Proposal for an Industrial Emissions Directive: Priorities of European engineering industries for second reading
Published: 17 February 2010
Policies & Issues: Environment
Notwithstanding that some adaptations following the entry into force of the new Lisbon Treaty, and especially changes related to the new comitology procedure, still have to be clarified before the Council will adopt its final position at first reading, Orgalime would like to provide its comments and proposals on the Council Common Position (document 11962/09) of August 2009 with a view to the upcoming second reading in the European institutions.
Our industries fully support the environmental objectives of the existing IPPC directive, its integrated approach to address emissions occuring from industrial installations at local level and are committed to a proper implementation of the directive in member states.
In general, Orgalime feels that the Common Position of August 2009 strikes a balanced compromise between the initial Commission proposal, the European Parliament’s first reading report and the different views of member states delegations in the Council in a number of areas that are of key relevance for an improved implementation of the directive.
In particular, the appropriate level of flexibility for emission limit values, the maintaining of the Seville process with the indispensible involvement of technical experts for the development of BAT-BREF documents and the re-setting of the scope of the directive are ways forward to guarantee both, a high level of protection of the environment and human health and the necessary level playing field for our industries that have to face ever changing legislations in a variety of sectors.
However, we invite the European institutions to settle some remaining aspects concerning publication of information, the criteria for determining the frequency of site inspections, the necessity to carry out an impact assessment if the Commission wishes to depart from technical evidence for the adoption of BAT decisions and the introduction of a risk based approach for site remediation.