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Ares(2019)3068613
Ares(2018)5657844 - 08/05/2019
06/11/2018

SERVICE REQUEST – ANNEX "Specific Terms of Reference"

Review of E-PRTR implementation and related guidance

1. GENERAL INFORMATION

The E-PRTR Regulation1 establishes an integrated pollutant release and transfer register at
Community level and thus implements the UNECE Kiev Protocol2.
In doing so, the E-PRTR helps improve public access to environmental information on
pollutant releases and transfers from some 33,000 of Europe's largest industrial facilities. By
establishing a coherent and integrated database with clear data on the annual mass emissions
(and transfers) of pollutants, the E-PRTR enables the public to become more closely involved
in environmental decision-making.
Consistent implementation of the E-RTR Regulation (by facility operators and by Member
States) is supported by, inter alia, a European Commission Guidance document3.
The Regulation and the Guidance both date from 2006 and reflect the technical and scientific
understanding at that time. Neither the Regulation nor the Guidance have been amended since
first publication.
In order to improve E-PRTR implementation, the European Commission considers that there
is benefit in assessing certain technical components of the E-PRTR Regulation and its
associated Guidance, and, where necessary, adapting these to technical progress.
Such technical adaptation is also relevant to supporting the E-PRTR's coherence with wider
policy development under the directive on industrial emissions (IED)4 e.g. E-PRTR data
helps identify key environmental issues for BREF reviews. These actions require sufficiently
robust and representative information.
Related to this, the Commission's first report on IED implementation5 concludes that there is
benefit in a fuller evaluation of the IED starting in 2019, namely:
'In addition to continuing with the activities described in this report, the Commission
considers it appropriate to reflect how the work on IED implementation should evolve
in the longer term and at what point it would be appropriate to take stock of
achievements and to consider the scope for improvement. By 2020, the Commission
will have received further reports from Member States and most BAT conclusions will
have been adopted. Furthermore, most of the LCP transitional arrangements will be

1
Regulation (EC) No 166/2006 of the European Parliament and of the Council of 18 January 2006 concerning
the establishment of a European Pollutant Release and Transfer Register and amending Council Directives
91/689/EEC and 96/61/EC
2
http://www.unece.org/env/pp/prtr.html
3
http://ec.europa.eu/environment/industry/stationary/eper/implementation.htm
4
https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1526545288714&uri=CELEX:32010L0075
5
Report to the Council and Parliament on implementation of Directive 2010/75/EU and final reports on its
predecessor legislation (COM(2017) 727 final)

1
close to their final deadlines. This would appear an appropriate time to consider the
launch of a full evaluation of the IED.'

2. INFORMATION ON THE E-PRTR REGULATION - ANNEXES I and II

The scope of the E-PRTR Regulation is defined in its Article 5 and through references to:

 Annex I – which describes the activities covered; and


 Annex II – which defines the pollutants to be reported and the thresholds which need
to be exceeded.

Operators report annual releases to their Member State competent authority when an activity
is above the Annex I threshold and that activity emits pollutants above the Annex II
thresholds.

2.1 Activities (Annex I)


Article 15(3) of the IPPC directive (96/61/EC) stated that:

An inventory of the principal emissions and sources responsible shall be published every
three years by the Commission on the basis of the data supplied by the Member States. The
Commission shall establish the format and particulars needed for the transmission of
information in accordance with the procedure laid down in Article 19.

This led to the creation of the EPER6 (European Pollutant Emission Register), which was the
first EU-wide inventory of emissions arising from IPPC activities. In 2006, the EPER
evolved into the E-PRTR in order to deliver the Kiev Protocol requirements.

The activities covered by the EPER were originally an exact mirror of the IPPC directive.
Annex A3 of the EPER even included a correlation to IPPC activities.

Whilst there continues to be a broad overlap between the activities covered by the regulatory
regime and its supporting inventory, divergence has occurred at two main junctures:

 In 2006, with the creation of the E-PRTR in order to deliver Annex 1 of the Kiev
PRTR Protocol. This extended the scope of the inventory to cover activities such as
urban wastewater treatment plants, aquaculture and mining/quarrying.
 In 2010, when the IED introduced additional activities for regulatory control e.g.
waste recovery, carbon capture and storage.

