Improvement proposals of the BAT process

The Industrial Emissions Directive (IED) provides for a strengthening of the reference documents describing Best Available Techniques (BAT reference documents or BREF documents).

The BAT conclusions developed from the BAT reference documents set out binding requirements for the emissions reduction of industrial installations. This means that the state of the art for preventing or reducing emissions from industrial activities is stipulated in binding fashion at European level for all Member States.

Accordingly, an optimal design of the process for drafting the BAT reference documents (known as the Sevilla process) is of great importance for industry. In the eyes of German industry, the Sevilla process must be considerably improved. BDI has compiled improvement proposals in a position paper. It addresses the following points:

  • A reliable framework for an effective and functioning BAT process
  • Adapt workload to limited capacities of involved stakeholders
  • Improvement of capacity and competence in the Sevilla office
  • Reducing data collection to the essential
  • Improvement of data evaluation required
  • Increasing the importance of the TWG
  • Obligation to carry out an impact assessment
  • Making BAT conclusions clear and open to all types of technology