At UPM, we believe that we can significantly promote sustainable development through our own actions. We want to create a profitable business that is sustainable both socially and ecologically. As part of this approach, our experts participate in various projects that promote sustainable development in the industry as a whole. A fine example of this is our substantial investment in the update of the EU BAT reference document.
The update of the BAT reference document (BAT = Best Available Techniques) was completed in May, after eight years of work. The document has over 800 pages and contains industry emission requirements as defined by the EU and the alternative methods of complying with the requirements. The emission levels defined are not merely provided for reference, as production plants are in fact required to comply with the new requirements. Therefore, it was only natural for UPM’s experts to be actively involved in preparing the document together with the Finnish Forest Industries Federation and CEPI.
A huge effort but worth it
The preparatory work required significant effort from UPM’s experts. They needed to participate in numerous meetings, read hundreds of pages of documentation and comment on them over and over again, collect information from UPM mills from all EU countries, and co-operate extensively with other experts, all within a tight schedule. Persistence and determination to promote individual perspectives and goals were also in frequent demand.
The information collected from mills during the preparation was very helpful during negotiations and in formulating the requirements that are essential from an industry perspective. The idea was based on the premise that it should be possible to direct any investment in the most environmentally reasonable way. In particular, a lot of effort was put on making equitable the nitrogen oxide emissions requirements of chemical pulp mills and the COD load requirements of paper mills. This goal was achieved. The negotiators also managed to remove the requirement of an additional third phase in the waste water treatment process, as the environmental benefits were proven to be insignificant.
One of the key factors from an industry perspective was the idea that in the document the specific amount of emissions (kilograms per one tonne of paper/pulp) should be chosen as the comparable indicator of environmental performance on a Europe-wide level. This factor was taken into account and the idea was implemented. However, the new BAT document has to be used in a flexible manner so that emissions can be reduced in a cost-effective way while still achieving environmental benefits. Therefore, it is highly desirable for permit decisions to continue to be based on the best practices of individual countries. In Finland, for example, this would mean that permit decisions were made on a monthly basis with effluent values given as daily load (t/d).
Reasonable solutions creating savings
From the perspective of the Finnish forest industry, we can be very satisfied with the result of the BAT reference document update. In the initial stages of the update, it seemed that tightening the emission limits would mean that a EUR 300 million investment would be required from the Finnish forest industry. The investment required for the implementation of the approved reference document has now dropped to approximately EUR 40 million. UPM will likely not face any additional expenses. The final cost effects depend on the emission limits in the environmental permits that are assigned to the mills.
The conclusions (50 pages) of the document were published in all EU languages in the Official Journal of the European Union on the last day of September. However, the work is not yet finished. The industry will now co-operate with authorities on a national level, and companies are investigating whether the possible changes required by the BAT reference document affect the environmental permits of individual mills. The production plants have four years to ensure compliance with the document.
At UPM, we will next start the preparation of mill-specific summaries to show that the operations, equipment and emission levels of our production plants comply with the BAT document. We want to ensure that our operations continue to be globally sustainable.
Link to BAT conclusions: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:JOL_2014_284_R_0017
Blog authors: Seija Vatka, Manager, Water, UPM Environment and Responsibility / Jarkko Hukkanen Manager, Ecolabels and reporting, UPM Environment and Responsibility / Harri Jussila Manager, Waste and chemicals, UPM Environment and Responsibility