1. Reference document for Energy Efficiency Michael Parth Tallinn – Estonia 27 – 28 March 2008

2. Presentation outline Why create an Energy Efficiency REF? Why a REF? What is the regulatory requirement for Energy Efficiency in IPPC? How does this fit with other legislation? Who is involved? When? ENE project and timing How the REF will develop? Questions to be considered?

3. Why create an Energy Efficiency REF? • Special request from the EC in 2001 to make better use of IPPCD: • Create a special ‘horizontal’ BREF • Focus on information and firm conclusions for energy efficiency in the revision of the BREF series • Guidance to operators and regulators on implementing energy efficiency for IPPC permits • One of the measures in ECCP to reduce GHGs

4. Why a REF? • IPPCD Art 2(11) defines for BAT: • ‘available’ techniques: ‘…in the relevant industrial sector under economically and technically viable conditions…’ • Difficult to draw BAT conclusions for the range of industries in IPPC: oil refineries to intensive farming • Some high level conclusions may be applicable to all (e.g. how energy efficiency is considered in management systems)

5. Energy Efficiency in IPPC • IPPCD Article 3: “MS shall take the necessary measures to provide that the competent authorities ensure that installations are operated in such a way that: (d) energy is used efficiently” • IPPCD Annex IV:“Considerations to be taken into account generally or in specific cases when determining BAT (…):9. the consumption and nature of raw materials (including water) used in the process and their energy efficiency”

6. Energy Efficiency in IPPC (cont.) • IPPCD Article 6.1: • Member States shall take the necessary measures to ensure that an application to the competent authority for a permit includes: • a description of the raw and auxiliary materials, other substances and the energy used in, or generated by, the installation. • IPPCD Article 9.1: • Member States shall ensure that the permit includes all measures necessary for compliance with the requirements of Articles 3 and 10.

7. Amendment to IPPCD Art. 9(3) by ETS Directive Art. 26 • "Where emissions of a greenhouse gas from an installation are specified in Annex I to Directive 2003/87/EC (…) in relation to an activity carried out in that installation, the permit shall not include an emission limit value for direct emissions of that gas unless it is necessary to ensure that no significant local pollution is caused. For activities listed in Annex I to Directive 2003/87/EC, MS may choose not to impose requirements relating to energy efficiency in respect of combustion units or other units emitting carbon dioxide on the site.(…)"

8. Energy efficiency and CO2 emissions in the vertical BREFs • There should be a thorough exchange of information on the efficient use of energy, with the aim of deriving BAT conclusions on energy efficiency for all units • For combustion plants and other units emitting CO2 on the site, MS may choose not to impose requirements relating to energy efficiency • The BREF documents should NOT include BAT associated emission levels (AELs) for CO2 • This does NOT automatically mean that all information on CO2 should be omitted from BREFs, as it may be useful in a different way

9. Who is involved in the REF? • Large TWG: ~90 members • DG JRC (EIPPCB, IE Petten, IES ISPRA) • DG ENV • DG ENTR (+ information from DG TREN) • 20 countries • MS (including 4 new MS) • 1 EFTA (Norway) • 32 Industry representatives (operators and suppliers)

10. EIPPCB • First author: Sirpa Salo-Asikainen • Finland, Oct 2004 – Oct 2006 • First draft, April 2006 • Second author: Paul Tempany • UK/EC: Oct 06 (since 2002: STM, STS) • Assistant author: Cristina Fernandez • ES/EC: March 07

11. ENE Project and timing

12. ENE REF Draft 1 • Ch 1: Types of energy, thermodynamics, identification of inefficiencies • Ch 2: Definitions of energy efficiency, system boundaries, site (structural) issues • Ch 3: Energy management and related actions. Tools: auditing, monitoring, pinch technology, benchmarking. ESCOs and public motivation schemes • Ch 4: Applied techniques: combustion, steam, power, cogeneration, waste heat recovery, etc. • Ch 5: Best Practices: conclusions

13. Proposals for new document • Refocus on: • Better use of IPPCD: Guidance on considering energy efficiency in IPPC permitting. Move non-permit issues to a separate chapter • Whole site and component systems (e.g. CAS). Fits with other EU initiatives, e.g. SAVE

14. Proposals for new document • Ch 1: Remove detail of thermodynamics to annex. Provide clear introduction to energy, efficiency and definitions of key terms. Is thermodynamics text needed? • Ch 2: Combine previous Ch 2 and Ch 3 to deal with ‘whole installation’ issues, boundaries, general cross-media effects,etc.. • Ch 3: Restructure around a clear, logical ‘component systems’ approach

15. Proposals for new document • After conclusions: • Financial: ESCOs, tax and other incentives, • Technical: off-site transport • Detail of examples, etc. in annexes

16. Conclusions and discussion points so far • Is the term ‘Best Practice’ helpful or confusing? Alternatives? • Perhaps some undisputed ‘BP’ should always apply (e.g. design for plant updating or for new plants should always optimise energy efficiency) = BAT! • Energy efficiency always has cost savings, but payback time may be long!

17. Conclusions and discussion points for the TWG • Is the proposed approach helpful? • Is a discussion of basic thermodynamics needed? • How to deal with ‘Best Practise’? • Alternatives? • Could some conclusions be applied to all IPPC installations, and how?

18. Thank you! • Contacts: • paul.tempany@ec.europa.eu • cristina.fernandez@ec.europa.eu