List 2.xls

This file contains all the comments received during the official review period (February 26 - April 1) for the draft revised Guidebook.

There are separate worksheets in this file:- General comments: addresses comments that are generic and not specific for a certain chapter- General Guidance comments: comments addressing General Guidance chapters. Comments are sorted by chapter number.- Sectoral - textual comments: comments addressing the text in one of the technical chapters. Comments are sorted by NFR code.- Sectoral - EF comments: comments addressing emission factors in one of the tables in the technical chapters. Comments are sorted by NFR code.

Comment

Comment relates to unc chapter (not in the drop menue): Please make reference to the requirements in the IIR

The formulas do not appear uniform: in some cases the legend is missing.

In copying text from the IPCC GLs, frequently inappropriate reference to GHG inventories remains. This must be checked and corrected everywhere.

The references in Tables don't have correspondence in reference list. It's often impossible to understand where the original emission factors are retrieved. The reference: Guidebook (2006) or CEPMEIP (2004) are not acceptable, they work as "Chinese nested boxes": substitute with original references! Also the reference "Visschedijk, 2004" is not a reference to the work where the user can found EF and detailed explanation of their derivation. The reference Espreme what means: the reference must be to a document where the methodology to derive EFs is explained.

The table 3.1 of the model chapter (cement as agreed in Dessau) is not implemented in many chapters (e.g transport), it provides the necessary overview of where emissions are to be expected or not. Please include a similar table in all chapters.

In the box "major changes since previous versions" please remove the remark on Tiers and the Thessaloniki meeting. On the other hand the comment in this box should be chapter specific, for example poit out if methods or emission factoes have been revised (which rarely is included), please add this information. This comment is generic to the entire guidebook.

Figure and table numbering is not harmonised throughout the revised Guidebook, this must be ensured before publishing

Everywhere where appropriate the new name of the Guidebook must be used (the name change will almost certainly be approved)

The new Guidebook must clearly describe where emissions of HM and POPs are expected emitted (ir not expected) (this is in line with the scope of the project). The version sent out for review has many gaps in this respect. Furthermore improvements in information on HM and POPs are expected through support by Germany and the Netherlands, this information must be included in the next version (prior to the TFEIP meeting)

The figures do not appear uniform. The explanation for the blue arrows is missing from time to time (but e.g. Chapter 2.A.1. Figure 2-1 is OK) and in some cases heat (or fuel) are not denoted. See below

The draft Guidebook use a mixed terminology for substance vs (air) pollutants, please consult the Guidelines and harmonise text everywhere

The Guidelines use the term "Key category" (agreed by TFEIP), the GB mus be consistent with this decisions (text and decision trees) (in the current draft both terminologies are used, even within the same chapter, while key source is most frequently used)

One objective of the project is to facilitate maintenance. Nevertheless, throughout the Guidelines there is a lot of repetition of information. Examples are definition of TCCCA and reference to the Guidelines. Please ensure that such repetiton as far as possible is avoided.

The Guidebook is endorsed by the Convention, consequently the term Party is correct (and not MS), and the GB must be written this way (the current draft not alwyas is). However a statement can be given to explain the role of the Guidebook under NEC. The term "country" is neutral

The whole draft needs to undergo a proper QA/QC by the consultantst, in the draft many references are missing, tables refereces are not correct, terminology (outline/numbering) is inappropriate/inconsistent and copy and paste mistakes makes part of the text meaningless

Pollutant subscripts eg NH3, SOx NOx etc. Please standardise across all chapters

References- for three authors or more in the text use Surname et al (year). Please standardise across all chapters

Scientific improvements: In the agreement betweeen the Commission and EMEP in starting this project some top priority scientific improvements were setteled. I have looked into a couple of these: i) for solvent use some of the T2 emission factors given are 18 years old (the rest are more than 10) (e.f domestic solvent use, some solvent chapters are updated), ii) fugitive emissions from fuel - parts updated - but not the very important chapter on fuel (gasoline) distribution iii) waste (landfills and waste incineration) - landfill chapter is empty waste incineration chapters have not been updated. All these are examples of sectors where technology has been changing and it is likely that the provided information is outdated. Hopefully the consultans can fill these gaps before the next version is sent for review.

In some cases different technologies/abatment system are defined introducing EFs for each technology (for example for Volume 2C) in some case new technologies/new products are introduced under abatment (for example for Volume 3). It's better to produce alwaays EFs tables (non reductions) with technology/products and put them in section 3.3.2. I think the approach must be unique!

Comment relates to unc chapter (not in the drop menue). Please cite the last draft Guidelines (same comment to be sec 7 of this chapter)

General guidance: throughout the chapters 'key categories' is interchangabley used with 'key sources'. A variety of capitalisation is also used: Key Source, key sources etc. Please standardise across all chapters (it should be key category in the UNECE context)

The number of signicant digits provided throughout the different chapters vary greatly. E.g. 0.1 (Lead - Residential - Biomass - Fireplaces) and 0.124467 (Lead - Residential - Solid fuels - Stoves)

A contact address would be extermely helpful (in order to refer any questions to / to report additional evidence). Probably, the Expert Panel chairs are most appropriate to be mentioned.

Numbering of tables and figures in general guidacne chapters needs standardising. Sometimes Fig 1, Fig 2 etc is used, other times Fig X.1, Fig X.3 is used where X is the section number - Please standardise across all chapters

In far too many instances, material copied and pasted from IPCC Guidelines still contains inappropriate references to eg other sections or Volumes of the IPPC docs. Please check and correct across all chapters

Terminology. In several general guidance chapters mention is made of reporting obligations for signatories (or signatory Parties etc) to the various Convention protocols. The obligations are actually only placed on Parties that have ratified the protocols (i.e. a number of parties have signed but not ratifed protocols). Please correct terminlogy across all general guidance chapters

General guidance chapters: references to a Party to the Convention should have a capital P. Member States should also be capitalised. Please standardise across all chapters

In many places the 2006 draft GB cites the previous GB for emission factors. It was agreed at the AEG meeting in Dublin that this only would be a last resort (jfr page 3 of the minutes). This must be updated where the original references are available in the current version of the GB (in most cases it is). Furthermore, the referencing to the current version of the GB is different in different chapters.

When all tables are equipped with a column providing the unit it is incomprehensible why this has not been utilised to ensure more meaningful emission factors, e.g. 4 mg/GJ instead of 0.004 g/GJ.

General guidance: several times CAFÉ is used with accent on the E, please correct to CAFE. Please standardise across all chapters

Some general guidance chapters use footnotes to provide reference details, while other references are included in the reference list. If a reference list is included ina chapter avoid use of footnotes.

Styles - not consistent across general guidance chapters i.e. sometimes Level one headings are ALL CAPS, sometimes Sentence case, sometimes Title Case. Needs to be standardised.

Reference list provided in each chapter - should be alphabetical, in ascending date of publication and following consistent format i.e. authors (year) Title etc. Please standardise across all chapters

The references need checking in all general guidance chapters (& sector chapters). In a number of cases references appear in the text but not in the reference list and vice versa

Abbrevaiations are not always explained. I recommend an explanation in the general volume or separately in the volume on each sector.

Need a consistent use of CLRTAP, LRTAP or LRTAP Convention - all three are used interchangably. Please standardise across all chapters (to LRTAP Convention?)

Action taken Comments

Accepted

Noted Done for as far as possible

Accepted Done for most chapters

Accepted

Accepted Done

Accepted

Accepted Remains to be done. What is exactly meant?

Accepted Done

Accepted Done

Accepted

Accepted Try to do this as much as possible

Accepted Done

Accepted

Accepted Done Use country as much as possible to avoid this issue

Accepted Done, at least to a large extent

Proposed decision

Try to avoid this as much as possible. Check mainly the GG chapters for these errors!

As agreed, we will take EFs from (peer-reviewed) literature or at least publicly available references as much as we can. However, in quite a number of cases we don't have anything better!

I assume it is meant to fill the "Not Applicable" and "Not Estimated" boxes with all relevant pollutants.

Revised in many cases. Comment about Tiers removed.

What is the exact new name? I'm not sure. Remains to be done.

Legends to be completed with every formula where appropriate

The EF tables will clearly display if emissions of each pollutant are expected for this source category (according to reporting template). All contributions from Germany & Netherlands will be included in final draft.

More explanations added to the figures where necessary

We'll try to avoid unneccessary repetition, but must keep in mind that the Guidebook is over 1700 pages

Noted

Rejected

Accepted Done

Accepted Done

Accepted

Accepted

Accepted

Accepted Checked

Noted

Accepted Done

Accepted DoneEditorial Done as much as possible

Noted

Editorial Done

Noted

Accepted Checked

Accepted Checked

Accepted Done

Accepted Done

Accepted

Solvent use - All chapters except domestic use (for this one no new information available) have been significanly updated with input from the industry, I therefore do not agree with this comment.Fugitives chapter has been updated in consultation with CONCAWE.Waste incineration - no other new emission factors available.

This approach was presented already in Dessau (May 2007) and approved for as far as I know. No time to change it now.

Checked, corrected where too much digits

6 digits too much, does not reflect the uncertainty of the numbers

Remains to be done, but decision on this is needed before.

Done, X-x used where X is section number

Referencing to old Guidebook harmonised. We'll refer to original literature as much as possible.

Footnotes sometimes explain more than just the reference.

To be discussed, one glossary might indeed be better than separate ones in each chapter

AcceptedHarmonized in GG chapters as much as possible

Volume

1 Introduction 1

1 Introduction 1

1 Introduction 1

1 Introduction 2 22 2 25







1 Introduction 2 37 2 381 Introduction 2 371 Introduction 2 31

1 Introduction 2 19

1 Introduction 2 27

1 Introduction 2 131 Introduction 2 21 Introduction 2 5

Chapter_ID

FromPage

ToPage

FromLine

ToLine

1 Introduction 2 191 Introduction 2 6





1 Introduction 3 2 3 41 Introduction 3 12

1 Introduction 3 15




1 Introduction 4 6

1 Introduction 4 27

1 Introduction 4 6 7

1 Introduction 4 5





1 Introduction 5 16

1 Introduction 5 13




1 Introduction 5 37


1 Introduction 6 13 161 Introduction 6 5

1 Introduction 6 24


1 Introduction 7 4 7 61 Introduction 7 4 7 11

1 Introduction 7 19

1 Introduction 7 25




1 Introduction 8 33 9 101 Introduction 8 111 Introduction 8 121 Introduction 8 36

1 Introduction 8 18

1 Introduction 8 15



1 Introduction 9 17 35

1 Introduction 9 38


1 Introduction 10 32


1 Introduction 10 201 Introduction 10 241 Introduction 10 201 Introduction 10 61 Introduction 11 25


1 Introduction 11 5


1 Introduction 12 26 12 261 Introduction 12 11

1 Introduction 12 121 Introduction 12 211 Introduction 12 251 Introduction 12 261 Introduction 12 311 Introduction 12 321 Introduction 13 28 13 281 Introduction 13 27 13 271 Introduction 13 19 13 19






