Originally posted by HershOstropoler
And all I said is that BAT is overall better than a technology mandated by statute. I know that you disagree with me as a matter of principle, but saying that BAT is flexible and does not always lead to perfect results is kicking in an open door.
"I'm unfamiliar with regs that have an economic spec written in. Certainly not one that is numeric."
Of course it's not numeric. Yet BAT usually includes an economic element. Where I'm currently working, IPPC law, the definitiion is technologies "developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and advantages, (...), as long as they are reasonably accessible to the operator."
"In the end, best available comes down to judegement calls and you get "clarification memos" and such"
Of course you need guidelines or even secondary legislation to get that broad fluffy outline applicable.
"It's not awful. But not perfect."
And what's perfect?
"But then some really rich competitor decides to buy it. And before you know it, it is GMP. And you are doing it to."
You always have early adoptors. Doesn't change the standard.
And all I said is that BAT is overall better than a technology mandated by statute. I know that you disagree with me as a matter of principle, but saying that BAT is flexible and does not always lead to perfect results is kicking in an open door.
"I'm unfamiliar with regs that have an economic spec written in. Certainly not one that is numeric."
Of course it's not numeric. Yet BAT usually includes an economic element. Where I'm currently working, IPPC law, the definitiion is technologies "developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and advantages, (...), as long as they are reasonably accessible to the operator."
"In the end, best available comes down to judegement calls and you get "clarification memos" and such"
Of course you need guidelines or even secondary legislation to get that broad fluffy outline applicable.
"It's not awful. But not perfect."
And what's perfect?
"But then some really rich competitor decides to buy it. And before you know it, it is GMP. And you are doing it to."
You always have early adoptors. Doesn't change the standard.
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