Ervaring met afwijkingen van de BBT-GEN's van de RIE

This report, published in 2015, examines the early implementation of Article 15 of the Industrial Emissions Directive (IED), which allows derogations from Best Available Techniques Associated Emission Levels (BAT-AELs). The report highlights the challenges faced by competent authorities in assessing derogation requests, particularly in conducting cost-benefit analyses and defining disproportionate costs. It concludes with recommendations for future work, including the development of guidance and a follow-up project.

This report, published in 2017, builds upon the 2014 report by examining the experiences of IMPEL members in granting or refusing derogations from BAT-AELs. It identifies key challenges, including inconsistent interpretations of BAT conclusions and difficulties in quantifying environmental impacts, particularly for emissions to water. The report emphasizes the need for clearer BAT conclusions and recommends the development of standard damage costs for various pollutants