EURELECTRIC comments on the draft BREF guidance document

Dear Ms Wenning,
Ms Marianne WENNING
Head of Unit – DG ENV
European Commission
Rue de la Loi 200
BE – 1049 BRUSSELS
Brussels, 22 March 2011
<strong>EURELECTRIC</strong> would like to thank you for giving us the opportunity to participate to the
meetings held on 8 and 9 March. We welcome the draft guidance proposed by the
Commission and would like to make the following <strong>comments</strong>.
Paragraph 1.1.1. (What a BREF is and its aim)
<strong>EURELECTRIC</strong> supports efforts to streamline the contents of the BREFs but would like to
stress that it is still necessary to provide competent authorities and all relevant stakeholders
with information on the techniques applied in Europe. We remain supportive of a process
that should provide sound technical and economic information.
Paragraph 1.1.3. (‘Horizontal’ and ‘vertical’ BREFs)
<strong>EURELECTRIC</strong> would welcome clarification on the status and use of horizontal BREFs. Those
are often crucial to the implementation of the vertical BREFs.
Paragraph 1.1.7. (Objective of a BREF review)
<strong>EURELECTRIC</strong> supports efforts to streamline the contents of the BREFs and ensure an
efficient process but it should be ensured that the BAT conclusions and the whole BREF are
fully consistent. In certain cases, the discussion on the scope of the BREF may be an element
the TWG will have to focus on.
Union of the Electricity Industry - <strong>EURELECTRIC</strong> AISBL . Boulevard de l’Impératrice, 66 - bte 2 . B - 1000 Brussels . Belgium
Tel: + 32 2 515 10 00 . Fax: + 32 2 515 10 10 . VAT: BE 0462 679 112 . www.eurelectric.org

Paragraph 1.2. (Generic schedule for the BREF review)
<strong>EURELECTRIC</strong> supports the drafting of shorter BREFs but would like to express its concerns
about the proposed deletion of the second draft in the generic schedule for the adoption or
revision of BREFs. Intermediate steps are important, in particular in the new context
established by the IED, and could prove extremely useful to solve specific problems or to
avoid split views. It is difficult to imagine the BREF LCP could be revised according to the new
proposed schedule given the scope of the document and the importance of a successful
revision for all stakeholders.
We question the necessity to merge the reactivation of the TWG and the call for wishes as
this would give insufficient time for appropriate preparation.
Paragraph 2.3.8. (Techniques to consider in the determination of BAT)
We would like to ask for the inclusion of the following relevant type of information in table
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'Environmental performance and operational data':
• fuel should be added to the list of examples of inputs
• fuel composition should be added to the list of operating conditions
'Applicability': the following should be added to the list of main restrictions expected
• operating pattern of the plant (e.g. base load with long continuous annual operating
time demand, peak load or mid-merit with many start-ups or very fluctuating load
demand)
• unreliability of performance
• deficiency of wide references in heavy duty commercial operation
Paragraph 2.3.9. (Best Available Techniques (BAT) conclusions)
We support the need for synthetic BAT conclusions but it is still essential that Split Views are
clearly reported.
Paragraph 3.2.3. (Information to assess the applicability of techniques)
<strong>EURELECTRIC</strong> supports the explicit inclusion of the load factor in the BAT conclusions, to
assess the applicability of techniques, as expressly requested by Finland during the IED
Article 13 Forum Sub-Group on 8 March and taken up by the Commission in its conclusion on
the discussions on chapter 3 of the draft guidance. In the case of large combustions plants,
for instance, a BAT suitable for base load operation is not necessarily suitable for peak load
operation.
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Paragraph 3.3.1. (BAT conclusions with BAT-associated emission levels)
We support the need for BAT conclusions to be associated with 'normal operating conditions' but
reference should be made to the possibility that many plant may not approach that efficiency or
pollutant abatement capability because of low load factor, climatic conditions or fuel diet.
Paragraph 5.2. (Principles for data collection)
We support the need for good data and the need for data from single installations. However, such
data must be representative of the sector or else the data can be interpreted in such a way as to be
reflective of conditions or equipment prevalent in other locations. We support the need for
information from the 'best' installations but efforts must also be made to understand the extent to
which these data are representative of the 'average' plant.
Paragraph 5.3. (Confidentiality issues)
We would argue that TWG Members should not give details on the name of the installation.
Paragraph 5.4. (Information type)
We would draw your attention to the paucity of guidance provided on costs. The BREFs must
recognise that cost data can be highly site specific, especially for retrofit installations and will be very
dependent on operating conditions, fuel etc.
Paragraph 5.5.5. (Energy)
For "Others" both the steam and the heat used to produce electricity should be indicated to
avoid duplication in collecting energy flows.
Paragraph 5.5.7. (Reference information)
Average values should also be given and calculated by considering coherent figures
regarding both “normal operating conditions” and “other than normal operating
conditions”. Indeed the set of data should also be representative of worst cases, provided
consistent conditions.
Whilst LCPs are generally designed for operation at base load over a design lifespan, after a
period of time, newer (and therefore more efficient or less costly) plant force older plant to
operate at lower and lower annual output (or load factor) before being closed. From a BAT
point of view, this is important since the reduced load factor, whilst contributing to a
reduction in total emissions, can impair a plant operator’s ability to retrofit abatement
equipment. This mode of operation needs to be addressed in the BAT guidance.
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Paragraph 5.6. (Specific issues)
We disagree (p 45-under 'Note') that loads are not useful for deriving BAT AELs (see above
<strong>comments</strong>)
Best regards,
John SCOWCROFT
Head of Environment & Sustainable Development Policy
<strong>EURELECTRIC</strong>
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