2.4Issues to ensure coherence with thematic legislation (e.g. definition of key concepts)
2.4.1Observations on the current Production Facilities Theme and its relation to the EU Registry of Industrial Facilities
Country /Issue number:
EEA-ACC2-1
Affected article / annex:
Annex III
Theme(s):
Production Facilities
Subject: Observations on the current Production Facilities Theme and its relation to the EU Registry of Industrial Facilities
Observations / problem description:
The EU Registry data flow took, as a basis, the INSPIRE data model developed for Production Facilities. This was a significant effort.
Given the implementation stage of the data flow, we consider beneficial ensuring stability in the medium term. We discourage changes in the rules or in the data model unless they are backwards compatible.
Changes aligning definitions to pre-existing definitions in the EU law would be welcome.
E.g.
definition of ProductionFacility should be aligned with the E-PRTR Regulation
definition of ProductionInstallations should be aligned with the Industrial emission Directive
definition of ProductionInstallationParts should be wide enough to be used for various “entities”, including waste incineration plants and large combustion plants, both defined in the Industrial Emission Directive
If any discussion take place on this matter, we consider necessary our involvement in the relevant community as we already have implemented an extension of the model that works at EU level.
We support the 4 issues considered on focus for the revision of the IR, as main areas of improvement, being the “flattening” the one more relevant for our cases. This would have simplified the modelling exercise. Although the EU Registry data flow would not benefit from the change immediately, we see the relevance of such a change for other cases or future updates.
We would also call for a general cleaning of redundancies/typos/inconsistencies across the various data models – again only if backwards compatible.
Proposed legislative change(s):
(including precise reference, current text and proposed amendment):
See above
Rationale for change(s):
(including concrete implementation evidence)
Expected impacts (including benefits):
TC facilitator evaluation:
TC link(s):
2.4.2eReporting
Title
4 - eReporting
Description
Data under other environment legislation with respect to reporting often is data underneath INSPIRE annex III environmental themes with a direct or indirect reference to a specific location or geographical area and therefore part of the core of INSPIRE relevant for reuse.
Most data providers, only want to support one information model for data harmonization, one data format and one information stream to fulfil European environmental legislation. This position is shared by the Dutch National Contact Point for INSPIRE
Impact
If INSPIRE data specifications and specifications for data harmonisation made under other environment legislation with respect to reporting are not or partially consistent, the rules made under other environment legislation with respect to reporting prevails although this is not a legal choice at this time.
In this situation INSPIRE interoperability and harmonisation of data according annex III will not be reached.
Recommendations
Make spatial data under other environment legislation with respect to reporting in one step by each theme consistent with INSPIRE so it could be used as the information model supporting both INSPIRE and the reporting obligations.
Improvements on data with not a direct or indirect reference to a location or geographical area, could be considered at a later stage.
TC facilitator evaluation:
Miroslaw: OK, discussed during the cluster meeting @ the INSPIRE Conference
Kathi: just have to be careful that we don’t get mandatory concepts in from reporting requirements (will not always be required). In a way related to the lack of optional attributes in INSPIRE, this would have made this process much easier!
Stefania: OK. See EU Registry example. http://cdrtest.eionet.europa.eu/help/ied_registry/documents/EU%20Registry_datamodel.pdf
One major problem is the semantic mismatch between the in principal legally defined definitions in reporting flows and the more “real world” objectrelated definitions in the INSPIRE implementing rules. The implementing rules define in chapter 8 of ANNEX IV Requirements for Spatial Data Themes Listed in Annex III to Directive 2007/2/EC. These are legally binding requirements for INSPIRE-Datasets for production and industrial facilities.
The legal definitions from the PRTR-Regulation 166/2006/EC and the IE-Directive 2010/75/EU are not harmonised with the definitions in regulation 1089/2010. The INSPIRE implementing-rules are not adjusted to the EU-registry model.
Proposed legislative change(s):
(including precise reference, current text and proposed amendment):
Annex I, chapter 8, no. 8.1.1.1 “ActivityComplex”
The definition should be harmonised with the point of view the experts on industrial emission take on it.
Annex IV, chapter 8, no. 8.2.1 “ProductionFacility”
The definition should be harmonised with the PRTR-Regulation 166/2006/EC
Annex IV, chapter 8, no. 8.2.2 “ProductionInstallation”
The definition should be harmonised with the PRTR-Regulation 166/2006/EC and the Industrial Emission Directive 2010/75/EU
Annex IV, chapter 8, no. 8.2.4 “ProductionSite”
The definition should be harmonised with the PRTR-Regulation 166/2006/EC
For adjusting to the data model of EU-registry and mismatching definitions in detail take a look at the attachment
Rationale for change(s):
(including concrete implementation evidence)
The semantic mismatch is especially obvious with the Production Installation. As a consequence of the mismatch two compilations and subsequent maintenance of two different data sets on similar objects with identical object-names but different semantics might be required. This should be clearly avoided.
We would propose to ensure that the harmonised reporting data sets under IED, PRTR, LCP are also the canonical European data definitions/sets for industrial installations under the INSPIRE-Directive.
We propose to draft the relevant amendments adjusting the INSPIRE implementing rules to the EU registry model.
Expected impacts (including benefits):
TC facilitator evaluation: Things have changed since this change request was made.
The current EU registry data model is an example of how INSPIRE concepts can be reused in the context of the EU Registry reporting obligation.
The EU Registry data model extends the INSPIRE Production and Industrial Facilities core model in accordance to the extension rules set out in the Annex F of the INSPIRE Generic Conceptual Model, i.e. it does not change anything in the INSPIRE PF Data Specification but normatively references it with all its requirements.
More specifically, the EU Registry application schema imports INSPIRE PF schema, adding new types and new constraints and extending INSPIRE code lists to cater for the specific requirements stemming from the Industrial Emissions legislation. The EU Registry will collect identification and administrative data on European Pollutant Release and Transfer Register Regulation (E-PRTR) facilities, installations under the scope of the Industrial Emissions Directive (IED), large combustion plants (LCPs) and waste incineration and co-incineration plants (WI).
At the same time, the EU Registry will be the reference dataset for the relevant integrated thematic reporting on Industrial emission. The data on pollutant releases and transfers will refer to entities reported to the EU Registry by means of unique identifiers, avoiding duplication of information.
Providing industrial emission reporting according to an INSPIRE extended schema empowers the Member States to streamline their efforts to fulfil both INSPIRE and e-reporting obligations, since investments in implementing the EU Registry are building on their INSPIRE compliance.
