Joint industry statement on representative EU pollution standards


The legal obligation for permitting authorities to set the emission limit value for a given pollutant at a level that
ensures that, under normal operating conditions, emissions do not exceed the BAT‐AEL, has far‐reaching
consequences. BAT‐AELs have to be implemented as ELVs and industrial installations have to comply with
those. A systematic approach to derive the BAT‐AEL as a result of the BREF review process and the data
collection performed in that context is therefore a must. A robust and transparent approach will secure
consistency for stakeholders throughout the BREF review process, as well as for regulators and operators at
permitting level. Based on both the Guidance1 published in the OJEU in March 2012 and on our combined
industrial experience, we have outlined in this paper an approach which should help deriving both ends of the
BAT‐AEL range systematically. This is crucial if one wants to preserve the integrity of IED implementation
through appropriately‐designed and truly applicable BAT conclusions, technically achievable and economically
viable BAT‐AELs.