Industrial plant operators: Environmental regulations tighten and costs rise

National and European environmental regulations are becoming increasingly complicated. Plant operators can sometimes feel overwhelmed: Permitting procedures are becoming more complex, the cycles of mandatory measurements shorter – not to mention the effects of national fuel emissions trading. Plant operators worry about getting distracted from their real focus: producing high-quality products and keeping plants running smoothly. Infraserv Höchst supports you with services at the quality you have come to expect.

The increased requirements and rising costs for the operation of industrial plants in Germany are due to reasons such as:

• More complex permitting procedures
• New measurement cycles or stricter limits for environmental compliance in air pollution control
• Effects of the Fuel Emissions Trading Act (BEHG)

Obtaining permits for industrial plants under the German Immissions Control Act (BImSchG) is complex and time-consuming in almost all cases, with the possible exception of the Tesla plant in Brandenburg. This is partly due to the thicket of rules to follow in the permitting procedure and partly due to short-staffing at the permitting authorities. The new Technical Instructions on Air Quality Control ( TA Luft ) recently came into force. This could further increase the complexity of future permitting procedures if only due to the additional administrative overhead of processing all the modification permits. Longer permitting and commissioning times inevitably entail higher costs. Stricter emission and measurement requirements also affect plant operating costs.

Another relevant issue is the Fuel Emissions Trading Act (BEHG). It affects power plant operators outside the European greenhouse gas emissions trading system as well as all consumers of fuels deemed “tradable” under the BEHG. The additional costs resulting from fuel suppliers trading certificates are passed on to end consumers as higher energy prices. That includes not only plant operators who consume large volumes of natural gas, but private households as well.

Example of the challenges of meeting measurement requirements: waste incineration plants

The 17th German Federal Immission Control Regulation (17th BImSchV) regulates the operation of plants whose main purpose is the incineration of waste or the production of materials using waste as an additional fuel.

The measurement cycle for recurring emission measurements was previously set at 12 months. This annual rhythm was changed in summer 2021 by the amendment to the 17th BImSchV. Recurring measurements are now required every six months – thus doubling the costs. While a passage in the regulation allows annual measurements to continue if certain conditions are met, there is another problem: The measuring institutes with § 29b BImSchG approvals were already running at the limit of their capacities before the measurement cycle was accelerated. It will be extremely difficult to make measurements more frequently. Things gets even more interesting when you look at the passage in the 17th BImSchV that lays out the conditions for maintaining annual emission measurements: all limit values have to be complied with at a 50% confidence level.

However, if a waste incineration plant operator cannot guarantee compliance with air pollutant emissions limits, two things will happen:

• The six-month measurement cycle doubles the costs of the measurement program (potentially into five figures)
• It may be very difficult to find an accredited measurement institute that can do the work, especially given the current skilled labor shortage and the requirement to prove years of experience during an audit

Infraserv Höchst provides services at the quality you have come to expect.

Infraserv Höchst helps you focus on operating your plants: By serving as an external immission control officer, measuring emissions at your plant or providing comprehensive immission control consulting when complying with the 17th BImSchV and maintaining the annual measurement cycle. Our decades of experience and environmental expertise can make it all possible.