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Facilitating Implementation of the IPPC Legislation through a Web-Based Environmental Consultancy Toolkit

Final ReportSummary - ENVIRON-MENTOR (Facilitating Implementation of the IPPC Legislation through a Web-Based Environmental Consultancy Toolkit)

In response to growing health and environmental concerns, industrial sectors whose activity may cause air, water or land pollution are being subjected to increasing European environmental legislations, such as the European Integrated Pollution Prevention and Control (IPPC) Directive. The IPPC is aimed at preventing, reducing or eliminating pollution through the more efficient use of natural resources. While recent European implementation of eco-friendly legislation is generally well received, given growing public concerns regarding the harmful effects of pollution on health and the environment, the costs to businesses, in particular SMEs, can be a significant challenge. Inability to meet IPPC requirements results in fines and penalties for non-compliance, as well as the risk of temporary closure.

Any company working in one or more of the areas that are considered as heavy pollutants are required to obtain an IPPC permit from their national authority. The national authority is obliged to implement this environmental enforcement through the IPPC directive (Directive 2008/1/EC of the European Parliament and of the Council of 15 January 2008 concerning integrated pollution prevention and control). The permitting process is a lengthy and laborious one and hence most of these SMEs turn to environmental consultants to get quality expert advice on how to meet IPPC requirements for pollution control, ask for guidance on permit applications as well as how to implement environmental management systems (EMS) and the best available techniques (BATs). However, such services are very expensive and require a considerable amount of time. It is estimated that a typical IPPC application can take up to a maximum of 100 days of a full time consultant and the true cost of an IPPC permit (including application and consultancy fees) is approximately EUR 20 000. The adoption of IPPC directives has become a serious challenge for companies that are often overwhelmed by the complexity and uncertainty of rapidly changing environmental policies.

ENVIRON-MENTOR is special software aimed at facilitating the process of acquiring the IPPC permit. The software assists the environmental consultant, by providing updated information on environmental measures. It also uses past knowledge to infer the right best available techniques (BAT) for the process in question. As part of its repertoire of services, ENVIRON-MENTOR also contains an implementation of the ISO 14001 Standard EMS. This is part of the IPPC permit and is required by the authority as part of the IPPC compliance. ENVIRON-MENTOR facilitates the implementation and accreditation of the standard by providing a set of building blocks that facilitate the process of ISO 14001 accreditation.

Finally, ENVIRON-MENTOR also deals with the trading of carbon emissions (emissions trading scheme). From 2013 onwards, in the third phase of the ETS scheme, the allowances are not expected to be allocated freely as has been the case in phase 1 and 2 of the trading scheme. During this last period, the allowances will be auctioned and ENVIRON-MENTOR implements a special type of auctioning platform based on multi agent technology. The technology mimics the reasoning process that occurs in a real life auctioning system where the actors are humans instead of software scripts whose behaviour is pre-programmed. Through this technology, ENVIRON-MENTOR employs a fair and just bidding process for all auctioneers and bidders.

Project context and objectives:

The proposed solution will consist of an intelligent, web-based expert system to assist environmental consultants in guiding plastics sector SMEs in environmental normative and standards. ENVIRON-MENTOR will also include a multi-agent platform for the trading of greenhouse gases, as established in the EU emissions trading scheme (ETS). The system will require no specific knowledge of environment legislations and normative on behalf of the end-user. This means that the proposed tool gives environmental consultants who currently do not offer IPPC guidance services, the possibility to explore a new sector thus enhancing their business prospects. Artificial intelligence tools will be used for company profiling so as to provide a tailored decision support to plan, implement, and control an EMS fulfilling the IPPC directive. The RTDs (MIIS (1), CRIC (7) and CSTM (8)), together with the other project partners, will design, develop and validate a web-based expert system that will apply knowledge and reasoning features based on the expert knowledge gathered from the requirements of the IPPC directive and information related to the plastics sector.

The main scientific objectives are:

- analyse the use and efficiency of an expert system for environmental impact assessment, and guidance on IPPC and EMS;
- analyze the use of multi-agent systems for automatic trading of emissions.

