Industrins energieffektivisering - styrmedlens ... - Naturvårdsverket

NATURVÅRDSVERKET RAPPORT 6460
Industrins energieffektivisering – styrmedlens effekter och interaktion
It is important to view the issues from a broader perspective where important
practical circumstances are also considered. A general regulation is simple form of
control, while the individual regulations are not always efficient. General regulations
are not in line with the Supreme Court’s general statement permit conditions
should be precise for reasons of legal certainty. In this regard, a revision on the part
of the Supreme Court would be needed (even though precise conditions must remain
the general rule). There is also a need for a more efficient monitoring and
enforcement system. In addition, the regulations following the so-called BREFsystem
will strengthened through the new EU Directive on industrial emissions, but
so far it remains unclear how energy issues will be addressed within BREF.
The report’s concluding chapter discusses some important policy choices for
future policy interventions concerning industrial energy use. We here discuss in
more detail the issue of whether industrial energy use should be regulated through
general or mill-specific conditions. We also present possible reforms of the existing
policies. Here we emphasize – as a first point – the importance of an efficient pricing
of energy carriers. PFE cannot replace the role of the pricing mechanism; ultimately
energy prices create the demand for energy efficiency measures. The introduction
of energy management systems can assist companies in identifying attractive
energy efficiency projects, and make efficient choices between these, but in the
end it is the potential to bring down energy costs that induce companies to pay
attention to these in the first place.
Our analysis shows that the Environmental Code and PFE in combination
imply a form of dual control of energy conservation behavior in the industry, and
there is therefore a need to “streamline” the two instruments. Our assessment suggests
that revisions are desirable in both cases. The Environmental Code can constitute
the main regulation for determining the conditions for the operation of existing
and new industrial facilities. The Code permits flexibility in terms of adjusting
conditions to meet the specific situations that face each industrial plant. The industry’s
criticism of the Code should however be taken seriously. A number of revisions
could make the environmental permitting process more efficient, such as: (a)
the development of specific guidelines for how assessments should be performed in
preparation for permits are needed; as is (b) the establishment of a forum for more
constructive dialogue between regulators and industry representatives. On the latter
point the regulating authorities need to overcome the often significant information
asymmetries. An efficient permitting process builds heavily on a common understanding
of the problems, opportunities, and of the challenges that exist in each
case, and this is often lacking today.
With these revisions the Environmental Code could address many of the issues
that PFE have dealt with, not the least requiring firms to constantly oversee
and act upon their energy management systems. The role of the regulating authorities
should mainly be to require effective energy management practices (including
demands for the implementation of energy management systems), but also to initiate
more comprehensive system changes to improve overall energy efficiency in
society. In the latter case there are good reasons to initiate a search process and
give the company time to identify the most cost-effective solutions.
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