Lesson 10 – Approaches to Effectiveness Evaluation of BAT Policies

Welcome to the lesson about the main approaches to the effectiveness evaluation of BAT policies. In this course, we will explore the different methods for evaluating the effectiveness of Best Available Techniques (BAT) policies.

Evaluating the effectiveness of a BAT policy involves assessing the policy’s impact on emission trends, including the concentration, mass, or percentage of industrial emissions, and comparing this to the policy’s defined objectives and a business-as-usual scenario.
In addition to assessing emission trends, the effectiveness evaluation may consider the impact of declining emission trends on negative externalities associated with industrial pollution.

This could include measuring improvements in human health, environmental, and economic indicators. For instance, we will learn how to assess changes in concentrations or relative proportions of key indicator pollutants in environmental media, the number of hazardous substances generated in production processes, and resulting changes in environmental impacts, resource use, and mortality and morbidity rates attributed to environmental quality.

We will explore how the Organization for Economic Cooperation and Development (OECD) projects the effects of industrial air emissions on human health and the economy by assessing the market costs of outdoor air pollution, including productivity, healthcare expenditures, and changes in crop yields. We will also learn about the multi-sectorial, multiregional ENV-Linkages model used by the OECD to link economic activities to energy and environmental issues.

We will discuss the importance of a comprehensive and detailed process-level cost-benefit analysis of a BAT policy. This analysis involves comparing the benefits of the policy, such as reduced industrial emissions, gains in productivity, and avoided health and environmental costs (i.e., damage costs), to the cost to industry operators of implementing improved techniques to comply with permit conditions. We will examine how emission reductions should be estimated for a period equivalent to the lifetime of the emissions reduction techniques and/or the envisaged operating time of the operator, and how the conditions of use of the techniques should be taken into account.
Moreover, we will discuss the challenges involved in fully understanding and obtaining supporting data on industry operators’ costs to BAT implementation, including legal requirements and confidentiality issues. We will also examine the uncertainties involved in estimating the damage costs avoided, including data access and methodology.

In addition, we will explore an alternative to process-level cost-benefit analysis, which is a high-level assessment of a BAT policy’s impact on emissions trends based on publicly available data. We will learn how this method determines the practical effects of the measures deployed.
Finally, we will discuss the importance of assessing the effectiveness of the BAT themselves, as part of regular reviews of BAT reference documents (BREFs), and examine the differences between ex-post and ex-ante evaluations. Ex-post evaluations are based on historical observations and seek to quantify the impact of a BAT policy after its implementation.

Ex ante evaluations, on the other hand, aim to predict the quantified impact of a policy prior to its implementation. We will examine the analytical steps involved in ex-ante regulatory impact assessment and opportunities for public engagement to hold governments accountable for conducting analysis before regulations or policies are issued.