the 1st stakeholder workshop for revision of the ied, 15

Assessment of options for the revision of the Industrial Emissions Directive

Ref: ED 13995 | Workshop 1 Notes | Issue number V1.0 | 05/05/2021

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The 1st stakeholder workshop for revision of

the IED, 15 December 2020, online

The first stakeholder workshop within the context of the Revision of the Industrial Emissions Directive took place on 15 December 2020, online. Approximately 350 registered for the workshop and over 250 attended. The keynote address was by Veronica Manfredi, Director, Quality of Life DG Environment. The final agenda is provided in Annex 1, while the registration list by organisation is in Annex 2.

This note provides an account of the discussion sessions that followed each of the presentations. During the talks, questions could be submitted using the online chat function. About 100 questions of substance were posed. Written responses were provided for about 30 questions and oral responses were given for about a further 30. These are recorded in these minutes. There was insufficient time to address a further 40 questions. These were addressed after the event and the full set of Q&A is in the project webpage at https://ee.ricardo.com/industrial-emissions-directive-revision-consultation.

The slides from the workshop and a recording are also available at https://ee.ricardo.com/industrial-emissions-directive-revision-consultation

This workshop was organised alongside a workshop on the revision of the E-PRTR Regulation.

Welcome and Outline of the first IED workshop, Michael

Bennett, EC DG ENV The ‘Welcome and outline of the IED workshop’ was delivered by Michael Bennett of DG Environment. It outlined the workshop with a morning session on revision of the IED and an afternoon session on revision of the E-PRTR Regulation. Michael also summarised opportunities to contribute to the revision of the IED and listed key contacts for both revisions.

Keynote, Veronica Manfredi, EC DG ENV The Keynote on ‘Overview of the Potential of the IED Sectors for the EU Green Deal’ was delivered by Veronica Manfredi, Director, Quality of Life from DG Environment. She welcomed participants noting that IED and E-PRTR had been combined in this meeting and in the OPC to reduce the call on stakeholder time. The context is the European Green Deal that designs a new growth strategy for Europe. One key aspect of this is zero-pollution, to which both IED and E-PRTR contribute. Notwithstanding major progress driven by the industrial sector, more can be done. From the recent evaluation it is evident that the IED has been important in reducing pollution to air. There is untapped potential for emissions to water and soil and also in contribution to decarbonisation, to the circular economy and to innovation.

On decarbonisation, looking beyond the short term to 2030/40/50, is there a possibility to accelerate the arrival in the market of breakthrough clean technologies and can the IED contribute to this. This would require working together of the market-based Emissions Trading System and the more “command and control” mode of the IED.

Considering the circular economy, is there scope to better encourage industrial symbiosis with system thinking leading to better flows of materials, energy and water?

Ms Manfredi concluded by stating that change is not an option, it is a necessity. Europe can set an example of addressing the ecological and climate crisis while consolidating European competitiveness.

The IED impact assessment, Tim Scarbrough, Ricardo An overview of the IED impact assessment process was given by Tim Scarbrough of Ricardo It outlined the context to the IED impact assessment, objectives of the impact assessment support study and the overall timeline. The following presentations were grouped by problem areas being considered:

https://ee.ricardo.com/industrial-emissions-directive-revision-consultation





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• The environment is polluted (zero pollution ambition)

• The environment is polluted (non-toxic environment)

• Climate crisis is happening (carbon neutrality at EU level)

• Natural resources are being depleted (circular economy)

• State-of-the-art techniques cannot respond in a satisfactory manner (deploy breakthrough technologies)

• Public access to information (empower citizens, etc.)

• Excessive burden may affect efficiency of policy (ensure proportionality of EU law)

The following presentations were on each of these problem areas. Each presentation gave an overview of the problem area, a summary of the main issues being investigated, and outlined the method of inquiry – and how stakeholders could provide input.

Environment is polluted – policy options towards 2050 “zero

pollution” ambition, Tim Scarbrough, Ricardo and Rob

Whiting, Wood

Problem area 1a – The environment is polluted (zero pollution ambition)

Questions with written responses in the workshop

Question Response

Deleting flexibilities will ensure that the zero emissions target is reached?

To clarify - some flexibilities may be contributing to higher emissions to the environment than compatible with application of BAT.

What is the reasoning behind widening the scope for forging presses? There are no similar KEI to forging hammers or other processes as usually heating is electrical (induction) and there is no major noise or vibration emission! There should be a focussed approach!

The IA will look at the scale of activity and look in more detail at the following environmental issues: energy consumption, noise and vibration. This is something that is under consideration as part of the IA.

Do you consider also the option to exclude certain activities from the Annex I which have proved to do not pose a risk of significant pollution and for which IED permit could be just an administrative burden?

Problem Area 6 looks at improving coherence (where admin burden can be reduced). Linkages between problems will be investigated as part of the IA.

Do you have plans to modify MCP directive? This related to the ideas to amend the threshold of the combustion plants (50 -> 20 MW).

