1 / 51

Technical Review of the IPPC Directive: Data Gathering and Impact Assessment

This draft final project presentation discusses potential amendments to the IPPC Directive, focusing on permitting, inspection, reporting, ELVs, WFD, combustion installations, and aquaculture. It aims to collect insights, assess impacts, and develop a methodology for further amendments.

vcovington
Télécharger la présentation

Technical Review of the IPPC Directive: Data Gathering and Impact Assessment

An Image/Link below is provided (as is) to download presentation Download Policy: Content on the Website is provided to you AS IS for your information and personal use and may not be sold / licensed / shared on other websites without getting consent from its author. Content is provided to you AS IS for your information and personal use only. Download presentation by click this link. While downloading, if for some reason you are not able to download a presentation, the publisher may have deleted the file from their server. During download, if you can't get a presentation, the file might be deleted by the publisher.

E N D

Presentation Transcript

  1. Data Gathering and Impact Assessment for a Possible Technical Review of the IPPC Directive A Draft Final Project Presentation to the AG Patrick ten Brink, IEEP Supported by Samuela Bassi (IEEP), Karl Vrancken (VITO), Peter Stouthuysen (VITO), Hélène Cruypenninck (Bio) and Shailendra Mudgal (Bio) On behalf of the project team: IEEP, VITO, and Bio IPPC Advisory Group Meeting Charlemagne, Brussels 26 October 2006

  2. Structure of the Presentation • Overview of the project • Issues for potential amendments • Short comment/question slot at the end of each section • 2A Permitting, Inspection, Reporting • 2B ELVs, WFD, Sevilla • 2C Combustion installations • 2D Aquaculture • Next steps

  3. Part 1 Aims and objectives • Develop understanding of arguments for/against specific potential amendments • There is no a priori preference for legislative route • To help assess potential implications of different options: • Collect insights on country practice / data • Collect comment from MS and stakeholders on the options • Carry out a first impact assessment • analysis of economic, environmental and social impacts • Develop methodology for analysis of further possible amendments in subsequent work

  4. Part 2 Part 2 Presentation of Areas for Potential Amendment: • Short presentation of each amendment • Short comment/question slot after each grouping • Clarification of “periodically” for reconsidering the permit conditions • Clarification of “periodically” for monitoring reports • Obligation to perform regular inspections • Specific Emission Limit Values • Requirements re. discharges to water • Provision of information by Member States in the Sevilla process • Thresholds for combustion installations • Aquaculture

  5. A2 Permitting Part 2A Potential Amendment A2: permit review frequency • Issue • Article 13(1) requires Member States to ensure that competent authorities periodically reconsider and, where necessary, update permit conditions. • Problem Definition • Frequency of permit renewal is not defined, but some conditions for permit reconsideration are set by art 13 (2) • Wide range of legal requirements and practices in different MS. • Different permit lengths may lead to issues of uneven environmental protection conditions and competitiveness effects where permits review periods are ‘unduly’ long.

  6. A2 Permitting Part 2A Current Practice • Complex picture across Europe, low comparability: • Permit review periods vary - for some MS every 5 years, others every 10, others much longer. • Some MS have no legal requirement, although regular reviews may exist in practice. • Permits length also differ – eg some 4 years other 20 years • Specific treatment for different sectors • Some MS allows longer periods for installations with EMS • Interaction with other Directives, eg: groundwater Directive 80/68 requires to review authorisations at least every four years • Review processes vary - eg some countries have simplified procedures for review, others follow the procedures provided for first grant) • Fees for permits vary – eg free in NL, symbolic in Belgium, fully cost reflective in UK

  7. A2 Permitting Part 2A Options • Do nothing • +ve: flexibility to MS, no additional costs • -ve: lack of clarity, potential ‘race to the bottom’ at the expense of environmental performance • 2 Flexible frequency but common methodology for assessing length, eg based on size, sector, emission, risk, EMS, etc • 2a: within the Directive • +ve: more control but still a lot of flexibility to MS, more clarity • -ve: higher complexity, amendment required • 2b: as a separate Guideline • +ve: no amendment hence more flexibility, but more clarity • -ve: less binding, soft instrument

