Linking the Water Framework Directive and the IPPC Directive
The IPPC Directive 2008/1/EC and Water Framework Directive 2000/60/EC are two of the most wide-reaching items of EU environmental law. Installations regulated under IPPC may impact on the water environment, such as through direct or indirect discharges of pollutants, water abstraction, etc. IPPC requires installations to operate to conditions in permits compliant with Best Available Techniques (BAT). They are also required to respect environmental quality standards established in EU law, including those derived under EU water law. However, the relationship between the two sets of obligations is often far from simple, such as different tests of disproportionate costs in the Directives, the presence of multiple pressures on water bodies affecting standards, different implementation timetables, etc. Therefore, ensuring integration of the implementation of the Directives is a challenge and this report seeks to analyse the different elements underlying this challenge.
This report examines some general issues concerning the interaction between the Directives. It considers the interactions from the perspective of the IPPC regulatory cycle and from the perspective of the WFD river basin planning cycle. It provides separate analyses of interactions with the EQS Directive, Groundwater Directive, Urban Waste Water Treatment Directive, E-PRTR Regulation and REACH Regulation. The report examines issues of interaction between the Directives set out in the WFD CIS Guidance Documents and in the IPPC BREF Notes. The report concludes with an examination of the challenges that the interactions pose to the competent authorities of the Member States and how these might be addressed.