1

[Draft]/[Final] Review Report 2018

Second phase of review of national air pollution emission inventory data

pursuant to the Directive on National Emissions Ceilings for certain Atmospheric Pollutants (Directive (EU) 2016/2284 or

‘NECD’)

MM

[DD-MM 2018]

Reference: 070203/2018/765105/SER/ENV.C.3

Umweltbundesamt GmbH

Spittelauer Lände 5

1090 Vienna

Austria

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Author Sabine Schindlbacher, Katarina Mareckova, Chris Dore, Emma Salisbury

Date 15/03/2018

Version Control V 1.2 – 2nd draft

Project deadlines First Draft by 02 March, Draft for MS 15 March, Finalisation by 30th April

Note:

Yellow and green highlighted text indicate optional text/example text

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Contents

I. Introduction ....................................................................................................................................... 5

II. Objectives of the review .................................................................................................................... 5

III. Review approach, team and scope ................................................................................................ 6

IV. Findings and Conclusions from the Technical Expert Review Team (TERT) for the follow-up to

the 2017 in-depth EU review ..................................................................................................................... 9

V. Findings and Conclusions from the Technical Expert Review Team (TERT) for the first phase of the

in-depth review of national emission inventories of POPs and heavy metals ........................................ 12

a. Cross cutting recommendations on HMs and POPs ........................................................................ 13

VI. Effect of revised estimates, technical corrections and adjustments recommended to be

approved on the national total and national total for compliance ......................................................... 13

VII. Findings and Conclusions from the Technical Expert Review Team (TERT) for the Review of

adjustment applications .......................................................................................................................... 16

VIII. Statement from MS on the conclusions presented by the TERT ................................................. 16

[ANNEX I Technical corrections deemed necessary by the TERT and revised estimates provided by MS

................................................................................................................................................................. 17

[ANNEX II Review of the 2017 adjustment application of MS TERT report for the EC ........................... 20

1 Introduction ................................................................................................................................. 20

1 Review of Adjustments approved prior to 2018 .......................................................................... 21

2 Review of New Adjustments Submitted in 2018 ......................................................................... 22

a) Assessment of Formal Criteria ................................................................................................. 22

3 Manure Management 3B (NOx and NMVOC), Agricultural Soils 3D (NOx, NMVOC) ................... 24

b) Assessment of Consistency with Requirements of EB Decision 2012/3 as amended by EB

Decision 2014/1 ............................................................................................................................... 24

c) Assessment of the Quantification of the Impact of the Revision ............................................ 24

4 Transport sector 1A3bi-iii (NOx ) ................................................................................................. 25

5 Conclusions and Recommendations of TERT concerning adjustment applications .................... 25

Information Provided by MS ................................................................................................................ 27

References and Supporting Documents .................................................................................................. 28

List of tables

Table 1: Scope of the comprehensive technical review NECD 2017 (under (EU) 2016/2284) .................. 8

Table 2: Recommendations from the NECD Review 2017, considering revised estimates (RE), technical

corrections (TC) ........................................................................................................................................ 11

Table 3: Recommendations from the NECD Review 2018 concerning the first phase of the in-depth

review of national emission inventories of POPs and heavy metals ....................................................... 13

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Table 4: National totals as reported and national totals including revised estimates (RE), technical

corrections (TC) and adjustments for NOx, NMVOC, SOx, NH3, PM2.5 ..................................................... 14

Table 5: Summary tables of Technical Corrections .................................................................................. 18

Table 6 Summary Information on the Submitted Adjustment Application, MS 2018 ............................. 20

Table 7 Expert Review Team(Adjustment approved prior to 2018) ........................................................ 22

55. Table 8 Expert Review Team ........................................................................................................ 23

Table 9 MS’s NOx and NMVOC Adjustment Applications for Agriculture, 2010-2016 ............................ 24

Table 10 Recommendations from the TERT to the Commission , MS 2018 (new and adjustments

approved prior 2017) ............................................................................................................................... 25

Table 11: Information Provided by MS .................................................................................................... 27

Abbreviations

EC European Commission

EEA European Environment Agency

EMRT Emission Review Tool

EU European Union

HMs Heavy Metals

kt Kilotonnes

MS Member State

NECD National Emissions Ceilings Directive

NFR Nomenclature for Reporting

NH3 Ammonia

NMVOC Non-methane volatile organic compounds

NOX Nitrogen oxides

PM2.5 Particulate matter equal to or less than 2.5 micrometres in diameter

POPs Persistent Organic Pollutants

RE Revised estimate

SO2 Sulphur dioxide

SOX Sulphur oxides

TC Technical correction

TERT Technical Expert Review Team

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I. Introduction

1. The review of the air pollution emission data submitted by Member States (MS) under the

European Union’s National Emissions Ceilings Directive (Directive (EU) 2016/2284) is defined in

Article 10(3):

"The Commission, assisted by the European Environment Agency and in consultation with the Member

States concerned, shall review the national emission inventory data in the first year of reporting and

regularly thereafter. That review shall involve the following:

(a) checks to verify the transparency, accuracy, consistency, comparability and completeness of

information submitted;

(b) checks to identify cases where inventory data is prepared in a manner which is inconsistent with

the requirements set out under international law, in particular under the LRTAP Convention;

(c) where appropriate, calculation of the resulting technical corrections necessary, in consultation

with the Member State concerned.

Where the Member State concerned and the Commission are unable to reach an agreement on the

necessity or on the content of the technical corrections pursuant to point (c), the Commission shall

adopt a decision laying down the technical corrections to be applied by the Member State

concerned.”

2. The second phase of the technical review of NECD inventories was undertaken in

accordance with the EU Air emission inventory review guidelines under Service contract No.

070203/2017/765105/SER/ENV.C.3 (EU 2018).

