Analysis of the reports submitted by Member States on the
implementation of directive 2008/1/EC, Directive
2000/76/EC, Directive 1999/13/EC and further development
of the web platform to publish the information
Draft report on subtask 3: Analysis of Member States
implementation of IPPC and WI Directives – Annex A:
Member States IPPC factsheets
Report to the European Commission
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April 2010
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Draft Report
Title
Analysis of the reports submitted by the Member States and the further
development of the web platform to publish the information
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European Commission
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ANV.C.4/FRA/2007/0011
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AEA Energy & Environment
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Table of contents
Annex A
iv
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Annex A
Annex A sets out the detailed overviews of the Member States responses to the questionnaire.
For each Member State a individual fact sheet is drafted containing:
-
The main text given in the response to each qualitative question by means of a short
summary. This short summary presents the most relevant information provided by the MS in
relation to each question. The responses of the Member States are compared with the data
given in the previous reporting exercise, to see whether important changes have been made
during this reporting period. The questions are structured using the 5 main categories, used
in the reporting tool. The qualitative questions are further split into subcategories providing
an overview of specific practical approach and experiences of the Member States for each
of the main categories.
-
Presentation of the Member States quantitative data in tables;
-
The completeness table, which indicates the degree to which the answers comply with the
requirements of the questionnaire. The method described in the main report is used;
-
A summary on the status of implementation. This summary describes whether or not all
requirements are implemented into a functional and effective practical systems. In particular
the recent progress since the previous reporting made by the MS is assessed and the
implementation issues solved are enlightened.
These fact sheets were presented to the Member States for approval. All comments, clarifications
and additional information provided by the Member States were taken into account.
These fact sheets are used as the basis for the analysis made in previous chapters.
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Estonia
Overview of the answers
The table below presents the detailed analysis of Austria’s responses to each question of the
questionnaire, by means of a short summary or standardised answer where appropriate. Comments
regarding the adequacy of the answers in relation to the requirements of the questionnaire are
added where necessary.
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Table 1: Estonia – overview of the answers
Question
number
–
sub
question
reporting
tool
1
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
Category: general description
Subcategory: National legislation and legal provisions
1.1
Have any significant changes been made since the last reporting
period (2003-2005) to national or sub-national legislation and to the
permitting system(s) that implement Directive 2008/1/EC?
Yes.
Remarks
Improved legislation - 14.01.2007 adoption of changes in
Integrated Pollution Prevention and Control Act (from 17.10.
2001) for improved harmonisation of the directives 2003/35/EC,
2003/87/EC, 2003/4/EC and 2008/1/EC (on the base of first draft)
and practical experience of implementation IPPCD
Reference to legislation (2003-2005)
AEA Group
Regulations of the Minister of Environment: a) from 20.01.2006
no 6 "Requirements, which specify the contents of a permit and
standard formats for permits"; b) from 09.02.2006 no 10
"Standard formats of annexes to a permit application and the
procedure for completion"; c) from 19.03.2007 no 24
"Confirmation of the formats of the announcements about
submitted and received integrated permits applications and
issued or refused integrated permits"
IPPC Directive was transposed into national legislation by a new
legal act: -Integrated Pollution Prevention and Control Act of 2001
(IPPC Act), which was amended by -Administrative Procedure
Acts change and implementation Act of July 2002 -Integrated
Pollution Prevention and Control Acts amended Act of November
2003 -Environmental Impact Assessment and Environmental
Management System Act of Feb 2005 The Act was admitted by 4
regulations of the Ministry of Environment: - Regulation no
77/2002 specifying the contents of a permit and standard formats
for permits - Regulation no 68/2002 on permit application
contents and specific formats - Regulation no 20/2004 on access
to the public through internet concerning permit applications Regulation no 37/2002 on reporting the permit application and
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Question
number
–
sub
question
reporting
tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
Level at which legislation apply
verifying procurement form of the application Regulation
No.150/2002 of the Government of the Republic also enacted on
sub-activities and threshold capacities subject to integrated
permits and deadlines for operators of existing installations for
submitting applications for integrated permits.
National.