Whilst continuing to deliver Kiev Protocol requirements, it is to be expected that any future
revision of the E-PRTR's Annex I would give consideration to including the newly

6
https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1526546695397&uri=CELEX:32000D0479

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introduced IED activities so that the two instruments once again become more closely
aligned.

However, it is possible that there are industrial sources of Annex II pollutants that are not
captured by the current list of activities in the E-PRTR. It is therefore pertinent to assess
whether other activities should be added to Annex I in order to get a better picture of
industrial releases and transfers. This consideration relates to both the existing list of Annex
II pollutants, plus any additional coverage that might flow from the assessment of Annex II –
see below.

In considering possible new and additional (agro-)industrial sources of Annex II pollutants, it


is important to consider the Commission’s 2014 study titled ‘Contribution of industry to
pollutant emissions to air and water’7.

2.2 List of pollutants (Annex II)


The E-PRTR list of pollutants largely reflects the pollutant lists in Annex III of the IPPC, and
Annex II of the IED, directives. It also reflects the 2006 scientific understanding of the main
environmental issues associated with Annex I activities.

Whilst the overwhelming majority of these pollutants continue to be of interest, there are new
pollutants and environmental issues that have risen in prominence in the intervening years. In
view of this, it is opportune to assess the Annex II list of pollutants arising from E-PRTR
activities to identify any that should be removed (in the unlikely event that they are no longer
of environmental significance); amended; or supplemented.

2.3 Pollutant thresholds (Annex II)


The Kiev PRTR Protocol (and the EPER before that) established a scope based on a list of
substances and media-specific thresholds. These thresholds were established by signatories to
the Protocol, on a technical basis, in the years immediately preceding adoption of the
Protocol. The E-PRTR Regulation includes substances and thresholds almost identical to
Annex 1 of the Kiev Protocol.

The emphasis of the Protocol is on the amount of pollutants. The Protocol aims to balance the
reporting burden against the relevance of the information provided. Instead of covering a
broad number of pollutants, the Protocol concentrates on releases of a limited number of
specific pollutants (and pollutant categories) in order to present an overall picture of
industrial emissions.

As such, the pollutant thresholds were originally set to capture the majority of releases and
transfers stemming from human activities. During Protocol negotiations, Parties attempted to
establish a numerical definition of this “majority” of releases and transfer. However, this was
not possible due to the uncertainties and information gaps that were present at the time, as
well as the very different situations across the Parties to the Protocol.

7
https://circabc.europa.eu/w/browse/b0435e80-9ef3-4275-8a00-c06a3bafd5a9

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Later on, scientific studies and policy assessments on PRTRs often used a benchmark of 90%
of total releases / transfers for each pollutant. While some assessments claim that the E-PRTR
effectively captures releases and transfers in accordance with this benchmark, uncertainties
still remain high. It is therefore questionable whether the E-PRTR ever captured such a large
majority of releases.

In addition, environmental improvements by industry in the intervening years mean that there
are now generally lower releases. An increasing number of facilities therefore fall below the
Annex II thresholds and do not report to the E-PRTR. This further indicates that the E-PRTR
probably no longer captures the “majority” of total industrial releases. For example, a recent
Commission report8 on mercury emissions flagged that most installations are below the 10
kg/year threshold and do not report under E-PRTR.

The use of thresholds for E-PRTR reporting has also impaired the use and interpretation of
data. For air emissions it is, to some extent, possible to provide the global context of
emissions for a number of pollutants because they are also reported to emission inventories
under international law (e.g. the Long Range Transboundary Air Pollution Convention or the
Greenhous Gas Reporting Mechanisms under the Climate Change Convention). However,
this possibility is limited because the E-PRTR covers many more substances than these
international agreements.

Furthermore, there is no similar approach for releases to water and land. Any potential
comparison relies on voluntary datasets or a possible correlation between state of the
environment data and the releases reported in a given area. This type of approach has
however proved to be very difficult and requires a number of assumptions that introduce high
levels of uncertainty.

Experience gained over recent years, prompts consideration of whether reporting thresholds
are now too high and whether they continue to be a suitable mechanism for some, or all,
substances within the scope of the Regulation.