3. The technical review assessed the implementation of all recommendations, potential

technical corrections and revised estimates from the NECD Review 2017. The Review Reports

from the year 20171 were the base for this assessment. In addition an in-depth review of the

national emission inventories of the POPs and heavy metals was initiated and in accordance with

the requirements of the NECD (Article 5(8)), all new adjustment applications submitted in 2018

were reviewed in-depth and all adjustment applications submitted in 2018, that were already

submitted, reviewed and accepted in 2017 were reviewed with a focus on reviewing the

consistency in the reporting of these adjustment applications: For the review of the adjustment

applications the Technical Guidance for Parties Making Adjustment Applications and for the

Expert Review of Adjustment Applications (ECE/EB.Air/130)2 was used.

II. Objectives of the review

4. The general objective of the second phase of the technical review of MS’ NECD inventories

as reported in February 2018 (and updated before DD MM YYYY) was an improvement of

transparency, consistency, comparability, completeness and accuracy of submitted data and as

such will contribute to establishing accurate, reliable and verified emission inventories for all MS.

5. The specific objectives of the second phase of the technical review of Member States’

NECD inventories were:

1 available at http://ec.europa.eu/environment/air/reduction/implementation.htm

2http://www.ceip.at/fileadmin/inhalte/emep/Adjustments/ECE_EB_AIR_130_AV_for_the_web.pdf

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a. a detailed review to verify that MS have effectively integrated the revised

estimates, technical corrections and other relevant recommendations from the

2017 in-depth EU review in their national emission inventories

i. a full in-depth review of national emission inventories, including the

calculation of technical corrections, for Greece and Finland as these MS

were not reviewed in-depth in 2017 due to the lack of reporting of the

necessary quantitative and qualitative data in 2017

b. initiation of an in-depth review of the national emission inventories of the POPs

and heavy metals for which the new NECD sets out mandatory reporting (see table

A of Annex I of Directive (EU) 2016/2284 ), i.e. polycyclic aromatic hydrocarbons

(PAHs), dioxins/furans, polychlorinated biphenyls (PCBs), hexachlorobenzene

(HCB), cadmium (Cd), mercury (Hg) and lead (Pb);

c. an expert review of

i. new adjustment applications submitted in 2018, not submitted and

reviewed yet in 2017 under the new NECD, including the review of the

supporting documentation as requested in part 4 of Annex IV of the new

NECD and an assessment of whether the adjustment application is

consistent with the circumstances described therein

ii. the adjustment applications submitted in 2018, that were already

submitted, reviewed and accepted in 2017 under the new NECD

(and/or previously under CLRTAP), with a focus on reviewing the

consistency in the reporting of these adjustment applications;

6. The review also sought to harmonise approaches used in monitoring inventories reported

under the NECD with reviews undertaken by other organisations that have similar interests such as

the reviews under the LRTAP Convention and the EU Greenhouse Gas Monitoring Mechanism

(MMR)/United Nations Framework Convention on Climate Change (UNFCCC)

III. Review approach, team and scope

7. For the Follow-up to the 2017 in-depth EU review the TERT performed a consistent and

detailed review to verify that all MS have effectively integrated the revised estimates, technical

corrections and other relevant recommendations from the 2017 in-depth EU review in their

national emission inventories of SO2, NOx, PM2.5, NMVOC and NH3.

For Greece and Finland that were not reviewed in-depth in 2017 due to the lack of reporting of the

necessary quantitative and qualitative data in 2017, an in-depth review of their national emission

inventories of SO2, NOx, PM2.5, NMVOC and NH3 was performed in accordance with the

requirements in the guidelines and guidance that were prepared for the 2017 in-depth EU review.

8. For the first phase of the in-depth review of national emission inventories of POPs and

heavy metals the TERT focused on the completeness and consistency in the emission reporting of

PAHs, dioxins/furans, PCBs, HCB, Cd, Hg and Pb with special emphasis on the review of identified

key categories.

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9. The results of this first phase of the in-depth review were general and sector specific

recommendations for quick and obvious improvements of MS' POPs and heavy metals inventories

and did not include proposals for technical corrections or revised estimates. Focus was on the

years 1990 (most common reference year used for compliance with basic reduction obligations

under the POPs and heavy metals protocols), on 2005 and 2016. However, the consistency of

time series data was also checked for all reported years.

10. Review of adjustment applications: New adjustment applications submitted in 2018 were

reviewed in depth. Adjustment applications submitted in 2018, that were already submitted,

reviewed and accepted in 2017 under the new NECD (and/or previously under CLRTAP) were

reviewed with a focus on consistency in the reporting of these adjustment. The review of

adjustment applications followed the Review Guidance. The review was performed by relevant

sector experts reviewing particular sectors and coordinated by adjustment lead reviewer.

11. The review was split in two phases:

a) Initial checks were carried out (by the project team) under service contract No.

70203/2017/765105/SER/ENV.C.3 and by the EU inventory team (ETC/ACM). Significant

findings from the initial checks that were relevant for the second phase of the technical review

and that were not resolved within the initial check phase were followed up by the TERT in the

comprehensive desk and centralised review.

b) A Desk Review and Centralised Review was performed by the TERT under service contract No

70203/2017/765105/SER/ENV.C.3 of the Directorate General Environment of the European

Commission. The TERT consisted of the following experts:

Lead Reviewers: Justin Goodwin, Kevin Hausmann, Ole-Kenneth Nielsen and Kristina Saarinen

Energy: Rianne Dröge, Stephan Poupa, Laetitia Serveau and Glen Thistlethwaite

Transport: Jean Marc André, Giorgos Mellios, Tim Murrells and Giannis Papadimitriu

IPPU: Jeroen Kuenen, Ardi Link, Ils Moorkens and Frank Sleeuweart

Agriculture: Michael Anderl, Bernard Hyde, Mette Mikkelsen and Beatriz Sánchez

Waste: Céline Gueguen and Garmt Jans Venhuis.