  8. A2 Permitting Part 2A Options • 3 Minimum frequency requirement. 3 cases: 5, 8 (= Brefs review) or 10 years. • also: Consider allowing longer/shorter length for specific categories (eg landfills, installations with EMS, etc) • +ve: clarity and enhanced harmonisation • -ve: amendment required, less flexibility, ‘one size fits all’ may not suit different countries’ real situations, risk of ‘race to the bottom’ • Additional options for the process to be followed in permit reviews • submission or application/report by operator, or request from authority if information needed • requirement for publicising the outcome of the review and the basis of the authorities decision

  9. A2 Permitting Part 2A Working Insights • Important to take into consideration interdependency between permit review and: • >> art 13(2) – may need to be clarified by guidance and best practices • >> role and frequency of inspections • >> monitoring and reporting obligations • >> BREFs revision (key issue) - v important to ensure that planned revision of BREFs is maintained • Effects of more frequent/regular permit review • installation updating according to BAT when suitable (not late) and hence better environment • more permits reviewed where only minor improvements are required (ie inefficient use of resources) and where action is required – there is a trade-off • Additional costs for more regular review will likely be smaller (ie in the order of tens of millions EUR/year for EU 15) in comparison to potential benefits, and mainly administrative.

  10. A2 Permitting Part 2A Interesting options There is an issue of clarity: it is unclear how MS should interpret review and permit length, and terminology in art 13(2) option 1 does not address this issue option 2 (a/b) could be a feasible solution Option 2 b (guidelines) has the advantage that it does not introduce amendments – although less binding Option 3 may lead to a more stringent regulation 5 years: may largely affect many MS current practices 10 years: it may not be v helpful to improve current practice 8 years: interesting because it takes into consideration Brefs reviews In general: guidance on art 13(2) may be v useful

  11. A2 Permitting Part 2A Remaining data needs • What is actual/expected average review periods in the MS to complement the legal maxima? • What Member States have put in place, in practical terms, to implement article 13(2)? • What are the mechanisms used to reconsider existing permits (eg formalised process, information required from operators, decision documents)? • What is the role of publishing information and/or public participation? • What is the relation, if any, between permit length (validity) and permit review periods?

  12. A4 Inspection Part 2A Potential Amendment A4Obligation to perform regular inspections • Issue/Problem Definition • Compliance and enforcement are an essential element of implementation but Directive has virtually no provisions on these issues • Article 14 of the IPPC Directive states that ‘operators of installations afford the representatives of the competent authority all necessary assistance to enable them to carry out any inspections’. • Does not define an inspection or state that MS should conduct inspections, what format inspections should take, their regularity or how they should fit with the rest of the enforcement proceedings conducted by a Member State. • Variety of practices adopted in MS re the regularity, approach and the obligation to complete inspections • Note - other compatible legislation does contain clear provisions re inspection eg Seveso II

  13. A4 Inspection Part 2A Objectives • To increase the emphasis on enforcement within the Directive • To make the compliance enforcement regime under IPPC more transparent, allowing citizens and civil society to engage more • To ensure an effective approach to inspection under IPPC across the EU • To avoid ambiguous requirements in the interests of better regulation • However, total harmonisation across MS is not considered achievable and is probably not desirable

  14. A4 Inspection Part 2A Options • Option 1 - Business as usual: ie non-action • Option 2 - Strengthen the compliance enforcement framework • To specify that inspection be conducted • Specify a variety of requirements Member States must meet in order to maintain an effective inspection system - ie development of a plan, programme, feedback to operators etc • MS to take into consideration provisions in Recommendation 2001/331 when conducting inspection (also under review) • Option 3 - Minimum frequency of inspection • A - Requirement that MS conduct inspections for all installations at least on an annual basis • B – On an annual basis unless a programme of inspections based on an appraisal of risks of the installations is in place