Whilst this issue was flagged in the E-PRTR evaluation, it was not proposed for immediate
action. However, since the scientific basis for thresholds is now old this could compromise
the representativeness of E-PRTR data by distorting the understanding of the dataset. It is
therefore opportune to assess how effective the thresholds are in continuing to provide useful
data on the mass releases of pollutants from E-PRTR activities and how well the E-PRTR
continues to support the IED as an emission reporting instrument.

8
Support to assessing the impacts of certain amendments to the Proposal of the Commission for a Regulation
on Mercury. July 2017. See section 8.3.3: https://publications.europa.eu/en/publication-detail/-
/publication/087ac555-aefa-11e7-837e-01aa75ed71a1/language-en/format-PDF/source-71516962

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3. INFORMATION ON THE E-PRTR GUIDANCE – APPENDICES 3, 4 & 5

Article 14(1) of the E-PRTR Regulation required the Commission to draw up a guidance
document (Guidance) to support E-PRTR implementation. The Guidance was expected to
address, in particular, the topics outlined in Article 14(2) of the E-PRTR Regulation i.e.:
(a) reporting procedures;
(b) the data to be reported;
(c) quality assurance and assessment;
(d) indication of type of withheld data and reasons why they were withheld in the case of
confidential data;
(e) reference to internationally approved release determination and analytical methods,
sampling methodologies;
(f) indication of parent companies;
(g) coding of activities according to Annex I to this Regulation and to Directive
96/61/EC.
The Commission duly published the Guidance in May 2006. It is available, in 22 EU
languages, on the websites of the European Commission9 and the European Environment
Agency (EEA)10. The guidance covers practical matters such as who should report, what
information is required and how data should be submitted.

Whilst the Guidance has provided useful implementation advice to Member States and
operators, a recent Staff Working Document11 from the Commission's REFIT evaluation of
the E-PRTR Regulation made the following observations:

 All the consulted stakeholders considered the Guidance extremely useful in the
reporting process, although the 2013 E-PRTR implementation review12 had identified
a number of minor areas where it could be improved.
 Having EU-wide Guidance ‘adds value’ as it provides rules and advice on such issues
as data collection, quality checking and presentation. The Guidance improves data
consistency, and hence comparability, between Member States. Due to occasional, but
significant, differences between the data reported (e.g. carbon dioxide emissions from
biomass combustion) some stakeholders called for improvements to the Guidance.
 Whilst Member States appear to be converging on good practices under the E-PRTR,
further gains in consistent interpretation could be delivered by updating the guidance.

9
http://ec.europa.eu/environment/industry/stationary/eper/implementation.htm
10
http://prtr.ec.europa.eu/#/downloadguidance
11
http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1513176768325&uri=SWD:2017:710:FIN
12
COM(2013) 111: Final Report from the Commission to the European Parliament and the Council on progress
in implementing Regulation (EC) 166/2006 concerning the establishment of a European Pollutant Release and
Transfer Register http://eur-lex.europa.eu/procedure/EN/202443

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In conjunction with the Staff Working Document, the Commission reported13 to the
Parliament and Council under Article 17 of the E-PRTR Regulation. This report makes the
following observations on the Guidance:

 ‘While extremely useful in the reporting process, the guidance is now 11 years old
and the time has come to update it. This would involve both refining the existing
issues covered by the guidance and addressing implementation questions and
experiences that have arisen since it was first published’.
 ‘Member States are coming together around good practices. However, further gains
in consistent implementation will come from updating the existing EU level guidance,
which dates back to 2006, since when many implementation issues have arisen.
Revising the E-PRTR guidance document has therefore been launched as part of the
Commission’s work programme for 201714. It will clarify such issues as the scope of
the Regulation, activity definitions, emission factors and the reporting elements that
can be considered confidential.’
 ‘There inevitably remains scope for further improvement of the E-PRTR and this
report identifies a number of lines that the Commission will pursue, notably: ….
revising the existing guidance document to help Member States with consistent
implementation;’

In parallel, the Fitness check evaluation on Member State environmental reporting and
monitoring15 concluded that there was scope for simplifying E-PRTR reporting obligations.
As a result, there are COM proposals to amend, through an Omnibus round, certain
provisions of the E-PRTR Regulation. The most notable proposal is to better streamline
Member State E-PRTR and IED reporting by annulling Annex III of the E-PRTR Regulation
and using the Article 19 Comitology procedure to define the type, format and frequency of
MS reporting.