12. The Desk Review and Centralised Review were coordinated by the project team (Sabine

Schindlbacher, Katarina Mareckova, Chris Dore and Emma Salisbury).

13. The EEA Review Secretariat consisting of Federico Antognazza and Anke Lükewille

supported the second phase of the technical review of MS’ NECD inventories.

14. The review was performed on the basis of NECD emission data officially reported by MS by

15 February 2018 and the Informative Inventory Reports (IIRs) reported by 15 March 2018 under

the revised NEC Directive. Resubmissions and other additional information provided by MS during

the review were taken into account until DD MM 2018.

15. To avoid any potential conflicts of interest, the lead reviewers and sector review experts

did not review emission inventories of MS where these individuals have themselves contributed to

the compilation of that inventory, or presently are or have been any part of the decision-making

process related to the compilation of that inventory. Reviewers who are nationals of the MS whose

inventory is concerned, did not take part in the review of that inventory.

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16. All review experts signed confidentiality agreements in which they agreed to keep

information received by MS confidential.

Table 1: Scope of the comprehensive technical review NECD 2017 (under (EU) 2016/22843)

Element Scope Further information

Member States EU geographical coverage of the MS

This Directive shall apply to emissions of the pollutants referred to in Annex I from all sources occurring in the territory of the MS, their exclusive economic zones and pollution control zones. This Directive does not cover emissions in the Canary Islands, the French overseas departments, Madeira, and the Azores.

Years 1990,2005 and 2016 for HMs and POPs)

In addition, time series consistency was reviewed across the whole time series.

Pollutants

Issues raised in 2017 review for NOx, NMVOC, SOx, NH3, PM2.5

and

New review for PAHs, dioxins/furans, PCBs, HCB, Cd,Hg and Pb

According to NECD Article 1(1)

Categories

All NFR categories, including selected memo items

All NFR categories as listed in Annex 1 of reporting guidelines Including the following memo items: 1A3ai(ii) International aviation cruise (civil) 1A3aii(ii) Domestic aviation cruise (civil) 1A3di(i) International maritime navigation 1A3 Transport (fuel used) – where a MS uses fuel used for compliance purposes.

National totals

National total and National total for compliance

Rows 141 and 144 in Annex I to reporting Guidelines

3 DIRECTIVE (EU) 2016/2284 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 14 December 2016 on the reduction of national emissions of certain atmospheric pollutants, amending Directive 2003/35/EC and repealing Directive 2001/81/EC

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IV. Findings and Conclusions from the Technical Expert Review

Team (TERT) for the follow-up to the 2017 in-depth EU

review

17. The TERT assessed the implementation of all recommendations, technical corrections and

revised estimates from the NECD Review 2017. This assessment was based on the inventory data

submitted under the NEC Directive in 2018 by MS pursuant to (Directive (EU) 2016/2284) and the

MS Review Report from the year 2017.

18. MS [provided]/[did not provide] to the Commission a resubmission on DD MM 2018. [The

TERT considered [could not consider] this resubmission as the basis for the review.]

19. Table 2 summarizes the conclusions of the TERT as to whether the recommendations

[revised estimates] [and technical corrections] from the NECD Review 2017 were implemented.

a. Recommendations: [The TERT noted [with content] that MS has implemented

[all]/[most]/[only a few] of the recommendations]. [The TERT recommends to

implement all remaining recommendations until the next submission and flags that

this is the second year in which these recommendations have been made.]

b. [Potential technical corrections and revised estimates: MS implemented

[all]/[most]/[only a few] of the [potential technical corrections and] [revised

estimates] from the NECD Review 2017.] [Those potential technical corrections and

revised estimates not implemented have been passed to the Commission which, in

accordance with Article 10.3 last subparagraph of Directive 2016/2284, may adopt a

decision laying down the technical corrections to be applied.] The TERT [agreed]/[did

not agree] with the recalculation in response to {number}/[all] [potential technical

corrections] [and revised estimates.] [The TERT asked MS to provide [a] revised

revised estimate.][MS [provided]/[did not provide] a revised revised estimate.] [The

TERT agrees with this revised revised estimate and recommends including it in the

next submission]. [The TERT [did not agree with this revised estimate and] provided a

potential technical correction.]. [The technical correction exceed[s] the threshold of

significance (2%) for at least one year of the inventory under review (but not

necessarily all the years of the time series)]. [The technical correction has been passed

to the Commission which, in accordance with Article 10.3 last subparagraph of

Directive 2016/2284, may adopt a decision laying down the technical corrections to be

applied.]

20. [The TERT noted [with content] that [all]/[most]/[only a few] of the recommendations

related to the use of the Guidebook versions prior to the 2016 version were implemented. [The

TERT assessed for all recommendations related to the use of the Guidebook versions prior to the

2016 version that concerned key categories if this recommendation would be above the

threshold of significance for a potential technical correction and identified {number} cases for

potential technical corrections for MS.] [In response to this analysis MS provided {number}

revised estimates.] [The TERT agreed with the revised estimates provided by MS.][The TERT

calculated [a]/{number} potential technical correction[s]]. [The technical correction[s] exceed[s]

the threshold of significance (2%) for at least one year of the inventory under review (but not

necessarily all the years of the time series)]. For those other recommendations in this category

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which have not been implemented, the TERT flags that this is the second year in which these

recommendations have been made.

21. The TERT considers that it received responses from MS that were sufficient in order to

undertake the follow-up to the 2017 in-depth EU review.

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Table 2: Recommendations from the NECD Review 2017, considering revised estimates (RE), technical corrections (TC)

Observation Key Category

NFR, Pollutant(s), Year(s)

Recommendation RE or TC in 2017

Imple-mented

RE or TC in 2018

Tier 1 used for a key category

Issue related to use of GB prior to the 2016 version

AT-1A1-2017-0002

No 1A1 Energy Production, SO2, NOX, NH3, NMVOC, PM2.5, 2000-2015

yes no yes no yes

AT-1A1-2017-0003

Yes 1A1 Energy Production, SO2, NOX, PM2.5, 2005-2015

no yes no no no

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22. [Greece and Finland receive an additional Review Report following the structure of the

Review Reports prepared in 2017 with the results from the in-depth review 2018.]

