The Sevilla Process

The Sevilla Process is designed to agree upon what constitutes the Best Available Techniques (BAT) for pollution prevention and control.

What is the EU BREF (or Sevilla) process?

The European Commission, EU Member States and representatives of European industry and environmental NGOs gather at the European Integrated Pollution Prevention and Control Bureau, part of the EU’s Joint Research Centre in Seville, Spain. Together, they make up Technical Working Groups, which provide input into the drafting of documents known as BREFs in what is known as the “Sevilla Process”.

The Sevilla Process is designed to agree upon what constitutes the Best Available Techniques (BAT) for pollution prevention and control. Requiring polluting industry to use ‘BAT’ to reduce pollution is a central feature of the Industrial Emissions Directive (IED). Once agreed, the techniques are laid out in Best Available Technique Reference Documents, or ‘BREFs’. 

Proposals for an EU BREF Process fit for the 2050 goals of climate neutrality, zero pollution and circular economy 

The updated EU framework on industrial emissions is paving the way for the much-needed transformation of industry towards the EU 2050 goals of climate neutrality, zero-pollution, and circular economy. The process of developing the EU Best Available Techniques reference documents (BREFs), that form the basis for the environmental permitting of the biggest industrial installations, should be adapted accordingly. We need to address the reform of the BREF process with a forward-looking approach.    

Future BAT conclusions compatible with the 2050 goals:

The BAT conclusions should determine which techniques, and under what circumstances, constitute ‘deep transformation techniques’ for a given sector; and which techniques and processes are incompatible with the transformation vision (and timeline) and should be phased-out.​

  • Any technique, e.g., involving the use of fossil fuels (or feedstock) needs to be included in the BAT conclusions as a so-called ‘negative BAT’, accompanied by a mandatory decommissioning or phase out plan (e.g., BAT2 and BAT3 in CAK BREF).​
  • The new innovation centre on industrial transformation and emissions (INCITE) shall be mandated to provide an opinion, that will subsequently be examined by the Forum, on which techniques qualify as ‘deeply transformative’ for a given sector. ​
  • Minimal expectations should be set in the BREF guidance as to the meaning of what ‘deeply transformative’ is.

An outcome-oriented approach is needed. The BREF guidance shall further provide Key Performance Indicators (KPIs) as to what expectations/outcomes the BAT conclusions shall deliver at installation (or sector) level.​

  • IED Art.1, Art. 14a (EMS) emphasize the dynamic nature of BAT and the aim to continuously improve the environmental performance of installations.​
  • The EMS shall include ‘environmental policy objectives’ for the ‘continuous improvement of the environmental performance and safety of the installation’, based on ‘objectives and performance indicators’, and those are to be developed on the basis of the so-called ‘benchmarks’ set out in relevant BAT conclusions (IED Art. 14a(b)).​
  • The BREF guidance shall provide clarity as to what common ‘headline KPIs’ should apply across IED activities.​
  • The KPIs, or outcome-oriented indicators, should be an integral part of the BREFs

The process needs to be fast-tracked if the 8-year review cycle and dynamic nature of BAT is to be respected. There are currently no tools to factor in the dynamic aspect of BAT determination, or to speed-up the information exchange.​

The reviews of the BREFs for energy-intensive sectors (steel, cement) should be prioritised, in line with IED Article 13(5) (highest potential to improve the protection of the environment), but to also ensure that the updated BAT conclusions will be taken up in the Transformation Plans (as these sectors should produce their plans, in priority, by 30 June 2030). A different governance model is needed:​

  • Consensus-finding should be fact-checked against compatibility with the 2050 transformation vision​
  • Rules enabling a balanced representation of interests, and a conflict-of-interest policy should be put in place​
  • Industry frontrunners (technique providers and operators) should be adequately represented instead of sidelined by well-established industrial associations

For more info see the paper and presentation on the BREF process reform.

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