5. POSSIBLE SOLUTIONS AND RECOMMENDATIONS FOR INTEGRATING VALUE CHAIN CONCEPTS
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5 Possible solutions and
recommendations for integrating value chain concepts into BAT determinations
There are numerous opportunities to apply value chain concepts to BAT determination to better address the environmental impacts of the whole value chain. Solutions may be tailored or broad but require careful consideration of the diverse interactions between sectors. Additionally, the exercise of defining the value chain and gaps in its consideration may highlight opportunities to leverage other regulatory and nonregulatory tools to minimize environmental impacts from industrial facilities.
How do we effectively integrate value chain concepts into BAT Reference Documents given framework limitations? Despite the challenges and framework limitations to integrating value chain concepts into BAT Reference Documents as described in the above chapter, some research has indicated the potential benefits of and possible initial steps for such integration.
Potential for integrating value chain concepts into the existing framework Although industrial emissions legislation has not been designed to incorporate circular economy priorities, Anderson et al. (2019[86]) emphasise that there is untapped potential for an enhanced contribution to objectives related to, in particular, waste generation, recycling rates and contribution of recycled materials to raw material demand, and innovation. Furthermore, the report points out that if the Technical Working Groups increasingly identify circular economy concerns as Key Environmental Issues, these would to be addressed in the BAT Conclusions to a larger extent. VITO and Ricardo provide a set of recommendations as to how the IED and the BREFs could be changed to better respond to circular economy concerns (Anderson, N. et al., 2019[83]), for example:
promote better uptake of emerging techniques in industry that have a focus on circular economy;
include experts on circular economy and from other sectors providing materials, energy or receiving by-products/wastes in the Technical Working Groups;
add a general/overreaching BAT to all sector BAT reports requiring consideration of value chain issues; and
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