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PUBLIC DIALOGUE IN THE FIELD OF BEST AVAILABLE TECHNIQUES AND INTEGRATED PERMITS: LESSONS FROM RUSSIAN CONSTRUCTION MATERIALS INDUSTRY
Abstract
Since 2014 Russia has been developing and implementing a new environmental policy based on the concept Integrated Pollution Prevention and Control and Best Available Techniques. Transition to Integrated Environmental Permits is gradual: first 300 industries characterized as пїЅkey pollutersпїЅ have to obtain permits in the period of 2019-2022. They will be followed by at least 5-6 thousand industries of nearly 30 economic sectors. Within the construction materials industry sector, several older cement plants are listed among пїЅkey pollutersпїЅ while glass and ceramic industries are not. Russian Information and Technical Reference Books (ITRBs) were issued for construction materials industries (production of cement, ceramics and glass) in 2015. Particular BAT Associated Emission Limits must be calculated for each installation based on sector BAT technological parameters (mostly specific emissions) set by sector ITPB. Key differences between current environmental permitting system and Integrated Environmental Permitting are the comprehensive character of new permitting and its transparency. Conditions of Integrated Environmental Permits should be logical, realistic, and enforceable. To form the necessary regulatory basis for the Integrated Environmental Permitting, Russian Government decided to encourage interested parties to participate in the development of draft documents and discuss them during business role-playing games. Experts of Russian BAT Bureau, industry specialists and local stakeholders played roles of representatives of permitting authorities, and other relevant federal and regional authorities. Business games allowed simulating permitting procedures for cement and glass industries. Each game provided for several recommendations of both general and sector specific nature. General comments helped improving the overall logic of the proposed permitting procedure. Sector specific recommendations addressed problems of continuous self-monitoring, shortcomings of Russian Information and Technical Reference Books and opportunities for preparing national sector oriented BAT standards.
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