14 1. WHAT’S THE ISSUE? specific activity may be impacted by upstream suppliers and affect downstream activities including further processing or consumer use that are not necessarily considered in BAT determinations. Additionally, the sector of focus could impose requirements upon upstream markets or be affected by downstream regulatory or market requirements. Environmental regulation along with other regulatory requirements and market decisions define the framework within which an industrial installation operates. Sector activities, including essential inputs, are increasingly fragmented across the globe with installations carrying out a variety of different industrial processes. The different processes and installations from an individual production chain may be located in different countries (VITO, 2014[2]). These production chain complexities and the broad array of factors, affecting a given industrial activity are not fully understood. In general, the establishment of BAT is focused upon dealing with industrial activities individually, in isolation. As such, there is the possibility that the BAT approaches identified do not adequately consider interactions with other industries and actors as shown in Figure 2.
Figure 2. Current Application of BAT
Source: (Huybrechts, D et al, 2018[3])
In the illustration above, the box is representative of established BAT requirements or guidance for a given sector. Global assessment across the value chain (significant up-stream and/or connected operations, and relevant earlier steps of associated activities with a technical connection) may indicate that the prescribed BAT-associated emission levels optimise environmental performance in one industrial process while at the same time have negative environmental implications on, influence the costs of, or the need for new techniques in, other parts of the value chain (VITO, 2014[2]). While the multi-stakeholder groups in charge of establishing BAT – known as Technical Working Groups in some countries – may consider value chain effects in the development of some BREFs, this is usually not done systematically (VITO, 2014[2]). Industrial symbiosis and circular economy are described in Chapter 2 and Chapter 3, respectively. This lack of systematic methodology for value chain consideration may result in regulatory gaps, deficiencies or no net gain in pollution prevention or reduction. Thus, researchers have called for more explicit and methodical approaches to ensure that BAT form a consistent BEST AVAILABLE TECHNIQUES (BAT) FOR PREVENTING AND CONTROLLING INDUSTRIAL POLLUTION © OECD 2022