V. Findings and Conclusions from the Technical Expert Review

Team (TERT) for the first phase of the in-depth review of

national emission inventories of POPs and heavy metals

23. The TERT checked the national inventory data submitted under NEC Directive submitted in

2018 by MS pursuant to (Directive (EU) 2016/2284).

24. MS [provided]/[did not provide] to the Commission a resubmission on DD MM 2018. [The

TERT considered this resubmission as the basis for the comprehensive review.]

25. The TERT carried out checks to verify the transparency, accuracy, consistency,

comparability and completeness of the HMs and POPs inventory. The focus was on the years 1990,

2005, and 2016

26. The TERT considers that it received responses from MS that were sufficient in order to

undertake the first phase of the in-depth review of national emission inventories of POPs and

heavy metals appropriately.

27. Transparency and Consistency: [The TERT found the submitted inventory to be sufficiently

detailed and documented.] /[The information in the IIR was not sufficient but MS provided

explanatory information on request.]/[The explanatory information provided by MS was not

sufficient for the following sectors /{list sectors} which could not be reviewed in detail./[The TERT

identified inconsistencies across data reported in the Annex I emission reporting template and the

IIR.]

28. Completeness: [The TERT identified [no]/[one]/[several] cases where no emission estimate

were provided though methods are provided in the EMEP/EEA Guidebook.]

29. The TERT noted that Tier 2 methods [are] /[are] [in general] [not]used for key categories.

[Instances where a Tier 1 method was used for a key category are flagged in Table 3.

30. Notation keys: The TERT noted that for the reporting of HMs and POPs the use of the

notation keys is [generally] [consistent]/[not consistent] with the Reporting Guidelines.

31. The TERT noted that the submitted HMs and POPs inventory [is]/[is in general not]

compiled in line with the EMEP/EEA emission inventory guidebook 2016 [and Directive (EU)

2016/2284]/[The TERT noted that the submitted HMs and POPs inventory is only partly in line with

Directive (EU) 2016/2284 regarding [the emissions in sector {xxx} /[the geographical coverage]/

[xxx]

32. The TERT noted that for HMs and POPs reported national total for compliance (row 144)

[differs]/[does not differ] from national total (row 141) [and is]/[is not] reported in line with NEC

Directive.

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33. The TERT noted that MS [reported]/[has not reported] transport emissions based on fuel

sold and [has]/[has not] additionally reported transport emission based on fuel used. This [is]/[is

not] in line with the reporting guidelines. The reporting of emissions based on fuel sold is

mandatory.

34. The TERT identified recommendations in order to improve the national HMs and POPs inventory

data of MS (see Table 3).

Table 3: Recommendations from the NECD Review 2018 concerning the first phase of the in-depth review of national emission inventories of POPs and heavy metals

Observation Key Category

NFR, Pollutant(s), Year(s)

Recommendation Tier 1 used for a key category

Issue related to use of GB prior to the 2016 version

AT-1A1-2017-0002

No no

Cross cutting recommendations on HMs and POPs

35. The TERT identified the following cross-cutting issues for improvement in the inventory and

recommends to MS :

(a) [to complete its emission inventory with estimating currently missing emissions;]

(b) [to use the notation key “NE” where emissions are expected to occur but are not

estimated;] / [that the MS corrects the use of notation keys according to the

definitions in the Reporting Guidelines]

(c) [calculate all emission for which methods are provided in the EMEP/EEA Guidebook]

(d) [to use the EMEP/EEA Guidebook 2016 for all categories]

(e) [improve transparency of the inventory by improving the IIR]

VI. Effect of revised estimates, technical corrections and

adjustments recommended to be approved on the national

total and national total for compliance

36. The table below shows differences between submitted inventories in Annex 1 table, rows

141 and 144 and revised national totals after accounting revised estimates, technical corrections

and adjustments recommended to be approved. The table shows the direct changes in response to

the NECD Review 2018. As no revised estimates and technical corrections were calculated for HMs

and POPs the table only shows the main pollutants.

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Table 4: National totals as reported and national totals including revised estimates (RE), technical corrections (TC) and adjustments for NOx, NMVOC, SOx, NH3, PM2.5

4

Description Reference Pollutant estimates (kt)

2005 2010 2016

NOx

National total (row 141) Annex I, xx/xx/2017 12.512 10.323 14.545

Total (row 144)

Difference between original estimate and revised estimates provided by MS and accepted by the TERT

2.A Mineral processes AT-2A-2017-0001 1.221 1.212 1.2483

2.C Chemical processes AT-2C-2017-0002 0.200 0.200 0.200

Difference between original estimate and technical correction deemed necessary by the TERT

1.A.2 Industrial combustion AT-1A2-2017-0003 0.100 0.020 0.120

Adjustment provided by the MS and recommended to be accepted by the TERT

1.A.3.b Road Transport Adjustment AT-2 -2.355 -3.478 -5.544

National total (row 141) including revised estimates and technical corrections accepted by MS

Calculated using data above

14.033 11.755 16.113

Total (row 144) estimate including revised estimates, technical corrections accepted by MS and adjustments recommended (by TERT) to be accepted by EC

11.678 8.277 10.5693

SOx

National total (row 141) Annex I, xx/xx/2017 12.512 10.323 14.545

Total (row 144)

Difference between original estimate and revised estimates provided by MS and accepted by the TERT

2.A Mineral processes AT-2A-2017-0005 1.221 1.212 1.2483

2.C Chemical processes AT-2C-2017-0003 0.200 0.200 0.200

Difference between original estimate and technical correction deemed necessary by the TERT

1.A.2 Industrial combustion AT-1A2-2017-0007 0.100 0.020 0.120

Adjustment provided by the MS and recommended to be accepted by the TERT

NA NA NA NA NA

National total (row 141) including revised estimates and technical corrections accepted by MS

Calculated using data above

14.033 11.755 16.113

Total (row 144) estimate including revised estimates, technical corrections accepted by MS and adjustments recommended (by TERT) to be accepted by EC

NMVOC

4 The tables presented in this report show numbers rounded to three decimal places, although most numbers are available with greater precision. For all calculations, all available decimal places were used. Therefore, the totals shown may slightly differ from calculation results where only three decimals would be taken into account.