  15. A4 Inspection Part 2A Working insights • More prescriptive approach to frequency/nature of inspections may deliver more consistency and enhance compliance and confidence • MS value flexibility to take account of compliance priorities, e.g. prescriptive approach, could affect ability to target biggest problems • Competent authorities have different rights and obligations to inspect in different MS • Inspection charges also vary widely • The institutional structures set up by MS to deal with inspections vary greatly • Inspection is only one element of a compliance and enforcement system

  16. A4 Inspection Part 2A Key Impacts • Environment • Option 2 - improvement of the quality of inspection • Option 3 - improvements only if it increases the periodicity of inspection, without jeopardising quality • Costs to public authorities • Option 2 : a more thorough approach could increase time/resources for some MS, but better planning and targeting might give some efficiency savings • Option 3: likely increased number of inspections, thus more resources needed (ballpark estimate ~ €30m/year). Option 3B may mitigate • Confidence of public in environmental control • Option 2 - increased quality of inspection leading to improved performance and public information • Option 3 – positive impact so long as increase in inspection does not result in pressure on resources and reduced quality • Clarity and consistency – Both options 2 and 3 would increase linkages with other legislation and provide clarity, making more clear what is required to assess compliance

  17. A4 Inspection Part 2A Remaining Questions • Details of practical inspection approaches utilised and how these are implemented • Minimum Frequency for Inspection – does this apply, what period for which installations • Randomly – how is this applied and when • Risk Based – is this accompanied by minimum requirements? What criteria is this based upon? • Other – please specify • Programme of inspection – is this applied and how does it work? • How did MS determine their approach (options considered, costs and benefits) • How can links best be made to other elements of the Directive, e.g. permitting review cycle

  18. A3 Reporting Part 2A Potential Amendment A3:Obligation on operators to report regularly for the purposes of demonstrating compliance • Issue • Article 14 of the IPPC Directive requires Member States to ensure that operators regularly report the results of emissions monitoring to competent authorities for the purposes of demonstrating compliance • Problem Definition • Monitoring level/frequency can vary between pollutants, installations • Not clear whether the lack of definition of the term ‘regularly’ causes a problem in relation to compliance enforcement, but MS practice varies • From 2007 E-PRTR requires MSs to report annually on total mass emissions from inter alia IPPC installations

  19. A3 Reporting Part 2A Practice • MSs have a variety of approaches towards reporting on emissions – for purposes of demonstrating compliance and other reasons: • Inclusion of reporting requirements in permits; • Requirement that results of monitoring be submitted on demand; or • Annual reporting, either: • o Specifically under IPPC implementation; or • o As part of a broader annual environmental report. • Member States actively developing monitoring and reporting procedures, not least taking advantage of the opportunities provided by advances in IT, e.g. Flanders and Walloon regions, Ireland

  20. A3 Reporting Part 2A Options • Do nothing • Guidance (e.g. from the Commission or revised BREFs) on focus and frequency of monitoring, and on how monitoring results are communicated • Insert an explicit requirement in the Directive that operators report results of monitoring at least annually for the purposes of demonstrating compliance; include an explicit link to E-PRTR to secure benefit of combined reporting

  21. A3 Reporting Part 2A Issues and interesting insights • Opportunity to align frequency of operator reporting across Member States • Opportunity to align reporting requirements of IPPC with those of E-PRTR • ‘Doing nothing’ (Option 1) would miss these opportunities • New (or amended existing) Guidance (Option 2) could set a benchmark against which practice could be judged • Development of guidance could be a complex, resource intensive process • Requiring operators to report annually for the purposes of demonstrating compliance would set frequency of reporting and bring consistency throughout EU; probably only require changes in some MSs / sectors • Link to E-PRTR in order to align reporting timetables, and make the link between the two pieces of legislation • Prescriptive requirements might be seen as contrary to subsidiarity • Prescriptive approach requiring annual reporting might have a limiting effect where more frequent reporting would be beneficial

