The undersigned sectors are willing to contribute to the development of a systematic approach for deriving suitable BAT‐AELs ranges
The legal obligation for permitting authorities to set the emission limit value for a given pollutant at a level that ensures that, under normal operating conditions, emissions do not exceed the BAT‐AEL, has far‐reaching consequences. BAT‐AELs have to be implemented as ELVs and industrial installations have to comply with those. A systematic approach to derive the BAT‐AEL as a result of the BREF review process and the data collection performed in that context is therefore a must. A robust and transparent approach will secure consistency for stakeholders throughout the BREF review process, as well as for regulators and operators at permitting level. Based on both the Guidance published in the OJEU in March 2012 and on our combined industrial experience, we have outlined in this paper an approach which should help deriving both ends of the BAT‐AEL range systematically. This is crucial if one wants to preserve the integrity of IED implementation through appropriately‐designed and truly applicable BAT conclusions, technically achievable and economically viable BAT‐AELs.