The main technical objectives are:

- Environmental normative access:
Users have ready access to updated normative and related legislation in a simple, step-by-step, intelligently profiled and quick manner, with the aim to obtain the integrated environmental permit. This system provides users with more structured information, facilitating the process of the retrieval of documents. Users can retrieve documents 20 % faster than through traditional means, where information is widely dispersed, not indexed and not easily attainable. The ENVIRON-MENTOR system has a structured, indexed repository which will assist the users to retrieve information more timely and accurately.

- EMS implementation support:
With access to IPPC expertise, consortium members, and clients of the ENVIRON-MENTOR system, will receive guidance on how their clients (specifically, companies in the plastics sector) can implement EMS with the support of the user-profiled tool, allowing them to plan, implement, review and improve the environmental organisation of the company. Moreover, the system will guide its users on the necessary requirements to obtain EMAS/ISO14000 certification in a step-by-step manner. ENVIRON-MENTOR will provide to its users all the required information to successfully obtain a certificate for EMAS/ISO 14000 without the need to retrieve more information from other sources.

- Best available technologies (BAT) information access:
Consultants will obtain recommendations regarding emission levels and BATs to meet European directives, always with the most recent data available and based on best available techniques reference documents (BREFs).

- Application module:
The system generates a duly made application in PDF format, including all the necessary information to satisfy all criteria made by the IPPC regulators. The application will include information obtained from the company profile, information on the site in question and type of installation(s). All this will be based on templates given beforehand by the consultant. Participating SME consultants state that the process to fill in the relative information manually takes on average 40 % of their total time to complete an IPPC application. Through this module, SME consultants will reduce the time taken to compile an IPPC application by >= 30 %.

- Multi-agent emissions trading platform:
The system includes an automatic trading platform that will permit emissions trading as specified by the ETS/JI/CDM. The ENVIRON-MENTOR system will mediate the automatic trading process, allowing any company (even those outside the EU, since trading of emissions is available internationally) to find the best offer of emissions purchase or sale, fulfilling company needs. The system will be based on parameters specified by the buyer and will inform the user of any potential opportunities available. Such information extracted by the trading platform will be similar to that provided by any expert consultant, having the same parameters and resources available. However, as more companies register, this module will be more reliable than autonomous expert consultant due to its potential to reach companies across the globe.

- In order to measure and validate the success of the project, participating SMEs (the environmental consultants) together with five other well recognised organisations and experts from the environmental consultancy tested the system in the different participating countries. The tool has been validated by comparing the results obtained from the ENVIRON-MENTOR system with the decisions taken by the environmental consultants. Case studies that provided by the participating SMEs have also been used for validation activities.

- The system is updatable and adaptable:
The adoption of new normative frameworks can be introduced into the already running system without major adaptations. As an online system, the user will always be working with the most updated information, without the need to consistently purchase updated versions of software

The other objectives related to training, dissemination and exploitation are listed below:

- Development of a website that was used to disseminate the status of the project and to provide interested parties regular updates of new features added to the system. The website contains links to the online demo and all the documents related to training like user manuals, videos and presentations.
- Development of training plan and organisation training workshops. A training plan was prepared and several training workshops where organised throughout the project duration. The training was open for SMEs and also interested parties and policy makers.
- Dissemination of the project in conferences, fairs and scientific publications: A dissemination plan was devised early in the project. The project was disseminated in a number of conferences and fairs and also two papers on the project where published.

Project results:

The ENVIRON-MENTOR system is made up of a number of modules that altogether make up the whole system. Each of the modules is an independent sub system which is a result in itself. The following section outlines each of the S&T results generated during the project:

Polymer BAT knowledge database

During the first period of the project, CSTM, experts in environmental legislation created a BAT knowledgebase for all categories that fall under the polymers section. For each process, the active processes and directly associated processes where identified and for each of these, the emissions and consumptions from each where identified. When this was ready, for each consumption and emission, the experts identified the BAT (options) that could be used. Some consumptions and emissions could have up to five different options and the options differ for each consumption and emission between processes. This means the BAT to reduce dust in a PVC process might be different to that in an ESBR process.

The generated knowledge base was first made in a series of Excel spreadsheets and then integrated into the database. Any user could use the knowledge base either from the online system or through the excel spreadsheets directly.

IPPC permitting module

The IPPC permitting module is the main module of the system. The module is basically a large repository split into different section based on the IPPC directive. To create an IPPC application permit, one has to fill in all the sections with the information requested from this module. The module also contains the knowledgebase explained earlier and an Expert system to use that knowledgebase.

