The EU air policy package

Summary:

The EU refining industry supports the principle of seeking cost-effective solutions to improve air quality. However, the high ambitions proposed by the Commission’s CAPE will lead the industry to take measures which are disproportionate, not cost-effective and resulting in a further impairment of the international competitiveness of the EU refiners.

The model used in designing the policy is subject to a high degree of uncertainty since:

  • It is based upon only one energy scenario, which may prove wrong, and also
  • it makes a number of key assumptions about the baseline emission reductions on which the policy scenario-related targets are based.

Therefore, there is a significant risk that the proposed 2030 targets will actually be unachievable, or only met with additional technical measures that are not cost-effective or even affordable for industry.

With regard to the proposal for a directive on the reduction of national emissions of certain atmospheric pollutants (NECD) FuelsEurope urges the Parliament and the Council to:

  1. Adopt more moderate emission reduction targets. Targets which are realistically achievable and cost-effective will balance environmental protection with the goal of promoting a competitive European refining industry;
  2. Ensure that installations that are applying BAT and are complying with their air pollutants emission limit values as set out in their Industrial Emissions Directive (IED) permits shall not be forced to implement additional measures even in the case national emission reduction commitment would not be met;
  3. Ensure that the emission reduction commitments (annex II of NECD) that are based on one reference energy scenario are subsequently adapted according to the update of the energy scenarios in order to ensure their achievability in a cost-effective way. For this purpose, a revision clause involving the active participation of stakeholders should be included in the NECD.

With regard to the proposal for a directive on the limitation of emissions of certain pollutants into the air from medium combustion plants (MCPD) FuelsEurope urges the Parliament and the Council to:

  1. Ensure that units belonging to an installation which is already regulated under the IED through permit conditions shall be excluded from the scope of the proposal for a directive on the limitation of emissions of certain pollutants into the air from medium combustion plants (MCP);
  2. Ensure that emission limit values laid down in annex II of the MCP for PM (particulate matters) and SO2 shall be compatible with the use of primary techniques only and therefore be economically achievable;
  3. Ensure that the MCP provision requesting MS to set stricter ELVs in zones not complying with air quality standards shall be removed since it goes beyond the subsidiarity principle and overlaps with the provisions laid down in the directive 2008/50/EC on ambient air quality and cleaner air for Europe (article 23 - air quality plans).

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