AEII joint statement fregarding the timing for the consultation of the next BREF review cycle and the efficiency of the online workshop
The Alliance of Energy Intensive Industries (AEII) expresses our concerns on the timing for the consultation of the next BREF review cycle.
Firstly, the Members of the Industrial Emissions (IE) Alliance welcome the efforts of the European Commission to support the decision of the previous Article 13 Forum meeting to gather stakeholders’ feedback on possible prioritisation for the next BREF review cycle.
However, we do wish to express our concerns on the timing for the consultation of the next BREF review cycle and propose that an additional face-to-face workshop be organized as soon as circumstances will allow.
The IED Article 13 Forum meeting of February 2019 took place well before the release of the European Commission Communication “The European Green Deal”, announcing the IED evaluation and its subsequent inception impact assessment (published on 24 March 2020). The upcoming workshop was, therefore, initially planned to take place within the context of the existing IED without having the revision process in mind. Consequently, the following IED Article 13 Forum may only agree to a preliminary work programme which may need to be revisited once the IED revision has been completed.
Additionally, we believe that the virtual meeting format will lead to a less effective information exchange process between the large number of Article 13 Forum members. This is due to several reasons such as the absence of a physical contact, language and pronunciation issues, and the inability of a web-based meeting to support an active discussion for a period of more than two-three hours.
With this in mind we would recommend that the 12th June workshop should focus on addressing sections 4.2, 4.3, 4.5, 4.6 and 4.7 of the background paper. This will facilitate the completion of those items linked to the existing cycle irrespective of the ongoing IED revision and will make best use of the current practical circumstances. Sections 4.1 and 4.4 would be better left for a follow up discussion during a face-to-face meeting once the ongoing IED revision process has been progressed (ideally after the upcoming open public consultation announced in the inception impact assessment).
Finally, we would also like to stress that the next BREF review cycle is not initiated until the IED revision has been finalized. Long-term stability and certainty in the legislation is a necessary factor for industry to stay competitive and plan ahead. In this way, confusion over which regulatory framework is applicable and a repetition of what happened during the transition of IPPCD to IED (e.g. stretched out NFM BREF review) will be avoided.
For the reasons above, the Industrial Emissions Alliance members propose:
- that an additional face-to-face workshop be organised as soon as circumstances will allow and to split the background document into related items for discussion.
- to take into consideration the overall progress of the IED revision process for the timeline.