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Is it


That a technology which can

no longer be legally installed should be the determinant factor in setting a sectors benchmark level.

Is it

That a technology which can

Is it

That a technology which can

fair? fair?

no longer be legally installed should

result in the closure of the rest of the nitric-acid industry with the loss of more than 10,000 direct jobs and considerably more indirect jobs.

no longer be legally installed should result in the loss of Europe’s self-reliance for food.

7 of the 11 plants dictating the benchmark proposed by DG CLIMA operate with NSCR technology that can no longer be installed.

A fair way to determine the benchmark is to base the calculation on the “average performance of the 10% most efficient installations”.

Average best 10% Benchmark

DG CLIMA Benchmark


The 10% most efficient


d Ba

The majority of these plants will through heavy investment be able to install a mix of “legally” available technology to reduce their emissions significantly.




“Bad Apples” Old plants will likely need to close.

reduction in emissions

installations. Benchmark based on “average performance of the 10% most efficient installations” Benchmark based on NSCR technology which is no longer possible to install Nitric-acid plants

Inclusion of NSCR will result in unavoidable plant closures and loss of jobs.


15% 30% 40% 15%


of the current population are fed thanks to mineral fertilizers.


included in benchmark


excluded from benchmark












If plants were forced to close in Europe with the production capacity shifting to neighbouring regions the increase in global emissions would be huge. Taking Russia as an example an extra 37million/t/kg/CO2 would be emitted. Equal to the total saved in the whole of ETSII .

New advancements in technology and considerable investment will allow plants to make substantial emission reductions. This will only be possible if a fair and reasonable approach using the “average performance of the 10% most efficient installations�.




Old plants without the possibility to upgrade and install new technology will require to close.



Because of the special nature of NSCR plants they should have their own fixed benchmark.

in emission reductions

If NSCR technology is used as the basis of determining the benchmark the industry in Europe will be nearly wiped out. The benchmark levels would be unachievable with the additional CO2 cost resulting in companies operating at a loss. This would result in the loss of more than 10,000 direct jobs and tens of thousands more indirect jobs.

Consequences of losing a vital industry

The world will have 3 billion more mouths to feed by 2050.

Without fertilizers…...... many will go hungry.

Fertilizers provide the only means to keep pace with the global demand for food.

Without fertilizers…Europe will lose its self-sufficiency in food and be less able to contribute to world needs.

Natural gas is a fundamental raw material for modern fertilizer production.

Without affordable natural gas…European fertilizer costs will be prohibitively expensive and Europe’s food production will suffer.

12% of global greenhouse gas emissions come from changes in land use. Fertilizers play a key role in meeting the EU ’s ambitious targets for renewable energy. The European fertilizer industry is deemed to be the sector most exposed to ‘carbon leakage’.

With more efficient use of existing land and greater crop yields, agriculture can minimise its effect on the environment. Without them….. Europe will continue to rely heavily on fossil fuels, an unsustainable natural resource. Without a European fertilizer industry… production will move to less environmentally conscious regions with far greater carbon emissions.

To set benchmarks in accordance with

It is


“the average performance of the 10% most efficient installations in a sector� By setting benchmarks in accordance with Article 10a of the directive the fertilizer industry has, with considerable investment, the chance of survival. It will also result in emission reductions of

75%. NSCR plants because of their special characteristics should have their own fixed benchmark.

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