EURELECTRIC
issued a response to EC Public Consultation on the Evaluation of the European
Pollutant Release and Transfer Register (E-PRTR) regulation (see full documenthere).
EURELECTRIC
considers Regulation (EC) No. 166/2006 concerning the establishment of a European Pollutant Release and Transfer Register (E-PRTR) as a cornerstone of
the EU’s regulatory framework for the protection of the environment and health in
Europe.
EURELECTRIC supports the aim of harmonising emission monitoring and reporting
across countries an d has published recommendations , in collaboration with VGB, for a
European ‐wide sector ‐specific calculation method for reporting to the E-PRTR. It
document, first published in 2008, includes emission factors that EURELECTRIC’s
members are invited to use for the reporting of obligations to their respective authorities.
EURELECTRIC would like to take the opportunity of the E-PRTR REFIT process and
consultation to address the main issues experienced by its members as data
providers as well as data users.It must be noted, that EURELECTRIC considers that
there is scope for improvement of the 2006 E-PRTR Guidelines. The following issues have been identified as needing harmonisation
and/or guidance at the EU level:
· Reporting and clear evidence for anyone accessing the register of the quality level of data (e.g. based on direct measurement, calculation or estimation, with different level of accuracy).
· Methodology to deal with emission reporting (in the air and in the water) when emissions are below the Limit of Quantification (LOQ).
· Clear deduction of the background load from water intake in the emissions into water.
· Use of non - validated emission concentration (as defined in IED Annex V Part 4) for annual mass emission reporting of pollutants continuously monitored.
· Recommendation to use EU - wide sectorial Emission Factors when available, and preferably to single periodic measurements, in order to improve the consistency of the database.
· Clarification of the reporting required in case of intermediate transfer of waste.