15

Description Reference Pollutant estimates (kt)

2005 2010 2016

National total (row 141) Annex I, xx/xx/2017 12.512 10.323 14.545

Total row (144)

Difference between original estimate and revised estimates provided by MS and accepted by the TERT

2.A Mineral processes AT-2A-2017-0005 1.221 1.212 1.2483

2.C Chemical processes AT-2C-2017-0003 0.200 0.200 0.200

Difference between original estimate and technical correction deemed necessary by the TERT

1.A.2 Industrial combustion AT-1A2-2017-0007 0.100 0.020 0.120

Adjustment provided by the MS and recommended to be accepted by the TERT

1.A.3.b Road Transport Adjustment AT-1 -2.355 -3.478 -5.544

National total (row 141) including revised estimates and technical corrections accepted by MS

Calculated using data above

14.033 11.75

5 16.113

Total (row 144) estimate including revised estimates, technical corrections accepted by MS and adjustments recommended (by TERT) to be accepted by EC

11.678 8.277 10.5693

VII. Statement from MS on the conclusions presented by the

TERT

37. MS agrees with the calculated estimates in Table 4. [MS [agrees]/[does not agree] that [a

technical correction is]/[{x} technical corrections are] necessary, as deemed by the TERT. [MS

[agrees]/[does not agree] with the calculated estimates for the technical correction[s] deemed

necessary by the TERT, presented in Table 5.]

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VIII. Findings and Conclusions from the Technical Expert Review

Team (TERT) for the Review of adjustment applications

38. MS [did]/[did not] submit in 2018 {x} adjustment application[s] undergoing review under

this contract [(see Statement from MS on the conclusions presented by the TERT)]

39. [The TERT concluded that the application[s] [do meet]/[do not meet] all of the

requirements laid out in Decision 2012/12 of the Executive Body of the CLRTAP, and therefore

recommends that the European Commission [ACCEPT]/[REJECT] [this]/[these] adjustment

application[s]. Details on the Review of Adjustment Applications are given in Annex 2.

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[ANNEX I Technical corrections deemed necessary by the TERT and

revised estimates provided by MS

40. The TERT calculated technical corrections for cases

a. where it did not agree with the way that a revised estimate or technical correction

form the NECD review 2017 was implemented and where no revised revised

estimate was provided by MS during the review

b. and in cases where a recommendation related to the use of Guidebook versions

prior to the 2016 version was not implemented and concerned a key category and

where no revised estimate was provided by MS during the review

41. The methods for calculating the technical corrections are set up in the “Guidance on

technical corrections” and are based on the basic adjustment methods referred in the revised

UNECE Reporting Guidelines and UNFCCC Adjustment guidance5 and use the EMEP/EEA

Inventory guidebook as a reference for methods and emission factors.

5 Technical guidance on methodologies for adjustments under Article 5, paragraph 2, of the Kyoto Protocol

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Table 5: Summary tables of Technical Corrections

[example that will be replaced, one table per TC per NFR category/pollutant to be included]

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EMRT-NECD ID: MS-2B2-2018-0001

EMRT-NECD URL: https://emrt.eea.europa.eu/2017/MS-2B2-2017-0001

Member State: Austria

Sector: 2B2 Nitric acid production

Gases: NH3

Completed by (SE): Chris Dore

Reviewed by (LR):

Reviewed by (Counterpart):

The underlying problem:

The country specific EF for emissions from the 2B2 Nitric Acid production is approximately 100 times lower than the default EF (Chapter 2B2, 2016 Guidebook). The MS explained that this calculation is based on point source reporting, but that the data received is considered to be unrepresentative of the situation across the whole sector, giving rise to an underestimate, and that it is more appropriate to use the Guidebook default value until improved data can be obtained.

The rationale for the corrected estimate:

Underestimation of NH3 emission from 2B2 Nitric Acid Production.

Summarise the methodology used:

Use of the 2016GB default EF instead of country specific data (which is considered to be unrepresentative).

2

Details of the corrected estimate

Original estimate (Gg) Notes

Year NOx SO2 NMVOC NH3 PM2.5

MS-2B2-2017-0001-OE 2005 2.924028

MS-2B2-2017-0001-OE 2010 3.315968

MS-2B2-2017-0001-OE 2016 3.114274

Was a Revised Estimate received from the MS? yes

Revised Estimate received from MS (Gg) Notes

Year NOx SO2 NMVOC NH3 PM2.5

MS-2B2-2017-0001-RE 2005 2.924

MS-2B2-2017-0001-RE 2010 3.6

MS-2B2-2017-0001-RE 2016 3.6

Was the Revised Estimate accepted by the TERT? yes

Technical Correction calculated by TERT (Gg) Notes

Year NOx SO2 NMVOC NH3 PM2.5

MS-2B2-2017-0001-TC 2005

MS-2B2-2017-0001-TC 2010

MS-2B2-2017-0001-TC 2016

Was the Technical Correction accepted by the MS? no

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[ANNEX II Review of the 2017 adjustment application of MS

TERT report for the EC]

Table 6 Summary Information on the Submitted Adjustment Application, MS 2018

Reasons for adjustment application (Decision 2012/3, para 6 as amended by decision 2014/1, annex, para 3)