Please describe the changes in 2006-2008
Amendment of existing legislation.
Please describe the reasons for these changes
Part of an overall revision of the environmental legislative
framework.
Reference to new legislation or legislative framework
See above.
1.3
Describe any legally binding measures or administrative plans
established to ensure compliance with the requirements referred to
in Article 5(1) by 30 October 2007
1.4
Have operators been obliged to submit, or could competent
authorities request from operators the submission of, permit
applications for this purpose?
National legislation (IPPC Act) requires installations to operate in
compliance with requirements of best available techniques at the
latest by 30 October 2007. A regulation has been issued in 2002
specifying deadlines for operators of existing installations for
submitting applications for integrated permits; the permit
applications must be submitted on 1/1/2007 at the latest.
Yes.
Remarks
1.4.1
If Yes, please explain:
1.5
Describe any changes made since the last reporting period in the
organizational structure of the permitting procedures (levels of
authorities, distribution of competencies, etc.):
Are there changes considering the involved competent authorities?
AEA Group
Regulation of The Government "Sub-activities and threshold
capacities subject to integrated permits and deadlines for the
operators of the existing installations submitting and application
for an integrated permit" + enforcement activities taken by
Environmental Inspection (penalties)
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Question
number
–
sub
question
reporting
tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
Remarks
1.5.1
If Yes, please explain:
1.6
Are there any particular difficulties in ensuring full co-ordination of
the permitting procedure and conditions, especially where more
than one competent authority is involved, as required by Article 7?
Principle "one authority" works well, no need for any change.
No.
Remarks
1.6.1
If Yes, please explain:
1.7
Are there any legislation or guidance documents produced on this
issue?
No.
Remarks
Solved on the level of IPPC Act.
1.7.1
If Yes, please explain:
1.8
What legal provisions, procedures or guidance are used to ensure
that competent authorities refuse to grant a permit in cases where
an installation does not comply with the requirements of Directive
2008/1/EC?
Have permits been refused so far?
1.9
Set in IPPC Act, in certain case derogations up to 6 months are
possible.
Yes
Remarks
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Question
number
–
sub
question
reporting
tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
If available, give information on the numbers and circumstances in
which permits have been refused (optional):
Decrease threshold capacity of an installation, withdraw from area
of IPPC regulation.
1.9.1
Total numbers of permits that have been refused within the reporting
period
4
1.9.2
Circumstances in which permits have been refused
Subcategory: Specific Member States approach
Subcategory: Experiences of Member States
1.2
Have Member States experienced any difficulties in implementing
the Directive 2008/1/EC associated with the availability and capacity
of staff resources?
Yes
Remarks
All difficulties arose because Estonia as the new EU member
state had only 5 years for full implementation of IPPCD, instead of
11 years as old member states had. Continuous raise of staff
capacity and streamlining of implementation procedure are
evergreen needs, as well as awareness of operators.
Raise staff capacity.
1.2.1
If yes, Describe these difficulties, for instance illustrated as
appropriate by data on current resources.
1.2.2
If yes, Describe any plans to address these difficulties.
2
Category: Permit application and determination process
Streamline implementing procedure.
Subcategory: National legislation and legal provisions
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Question
number
–
sub
question
reporting
tool
2.1
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
Describe any general binding rules, guidance documents or
application forms produced to ensure that applications contain all the
information required by Article 6, either generally or in relation to
specific issues (e.g. methodology for the assessment of significant
emissions from installations).
National legislation includes all information required by Article 6 of
IPPC Directive on the permit application content. An executive
regulation (No 68/2002) standardises the permit application and
procedure for completion.
2.2
Describe any general binding rules or specific guidelines for
competent authorities that have been issued on the following issues:
2.2.1
the procedures and criteria for setting emission limit values and
other permit conditions
Set in legislation, no specific guidelines.
2.2.2
the general principles for the determination of best available
techniques
Principles is set in IPPC Act, more specifically ib subsidiary
regulation (see 1.1 a and b).
2.2.3
the implementation of Article 9(4)
Set in legislation, no specific guidelines.