This is an area under consideration as part of the IED IA regarding the cut off value between IED and MCPD. But otherwise Cion has not indicated any plans to review the MCPD.

We DO have non compliant units in EU? Do you mean those, which are operating under 15(4)? This would not be incompliant, or?

Thanks! You are correct that derogations Art 15(4) do not mean an installation is not compliant. We will review wording to avoid any confusion on this.

Will contractors ask MSs for some information regarding e.g. number of non IED installations or installations from the sector not currently included by the Annex I including emissions from those sectors. What is a main source of data for these analysis?

There are a number of complementary studies under way to close this data gap (sector/ activity specific). In addition, this will data gap will be closed by stakeholder consultation activities.

How avoid double regulation with WFD, battery regulation, ELV directive?

This will be carefully reviewed as part of the IA study.



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Question Response

Will you also consider the need to redesign the scope of the IED? Annex I needs to be adapted to change the approach of how industrial activities are regulated, by setting BAT for lowest ratio ‘environmental impact of industrial activity’ versus ‘public good/service provided’, in order to promote the industrial activity with the least negative environmental impact for the provision of a given product/service. If you keep the scope to a subset of Energy industries e.g. Thermal power plants with rated power >50MWth this leads to no-where, amend to cover: energy production (be it electrical, heat or mechanical) of a certain scale, then you can combine all options, including setting a BAT hierarchy (not combustion based Renewable Energy Sources), then also look at other areas so the CE approach can work: water quality and supply, protein production, resource management, substitution of chemicals of concern

The scope of the IED is under consideration in relation to problem area 1a (zero pollution ambition).

Questions with oral responses

Question Response 1

Slide # 19: What is the difference between A ii and A iii?

Aii is about BAT-AELs not always being achieved - related to derogation flexibilities or derogation issues. A iii is related to delivering specific improvements on implementation for monitoring and approach to compliance as well as on other points on baseline reports and inspections. There is a theme running through many of these points related to implementation issues.

A.ii: can you be more precise regarding the proportion of those BAT-AELs that are not always achieved? You referred to derogations which - to my knowledge - have not been used to a large extent. In other words: did you observe exceedances above the limit values set in permits or limit values that were set above BAT-AELs instead? Thank you.

Regarding derogations recent studies have identified regular but not systematic use of Article 15 (4) derogations. There is further ongoing work to examine further sectors to improve the evidence base available, based on member State reports and availability of permits online. This will allow better understanding of the effect of Article 15 (4) derogations on emissions. There is also other evidence that suggests that some of the other important flexibilities are not always well applied, e.g. related to indirect releases to water. There is ongoing implementation reporting by the Member States - includes uptake of 15 (4) derogations. On the proportion of BAT-AELS that are not achieved, there are studies on small samples that show that there are some cases where BAT-AELS are not being met - this is being investigated further.



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Problem area 1b – The environment is polluted (non-toxic environment)


Question Response

Are the risks of environmental dumping (outside EU) taken in account?

The impact assessment will look at risks of leakage and secondary impacts (as relevant to the revisions under consideration).


Question Response

Area1.b - The problems are related to BREF or to permits? BREFs have a physiological "time of reaction" of almost 10 years. Permits could be tuned with the new regulation in few months. And in some member states they have to.

Fully agree that permits can react more swiftly. Only concern is that if POPs are added to the POPs Regulation, then the follow on to that in IED, if amending permits a done by MS, then response can be patchy. So consider also needs to appear in BREF itself - noting this is a slower process. Needs to be a trigger that if something is added to the POPs Regulation, it is added to the BREF process.

B.i: do you suggest that "EIPPCB Seville" would run faster than "ECHA Helsinki" when it comes to identify the "safer alternatives", anticipating the authorisation process. Can you elaborate on what the thinking is here?

Suggesting there needs to be better communication and one body takes its cues from another. REACH process, run under ECHA, is already well defined and has been running for some years. Not suggesting that one body replaces or tries to get ahead of another. Rather that there is a flow of information so that if a substance is under consideration by ECHA, Seville is aware of it and starting to respond to this.

1B - how do you avoid double regulation REACH >< IED?

This will come out at the end of this process. Aware that this is a potential pitfall, and so something that we aim to avoid.

Decarbonisation opportunities, Toon Smets, Wood


Question Response

Are you going to include the CO2-related component within the IED framework?

To clarify - this is only under consideration at this stage (as will be clarified in slides to come)


Question Response

Have GHG in the chart been all measured with the same method? Shouldn't livestock (Agriculture) methane emissions not be measured with GWP* (Star) that takes into account their decomposition in a decade?

Thanks for the comment. Might well be the case. Point was to illustrate trends - main message is that there is a need for a step change towards 2030 and 2050 targets.

Could you please clarify what you mean when stating that the GHG emissions have been "omitted". I don't feel it was an omission.

Perhaps wording is too strong. Has been included indirectly through energy efficiency. There are some BAT-AELs on GHG emissions. But this is referring to Article 9. So possibly not being



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Question Response

considered in the BREF process to the same extent as other pollutants.

