Dr Richard Schlachta holds a PhD in physical chemistry from the Technical University of Munich and has over 33 years of professional experience in environmental protection within the Bavarian government. Since 2014, he has been serving as Head of the Department for Technical Environmental Protection at the District Government of Upper Bavaria. His responsibilities include the implementation and enforcement of the Industrial Emissions Directive (IED), with a focus on application of Best Available Techniques (BAT) in environmental permitting, emission monitoring and inspection of industrial installations. His technical focus areas especially include air quality planning, VOC and chemical installations, refineries and waste treatment installations.
Dr Schlachta has been an active member of several EU and German technical working groups (TWGs) for the development and revision of BAT Reference Documents (BREFs), including Surface Treatment Using Organic Solvents (STS), Textile Industry, Chlor-Alkali, Large Volume Organic Chemicals, and Common Waste Gas Treatment in the Chemical Sector. He is also a member of the German national ad hoc expert group on the 31. BImSchV (national implementation of the EU VOC Directive 1999/13/EC – Chapter V of the IED), and has contributed to various initiatives under the Alpine Convention and Clean Air for Europe (CAFE) programme. In addition to his regulatory work, he is engaged in the training of environmental staff in the application of BAT and inspection procedures in other countries within projects of EU-Commission or of German Government like Armenia, Romania, Slovenia, Turkey, Israel, Moldova, North-Cyprus etc.
Dr Schlachta has supported Serbia’s alignment with EU environmental legislation since 2010 through his participation in several technical assistance and Twinning projects. He was involved in the eVOC Serbia project (2019 – 2022), where he provided expert support for the implementation of the EU VOC Directive. He also contributed to the PLAC I and PLAC II projects, delivering training on VOC control and IED Chapter V requirements. His recent work under the IED Serbia project includes expert support for the preparation of the Directive Specific Implementation Plan (DSIP) for IED and capacity building regarding new IPPC activities and integrated permitting procedures.
IED Serbia: Richard, could you briefly introduce yourself and share key aspects of your professional background in the field of environmental protection, particularly regarding your previous cooperation with institutions in Serbia?
Dr Richard Schlachta: After completing my doctorate in physical chemistry in 1992, I began my professional career as an environmental inspector at the Bavarian State Agency for the Environment. The next stages of my career included around ten years at the Bavarian State Ministry of the Environment, and since 2014, I have been Head of the Technical Environmental Protection Department at the Upper Bavarian Environmental District. The focus of my professional activities has therefore always been closely related to the IPPC Directive and the IED, with an emphasis on permitting, application of BAT, emission monitoring and control. Today, I hold a senior position responsible for the implementation and enforcement of IED requirements in the field of technical environmental protection in my district. Thanks to my many years of professional experience with such installations, I have also had the opportunity to serve as a member of the EU Technical Working Group and the German national working group for BREFs on Surface Treatment Using Organic Solvents (STS), Production of Large Volume Organic Chemicals (LVOC), the Textile industry and Common Waste Gas Treatment in the Chemical Sector (WGC).
As part of the Czech-German Twinning project in 2010, I supported the Serbian Ministry of the Environment in drafting proposals for the implementation of Directive 1999/13/EC on solvent emissions and the Petrol Stage I/II Directives. Later, I had the opportunity to train representatives of the relevant Serbian authorities, particularly inspectors, through a number of EU-funded projects. During my work with my Serbian colleagues, I have developed a close connection with Serbia and its people, and I have made several trips to explore the country in my free time. Because of these wonderful experiences, I have a strong personal interest in supporting Serbia to the best of my ability by sharing my expertise in the implementation and enforcement of EU legislation, such as the IED Directive and the Petrol Stage I/II Directives.
IED Serbia: Within the “Green Transition – Implementing Industrial Emissions Directive in Serbia – IED Serbia” project, your role includes providing support for the development of the Directive Specific Implementation Plan (DSIP) for the Industrial Emissions Directive (IED), as well as assisting operators in identifying and resolving potential non-compliance with emission limit values and implementing measures to achieve full compliance with the IED. What are the main challenges and priorities at this stage of DSIP preparation?
Dr Richard Schlachta: Firstly, I would like to point out that I have always met highly motivated and committed operators who are genuinely interested in improving their environmental performance. In general, operators are well trained and, in most cases, very familiar with the environmental challenges. However, as in many other countries, there are clear budgetary limitations. This means that operators must often make difficult decisions about how and where to invest in their facilities. Problems tend to arise particularly in older plants that have not seen significant investment in improving production efficiency and environmental performance over many years. Of course, there is a gap when comparing these plants with similar EU installations that have been required to comply with the best available techniques (BAT) under the 1996 IPPC Directive for decades. In other words, many older Serbian plants that have not yet invested in environmental performance and production efficiency are now facing major difficulties in meeting the binding EU environmental standards set out in the BAT conclusions under the IED. In order to keep such plants alive and secure jobs, it will therefore be essential to develop individual, specific implementation plans that can guide the industrial transformation process in a realistic and manageable way. Personally, I think that by the time these plants have achieved their conversion targets, new EU environmental requirements will already be in place, and the process may be perceived as never-ending. However, in a globalised and competitive world, the willingness to embrace continuous improvement and change, is becoming increasingly essential. This is evident in the efforts of operators worldwide to reduce the energy consumption of their plants due to rising energy costs and to align with ambitious climate targets.
IED Serbia: You recently participated in a technical workshop focused on new categories and subcategories of industrial activities that, due to harmonisation with the IED, will be subject to integrated (IPPC) permitting requirements. What were the key topics and takeaways from the workshop, and what kind of feedback did you receive from the participants?
Dr Richard Schlachta: The main topics of the capacity-building workshop were raising awareness and providing information to new IED operators and to competent authorities, about the new categories included in Annex I of IED 2010/75/EU[1] compared to the ‘old’ IPPC Directive 96/61/EC of 24 September 1996. This workshop, organised by the IED Serbia project in cooperation with the Ministry of Environmental Protection of the Republic of Serbia and the Serbian Chamber of Commerce and Industry, provided participants with up-to-date information on the planned legislative changes.
Participants showed great interest in the new legal developments and the best available techniques. As expected, industry representatives pointed out that the new requirements will require significant financial efforts. However, alignment with the EU acquis is mandatory for the association process, and this includes the implementation and enforcement of the IED and the best available techniques. Returning to the second question, the development of DSIPs based on the individual specific situation of each installation, taking into account the gap between the installed technology and the required environmental performance, is essential to achieve a balanced technical transformation process between environmental requirements and economic needs. Ultimately, however, closing the technological gap will be positive for the Serbian companies concerned, making them fit for the future and competitive with other EU companies. An individual approach is necessary, as many Serbian industrial companies have already achieved a high level of technology. The IED Serbia project is therefore the best opportunity for operators to verify compliance with the relevant EU BAT conclusions or to receive support in developing DSIP.
I would like to point out that Serbia’s approach to launching such a project under the leadership of the Cleaner Production Centre of the Faculty of Technology and Metallurgy of the University of Belgrade is exceptional and unique – I have been involved in many IPPC projects in other countries, but this approach and concept for implementing the IPPC and IED Directives through the IED Serbia Project are, in my view, particularly suited to achieving the implementation goals. This project facilitates cooperation between competent authorities and operators, enabling them to work together and receive technical advice and support to help meet EU requirements – a particularly effective model!