2.13
For which categories of installations and which requirements, if any,
have general binding rules been established, as provided for by
Article 9(8)? (Q 8.1.1) Provide reference to the general binding rules.
No general binding rules have been established.
2.14
What form do such rules take (e.g. who establishes them and what
legal status do they have)?
No general binding rules have been established.
Who establishes them?
What legal status do they have?
Remarks
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Question
number
–
sub
question
reporting
tool
2.15
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
When applying such rules, is provision still made for taking into
account the local factors (mentioned in Article 9(4))?
No.
Remarks
2.16
If known, how many installations (either as an absolute number or a
percentage) were subject to these rules by the end of the
reporting period?
Not provided.
2.18
How do competent authorities decide in practice, under Article 12,
whether a “change in operation” may have consequences for the
environment (Article 10), and whether such a change is a
“substantial change” which may have significant negative effects on
human beings or the environment (Article 11)?
EIA reports are reviewed, for the case of significant changes in an
installation, or for smaller changes, emission limit values are
compared with the emissions of the plant. BAT techniques are
also used as a basis for comparison.
2.20
Is the frequency of reconsideration and, where necessary, updating
of permit conditions (Article 13) specified in national or sub-national
law?
Yes
Remarks
Yearly
Is there a time limit in the permits?
No.
2.21
Remarks
2.22
If determined by other means: What are those other means?
Give reference to relevant legislation, guidance or procedures
AEA Group
The permit authority reviews the permit conditions and performs
an on-site inspection at least once a year. Permits can be also
updated upon significant changes made in a plant and on the
basis of a number of other reasons, described in legislation.
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Question
number
–
sub
question
reporting
tool
2.24
2.25
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
What does the process of reconsidering and updating permit
conditions consist of?
How is the provision to reconsider permit conditions in cases of
substantial changes in the best available techniques implemented?
Give reference to relevant legislation, guidance or procedures
The frequency of reconsideration and updating of permit
conditions, is specified in national law, according to which,
reviews of the permit conditions and an on-site inspection
(environmental supervision) are carried out, at least once a year.
No experience yet.
In general terms this issue is covered by IPPC Act.
Subcategory: Specific Member States approach
2.3
How, in general terms, is the information published by the
Commission pursuant to Article 17 taken into account generally or in
specific cases when determining best available techniques?
Generally on training issues and in specific cases of permits
application and issuing processes.
2.4
How are the BREFs concretely used for setting permit conditions?
Operators use BREFs for their action plan on the introduction of
BAT. Competent authority have the rights to set conditions and
accept the action plan or propose changes of the plan.
2.5
Are the BREFs (or part of them) translated?
No, but reachable through www.envir.ee/ippc in English and
summaries in Estonian. It would be regrettable if the BAT
chapter as would be translated by Commission in all official EU
languages.
www.envir.ee/ippc
If available, provide a weblink on where these translations can be
found
2.8
Have environmental management systems been taken into account
in setting permit conditions?
Yes.
Remarks
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Question
number
–
sub
question
reporting
tool
2.9
2.10
2.11
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
If Yes, please explain how
Not provided.
What types of permit conditions or other measures have typically
been applied for the purposes of Article 3(f) (site restoration upon
definitive cessation of activities) and how have they been
implemented in practice?
What types of permit conditions relating to energy efficiency have
typically been determined (Article 3(d))?
No experiences.
How has the possibility set in Article 9(3) to choose not to impose
requirements relating to energy efficiency been used?
All installations covered by EU ETS were not subject to
requirements relating to energy efficiency.
Energy consumption norms by BAT or BAP (practice), overall
energy saving issues.
Remarks
2.12
Have any steps been taken to ensure that, in accordance with Article
11, competent authorities follow or are informed of developments in
best available techniques?
Yes.
Remarks
If so, provide details
Regular training for competent authorities, availability of new
information via internet, including intranet.
If not, what plans are there to meet this requirement?
2.17
Have cases arisen where Article 10 applies and the use of best
available techniques is insufficient to satisfy an environmental quality
standard set out in Community legislation (as defined in Article
2(7))?
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Question
number
–
sub
question
reporting
tool
2.23
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
What is the representative frequency (or expected representative
frequency) for the reconsideration of permit conditions?