What is methane recovery? Refers to activity of landfill. Also proposed as an area for extending scope of the IED - relevant for areas 1a and 2.

When mentioning that the IED will look at GHG emissions, will this also have an impact on how the EU-ETS will apply to those installations or will there be a double regulation applying (IED, EU-ETS)?

Lot of questions on interface between IED and ETS and what are the intentions. Currently at Impact Assessment phase and looking at problems. There is an environmental problem which is the climate issue. Then there is a coherence issue which is looking at how policies interact. More and more understanding is that, up to now, measures taken by plants to reduce GHG could be distinguished from actions to reduce emission of pollutants. At a later stage, when breakthrough technologies would come on the market it is not at all clear that this will still be the case. Some, already known about, will both reduce pollutant emissions and climate emissions. This means that the reality of the interaction between IED and ETS will change over time - we need to understand better how they will work together when it is the same technologies/investments that are BAT for pollutant reduction and that are consistent with carbon neutrality. So we need to look at how the two instruments will work together in a different situation to today. Applies to 2030 to 2050 rather than immediately as the new BREFS from a revised IED will come into effect towards the end of this decade.

Fostering opportunities in the IED: (i) Circular

Economy; (ii) Innovation, Dirk Nelen, VITO and Alfredo Lopez, Ricardo

Problem area 3 - Natural resources are being depleted (circular economy)


Question Response

Area #3 : why are you writing that BAT-AEPLs are not binding "in some Member States" ?

This is based on implementation studies we have conducted some of the Member States have made them mandatory and others have not.

Area 3: Energy consumption is CBI, how do you want to derive BAT-AELS for energy?

Evaluation has identified CBI as a limiting factor. IA is opportunity to understand how to proceed further, especially as aspects such as resource efficiency could be increasingly, with increased issues related to CBI.



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Question Response 1

BAT 1 has recently been updated and expanded. It is an overarching BAT that should cover all. How this should be nationally implemented?

Not about setting performance or emission levels to be included in permit conditions. Have seen, and also in study on IED contribution to the circular economy, that there is little knowledge on whether a sector could contribute to e.g. industrial symbiosis initiatives or how choices on feedstock or waste pre-conditioning in an installation could facilitate upstream or downstream treatment. The small amount of available information conflicts with the very high expectations of what particular industries could do to promote industrial symbiosis with their sector - enhancing industrial performance upstream or downstream. Really an issue of providing information at a sectoral level to reduce expectations to more realistic levels.

In BREF works often data regarding specific emission and efficiency is considered CBI, and it is a problem to set BAT-AEL regarding it. Are you plan to specify in the revised directive it is no CBI data?

There are several questions on confidential business information (CBI). When we talk about circular economy - we talk about the use of natural resources as an input, the aligning with IED still is very poor. Different perspectives - circular economy on one side and IED on the other. We have seen that such CBI issues can be adequately handled. For instance in the E-PRTR where we also have a lot of CBI of plants and industries, I understand there are ways to deal with CBI.

Measures for better downstream resource efficiency (industrial symbiosis) could also refer to a better clean up of by-products (e.g. hides & skins) where these can be better valorised (food/feed chain) before giving them further to other industrial uses (leather tanning). Are such measures also considered in your reflections?

Very good point. Need to be careful not to mix up concepts of waste management and industrial symbiosis. Latter lies between one extreme of waste recycling and another of process integration. Temptation to consider recycling of waste of the use of someone else's waste as industrial symbiosis. Important to clarify terms and where industrial symbiosis may operate.

Problem area 4 - State-of-the-art techniques cannot respond in a

satisfactory manner (deploy breakthrough technologies)


Question Response 1

Regarding point B.iii (long-term BAT-AELs): do you mean setting stricter AELs but allowing for a longer period of compliance with these AELs? could you clarify? Thank you

2 sets of BATs/BAT-AELs: one for now (4 years implementation period) and another for middle-term

Area 4 - B - Promoting new techniques is a main issue, but BREFs don't seem the right tool to tackle it. A BREF regards the contingent situation of the sector, not a hopefully development of it. Have you considered other tools (for example a permanent TWG in Seville for each sector).

Thank you for your comment - we will reflect on this. The Innovation Observatory can play this role: performing continuous (or more frequent) evaluation tasks that the current BREF reviews



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Question Response 1

In Italy, it is actually possible to see energy efficiency / consumption info in the annual reports of the operators because of the permit, how can this even be claimed CBI?! Also note that Art 13.2 of the IED requires to address in particular exchange on energy consumption / efficiency... Bigger limitation issue: get rid of Art 26 of the EU-ETS /Art 9 of IED

Comment from an NGO participant in light of previous question.


Question Response

Area 4: will suppliers of emerging techniques have to provide data for derivation of BAT-AELS?

