Experience of Estonia

1. Transitioning to a BAT approach
Experience of Estonia
16.11.2020, Regional meeting with Eastern Partnership countries on implementing BAT
Senior Officer / Ministry of the Environment of Estonia
Kristel Lopsik

2. Background
IPPC regulation was in place from 2001 which was followed by the
implementation of Industrial Emissions Directive in 2013.
Today there are 242 installations with integrated permits
Main activities include: intense farming, combustion of fuels, pyrolysis of fuels,
chemical industry, metal industry, mineral industry, wood and pulp industry, waste
management.
Estonia joined EU in 2004
Transitioning to BAT approach started in 1998 BAT-based
permitting system.

3. EestiVabariik
Methods to support transition to a BAT approach
• In general BAT is based on BREF-s and BAT Conclusions which have been
developed in the EU.
• Estonia has not developed a separate legal procedure (incl. General binding
rules) to translate or to implement BREF/BAT documents EC
implementing decisions and BREFs are directly applicable by environmental
authority according to law Guidance and seminars have been carried out
to support implementation.
• Close cooperation between authorities and installations/industrial
association is necessary, but also international cooperation.
• Some problems have remained: BREFs are in English (more difficult to
understand), BAT Conclusions have official translations. Implementation
requires guidance and guidelines.

4. EestiVabariik
• Estonia had support in transitioning to BAT approach:
- in 1998-2003 cooperation with Denmark to develop example IPPC permits, to set
up a webpage for IPPC and BAT and to carry out trainings
- in 2002-2004 cooperation with Sweden on monitoring in industrial installations
• In 2008 a study was launched to investigate permitting and implementation of
IPPC Directive, including BAT. Recommendations for improvement were given.
• Support for installations has been mainly through seminars, trainings and
consultations.
• For uniform implementation regular meetings between authorities are in place.
International cooperation (IMPEL, EU MS).
• Supporting investments (in Estonia through Environmental Investment Centre)
Methods to support transition to a BAT approach

5. EestiVabariik
Permitting procedures

6. EestiVabariik
Permitting procedures
• Implementing BAT starts from applying an integrated
environmental permit. First applications from 2004.
• Guidance and consultations are necessary for the
installation but also for authorities.
• In Estonia integrated environmental permits are granted by
Environmental Board. Local municipalities are involved by
asking for opinions and conditions  goal is to co-ordinate
applied activities.

7. EestiVabariik
Experiences with Technical Working Groups
• Estonia has set up technical working groups to develop BAT for
intensive cattle farming and to develop local fuel (oil shale) based BAT
and emission limit values for the energetic use of oil shale and the
production of shale oil.
• A multi stakeholder TWG was formed, including authorities, industry,
NGO, scientists and experts. A research and data collection was
carried out by contracted experts. The outcome was local BREF and
BAT Conclusions.
• Participation in TWG-s on EU level: large combustion plant (LCP),
surface treatment with organic solvents (STS).

8. EestiVabariik
Experiences with Technical Working Groups
• Challenges with local BREFs: difficult to determine BAT
associated emission levels when there are a few
installations using different technologies
• Requires full cooperation in providing and analysing data
from installations
• Important to ensure confidentiality

9. EestiVabariik
Implementing BAT in challenging sectors
• Challenging sectors: the use of oil shale, large combustion plants, chemical
and mineral industry
• The cost of investments limited by the deadline of implementation of BAT
Conclusions for a maximum of 4 years from publication
• Derogation if given, they have to be according to certain conditions.
• When possible an action plan is determined in the permit to set activities for
full compliance by implementation deadline.
• ELV-s: Multi-fuel combustion and the variation of fuels. Renovation of boilers
and combining existing and new installations.
• Local differences
• Learning from the experiences and guidance from other countries.

10. Thank You for Your attention!
Senior Officer / Department of Environmental Technology, Ministry of the Environment of Estonia
Kristel Lopsik
kristel.lopsik@envir.ee, +372 6 262 860