Criteria for limits on the emission of dust from cement kilns that burn waste as fuel

This note performs a cost-benefit analysis of proposed limit values for the emission of dust from cement kilns that use waste as fuel (currently under discussion between the European Council and the European Parliament as part of the new Directive to regulate the emissions by facilities that incinerate waste). The estimation of benefits is based on the most recent results of the ExternE Project of the European Commission, taking into account the typical sites where cement kilns are located. The benefits are found to be significantly lower than the costs. The conclusion that the proposed limit values are not justified by a net benefit is robust even in view of the uncertainties. A cost-effectiveness criterion does not provide a justification either.