Assuming that main process steps to develop BREF will remain. Data to be used as an argument needs to be shared. Only difference is that Innovation Observatory will be an opportunity to gather additional information on these emerging techniques and their performance. We have been doing that in the pilot test of the Innovation Observatory - providing an additional source of information to feed BREF.

Shorter BREF reviews are very challenging. The time to write a BREF is already short and a lot of pressure is on the MS, the JRC and industry to find consensus. Where do you see potential to be faster?

What has been discussed in the past for emerging techniques and the Innovation Observatory (IO) is that the IO could take care of some other activities to facilitate the process e.g. the IO could, at any point, determine whether an emerging technique is being tested at commercial scale so it is mature (TRL 9). This could work in parallel with BREF and would not substitute for parts of or reduce the BREF cycle.

I do not understand the concept of dynamic BAT and BAT AEL. Can you explore this a little further?

Proposed two different ideas: Normal BREF. Data captured from reference plant. Instead of setting normal BAT-AELs one could set a bit more ambitious BAT-AEL for the long term (capturing best performers rather than good performers) - to be implemented not in 4 years after adoption, but maybe in 10 years. Similar idea - related to IO and emerging techniques. Understand this has been tested in other regulatory frameworks. Based on Best Not yet Available Techniques. So BAT-AELs or dynamic BAT-AELs are based on capability of emerging techniques.

Industry has a long term investment and planning cycle. Any change of the rules in between is very critical. When assessing new techniques it is important to clearly investigate TRL, KEI/GHG reduction potential, impact on media(!) and indirect impacts.

Agree with statement. Understand that investment cycles are long and that 2, 3 or 4 years may be needed to implement a new BAT once an emerging technique has reached the stage of qualified candidate BAT.



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Access to information & access to justice, Harry Smith,

Ricardo Questions with written responses in the workshop

Question Response

Area 5: When making information available on the internet, how to protect confidential data against competitors, and how not give relevant information to persons intending to damage sites (sabotage, acts of terrorism)?

Art. 24(4) notes that information supplied to the public under Art. 24(2) is subject to the restrictions laid down in Article 4(1) and (2) of Directive 2003/4/EC on public access to environmental information. This allows for specific confidentiality provided criteria are met.

Are you also looking into the issue of (non)substantial permit change, its legal definition and implementation and its impacts on public participation?

We specifically note this issue and note the uncertainty as to whether a competent authority's decision that a change is 'non-substantial' can be challenged via the provisions laid out in Article 25.

Has the option of making available (in real time) the CEMs data in the EU centralised register along with permit ELVs to enable comparison and the content of annual compliance reports?

We are actively considering measures regarding Continuous Emission Monitoring. Similarly, measures are under consideration to improve both access to permit documentation and the presentation of permit information (e.g. via requiring a uniform permit summary). Emission Limit Values (ELVs) are considered within such measures as a key piece of information. With reference to annual compliance reports, we believe the reports referred to in your question are the reports required under Art. 23(6), referring to compliance with permit conditions. These are already required to be made publicly available under that provision and are included within current EU Registry reporting, however we will consider whether further measures are required in light of similar measures considered.



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Question Response

Will COM also consider a fast track route to get finally a) continuous emissions monitoring (CEM) data in a centralised EU IED register in real time b) the permit ELVs so to enable comparison? c) the content of annual compliance report (harmonised) ? That can be dealt with via the IED COM implementation rules AND also via E-PRTR review See more here https://meta.eeb.org/2020/10/22/industrial-pollution-its-time-to-enter-the-digital-age/

On a) currently an internal report looking at CEM and displaying that in a harmonised EU form. We can look into whether that will be part of the EU IED register . On b) things such as the uniform permit summary may pick up on such aspects and further reporting under the E-PRTR and the IED through the EU registry will also help enhance the availability of permit documentation. Cannot comment on the content of the annual compliance reports - we will bear this in mind further.

Impact of art 15(4) derogations should take into consideration how a Member State complies with targets in the NEC Directive. Is it something that would be regarded?

Measures currently considered are targeted at enhancing the understanding of derogation impacts, particularly among the public by making information available. Competent authorities, under Art.15(4), may grant derogations 'without prejudice to Article 18', concerning Environmental Quality Standards, further defined within Art. 3 of the IED.

On B1 of problem area 5: Are you assessing publication of all information referred to in Art. 24(2) or only "permits", as it appeared from your slide? On B4: It is good to see this recognized. Are you considering the findings of the UNECE Aarhus Compliance Committee on case C121 of March 2020 in this regard? Here the Committee held that Art. 24 should cover Art. 21(3) (as mentioned), but also Art. 24(4) and (5)(b) and (c) does not comply with the Convention.

We are actively considering measures which apply to all information detailed within Art. 24(2), though specific regard will be given to permit documentation. We are actively considering all findings of the UNECE Aarhus Compliance Committee case C121 of March 2020, which includes a number of aspects within Art. 21, as noted.

https://meta.eeb.org/2020/10/22/industrial-pollution-its-time-to-enter-the-digital-age/

https://meta.eeb.org/2020/10/22/industrial-pollution-its-time-to-enter-the-digital-age/



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Policy efficiency: cost considerations & administrative

burdens, Tim Scarbrough, Ricardo Questions with written responses in the workshop

Question Response 1

What is the planned schedule for reviewing the Conclusions and BAT for the LCP?

