WHY ATTEND?

The new WGC UK BATC that form part of the consultation are “horizontal” in nature - i.e., they do not apply to one specific chemicals sub-sector but will cover many processes where emissions are to air are not otherwise covered by existing BATC. Defra estimates that the WGC UK BATC will be the main or primary set of statutory requirements establishing BAT at more than 300 chemicals installations in the UK, representing more than 75% of the total number of permitted installations.

Under the requirements of the relevant permitting regulations in England, Wales, Scotland and Northern Ireland, the respective regulators are required to update conditions in permits to reflect new BATC within four years following the publication of the BATC, although due to the number of sites affected, it is understood the permit review process will be extended to four and half years for the WGC UK BATC. The BAT-AELs will be reflected in updated permits by way of new, generally more stringent, emission limit values (ELVs). Dependent on current emissions performance, this may require operators to invest in abatement retrofits to meet new ELVs with associated upfront and ongoing costs.

However, there are provisions available within the regulations that allow regulators to set less stringent ELVs in certain circumstances. These ‘derogations’ may only be granted where an assessment shows that the achievement of BAT-AELs would lead to disproportionately higher costs compared to the environmental benefits due to: (a) geographical location or the local environmental conditions; or (b) the technical characteristics of the installation. Consequently, fundamental to the derogation clause is the requirement for a detailed assessment of financial costs and monetised environmental benefits at a site-specific level.

Cost-benefit analysis (CBA) is, therefore, a crucial component of a derogation case, and is the basis for the Environment Agency’s derogation process and accompanying tool, which members of Logika supported the Environment Agency to develop. Various approaches are available to inform the assessment of environmental benefits as part of CBAs, ranging from more basic application of largely non site-specific “damage costs”, through to more detailed impact-pathway approaches which consider, in a site-specific manner, how emissions disperse from an emission source and their resultant impacts on human health, ecosystem services, building damage and crop productivity.

The webinar will therefore:

• provide an overview of the WGC UK BATC and associated implications for the chemicals industry;
• clarify the process and expected timescales by which permits will be updated;
• provide guidance on how cost-benefit analysis can be used to support derogations from BAT-AELs, including case studies on previous derogations in other sectors; and
• provide an overview of developments in the EU on the European Commission’s strategy for harmonising the Chemicals BREF series which may act as an early indicator for the future direction of travel in the UK.

WHO SHOULD ATTEND?

The webinar is designed for operators of permitted installations that may be impacted by the WGC UK BATC. In particular, Environmental Managers, Process Engineers etc., who may be involved in the permit reviews and have to respond to regulator requests for information once the WGC UK BATC have been finalised as a statutory instrument.

AGENDA:

09.30 – 09.45: Welcome, introductions and context (Mike Squire, Head of Environment, Chemical Industries Association)

09:45 – 10:15: Background to the UK BAT development, permit review process and potential implications of the WGC UK BATC to operators (Adam Clegg, Technical Director – Industrial Emissions and Permitting Lead, Logika Group)

10:15 – 11.15: The derogation process and the role of cost-benefit analysis (David Birchby, Technical Director – Environmental Policy and Economics – Logika Group)

11.15 – 11.30: Coffee break

11:30 – 12.00: Previous derogation case studies (David Birchby and Adam Clegg)

12.00 – 12.30: EU future Chemical BREF strategy (Ben Grebot, Director – Environmental Policy and Economics – Logika Group)

12.30 – 13.00 Discussion and Q&A

**This the webinar is intended for operators only**