  22. Part 2B A1 ELV Potential Amendment A1Specific Emission Limit Values • Issue • The IPPC Directive requires that all permits set emission limit values (ELVs) that reflect, inter alia, BAT and local environmental conditions. • Problem Definition • No specification on how ELVs should be set. • Mostly as concentration limits. • Limited possibilities for: • Comparability • Benchmarking/eco-efficiency • Load-based limits (e.g. mass/product) might overcome this

  23. Part 2B A1 ELV Current Practice • Source: data gathering + questionnaire responses from 16 MS and 6 industry organisations • ELVs not comparable EU-wide. • Few MSs apply load based ELVs. Some of them only apply load/time ELVs (e.g. ton/year) • Sectors applied: Pulp & paper (frequently mentioned), LCP, ILF, Slaughterhouses, LVIC • Total of 29 BREFs: • 10 BREFs mention load based BAT AEL • 7 BREFs use load based emission levels to describe the current situation but not in the setting of BAT AEL. • Generally for a limited amount of processes. • Exceptions: particularly Pulp & paper, also Chlor-alkali, LVIC, Polymers • Current ELV and EPER data are not suitable for comparison of eco-efficiency without additional data.

  24. Part 2B A1 ELV Options • Option 1 - Business as usual: ie non-action • Option 2 – Guidance on ELV’s • Non-legislative approach • Option 3 – Encourage load-based BAT AELs in BREFs • Non-legislative approach • Builds on the established BREF mechanism • Option 4 – Change IPPC Directive to favour ‘load units where appropriate’ • Legislative approach: explicit or general reference in the IPPCD Art 9(3) • Option 5 – Reporting requirement for operators on actual load-based emissions • Legislative approach: incorporation in EPER/E-PRTR requirements • Purpose: collect comparable data on eco-efficiency • No direct impact on ELV-setting

  25. Part 2B A1 ELV Working insights • Load based E(L)Vs allow better eco-efficiency comparison –statement is generally supported. • Actual performance (e.g. EPER-data) instead of required performance (ELVs) may give fairer comparison. • MSs do not want the IPPCD to intervene in the ELV unit setting. Reference is made to subsidiarity principle. • Additional monitoring problems with load based ELVs: • Difficulties in inspection: Coupling of emission measurements and production data (have to rely on data delivered by company) • One installation may produce different kinds of (intermediary) products. Difficulties to allocate emissions. • Load-based ELVs (in the form of mass/product) would not be applicable for all industries. • Concentration based ELVs remain necessary to avoid peak emissions

  26. Part 2B A1 ELV Key Impacts • Problem adressed (no comparable data on eco-efficiency) • Load based ELVs better than concentration based ELVs to compare eco-efficiency: options 2 (guidance), 3 (BREF) and 4 (reference in IPPCD) • Actual performance data better than required performance data (ELVs): option 5 (reporting requirement on load based emissions) • Environment: • Use of load based ELVs for water: no incentive for dilution (mentioned by some MSs as incentive to introduce load based ELVs) (options 2-4) • Use of load based ELVs will result in better knowledge of production processes (options 2-4) • Making actual environmental performance public may stimulate companies not to be the worst performer (option 5) • Economic: • Additional administrative burden for redesigning permit system and extending the inspection requirements (production figures) (options 2-4) • Companies may not be eager to make (confidential) production data public. (option 5)

  27. A5 Water Part 2B Potential Amendment A5 Discharges to Water • Issue • IPPC results in ELVs in permits for water discharges • Water framework Directive requires controls on activities that prevent ‘good ecological status’ • Under WFD controls are to be developed on controlling priority hazardous substances – proposed Directive July 2006 – only proposes EQSs, not ELVs - proposes priority substances to be taken account of in IPPC permits and IPPC permits to be reviewed. • How do the two (or more) Directives interact and should IPPC be amended to make this clearer?

