– in the opinion of RTD one of policy option should be based on performance criteria as to avoid preferring any specific technologies. As the result of the discussions it was agreed that those issue will be dealt with on technical level (verification of calculation and explain differences of methodologies) by cooperation of RTD and ENV. The policy option based on performance criteria could be acceptable, however no adequate criteria has been yet developed. While this option has not been analysed as the scenario it should be reviewed when performance criteria would be identified. The environmental, economic and social effects should be very similar to options discussed in the IA, while setting performance target would give more Member States and enterprises more flexibility and avoid promotion of any specific technology. It was agreed to flag this issue in IA but discuss in details when concrete proposals would be available (also possible at later stage of possible legislative process). However ENV stressed that proposed approach of promotion of separate collection is already to large extent "technology neutral" as it gives freedom as for further use of collected waste. Final item discussed was the timeline for possible future police developments based on this IA, taking into account the start-up of new Commission. In parallel to ISG meeting ENV has received a written input from JRC and TREN. These contributions pointed out that the CO2 calculation methodology counts biomass carbon as "fossil" carbon and by including a discount factor skews the result in favour of composting. JRC and TREN also reflected on the methodology of calculation of environmental impact from the energy replaced by energy from bio-waste. The final text has been modified to more clearly show the differences concerning methodology of carbon calculations (figures in chapter 8.1.2). The comment on calculation of marginal energy has not been included due to data problems. Further actions:
As the comments received during and after IASG meeting implied considerable further work on the IA draft before submission to the IAB, additional written round of comments was held in December - resulting with set of remarks regarding structure of IA in general and proposal of improvement and clarifications in the text (ECFIN). Additional comments concerned need of better visibility in the text the issue that methodology could favour composting over incineration (TREN) and provided IA with additional data on potential of bio-fuels from biowaste (RTD).
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