The forum will discuss future BREF work programme. ENV anticipates to call a Forum meeting early in the new year. However, please note that this is not in scope of the IED IA.

Article. 9 is there for a good reason, if covered by ETS, to have another mechanism? This is an additional burden!

We are in the preliminary stages of developing options. If options are selected for further assessment the IA will review burden.


Question Response

Does the statement regarding "no excessive administrative burden" also refer to activities below the thresholds that might be included in the IED framework in the future?

Yes it does. In the Impact Assessment process when considering potential additional activities for inclusion, one of the factors is the additional administrative burden.

Is the possibility to align the scope of PRTR and IPPC in taken in account?

Yes, very much so. One aspect of this is that the workshop today covers both the IED and the E-PRTR Regulation. The Open Public Consultation is also shared. So aspects covered in E-PRTR and not current in the IED will be considered in the IED impact assessment - and vice versa.

Almost the 33% of IPPC plants are intensive farming. Is the administrative burden for those plants considered?

In the evaluation of the IED, high administrative burden was not raised as an issue for that. Nevertheless this will be looked at in detail in regard to any potential revision of the threshold for those plants to make sure there is an appropriate balance between the environmental impacts and the administrative burden. That is also why in Problem area 1a a tailored IED approach is to be considered for plants that are below current thresholds.

Area 6: Have you already identified a possible route to solve the issue of terminology for WI plants on EOT and NOC?

We will be looking at this. Please provide any input as appropriate through the stakeholder surveys

Will the impact assessment work also rate societal costs of possible shortcomings of policy options considered and "protection level effectiveness" on delivery? E.g. Art 15(4) derogations allows 'pick and choose' methods to do the balancing of costs versus benefits and tend to favour the polluters due to limitations on methods (e.g. air Value of Statistical Life v. Value of Life year lost =factor 3 difference, US method factor 9 difference in higher costs side). Will you also rate the unlevel-playing field/shortcomings in implementation costs due to flexibility offered by Directive v. Regulation?

This point was picked in in problem area 1a. One point was potential additional guidance to set out and describe a more standardised approach to cost benefit analysis to be carried out for Article 15(4) derogations.



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Impact Assessment steps & consultation methodologies

used, Tim Scarbrough, Ricardo Tim Scarbrough, Ricardo, outlined the process for each problem area, modelling work in support of the impact assessment and the stakeholder consultation objectives and process. The main stakeholder consultation activities are:

• An Open Public Consultation covering both the IED and E-PRTR, due to open later in December and close on 23 March

• A Targeted Stakeholder Survey, due to open in January 2021 and close on 23 March 2021

• The stakeholder workshops: Current workshop and a further workshop anticipated around May 2021.

Additional targeted stakeholder consultation will be by interviews by phone and through online focus groups.

General questions with written responses in the workshop

Question/ comment Response

The Staff Working Document [on IED] was sent to EP and Council for comments. Do you know if they will reply - doing conclusions, a INI or wait?

There is no indication yet from the European Parliament on whether they will develop a report on the IED evaluation SWD.

Will we receive the ppt presentation at the end of the meeting?

We will upload slides and recordings of the event to: https://ee.ricardo.com/industrial-emissions-directive-revision-consultation

Regarding the conclusion that 'the BREF process works well': could you please clarify the criteria considered to come to this conclusion? Based on our long-term engagement to the process, we believe there are shortcomings to be addressed, linked to: the BAT determination, to the criteria for selecting 'well-performing' installations, to clearer BAT conclusions and broader TWG expertise for delivering on CE and decarbonisation objectives, to the inadequate engagement of innovative technique provides and the process governance. Thank you for clarifying

Revisions are under consideration that look at the BREF process as part of the IA. The conclusion that the BREF process works well is based on evidence gathered under the evaluation (recognising there may be room for improvement).

Are the problems listed according to importance?

No - there are also linkages between the problem areas that are being investigated as part of the study.

For the full questionnaire – it is needed to give a definitions on the words used in questions such as innovation, non-toxic, industrial symbiosis, circular economy and so on. There are different understandings on these terms. Also to keep in mind, to add on everything in IED and BREF will not be very efficient

The questionnaire will be accompanied with a glossary.





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Question/ comment Response

Will the impact assessment report be made publicly available as soon as it is finalized, presumably in July 2021 (i.e. before publication of the legislative proposal)? We would highlight in this regard that the CJEU has recently confirmed that impact assessment reports are legislative documents that should be made publicly available. It would indeed be great to have a reply from the Commission on this.

SWD is integral part of Cion proposal as a supporting document, so is made available together with Cion proposal.

How can we participate/apply for the focus groups? As the German chemical industry we are very interested in such groups.