  28. A5 Water Part 2B Options and Pros and Cons • 1 – do nothing. Simple, but leaves interactions unclear – not good option • 2- Introduce cross-referencing in IPPC to the environmental quality and objectives of WFD as it already exists for other Directives, and introduce the list of PHS into IPPC Annex III – obvious simple cross-referencing, no cons. • 3 - Amend IPPC to ensure that priority substances are taken account of in permitting and that permit reviews are initiated in areas of transitional exceedence – this is required in the proposed Directive anyway

  29. A5 Water Part 2B Conclusions – Preferred Options • Options 2 and 3 are both preferred. There is no con, other than for the Commission to produce guidance • The aim is to deliver legislative coherence and not to introduce any new obligation

  30. B Sevilla Part 2B Potential Amendment BProvision of information from Member States in the Sevilla Process • Issue • Examine the best way to secure a suitable contribution from Member States to the Sevilla Process. • Problem Definition • Sevilla process can benefit from better (timed) information • Encourage MS to provide more data on emissions and performances. • Increase involvement of MS in Sevilla process • Better data Representative BREFs Easier national implementation

  31. B Sevilla Part 2B Current Practice • Lower contribution from MSs in the Sevilla process due to: • Voluntary aspect of the process • Various BREFs have to be followed up by a small group of people • Experts for TWGs also in charge of local IPPC implementation • To extract, link, translate and send the useful data still creates big workload. People (money) not available. • Tendency to computerise permit data is expected to have a beneficial effect on the MSs contribution. • Art 16.1 regulates periodic collection of data on ELVs and BATs from which they are derived (if appropriate). • Could be useful data for the Sevilla process • Up to now only ELV-data received, no data on BAT • Commission recognised problem – publication of “practical guidance” for current reporting period

  32. B Sevilla Part 2B Options • Option 1 - Business as usual: ie non-action • Option 2 – Public listing • Noting which MS contributed and in which way. • Could be a stimulus to send information • Option 3 – Obligatory Member State contribution • Introduction of an amendment in the IPPC Directive obliging MS to report to the commission. • Scope: a) Sample of installations • b) All installations • Option 4 – Integration of Article 16.1 and Article 16.2 (new option) • The obligatory information exchange (16.1) would be in support of the BREF writing/review process. • Practical guidance provided • Option 4 is an extended version of the approach for the current reporting period.

  33. B Sevilla Part 2B Working insights • MSs agree that information exchange should be organised more efficiently. • Ongoing efforts to issue IPPC permits will already lead to more valuable data from MSs. • MSs consider the approach for the recent reporting period to be a step forward in coming in line with the needs of the Sevilla process. • However, this approach will only affect 2 BREF revisions, not the total amount of upcoming BREF-revisions planned (11). • Most of the MSs emphasize the importance of the voluntary nature of the Sevilla process: • “Producing BREF notes should assist MSs not burden them” • It is also indicated that a lot of available data is not sufficiently used in the current Sevilla process: • EPER/E-PRTR data • BAT documents written in language BREF-author not familiar with.

  34. B Sevilla Part 2B Key Impacts • Problem adressed (low contribution of MSs in Sevilla process) • Option 2 (public listing) is not expected to solve this problem • Making information delivery obligatory would solve the problem of contribution. However, this information needs to be available and of certain quality to be useful in the BREF process. (Options 3 & 4) • However, additional data are not necessarily better data: quantity vs quality • Environment: • It can be expected that additional data would lead to better BREFs and therefore would have an indirect environmental benefit • Public authorities: • Additional reporting requirements would (may) put an additional burden on MS. (option 3 & 4) • Therefore, approach of specific (and limited) data gathering with the assistance of practical guidance documents is supported (option 4)