One thing to note is that for the users, the IPPC permitting module does not change when doing an IPPC application for a different country. The transformation from one domain into another domain is handled by the application generator explained below. Finally, the module also contains a special section called the EMS. The EMS is required by IPPC and ENVIRON-MENTOR contains a special ISO standard implementation to allow easy adaptation of an EMS to that particular case.

Case based reasoning expert system

The knowledgebase in itself is basically a reference which SMEs can see to identify particular options but ENVIRON-MENTOR goes an extra step by using an expert system to provide the SME with the best option based on special reasoning which improves with the system (learning). This particular reason is obtained using case based reasoning (CBR). Case based reasoning uses previous cases to infer which options best suite the case in question. Obviously the system is started with a set of known 'good' cases and from then onwards every case becomes a wealth of information for the CBR to work with. A special algorithm is used to find similarity between cases and ordered so that the user could decide which one to use.

Application generator

The IPPC is a directive but it is then left up to the national authority to implement this directive as long as the implementation is in line with the directive. This means that every country has a different implementation of the directive an in fact the application document between one country and the other has a different format and too some extent different contents. During the initial phases of ENVIRON-MENTOR, when the architecture of the system was being selected, it was decided to use the IPPC format for all countries and then develop an application generator that transforms the application into the required country. Special content required by the national authority in particular countries only is entered after the application is generated. The output from this module is a word document which can be submitted directly to the authority.


Study on ETS auctioning and the application of multi agent technology to this area

Before developing the multi agent auctioning platform, the consortium studied the benefits and the legal matters that the system would have to deal with. Since auctioning is a new 'procedure', the study outlines the benefits of applying the multi agent technology to this area, what instructions the agents will work with, the degree of autonomy and other factors. The study also outlines how to provide 'fair' bidding and other matters.

Multi agent auctioning platform

The auctioning platform is a special module within the ENVIRON-MENTOR system that allows the auctioning of carbon units. Unlike traditional auction systems where the user bids on an auction in real time or through 'timed' actions, ENVIRON-MENTOR utilises a software agent framework. A software agent is a special software which, like a human, has behaviour, can interact with other agents, obeys instructions and more importantly has one aim that of reaching a particular aim. In our case the aim is to win an auction(s) based on the instructions given. This means the bidders, only need to assign an agent and provide it with instructions (units require and bidding allowance) and from then on, the process of bidding is automated by the agent. During the bidding, the agent changes behaviour and interacts to try and win the required units with the least price. This kind of technology has many benefits with our outlined in the deliverables of this project.

EMS module

The EMS module is part of the IPPC module but it can work independently from the IPPC module. Since an IPPC application has to be accompanies by an EMS, the consortium decided to add a special module that can facilitate the implementation of an EMS inside an organisation. The EMS module is based on the ISO 14001 standard which is accepted by the IPPC directive. Using this module, users can easily adapt the EMS and tailor it to their companies hence facilitating the process of implementing the EMS inside the organisation.

Virtual appliance of the ENVIRON-MENTOR system

One of the issues system like ENVIRON-MENTOR suffer from is that they are highly complex to deploy. This is because they rely on a client server architecture and the server is made up of a number of components. To reduce this burden, the RTDs packaged the whole ENVIRON-MENTOR system in a virtual appliance, a software that can be 'played' in a special software hence reducing deployment time and making the system more portable.

Potential impact:

The potential impact for the partners within the consortium comes from different areas. The main and most important impact of the project for the consortium comes from sales of ENVIRON-MENTOR's services for environmental consultants. With the system, environmental consultants can facilitate their process of acquiring an IPPC permit. Clients could also use ENVIRON-MENTOR to obtain ISO 14001 accreditation since this module is an independent module from the IPPC module. The third service is carbon emissions trading and clients can use ENVIRON-MENTOR to auction their units, through which the SME partners will reap benefits both from the auctioning service and from the transaction fee which is a small percentage over the total transaction.