Once a year.
Subcategory: Experiences of Member States
2.6
How useful, as a source of information for determining emission limit
values, equivalent parameters and technical measures based on
the best available techniques, is the information published by the
Commission pursuant to Articles 17?
How could it be improved?
Important as base for permit conditions.
2.19
How many applications for ‘substantial changes’ were determined
during the reporting period? Provide the data by activity type,
referring to the template and notes laid down in part 2.
Not available.
3
Category: Compliance and enforcement
2.7
By improvement of BREFs quality.
Subcategory: National legislation and legal provisions
3.4
Give reference to any specific regulations, procedures or guidelines
for competent authorities on this subject.
Many laws, for example IPPC Act, Ambient Air Protection Act,
Water Act, Waste Act etc, and subsidiary regulations contains
provisions and general description of procedures.
Subcategory: Specific Member States approach
3.1
How do operators regularly inform authorities of the results of
release monitoring?
Electronically – e-mail; information on paper.
Remarks
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Question
number
–
sub
question
reporting
tool
3.2
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
Provide information on the representative frequency for the
submission of such information.
Quarterly and annually.
Remarks
3.3
Is a periodic monitoring report submitted by operators?
Yes.
Remarks
3.5
To the extent available, and if not submitted in the reporting under
the Recommendation providing for minimum criteria for
environmental inspections in the Member States, provide
representative information, as regards installations falling under the
scope of Directive 2008/1/EC, on the carrying-out of on-site
inspections and the taking of samples (type, number, frequency).
Regular inspection once in year is set in IPPC Act. On-site
inspection may include sampling, measurements, other analyses
etc, but it depends from the case. Local criteria based on IMPEL
criteria is under elaboration.
3.6
What types of actions (e.g. sanctions or other measures) have been
taken as a result of accidents, incidents and non-compliance with
permit conditions.
Fine or penalty.
Subcategory: Experiences of Member States
3.5.1
(Optional) If available, provide the total number of site visits during
the reporting period.
3.5.2
(Optional) If available, provide the number of installations where site
visits took place.
3.5.3
(Optional) Are samples taken during site visits?
AEA Group
2006: 8
2007: 16
2008: 17
Only these site-visits where enforcement activity was used.
2006: 8
2007: 16
2008: 17
In some cases.
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Question
number
–
sub
question
reporting
tool
3.5.4
4
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
(Optional) If available, provide information on the type and number of
samples taken.
Not available.
Category: Access to information, public participation
and transboundary cooperation
Subcategory: National legislation and legal provisions
4.1
What, if any, significant changes have there been since the last
reporting period to transposing legislation providing for information
and participation of the public in the permit procedure, as required by
Directive 2008/1/EC (Articles 15 and 16) ?
National legislation provides for public information and
participation in the permit procedure by Chapter 3, par. 29 and
par. 32.
If there have been significant changes, please describe these
There have been significant changes.
Improved relationship with public (wider internet access to
information including access to single permit applications and
permits via internet as well as results of yearly overview of single
permits).
Subcategory: Specific Member States approach
Subcategory: Experiences of Member States
4.2
If there have been significant changes, what has been the effect
upon competent authorities, permit applicants and the public
concerned of the amended requirements?
Remarks
4.3
Have there been instances in the reporting period of the use of
Article 18 requirements in respect of transboundary information and
cooperation?
AEA Group
Wider internet access to information related to IPPC directive
Access to single permits applications via internet
Access to monitoring data via internet
Other
Improved access and more frequent update of all four
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Question
number
–
sub
question
reporting
tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
If Yes, provide examples illustrative of the general procedures used.
5
Category: Other
Subcategory: National legislation and legal provisions
Subcategory: Specific Member States approach
5.3
What measures have been taken within national or sub-national
legislation or administrative arrangements to increase coherence
between implementation of the Directive 2008/1/EC and other
instruments?
Council Directive 85/337/EEC on the assessment of the effects of
certain public and private projects on the environment
All applications for new and substantially changed installations
were assessed.