  35. C1 Combustion Part 2C Potential Amendment C1Small combustion installations • Issue • Lowering of the threshold for combustion installations in energy industries from 50 to 20 MW (or an appropriate value) thermal input • Problem Definition • Presently, installations > 50 MW controlled by LCP and IPPC Directives: While LCP sets ELVs, the IPPC Directive uses permit conditions based on BAT. (Note: Some combustion units < 50 MW are also regulated under IPPC as ‘directly associated activities’) • EU Emissions Trading Scheme Directive 2003/87/EC, makes all installations carrying out energy activities with a net thermal capacity greater than 20 MW eligible for GHG emissions trading. • Reducing the threshold from 50 to 20 (or another threshold) MW will bring more installations and sectors under IPPC, and may lead to significant reduction of emissions

  36. C1 Combustion Part 2C Current Practice – Scale of the sector • About 3 000 combustion installations in the 20-50 MW capacity (i.e. one third of the total European combustion installations covered by EU-ETS Directive) • More than 65% of them are concentrated in 6 MS (Germany, UK, Poland, France, Italy, and Denmark) • Other MS having less than 150 installations each. • Some installations already under IPPC as directly associated activities but UK example suggests about 1/2 - 2/3 are still not covered

  37. C1 Combustion Part 2C Current Practice (2) – Environmental Impacts From all small combustion installations (residential and industrial) (Source: IIASA, 2004), Note that for PM and VOC, contributions vary widely from one MS to another • For industrial small combustion installations, the emission estimates for SO2, NOx, PM2.5, and PM10 represent about 12%, 12%, 18% and 15% of total industrial combustion emissions of EU-25. • The impacts for POPs and heavy metals emissions significant

  38. C1 Combustion Part 2C Current Practice (3) – Impacts • Photochemical oxidation and acidification impacts significant - 28 and 25 million European citizen equivalent respectively (about 5% of the EU-25 activity impacts)

  39. C1 Combustion Part 2C Options • 1. (A) Do nothing • (B) update the BREFs or guidance document to include BAT for the combustion installations less than 50 MW • 2. Lowering the threshold of the IPPC Directive from 50 to 20 MW • 3. Lowering the threshold of the IPPC Directive to industrial installations of below 20 MW (with a threshold to be determined)

  40. C1 Combustion Part 2C Analysis of options (1) • General Issues • Option 1B will not affect additional installations, provides means to implement BAT in the installations < 50MW already covered • Option 2 may bring significant installations under IPPC - benefits achieved through the impacts reduction substantial. • Option 3 will cover even more installations and thus more benefits but it will also bring non-power/manufacturing sectors under IPPC, as the installations <20 MW are also used for heating .

  41. C1 Combustion Part 2C Analysis of options (2) • Environmental Issues • For most of the environmental issues, the impacts of the options 1B, 2, and 3 are positiveand in increasing order • Economic Issues, Social and other issues • Increased costs for the industry, and administrative burden for the MS but • Improved public confidence as directly linked to the health benefits • Single media problem (air pollution)

  42. C1 Combustion Part 2C Key Insights • Data on the number of installations derived from EU-ETS sources and the real number maybe higher • New and better technologies are being developed - the concept of BAT is very well applicable • Fuel quality regulation may also affect the emissions from these smaller installations • At the MS level, a large disparity exists for regulating the small combustion installations (e.g. ELVs for SO2 in in one MS 200-1700 while other 800-2500 and for CO the ELVs used are 60-200 and 650-1000 in two MS).

  43. C2 Aquaculture Part 2D Potential Amendment C2.gAquaculture • Issue • Addition of aquaculture to the list of covered activities with a suitable threshold definition. • Problem Definition • Various definitions of "aquaculture" exist. In general, aquaculture means the rearing of culture of aquatic organisms using techniques designed to increase the production of the organisms in question beyond the natural capacity of the environment. • ‘Aquaculture’ is currently not covered under the IPPC Directive, and there have been calls for environmental regulation of the sector to be extended by including it in the IPPC Directive. • Including aquaculture in the scope of IPPC could lead to environmental improvements but may also affect the European market share of this competitive sector at the international level.