Since this proposal will be subject to the co-decision process, there will be some legislative
uncertainty on the E-PRTR for several years. Whilst this precludes a full revision of the
Guidance, E-PRTR implementation would benefit from updates to several components of the
Guidance to support implementation through adaptation to technical progress. These are:

a) The methods used by operators to quantify the emissions and transfers from industrial
facilities i.e. as described in section 1.1.1 and Appendix 3 of the Guidance. This needs
updating to, inter alia, reflect developments in measurement methods and to provide
better advice on release estimation/calculation methods.
b) The indicative lists of air and water pollutants that can be expected to arise from E-
PRTR facilities. There are known to be errors in the Appendix 4 and 5 lists and they
should be updated to better reflect observed and expected releases / transfers.

13
COM/2017/810 http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52017DC0810&from=EN
14
This contract
15
http://ec.europa.eu/environment/legal/reporting/fc_overview_en.htm

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3.1 Release quantification methods - Appendix 3
The chosen method for quantifying releases / transfers can have a large bearing on the values
reported to the E-PRTR. This affects the absolute value reported by operators and whether
the Annex II thresholds are exceeded. In turn, this can compromise the comparability of data
– both temporally (i.e. year on year) and spatially (i.e. between facilities).

According to Article 5(1) of the E-PRTR Regulation:

'The operator of each facility that undertakes one or more of the activities specified in
Annex I above the applicable capacity thresholds specified therein shall report the
amounts annually to its competent authority, along with an indication of whether the
information is based on measurement, calculation or estimation, of the following:….'

'In the case of data indicated as being based on measurement or calculation the
analytical method and/or the method of calculation shall be reported.'

In Annex III of the E-PRTR Regulation, these three options appear as M (measured;
Analytical Method used), C (calculated; Calculation Method used) and E (estimated).

Article 5(4) goes on to elaborate that:

'When preparing the report, the operator concerned shall use the best available
information, which may include monitoring data, emission factors, mass balance
equations, indirect monitoring or other calculations, engineering judgements and
other methods in line with Article 9(1) and in accordance with internationally
approved methodologies, where these are available.'

The reference to Article 9(1) concerns 'Quality assurance and assessment' and states that; 'The
operator of each facility subject to the reporting requirements set out in Article 5 shall assure
the quality of the information that they report.'

In accordance with Article 14 of the E-PRTR Regulation, the existing Guidance provides
further information, in particular: 'Measurement / calculation / estimation of releases and off-
site transfers' (Chapter 1.1.11) and 'Quality assurance' (Chapter 1.12).

However, this information is quite limited (especially for calculation and estimation methods)
and outdated (in the case of measurement techniques).

3.2 Indicative air and water pollutants – Appendices 4 & 5


Article 5(1) places an obligation on operators to report annually to their competent authority
those ‘releases to air, water and land of any pollutant specified in Annex II for which the
applicable threshold value specified in Annex II is exceeded’.

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Whilst the onus is on the operator to identify which pollutants are to be reported, Appendices
4 and 5 of the Guidance provide indicative lists of which air and water pollutants might
reasonably be expected to be released from different activities. However, such is the diversity
of industrial activities, the named pollutants will not always be released and, by contrast,
unlisted pollutants may in fact be present.

In practice, each facility will decide on a case-by-case basis which Annex II pollutants are
relevant for reporting purposes. Nonetheless, Appendices 4 and 5 give operators and Member
States competent authorities a useful, if crude, first plausibility check of data returns.

Some spot-checks against reported E-PRTR data indicates that are anomalous entries16 in
Appendices 4 and 5 which should be corrected.

4. SUBJECT OF THE SERVICE REQUEST

The objective of this Service Request is to support implementation of the E-ERTR


Regulation by assessing and, where necessary, suggesting updates to certain components of
the E-PRTR Regulation and the E-PRTR Guidance to reflect advances in technical progress
since 2006.

The primary outputs should be:

1. In the case of the Regulation; information on industrial activities and pollutants that
supports the planned future review of the IED;
2. In the case of the Guidance; updated versions of Appendices 3, 4 and 5 in formats
conducive to ready incorporation into a revised Guidance document and/or other
methods of dissemination to the E-PRTR community.