Council Directive 96/82/EC on the control of major accident
hazards involving dangerous substances
IPPC permit applications for the installations contains accident
prevention plans and permits relevant requirements.
Council Directive 1999/13/EC on the limitation of
emissions of volatile organic compounds due to the
use of organic solvents in certain activities and
installations
Council Directive 1999/31/EC on the landfill of
waste
IPPC permit applications and permits contains tables for that and
STS BREF is in use.
Directive 2000/60/EC of the European Parliament
and of the Council establishing a framework for
Community action in the field of water policy
IPPC permit applications and permits contains tables for water
intake, purification of waste water and monitoring of discharge
into sewage or water bodies.
Directive 2000/76/EC of the European Parliament
and of the Council on the incineration of waste
No municipal waste incineration plants in Estonia, some industrial
installations works as co-incinerators. In the case IPPC permit
applications contains relevant data and permits requirements.
AEA Group
IPPC permit applications and permits contains tables for that and
WT BREF is in use.
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Question
number
–
sub
question
reporting
tool
5.4
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
Directive 2001/80/EC of the European Parliament
and of the Council on the limitation of emissions of certain pollutants
into the air from large combustion plants
IPPC permit applications and permits contains tables for that and
STS BREF is in use.
Directive 2003/87/EC of the European Parliament
and of the Council establishing a scheme for
greenhouse gas emission allowance trading
All relevant IPPC installations are subject to ETS and have
emission permits fot ETS.
Regulation (EC) No. 166/2006 of the European
Parliament and of the Council establishing the
European Pollutant Release and Transfer Register
All IPPC installations oblidged to quarterly report to environmental
authorities and ministerial Information Center to Minister of
Environment and EC. Generalized data are publicly available.
Other:
Not available.
Have measures been introduced at national or sub-national levels to
streamline the reporting requested by competent authorities from
operators under the Directive 2008/1/EC and other Community
instruments?
Remarks
Yes.
If yes,
(Optional) If available, provide reference to such measures, and any
possibilities that you see for improvement of the EU requirements in
this area.
Duplication of reporting is avoided so much as it possible.
-
Subcategory: Experiences of Member States
5.1
How do Member States generally view the effectiveness of Directive
2008/1/EC, inter alia in comparison with other Community
environmental instruments?
Effective tool in combating industrial pollution.
Remarks
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number
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reporting
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5.2
5.3
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
Based on relevant studies and analysis, if available, what have been
the estimated environmental benefits and costs (including
administrative and compliance costs) of implementing the Directive
2008/1/EC? Give references to these studies and analyses.
No studies available.
What is your practical experience regarding the interface between
the permitting requirements under the Directive 2008/1/EC and
other Community instruments which can apply to installations falling
under scope of Directive 2008/1/EC?
Council Directive 85/337/EEC on the assessment of the effects of
certain public and private projects on the environment
Environmental impact assessment is one part of IPPC permitting
procedure for new and substantially changed installations based
on Estonian EIA and EMS Act and IPPC Act.
Council Directive 96/82/EC on the control of major accident
hazards involving dangerous substances
Taken into account in the Estonian IPPC Act and specified in
relevant ministerial subsidiary regulations (content and forms of
IPPC permit applications and permits).
Council Directive 1999/13/EC on the limitation of
emissions of volatile organic compounds due to the
use of organic solvents in certain activities and
installations
Council Directive 1999/31/EC on the landfill of
waste
Taken into account in the Estonian IPPC Act and specified in
relevant ministerial subsidiary regulations (content and forms of
IPPC permit applications and permits).
Directive 2000/60/EC of the European Parliament
and of the Council establishing a framework for
Community action in the field of water policy
Taken into account in the Estonian IPPC Act and specified in
relevant ministerial subsidiary regulations (content and forms of
IPPC permit applications and permits).
Directive 2000/76/EC of the European Parliament
and of the Council on the incineration of waste
Directive 2001/80/EC of the European Parliament
and of the Council on the limitation of emissions of certain pollutants
into the air from large combustion plants
Taken into account in the Estonian IPPC Act and specified in
relevant ministerial subsidiary regulations (content and forms of
IPPC permit applications and permits).