1 Introduction 14 101 Introduction 15 23 33














1 Introduction 22

1 Introduction 221 Introduction 26


1 Introduction

1 Introduction

1 Introduction

2 1 1

2 1 1

2 1

2 2 7

2 2 8

2 3 1

2 3 5 3 6

Methodological Choice







2 3 7 3 9

2 3 7 3 8

2 3 7 3 9

2 3 7 3 7

2 3 7 3 9

2 3 12

2 3 28 3 32

2 3 29

2 3 29

2 3 32

2 4 3

2 4 3

2 4 4

2 4 6

2 4 8

2 4 8 4 8

2 4


















2 4 6

2 5 5

2 5 5 5 5

2 5 7

2 5 8

2 5 8

2 5 16

2 5 26

2 5 33 5 34

2 6 3

2 6 3 6 3

2 6 3 11 1

2 6 10

2 11 1

2 11 1

2 11 20

2 12 5


















2 12 18

2 12 12

2 13 4 14 37

2 13 4

2 13 16 13 17

2 13 16 13 17

2 13 16 13 17

2 13 20 13 21

2 13 22

2 14 12

2 14 23

2 14 38 17 3

2 15 25 15 26

2 18 12

2 19 7 19 8

2 19 14 19 14

2 19 38 19 38

2 20 6

2 20 7 30

2 20 7 30

2 20 7 30






















2 20 7 30

2 20 12

2 20 22

2 20 22

2 20 36

2 20 30

2 20 30

2 31 1

2 32 1

2 32 1

2 32 1

2 32 4

2 32 15 33

2 32 15

2 32 36

2 32 36

















2 32 36

2 32 36

2 35 2

2 35 2

2 35 5 36 2

2 35 6

2 36 42

2 37

2 37 37

3 1 11

3 2 13

3 2 2

3 3 14 3 29

3 4 5

3 4 17 4 17

3 7

3 8 5

3 10 14

3 14 40 14 41

3 14 35










Data Collection Issues











3 18 16

3 19 1

3

3

4 1 1

4 2 18

4 2 16

4 2 5

4 2 3

4 2 5

4 3 35

4 3 17

4 3 15

4 4 6

4 5 6

4 6 32

4 7 12

4 7 11

4 7 9

4 7 2

4 7 1

4 8 12

4 9 13

4 9 1

4 10 1





Time series consistency





















4 10 24

4 10 11

4 11 20

4 11 9

4 11 4

4 12 17

4 12 17

4 12 17

4 13 10

4 13 13

4 13 15

4 14 8

4 14 18

4 14 1

4 16 1

4

4

4

4

5 Uncertainties 1 1

5 Uncertainties 2 25 Uncertainties 2 3

5 Uncertainties 11 1

























5 Uncertainties 21 34 21 35

5 Uncertainties 21 30 21 31






5 Uncertainties 23 365 Uncertainties 24 1

6 1 27

6 2 2 2 2

Inventory Management


6 2 19 2 19

6 2 19

6 3 7

6 3 24 3 24

6 3 27 3 28

6 3 34

6 4 7 4 10

6 4 8 4 8

6 4 11 4 12

6 6 4

6 6 7 6 7

6 6 25

6 6 32 6 32

6 7 25 7 26

6 7 35
















6 8 17

6 8 19 8 36

6 8 31

6 9 3

6 10 13 10 13

6 11 6 11 6

6 11

6 11

6 12 9 12 14

6 12

6 13 16

6 15 18

6 16 26

6 16 28

6 18 10

6 19 20 19 21

6 19 20 19 20

6 20 9 20 9

6 21 3




















6 21 7

6 21 27 21 27

6 21 27

6 21 31

6 21 38 21 38

6 21 38

6 21

6 22 1

6 22 1

6 22 22

6 22 22

6 23 2

6 23 2

6

6

6

7 1 8

7 1 23

7 1 22

7 1 1

7 1 1

7 1 1

















Spatial disaggregation






7 1 1

7 2 18 2 18

7 2 33 3 31

7 2 25 2 25

7 2 5 2 2

7 2 33 2 33

7 3 24

7 3 11 3 12

7 3 20

7 3 35 3 35

7 3 30 3 31

7 3 6

7 4 16

7 4 14















7 4 7 4 77

7 5 22

7 5 2 5 2

7 6 15

7 6 19

7 6 30 6 30

7 6 28 6 28

7 8 16

7 10 12 10 12

7 10 3 10 3

7 11 22

7 11 4

7 13 13

7 13 11 13 12

7 14 1 14 4

7 14 12

7 15 17

7 15 17

7 15 13

7 15 17

7 15 17






















7 17 1

7 24 16

7 27 1

7 32 36

7 32 36

7 33 1

7 35 11

7 37

7 37 2

8 Projections 1 1

8 Projections 1 1

8 Projections 1 18 Projections 2 13

8 Projections 2 15


8 Projections 2 78 Projections 3 38 Projections 3 1










8 Projections 3 18

8 Projections 3 1

8 Projections 3 12

8 Projections 3

8 Projections 3 9 3 17



8 Projections 4 1

8 Projections 4 2

8 Projections 4 1 4 28 Projections 4 10 4 12

8 Projections 4 11



8 Projections 4 4 4 148 Projections 5 2




8 Projections 5 4



8 Projections 68 Projections 6 7


8 Projections 6 18 Projections 7 178 Projections 7 198 Projections 7 228 Projections 7 1 7 28 Projections 7 48 Projections 7 14




8 Projections 8 298 Projections 8 228 Projections 8 58 Projections 8 48 Projections 8 58 Projections 8 228 Projections 8 21

8 Projections 8 188 Projections 9 25 9 258 Projections 9 25

8 Projections 10 24

8 Projections 10 4 10 118 Projections 10 148 Projections 10 20

8 Projections 10 13

8 Projections 10 3

8 Projections 10 14 158 Projections 10 178 Projections 10 188 Projections 10 19


8 Projections 10 23


8 Projections 10 35

8 Projections 10 39 408 Projections 11 1



8 Projections 11 1 2

8 Projections 11 35 11 378 Projections 12 268 Projections 13 17


8 Projections 13 20 13 228 Projections 13 178 Projections 13 188 Projections 13 20

8 Projections 13 218 Projections 13 20 22


8 Projections 14 32


8 Projections 15 5

8 Projections 16 7

8 Projections 16 8


8 Projections

8 Projections

8 Projections

Comment

Noted

Accepted

Accepted

Accepted

Noted

Rejected

Rejected

Accepted

Rejected

Noted

AcceptedEEA's THEN European... Editorialtypo - change to to in. Editorial

Accepted

Guidelines - first time of use properly define and reference Editorial

Acceptedtypo - hereafter CALLED EditorialSuperscript the footnote reference 1 Editorial

Proposed decision

Proper references should be given to EC legislation and Convention etc mentioned in the text

I felt Appendix C fuels should be deleted from this chapter, as it is technical material being presented in a non-technical chapter. A table of fuels is repeated in Methodological choice chapter - just present this Fuels information once (i.e. in the more technical Methodological chapter)

Appendix A (pollutants) and Appendix B (sectors) should be deleted. Instead reference should be made to the Guidelines which is the single source where this information should be defined. Also helps future-proof the text and removes potential user confusion - e.g. already there are inconsistences between the pollutant list with what is in the latest Guidelines

These sentences should be deleted - not future proof (i.e. will be out of date in next years version of the GB already)

Ridiculous statement: there is a relationship between the resources allocated and the reliability of the emission inventory

Some 'scene setting' is needed, to explain the importance of emission inventories

SNAP is developed by TFEIP not ETC, in the past there was a SNAP/NOSE committe in cooperation between EEA and Europstat.

NFR was further developed in 2006 and 2007 in revising the GLs, please correct

Please also provide information on the improvements made to HM and POPs through the support by Germany and the Netherlands

Please specify that only Tier 1 and Tier 2 methods have been updated. Many needs for updating Tier 3 methods have been identified, but were outside the scope of this project.

SNAP97 was developed by CITEPA or ETC/AE respectively ?

Signatories do not have reporting obligations - only parties that have ratified do (many Parties have signed but not ratified protocols). Needs rewording throughout chapter

Change wording of 'updated where necessary' i.e. not all needed updates have been done by this project

Acceptedtypo - word Guidebook missing Editorial

Accepted

Editorial

Noted

Noted

AcceptedDelete 2008 - not future proof Editorial

Accepted

EditorialDelete 'and actors' - its jargon Editorialparties should have capital P throuighout chapter Editorial

Editorial

Accepted

Accepted

Noted

Include info what is the purpos of this section Accepted

Rejected

Noted

Rejected

Accepted

Convention - first time of use please write out formal name of Convention, define abbreviation (see general comment) and properly reference

Appendix A should be dleted. It's already inconsistent with the latest GL. Use instead text such as 'for those pollutants for which reporting is required as defined in the EMEP reporting guidelines

Correct typos in these bullets - procedures, users to, levels of

Kyoto protocol and IPPC Guidelines should be properly referneced at their first time of use

Please insert compliance checking under the Protocols of the Convention and an explicit reference to EMEP modelling activities (disopersion and integrated assessment)

Please delete text "Such a knowledge…" under rest of the sentence, this does not belong here

Emissions data is no longer reported to UNECE Secretariat (now to CEIP). Reword

NEC - reference this and defien abbreviation which is later used - NECD etc

Please use the exact wording of the last version of the Guidelines (consult the Secretariat). The term "Member states" must NOT appear, but "Parties"

Please check - Defintions of TCCCA elements here need to be identical to the defintions used in the latest draft Guidelines

Include para on Recalculations - it is very important and should be highlited

consider to change 'this' to 'relevant' or 'appropriate' directive

consider to change 'Concepts' to 'Glossary' or channge the system of paras instead of alphabetic order group sysetmetic ( it takes some time to undersatand whats about )

This paragraph states that the guidebook covers all pollutants, however there are significant shortcomings with regard to HCB and PAHs. The PAH's have for stationary combustion been lumped together.

TNO will as a side project add information on new POPs for consideration into future protocols (also resulting from product use). Please update the text accordingly

Please see general remark to use of the term "substance" vs "air pollutant"

Accepted

Accepted

Editorial

NotedParties' should be Party's Editorialtypo - 'in that helps' is missing a word(s) Editorial

Please check - use of signatory versus ratified for the EC EditorialParty TO the… Editorial

Editorialreplace covers with 'designed to' Editorial

Noted

Editorial

Acceptedreplace gas with pollutant Accepted

Accepted

Accepted

AcceptedText should be under the Scope section Noted

Rejected

Rejected

In accordance with TFEIPs decision, the Guidelines are using the term "key category", please be consistent with the Guidelines

terminology - do not use key source. The agreed term under UNECE is key category. Correct here and throughoput all chapters (also, do not captilisise this term if used in middle of a sentence)

delete 'actual nature and' . Reproting formats are the same for all directives , countries just do not need to complete columns if not ratified protocols

consider to use 'CLRATP' and 'NECD' inventory instead of LRTAP and NEC (trough the whole report)

The EMEP GL should have been properly referneced before, so don’t need full refernece and weblink here

Propose to delet Appendix B in which case reference to the Appendix here should be removed

delete sentence - this is reporting specific and is different for eg NEC. Instead use text ' A national total is…each pollutnat and categories as defined in the repsective reporting requirements

consider to add sentence like 'Relevant information shell be provided in IIR'

delete reference to EPER Guidance - is outdated and replaced by E-PRTR Guideance. In any case I didnl;t see any reference/common approaches with to EPER/E-PRTR Guidance in later chapters so perhaps should be deleted.

Please also introduce abatement as it frequently used in compiling air pollutant inventories

Text appears partly repetition of a prev paragrap, please streamline

Prefrably introductory text should be user manual like and not a novel. It is not easy to find in the text what the user you looking after. Consider to highlit the 'key words' and other options to structure the text

What kind of key sources are you refering to, avaerage in Europe or ? Consider explanation as a foonote?

Acceptedtypo - or IS missing Editorial

Editorial

Accepted

AcceptedParties - capital P Editorialreword - secreatriate no longer receives data EditorialGuidelines need to be properly referneced Editorial

Editorial

Accepted

Noted

Editorial

Consider to reference also LPS directive Editorial

Editorial

In the Chapter there is a Table 3-3 which provides the rating definitions and typical error ranges used in the Guidebook.However, there are commonly used rating definitions developed by theUS EPA. All of the emission factors in e.g. AP-42 are given an EPAquality rating. These have been copied in previous versions ofCorinair where EPA EF's have been given.Other US institutes, eg API also use the same quality codes.However, the EPA quality rating definitions and those in Table 3-3are not the same, and this could cause confusion if the userof the Guidebook is not aware of this.It is proposed that a new paragraph is added after line 22, page 7,just before Table 3-3, as follows:"It should be noted that the definitions of emission factor quality ratings given in Table 3-3 are not the same as the definitionsused by the US EPA. Where emission factors developed by the US EPA or other American technical institutes are used, the US ratings A, B and C can be considered to be equivalent to the ratings A, B and C in Table 3-3. However, US ratings D and Ecan be considered to be equivalent to ratings C and D in Table 3-3.The US EPA has no equivalent to the Corinair rating E as allemission factors developed by the EPA are from measurement andnot from engineeering calculation."

Please change text to "… report emission data to the Convention to fulfil their obligations under the Protocols. These protocols are…

"Relevance" has not previously been defined (page 4), and needs some more explanation. The remaining text of the par appears redundant with previous text

To support more easy maintenance I propose not repeating the information from the Guidelines here. The same applies to following paragraphs (e.g NEC and UNFCCC), the text should be made more general

The Convention on long-range…and its abbreviation doesn't need defining in every new subsection.

use word pollutnats instead of species (species means soemthing else)

Emissions should be reported in the NFR format for year X-2 by the 15th February each year; that is not a realistic proposition; between 15 and 30 of March will be more realistic

Remove bold formatiing for GHG legislation - this isn’t done elsewhere

Don’t have gapo between UN FCCC - is not commonly done

NotedNH3 not ammonia for consistency Editorial

Accepted

Accepted

Rejectedlegislation, not Law Acceptedtypo in title Editorialthe the Editorialtypo - sources Editorial

Rejected

Noted

Accepted

NotedNot polluting, but pollutant Editorial

There is no mention of the on-going review of the NECD - the text should be updated to reflect this

footnote 2 - has variuos superfluous sub-footnote numbering included - delete. These documents should also be fully references in the refernece list of the chaptetr

replace should with may. It isn’t justified to make such a conclusion here

No mention of upcoming review of the EU-MM - text should be updated to mention this important aspect

Details of the enrty into force of the protocol should be given

The international PRTR started at the conference in Rio de Janeiro in 1992 where all countries were in the so-called Agenda 21 advised to establish a Pollutant Release and Transfer system. OECD took the lead for supporting these activities in close cooperation with UNITAR and UNEP chemicals. After a series of regional conferences it was decided to focus on more technical support using the experiences from countries having already a more established PRTR.

