8 European professional associations advise against a hasty use of the BATAELs given in the draft incineration BREF
The professional associations CEWEP http://www.cewep.eu/, ESWET http://www.eswet.eu/, FEAD, MWE, Euroheat & Power https://www.euroheat.org/, EURITS http://www.eurits.org/, HWE and CEFIC http://www.cefic.org/ advise against a hasty use of the emission and energy efficiency levels given with the Best Available Techniques in the draft version of the BREF for Waste-to-Energy plants. Indeed, BATAEL values in the Waste Incineration BREF Draft (in particular lower ends) are not final values and need contextual information since it may happen/has happened that they are already considered as requested limit values in future permits or in calls for tenders from either consultants or local authorities. However the BREF process is actually still ongoing and the current draft has been commented by the members of the Technical Working Group, in particular because the proposed values do not consider major issues as integrated approach and measurement uncertainty. Moreover, the BREF’s BAT conclusions do not mention pieces of information provided in legislation, in JRC-EIPPCB background papers or during exchanges within the WI BREF Technical Working Group, that are of the utmost importance to avoid misunderstanding these BAT conclusions.