The use of an expert system such as ENVIRON-MENTOR will significantly facilitate access and guidance for the IPPC directive, EMS standards (ISO 14000) as well as emissions trading schemes (ETS, CDM, JI). Environmental consultants using the proposed system will be able to offer higher quality services at lower prices with more efficiency. Environmental consultants will have instant access to updated environmental legislations and standards with the purpose to provide excellent service to their clients. ENVIRON-MENTOR will also enable the participating SMEs to offer greenhouse trading services to their clients via the trading platform.

To this end, the ENVIRON-MENTOR system will enhance the services of the SMEPs and will improve their profits by giving them a competitive advantage over other consultants in the environment sector. Notwithstanding, the IT SME partner being an expert in software development, will have an additional tool in their product portfolio and more importantly they will have an expert system based on CBR that allows them to implement it in other areas where simple database approaches are not possible. Moreover, through ENVIRON-MENTOR, Introsol will gather knowledge in a different area giving them the possibility to use this technology in other sectors.

Currently, the project is aimed to be launched in the consortium partners countries but ENVIRON-MENTOR will be launched throughout the whole EU-27 and associated countries since this is not a problem faced only by the participating countries. Participating SMEs have already agreed that this tool bears great potential for the expansion into new vertical (specialisation i.e. pharmaceuticals) and horizontal (different i.e. minerals) markets. Once ENVIRON-MENTOR reaches its maturity stage in the product lifecycle and obtained potential positive feedback from the market, a strategic market plan will be devised, forecasting prospective opportunities for the growth of ENVIRON-MENTOR in other sectors. Such strategy will result in extension of the product line sheltered by the parent brand which will ensure that consumers have an instant recognition of the product name, hence lower promotional costs for the line extension.

Based on calculations made at the end of the project including market studies and other factors a return of EUR 4.5 million is predicted within 5 years after the project completion, giving a return on investment of 3.7.

Economic impact on the plastics sector

The plastics sector is formed by 172 575 companies (of which 29 % are SMEs) and employs well over 1.5 million people around Europe. Plastic manufacturing companies especially SMEs are facing significant challenges in terms of IPPC implementation. TT Environmental, a consultancy firm, said that environmental legislation is putting of investment in the UK due to the unavoidable expensive consultancy services. As has already been explained in section 1, typical cost for a permit application (including EPA fees) is EUR 16 000 and in some cases can even reach EUR 20 000. A discussion between the participating environmental consultants has shown that on average an environmental consultant charges EUR 415/day. ENVIRON-MENTOR will enable environmental consultants to reduce the time taken to prepare and submit a permit application (hence the costs incurred) while still keeping the same quality as before. To this end, users of ENVIRON-MENTOR will become more competitive than other environmental consultants, resulting in an increased clientele.

Impact on carbon trading within the EU and internationally

Another area which ENVIRON-MENTOR is expected to provide benefit is in the area of carbon trading by providing the market with an auctioning system that is not just like all other auction systems but through the use of a novel technology, the system can automate the auctioning process, keep it fair and mimic behaviour that is normally difficult to implement in regular software scripts. This implementation will bring benefits primarily to the auctioneers and bidders who need a fair, open and a bidding process that makes the best possible economic benefit for their needs. Secondly, given the attractive approach of the system, the partners will reap the benefits of the transaction fees charged for using the auctioning system.

Impact on European standards and policy

Given the demonstrated difficulties in fully understanding IPPC requirements it is not surprising there have been problems associated with its implementation. In fact, a review regarding the execution of the IPPC directive carried out by the European Commission (EC), highlighted the 'slow pace of implementation' of the normative as one of the challenges faced by Member States in general and industry in particular. The report stated that 'most Member States and many IPPC operators have not yet fully realised the urgency of the matter and need a wake-up call.'

The ENVIRON-MENTOR system will help to significantly accelerate the IPPC implementation. It will also facilitate the process for those companies that want to implement an environmental management system and get certified either under the EMAS scheme or the ISO14000 standard. Moreover, ENVIRON-MENTOR will push forward the idea of emissions trading by enabling environmental consultants' clients to trade emission allowances with other companies using the multi-agent trading platform.