In 2005 the taskforce was merged with the IOMC PRTR coordination group and is now called the PRTR coordination taskforce. Useful products are sofar a resource centre built by Environment Canada and recently a PRTR portal (www.PRTR.net) providing links with international and national PRTR activities and information sources (also by Environment Canada). In 2008 a the following documents are expected: An overview of quality control methods (Australie en USEPA), methods for estimating emissions from small and medium sized enterprises (Finland), and emissions from product use (Nordic Council). Japan is working on a paper called Sharing and Comparing, making links between emissions and statistical data like national product or number of inhabitants

UNITAR is in 2008 supporting Armenia, ChIle, Ecuador, Panama and Togo with some plans for further support in Middle America

Acceptedlater that year' replace with october 2009 Acceptedreplace 14 with 22 Accepteddelete final sentence Acceptedreplace signatories with Parties EditorialMembership of the TFEIP and the expert panels… AcceptedPlease delete "should allow for maintenance and", AcceptedDelete "expert" EditorialWhat is the "verification" panel? Noted

Accepted

delete: and will be subject to… etc

Noted

EditorialDelete 2008 - not future proof Editorial

Rejected

AcceptedUse numbering instead of bullets Accepted

Accepted

Consider to include headings EMEP , TFEIP (and CEIP) Rejected

Noted

Accepted

Accepted

Accepted

mention that E-PRTR also goes beyond requirements of the protocol (more polls, strciter thresholds)

The text deviates slightly from the panel TOR agreed in Dublin, is any difference justified?

Please consider shortening, e.g describing all TFEIP meetings would require an annual update of the introduction.

reword - maintenance of the technical content of the Guidebook is the responsibility of the TFEIP expert panels

make bold all the CORINAIRXX so the user can see the development.From the text it is not clear what is the current system. At the end of this section should be clearly defind how is refered current system and include also info on new extended NFR main sectors.

text not updated. Delete refernece to ETC/AEM. State again here that TFEIP is responsible for the technical content and EEA for hosting

Consider to Include para explaining the role of the EMEP Centre on Emission inventories and Projections (CEIP) http://www.emep-emissions.at/ceip/

check - EMEP is not formed by a protocol I believe (it existed before the convention). Replace formed with 'funded via'

DELETE - 'develops the EMEP emissions inventory based on emission data from Parties' - it doesn't.

delete UNFCCC and Kyoto and replace with NEC and LRTAP Convention

Group Switzerland with Iceland etc and call EFTA (European free Trade Area countries)

Capitalise Member States NotedAdd Kosovo to the list Accepted

SOER report needs proper referencing Noted

Rejected

Accepted

Rejected

Rejected

Rejected

Rejected

Rejected(b) add... and emissions from Cultivation of Rice Rejected

Rejected

Rejected

Rejected

Rejected

Title of chapter and header is spelt wrong. Methodological! Editorial

Accepted

Rejected

typo - uncertainty Editorial

Removals not repoted under LRTAP convention Accepted

Change "quick and dirty" to "simple" Editorial

Accepted

Appendix 1 A Pollutants, The list of POP does not match with list of the GL

Include in row Dioxins: "expressed as "International Toxic Equivalents" I-TEQ"

Include more clear definition of PM2.5 and PM10 (possibly EN 12341 standard => "real world" PM2.5 and PM10 measurements always include larger particles).

Please add the additional POPs proposed added to the protocols (consult Hugo at TNO)

consider to incclude column with aggregations used fro gridding . See http://www.emep-emissions.at/fileadmin/inhalte/emep/doc/AnnexIII__Aggregation__gridded__data_Jan2008.doc

I suggest to include in Appendix B "Sectors by NFR code" corresponding SNAP code

Please use the latest version, consulting Katarina M (UBA-V) [there are some smaller differences]

Table "Fuel": For all pollutants except CO2 it doesn' make much sense to divide MSW into biomass and fossil fractions because emission factors will be available only for total MSW.

The claim that the guidebook includes default emission factors for all sources and pollutants where applicable is simply not correct. The guidebook should contain guidance, but many pollutants from many sources are listed as not estimated.

General: please also define natural vs anthropogenic (included in national totals)

Please append a list of abbreviations (SNAP, LRTAP, TFEIP...)

Chapter contains many cross references to other IPCC Volumes, IPCCC Guidance sections. All need deleting or rewording

The title of the chapter should be added "and identification of key categories"

Insert text stating the quality criteria of Tier 3 (sent by email 27.11.07)

Give a proper reference for the 'present' Guidebook Editorial

Editorial

Accepted

Editorial

Accepted

What does * refer to? Correct Accepted

Noted

Noted

Can sinks be deleted in UNECE context

Noted

Rejected

Noted

Noted

Accepted

Accepted

Accepted

Decison tree, please delete reference to sinks Accepted

What is meant by "the present GB"? Please redraft to "the previous EMEP/Corinair Guidebook…"

Delete these sentences - referencs to the 'present' (existing now) GB are very confusing for future readers and will be irrelvant onve the updated version is published

To be more clear "The present Guidebook" should be replaced with "the 2007 EMEP/CORINAIR Guidebook".

If this way of describing methods is kept in the guidebook the Tier wording has to be changed accordingly

The analysis is based on single pollutants, so this text would mean that the inventory compiler would look for decision trees etc in sector chapters for categories and for pollutants.

Volume B - incorrect IPPC cross-reference - delete or correct

Section B - incorrect IPPC cross-reference - delete or correct

Inventory Management is not the proper name of the chapter

Volume A incorrect IPPC cross-reference - delete or correct

Volume B - incorrect IPPC cross-reference - delete or correct

Figure 1 does not print well and is unreadable - repaste in at higher quality?

GHG inventory compiler reference - incorrect IPPC wording - delete or correct

Please delete reference to "greenhouse gas inventory" (comment applies throughout the chapter)

Rejected

Good - captialise Editorial

Editorial

pollutant - I think key categories is meant Editorial

Annex 1 - there is no Annex 1. Appendix A? Editorial

Editorial

Editorial

typo - particulate Editorial

Accepted

Accepted

Accepted

Accepted

accepted

accepted

accepted

Add Section before 2.4.3

incorrect GHG inventory reference - delete or correct accepted

General: The proposed key-category approach (single handling of each substance) will lead to the fact that almost all categories will be identified as key. In practice this would request whether the use of different (simple and detailed) approaches for one given source category depending from the substance or the general treatment of the entire inventory whit detailed approches. Both ways produce avoidable work. We propose to include a kind of normation of the released emissons e.g. by using accidification potentials (or other "transferring" parameters like for UNFCCC the use of GWP-values). This would streamline the results analysis due to the inclusion of more than one substance in one approach.

I assume the proper reference here is not the "good practice guidance", please add the correct reference of the 2006 Guidelines

Since no "annex 1" is available we guess this refers to "Appendix A"

Approach 2 - add relevant chapter cross reference e.g. Section 2.X.X

How to take cross-correlations into account is not (neither in the IPCC GL2006) described. An inclusion of a text as in the IPCCC GL 2006 p4.7 note 2 should be considered.

table 1 - put in an Appendix - too long for the body of the text

Large table which does not include very helpful information.

The b footnote should reflect the NFR codes. The c footnote is irrelevant

Please compare with latest NFR list and correct as appropriate. Please check table font (appears mixed, also in the footnote)

Table footnote C- what does this mean in the GB context??? Assessed jointly is relevant to GHGs only??

Footnote to table - b - reference to IPPC needs deleting or rewording (NFR?)

Consult with Expert Panel

accepted

accepted

accepted

accepted

accepted

Superscript footnote references 5 and 6 Editorial

change footnote references to upper case Editorial

Rejected

accepted

Removals relevant?? accepted

typo - dispersed Editorial

accepted

Rejected

incorrect IPCC reference? - there is no Table 3.3 accepted

Skip "or removals have increased". accepted

Skip "or decrease of removals in the future". accepted

Please make a reference to the IIR accepted

accepted

accepted

Rejected

accepted

This section must be adopted to air pollutant inventories: i) reference to sinks must be removed from the text ii) the equantions should be substantially simplified when sinks are not considered (see the IPCC GPG 2000) iii) change reference to GHG inventories to air pollutants

Footnote 3, there are no UNECE emission reporting, please provide the proper reference

The chapter talks about Greenhousegas inventories. For APs we do not expect "removals" so that we can skip calculation of absolute values.

Is sink/removal anywhere relevant for NFR reporting (It is not for Danish reporting)? If not, then change the text accordingly.

Are removals relevant to UNECE inventory context - if not delete

Since the analysis is to be carried out for each pollutant, the pollutant should be in the heading not as a column.

Footnote 6 - incorrect GHG inventory reference - delete or correct. Sinks relevant??

For APs we do not expect "removals" so that we can skip calculation of absolute values.

Since the analysis is to be carried out for each pollutant, the pollutant should be in the heading not as a column.

Examples on the actual pollutants and NFR categories should be worked out

A quarter of this chapter is dedicated to illustrate key source analysis, too many pages? Why showing contributions of sources that are not key sources? Is the chosen example relevant?

The example relates to GHG when CLRTAP/NECD reporting does not concerns GHG.

The key sources are defined per pollutant in the new Guidebook, when the example illustrates an other definition (key sources defined for the different GHG as GWP).

accepted

key categories in bold. No they're not?

accepted

accepted

accepted

accepted

Editorial

Appendix A is not mentioned in the text - it needs to be Accepted

Noted

its not it's Editorial

Noted

Correct caption numbering Editorial

Noted

It is confusing to display category codes within the example that are not consistent with the recommended ones (cf. table 1), as far as they relates to the new IPCC categories, from IPCC GL 2006 which are not yet applied even for UNFCCC reporting yet.

tables needs to be put in Appendix - is far too long for body of the chapter

table 4 - Can we not just have an example relevant for air pollutants instead of GHGs?

Please provide an example for an air pollutant inventory (one substance) rather than this example copied from the GHG inventory guidance

Chapter 2.6 Examples of key category analysis should be deleted, if the reference is given in the spec. chapter in the IPCCC GL, then it should be refer to that. Otherwise an examle with the air pollutants should be given!

General: We propose a reference system instead of quotation of all these detailed tables 4, 5, 6, 7, 8 (taken from the UNFCCC Guidelines).


References should be in correct order of date ie IPCC 2000 before IPCC 2006

Is the exercise meaningfull and is the results to be used for methodology demands?


This is a mathematical exercise weighing all pollutants identically and weighing categories accordingly. (What is meant by the text refering to the annex (page 5 line 7) that it consolidate the pollutant?)

The example assumes 95% treshold for key categories but the keysource chapter recommends 80%.

If the intention is that countries should perform a combined ranking of different pollutants it should be addressed in the main chapter and not only as an appendix.


The method for combining the key category analysis decribed in Appendix A is not mentioned nor referenced in the main chapter.

Noted

Noted

noted

typo Editorial

already have a Table 4 in the chapter - renumber Editorial

NOx Editorial

"Error! Bookmark not defined" Editorial

key sources should be key categories Editorial

Accepted

Accepted

Full stop missing Editorial

Please define MS (or better rewrite) Editorial

Please provide reference to EPER measurement guidance Accepted

Accepted

Remove bullet point Editorial

Proper references needed for CEN standards Rejected

Proper reference needed for EN ISO/IEC… Accepted

What is the result of the proposed combining procedure in Annex 2? Could this be used to minimise the overall number of key-categories in the sence of comment 1? E.g. by inclusion of all results for the different substances in these combination procedure. It would request a treshold value to identify the "overall-key-categories".

Page 32 line 11 states that this combined ranking SHOULD be done, however the described approach is only mentioned as a possible approach.

The individual ranking and scoring for the rank placng can bee seen in the right columns.

Why the definition of fuels is given in Appendix B, it is also given in Chapter 1 Introduction Appendic C Fuels???


What is this table doing here? It is misplaced and already included in the introduction. Please correct


The same fuel table is already included in Part "Introduction".

