (A.iv) Art. 24 provisions do not cover all permitting procedures (e.g. there is no requirement to
invite the public to participate in cases where a permit is updated to reflect BAT conclusions).
A. Overview of problem area
Area #5: Private individuals have limited opportunities to get
informed on and take action regarding impacts caused by large
industrial and agro-industrial plants (empower citizens, etc.)
4215 December 2020ED13995Public© Ricardo plc 2020
B. Main issues being investigated
Area #5: Private individuals have limited opportunities to get
informed on and take action regarding impacts caused by large
industrial and agro-industrial plants (empower citizens, etc.)
Issue Options
B.i. Revisions to harmonise
approaches between and within
Member State
• Amend IED Article 24 to state that ‘the competent authority shall
make available [permits] to the public by publishing open-access
on the internet’.
• Require a publicly available uniform permit summary and a clear
overview of permitting process, via new provisions to the IED.
B.ii. Revisions to enhance links
between IED/E-PRTR to enhance
public access to information
• Link the IED Article 24(3) requirement to provide public access to
information on emissions monitoring with reporting to the E-
PRTR.
• Formalise the legal basis of EU Registry.
B.iii. Revisions to make the results of
emission monitoring available for
specific derogations granted under
IED Article 15(4)
• Ensure that information to monitor the impact of Art. 15(4)
derogations is made publicly available, amending the legal scope
of the IED.
B.iv. Revisions to widen the scope of
public participation under the IED to
all permitting procedures
• Revisions to widen the scope of public participation under the
IED to all permitting procedures, including permit updates,
particularly when expected to have a significant environmental
impact.
4315 December 2020ED13995Public© Ricardo plc 2020
• C.ii. Open text feedback
• Seeking additional information on the reasons
why more information is not made available
now and associated potential costs, and any
other factors that may affect public
participation
• C.i. Multiple choice questions
• Characterising the availability and access to
information in the status quo
• Exploring impacts of measures, especially on
admin costs
C. Method of inquiry
Area #5: Private individuals have limited opportunities to get
informed on and take action regarding impacts caused by large
industrial and agro-industrial plants (empower citizens, etc.)
4415 December 2020ED13995Public© Ricardo plc 2020
• A.i. Excessive administrative Burden
The evaluation made it clear that in general no excessive burden was identified. Provisions may need
clarification or simplification to reduce unnecessary burden (incl. but not only due to internal
overlapping provisions in the IED)
• A.ii. Incoherence between Industrial Emissions policy and related environmental policies
There may be overlapping provisions between the IED and other pieces of European environmental
legislation (e.g. the EU-ETS)
A. Overview of problem area
Area #6: Excessive burden may affect efficiency of policy (ensure
proportionality of EU law)
4515 December 2020ED13995Public© Ricardo plc 2020
B. Main issues being investigated
Area #6: Excessive burden may affect efficiency of policy (ensure
proportionality of EU law)
Issue Options
B.i. Conflicting operating regimes
internally within the IED leads to
excessive burden
• Rationalise IED minimum requirements for LCPs (Annex V + LCP
BATC), including averaging periods
• Rationalise IED minimum requirements for WI plants (Annex VI + WI
BATC)
• Clarify terminology for WI plants on effective operating time and
normal operating conditions
B.ii. Interaction of IED and EU-ETS • There is currently a lack of alignment in how combustion plants are
defined under the IED (>50 MW, below this regulated by the MCPD)
and the EU-ETS (>20MW).
• In light of policy options under Problem 2 to remove Article 9 of the
IED, future developments of lack of alignment will be investigated
B.iii. Interaction of IED and legislation
relating to accidents and
environmental damage
• There may be overlapping burden between Article 7 of the IED
relating to accidents and provisions of the Seveso Directive (Article
8 on accident prevention and Article 12 on emergency plans), and
the Environmental Liability Directive (Article 6 and Article 7)
4615 December 2020ED13995Public© Ricardo plc 2020
– Exploring overlaps between IED and different
regulations and the resulting burden
– Considering impacts of measures, especially on
admin. costs
– Seeking additional information on the current
administrative costs and most burdensome aspects
associated with the permitting framework
• C.i. Multiple choice questions
• C.ii. Open text feedback
C. Method of inquiry
Area #6: Excessive burden may affect efficiency of policy (ensure
proportionality of EU law)
4715 December 2020ED13995Public© Ricardo plc 2020
Questions
4815 December 2020ED13995Public© Ricardo plc 2020
• IED Impact Assessment – Overview
• Summary of problems and policy options being considered for revision of
the IED – 7 short presentations
• Impact assessment steps and consultation methodologies used
(Tim Scarbrough, Ricardo)
• Q&A
• AOB/ wrap up/ close (DG ENV)
4915 December 2020ED13995Public© Ricardo plc 2020
Describe problems
• Define and clarify the problems to be addressed
Option long list
• Desk-based review
• Structure policy options according to the drivers/objectives that they target
Develop options
• Develop shortlist of policy options and describe in more detail
• Screening criteria (legal feasibility, technical feasibility, effectiveness and efficiency, proportionality, EU added value, coherence)
Assess impacts
• Screen impacts (relevance, significance, likelihood, importance for horizontal EC objectives)
• Quantify economic, environmental, social impacts – bespoke calculations, standard cost model
• Assess other impacts qualitatively (likelihood, stakeholders impacted, scale etc.)