Thank you - your interest is noted and much appreciated.

General questions with oral responses

Question Response

Since the OPC will be a joint one for IED and E-PRTR do you foresee extra timing for providing replies? Meeting the deadlines can be challenging for industry experts - also given the current EU situation. Thank you for this consideration

The timetable announced today includes some additional time beyond 12 weeks.

Wrap up and close of session, Aneta Willems, HoU DG

ENV.C4 The session of the stakeholder workshop on revision of the IED was wrapped up and closed by Aneta Willems, Head of Unit of DG ENV.C4. In response to one query she noted that the current plan is to publish the impact assessment along with the communication and proposal in Q4 2021.

She thanked participants for their engagement during the session. She reiterated that the aim of the revision of the IED is to address weaknesses identified in the evaluation and to eliminate ambiguity and incoherence. It is also important to modernise the legislation and make it future-proof recognising that this is a time of climate crisis, that natural resources are being depleted and that the environment is polluted. It is also important to ensure that the developments are coherent with other current developments in strategies and legislation. She requested further engagement by participants in consultation mechanisms when contacted.



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Annex 1 - Agenda

Times Duration mins

Item Presenter

09:00 – 09:30 30 Log-in to workshop/ connection check (log on at least 20 mins in advance)

Introduction and overview

09:30 – 09:35 5 Welcome & Housekeeping Ricardo

09:35 - 09:40 5 Welcome and Outline of 1st IED Workshop

Michael Bennett, Policy Officer, EC DG ENV C4

09:40 – 09:55 15 Keynote: Overview of the Potential of the IED Sectors for the EU Green Deal

Veronica Manfredi, Director, Quality of Life EC DG ENV C

09:55 – 10:10 15 The IED Impact Assessment - overview Tim Scarbrough, Ricardo

Summary of Problems and Policy Options being considered for revision of the IED

10:10 – 10:25 15 Environment is polluted – policy options towards 2050 “zero pollution” ambition

Tim Scarbrough, Ricardo &

Rob Whiting, Wood

10:25 – 10:30 5 Q&A – taken from Chat

10:30 – 10:45 15 Decarbonisation opportunities Toon Smets, Wood


10:50 – 11:00 10 Break

Summary of problems and options (continued)

11:00 – 11:20 20 Fostering opportunities in the IED:

(i) Circular Economy; (ii) Innovation

Dirk Nelen, VITO & Alfredo Lopez, Ricardo


11:25 – 11:35 10 Access to information & access to justice Harry Smith, Ricardo

11:35 – 11:45 10 Policy efficiency: cost considerations & administrative burdens

Tim Scarbrough, Ricardo

11:45 – 11:50 5 Q&A – from Chat

Details of the Planned Consultation Process on the IED over the coming months

11:50 – 12:05 15 Impact Assessment steps & consultation methodologies used

Tim Scarbrough, Ricardo

12:05 – 12:15 10 Q&A – from Chat

12:15– 12:20 5 AOB/ Wrap-up & Next Steps/ Close of the session on the revision to the IED

Aneta Willems, HoU DG ENV C4



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Annex 2 - Registrants The following registration list gives organisations only.

This is sorted by stakeholder type, then by country of residence and then by organisation.

Some organisations may appear more than once if there were registrations from more than one country of residence.

Stakeholder type: Country of residence:

Organisation:

Environmental NGO Belgium Carbon Market Watch

Environmental NGO Belgium ClientEarth

Environmental NGO Germany ClientEarth

Environmental NGO Belgium Climate Action Network (CAN) Europe

Environmental NGO France EEB

Environmental NGO Belgium European Environmental Bureau

Environmental NGO Czech Republic Frank Bold Society

Environmental NGO Bulgaria Greenpeace CEE - Bulgaria

Environmental NGO France Hazardous Waste Europe

Industry Belgium accessa

Industry Belgium ACEA

Industry Czech Republic ACPP - Associacion of the Czech Paper Industry

Industry Spain aelēc (Asociación de Empresas de Energía Eléctrica)

Industry Germany Albemarle Germany GmbH

Industry Belgium ArcelorMittal Europe

Industry Spain ASPAPEL

Industry Czech Republic Association for District Heating of the Czech Republic

Industry Austria Association of Metaltechnology Industries

Industry Sweden AstraZeneca

Industry Germany AURUBIS AG

Industry Austria Austrian Association for Building Materials and Ceramic Industries

Industry Belgium Austrian Federal Economic Chamber

Industry Austria Austrian Mining and Steel Association and Austrian Non Ferrous Metals Federation

Industry Austria Austropapier

Industry Germany BASF SE

Industry Germany Bayer AG

Industry Germany BP

Industry Germany Bundesverband der Deutschen Ziegelindustrie

Industry Germany Bundesverband der Energie- und Wasserwirtschaft - BDEW

Industry Germany Bundesverband Glasindustrie e.V. (BV Glas)

Industry Germany Bundesverband Keramische Industrie e.V.