Mention clearly in introduction that section draws heavily on IPCC - eg as done for chapter time series consistency

In adopting this to air pollutants, the focus must include Euroean sources, eg Eurostat and E-PRTRs/PRTRs

For some of the points the understanding is not very clear. I suggest to include some typical examples for each point to increase the usiblity of this list also for "measurement dummies"

Editorial

delete final colon from the title Editorial

Accepted

Accepted

Editorial

No such sections as 1.4 and 1.5. Check and correct Editorial

1.3 should be 2. Check. Editorial

typo - component an air pollutant… reword Editorial

Editorial

Editorial

No such section - check and correct Editorial

typo - insert …'necessary' to prepare... Editorial

No such section as 5.2.3 - check and correct Editorial

Editorial

typo - to APPLY different Editorial

Rejected

Editorial

Editorial

Editorial

Editorial

Editorial

Box numbering - remove 5 Editorial

Equation numbering Remove 5 from 5.2 Editorial

Box numbering - remove 6 Editorial

Editorial

references should be put in ascending date order. Use author (date) title format throughout (for books as well as articles)

General: guidance on use of PRTR data is missing and must be added

General: reference to guidance for collection of spatial data is missing

Chapter contains many cross references to other IPCC Volumes, IPCCC Guidance sections. All need deleting or rewording

good practice guidance' is IPCC 2000. Clarify wording - 'good practice guidance of the IPCC2006 guidelines' if that is what is meant

Revise "is a central component an" e.g. "is a central component of an"

Capital R for reporting. Provide proper reference at first time of use

Footnote 2 - Overall rather than overlap? Check equation numbering - there is no equation 5.1. Correct different font sizes within footnote

Section numbering - use a 3 digit heading before a 4 digit heading (there is no 2.1.1)

Figure 5.2 - correct figure numbering (the 5 has no meaning?)





Box numbering. section not Section Editorial

Use 3 digit heading numbering Editorial

Accepted

Box numbering Editorial

Box numbering Editorial

Editorial

Add table numbering Editorial

table numbering - no 5 Editorial

Editorial



Editorial

table numbering - no 5

Editorial

references - arrange in ascending date order Editorial

Editorial

Editorial

Accepted

Accepted

Accepted

AcceptedUncertainties chapter - paragraph not article Accepted

Rejected

Accepted

Define AFOLU from figure caption (or delete as not relevant to UNECE inventories)

Add horizontal lines to table to improve readibility - 3rd column not aligned properly

Volumes - incorrect GHG inventory reference - delete or correct

Since the FOD has a chapter on QA/QC the refernce in the parenteses should presumably be changed from the IPCC GL to the FOD chapter

Volumes - incorrect GHG inventory reference - delete or correct

General: This chapter has been copied from IPCC Gls, and need to be properly review with the objective of changing terminology and references to this manual. Furthermore, figure numbering needs to be changed

If nowhere and for none of the pollutants sink/removal is actual the text should be looked through and revised accordingly

Since "base year" might not be precise/unique to the air pollutants the text should be looked through/revised.

Reference to sections and tables does not match the sections and table headings.

Uncertainties chapter - There are a number of references in the text not provided in the references list. Check and correct

Uncertainties chapter - incorrect reference draft GL 2003?? Update to 2008 draft GL or the existing final 2003 GL

Uncertainties chapter - Why table 6.(1)? Correct numbering - 6 is not relevant

Uncertainties chapter - incorrect reference draft GL 2003?? Update to 2008 draft GL or the existing final 2003 GL

Uncertainties chapter - paragraph not article Accepted

Accepted

Accepted

Accepted

Accepted

Uncertainties chapter - References not in reference list Accepted

Uncertainties chapter - Reference not in reference list Accepted

Accepted

Accepted



Uncertainties chapter - References not in reference list AcceptedUncertainties chapter - Delete if Appendix is empty Accepted

Noted

"principles" not principals Accepted

Uncertainties chapter - Footnote 4. A number of references are provided with no details given in the reference list. Add to reference list or delete.

Uncertainties chapter - Fig 3.5. correct numbering - there are no Figures 1-4

Uncertainties chapter - AFOLU - define or preferable delete - not relevant to UNECE inventories

Uncertainties chapter - Add references to reference list. And those in footnote 6

Uncertainties chapter - What are approaches 1 and 2. these are not defined at all in the chapter? Correct or delete

Uncertainties chapter - Not consistent. Section 3.2.3 does not give details of Approaches 1 and 2

According to me all the chapter is very clear; perhaps for being more practicable could be appreciated some operating examples related to the management inventory report (for ex some sheets related to the main phases (data request/raw data/compilation/QA_QC)) suggesting a way to include all info as introduced in paragraph 4.6

Accepted

Accepted

Add referencing for IPCC documents Accepted

"expamnds" -> "expands" Accepted

Accepted

Accepted

Please reference the 2008 Guidelines Accepted

Accepted

One from the data providers would be facility operator Accepted

EMEP Reporting guidelines - add proper reference Accepted

"detailed energy statistics" I suggest to remove detailed Accepted

Delete quite string and replace with fixed Accepted

"incventory" ->"inventory" Accepted

delete 2nd part of sentence following Authority Rejected

5 should be 6. Reorder bullets once corrected Accepted

At this point or/and in the paragraph 2.2 could be better distinguished the difference between "inventory manager" and "inventory compiler". As for the first one in page 2 line 19, it'd be specified that also the inventory compiler could be an individual or staff, one institution or more institutions. If the inventory manager is external to the inventory compiler staff, the last one need generally a chief inventory compiler staff. Probably in the case of small group they can overlap. Anyway I suggest to point out, also ahead, that the inventory manager (or chief inventory compiler staff if different) is responsible for the technical staff management (how to share resp, if for sectoral or trasversal topics, how to attribute internal deadline, how to introduce and guarantee that internal reports in the differents steps must be filled etc.), as financial budget management to guarantee hw_sw, data acquisition availability, inventory related external consultants etc.

Footnote 1 - Party not party. Check EC signatory or ratified protocols

Please harmonise with latest version of the draft Guidelines (see also comment to the introduction)

These TCCCA criteria have different definitions to those in the GB Introduction! They should be consistent with the formal definitions in the latest version of the draft Guidelines

"Inventory compilers, virtual or real institutions," I suggest to substitute with "Inventory compilers, one o more institutions,"

Accepted

Accepted

Accepted

Delete bit, replace with rather Accepted

"sectoral inventory" I'd suggest to remove sectoral Accepted

Accepted

Table 1, please make explicit reference to the IIR Accepted

Figure 4: please change references to CRF Accepted

Please update the text for air pollutant inventories Rejected

Accepted

No such box. Correct or delete Accepted

Accepted

typo Accepted

typo > Accepted

replace will with may Accepted

Accepted

Accepted

Rejected

partial text - delete Accepted

Styles - not consistent across chapter i.e. sometimes Level one headings are ALL CAPS, sometimes Sentence case, sometimes Title Case. Needs to be standardised.

A bit confusing the reference to year N and N+1 (line 22) and to year N and N+1 (line 36). It coul be briefly extended the first sentence "compiling an inventory is an annual process" (line 19) by mentionning that activities can

Delete should and replace with may. (It's not a requirement for parties)

the figure is very interesting, only few comments. Some symbols referred to documentation aren't clear for example "unique reference"; I suggest to move down "explain large changes" as it could be referred to all the previous parameters comparison/balance. The legend should be highlighted to be distinguished from the other rectangles; the figure is a bit compressed, there are some text characters with different dimensions;"CRF" and "NFR" compare for the first time in the chapter, maybe can be referred to general glossary or referred in the text

Table 1, there are no good practice guidance for air pollutant inventories, please change the terminolog

Delete protocol provisions as this is confusing (not all protocols reflect this). Instead refer to the applicable text in the Guidelines

I'd suggest to move in the previous part ("institutional" or "contact person")

"institutional" I suggest to change with or to add also "contact/reference person"

"technical" I'd suggest to change with software or archive aspects

Rejected

Venthoven et al, 2004 is not included in "references" Rejected

van Velthoven et al for 3 or moe authors Accepted

NACP missing from reference list - include Accepted

In -> An Accepted

table - data provider: An institution… Accepted

Rejected

Emissions reporting guidelines should be in reference list Accepted

Accepted

Rejected

In Validation …. "is" -> "Is" Accepted

Accepted

IPCC refereences need completeing Accepted

Rejected

Accepted

Rejected

Editorial

is ALSO required Editorial

Accepted

Rejected

Accepted

GAINS should be mentioned as a key source of verification here (both activity data and emissions)

Please discuss the role of EMEP modellering data for verification purposes

Quality Assurance - Section 6.5 - no such section - delete or correct

I suggest to enlarge the "Inventory system" definition, all the institution involved in the emission inventory planning/compilation/dissemination etc..

Peter van… references should be ordered by surname not first name. Date missing from reference details

Please discuss the role of PRTR data in QA/QC (e.g verification)

General: many Parties have integrated UNFCCC and LRTAP/NEC inventories, but not all. The authors of the current chapter seems to assume the former. This issue (institutional set-up) should be better explained, perhaps even in the introduction (see e.g figure 5)

General: Please define inventory compiler, under the Convention the responsibility lays with the "designated emission experts"

Instead of referring to gothenburg, refer instead to the Reporting Guidelines as the driver for reporting. (technically various EB decisions also implement spatial reporting and not just the protocol - its easier just to refer to the GL)

Reporting guidelines- use the reference list for referencing - not footnotes

styles - different chapter sections are in different fonts. Standardise throughout

Chapter name might be changed to reflect reporting of gridded data also? - 'Spatially disgagregated emissions mapping'?

Chapter could mention in introduction the basic work of the chpater was developed by EEA's ETC/ACC.

Accepted

Remove after key spatial data sources "." Editorial

add para on SNAP Editorial

Editorial

Editorial

Rejected

typo - gross Editorial

Accepted

Editorial

.. by an x and y coordinate"s." Editorial

Accepted

Say also when the protocol entered into force Editorial

Accepted

Accepted

Some areas of additional guidance are missing from the chapter (which the Guidebook consultants agreed to complete after taking over responsibility from ETC/ACC for completion of the chapter.) Specifically, augmented information on data sources and methods for mapping forest fires, biogenic VOC emissions, shipping and aviation should be provided and included in the final draft of this chapter.

I suggest to substitute here and after "50x50 km grid" wirh "50x 50 km2"

I suggest to add after "their dispersion partners" "and impact area"

Among "General Terms" I suggest to keep terms more related to spatial mapping, (such as NUTS, surroggate etc., I'd include "GIS" definition) and remove those as "HDV" and "LDV" for example.

Delete mention of associated proposed directives - its not at all clear which proposed directives are being talked about here

HDV: Heavy Duty Vehicles are vehicles with a gross vehicle weight of < 3,500 kg ==>>>> Heavy Duty Vehicles are vehicles with a gross vehicle weight of > 3,500 kg

I'd try to mention an example for each surrogate resolution level/type and keeping possibly the same order "as land use coverage pecentage by grid, vehicle flow by road link, employers number by industrial point, population by administrative boundary

References for the various legislative acts should put in the references, not in footnotes. Delete footnote 4 given earlier comment about the whole table should be deleted

this LPS definition is very messy - mixing up E-PRTR and Guidelines aspects. Rather directly refer to the Guidelines as the source where the definitions of LPS for reporting under the convetion and its protocols can be found. Mention also that defintions of LPS (sectors, thresholds etc) can differ between different reporting mechanisms. Don't provide details of the reporting thresholds and pollutants here - instead refer just to the Guidelines where these are defined. This will help avoid inconsistencies. Mention of the E-PRTR reporting thresholds and faility defintions should be deleted as they confuses the issue too much here.

Accepted

Appendix G not Annex 6 Editorial

Accepted

typo identify to? Editorial

typo delete misses Editorial

Accepted

Accepted

delete and EU- ETS?

Accepted

Accepted

Not 4.2 - should be 4.3 Check. Editorial

Editorial

Editorial

Accepted

not Annex II, it's Appendix G Editorial

Accepted

Accepted

Appendix G not Annex 6 Editorial

Complete reference list for TEMIS Editorial

Apmosphere reference - Briggs not Brigg Editorial

Definition of LPS: anything is written about th e stack height, which is also an important parameter for spatiol resolution and the EMEP gridding.

