Revision of the Industrial Emissions Directive: avoiding the leap into the unknown
- Maintaining the core principles of the Directive. The current Industrial Emissions Directive (IED) framework is fit to enable the environmental transformation the European industry is undergoing. To ensure its success, it will be key to maintain the core principles that anchored the IED (definition of BAT, the “Sevilla process”, and its integrated approach). Furthermore, it will be essential to limit changes to the absolute minimum, otherwise it risks breaking a system that works and delivers.
- Respecting scopes of EU law and avoiding overburdening the Industrial Emissions Directive. Under the current regime, the “Sevilla process” is already long and complex, and a range of other environmental legislations covering industrial sectors are already in place. Therefore, a scientific and evidence-based assessment on a possible extension of the scope should be performed. It should make sure that the IED is the correct tool to address the environmental performance of new sectors/plants, and that no other legislation is in place.
- Streamlining the permit process. The IED licensing process can take a significant amount of time, which can be detrimental to investment decisions. The directive should consider setting fixed processing time that would ensure the authorities deliver a revised permit within a given timeframe.
- Keeping flexibility under current BAT-AELs ranges. The range of BAT-Associated Emission Levels and the possibility to derogate from them, if properly justified, should be maintained. Higher level of support for innovation, should be directed where further efforts would be desirable.
- Incentivising, not mandating, GHG, energy efficiency and circular economy. Greenhouse gas (GHG) emission reduction, energy efficiency and circular economy are of high importance for industry and are already accounted for in the directive and/or the BREF process. They should continue to be incentivised, but not become mandatory requirements under the IED permitting process.