5. POSSIBLE SOLUTIONS AND RECOMMENDATIONS FOR INTEGRATING VALUE CHAIN CONCEPTS
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such an approach could be facilitated by focusing on cross-media aspects, or specifying consumption of input material as parameters for monitoring, when establishing the BAT-AELs. Furthermore, SYKE’s study (Dahlbo et al., 2021[39]) outlines how the EU BREF Guidance Document (EU, 2012[30]) addresses aspects related to raw materials, waste generation and recycling. The guidance document provides the following instructions:
The chapter of a BREF that concerns applied processes and techniques should include information that might be relevant in the determination of BAT, such as the use of raw materials (including secondary/recycled materials), consumables and auxiliary substances/materials used, as well as handling and fate of by-products and residues/wastes.
The BREF chapter on current emission and consumption levels should address options for the recycling and reuse of materials within the whole process or beyond.
When considering cross media effects in assessing candidate BAT, the “limitation of the ability to reuse or recycle residues/waste” should be taken into account.
Possible initial steps for the integration An example of how to practically integrate value chain concept in EU BAT Reference Documents is provided by VITO (2014[2]) (see Box 3).
Box 3. Proposed value chain approaches to developing EU BAT Reference Documents VITO proposes three approaches to considering environmental impacts upstream and downstream in the value chain when developing BAT Reference Documents in the EU: 1. Systematically consider possible positive or negative effects of a technique on other parts of the value chain or on the value chain as a whole (“cross-sector effects”), as part of the evaluation of candidate BAT for a given industrial activity. This could be similar to the way in which crossmedia effects are assessed in the EU BREF Process today. If a technique has negative effects on other parts of the value chain or on the value chain as a whole, it should not be considered BAT. That is, some techniques could be eliminated from the list of candidate BAT due to their negative impact in other parts of the value chain or on the value chain as a whole. Guidelines for this assessment would have to be developed. 2. Not limit the selection of BAT to techniques that reduce the environmental impact of the given industrial activity, but also consider techniques that would reduce the environmental impact in other parts the value chain, or in the value chain as a whole. That is, some techniques would be included in the list of candidate BAT or emerging techniques due to their positive impact in other parts of the value chain or on the value chain as a whole (value chain BAT), even if they don’t have a positive impact, or an impact at all, on the concerned industrial activity. 3. Carry out cluster studies in preparation of the development of a new or revised BREF: representatives from related industries in the value chain would come together to identify interactions across the sectors, or for example key environmental indicators for the value chain, so that this information could feed into the process to determine BAT. Source: : (VITO, 2014[2]).
This kind of integration has been implemented in Flemish BAT studies, which assess the candidate-BAT using three criteria: 1-technological feasibility, 2-impact on the environment as a whole, and 3- the BEST AVAILABLE TECHNIQUES (BAT) FOR PREVENTING AND CONTROLLING INDUSTRIAL POLLUTION © OECD 2022