Agriculture, 3B, 3D: New sources

Transport 1A3bi-iii ; revised EFs

Pollutant/sector for which adjustment is applied for NOx, NMVOC

Year(s) for which inventory adjustment is applied 2010 - 2016

Date of notification of adjustment to the Secretariat

15 February 2016

Date of submission of supporting documentation 15 March 2018[, resubmission 15th April]

1 Introduction

42. Article 5.8 of the NECD text (Directive (EU) 2016/2284) explains that “The Commission,

when exercising its powers under paragraphs 6 and 7 (reviewing the use of flexibilities), shall take

into account the relevant guidance documents developed under the LRTAP Convention.” Article 8.4

and Part 4 of Annex IV of the NECD text further specify that MS that opt for the adjustment

flexibility must include supporting information in the Informative Inventory Report, including a

demonstration that the use of the adjustment procedure fulfils the relevant conditions set out in

Article 5.1 and Part 4 of Annex IV. The minimum supporting information required is highlighted in

Part 4.1 of Annex IV (which is based on Part 1, paragraph 2 of the Annex to LRTAP Executive Body

Decision 2012/12). In the chapeau of Annex IV it is further specified that adjusted emission

inventories should be prepared using the EMEP reporting guidelines (which in its turn contains

references to the relevant EB decisions 2012/3 and 2012/12, as amended in 2014/1), while also

adding that reliance upon these EMEP reporting guidelines is without prejudice to the additional

arrangements specified in Part 4 of Annex IV. Consequently, the review of Adjustment applications

under the NECD will in principle follow the process for reviewing Adjustment applications made

under the CLRTAP (as presented in relevant EB decisions), however (formally) without prejudice to

the additional arrangements specified in Part 4 of Annex IV of the new NECD.6 It allows inter alia

the submission of additional information during the review, necessary for a proper and full

assessment of the adjustment application.

43. MS may apply to adjust their inventory data or emission reduction commitments if they are

in non-compliance with their emission ceilings established in NEC Directive 2001/81/EC (in

accordance with article 21(2) of new NECD). If a MS applies for more than one adjustment and not

all these adjustments are required to bring that MS into compliance, that MS should be informed

that in accordance with the intent of the adjustment procedure, recommendation for approval will

6 See the following overview and guidance documentation: ECE/EB.AIR/111/Add.1, ECE/EB.AIR/113/Add.1, ECE/AB.AIR/127/Add.1 and ECE/EB.AIR/130).

21

be limited to adjustments necessary to bring compliance and be invited to withdraw one or more

of its adjustments. In making an adjustment application, MS must demonstrate that extraordinary

circumstances have given rise to revisions to their emissions estimates. These extraordinary

circumstances fall into three broad categories:

a) Emission source categories are identified that were not accounted for at the time when the

emission reduction commitments were set; or

b) For a particular source, the emission factors used to estimate emissions for the year in

which emissions reduction commitments are to be attained are significantly different to those used

when the emission reduction commitments were set; or

c) The methodologies used for determining emissions from specific source categories have

undergone significant changes between the time when emission reduction commitments were set

and the year they are to be attained.

Technical corrections and revised estimates may change the national emission totals making a

specific adjustment no longer necessary or make a specific adjustment incompatible/invalid when

applied to the same category for which a technical correction or revised estimate was approved.

Adjustment applications that are affected by technical corrections or revised estimates should also

be reviewed in these cases, but any recommendation on the review of concerned adjustment

applications should be subject to the outcome of the work on technical corrections and revised

estimates. The review of an adjustment application can recommend acceptance or rejection. In the

case of a rejection, the recommendation may be accompanied by information explaining that the

principle of the adjustment is considered appropriate but that the quantification has not been

determined correctly, or it has not been possible to adequately assess the quantification in the

time available for the review. Consequently, it may appropriate for MS to consider resubmitting

selected rejected applications at a future date.

44. Any MS submitting an application for an adjustment to its inventory is required to notify

the European Commission by 15 February at the latest. As explained above the supporting

information must be included in the Informative Inventory Report (by 15 March of the same year)

including a demonstration that the use of the adjustment procedure fulfils the relevant conditions

set out in Article 5.1 and Part 4 of Annex IV. The minimum supporting information required is

specified in Part 4.1 of Annex IV.

45. As mandated by the European Union’s National Emissions Ceilings Directive (Directive (EU)

2016/2284) applications for adjustments that are submitted by MS are subject to an expert review.

46. The reviewers undertake a detailed technical review of the adjustment application in

cooperation with EEA and make a recommendation to the European Commission on the

acceptance or rejection of the application. The European Commission then takes its decision on any

adjustment application based on the outcome of the technical assessment completed by the

reviewers considering also the effect of technical corrections and revised estimates.

1 Review of Adjustments approved prior to 2018

47. MS had the following adjustments granted prior to 2018: {name pollutant, sector, years –

for each adjustment}. MS included information on these adjustments in its submission under the

National Emissions Ceilings Directive (Directive (EU) 2016/2284) of DD/MM/2018 [and thus after

22

the legal deadline of 15 February], reporting sectoral level data in Annex VII to the reporting

guidelines and in line 143 of Annex I. Along with Annex VII, MS [submitted]/[did not submit] the

“Declaration on consistency” with a short summary of recalculations of these granted

adjustments. [No] [A]/[a]dditional documentation was provided during the review in response to

requests from the reviewers. [Table 11 lists the documentation provided by MS.]

48. [The reviewers noted that for the following adjustment {name pollutant, sector, years}, no

substantial recalculations have occurred and that all supporting information has been provided.