I suggest to mention that also "trasport emission can be handled sometimes as area soources, for example arcs that are too numerous or information are not available to be individually identified as line sources". Those cases they can be treated as area source as polygon or as area source as grid by the use of different surrogate variable (for example as percentage of linear emission density or from fuel balance, as difference between total fuel and linear traffic fuel induced)

I suggest to invite compilers to the use when possibile of the spatial surrogate used for spatial mapping in previous years to guarantee consistency

As the "example 1" is a bit far from the referring text, I suggest to include the corresponding page (e.g. Example 1, "pag 9")

Perhaps the emission total to be distributed is "emission t" instead of "emission ix"

I suggest to include in formula note ..to an "(i)" specific geographic feature

styles - delete full stop from heading and all headings from here on

Check - does the latest CORINE provide 45 or more? andcovers

Just provide one generic link to EEA dataservice - specific links become outdated

EUROSTAT has several useful agricultural datasets, e.g. From the Farm Structural Survey

The COPERT refernece can be updated to latest v4 manual available on the COPERT website

Reference to Guidelines should be updated to latest draft, not the Thessaliniki one (or final version when agreed)

Accepted

Noted

Noted

Figure numbering inconsistent Editorial


Accepted


Accepted

Editorialchange "though" to "through" Editorial

Editorial

Editorialdelete "data" Editorial

Accepteddelete "to" Editorialchange "and" to "or" Editorial

There is no mention/consideration given in the chpater to the gridded NFR GNFR which parties are required to report spatial data in. This is a major omission from the chapter and needs to be corrected. At least some short explanation needs to be given on how NFR emissions may be aggregated to the GNFR and reference made to the draft Guidelines where this is defined. Ideally proxy variables for each of the GNFR sectors should also be provided


It should be noted in the text that updated information on % gas connections etc may be available from Eurostat/IEA etc. This should be checked before being stated

See previous comment - surrogates should also be given for GNFR sectors, as this is the minium that some Parties will be able to do


Hopefully this might enhance the accuracy and consistency of the reported emission data. It would be nice also to include a section describing this issue in the guidebook.

We recommend, that a common harmonized GIS theme on coast line and territorial sea should be available for the member countries reporting gridded emission data. This to avoid the use of themes with different resolution and level of generalization.

EMEP is extening area to the east , consider to provide info and add map with extended EMEP area

I miss any reference to the various guidance material developed for EU MS compilation and reporting of GHG projections under the working group of the EC climate change committee. This at least should be referred to.

Throughout chapter, references need checking (text to reference list and vice versa)

Throughout chapter mixture of key sources, key categories and different capitalistaion is used - Key categories, Key Categories etc. please standardise

"Projections are usually much less certain than the historic inventory and require... "

"Guidance on tackling common problems associated with gathering appropriate data on…"

Definition of "without measures": what technology has achieved to date, is confusing. Especially comparing with terminology on p.3, l.16: without measures scenarios usually start from a convinient historic year.

Editorial

Editorial

Editorial

Editorial

Accepted

Noted

Change "with" to "where" Editorial

Change "post the historic year" to "are" Editorial

Editorialduplication of (b) on line 10 and subsequent lettering Editorial

Accepted

Noted

Noted

"targets, which has now been superceded." Editorial

Footnote, line1- change "and" to "or". Line3, delete "resulting"

Footnote 1: Line 1 Delete 2nd 'and'. Line 3 Delete 'resulting' Delete 'resulting'

Delete 'present' and replace by 'represent' or 'derive from' or 'reflect'

Footnote: Policies and Measures and can be laws - delete "and"

WoM scenario. No actual guidance on how this scenario should be developed i.e. are emissions to be projected from a base-year based on GDP for example?

Generic text on determining cost-effectiveness is not very helpful. Some guidance on how an costs can be determined would be useful.


We do not understand this definition. The starting year is only 1995 or 2000? Or may be the latest year of historic inventory? We think that this should be topic of discussion in Tallinn on projection expert panel.

Text Unclear, I suggest '…scenarios can include the estimation of "what would have happened" if the measures already implemented since the historic year had not been implemented.'

(c) and (d) are a bit vague- it is not clear how they could differ from the others. It might be helpfut to give examples of each?

It would be also good practice to clearly define the measures that the WM, WoM and WaM scenarios refer.

The definitions used for With measures and with additional measures should be fully in line with what is required for future reporting under NEC and EU-MM (or in the draft EMEP Reporting Guidelines or draft decisions if this is specified there). At present the defintions presented here differ, and thus need to be harmonsied with those specified in the formal reporting requirements.

In the definition for "With Measures" an agreed date, beyond which policies and measures are not considered, should be mentioned. For example, legislation, policies and measures in place by 31st of December of the previous year will only be considered under the "With Measures" scenario. Policies implemented in the current year, when the projection is being prepared should be included in the "With Additional Measures" scenario.


change "estimates" to "estimated" Editorial"… based on a range of datasets, including…" Editorial

Accepted

Accepted

Editorial

Accepted

AcceptedFigure - can't read the text on some sections of this Accepted

AcceptedYou could give an example eg road traffic model Accepted

Accepted

Accepted"An emission factor…" EditorialAdd a comma after "Key Source" Editorialeffect Editorialformula is singular; plural is formulae or fomulas Accepted…..and involves EditorialRevise sentence beginning at ( Accepted

Editorialsector's Editorial=Ads should have upper case D Editorial

AcceptedAn emission factor Editorial

Rejected

It depends how much detail you want to go into here but, the marginal cost curve in terms of a plot of total quantity of pollution avoided against the marginal cost of reduction in euros/tonne, is often used.

Future assumptions could also be based on behavioural changes or structural changes in society.

Emission projection scenario should be compiled - either scenarios should be plural or the sentence should start "An emission…"

There can also be regional considerations that necessitates that a measure is carried out despite the fact that it does not the biggest emission reduction for the lowest cost. For example health considerations in urban areas.

Generic text on the use of "energy models" to determine basic growth factors. Guidance on which models are recommended would be useful.

Flow Chart: Decision Diamond 2- The last sentence is 'or are current emission factors adequate' to which I answered yes and am then told in Tier 2 to use a future emission factor. I think you have to be clearer on what question you answer yes or no to

Not clear what is the difference between Tier 3 and Tier 2. Tier 2 mentions taking "reasonable account" of future activity changes. Not very specific.

No caption. Figure poor quality and unreadable when printed. Paste in higher quality version?

Be consistent in the use of 'emission factor' and 'emission rate'. Insert comma after Source

The emission factor for a source using a specific technology or control in year n

Page 7, formula 2 (row 26): in the denominator is ADn, where in row 33 is ADn = ADs*GFn. But on page 8, row 1, the formula for ADn is sum of ADt for t=1 to p. If we set the formula from page 8 to formula 2, then the formula 2 will be sum of the emission factors for t=1 to p. We think, that in formula on page 8 (row 1) should be correct ADt=sum of ADt for t=1 to p (not ADn).

Accepted"… so that a measure…" Editorial"… methods, the…" EditorialAvailable - uppercase A Editorialcomma after methods Editorialits measures Editorialneed to be broken down Accepted

AcceptedFGD is Flue Gas Desulphurisation? EditorialFGD: abbreviation is not explained Editorial

Accepted

Acceptedportray a picture consistent with Editorial…in from … Rephrase Editorial

Accepted

Editorial

Editorial"The energy related emissions should be checked…" Editorialchange "matched" to "match" Editorial"… estimates. The overall…" Editorial

Editorial"The transition…" Accepted

"… projection must be realistic. Check for …" Rejected

I think that it is worth stating in general terms that in some complex detailed sectors there can be an interraction between the emission factors assumed for pollutant control technologies and the projected activity data. For example in electricity generation the underlying activity data maybe future electricity demand. The energy consumption of the power sector must be consistent with the electricity demand and the efficiency of the future mix of power stations. The control measures applied (eg FGD, SCR, carbon capture and storage) will affect the efficiency of the power stations and hence fuel consumption. Thus the assumed mix of emission factors affects the fuel consumption data. In such cases the assumed mix of abatement technologies is an input to the model which predicts energy consumption.

Either include a definition of Stratification here, or refer to it's definition somewhere else

Possible addition to list. Compare projected trends in data (emissions or activity) with historic trends- if there are significant differences then need to explain why. This is based on a general observation that national emissions/activity data tend to change gradually (though not always eg N2O emissions in chemical industry)

We need some text to explain what this figure means- also it looks as if the arrows are displaced

There is nothing in this section referring to best practice used in historic compilation. Either include a reference to another section of the Guidebook, or add the following text:

Example of simplification - arrows need to be re-aligned in diagram

"It is important to ensure that the resulting emission projections are consistent with the underlying input data. The following checks…"

"… inventory should be consistent with the energy balance from…"

Noted"… are correct, and that revisions are transparent." Editorial

"… results and what were the sources of the difference." Editorial

Rejectedsectors Editorial

Acceptedbased on measured Editorial

Editorial"… based on measured…" Editorial

"to assume that projections are the same as those for…" Editorial

AcceptedNeed a heading "Emission factors" Acceptedprojected Editorial

Editorial

Acceptedtypo Editorialchange "improve" to "improving" Editorialchange "are based" to "or based" Editorial

"… employed to make all…" EditorialThis para is about sensitivities, should it be moved ?? Accepted

Acceptedchange "latst" to "latest" Editorial

Accepted

Accepted

Editorial

"… noted. If there is a large step change, then methods will need to be modified."

More sensible to use domestic as the example for both e.g.'s

Example: The emission limit value defined by the large combustion plant directive (Directive 2001/80/EC) for new coal plant is 200 mg/Nm3 NOx as NO2 (@6%O2). Applying an appropriate volume factor for coal of 364 m3/GJ (NCV) gives a projected emission factor of 72.8 g/GJ coal consumed. (Reference for the volume factor is Graham, DP, Salway G, Ray, P. Stack Gas Flow Rate Calculation for Emissions Reporting - Aguide to Current Best Practice for the Operators of Coal Fired Boilers.,PT/07/LC422/R May 2007

Needs re-wording eg. ..no surrogates available for source sectors, it is good practice to assume the projected value is the same as the latest historic yeear.

Including the impact of non-technical measures is mentioned. No guidance on how this quite complex task could be carried out.

Emission projections are always modelled "and" are based on….

The paragraph is listed under the headline "Uncertainties", however it seems to be referring to sensitivity, which is described from line 26.

Define CART and provide proper reference in reference list

Not a good examples because recent catalytst are not emitted higher NH3. Choose something simple e.g. aviation

A WoM scenario should not be listed as a necessary activity for compiling emissions projections.

change "be in accordance" to "have a methodology that is consistent"

Accepted

Accepted

AcceptedThis isn't a bullet point EditorialI note that Sectoral Overview of Methods has been cut Noted

Noted

Noted

Accepted

I think some more detail is required ie some sort of list refering to elements discussed in previous sections. eg. values and sources of activity data used, GF factors used, emission factors, details of tiers, sector definitions, sector stratification, assumptions made in deriving future EFs.

Again reference to QA/QC activities referred to in text- checking, energy balances, etc

Properly define reference for current guidebook EMEP/TFEIP (2003) etc

I expect there are similar interractions in transport eg projected air km and airccraft mix; vehicle km and vehicle mix.

Guidance for projections is very generic. The 2006 Guidance is more comprehensive

"The best practice principles for emission inventory compilation also apply for projections. Therefore the resulting projections will need to be transparent, accurate, consistent, complete, and comparable."


Amended

Not sure what this is referring to

Text amended

Self evident

track changed (page 2, lines 34-39)

Text amended

The current Guidebook credits the ETC/AE

The Task Force relies on, and is grateful for, contribution from a number of countries; it would be invidious to acknowledge all contributions.

The previous version referred only to Simple and Detailed methods, the text has been revised.

The current Guidebook credits the ETC/AE

Text amended to …countries that have ratified Convention Protocols

Text amended

Text amended.

Replaced All

Text amended

Text amended where possible

Compliance checking is already included. There is reference to suitability for monitoring. EMEP is now referenced directly.

Definitions are now based on the IPCC 2006 Guidelines.

A Note has been added to the Transparency definition

Section 3 Concepts are introduced in lines 7-9

Intorduction amended. N.B.Readers might rightly expect a glossary to be more comprehensive and Definitions is equally confusing in this context.

The comment is not relevant to this section of the Guidebook.

The Task Force relies on, and is grateful for, contribution from a number of countries; it would be invidious to acknowledge all contributions.

Replaced All

Replaced All

Added "it"

changed to 'is designed to cover'

Text amendment made

text removedText amended - no longer relevant

EMEP prefer LRTAP, NEC Directive used

Added "and category as defined in the repsective reporting requirements"

Not practical, would introduce too great a change to the style of the document.

Key Catgories are now a defied concept in section 3.

Footnote 2 added.

Paragraph deleted.

Text abridged

No longer relevant - text has been amended

No longer relevant - text has been amended

Footnote removed.

Text amended

No action taken, wherever possible the mention of time refereced events has been avoided for ease of future updating.

No action taken, wherever possible the mention of time relative events has been avoided for ease of future updating.