For the purposes of this contract, the winning tenderer would be able to use certain
information already held by the European Commission and the EEA. This includes the
reports mentioned in this Service Request (together with their supporting documentation) and
E-PRTR datasets. Other information will need to be gathered by the contractor.

5. TASKS

5.1 General task information


Each tenderer is invited to set out, in its offer, the specific methodology that is proposed to
deliver the work necessary to complete this Service Request. In general terms, the
Commission anticipates that the work will entail at least the elements listed in these terms of
reference, however the tenderer is expected to elaborate or expand on the activities proposed
where necessary. The tenderer is expected to describe how the tasks will fit together both in
terms of timing and substance. This should be based on robust knowledge (literature research,

16
For example, trichloroethylene to air from thermal power stations (1.c activity).

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comparison of national practices and guidance in this field) and practical examples or
demonstrations.

Throughout the contract the contractor should regularly inform the Commission of the
progress of the work and any important issues that may arise.

All tasks described in these specifications are the responsibility of the contractor but must be
carried out in close co-operation with the Directorate General Environment of the European
Commission, in particular with Unit C.4 'Industrial Emissions and Safety'. Furthermore, it
may involve contacting relevant stakeholders. DG ENV will associate the European
Environment Agency to this work.

An overview of the expected deliverables and deadlines is detailed below.

The effort required for each task should be identified. An anticipated, indicative effort is
shown below for each task.

5.2 Tasks to be performed


The contractor should perform the following four tasks; each of which concerns adaptation to
technical progress on the following subject areas:

Task 1: E-PRTR Regulation - Annex I activities (10%)

Task 2: E-PRTR Regulation – Annex II substances and thresholds (40%)

Task 3: Guidance - release quantification methods (40%)

Task 4: Guidance - indicative air and water pollutants (10%)

Task 1: E-PRTR Regulation - Annex I activities


Assess, and where necessary suggest updates to, the list of E-PRTR Annex I activities to
ensure that E-PRTR continues to provide an accurate and comprehensive inventory of
releases and transfers from Europe’s most environmentally important (agro-)industrial
activities.

In assessing the existing lists of activities, the contractor should, as a minimum, explore:

a) How well the E-PRTR activities list supports the needs of the IED regulatory
instrument;
b) How well the E-PRTR activities list supports medium-specific EU legislation on air,
water and waste. Whilst there are already close links with facilities covered by the
UWWTD17 and the NECD18, explore whether these should be further enhanced. For
example, E-PRR activity 5(f) covers ‘Urban waste-water treatment plants’ with a

17
https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1526551954207&uri=CELEX:31991L0271
18
https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1526552029351&uri=CELEX:32016L2284

9
capacity threshold of 100,000 population equivalents (p.e.), whilst the UWWTD
covers plants as small as 2,000 p.e.
c) Whether any Member States already supplement the E-PRTR list of activities with
additional activities that are of specific national interest;
d) The activity lists generated by existing international obligations (Kiev Protocol) and
recommendations (OECD19), with regards to a more harmonised global list;
e) Future-proofing the list of activities by considering those (agro)-industrial activities
that are likely to have increasing environmental interest i.e. horizon scanning;
f) Where any additional activities are proposed, to also propose appropriate 'capacity
thresholds';
g) How well the Annex I 'capacity thresholds', for existing activities, align with other EU
regulatory requirements (IED, UWWTD etc.) and the reality of EU industrial
operations. In view of there being no equivalent IED threshold under activity
description 6.11, particular attention should be given to the 10,000 m3/day threshold
for E-PRTR activity 5(g) i.e. 'independently operated industrial waste-water
treatment plants which serve one or more activities of this annex'20.

Task 2: E-PRTR Regulation - Annex II substances and thresholds


Assess, and where necessary suggest updates to, the list of E-PRTR Annex II substances and
their thresholds to ensure that the E-PRTR continues to provide an accurate and
comprehensive inventory of releases and transfers from Europe’s most environmentally
important (agro-)industrial activities.