Directive 2003/87/EC of the European Parliament
and of the Council establishing a scheme for
greenhouse gas emission allowance trading
Taken into account in the Estonian IPPC Act and specified in
relevant ministerial subsidiary regulations (content and forms of
IPPC permit applications and permits).
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Question
number
–
sub
question
reporting
tool
Main category
Subcategory: approach or experiences
Summary of MS response
Comments
Question (Q)
Regulation (EC) No. 166/2006 of the European
Parliament and of the Council establishing the
European Pollutant Release and Transfer Register
Regulation is under full implementation.
Other:
5.5
Are there any particular implementation issues that give rise to
concerns in your country?
No.
Remarks
If yes, please specify
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Member State quantitative data
The table below presents the data related to ‘Numbers of installations and permits’ (question 2.1 of the original questionnaire). X = answered with: “Not relevant
for Estonia.
Ins tallation type
Pe r m its for ne w ins tallations
Pe r m its for e xis ting ins tallations
Othe r data
1. No. Of new
installation at the
end 2008
2. No. of permits
granted by end
2008
3. No. of existing
installations
operating at end
2008
4. No. of permits
granted under
A rts. 6 and 8 by
end 2008
1. Ene r gy
0
0
13
13
X
X
1.1. Combustion
0
0
10
10
X
X
0
10
0
1.2 Mineral oil and gas ref ining
0
0
3
3
X
X
0
3
0
1.3. Coke ovens
0
0
0
0
X
X
0
0
0
1.4. Coal gasif ication and liquef action
0
0
0
0
X
X
0
0
Installation type based on A nnex I activity to
Directive 96/61/EC
2. Fe r r ous m e tals
0
0 4
X
X
0
X
X
0
0
0
2.2. Producing pig iron or steel
0
0
0
0
X
X
0
0
0
2.3 (a) Hot-rolling mills
0
0
0
0
X
X
0
0
0
2.3 (b) Smitheries
0
0
0
0
X
X
0
0
0
2.3 (c) A pplying f used metal coats
0
0
0
0
X
X
0
0
0
2.4. Foundries
0
0
1
1
X
X
0
1
0
2.5 (a) Producing non-f errous crude metals
0
0
1
0
X
X
1
1
0
2.5 (b) Smelting non-f errous metals
0
0
0
0
X
X
0
0
0
2.6. Surf ace treatment of metals and plastic
0
0
3
3
X
X
0
3
0
3. M ine r als
0
X
X
3.1. Producing cement or lime
0
0
2
2
X
X
0
2
0
3.2. Producing asbestos
0
0
0
0
X
X
0
0
0
3.3. Manuf acture of glass
0
0
1
1
X
X
0
1
0
3.4. Melting minerals
0
0
0
0
X
X
0
0
0
3.5. Manuf acture of ceramics
0
0
3
3
X
X
0
3
0
4. Che m icals (s e e note 8)
0
0
9
8
X
X
1
9
0
4.1. Producing organic chemicals
0
0
7
6
X
X
1
7
0
4.2 Producing inorganic chemicals
0
0
0
0
X
X
0
0
0
4.3 Producing f ertilisers
0
0
1
1
X
X
0
1
0
4.4 Producing plant health products/biocides
0
0
0
0
X
X
0
0
0
4.5 Producing pharmaceuticals
0
0
0
0
X
X
0
0
0
4.6 Producing explosives
0
0
1
1
X
X
0
1
0
0
4
4
X
X
4
0
6
0
0
5
0
0
6
1
13
0
0
5
8. No; of
installations
0
0
0
0
2.1. Metal ore roasting/sintering
5. Was te
0
6. No. of permits
reconsidered and
updated by end
2008
7. No., if any, of
outstanding
permits at end
2008 (in conf lict
w ith Directive)
9. No of
applications f or
‘substantial
changes’
determined during
the reporting
period
5. No. of IPPC
permits
reconsidered but
not updated by
end 2008
6
0
5.1. Disposal or recovery of hazardous w aste
0
0
4
4
X
X
0
4
0
5.2. Incineration of municipal w aste
0
0
0
0
X
X
0
0
0
5.3. Disposal of non-hazardous w aste
0
0
0
0
X
X
0
0
0
5.4. Landf ills
0
0
0
0
X
X
0
0
0
53
52
X
X
1
53
0
6.1 (a) Producing pulp
1
1
1
1
X
X
0
2
0
(b) Producing paper and board
0
0
1
1
X
X