The Kiev protocol , while adopted in 2003, has yet to come intor force. No action taken, wherever possible the mention of time relative events has been avoided for ease of future updating.

Reference to to UNITAR and UNEP chemicals introduced.

Information not relevant to theGuidebook.

Text has been amended

Dublin text inserted

text removed

Reference to CEIP included

Text made more generic

Added "it goes beyond the requirements of the protocol, covering more pollutants with stricter thresholds"

Sentence changed due to earlier comment

Unecessary - this is 'additional information'. Guidance on using the Guidebook - and the link between NFR and SNAP is provided in both the Introduction and the section on how to use the Guidebook

Unecessary - this is 'additional information'.

The 1984 Protocol on Long-term Financing of the Cooperative Programme for Monitoring and Evaluation of the Long-range Transmission of Air Pollutants in Europe (EMEP); 42 Parties. Entered into force 28 January 1988.

Appendicies removed

Appendicies removed

Appendicies removed

Appendicies removed

Appendicies removed

Appendicies removedAppendicies removed

Appendicies removed

Appendicies removed

Appendicies removed

Appendicies removed

Changed title and headers

references have been revised

removals removed.

Text added

"Member States" already removed in favour of "Parties"

Text amended to make it generic and, as elsewhere in the text, mention of dated information subjet to regular review is avoided.

Title is included already in the heading box.

Text Deleted

Text Deleted

Text Deleted

Text will be clarified





Figure will be reproduced

Text changed

Text changed

Figure will be reproduced

This an improved version of the IPCC QA/QC chapter with more detailed guidance on inventory management.

Text changed

Text changed

Text changed

Text ammended

It was agreed in Dublin in October that a normation approach should not be applied and each pollutant evaluated in its own right. Accifiying potentials would only address a subset of pollutants and would not resolve the issue for other pollutants…

Do once other changes made so not to lose page reference





don't know what is meant by this comment..

Text ammended

Text ammended

Text ammended

Text ammended

Text ammended

Text ammended

Text ammended

text will be ammended








Example will be provided



It helps with the optional step 2 to have the pollutant as a column feature.

It helps with the optional step 2 to have the pollutant as a column feature.

The examples still illustrate the approach adaquately






Text clarified

It is now mentioned at the bottom of section 2.2

issue clarified in text. There are limited examples for Air Pollutant Key Cateogrit analysis..

it was agreed to move it ot an annex by the AEG and discussed in Dublin.

It is now mentioned at the bottom of section 2.2

will clarify

will clarify

will clarify

Updated contents table

Amended

P 2, lines 2&3 added

NOTE: not all EMEP members are EU members.

Amended

MS updated to Microsoft

Examples added

Amended

Edited where necessary

That was the idea.. To minimise the number of key categories. It was agreed to offer it as an option only..

Test amended to include specific mention of EUROSTAT and data reported under the E PRTR

Note added to Table 2.1 and reference included.

The Guidance for EPRTR is regime specific and not information of the same generic type as that in the text.

CEN standards are referred to as EN

Amended

Amended

Text added to P7 2.1.1.

Explanatory paragraph added.

Will re-assign

reference corrected

reference corrected

Added "of"

Overlap is meant as this describes the equation.corrention made to the font and the equation number.

note added

Checked

DoneCorrected

Done

Foot note added to explain Base Year.

Reference sections (main text as well as appendix) checked and completed

6 is chapter number, this is the format for table/figure numbering chosen.

Corrected

Corrected

Deleted

Corrected

Corrected

Done

Corrected








Text added

Text modified

Done

Done

Done

Done

Done

Done

Done

Done

Reference however should be to the UNFCCC reporting Guidelines here.

Copied definitions from the draft guidelines

Added a reference to the still draft 2007 Guidelines

We believe that in a text box like this one the suggestion to harmonize with the UNFCCC is useful; the laguage is a bit weekened though.

Done

text updated

It is good practice to …

Done

Done

Done

Done

Done

text removed

Done

Done

Done

Done

Done

Done

Present text is clear

Done

Replaced CRF by NFR in two checks. Made figure a bit larger. Explain large changes is the first of a different klind of checks. Therefore order not changed.

The GHG guidance here can provide support for air pollution inventories

It is included i nthe references

Done

Couldn't find it, reference removed

Done

Done

Do not understand this

Done

Done

Done

Done

Done

Is in data collection issues

See text box

Do not understand this

Justin might like to check

Reporting is ALSO required..

Reference moved to Reference list Needs new guidelines reference?

Can we change the chapter name?

GAINS is to be fed by national reported data, rather than the other way around.

Ijn our view this is exactly what is meant

Current heading is sufficient to include gridding.

Terms left in. GIS added

text deleted

text changed

text to be changed

text to be changed

This guidance will be included in the final version.

Aviation and National Navigation methods are already inccluded

This is supposed to include relevant terms used for the chapter.

Note added

text changed

text added

text added

text changed

text changed

text added

text added

Might want to check this is the best way - one of those links has already been updated!

text added

See above

will add

Changed all to Key Categories

Doesn't really make a difference

Need to ensure we respect the boundary between reporting and methodological guidance.

Ok but the underlying purpose of the Guidebook is certainly to assist with reporting (this is why for example it is structured to NFR which is a reporting requirement, and not a methodological requirement…). It is indeed strange that the chapter doesn't mention GNFR at all given this role of the GB. Some information/consideration of GNFR needs to be added.

Need to ensure we respect the boundary between reporting and methodological guidance.

Included footnote and reference in the reference section.

modified text to remove reference to technology

Text added to paragraph.

Text updated

Text left unchanged.

Text to be updated.

Some references will be included where they are available.

The description has been extended to include some proposed methodology for calculation (see somment in line 16 above.

1995 and 200 are possible starting years for a WOM scenario. Other years can be chosen.

Texted changed due to another comment

Texted changed due to another comment

Measures will be different for different MS. We can not be prescriptive about what measures belong where in the WM WAMs scenarios. The boundary for WM is clearly defined in the WM text inder items a- f.

Definitions will be brought into line. However, as this is the latest document in the evolution of our understanding there may be some enhancements to the definitions in this document over that of the Reporting Guidance.




Text added under 3.8Made more clear

Text in diagram will be changed.text added

text clarified

Updated

Text changed

text changed

Text Changed

Make text in the Tier 2 box read …..(or adaquate current emission factors)

Text definition of Adt changed to clarify that ADt is a sub source of ADn

Text definition of Adt changed to clarify that ADt is a sub source of ADn

Text added

Text added

Definition added

Text added thank you.

Text added to clarify.Changed with another comment

Text and reference added.

Text modified.

more appropriate text providedbullet replaced with more appropriate text.

Text modified.

text left the same

Example Added

Changed from another comment

Some text added.Some text added.

Paragraph moved

Paragraph moved

Text ammended

text changed

text changed

This example is good because it shows the linkages between different sectoral data for projections.

Changed by another comment to "or" based

Changed sentence to make more sense, not in exactly the way suggested.

text changed

text changed

text changed

text added

Additional note(s)

Will propose some text for this…

Will propose some text for this…

Chapter_Name NFR_Code

1 Energy industries 1.A.1.a 1 1 29 8

1 Energy industries 1.A.1.a 1 65

1 Energy industries 1.A.1 2 20 2 21


1 Energy industries 1.A.1 5 4




1 Energy industries 1.A.1 6 11 Energy industries 1.A.1 6 2




Chapter_ID

FromPage

ToPage

FromLine

ToLine




1 Energy industries 1.A.1.a 9 321 Energy industries 1.A.1.a 10 37 10 37

1 Energy industries 1.A.1.a 10 3 11 81 Energy industries 1.A.1.a 10 21

1 Energy industries 1.A.1.a 10







1 Energy industries 1.A.1.a 13 121 Energy industries 1.A.1.a 13 13





























1 Energy industries 1.A.1.b 29 11 29 13


1 Energy industries 1.A.1.b 29 26





1 Energy industries 1.A.1.b 30 301 Energy industries 1.A.1.b 31 21 Energy industries 1.A.1.b 31 3


1 Energy industries 1.A.1.b 33 71 Energy industries 1.A.1.b 34 33






















1 Energy industries 1.A.1.c 40 21 40 21



1 Energy industries 1.A.1.b 40 121 Energy industries 1.A.1 42 42






1 Energy industries 1.A.1 46 15 47 11 Energy industries 1.A.1.c 48 48 48 36




1 Energy industries 1.A.1.b 53






1 Energy industries 1.A







1 Energy industries 1.A.1

1 Energy industries 1.A.1

1 Energy industries 1.A.1.a




2 1.A.2 1 52

2 1.A.2 2 13 2 14

2 1.A.2 3 1 3 2

2 1.A.2 3 1 3 2

2 1.A.2.c 5 32 5 34

2 1.A.2 8 31 8 34

2 1.A.2 8 27 9 27

2 1.A.2 12 2 12 2

2 1.A.2 12 5 12 5

2 1.A.2 12 4 12 4

Manufacturing industries and construction (combustion)