Industry Sweden Business Europe

Industry Belgium BusinessEurope

Industry Germany CAEF The European Foundry Association

Industry Spain Calcinor

Industry Belgium Cefic



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Organisation:

Industry Germany Cefic

Industry Netherlands CEFIC

Industry Belgium Cefic/Petrochemicals Europe

Industry Belgium CEFS

Industry Belgium Celanese Production Belgium bv

Industry Portugal Celtejo, Empresa de Celulose do Tejo SA

Industry Germany Cemex Zement GmbH

Industry Spain CEOE

Industry Belgium Cepi

Industry Portugal CEPI / CELPA

Industry Belgium Cerame-Unie

Industry Belgium CEWEP

Industry United Kingdom Chemical Industries Association

Industry Poland Companies

Industry Belgium Concawe

Industry Denmark Confederation of Danish Industry

Industry Belgium Confederation of Finnish Industries

Industry Czech Republic Confederation of Industry of the Czech Republic

Industry Belgium COTANCE

Industry Germany Covestro Deutschland AG

Industry Denmark Danish Agriculture & Food Council F.m.b.A.

Industry Germany DEBRIV e.V.

Industry Germany Deutscher Braunkohlen-Industrie-Verein e. V.

Industry Portugal DS Smith Paper Viana

Industry Belgium ECCA - European Coil Coating Association

Industry france ECOLAB

Industry France EDF

Industry SPAIN EDP ESPAÑA

Industry Portugal EMPRESA DA CELULOSE DO TEJO, SA

Industry Belgium Engie-Laborelec

Industry Belgium ePURE

Industry Belgium ESTAL European association of Surface Treatment on Aluminium

Industry Belgium ESWET

Industry Belgium ETRMA European Tyre and Rubber Manufacturers´ Association

Industry Belgium EUCOPRO

Industry Belgium EURACOAL aisbl

Industry Belgium Eurelectric

Industry United Kingdom Eurits

Industry France EUROALLIAGES

Industry Belgium EUROFER

Industry Belgium EUROFORGE AISBL

Industry Germany Eurogypsum

Industry Belgium Euroheat & Power

Industry Sweden Euroheat & Power



Public 16


Organisation:

Industry Belgium EUROMOT - European Association of Internal Combustion Engine Manufacturers

Industry Belgium European Aggregates Association

Industry Belgium European Aluminium

Industry Belgium European Carbon and Graphite Association (ECGA)

Industry Belgium European Solvents Industry Group, a Cefic Sector Group

Industry Belgium EUTurbines - European Association of Gas and Steam Turbine Manufacturers

Industry Germany Evonik Operations GmbH Technology & Infrastructure

Industry belgium EXCA

Industry Belgium FEAD

Industry Netherlands FEAD

Industry Belgium Federation of Enterprises in Belgium

Industry Belgium FEDIAF - European Pet Food Association

Industry Netherlands FEDIOL

Industry Spain FERTIBERIA S.A.

Industry Finland Finnish Energy

Industry Finland Finnish Forest Industries Federation

Industry Austria FMTI

Industry France FNADE

Industry Belgium Food Drink Europe

Industry Belgium FuelsEurope

Industry Portugal GE

Industry Germany Gesamtverband Textil und Mode

Industry Belgium Glass Alliance Europe / AGC Glass Europe

Industry France HAZARDOUS WASTE EUROPE

Industry France Hazardous Waste Europe

Industry Sweden IKEM – Innovation and Chemical Industries in Sweden

Industry Belgium IMA-Europe

Industry Croatia INA, d.d. - Industrija nafte

Industry Germany Integrity Management

Industry Belgium Interel

Industry Belgium INTERGRAF

Industry Belgium IOGP

Industry Belgium KGHM Polska Miedź S.A.

Industry Belgium Kreab

Industry Austria Lenzing AG

Industry Czech Republic Lhoist Central Europe

Industry Austria Magna Stey Fahrzeugtechnik AG & Co Kg

Industry Germany Merck KGaA

Industry Poland n/a

Industry Germany OQ Services GmbH

Industry Germany Pfleiderer Deutschland GmbH, Neumarkt



Public 17


Organisation:

Industry Poland PGE Polska Grupa Energetyczna S.A.

Industry Poland PKN Orlen S.A.

Industry Poland Polish Chamber of Chemical Industry

Industry Poland Polish Electricity Association

Industry Poland Polish Power Plants Association

Industry Poland Polski Koncern Naftowy ORLEN S.A.

Industry Spain Repsol

Industry Denmark Rockwool International

Industry Denmark ROCKWOOL Technical Insulation

Industry Netherlands RWE

Industry Germany RWE GCC NL

Industry Germany RWE Power AG

Industry Netherlands SABIC

Industry Czech Republic Sev.en Energy

Industry Netherlands Shell

Industry Germany Siemens Energy

Industry Austria Stahl- und Walzwerk Marienhütte

Industry Austria Stoelzle Glass Group

Industry Sweden Swedish Forest Industries

Industry Poland TAURON POLSKA ENERGIA S.A.