The reviewers therefore conclude that the adjustment should continue to be granted.]. [The

reviewers noted that for the applied adjustment in the sector {name pollutant, sector, years}

substantial recalculations have occurred. All supporting information has been provided. The

review of the recalculations and the supporting information showed that the method has not

been changed and thus the reviewers conclude that the adjustment should continue to be

granted.]. [The reviewers noted that for the applied adjustment in the sector { name pollutant,

sector, years} substantial recalculations have occurred. All supporting information has been

provided. The review of the recalculations and the supporting information showed that the

method has been changed and thus the reviewers conclude that the adjustment should not

continue to be granted, and that a new adjustment application, and hence detailed review, is

necessary.]

Table 7 Expert Review Team(Adjustment approved prior to 2018)

Role Sectors Name Country

Adjustment lead

reviewer All Chris Dore Project team

Primary expert

reviewer Agriculture 3B, 3D Mette H. Mikkelsen Denmark

Primary expert

reviewer Transport 1A3b xxxx

Basic checks

(Step 1 and 2) N/A Katarina Mareckova Project team

2 Review of New Adjustments Submitted in 2018

a) Assessment of Formal Criteria

49. MS notified the European Commission through the EIONET Central Data Repository (CDR)

partnership network of the EEA through the Executive Secretary of its intention to apply for a new

adjustment on DD/MM/2018 [and thus after the legal deadline of 15 February]. [Not] [A]/[a]ll

supporting information requested by Directive 2016/2284, Article 5.1, Article 8.4 and Annex IV,

Part 4 was provided [as part of the Informative Inventory Report]/[as separate report] [by the legal

23

deadline of the 15 March of the same year], [however MS resubmitted their IIR on the DDth MM.

][No] [A]/[a]dditional documentation was provided during the review in response to requests from

the reviewers. Table 11 lists the documentation provided by MS.

50. MS submitted an application for emissions adjustments to 2010-2016 for the pollutants

and sectors indicated below:

a. NOx, NMVOC – Agriculture 3B, 3D.

b. NOx – Transport 1A3bi-iii……

51. MS [provided]/[did not provide] information on exceedance of emission ceilings (DIRECTIVE

2001/81/EC) for {particular pollutant(s)} in {year(s)}.[]

52. MS [provided]/[did not provide] information on the impact of the adjustment to its

emission inventory, and the extent to which it would reduce the current exceedance and possibly

bring the Party in compliance with emission reduction commitments.

53. MS [included]/[did not include] information on when it will meet its emission ceilings for

{particular pollutant(s)}without the adjustment in the supporting documentation.

54. The adjustment application requires the provision of specific supporting information to

demonstrate compliance with specific criteria (Directive 2016/2284, Annex IV, Part 4.1(d), and EB

Decision 2012/3, para 6a-c as amended by EB Decision 2014/1, Annex, para 3). MS [provided]/[did

not provide] supporting documentation [and the reviewers have reviewed this information (see

Table 11) with regard to these criteria.] [The reviewers considered the supporting information

provided by MS to be complete.]

55. Table 8 Expert Review Team

Role Sectors Name Country

Adjustment lead

reviewer All Chris Dore Project team

Primary expert

reviewer Agriculture 3B, 3D Mette H. Mikkelsen Denmark

Secondary expert

reviewer Agriculture 3B, 3D J Webb United Kingdom

Primary expert

reviewer Transport 1A3b xxxx

Secondary expert

reviewer Transport 1A3b yyyy

Basic checks

(Step 1 and 2) N/A Katarina Mareckova Project team

24

b) Manure Management 3B (NOx and NMVOC), Agricultural Soils 3D (NOx, NMVOC)

Assessment of Consistency with Requirements of EB Decision 2012/3 as amended by EB

Decision 2014/1

56. MS made an application based on criteria: “a new source”.

57. The reviewers noted that no methodologies for the estimation of NOx and NMVOC

emissions from manure management (including manure application on land), and agricultural soils

were included in the EMEP/CORINAR Inventory Guidebook 1999 and conclude that the provided

supporting evidence does comply with the criteria presented in Decision 2012/3, and that the

circumstances on which the adjustment is based could not have been reasonably foreseen by the

Party when the emission ceilings were established for 2010.

58. The reviewers studied the documentation that was provided to support the application

(listed in Table 11).

59. The supporting information provided by MS [clearly presented]/[did not clearly present]

the adjustment totals, [but]/[and] the method of calculation was [not] transparent. [[However,]

[A/a]s the adjustment application is for a new source, the quantification is equal to the sectoral

emissions.]

Assessment of the Quantification of the Impact of the Revision

60. The adjustment application process requires that MS submits a quantification of the impact

of the adjustment for which an application has been submitted. Table 2 provides an overview of

the NOx adjustment applications of MS in the Agriculture sector.

Table 9 MS’s NOx and NMVOC Adjustment Applications for Agriculture, 2010-2016

Reference number

Pollutant NFR14 unit 2010 2011 2012 2013 2014 2015 2016

MS_3B_NOx NOx 3B kt -0.053 -0.050 -0.048 -0.051 -0.052

MS_3D_NOx NOx 3D kt -0.773 -0.828 -0.779 -0.794 -0.799

NOx Total kt -0.826 -0.877 -0.827 -0.845 -0.851

Reference number

Pollutant NFR14 unit 2010 2011 2012 2013 2014

MS_3B_NMVOC

NMVOC 3B kt -2.270 -2.210 -2.171 -2.239 -2.285

MS_3D_NMVOC

NMVOC 3D kt -0.113 -0.113 -0.113 -0.113 -0.112

NMVOC Total kt -2.383 -2.323 -2.284 -2.351 -2.397

61. The reviewers were not able to determine whether the quantification of the recalculations,

as calculated by MS, includes any calculation errors or is in line with the most up-to-date available

EMEP/EEA Inventory guidebook and scientific literature.

25

62. In the 201x submission, MS reported NOx and NMVOC emissions from manure

management category 3B and NMVOC emission from agricultural soils 3D for the first time. MS

explained that this improvement is based on the updated EMEP/EEA Guidebook (2013) which

provides new EFs for animal husbandry, manure management and agricultural soils. At the time

of setting the reduction commitments no valid methodology was provided by the 1999

Guidebook.