2 1.A.2 12 4 12 4

2 1.A.2 13 2 13 2

2 1.A.2 13 5 13 5

2 1.A.2 13 1 13 1

2 1.A.2 13 1 13 1

2 1.A.2 13 4 13 4

2 1.A.2 13 1 13 2

2 1.A.2 13 47

2 1.A.2 14 2 14 2

2 1.A.2 14 5 14 5

2 1.A.2 14 1 14 1

2 1.A.2 14 1 14 1













2 1.A.2 14 1 14 1

2 1.A.2 14 4 14 4

2 1.A.2 14 14 48 4

2 1.A.2.a 15 13 15 13

2 1.A.2.a 15 11 20 4

2 1.A.2 15 49

2 1.A.2 15 10 11

2 1.A.2 16 16

2 1.A.2.a 16 3 16 3










2 1.A.2.a 16 6 16 6

2 1.A.2.a 17 7 17 7

2 1.A.2.a 17 2 17 4

2 1.A.2.a 17 2 17 4

2 1.A.2.a 17 5 17 8

2 1.A.2 18 18

2 1.A.2.a 18 2 18 2

2 1.A.2.a 18 1 18 2

2 1.A.2.a 18 1 18 2

2 1.A.2 18 19

2 1.A.2.a 19 3 19 3

2 1.A.2.a 19 1 19 3













2 1.A.2.a 19 1 19 3

2 1.A.2.a 19 1 19 3

2 1.A.2.b 20 2 20 4

2 1.A.2.b 20 2 20 4

2 1.A.2 20 26

2 1.A.2.b 20 1 27 3

2 1.A.2.b 21 1 21 3

2 1.A.2.b 22 1 22 3

2 1.A.2.b 22 1 22 3










2 1.A.2.b 22 1 22 3

2 1.A.2.b 22 1 22 3

2 1.A.2 22 25

2 1.A.2.b 23 1 23 3

2 1.A.2.b 23 1 23 3

2 1.A.2.b 24 1 24 3

2 1.A.2.b 24 1 24 3

2 1.A.2 24 27

2 1.A.2.b 25 2 25 4

2 1.A.2.b 25 2 25 4

2 1.A.2.b 25 2 25 4

2 1.A.2.b 26 1 26 3

2 1.A.2.b 27 1 27 3

2 1.A.2.d 28 2 28 4















2 1.A.2.d 28 1 29 5

2 1.A.2.d 29 3 29 5

2 1.A.2.d 29 1 29 2

2 1.A.2.d 29 1 29 2

2 1.A.2.d 29 3 29 5

2 1.A.2 29 4

2 1.A.2.f.i 30 1 30 1

2 1.A.2.f.i 30 3 30 5

2 1.A.2.f.i 30 2 31 4










2 1.A.2.f.i 30 2 31 4

2 1.A.2.f.i 31 2 31 3

2 1.A.2.f.i 31 2 31 3

2 1.A.2.f.i 32 1 35 4

2 1.A.2.f.i 32 3 35 3

2 1.A.2.f.i 32 3 35 3

2 1.A.2.f.i 32 1 35 4

2 1.A.2.f.i 33 3 33 5

2 1.A.2.f.i 33 3 33 5

2 1.A.2.f.i 34 1 34 3

2 1.A.2.f.i 34 1 34 3












2 1.A.2 35 35

2 1.A.2.f.i 35 1 35 3

2 1.A.2.f.i 35 3

2 1.A.2.f.i 36 1 39 3

2 1.A.2.f.i 36 1 39 3

2 1.A.2.f.i 37 1 37 3

2 1.A.2.f.i 37 1 37 3

2 1.A.2 37 2

2 1.A.2.f.i 38 2 38 2










2 1.A.2.f.i 38 2 38 2

2 1.A.2.f.i 40 1 40 4

2 1.A.2.f.i 40 1 41 2

2 1.A.2.f.i 40 1 41 2

2 1.A.2.f.i 41 1 41 2

2 1.A.2.f.i 41 1 41 2

2 1.A.2.f.i 42 3 42 3

2 1.A.2.f.i 42 3 42 3









2 1.A.2.f.i 42 1 43 3

2 1.A.2.f.i 42 1 43 3

2 1.A.2.f.i 43 1 43 3

2 1.A.2.f.i 44 1 46 3

2 1.A.2.f.i 44 1 48 3

2 1.A.2.f.i 45 2 45 2

2 1.A.2.f.i 45 2 45 2

2 1.A.2.f.i 46 1 46 3

2 1.A.2.f.i 46 1 46 3

2 1.A.2.f.i 47 3 47 3

2 1.A.2.f.i 47 3 47 3












2 1.A.2.f.i 47 1 48 3

2 1.A.2.f.i 47 1 48 3

2 1.A.2.f.i 48 1 48 3

2 1.A.2 51 10 51 10

2 1.A.2 51 10 52 1

2 1.A.2 52 52

2 1.A.2 52 2 52 4








2 1.A.2

2 1.A.2.a

2 1.A.2.f.i

2 1.A.2.f.i

2 1.A.2.f.i






2 1.A.2.f.i

2 1.A.2.f.i

2 1.A.2.f.i

2 1.A.2.f.i

2 1.A.2.f.i

2 1.A.2.f.i







2 1.A.2.f.i

2 1.A.2.f.i

2 1.A.2.f.i

3 Civil aviation 1.A.3.a 1 13 Civil aviation 1.A.3.a 2 5 2 5

3 Civil aviation 1.A.3.a 2 9 2 17


3 Civil aviation 1.A.3.a 3 14





3 Civil aviation 1.A.3.a 5






3 Civil aviation 1.A.3.a 7 2 7 33 Civil aviation 1.A.3.a 7 9 7 10










3 Civil aviation 1.A.3.a 13 32 14 133 Civil aviation 1.A.3.a 14 29 14 32






















3 Civil aviation 1.A.3.a 22 12 23 83 Civil aviation 1.A.3.a 23




3 Civil aviation 1.A.3.a 25 43 Civil aviation 1.A.3.a 26 5 26 6


3 Civil aviation 1.A.3.a 26 9 273 Civil aviation 1.A.3.a 26 11










3 Civil aviation 1.A.3.a


















4 Road transport (exhaust) 1.A.3.b 1

4 Road transport (exhaust) 1.A.3.b 3 1 3 2

4 Road transport (exhaust) 1.A.3.b 3 3 3 174 Road transport (exhaust) 1.A.3.b 3 8 3 9

4 Road transport (exhaust) 1.A.3.b 3 13 3 144 Road transport (exhaust) 1.A.3.b 3 19 3 28



4 Road transport (exhaust) 1.A.3.b 3 3




4 Road transport (exhaust) 1.A.3.b 3 194 Road transport (exhaust) 1.A.3.b 3 204 Road transport (exhaust) 1.A.3.b 3 21

4 Road transport (exhaust) 1.A.3.b 3 304 Road transport (exhaust) 1.A.3.b 3 33


4 Road transport (exhaust) 1.A.3.b 4 24 Road transport (exhaust) 1.A.3.b 44 Road transport (exhaust) 1.A.3.b 4 9

4 Road transport (exhaust) 1.A.3.b 6 29 6 304 Road transport (exhaust) 1.A.3.b 6 74 Road transport (exhaust) 1.A.3.b 6 35




4 Road transport (exhaust) 1.A.3.b 8 14 Road transport (exhaust) 1.A.3.b 8 13 8 13



4 Road transport (exhaust) 1.A.3.b 8 12 15 34 Road transport (exhaust) 1.A.3.b 11 2 11 24 Road transport (exhaust) 1.A.3.b 12 2 12 24 Road transport (exhaust) 1.A.3.b 13 2 13 24 Road transport (exhaust) 1.A.3.b 15 3 15 34 Road transport (exhaust) 1.A.3.b 15 3







4 Road transport (exhaust) 1.A.3.b 35 9 35 104 Road transport (exhaust) 1.A.3.b 35 16 35 164 Road transport (exhaust) 1.A.3.b 35 16







4 Road transport (exhaust) 1.A.3.b.iii 53 25 54 344 Road transport (exhaust) 1.A.3.b 53 34 Road transport (exhaust) 1.A.3.b 53 8