Industry Poland TAURON Wytwarzanie SA

Industry Belgium The Brewers of Europe

Industry France TOTAL

Industry Belgium UECBV

Industry Italy unem

Industry United Kingdom Uniper

Industry Finland UPM

Industry Finland UPM/Responsibility

Industry Finland Valmet Technologies

Industry France VEOLIA

Industry Germany Verband der Chemischen Industrie (VCI)

Industry Germany Verband Metallverpackungen e.V.

Industry Austria Voestalpine AG

Industry Germany Volkswagen AG

Industry Finland Wartsila Finland

Industry Belgium Water Europe

Industry Germany Wirtschaftsvereinigung Stahl

Industry Austria WKO

Industry Finland Yara Suomi Oy

Member State authority

Austria Environment Agency Austria


Austria Federal Ministry for Climate Action, Environment, Energy, Mobility, Innovation and Technology


Austria Federal Ministry for Digital and Economic Affairs


Austria Umweltbundesamt GmbH



Public 18


Organisation:


Belgium AWAC


Belgium Brussels Environnment


Belgium Flemish Environment Agency


Belgium Public Service of Wallonia


Belgium Public Waste Agency of Flanders (OVAM)


Belgium SPW _-ARNE


Belgium Vlaamse Overheid


Belgium Walloon Agency for Air and Climate


Bosnia and Herzegovina

Ministry of Foreign Trade and Economic Relations


Bulgaria Ministry of Environment and Water


Croatia Ministry of Economy and Sustainable Development


Cyprus Department of Environment


Cyprus Department of Labour Inspection


Czech Republic CENIA, Czech Environmental Information Agency


Czech Republic Ministry of Environment


Czech Republic Ministry of industry and trade of the czech republic


Czech Republic Ministry of Industry and trade, dept. of industrial ecology


Denmark Miljø og fødevareministeriet


Estonia Estonian Environment Agency


Estonia Ministry of the Environment


Finland Finnish Environment Institute SYKE


Finland Ministry of the Environment


France French Ministry in charge of Environnement


France French Ministry of Ecology


France INERIS



Public 19


Organisation:


France Ministère de la transition écologique


Germany Bavarian Environment Agency


Germany Environment Ministry


Germany Federal Ministry for the Environment, Nature Conservation and Nuclear Safety


Germany GAA Hildesheim


Germany German Environment Agency


Germany German Environment Agency (UBA)


Germany Hessisches Landesamt für Naturschutz, Umwelt und Geologie


Germany Regierungspräsidium Freiburg


Germany Umweltbundesamt


Greece MINISTRY OF ENVIRONMENT AND ENERGY


Hungary Ministry of Agriculture


Ireland EPA Ireland


Itay Ministry of Environment, land and see


Latvia Ministry of Environmental Protection and Regional Development of Latvia


Luxembourg ADMINISTRATION DE L'ENVIRONNEMENT


Malta Environment and Resources Authority


Netherlands Ministry of Infrastructure and Water Management


Netherlands Rijkswaterstaat


Norway Miljødirektoratet


Norway Norwegian Environment Agency


Poland Ministry of Climate and Environment


Poland Ministry of Economic Development, Labour and Technology


Poland Ministry of Energy and Environment


Portugal APA - Portuguese Environment Agency



Public 20


Organisation:


Romania Ministry of Environment, Waters and Forests


Romania NEPA


Serbia Environmental Protection Agency


Slovak Republic Ministry of Environment of the Slovak Republic


Slovenia Ministry of the Environment and Spatial Planning


Spain Basque Government


Spain Ministry for Ecological Transition and Demographic Challenge


Sweden Miljö- och byggförvaltningen, Vetlanda kommun


Sweden Ministry of Environment


Sweden Swedish Environmental protection Agency


Turkey Ministry of Environment and Urbanization


United Kingdom REE

Other United Kingdom Aether Limited

Other United Kingdom AQC

Other Belgium Cepi

Other Netherlands DCMR environmental agency Rijnmond area

Other Belgium Dods EU

Other Belgium Dods EU Monitoring

Other United Kingdom ECCA

Other Finland ECHA

Other Belgium ESWET - European Suppliers of Waste-to-Energy Technologies

Other Belgium EuRIC

Other Spain European Commission Joint Research Centre

Other Denmark European Environment Agency

Other Luxembourg European Investment Bank

Other Belgium European Turbine Network

Other Belgium Herr

Other Italy IMPEL

Other Belgium Interel

Other Italy ISPRA

Other Sweden IVL Swedish Environmental Institute

Other Norway Norwegian Environment Agency

Other Greece PASEPPE

Other Sweden Private citizen

Other Lithuania RPA Europe



Public 21


Organisation:

Other Italy Rse

Other Spain SPAIN TRADE UNION: CCOO CONSTRUCCION Y SERVICIOS

Other Belgium VITO

Other Netherlands W+B

the 1st stakeholder workshop for revision of the ied, 15

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