Health and environmental impact

Companies within the plastics sector use and produce hazardous substances both as raw materials and by-products. Although the economic success of the plastics sector is evident, it is also a highly polluting industry and a key target for IPPC. An example of the pros and cons of plastics is polyvinyl chloride, (IUPAC polychloroethene) commonly abbreviated - PVC, a widely used thermoplastic polymer and one of the most valuable products in the chemical industry, in terms of revenue generated. This material is used in a number of industrial sectors (such as automotive, packaging, medical care and agriculture). Over 50 % of PVC manufactured is utilised for construction. Despite it is the world's second most commonly used plastic, its production is the most harmful to the environment as it is one of the world's largest dioxin sources. Dioxin is a powerful hormone-disrupting chemical which binds to a cell's hormone receptor and modifies the functioning and genetic mechanism of a cell, causing a wide range of effects, such as cancer, reduced immunity, nervous system disorders, miscarriages and birth deformity.

ENVIRON-MENTOR will help such companies by providing them with the best-suited environmental management system certified under EMAS/ISO 14000. ENVIRON-MENTOR will also provide such companies with the latest best available techniques (BATs) ensuring that they are always up-to-date with the current technology. Overall, this will result in an increased adherence to environmental standards and legislation leading to more efficient use of resources (including energy sources) and better management of hazardous by-products within the plastics sector. Companies within this sector will be working to the highest practicable standard, hence minimising harm to the environment.

Moreover, ENVIRON-MENTOR as a collection of environmental normative and standards knowledge will be helping the EC to reach its pollution-reduction targets.

Dissemination

The project has been disseminated in a number of fairs and conferences. The following is a list of the dissemination activities of the project and the response obtained from the audience during each activity.

International Joint Conference on Artificial Intelligence (Barcelona, 2011)

ENVIRON-MENTOR was disseminated in the twenty-second international joint conference on artificial intelligence in Barcelona. CRIC, an RTD in the project were responsible for the dissemination of the project in this conference. They designed a poster for the project which can be found in attachments of this report. The audience in this conference is mostly academics working in the growing field in IT.

Overall the response on the project was very good and many visitors showed interest in the project. Some visitors raised questions on the international applicability of the system stating problems like language and knowledge domain as the main limitation it has should the technology be applied in different countries. Most visitors also said that the choice of using a CBR as an expert system was the right one for this case.

United Nations Conference on sustainable Development (RIO+20 Brazil, 2012)

Participation in RIO+20 side-events was purposed to indicate possibilities for an ENVIRON-MENTOR follow up. The project ENVIRON-MENTOR is mentioned in the presentation at a side event of the RIO+20, called the Global Research Forum on Sustainable Consumption and Production (GRF-SCORAI). This side event brought together about 80 high level experts from all over the world. The audience was primarily interested in impacts of policies on the consumption, which is only a side-line of the ENVIRON-MENTOR project. Several side events about pollution and models on internet are followed at the RIO+20 and leaflets on ENVIRON-MENTOR are distributed at the auditorium. For ENVIRON-MENTOR, the LEDS global partnership (see http://en.openei.org/wiki/LEDSGP online) is interesting because several countries and non-governmental organisations aim to provide access to various models through internet. ENVIRON-MENTOR is invited to participate (Ron Benioff NREL, ron.benioff@nrel.gov via e-mail). The European Environmental Agency (EEA) has developed open source models on internet that map various pollutants and their impacts but how to link up is unclear (it is rather driven by the EU administration). In another side event, Luisa Prista, head of the EU unit environmental technologies, indicated that the R&D programme Horizon 2020 is focused on societal demands. In sum, the follow up of ENVIRON-MENTOR can link up with the open access initiatives and follow the EU priorities on societal interests with respect to environmental technologies, whereas SCORAI is not the suitable platform.

International Conference on Public and Private Strategies for Sustainable Regional Development

The paper of 'ENVIRON-MENTOR , an expert system to assist businesses with environmental permits' was presented the first day according to the programme. A combination of papers and special presentations (mainly from the industrial sector) conformed the programme: 30 abstracts and 21 full papers.

The registration to the conference achieved 80 records. In some extent, all stakeholders were represented: academia (national and International institutions), government (Minister of Environment, Mexico City, Fideicomiso para el Ahorro de Energía (FIDE)), NGOs, private sector (multinational and local companies).

Comments about ENVIRON-MENTOR paper

The paper had positive feedback from audience. The practical use of an expert system for the polymer sector in the European context was highly appreciated by the audience. The perception of complexity of the system was mentioned by some participants. The fact that the expert system includes regulatory and market based policy instruments have provoked comments of interest for adapting it to other contexts such as the Latin American one. In most of the cases, industries and/or companies have to deal with different sources and tools in order to implement the environmental policies. Therefore, just by having the main checklists and guidelines integrated in the same software that will save an important amount of time and resources.