0
1
0
6.2. Pretreatment or dyeing of f ibres or textiles
0
0
1
1
X
X
0
1
0
6.3. Tanning hides and skins
0
0
0
0
X
X
0
0
0
6.4. (a) Slaughterhouses
0
0
0
0
X
X
0
0
0
6.4 (b) Treatment and processing of f ood
products
0
0
1
1
X
X
0
1
0
6.4 (c) Treatment and processing of milk
0
0
2
2
X
X
0
2
0
6.5. Disposal or recycling of animal carcasses
1
1
0
0
X
X
0
1
0
6
6
X
X
0
6
0
34
33
X
X
1
34
0
see 6.6.b
see 6.6.b
X
X
8
8
X
X
0
8
0
6. Othe r
6.6 (a) Intensive rearing of poultry
6.6 (b) Intensive rearing of production pigs
0
0
6.7. Surf ace treatment using organic solvents
0
0
6.8. Producing carbon or electrographite
0
0
0
0
X
X
0
0
0
Totals
2
2
100
96
0
0
4
102
0
6.6 (c) Intensive rearing of sow s
AEA Group
22
Unrestricted
Analysis of the reports submitted by the Member States
Framework contract No. ENV/C.4/FRA/2007/0011
Draft Report
Analysis of completeness
Table presents the level of completeness of the report of Estonia
Table 2: Estonia – Completeness analysis table
Question
number,
subquestion
Level of
completeness
Comments
1.1
1.2
1.3
1.4
1.5
1.6
1.7
1.8
1.9
2.1
2.2
No clear answer.
2.3
2.4
2.5
2.6
2.7
2.8
2.9
2.10
2.11
2.12
2.13
2.14
2.15
23
Unrestricted
Analysis of the reports submitted by the Member States
Framework contract No. ENV/C.4/FRA/2007/0011
Draft Report
Question
number,
subquestion
2.16
2.17
2.18
2.19
2.20
2.21
2.22
2.23
2.24
2.25
3.1
3.2.
3.3
3.4
3.5
3.6
4.1
4.2
4.3
5.1
5.2
5.3
5.4
5.5
24
Level of
completeness
Comments
Unrestricted
Analysis of the reports submitted by the Member States
Framework contract No. ENV/C.4/FRA/2007/0011
Draft Report
Analysis of implementation status
Estonia provides a clear and (fairly) complete overview of the national legislation and the legal
provisions in place to ensure compliance with the IPPC Directive (including art 5(1)).
In Estonia, significant changes have been made since the last reporting period (2003 - 2005) to
national legislation and to the permitting system(s) that implement the IPPC Directive.
Regarding the permit application and determination procedures, Estonia describes all relevant
procedures, criteria and general principles. Based on the information made available, it is
however not clear whether the general principles for the determination of BAT are in conformity
with art. 10 and Annex IV of the IPPC Directive (question 2.2.2).
Depending on the BREF, they are regarded as not useful to very useful. They are used, by
operators, for making action plans. To improve their usefulness/practicability Estonia suggests to
improve the quality of the BREFs. Regarding the follow-up of developments in BAT by competent
authorities, Estonia has taken steps, e.g. the dissemination of information via trainings and
intranet.
Regulations, procedures, guidelines to ensure compliance with permit conditions and
enforcement are in place. Operators are obliged to report the results of release monitoring
quarterly and annually. Installations are inspected (based on the data, the number of inspections
is limited). In some cases samples are taken.
In general, Estonia views the IPPC Directive as an effective tool in combating industrial pollution.
Estonia experienced the implementation period of 5 years, for new EU members, as too short.
25
Unrestricted
Analysis of the reports submitted by the Member States
Framework contract No. ENV/C.4/FRA/2007/0011
Draft Report
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