The European Environment Agency's 2016 Air Quality Report estimates that air pollution is responsible for more than 430,000 premature deaths in the EU every year.
Sensitive and vulnerable groups such as pregnant women, children, the elderly and those already suffering from respiratory and other serious illnesses or from low income groups are particularly affected. Nine out of ten European city dwellers still breathe air that the World Health Organization (WHO) considers to be harmful to health.
The EEA Report: Costs of air pollution from European industrial facilities 2008-2012 estimates that air pollution from the largest facilities covered by the Industrial Emissions Directive leads to health and environmental costs of between €65 and €211 billion every year.
A special series of EEB Factsheets on Air Quality (zip file) provides more information on the health and financial costs of air pollution, including from industrial activities.
Industrial installations emit large amounts of air pollutants in Europe and are regulated in the EU by the Industrial Emissions Directive (IED). These installations are located across Europe and air pollution is often carried over long distances and across international borders. The report 'Europe's Dark Cloud' exposes how pollution resulting from coal combustion is carried through the air over long distances, inflicting health costs and premature deaths in neighbouring countries.
The EU Pollutant Release and Transfer Register (E-PRTR) publicly reports release data for 91 pollutants emitted into the air every year by activities covered by the IED.
Of particular concern to human health and ecosystems are emissions of sulphur dioxide (SO2), particulate matter (PM), nitrogen oxides (NOx), carbon dioxide (CO2), volatile organic compounds (VOCs), persistent heavy metals such as mercury, cadmium and lead, and persistent organic pollutants such as dioxins and furans (PCCD/F).
NOx, PM, SO2, certain VOCs and ammonia (NH3) are the most damaging pollutants in purely economic terms.
The European Environment Agency's Costs of air pollution from European industrial facilities report reveals that just 1% of all facilities were responsible for 50% of the total damage costs. It is also shown that 90% of costs were caused by the dirtiest 11% of all 14,325 facilities investigated.
Many other sources of industrial pollution, such as Medium Combustion Plants (with a thermal capacity of <50 MW), cause damage (in particular through dust and NOx emissions) but are not covered by the IED. Such installations are therefore not factored into this assessment, although they could apply the very same abatement techniques.
Activities covered by the IED are responsible for about a quarter of the total emissions of 17 air pollutants in the EU. However, when referring to specific pollutants, such as heavy metals, IED activities are clearly responsible for the higher share. The 2014 AMEC study for the European Commission: "Contribution of industry to pollutant emissions to air and water” provides further information.
Industry is still the largest source sector for emissions of lead, arsenic, cadmium, non-methane volatile organic compounds (NMVOC) and nickel and the second largest source of primary particulate matter, SOx and mercury emissions. Figures can be found in the European Environment Agency's update No 5/2015.
Annex II of the IED lists just 13 relevant groups of air pollutants which need to be addressed. At present only a few BREFs set effective BAT conclusions on these pollutants. Recent examples tend to focus on SOx, NOx and dust.
|Pollutant||Comprehensively covered by BREFs?||Comments|
|Sulphur dioxide (SO2)||YES||All combustion related activities|
|Oxides of nitrogen (NOx)||YES||All combustion related activities|
|Carbon monoxide (CO)||NO||In recent BREF reviews BAT requirements are indicative|
|Carbon Dioxide (CO2), other Greenhouse Gases||NO||Article 26 of the Directive establishing a scheme for greenhouse gas emissions allowance trading within the Community (EU ETS Directive) in 2003 prevents permit writers to set a limit on CO2 / other Greenhouse gases if the installation is covered by the EU ETS Directive.|
However emissions of greenhouse gases are indirectly tackled through provisions on energy efficiency. Nothing prevents the BREFs to set BAT-AELs on GHGs, it is just opposed by industry (and some Member States, on argument of “double-regulation”
|Volatile organic compounds (VOCs)||YES||Case by case e.g. combustion of process fuels of chemical industry,|
|Metals and their compounds||NO||Not specifically addressed, assumed to be covered through dust parameter.|
LCP BREF covers mercury and group of metals where co-incineration of waste occurs
|Dust, including fine particular matter||YES||Diffuse emissions not comprehensibly addressed|
|Asbestos (suspended particulates, fibres)||NO||Addressed in CAK BREF, heavily restricted|
|Chlorine and its compounds||NO||Covered in some BREFs (LCP)|
|Fluorine and its compounds||NO||Covered in some BREFs (LCP)|
|Arsenic and its compounds||NO||Not specifically addressed|
|Cyanides||NO||Not specifically addressed|
|Substances/Mixtures with CMR properties||NO||Not specifically addressed|
|Polychlorinated dibenzodioxins and polychlorinated dibenzofurans (PCCD/F)||YES||Case by case e.g. combustion of process fuels of chemical industry and waste (co)incineration|
Emissions to air can be prevented or reduced (‘abated’) by a common set of techniques available to all IED sectors. However, the effectiveness of abatement varies widely and depends on the techniques adopted by the operator. Individual techniques may be adopted alone or in combination with other options.
The BAT-AELs on air emissions are largely derived from the performance levels of existing abatement equipment currently in use in various installations. BAT-AELs are therefore not linked to what is technically achievable, but rather to a calculation based on what is already being achieved under current permit requirements.
The main justifications for low ambition are driven by considerations about fuel flexibility, costs for the operators, in rare cases environmental cross-media impacts and in even rarer cases technical reasons.
This is in particular visible when BAT-AELs for a specific pollutant are expressed in the BAT conclusions with a wide range, such as in the following format “< X – Z mg/Nm³”. In this case an emission level below X would be achieved by a more effective technique A (or a combination of technique A and another technique) while the emission level Z would be achieved by technique B, which is more commonly implemented (and/or cheaper).
It may even appear that two sets of BAT-AEL ranges are proposed, which are solely due to different techniques and not linked to the intended outcomes or performance levels to be achieved. For example, in the new 2013 BAT Conclusions for dust emissions from sinter plants, the BAT-associated emission level for dust is “< 1 – 15 mg/Nm³” for the bag filter and “< 20 – 40 mg/Nm³” for the advanced electrostatic precipitator (ESP).
In this example it is clear that the technique A (bag filter) could achieve a better abatement of dust by a factor of 40 compared to the technique B (advance ESP). The current formulation offers maximum flexibility to the polluters to choose from various technique options but is not focused on the performance outcome to be achieved.
To effectively achieve the IED’s aim of “reducing harmful industrial emissions” any BAT-AEL range should be set on outcome-focused (environmental performance) considerations only, irrespective of the technique(s) used. BREFs are not supposed to constitute a sales catalogue for various techniques. BAT performance levels should be decided on the genuinely “best” (i.e. the most effective) technique or combination of technique(s) for delivering the best possible “level of protection of human health and the environment”. In this case, this means not negatively affecting air quality.
The EEB believes BAT conclusions, in particular BAT-AEL ranges for air emissions, should be based on outcome-focussed (environmental performance) considerations only, irrespective of the technique(s) used.
We are therefore interested in, and would support, any technique most effective technique able to deliver pollution prevention, in particular for pollutants which are PBTs, pollutants covered by the National Emissions Ceilings and Ambient Air and Cleaner Air for Europe Directives. Multi-pollutant abatement options without negative cross-media effects would be preferred as emission abatement options.
Considering recent experience in BREF reviews, we are interested in gathering the following information: