Screening Regulatory Impact Analysis Proposed Directive on Industrial Emissions 1. INTRODUCTION 1.1 This is a Screening Regulatory Impact Analysis (RIA) on the proposed Directive on Industrial Emissions (Integrated Pollution Prevention and Control). The proposed Directive revises and merges seven separate existing Directives related to industrial emissions into a single Directive. The Directive proposes to amend and simplify existing legislation related to industrial emissions which applies minimum standards for the prevention and control of industrial emissions across the whole Community. A copy of the proposed Directive is available on the Department's website (www.environ.ie). 1.2 The purpose of this Screening RIA is to outline the contents of the proposed Directive and to seek the views of stakeholders so as to inform Ireland's negotiating position with a view to minimising any potentially negative implications for Ireland. Comments are invited on any aspect of this document or on any aspect of the proposed Directive. Comments must be received by 25 July 2008. 1.3 This Screening RIA will be subject to further amendment and refinement in light of the negotiations at European level, and as part of the subsequent transposition of the adopted Directive into Irish law. 2. DESCRIPTION OF POLICY CONTEXT, OBJECTIVES AND OPTIONS 2.1 Policy Context 2.1.1 Emissions from industrial installations have been subject to EU-wide legislation for some time. This legislation includes: - Directive 96/61/EC concerning integrated pollution prevention and control (IPPC) which sets out the main principles for the permitting and control of installations based on an integrated approach and the application of best available techniques (BAT) which are the most effective techniques to achieve a high level of environmental protection, taking into account the costs and benefits; and - sectoral Directives which regulate the emissions (generally to air and water) of installations from certain industrial sectors; these Directives define specific requirements (generally emission limit values and monitoring provisions) for certain pollutants for the installations concerned; the Directives are those relating to large combustion plants (2001/80/EC), waste incineration Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 1 of 13 (2000/76/EC), and activities using organic solvents (99/13/EC) and waste from the titanium dioxide industry (78/176/EEC, 82/883/EEC, 92/112/EEC). 2.1.2 In 2005, the European Commission launched a review of the EU industrial emissions legislation with a view to ensuring its environmental and cost-effectiveness. The review involved an extensive programme of studies and continuous and structured consultation with stakeholders. 2.1.3 Based on a detailed analysis of the current situation and the outcome of the review process, the Commission identified five specific problems: - insufficient implementation of Best Available Techniques (BATs) leading to limited progress in the prevention and reduction of industrial emissions and to distortion of competition due to large differences in environmental standards; - limitations with regard to compliance, enforcement and environmental improvements that hinder environmental effectiveness and the stimulation of innovation; - unnecessary administrative burdens due to the complexity and inconsistency of parts of the current legal framework; - insufficient scope and unclear provisions of the current IPPC Directive that could hinder the achievement of the objectives set in the Commission's Thematic Strategies (Air Pollution, Soil Protection, and Prevention and Recycling of Waste); and - a constraint on the use of more flexible instruments such as NO x and SO2 emission trading systems. 2.1.4 The Commission is now proposing a Directive on industrial emissions aimed at strengthening the provisions already in force and reducing industrial emissions throughout the EU. The proposed Directive and Explanatory Memorandum was published by the Commission on their website on 21 December 2007. In addition, the Commission also published a number of accompanying documents, these are their: Impact Assessment of the Proposed Directive; an Executive Summary of this Impact Assessment; and policy document, Towards an improved policy on industrial Emissions. These documents are available on the Commission's website (http://ec.europa.eu/environment/ippc/proposal.htm). 2.1.5 The main features of the proposed Directive on industrial emissions are outlined in Appendix 1. 2.2 Objectives 2.2.1 The overall objective of the proposed Directive is to prevent and control pollution and its impacts arising from industrial activities so as to achieve a high level of protection of human health and the environment; and to achieve this in the most cost-effective and efficient way while ensuring the reduction of unnecessary administrative Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 2 of 13 burdens. To achieve this overall objective, the proposed Directive has a number of specific objectives and these are outlined below. 2.2.2 The proposed Directive aims to increase the effectiveness of the legislation by supporting Member States in implementing BAT-based permitting. The Directive aims to improve and clarify the concept and use of BAT and increases transparency by requiring that the use of flexibility must be justified and documented leading to a more coherent and EU-wide application of BAT. It also strengthens existing minimum requirements in certain sectors such as Large Combustion Plants so as to ensure the achievement of objectives of the Commission's Thematic Strategy on Air Pollution. 2.2.3 The proposed Directive aims to further increase the effectiveness of the legislation by strengthening provisions on enforcement and environmental improvement, while stimulating innovation. The Directive introduces minimum provisions on environmental inspections of installations, the review and update of permits, and reporting of compliance. It also provides incentives for the development and promotion of environmentally-friendly technologies. 2.2.4 The proposed Directive aims to cut all identified unnecessary administrative burden and simplify current legislation. The Directive tackles the shortcomings of current EU legislation on industrial emissions by overhauling the seven existing pieces of legislation on industrial emissions. It aims to improve the clarity and coherence of the legislation and reduces the administrative burden through combined requirements on granting permits and streamlined reporting. 2.2.5 The proposed Directive aims to better contribute to the objectives of the Thematic Strategies by amending, where cost-effective, the current scope and provisions of the IPPC Directive. The Directive clarifies the current scope of the IPPC Directive including waste treatment activities. It provides for the inclusion of some additional activities in the IPPC code such as combustion installations between 20 and 50 MW, preservation of wood and wood products, production of wood based panels, and specific waste treatment activities. It also introduces more specific provisions on soil monitoring and remediation. 2.3 Identification of Options 2.3.1 The proposed Directive will be subject to discussion and negotiation by the Commission's Environment Working Group, made up of representatives from all the Member States and will require political agreement by Environment Ministers. In addition, the approval of the European Parliament will also be required. 2.3.2 As such, the final text of the Directive will depend on the outcome of these negotiations and discussions. It is unclear how long this negotiation period will be. The proposed Directive suggests that the Directive would enter into force on 1 January 2011 and that Member States would be given 18 months to transpose the proposed Directive. Some transitional provisions are provided in the proposed Directive to allow existing installations time to technically adapt to the new requirements of the Directive Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 3 of 13 2.3.3 The options for transposing the proposed Directive will be considered in light of the final negotiated text of the Directive when it is adopted by the Council and the Parliament. 2.3.4 The recasting and revision of the seven pieces of existing EU legislation would inevitably result in a review of existing domestic legislation and amendments where appropriate. The table below outlines details of the domestic legislation which will need to be examined in light of the final negotiated text of the Directive when adopted by the Council and the Parliament. Community Legislation Details of Domestic Legislation transposing these Directives Council Directive 78/176/EEC of 20 February 1978 on waste from the titanium dioxide industry Council Directive 82/883/EEC of 3 December 9182 on procedures for the surveillance and monitoring of environments concerned by waste These Directives have not been transposed from the titanium dioxide industry into Irish law as Ireland does not have a Council Directive 92/112/EEC of 15 December titanium dioxide industry 1992 on procedures for harmonizing the programmes for the reduction and eventual elimination of pollution caused by waste from the titanium dioxide industry (the last three are known collectively as "TiO2 Directives") Council Directive 96/61/EC of 24 September The Environmental Protection Agency Acts 1996 concerning integrated pollution prevention 1992 to 2003, the Environmental Protection and control ("IPPC Directive") Agency (Licensing) Regulations 1994 to 2004, and the Waste Management (Licensing) Regulations 1997 to 2004 primarily transpose the IPPC Directive. Details of the full suite of relevant legislation are outlined at Appendix 2. Council Directive 99/13/EC of 11 March 1999 on Environmental Protection Agency Acts 1992 to the limitation of emissions of volatile organic 2003, Emissions of Volatile Organic compounds due to the use of organic solvents in Compounds from Organic Solvents certain activities and installations ("VOC Solvents Regulations 2002 (S.I. No. 543 of 2002), Directive") Limitation of Emissions of Volatile Organic Compounds due to the use of Organic Solvents in Certain Paints, Varnishes and Vehicle Refinishing Products Regulations 2007 (S.I. No. 199 of 2007) Directive 2000/76/EC of the European Parliament The Environmental Protection Agency Acts and of the Council of 4 December 2000 on the 1992 to 2003, the Environmental Protection incineration of waste ("Waste Incineration Agency (Licensing) Regulations 1994 to 2004, Directive") and the Waste Management (Licensing) Regulations 1997 to 2004, Waste Management Act 1996, European Communities (Incineration of Waste) Regulations 2003 (S.I. No. 275 of 2003) Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 4 of 13 Community Legislation Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on the limitation of emissions of certain pollutants into the air from large combustion plants ("LCP Directive") Details of Domestic Legislation transposing these Directives The Environmental Protection Agency Acts 1992 to 2003, Air Pollution Act 1987, Large Combustion Plants Regulations 2003 (S.I. No. 644 of 2003) 3. IDENTIFICATION OF COSTS, BENEFITS AND IMPACTS 3.1 Costs 3.1.1 The proposed Directive has cost implications for the operators of those activities coming within the scope of the Directive. It also has implications for the EPA as the EPA has already been designated as competent authority for most of the Directives which are now being amended by the proposed Directive. The extent of the cost implications for these and others that may be affected by the proposed Directive will depend on the final negotiated text when (and if) the Directive is adopted by the Council and the Parliament, and on its subsequent transposition into Irish law. However, stakeholders may identify specific cost implications of the proposed Directive as part of the consultation on this Screening RIA. 3.1.2 The Commission in their Impact Assessment of the proposed Directive considers that the Directive will eliminate unnecessary administrative burdens through combined permitting and through streamlined reporting and monitoring and as such will provide cost savings for both operators and competent authorities. 3.2 Benefits 3.2.1 The proposed Directive has benefits for the operators of those activities coming within the scope of the Directive, the EPA as competent authority for the Directives being amended by the proposed Directive, and for consumers in general. The extent of the benefits for these and others that may be affected by the proposed Directive will depend on the final negotiated text when the Directive is adopted by the Council and the Parliament, and on its subsequent transposition into Irish law. However, stakeholders may identify specific benefits of the proposed Directive as part of the consultation on this Screening RIA. 3.2.2 The Commission in their Impact Assessment of the proposed Directive considers that the Directive will provide health and environmental benefits from enhanced take up of BAT, the inclusion of additional (IPPC) activities within the scope of the proposed Directive, and specific provisions relating to the application and enforcement of the proposed Directive leading to the achievement of environmental objectives. Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 5 of 13 3.3 Other Impacts 3.3.1 The Commission in their Impact Assessment of the proposed Directive considers that the Directive will have no significant long-term impacts on competitiveness, social impacts or detrimental long-term effects on economic growth given possible flexibility in well-founded and documented cases. In addition, the analysis showed that a more unified application of BAT would help reduce distortion of competition in the industry sectors covered by the proposed Directive. 3.3.2 The impacts on National Competitiveness, Socially Excluded or Vulnerable Groups, the Environment, Consumers and Competition, the Rights of Citizens, and Compliance Burdens will depend on the final negotiated text when the Directive is adopted by the Council and the Parliament, and on its subsequent transposition into Irish law. However, stakeholders may identify specific impacts of the proposed Directive in this area as part of the consultation on this Screening RIA. 3.3.3 The Directive will, to some extent, involve familiarisation for regulating authorities and licensees with a new statutory framework at a time when many licensees, especially those whose activities are within the IPPC system, are only now becoming conversant with the existing regulatory regime. The question might be asked as to whether the Commission could secure some of the benefits it seeks (more uniform use of BAT, for example) through amending existing regulatory provisions as opposed to replacing them with a new and complicated system. 3.4 Summary of Costs, Benefits and Impacts 3.4.1 The summary of costs, benefits and impacts will be identified in light of the outcome of the consultation on this Screening RIA, the conclusions on the final negotiated text when the Directive is adopted by the Council and the Parliament, and having regard to the transposition of the Directive into Irish law. 4. CONSULTATION 4.1 In formulating their proposals on the proposed Directive, the Commission undertook an extensive programme of studies and continuous consultation with stakeholders. Details of the consultation is outlined in the Commission's Impact Assessment of the proposed Directive. 4.2 As part of the negotiations on the proposed Directive, the Department is engaging with other Government Departments, agencies, and key stakeholders as well as the public in general and this Screening RIA is being placed on the Department's website (www.environ.ie) for this purpose. The outcome of this consultation process and other further consultations that will arise in transposing the final negotiated and adopted Directive will be recorded in the final version of this RIA. Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 6 of 13 5. ENFORCEMENT AND COMPLIANCE 5.1 The EPA is the competent authority for the Directives that are being recast in the proposed Directive. As such, it is envisaged that the EPA will be the appropriate agency to enforce the proposed Directive. However this will depend on the final negotiated text of the Directive when it is adopted by the Council and the Parliament. 6 REVIEW 6.1 Mechanisms to review the Directive will depend on the final negotiated text of the Directive when it is adopted by the Council and the Parliament. Environment Policy Section Department of the Environment, Heritage and Local Government April 2008 Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 7 of 13 Appendix 1 Main Features of the Proposed Directive on Industrial Emissions Aim The proposed Directive on industrial emissions is aimed at strengthening the provisions already in force and reducing industrial emissions throughout the EU. Content The proposed Directive revises and merges seven separate existing Directives related to industrial emissions into a single Directive. The seven existing Directives are the : - 3 Titanium Dioxide Directives (78/176/EEC, 82/883/EEC and 92/112/EEC on waste from the titanium dioxide industry); - Integrated Pollution Prevention and Control (IPPC) Directive (96/61/EC); - Volatile Organic Compounds (VOC) Solvents Directive (99/13/EC); - Waste Incineration Directive (2000/76/EC); and - Large Combustion Plants (LCP) Directive (2001/80/EC). The European Commission uses the recasting technique to combine in single text both the substantive amendments proposed to the Directives and those of their original provisions which remain unchanged. The relationship between the various articles and annexes in each of the seven existing Directives with the proposed Directive are outlined in Annex X of the proposed Directive. The adoption of the proposed Directive will lead to the repeal of the seven existing Directives (Article 72 and Annex IX of the proposed Directive refers). Scope of Proposed Directive The proposed Directive applies to : - activities covered by the IPPC Directive and other activities which are being included in the IPPC code; these are listed in Annex I and further details of these are provided below (Article 11 of the Proposed Directive refers); - activities covered by the VOC Solvents Directive; these activities are those listed in Part I of Annex VII which reach the consumption thresholds set out in Part 2 of that Annex (Article 51 of the Proposed Directive refers); - combustion plants designed for production of energy, the rated thermal input of which is equal to or greater than 50 MW irrespective of the type of fuel used (Article 31 of the Proposed Directive refers); - waste incineration plants and waste co-incineration plants which incinerate or coincinerate solid or liquid waste (Article 38 of the Proposed Directive refers); and - installations producing titanium dioxide (Article 61 of the Proposed Directive refers). Structure of the Proposed Directive The proposed Directive is divided into 7 Chapters containing a total of 75 Articles and 10 Annexes. A summary of the contents of these Chapters is outlined below. Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 8 of 13 Chapters Chapter I (Articles 1 to 10) contains common provisions dealing with definitions, scope, issues relating to the holding and granting of a permit and compliance matters. This Chapter primarily recasts the IPPC Directive but includes some amendments to the VOC Solvents, LCP and Waste Incineration Directives. This Chapter applies to all industrial activities covered by the proposed Directive. Chapter II (Articles 11 to 30) deals with special provisions for activities listed in Annex I of the proposed Directive. That Annex is effectively an amended version of Annex I of the IPPC Directive. The various articles in this Chapter relate to obligations of the operator, applications for permit, BAT and BAT reference documents, permit conditions, emission limit values, monitoring requirements, general binding rules, site closure and remediation, inspections, compliance and reporting, access to information and public participation, access to justice as well as transboundary issues. Effectively, this Chapter recasts the IPPC Directive and amendments to that Directive and as such this Chapter only concerns IPPC activities as now listed in Annex I of the proposed Directive. Chapter III (Articles 31 to 37) deals with special provisions for combustion plants and primarily recasts the LCP Directive. The various articles in this Chapter relate to scope, aggregation rules, emission limit values, monitoring and compliance. Chapter IV (Articles 38 to 50) deals with special provisions for waste incineration and waste co-incineration plants and primarily recasts the Waste Incineration Directive. The various articles in this Chapter relate to scope, permit applications and conditions, control and monitoring of emissions, compliance, operating conditions, and delivery and reception of waste. Chapter V (Articles 51 to 60) deals with special provisions for installations and activities using organic solvents and primarily recasts the VOC Solvents Directive. The various articles in this Chapter relate to scope, definitions, control and monitoring of emissions, compliance and reporting, and access to information. Chapter VI (Articles 61 to 65) deals with special provisions for installations producing titanium dioxide and primarily recasts the three Titanium Dioxide Directives. The various articles in this Chapter relate to scope, and control and monitoring of emissions. Chapter VII (Articles 66 to 75) deals with committee, transitional and final provisions. The various articles in this Chapter relate to competent authority, reporting by Member States, penalties, transposition, repeal and entry into force of the proposed Directive. Annexes Annexes I to IV are a recasting of Annexes I to IV of the IPPC Directive. These Annexes concern categories of industrial activities referred to in Article 11 (Annex I), list of polluting substances (Annex II), criteria for determining BAT (Annex III), and public participation in decision-making (Annex IV). Annex V outlines the technical provisions relating to combustion plants and recasts Annexes I to VIII of the LCP Directive. Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 9 of 13 Annex VI outlines the technical provisions relating to waste incineration and coincineration plants and recasts Annexes I to VI of the Waste Incineration Directive. Annex VII (page 162) outlines the technical provisions relating to solvents installations and recasts Annexes I to III of the VOC Solvents Directive. Annex VIII outlines the technical provisions relating to installations producing titanium dioxide and recasts various annexes and articles of the three Titanium Dioxide Directives. Annex IX outlines the repealed Directives with their successive amendments and the time-limits for transposition of these Directives. Annex X of the proposed Directive provides a Correlation Table showing the relationship between the various articles and annexes in each of the seven existing Directives with the proposed Directive. Main Amendments to the Existing Legislation The proposed Directive, in revising and merging the seven existing Directives, contains a number of significant amendments to the existing legislation. Some of these amendments are outlined below. The background to these amendments, including the reasons for them and the options considered by the European Commission are explored in the Commission's Impact Assessment of the proposed Directive. This document is available on the Commission's website (http://ec.europa.eu/environment/ippc/proposal.htm). Operators and Permits The proposed Directive, in Article 4(2), provides that a permit may cover two or more installations or parts of installations operated by the same operator on the same site or on different sites. It defines operator in Article 3(10). In Article 5, it considers that two or more natural or legal persons may be the joint operator of an installation, or combustion plant, waste incineration plant, or waste co-incineration plant, or may be the operators of different parts of an installation or plant. An installation is defined in Article 3(3). BAT Articles 14 to 17 of the proposed Directive requires that BAT reference documents are the reference for setting permit conditions and that emission limit values do not exceed the emission levels associated with the best available techniques as described in those BAT reference documents. Competent authorities will be in a position to grant derogations to allow emission limit values to exceed the emission levels associated with the best available techniques as described in the BAT reference documents. However, such derogations will be required to be based on well defined criteria and should not exceed the emission limit values set out in Chapters III to VI of the Directive; and such derogations and their justification will be required to be made available to the public. Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 10 of 13 In addition, the proposed Directive, in Article 22, introduces a requirement for permit conditions to be reconsidered, and where necessary, updated after a new or updated BAT reference document is adopted in order to take account of developments in the best available techniques or other changes regarding the operation of an installation. Such a review and update to be undertaken within 4 years of publication of the BAT reference document. Compliance and Reporting Requirements The proposed Directive lays down more specific provisions to ensure an effective implementation and enforcement of this Directive and as such in Article 8 it introduces a requirement for operators to report regularly on compliance with permit conditions to the competent authority. Member States are also required to ensure that the operator and the competent authority take necessary measures in a case of non-compliance with this Directive. Member States are required in Article 67 to develop and regularly update national information systems to make available in an electronic format information relating to emissions, emission limit values and the application of best available techniques. It is envisaged that the reporting requirements of operators and Member States will tie in with the EPRTR reporting requirements and arrangements. Emission Limit Values - Combustion Plants In Article 33 and Annex V, the proposed Directive sets more stringent emission limit values, aligned with best available techniques, for certain categories of combustion plants and pollutants. Inspections In Article 25, the proposed Directive introduces a requirement for Member States to provide a system of environmental inspections and that all installations are covered by an inspection plan. Such a plan provides for routine and non-routine inspections, as defined in Articles 3(16) and 3(17) Incentives relating to environmentally-friendly technologies In Article 3(13), the proposed Directive defines and introduces the term, "emerging technique" as a novel technique that could provide a higher general level of protection of the environment or higher cost savings than existing best available techniques. In addition, the Directive, in Article 16 provides the competent authority with the option to grant temporary derogations from emission levels associated with the best available techniques as described in the BAT reference documents to enable an operator to test and use emerging techniques which might provide for higher level of environmental protection. Soil Monitoring and Remediation In Articles 15 and 17, the proposed Directive introduces a new requirement to monitor periodically the soil and groundwater on the site of the installations in order to ensure that appropriate information is available to protect these media from contamination by dangerous substances. In relation to site closure and remediation, the proposed Directive, in Article 23, requires that a baseline report, as defined in Article 3(15) is established by operators to provide quantified Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 11 of 13 information on the initial state of soil and groundwater contamination. Upon definitive cessation of activities, the operator is required to remediate the site and return it to that state. This Article also provides a linkage with the Environmental Liability Directive and the proposed Soil Protection Directive. Penalties In Article 70, the proposed Directive requires Member States to determine penalties applicable to breaches of the national provisions adopted pursuant to this Directive. Similar provisions were included in the VOC Solvents, Waste Incineration and the LCP Directives. IPPC Activities Annex I of the proposed Directive clarifies the scope of the IPPC activities to be covered under this Directive. In some cases, the Directive provides a rewording of some activities, incorporates new thresholds for other activities, and includes additional activities. Some of the significant amendments are as follows : - combustion plants between 20 and 50 MW are now included (category 1.1); - operation of non-ferrous metal foundries producing cast metal products of specified thresholds are now included (category 2.5(c)); - chemical industry now includes biological processing of substances (category 4); - production of chemicals for use as fuels or lubricants are now included (category 4.7); - waste management activities are specifically itemised and now include oil refining or other reuses of oil; incineration of non-hazardous waste with a capacity exceeding 3 tonnes per hour; disposal or recovery of non-hazardous waste with a capacity exceeding 50 tonnes per day involving biological treatment or physico-chemical treatment; the pretreatment of waste for co-incineration; treatment of slags and ashes; and the treatment of scrap metal (categories 5.1 to 5.4); - production of wood based panels (category 6.1(c)); - treatment and processing intended for the production of food products for humans or animals from a mix of animal and vegetable raw materials with capacity to produce 75 tonnes per day (excludes activities where the raw material is milk only) (category 6.4(b)(iii)); - intensive rearing of poultry or pigs with more than 40,000 places for broilers or 30,000 places for laying hens or 24,000 places for ducks or 11,500 places for turkeys (category 6.6); - preservation of wood and wood products (category 6.9); and - off-site treatment of waste water not covered by Directive 91/271/EEC and discharged by an installation covered by Chapter I (category 6.10). Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 12 of 13 Appendix 2 The following list is the full suite of legislation relevant to the transposition of the IPPC Directive (96/61/EC). Environmental Protection Agency Act 1992 (No. 7 of 1992) Protection of the Environment Act 2003 (No. 27 of 2003) Water Services Act 2007 (No. 30 of 2007) Waste Management Act 1996 (No. 10 of 1996) Environmental Protection Agency Act 1992 (Commencement) Order 1993 (S. I. No. 235 of 1993) Environmental Protection Agency Act 1992 (Commencement) Order 1994 (S. I. No. 82 of 1994 Environmental Protection Agency Act 1992 (Commencement) (No. 2) Order 1994 (S. I. No. 178 of 1994) Environmental Protection Agency Act 1992 (Commencement) Order 1995 (S. I. No. 57 of 1995) Environmental Protection Agency Act 1992 (Commencement) (No. 2) Order 1995 (S. I. No. 337 of 1995) Environmental Protection Agency Act 1992 (Commencement) Order 1996 (S. I. No. 13 of 1996) Environmental Protection Agency Act 1992 (Commencement) (No. 2) Order 1996 (S. I. No. 77 of 1996) Protection of the Environment Act 2003 (Commencement) Order 2004 (S. I. No. 393 of 2004) Protection of the Environment Act 2003 (Commencement) (No. 3) Order 2003 (S. I. No. 498 of 2003) Protection of the Environment Act 2003 (Commencement) (No. 2) Order 2003 (S. I. No. 413 of 2003) Protection of the Environment Act 2003 (Commencement) Order 2003 (S. I. No. 393 of 2003) Waste Management Act 1996 (Commencement) Order 1996 (S. I. No. 192 of 1996) Environmental Protection Agency (Licensing) Regulations 1994 (S.I. No. 85 of 1994) Environmental Protection Agency (Licensing) (Amendment) Regulations 1995 (S.I. No. 59 of 1995) Environmental Protection Agency (Licensing) (Amendment) (No. 2) Regulations 1995 (S.I. No. 76 of 1995) Environmental Protection Agency (Licensing) (Amendment) Regulations 1996 (S.I. No. 79 of 1996) Environmental Protection Agency (Licensing) (Amendment) (No. 2) Regulations 1996 (S.I. No. 240 of 1996) Environmental Protection Agency (Licensing) (Amendment) Regulations 2004 (S.I. No. 394 of 2004) Waste Management (Licensing) Regulations 1997 (S.I. No. 133 of 1997) Waste Management (Licensing) (Amendment) Regulations 1998 (S.I. No. 162 of 1998) Waste Management (Licensing) Regulations 2000 (S.I. No. 185 of 2000) Waste Management (Licensing) (Amendment) Regulations 2001 (S.I. No. 397 of 2001) Waste Management (Licensing) (Amendment) Regulations 2002 (S.I. No. 336 of 2002) European Communities (Amendment of Waste Management (Licensing) Regulations, 2000) Regulations 2002 (S.I. No. 337 of 2002) Waste Management (Licensing) Regulations 2004 (S.I. No. 395 of 2004) Water Services Act 2007 (Commencement) Order 2007 (S.I. No. 846 of 2007) European Communities (Greenhouse Gas Emissions Trading) (Amendment) Regulations 2005 (S.I. No. 706 of 2005) European Communities (Greenhouse Gas Emissions Trading) Regulations 2004 (S.I. No. 437 of 2004) European Communities (European Pollutant Release and Transfer Register) Regulations 2007 (S.I. No. 123 of 2007) Water Services Act 2007 (Commencement) Order 2007 (S.I. No. 846 of 2007) Screening RIA - Proposed Directive on Industrial Emissions (version 1) page 13 of 13