Compare options
• The balance of economic, environmental and social impacts
• The effectiveness, efficiency, coherence and proportionality of options
• Trade-offs and synergies (e.g. among various stakeholder groups)
Process for each problem area
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Modelling work
1.Economic/
Environmental
modelling
2.Case studies
1.a. 2050 baseline • Baseline modelling, including overall macroeconomic
scenarios, will be produced using the GEM-E3 macro-
economic model. This will be based on work carried out with
DG CLIMA- DG ENER
• Economy-wide modelling complemented by more detailed
bespoke (off-model) calculations that reflect sufficient
granularity of the IED activities to assess impacts
• A Standard Cost Model approach will be developed to cover
net impacts on admin. burden
• Bottom-up data collection and quantification of e.g. additional
activities proposed to be brought inside the scope of the IED
and their impacts
• Bring together a set of inputs to use as package for main
CLIMA/ENER overall climate scenario modelling by using
case studies and/or an IED overview from on-going study
2.a. Highly energy intensive
industry e.g. steel
1.b. Bespoke modelling of
key indicators/ impacts
1.c. Policy scenario for
CLIMA/ENER modelling
• Identification and characterisation of 2-3 IED/BREF sectors
as case studies drawing on the targeted stakeholder
consultation (survey and interviews)2.b. Low energy intensive
sector e.g. food processing
2.c. Intermediate sector if
possible
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• Provide opportunity to relevant
stakeholders to contribute to the
impact assessment
• Build on and update information
collected as part of the
stakeholder engagement
activities undertaken for the
evaluation of the IED
• Validate the problems defined.
• Gather stakeholder opinion on
the proposed policy options, in
particular any data and/or
qualitative input concerning the
expected impacts of the policy
options considered, where
relevant taking into account
simplification or administrative
burden issues
Project tasks
Stakeholder consultation objectives
Stakeholder groups
Public authorities
Industry
NGOs
Citizens
Workers associations
EC/ other EU services
/ expert groups
Third countries
with links to IED
Academia/ research
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Project tasks
The main stakeholder consultation activities
1) open public consultation
2) targeted stakeholder consultation
3) stakeholder workshops
Dec 2020
Open public
consultation
Workshop 1
Jan 2021 Targeted
stakeholder
surveyFeb 2021
Stakeholder
phone
interviewsMar 2021
Apr 2021 Focus groups
May 2021 Workshop 2
Target: Public Target: specialist views
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• Joint OPC: IED and E-PRTR impact assessments
• Gather views (and data) on:
– The problem definition (scale of the problem and scope of those affected)
– EU added value
– Objectives and level of policy ambition
– Available policy options (and suggestions for alternatives to those suggested)
– Initial screening of impacts related to the policy options considered
• Target audience: 1st part: general public 2nd part: any with more expertise
– (specialist views please use the targeted consultation)
• Platform: online on the Commission’s “Have your say” website
• Languages: English, French and German
• Dates: expected launch late December 2020
– Will be open until 22 March 2021
– (12 weeks excluding Christmas/ New Year)
Project tasks
Open public consultation (OPC)
Illustration
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• Survey dedicated to IED impact assessment
• Target audience: EU level actors, national and sub-national authorities, industry trade
associations, business and economic actors, technical experts, academia and
researchers, and civil society organisations.
• Platform: online – link will be circulated – you are welcome to forward it
• Language: English
• Dates: Expected launch: early January
– Will be open until 22 March 2021
Project tasks
Targeted stakeholder survey (TSS)
Illustration
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• Stakeholder interviews by phone:
– By invitation
– Follow-up to some responses to targeted survey to:
• (1) seek more specific feedback on options
• (2) fill specific data gaps identified for the impact assessment
– Will run over a three-month period (partially in parallel with the TSS)
• Stakeholder focus groups:
– By invitation
– Follow up to the targeted survey to gather more information as needed
– Held online, each involving 10-12 stakeholders representing national authorities,
industry and non-governmental organisations.
• Stakeholder workshops:
– 1: [today] to raise awareness and announce consultations
– 2: [early summer] to present preliminary findings and gain feedback
Project tasks
Further targeted stakeholder engagement through interviews, focus
groups and workshops
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Questions
James Tweed
Tim Scarbrough
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IED revision
AOB/ Wrap-up & Next Steps/ Close of
the Workshop
Aneta Willems, HoU DG ENV C4
First workshop