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Upcoming reporting according to Decision 2012/795/EU

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European Commission, DG Environment C.4

Industrial Emissions Unit ENV-IED@ec.europa.eu

Legal situation

• Basic reporting obligations contained in IED e.g. Chapter III and Articles 51, 55, 59, 72

• Type format and frequency to be set in secondary legislation

• Commission Implementing Decision 2012/795/EU set more detailed requirements for 2012-16.

• Desirable to consider the value and appropriateness of requirements for the future

General reflections

Appropriateness:

• Frequency

• Detail of reporting

Use of the data:

• Cross-comparisons between different datasets (e.g. E-PRTR, LCPs, WIs, IED installations)

• Assessments such as policy evaluation

• Quantify IED installation emissions to water and air

• Impact of BAT conclusions

Decision 795 - contents

ANNEX I - (by Sept 2014)

Questionnaire on the implementation of Directive 2010/75/EU

Annex II - (by Sept 2017)

Four modules:

MODULE 1 — Implementation update

MODULE 2 – Information on individual installations

MODULE 3 – Sectoral spotlight

MODULE 4 – Minimum requirements for WI and SE

Annex 1 — IMPLEMENTATION One-off – situation in 2013

Required information on: • non-compliance,

• use of BAT for permit conditions,

• ELVs and monitoring requirements,

• GBRs,

• developments in BAT,

• reconsideration of permit conditions,

• site closure,

• environmental inspections,

• public access to information

• emerging techniques.

Subsequent updates covered by Annex II module 1

Annex II

Four modules set out reporting requirements

Details of these requirements previously described

The following slides give for each current module a view on:

• Complexity

• Potential uses of the reported information

• Issues for reflection on a possible future reporting Decision.

Implementation update (Module 1)

Administrative requirements:

Straightforward.

Possible uses:

Confirmation of correct and uniform application of IED (implementation monitoring). Information on areas where changes or clarifications are needed.

Possible issues:

Frequency

Number of questions

Level of detail of questions and answers

Information on individual installations (Module 2 - Registry)

Aspects covered:

Installation name, reference numbers of IED installation / E-PRTR Facility, geographic location, activities covered, responsible competent authorities and permit information.

Reflections:

• Straightforward but essential information for all other modules.

• Annual updating seems essential.

• Information on numbers of installations in different activity categories paramount for evaluating effectiveness of reduced environmental impacts per sector!

Coverage envisaged:

• WI falling under IED Annex 1 will be reported as IED installations

• All WI plants (IEDs and non-IEDs) will report, among other things,

their nominal capacity and the type of waste they incinerate.

• Queries will enable the different groups defined by the legislation

to be distinguished .

• (Note: Module 4 IED has a wider scope than Annex 1 IED. A

solution is needed for the Registry to gather data for all WI plants

under Module 4)

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WI installations (Module 2 - Registry)

Need for reflection on incorporation of other facilities in the longer term. For example:

1. Refineries (Implementing Decision 2014/768/EU)

2. Seveso establishments

In contrast it is currently envisaged that the following types of facilities would not be included in the registry:

Medium Combustion Plants

SE installations under Chapter V of the IED

Other installations (Module 2 - Registry)

Possible issues:

• Frequency - annual

• Coverage

• Provision for the registry to be the reference dataset of E-PRTR reporting, LCP reporting, WI plants

• Annex with specific data fields to be reported (similar to Annex 3 of the E-PRTR Regulation and table of module 2 of 2012/795)

Registry (Module 2)

Sectoral Spotlight (Module 3) Aspects covered:

1. Permit conditions (Article 14)

2. Stricter permit conditions (Articles 14(4) and 18)

3. Setting permit conditions in the absence of relevant BAT conclusions (Article 14(5) and (6))

4. Emission limit values, equivalent parameters and technical measures (Article 15)

5. Monitoring (Article 16)

6. Reconsideration and updating of permit conditions (Article 21)

7. Other

Administrative requirements:

Relatively complex and detailed reporting efforts (level of individual BATc's) required to generate added value.

Possible uses:

Feedback to CAs and EIPPCB for revisions of BATc;

Increased understanding overall impact and value of BATC for CAs;

Comparison of approaches by CAs;

Assessment of impacts;

Assessing overall compliance with BATc obligations.

Sectoral Spotlight (Module 3)

Varying sectoral focus = fluctuating reporting efforts!

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Future sectoral reports (Module 3)

Possible issues:

Does it make sense to have sectoral spotlight?

Is it better to provide information on updated permits each year?

Most questions are not sector specific.

Frequency

Level of detail

Sectoral Spotlight (Module 3)

Administrative requirements:

Article 51, 55 and 59 reporting is required in the IED itself. WI relatively complex. SE limited.

Possible uses:

Estimate of proportion of relevant installations above ELVs is useful to understand overall impacts.

Some information on progress to reduce these in line with goals.

Module 4 – Minimum requirements

Two categories of SE activities in IED

1. Chapter 2 IED / Annex I Category 6.7: surface treatment using organic solvents. No. of installations: 1167 (range 1 – 308 / MS) This category will be included in the registry.

2. Chapter 5 IED / Annex VII a) Part 1 describes 20 sub-categories of installations.

A total of 53,135 installations in 2013 (down from 63,282)

b) Part 2 lists individual ELVs for each of these 20 sub-categories

This category is subject to interim reporting via Excel sheets 17

Minimum requirements SE (Module 4)

Frequency of reporting?

Detail:

1. Waste incineration and co-incineration:

• Reporting of plants with different operating conditions under Art. 51?

2. Solvent Emissions

• Reporting of installations under reduction schemes and derogations?

• Reporting of list of the number of installations and their locations sufficient (link with Registry)?

Minimum requirements (Module 4)

General questions for the future

• Are requirements appropriate to Registry?

• Time period to be covered?

• Frequency of reporting Registry and other aspects?

• Level of detail?

• Questions on implementation status?

• Specific sectoral aspects or permit updates?

• Requirements relating to WI and SE?