In assessing the existing lists of pollutants, the contractor should, as a minimum, explore:

a) How well the E-PRTR reflects substances that are relevant to IED activities;
b) How well the E-PRTR reflects substances that are relevant to medium-specific EU
legislation on air, water and waste;
c) Whether any Member States already supplement the E-PRTR list of pollutants with
additional pollutants that are of specific national interest;
d) The pollutants lists generated by existing international obligations (Kiev Protocol) and
recommendations (e.g. OECD21), with regards to a more harmonised global approach;
e) Future-proofing the list of substances by considering those pollutants that are likely to
have increasing environmental interest i.e. horizon scanning.

In assessing the existing release thresholds, the contractor should, as a minimum, explore:

f) How well the E-PRTR thresholds continue to be relevant to IED activities;

19
http://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=env/jm/mono(2013)5&doclanguage=en
20
NB Footnote 4 of Annex I to the E-PRTR Regulation says: 'The capacity threshold shall be reviewed by 2010
at the latest in the light of the results of the first reporting cycle'. There is some consideration of this issue in
the 2012 Commission report ‘Three years of implementation of the E-PRTR’
http://ec.europa.eu/environment/industry/stationary/eper/pdf/Final%20report_20120605.pdf
21
http://www.oecd.org/officialdocuments/publicdisplaydocumentpdf/?cote=env/jm/mono(2014)32&doclanguage=en

10
g) Analyse data returns since 2006 to identify the numbers and percentages of facilities
that fall above and below the Annex II thresholds;
h) For each pollutant, establish what thresholds would now capture 90% of total
emissions from E-PRTR facilities. This should be analysed for air, water and land
releases, since the threshold may differ for each medium;
i) The additional benefit, and administrative burden, that would arise from removing E-
PRTR release thresholds – either on a wholescale basis or for specific pollutants;
noting that some Member States, e.g. Spain, already require reporting without the
trigger of a threshold;
j) Where release thresholds are no longer considered useful, indicate whether de minimis
values should be introduced in order to reflect the detection limits of measurement
techniques and to avoid disproportionate reporting obligations on operators.

Task 3: Guidance - release quantification methods


With a view to improving the overall quality and compatibility of inventory data assess, and
where necessary suggest updates to, the current guidance on methods for the measurement,
calculation and estimation of releases / transfers.

In assessing the existing release quantification methods, the contractor should, as a minimum,
explore:

a) Quantify to what extent current E-PRTR returns rely on measurement, calculation or


estimation methods. This should include a breakdown by sector, Member State,
pollutant and medium (air/water/soil), as well as an indication of whether these
profiles have changed since 2006.
b) From the above analysis, identify the main areas where data quality is compromised
by the use of calculation and estimation methods.
c) Assess existing, relevant guidance and reference material:
o Under the IED e.g. the JRC Reference Report on ‘Monitoring of Emissions to
Air and Water from IED installations’ (ROM)22
o To support other EU legislation on air, water and waste emissions;
o Issued or widely used by industry / trade associations;
o Issued or widely used by Member State national administrations / competent
authorities;
o From international sources e.g. OECD ‘Release Estimation Techniques’23,
EMEP guide under CLRTAP.
d) Separately for the categories of measurement, calculation and estimation, prepare new
recommendations on the methods that can be used by operators and Member States.
These recommendations should be:
o Concise and practical;

22
http://eippcb.jrc.ec.europa.eu/reference/BREF/ROM/ROM_RFD_2017-06-05.pdf
23
http://www.oecd.org/env/ehs/pollutant-release-transfer-
register/publicationsintheseriesonpollutantreleaseandtransferregisters.htm

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o Recognise the accuracy and precision of different methods;
o Cognisant of the cost to industry by indicating generic cost bandings (low,
medium and high) so that industry can identify cost-effective options;
o Address known problematic issues, sectors or pollutants (e.g. ammonia from
intensive livestock production);
o In a format that can be readily adapted by the Commission for inclusion in any
future revision of the Guidance document.

Task 4: Guidance - indicative air and water pollutants


Assess, and where necessary suggest updates to, Appendices 4 and 5 of the Guidance to
ensure that the lists provide a more accurate checklist of the expected pollutant releases from
each E-PRTR activity.

In assessing the indicative lists of pollutants, the contractor should, as a minimum, explore:

a) Lists that better reflect releases that are actually reported to the E-PRTR;
b) A more nuanced system than the current binary indication of presence or absence.

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