63. In its application for an adjustment MS indicated that its national totals of both NOx and

NMVOC emissions would be below their ceilings in accordance with the NECD from 2013

onwards, if the proposed adjustments are accepted, although the reviewers note that the

NMVOC emissions would be below the NECD ceilings from 2010 onwards.

64. The TERT concluded that increased emissions are based on new emission sources reported

by MS, and are not the result of new agricultural activities causing additional emissions in MS. The

reviewers is therefore of the opinion that this is a valid case for an adjustment.

c) Transport sector 1A3bi-iii (NOx )

Assessment of Consistency with Requirements of EB Decision 2012/3 as amended by EB

Decision 2014/1

….

Assessment of the Quantification of the Impact of the Revision

…..

3 Conclusions and Recommendations of TERT concerning adjustment applications

65. The reviewers have undertaken a full and thorough assessment of the application for an

adjustment of the NOx and NMVOC emissions inventory that was submitted by MS in 2018 for

Transport 1A3b and for Agriculture 3B and 3D and also adjustments approved prior 2018 for NOx

emissions from off road transport 1A3xx . .

66. The review of the submitted application followed the guidance provided in the Annex to

Decision 2012/12 of the Executive Body of the CLRTAP as amended by Technical Guidance

ECE/EB.AIR/130. The findings of the reviewers are described in detail in sections above of this

report.

67. Table 10 below provides a summary of the adjustment applications received from MS, and

the subsequent recommendations made by the reviewers to the European Commission.

Table 10 Recommendations from the TERT to the Commission , MS 2018 (new and adjustments approved prior 2017)

MS

Sector NFRs Pollutant Years reviewers

Recommendation

MS New 2018 Agriculture 3B, 3D NOx 2010- 2016 Accept/Reject

MS Approved Agriculture 3B, 3D NMVOC 2010- 2016 Accept/Reject

26

MS

Sector NFRs Pollutant Years reviewers

Recommendation

2017

MS Approved

2017 Transport 1A3b NOx

2010- 2016 Accept/Reject

27

4 Information Provided by MS

68. Table 11 lists the information provided by MS in its adjustment application. The

information provided by MS was stored on the EMRT-NECD review platform.

Table 11: Information Provided by MS

Filename Short description of content

MS_CLRTAP_2016v1_Notification_2016

v1_160215.docx

The notification of a 2016 adjustment application

MS_CLRTAP_2016v1_Appendix_B1_Adj

ustment_Application_Tables_VIII_1602

15.xlsx

The detailed calculations for the quantification of the 2016

adjustments.

MS_IIR_2016_draft_160315_v4.pdf The Informative Inventory Report provided by MS.

69. The reviewers found it necessary to ask MS for further information. The information was

partly provided in an email.

Table 5: Additional Information Provided by MS

Filename Short description of content

E-mail send to MS 23/6- 2016 The reviewers have asked for more information regarding the calculation of NO emission from livestock production (NFR 3B). MS replied with a partial answer. However, the national expert didn’t have the opportunity to answer during the review week.

28

References and Supporting Documents

Annex I emission reporting template. Available at

http://www.ceip.at/ms/ceip_home1/ceip_home/reporting_instructions/

EEA 2018. Tista M., Gager M., Ullrich B., NEC Directive status report 2016. European Environment Agency,

Copenhagen. Available at:

http://www.eea.europa.eu/themes/air/national-emission-ceilings/nec-directive-reporting-status-2016 [will be

up-dated)

EU 2018, EU Air Emission inventory review Guidelines .Available at

http://ec.europa.eu/environment/air/reduction/implementation.htm [will be up-dated)

EU 2018, Guidance for TERTs. Available upon request.

Decision 2012/3 (ECE/EB.AIR/111/Add.1): Adjustments under the Gothenburg Protocol to emission reduction

commitments or to inventories for the purposes of comparing total national emissions with them

Decision 2012/12 (ECE/EB.AIR/113/Add.1): Guidance for adjustments under the 1999 Protocol to Abate

Acidification, Eutrophication and Ground-level Ozone to emission reduction commitments or to inventories for

the purposes of comparing total national emissions with them

Decision 2014/1 (ECE/EB.Air/127/Add.1) Improving the guidance for adjustments under the 1999 Protocol to

Abate Acidification, Eutrophication and Ground-level Ozone to emission reduction commitments or to

inventories for the purposes of comparing total national emissions with them

EMEP/EEA, 2016 EMEP/EEA air pollutant emission inventory guidebook – 2016 EEA technical report No. 21/2016

European Environment Agency, Copenhagen. Available at: http://www.eea.europa.eu//publications/emep-eea-

guidebook-2016

EMEP/EEA Air Pollutant Emission Inventory Guidebook 2013

http://www.eea.europa.eu/publications/emep-eea-guidebook-2013

2014 Reporting Guidelines (ECE/EB.AIR/125 ) for Estimating and Reporting Emission Data under CLRTAP

http://www.ceip.at/ms/ceip_home1/ceip_home/reporting_instructions/

ECE/EB.AIR/130: Technical Guidance for Parties Making Adjustment Applications and for the Expert Review of

Adjustment Applications, 14 April 2015

http://www.ceip.at/fileadmin/inhalte/emep/Adjustments/ECE_EB_AIR_130_AV_for_the_web.pdf

NEC Directive 2001, DIRECTIVE 2001/81/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL ,of 23

October 2001 on national emission ceilings for certain atmospheric pollutants

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:02001L0081-20130701&from=EN

NEC Directive 2016, DIRECTIVE (EU) 2016/2284 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 14

December 2016 on the reduction of national emissions of certain atmospheric pollutants, amending Directive

2003/35/EC and repealing Directive 2001/81/EC. http://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=uriserv%3AOJ.L_.2016.344.01.0001.01.ENG