The first draft of the BREF was published in December. This was sent to members asking for feedback, particularly on the BAT conclusions (chapter 6).
REA sits on the Technical Working Group (TWG) and attended a meeting in Berlin in January to discuss the draft with the Biological Treatment subgroup. Discussions focused on Chapter 6 the BAT conclusions. Lots of clarity is needed over many points but the major ones seem to be:
- Clarity needed over definitions of certain things as currently the definition of MBT could include composting and AD and it is not thought to be the intention to require composting and AD to comply with the BATs for MBT.
- Monitoring of emissions to air, clarity is needed as to the methodology of testing as without this being defined there is little point setting emission limits and some of the limits are below the level of detection
- Generally a lack of clarity over how the Associated Emission Limits (AELs) for air and water seem to have been set with very little data, need to question how appropriate these are
- Monitoring emissions from biofilters doesn’t consider odour and could be more relevant
- Confusion between indirect and direct emissions to water
Going forward the Biological Treatment Subgroup will be preparing feedback to the Commission.
In addition to this, the REA will be providing feedback on the UK’s response and will be drafting comments directly. We plan to give members an opportunity to comment on these then submit directly to the Commission and to our European Trade Associations.
If you would like to discuss this further, or have comments, please contact Jenny Grant on firstname.lastname@example.org or by 'phone: 07796 430168.