Questions were risen about the timing to finalise the complete expert system and also about its commercialisation. The paper presenter on this conference (Laura Franco) said that the complete version of the expert system is planned by end of 2012. A question about copyrights came from the audience and it was answered that those correspond to the software developers accordantly to the project description.

Tardis Workshop (Austria, April 2012)

Tardis stands for Trans-Atlantic Research and Development Interachange on Sustainability. The workshop is organised by the Graz Technical University, EPA - US and Ministry for Science and Development in Austria. The participants on this workshop are senior experts and policy makers on sustainable development. The presentation has caught interest particularly the possibility of cost saving through use of ICT in the permit procedures is found highly relevant for the European and US contexts. Dissemination of information is possible. A model for testing is found useful.

Sustainability Live (Birmingham 2012)

Sustainability live is a big conference held in Birmingham. It is a combination of about four smaller fairs that were grouped into one fair (see http://www.sustainabilitylive.com/ online). MIIS had a stand in the Sustainability Live fair. Leaflets were distributed to interested parties in the fair and a demo was set up and shown to the interested user. The fair has an international audience and is free to enter for visitors.

The visitors working in the area of environmental consultancy were generally all interested and most of them asked for a small tour of the product. Most of them expressed their need for software in this area with some consultants working for big companies stating that in some cases they have developed some in house solutions for their needs. Some of them use simple excel spreadsheets and some are using special software like CVS to store and retrieve knowledge and past cases.

Some visitors also asked why such tools are not yet implemented by the government itself to make it easier for the SME to acquire the permit. In total, more than 900 leaflets were distributed during the fair and an Excel of interested parties was created and distributed among the SMEs to contact the interested parties and send them more information about the project.

Exploitation

It has been agreed between all the SMEs in the project that the exploitation of ENVIRON-MENTOR will take two routes. The first exploitation route is the same one planned throughout the project which is selling the services of ENVIRON-MENTOR to environmental consultants within the EU where it can be used to acquire IPPC permitting. Under this exploitation route, the SMEs will offer ENVIRON-MENTOR's service as a paid subscription per application to environmental consultants in need of acquiring and IPPC permit.

The SMEs will open a new spin-off company, probably with the name ENVIRON-MENTOR which will commercialise the product. The initial plan is to acquire a good customer base in the four countries of the four SMEs listed above (United Kingdom (UK), Spain, Slovakia, Czech Republic). Since the SMEs are already familiarised with the IPPC system in their respective countries, they can offer support from the 'environmental knowledge' area while Introsol will offer technical support on IT related issues.

In the second route, the SMEs will look to sell ENVIRON-MENTOR, as a system and model to developing countries that are in need of establishing and environmental permitting system similar to the IPPC in the EU. ENVIRON-MENTOR can serve as a basic model and since it is an online software system, the county implementing it would have an IT system that minimises paperwork and makes the process more transparent. Under this route the SME environmental consultants will be responsible in the implementation of the ENVIRON-MENTOR model along with the transfer of the rights to use the ENVIRON-MENTOR software in the country in question.

At this stage some contacts have been established through a large working group called 'LEDs global partnership'. The group, low emissions development strategies, was founded to enhance coordination and information exchange between countries, specifically between programs from these countries with the aim to reduce global emissions. The group contains government agencies and international institutions (private and public). Of particular interest to the project are the government agencies in the South American region like Chile, Columbia and Mexico. The consortium has already attended three conferences on this subject in this region and has achieved some contacts which are currently being followed up to create possibilities of exporting the services of ENVIRON-MENTOR to these developing countries that need a similar model to the EU environmental permit system.

All the exploitation activities will be carried out under the coordination of the exploitation committee chaired by Mr Martin Glossop from IPPC Consultants. The final system (software) can only be protected by copyright which is automatic (i.e. no registration needed). Technological measures will be taken in order to prevent illegal copying by third parties. The knowledge-base, which in essence is a database, is automatically protected under the 96/9/EC directive which states the legal protection of databases.

Project website: http://www.environmentor-project.com