Declaration of Czech industry on the proposal for a directive on industrial emissions (IPPC)

Declaration of Czech industry on the proposal for a directive on industrial emissions (IPPC)

ArcelorMittal Ostrava, a.s., Czech Chambre of Commerce, ČEZ Group, Confederation of Industry of the Czech Republic, Association for District Heating of the Czech Republic

In 2010, the Council of the EU and the European Parliament should reach an agreement on the new wording of one of the most important pieces of legislation in the environmental area, i.e. directive on industrial emissions (IPPC recast). Due to the primordial importance of the directive we have decided as representatives of the below undersigned companies to drawn up this declaration on the given proposal.

The existing directive (96/61/EC) introduced at that time revolutionary principle of complex control of the influence of industrial enterprises on the environment. After more that ten years we can state that this principle contributed to the decrease of pollution of the environment in a considerable way. We have learnt to consider new rules not only as a necessary burden of “public interest”; we have used these rules to until than unprecedented changes in our strategic reasoning and technological processes. With regard to the then state of technologies and their environmental characteristics it was not easy and not at all free of charge.

We welcome that after 15 years from the adoption of IPPC Directive, the directive is to be revised. This decision is reasoned not only by legislative reasons but also by logical explanation which mirrors the current interests of European public to contribute more deeply than before to the protection of environment on the global basis. There are new political priorities and technologies allowing better compliance with these priorities.

As each public interest this interest is meaningful only if it is feasible. Therefore, the industry has vigilantly pursued the difficult process of elaboration and adoption of the new directive. The current common position of the Council of the EU is in principle acceptable compromise in contrast to the initial Commission’s proposal. To adapt the plants to the requirements of the directive will be very demanding due to the investment costs and the companies’ processes and strategies; it is nevertheless possible. The adaptation is possible thanks to the new principles that the common position of the Council fixed, notably the possibility to achieve the given emission limit values gradually on the basis of the so-called transitional national plan and the possibility of limited life time derogation. The principle of derogations is essential in the Czech Republic the economy of which is still dependant mainly on power generation from traditional resources, notably coal.

We would consider it as a serious problem when the abovementioned rules are in the final wording of the directive abandoned or strongly limited. Our fear is led exclusively by the responsibility that has to accompany each similarly serious decision (not only) in the environmental area: the goal which is not feasible, is not a goal, but only devout wish. We want to contribute to the improvement of the environment, water and countryside of our country. However, it may not threat the viability of our enterprises to the extent that new problems would have arisen especially in the area of employment and the provision of energy to companies and households and the capacity to achieve these environmental goals in general.

For these reasons we appeal to the political representation of the Czech Republic and the other Member States in order the abovementioned flexible principles are adopted in the final wording of the new directive regulating the industrial pollution. The common position of the Council offers the acceptable solution in order to meet the new requirements on the protection of the environment. We are ready to defend our position within all the respective institutions and give detailed information for it.

COMMENTS ON PROPOSAL ON A DIRECTIVE ON INDUSTRIAL EMISSIONS (November 2009)