  44. C2 Aquaculture Part 2D Current Practice – Scale of the sector • 3.9 billion euros of sales for a production of 1.4 M tons of finfish and shellfish (45% and 55%) • Five countries represent more than 75% of Eu25 production: Spain (~365 kt), France (~245 kt), UK (~205 kt), Italy (~115 kt), and Greece (~95 kt). Main producer in Europe Norway (~635 kt). • Total number of installations is in the order of 8-10 thousand though some are very small. • Not many installations have production of 1000 t/year and most of them are in the UK (about 60 in Scotland) and Norway and regulated by national laws

  45. C2 Aquaculture Part 2D Current Practice (2) – Environmental Impacts Fish Farming is the most critical stage in the aquaculture from environmental impacts point of view • Environmental impacts are species specific and majority of the potential impacts are related to fin fish rather than shellfish aquaculture • Main environmental impacts are water pollution and biodiversity • Eutrophication ~31 kt PO4 eq. per year i.e. about 1% of total potential eutrophication generated by EU-25 annual economy (cf. 18% for pig farming) but a contribution up to 27% to eutrophication at local level.

  46. C2 Aquaculture Part 2D Current Practice (3) – Impacts • External costs • aquaculture is estimated as representing less than 0.1% of total EU economy externalities and a small % of the annual value of the sector. • Other impacts: • biodiversity issues (presence of alien species and the escape of fish); • eco-toxicological impacts on eco-systems (chemicals, antibiotics); • pressures on wild fish stocks (e.g. the demand for feed).

  47. C2 Aquaculture Part 2D Options • Do nothing • Addition of aquaculture to the list of covered activities in Annex I, with a production capacity of 1,000 tonnes of fish or shellfish per year (same as E-PRTR threshold) • Addition of aquaculture - with a lower production capacity than 1000t/year. • Addition of aquaculture - using another indicator than production capacity as a criterion: e.g. standing biomass or tonnes of fodder used per year.

  48. C2 Aquaculture Part 2D Analysis of options (1) • General issues • Option 2 concerns a rather limited number of installations, main MS affected is UK. • A lower production threshold (option 3) will bring a large number of installations under IPPC (the number will obviously depend on the capacity threshold) hence benefits achieved higher • Option 4 is more peculiar as it uses approaches which have been based on the experience. • Environmental issues • the impacts of the options 2, 3, and 4 are going to be positive and in the increasing order, however, depends on the fish species and the harvesting/farming method used.

  49. C2 Aquaculture Part 2D Analysis of options (2) • Economic issues • Option 3 and 4 more critical as they may add costs and thus affect competitiveness, additional load for regulatory authorities • Cross-sector impacts (e.g. tourism) • Social issues • aquaculture employs about 65000 people (15% of fisheries sector) in EU25, half in FR and ES, where shellfish are harvested predominantly • average number employed in aquaculture per million inhabitants is about 140 • Aquaculture sector more active in rural areas, employment is very crucial, IPPC inclusion may affect in +ve or –ve way. • Other issues • Practicability and enforceability (complicated for option 4)

  50. C2 Aquaculture Part 2D Key Insights • Key issues of current practice • Many environmental impacts in the case of aquaculture are bi-directional; better quality fish need better growing environment. • Aquaculture sector is subject to different national/EU legislation directly or indirectly and these laws are heterogeneous. Many MS seem to issue an authorisation (before constructing) and/or a permit to operate (can be updated during the operation). • Some MS have started thinking about an approach similar to BAT and this will significantly reduce the key environmental impacts, however, the factors affecting the choice of technology depend on several site-specific parameters, so a generalised BAT is difficult. • Threshold definition and local factors e.g. farmed species, site hydrography, and water quality are important.

More Related