News » CCB's comments on the Final Draft of the IRPP BREF

05.10.2015

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Proposal for some rewording in the BAT conclusions 30 to 34 of the Final draft of the BAT reference document for the Intensive Rearing of Poultry or Pigs (IRPP BREF) has been issued by the CCB.

With the understanding that the BREF sets number of new BAT provisions i.a. addressing wise nutrient management, pollution prevention, as well as resource-efficiency for water and energy use, we would like to point to several major concerns, especially with regards to the Baltic Sea Area:

  1. In general, the proposed BAT for manure management does not necessarily/clearly encourage nutrient recycling path and hence does not follow the circular economy thinking and waste management hierarchy, that should primarily address recycling and recovery of manure?s nutrient and/or energy value.
  2. It would be advisable to set up clear minimum storage capacity (in months of storage) for boreal area, as currently, despite stricter requirements set for some Baltic Sea Member States, few other states are referring to the Nitrates Directive that set stricter manure storage provisions only for Nitrate Vulnerable Zones, while NVZs are not always designated effectively.
  3. Cattle manure, as well as animal waste produced by other animal husbandry (horse, goat, sheep and even fur farms) need to be addressed by IED requirements as it represents equally big share of pollution, as well as equally important source of nutrients/energy that could be diverted from waste streams into a resource.

Most of the above is to a certain extent addressed by the Convention on the Protection of the Marine Environment of the Baltic Sea Area (Helsinki Convention 1992) and its Annex III, part II ?Prevention of Pollution from Agriculture?, which the European Union is a Contracting Party to. However, to most the EU Member States, being also HELCOM Contracting Parties, the EU acquis remains prevailing.

 For more information visit www.ccb.se.

 

Federacja Zielonych GAJA
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Coalition Clean Baltic
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SHORT ABOUT THE PROJECT

Project Industrial animal farms in the Baltic Sea Region - sustainable practices to reduce nutrient loads is a part of a long-term campaign of the Coalition Clean Baltic and Green Federation "GAJA", aiming to reduce the negative impact of large-scale animal production on the environment and local communities in the Baltic Sea Region, particularly by reducing nutrient run-off into the sea. The project is part-financed by the European Union. This website reflects only the view of the Coalition Clean Baltic. The Executive Agency for Small and Medium-sized Enterprises (EASME) is not responsible for any use that may be made of the information it contains.

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