In a position paper circulated this week, Cepi says that a series of emission limits recommended in the best available techniques (BAT) reference document will be almost impossible to achieve in a single installation.
"The emission levels associated with BAT presented in the bref do not reflect the variety of the industry in terms of age, size, raw materials, products and trade-offs... nor do they consider costs," the statement says. "You can find one or two mills meeting all the limits in the bref, but it's not possible in all mills in the immediate future," Cepi's Annick Carpentier told ENDS Daily today.
The directive stipulates that, by 2007 at the latest, emission limits for pulp and paper mills must be "based on BAT". In setting limits, authorities must "take account of" the values set out in the bref but are given wide margins of discretion depending on local conditions. But Ms Carpentier said there were already indications that the UK and Portugal would apply BAT earlier than 2007, and that Germany would apply uniform national emission limits.
"There is a risk that some local authorities may impose the reference values presented in the bref as emission limit values," the statement says. "Imposing the reference values on mills as a whole would undoubtedly jeopardise the competitiveness of the... industry." Ms Carpentier said a comparison with the equivalent guidance document in the USA showed the EU was setting "much more demanding" targets.
The bref was finalised earlier this year by the European IPPC bureau and is expected to be adopted by the European Commission soon (ENDS Daily 5 October). During talks in the stakeholder technical working group that agreed on the BAT values Cepi's objections were supported by experts from Spain and Greece, along with pulp and paper powerhouse Finland. A note in the bref points out, however, that "this minority view was not shared by most members of the group."
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