4 Road transport (exhaust) 1.A.3.b.iii 63 26 65 29









4 Road transport (exhaust) 1.A.3.b











5 Road transport, gasoline evaporation 1.A.3.b.v 1 31

5 Road transport, gasoline evaporation 1.A.3.b.v 2 12 2 14





5 Road transport, gasoline evaporation 1.A.3.b.v 2
























5 Road transport, gasoline evaporation 1.A.3.B.V 5 3 20 1







































5 Road transport, gasoline evaporation 1.A.3.b.v






6 1.A.3.b.vi 1

6 1.A.3.b.vi 2 10 2 15

Road transport, automobile tyre and brake wear and road abrasion


6 1.A.3.b.vi 2 23 2 25

6 1.A.3.b.vi 2 10

6 1.A.3.b.vi 2 14

6 1.A.3.b.vi 2 17

6 1.A.3.b.vi 5 20

6 1.A.3.b.vi 6 3

6 1.A.3.b.vi 7 33

6 1.A.3.b.vi 10 9 12 1

6 1.A.3.b.vi 10 10

6 1.A.3.b.vi 11 1 12 1











6 1.A.3.b.vi 12 1 13 27

6 1.A.3.b.vi 13 34

6 1.A.3.B.VI 14 6 28 5

6 1.A.3.b.vii 14

6 1.A.3.b.vii 14 13

6 1.A.3.b.vi 14

6 1.A.3.b.vi 14

6 1.A.3.b.vi 14 15

6 1.A.3.b.vii 15 16

6 1.A.3.b.vi 15 21 16 2

6 1.A.3.b.vi 15 21 16 2

6 1.A.3.b.vi 15 12

6 1.A.3.b.vi 15 15

6 1.A.3.b.vi 15 19

6 1.A.3.b.vii 16 18

6 1.A.3.b.vi 16 6

















6 1.A.3.b.vi 16 20

6 1.A.3.b.vi 17 6 17 8

6 1.A.3.b.vii 17 23

6 1.A.3.b.vi 17 14

6 1.A.3.b.vi 17 14

6 1.A.3.b.vi 17 16

6 1.A.3.b.vi 17 22

6 1.A.3.b.vii 24

6 1.A.3.b.vii 25

6 1.A.3.b.vii 26

6 1.A.3.b.vi 26 11

6 1.A.3.b.vi 26 18

6 1.A.3.b.vi 27 4














6 1.A.3.b.vi 28 1

6 1.A.3.b.vii 29 13 29 18

6 1.A.3.b.vi 29 2 29 3

6 1.A.3.b.vi 30 30

6 1.A.3.b.vi 60 6

6 1.A.3.b.vii

6 1.A.3.b.vii

6 1.A.3.b.vii

6 1.A.3.b.vii

6 1.A.3.b.vii

6 1.A.3.b.vi












6 1.A.3.b.vi

6 1.A.3.b.vi7 Railways 1.A.3.c 4 16

7 Railways 1.A.3.c 6 15 6 21

7 Railways 1.A.3.c 6 13 8 1

7 Railways 1.A.3.c 6 97 Railways 1.A.3.c 6 13

7 Railways 1.A.3.c 6 20

7 Railways 1.A.3.c 7 18 7 24

7 Railways 1.A.3.c 7 29 7 327 Railways 1.A.3.c 7 2


7 Railways 1.A.3.c 8 2 9 2


7 Railways 1.A.3.c 97 Railways 1.A.3.c 9

7 Railways 1.A.3.c 10 29 10 29

7 Railways 1.A.3.c 10 29 10 29

7 Railways 1.A.3.c 11 20 11 24



7 Railways 1.A.3.c 11 28 11 28

7 Railways 1.A.3.c 11 20 11 24

7 Railways 1.A.3.c 11 28 11 28

7 Railways 1.A.3.c 11 25 11 28


7 Railways 1.A.3.c 12 25 12 37

7 Railways 1.A.3.c 12 2 12 27 Railways 1.A.3.c 12 8 12 8

7 Railways 1.A.3.c 12 22 12 22

7 Railways 1.A.3.c 12 2 12 27 Railways 1.A.3.c 12 8 12 8

7 Railways 1.A.3.c 12 22 12 22

7 Railways 1.A.3.c 12 23 15 137 Railways 1.A.3.c 14 77 Railways 1.A.3.c 15 7

7 Railways 1.A.3.c 16 1 16 1

7 Railways 1.A.3.c 16 1 16 1

7 Railways 1.A.3.c

7 Railways 1.A.3.c

8 1.A.3.d 3

8 1.A.3.d 4 32 4 42

Inter(national) navigation, national fishing


8 1.A.3.d 4 32 4 42

8 1.A.3.d 5 2 5 11

8 1.A.3.d 5 15 5 17

8 1.A.3.d 5 15 5 17

8 1.A.3.d 5 24

8 1.A.3.d 6 27 6 19

8 1.A.3.d 7 20 7 29

8 1.A.3.d 10 11

8 1.A.3.d 11 16 11 18

8 1.A.3.d 11 16 11 18











8 1.A.3.d 11 18

8 1.A.3.d 11 18

8 1.A.3.d 11 21

8 1.A.3.d 35 6 35 14

8 1.A.3.d 35 6 35 14

8 1.A.3.d 35 10

8 1.A.3.d 35 10

8 1.A.3.d 36

8 1.A.3.d 36

8 1.A.3.d 36

8 1.A.3.d 36

8 1.A.3.d 37

8 1.A.3.d 37

8 1.A.3.d 38

8 1.A.3.d 38

8 1.A.3.d 39 8

8 1.A.3.d 39 31

8 1.A.3.d 39 8

8 1.A.3.d 39 31

8 1.A.3.d 39

8 1.A.3.d 40 1 40 3

8 1.A.3.d 40 24 40 27

8 1.A.3.d 40 1 40 3
























8 1.A.3.d 40 24 40 27

8 1.A.3.d 47 4 48 2

8 1.A.3.d 47 4 48 2

8 1.A.3.d 48 6 48 11

8 1.A.3.d 48 6 48 11

8 1.A.3.d 48 49

8 1.A.3.d 48 26








8 1.A.3.d 49

8 1.A.3.d 50 34 51 28

8 1.A.3.d 50 34 51 28

8 1.A.3.d 53 1 53 1





8 1.A.3.d 53 1 53 1

8 1.A.3.d 53 1

8 1.A.3.d 53 1

8 1.A.3.d

8 1.A.3.d






8 1.A.3.d

8 1.A.3.d



8 1.A.3.d

8 1.A.3.d

8 1.A.3.d

8 1.A.3.d

8 1.A.3.d

8 1.A.3.d

8 1.A.3.d

8 1.A.3.d

8 1.A.3.d

8 1.A.3.d

9 Pipeline compressors 1.A.3.e.i

10 Small combustion 1.A.5 1











10 Small combustion 1.A.4 2 23 2 23

10 Small combustion 1.A.4 2 2





10 Small combustion 1.A.4 4 710 Small combustion 1.A.4 5 36 5 36















10 Small combustion 1.A.4.b.i 19 10 19 15


10 Small combustion 1.A.4 19




10 Small combustion 1.A.4.b.i 21 22





















10 Small combustion 1.A.4.a.i 37 1 37 4










10 Small combustion 1.A.4 89 1 89 610 Small combustion 1.A.4 90 1 95 1


10 Small combustion 1.A.4.a.i 95 1 95 9

10 Small combustion 1.A.4



10 Small combustion 1.A.410 Small combustion 1.A.4

10 Small combustion 1.A.4.b.i


11 1.A.2.f.ii 9 24 9 26

11 1.A.2.f.ii 13 10 13 13

11 1.A.2.f.ii 13 15

11 1.A.2.f.ii 14

11 1.A.2.f.ii 15

11 1.A.2.f.ii 16

11 1.A.2.f.ii 17

11 1.A.2.f.ii 22 6 22 8

11 1.A.2.f.ii 23 11

11 1.A.2.f.ii 23 13

11 1.A.2.f.ii 28 31

11 1.A.2.f.ii 28 31

11 1.A.2.f.ii 37

11 1.A.2.f.ii 37 5

Non-road mobile sources and machinery














11 1.A.2.f.ii 38 16

11 1.A.2.f.ii 39 1

11 1.A.2.f.ii 40 17

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii



















11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii




















11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

11 1.A.2.f.ii

12 Coal mining and handling 1.B.1.a 2 6 2 6










12 Coal mining and handling 1.B.1.a






13 Solid fuel transformation 1.B.1.b 9 14 9 14

14 Other (please specify) 1.B.1.c 2 10 2 10

14 Other (please specify) 1.B.1.c 2 10 2 10

15 1.B.2.b 2 13 2 13

15 1.B.2.a.i 5 7 5 7

15 1.B.2.a.i 5 9 5 9

15 1.B.2.a.i 5 26 6 25

15 1.B.2.b 9 15 9 17

15 1.B.2.b 12 12 12 17

15 1.B.2.b 12 15 12 17

15 1.B.2.a.i 14 6 14 6

15 1.B.2.a.i 14 4 14 4

15 1.B.2.a.i 15 1 15 3

Exploration production, transport of oil and natural gas










15 1.B.2.b 15 8 15 9

15 1.B.2.b 16 1 16 2

15 1.B.2.b 17 24 25 14

15 1.B.2.a.i 18 3 18 24

15 1.B.2.a.i 22 10 23 18

15 1.B.2.a.i 23 19 24 3

15 1.B.2.a.i 23 19 24 3

15 1.B.2.b 27 28

15 1.B.2.a.i

15 1.B.2.b

16 Refining / storage 1.B.2.a.iv 2 8


16 Refining / storage 1.B.2.a.iv 13 616 Refining / storage 1.B.2.a.iv 14 2 14 3


16 Refining / storage 1.B.2.a.iv 15 21 15 21





















16 Refining / storage 1.B.2.a.iv 21 1216 Refining / storage 1.B.2.a.iv 22 616 Refining / storage 1.B.2.a.iv 22 7



16 Refining / storage 1.B.2.a.iv 22 1816 Refining / storage 1.B.2.a.iv 22 23

16 Refining / storage 1.B.2.a.iv 23 2 23 516 Refining / storage 1.B.2.a.iv 23 1

16 Refining / storage 1.B.2.a.iv 24




16 Refining / storage 1.B.2.a.iv 2417 Distribution of oil products 1.B.2.a.v 1

17 Distribution of oil products 1.B.2.a.v 3 1

17 Distribution of oil products 1.B.2.a.v 4 27 4 2717 Distribution of oil products 1.B.2.a.v 4 2917 Distribution of oil products 1.B.2.a.v 4 33


17 Distribution of oil products 1.B.2.a.v 7 10 7 10

17 Distribution of oil products 1.B.2.a.v 7 917 Distribution of oil products 1.B.2.a.v 7 27


17 Distribution of oil products 1.B.2.a.v 8 1217 Distribution of oil products 1.B.2.a.v 8 1817 Distribution of oil products 1.B.2.a.v 8 2117 Distribution of oil products 1.B.2.a.v 8 3017 Distribution of oil products 1.B.2.a.v 8 3917 Distribution of oil products 1.B.2.a.v 9 217 Distribution of oil products 1.B.2.a.v 9 1117 Distribution of oil products 1.B.2.a.v 9 32

17 Distribution of oil products 1.B.2.a.v 11 8 12 1217 Distribution of oil products 1.B.2.a.v 11 17














17 Distribution of oil products 1.B.2.a.v 18 517 Distribution of oil products 1.B.2.a.v 18 1617 Distribution of oil products 1.B.2.a.v 18 21






17 Distribution of oil products 1.B.2.a.v 21 8 21 917 Distribution of oil products 1.B.2.a.v 21 1917 Distribution of oil products 1.B.2.a.v 21 21


17 Distribution of oil products 1.B.2.a.v 21 917 Distribution of oil products 1.B.2.a.v 22 12 22 19






18 Geothermal energy extraction 1.B.2.a.vi 3 31 3 33

18 Geothermal energy extraction 1.B.2.a.vi 4 3 4 418 Geothermal energy extraction 1.B.2.a.vi 4 11 4 11

18 Geothermal energy extraction 1.B.2.a.vi 5 1 5 1

19 Venting and flaring 1.B.2.c 4 17 4 26




19 Venting and flaring 1.B.2.c 8 11 9 719 Venting and flaring 1.B.2.c 9 1 9 7



19 Venting and flaring 1.B.2.c 10 20

19 Venting and flaring 1.B.2.c 11 319 Venting and flaring 1.B.2.c 12 20 12 21

19 Venting and flaring 1.B.2.c

19 Venting and flaring 1.B.2.c

20 Cement production 2.A.1 1 1 1 1

20 Cement production 2.A.1 1 18


















20 Cement production 2.A.1 13 1420 Cement production 2.A.1 16 13



20 Total industrial processes 2

20 Cement production 2.A.1






21 Lime production 2.A.2 8 2 8 2

21 Lime production 2.A.2 8 8

21 Lime production 2.A.2 8 1

21 Lime production 2.A.2 9 20 13 3

22 Limestone and dolomite use 2.A.3 1 4

22 Limestone and dolomite use 2.A.3 2 21 2 22






23 Soda ash production and use 2.A.4 1 6

23 Soda ash production and use 2.A.4 2 15 2 16




23 Soda ash production and use 2.A.4 4 1 4 223 Soda ash production and use 2.A.4 5 2 5 9



24 Asphalt roofing 2.A.5 1 1 1 1


24 Asphalt roofing 2.A.5 2 17







24 Asphalt roofing 2.A.5

25 Road paving with asphalt 2.A.6 1 1 19 19

25 Road paving with asphalt 2.A.6 4 2

25 Road paving with asphalt 2.A.6 7 15 8 3

25 Road paving with asphalt 2.A.6 13 3

26 2.A.7.a 1 5

27 Construction and demolition 2.A.7.b 3 11 4 4

27 Construction and demolition 2.A.7.b

28 2.A.7.c 3 24

28 2.A.7.c 4 15

28 2.A.7.c 6 16

Quarrying and mining of minerals other than coal

Storage, handling and transport of mineral products



29 2.A.7.d 1 37

29 2.A.7.d 1 1 37 1

29 2.A.7.d 3 32 3 34

29 2.A.7.d 4 5 4 7

29 2.A.7.d 5 22 5 22

29 2.A.7.d 7 38 7 41

29 2.A.7.d 11 19

29 2.A.7.d 12 31 12 34

29 2.A.7.d 14 21 14 22

29 2.A.7.d 15 6 15 8

29 2.A.7.d 18 4 18 8

Other mineral products (Please specify the sources included/excluded in the notes column to the right)











29 2.A.7.d 20 16

29 2.A.7.d 22 2 22 2

29 2.A.7.d 22 2 30

29 2.A.7.d 22 30

29 2.A.7.d 24 2 24 2

29 2.A.7.d 24 25

29 2.A.7.d 24 2 30 2

29 2.A.7.d 25 25

29 2.A.7.d 27 27










29 2.A.7.d 27 30

29 2.A.7.d 27 30

29 2.A.7.d 27 30

29 2.A.7.d 31

29 2.A.7.d 35 19

29 2.A.7.d 36 37

30 Chemical industry 2.B 2 9



30 Chemical industry 2.B 3

30 Chemical industry 2.B 3

30 Chemical industry 2.B.1 5 9 5 9







30 Chemical industry 2.B.2 6 1 6 130 Chemical industry 2.B.5.a 8 17 8 1730 Chemical industry 2.B 9 33 9 34




30 Chemical industry 2.B 13 5 13 5







30 Chemical industry 2.B.5.a 15 14 15











30 Chemical industry 2.B.5.a 24 7

30 Chemical industry 2.B.5.a 25 1 25 3





30 Chemical industry 2.B.5.a 30 1 31 330 Chemical industry 2.B.5.a 31 13 31 13




30 Chemical industry 2.B.5.a 36 4 36 430 Chemical industry 2.B 37 37




30 Chemical industry 2.B.5.a 39 1 330 Chemical industry 2.B.5.a 42 17 43 3






30 Chemical industry 2.B.5.a 46 1 330 Chemical industry 2.B.5.a 48 3 48 9











30 Chemical industry 2.B.5.a 53

30 Chemical industry 2.B.5.a 5330 Chemical industry 2.B.5.a 55 11 55 11

30 Chemical industry 2.B.5.a 57



30 Chemical industry 2.B 59 1 59 1930 Chemical industry 2.B 61 23



30 Chemical industry 2.B.1 63 2











30 Chemical industry 2.B.1

31 Iron and steel production 2.C.1 1 61







31 Iron and steel production 2.C.1 11 3631 Iron and steel production 2.C.1 12 17



31 Iron and steel production 2.C.1 14 11 15 9


31 Iron and steel production 2.C.1 18 931 Iron and steel production 2.C.1 21 6



31 Iron and steel production 2.C.1 22


















31 Iron and steel production 2.C.1 28 2831 Iron and steel production 2.C.1 28 12 28 13

















31 Iron and steel production 2.C.1

31 Iron and steel production 2.C.1

32 Ferroalloys production 2.C.2 1 6

32 Ferroalloys production 2.C.2 4 23 4 23

32 Ferroalloys production 2.C.2 4 22 4 23

33 Aluminium production 2.C.3 2 2


33 Aluminium production 2.C.3 10 1 10 2











33 Aluminium production 2.C.3 14


34 Copper production 2.C.5.a 1 16


34 Copper production 2.C.5.a 2 3 2 4











34 Copper production 2.C.5.a

34 Copper production 2.C.5.a34 Copper production 2.C.5.a












35 Lead production 2.C.5.b 1 21



35 Lead production 2.C.5.b 6 3 16 4











36 Nickel production 2.C.5.c 1 8


36 Nickel production 2.C.5.c 2 6 2 8





37 Zinc production 2.C.5.d 1 20


37 Zinc production 2.C.5.d 2 10 2 11






















37 Zinc production 2.C.5.d





38 2.C.5.e 1 8

38 2.C.5.e 4 4

38 2.C.5.e 7 7

Other metal production (Please specify the sources included/excluded in the notes column to the right)



39 2.C.5.f 2 9 2 9

40 Pulp and paper 2.D.1 2 15


40 Pulp and paper 2.D.1 5 1640 Pulp and paper 2.D.1 7 3740 Pulp and paper 2.D.1 13 740 Pulp and paper 2.D.1 13 7

40 Pulp and paper 2.D.1 16 2 16 2


40 Pulp and paper 2.D.1 17 3 17 3


40 Pulp and paper 2.D.1 18 3 18 3

40 Pulp and paper 2.D.1

41 Food and drink 2.D.2 11 2 12 2

41 Food and drink 2.D.2 11 24

41 Food and drink 2.D.2 16 7 16 7

41 Food and drink 2.D.2 17 3 17 4

41 Food and drink 2.D.2 17 5 17 741 Food and drink 2.D.2 18 4 18 4

41 Food and drink 2.D.2 22 24

43 Production of POPs 2.E 1 3

Storage, handling and transport of metal products (Please specify the sources included/excluded in the notes column to the right)

43 Production of POPs 2.E 1 1 3 1643 Production of POPs 2.E 3 3

43 Production of POPs 2.E43 Production of POPs 2.E

44 Consumption of POPs and HMs 2.F 1 1

44 Consumption of POPs and HMs 2.F 6 6

46 Paint application 3.A 3 9 3 14






46 Paint application 3.A 10 25 10 2646 Paint application 3.A 10 26 10 2646 Paint application 3.A 11 1 11 246 Paint application 3.A 11 1 11 2

46 Paint application 3.A 11 1 11 246 Paint application 3.A 11 1 11 246 Paint application 3.A 11 1 11 246 Paint application 3.A 11 1 11 246 Paint application 3.A 11 1 11 246 Paint application 3.A 11 1 11 246 Paint application 3.A 11 1 11 246 Paint application 3.A 11 1 11 2


46 Paint application 3.A 11 1












46 Paint application 3.A 16 1746 Paint application 3.A 16 22



















46 Paint application 3




46 Paint application 3.A




47 Degreasing 3.B.1 7 8

47 Degreasing 3.B

47 Degreasing 3.B.1

47 Degreasing 3.B.1

48 Dry cleaning 3.B.2 8 17 8 209

48 Dry cleaning 3.B.2

49 3.C 1 1

49 3.C 3 2 3 5

49 3.C 3 33 3 33

49 3.C 4 21 4 22

49 3.C 5 26

Chemical products, manufacture and processing





49 3.C 5 27 37

49 3.C 7 22 8 10

49 3.C 7 3

49 3.C 7 3

49 3.C 8 26 8 33

49 3.C 8 26 8 33

49 3.C 8 22 8 25

49 3.C 11 11

49 3.C 12 22 12 25

49 3.C 13 13

49 3.C 13 15

49 3.C 13 2 9

49 3.C 14 10 14 11

49 3.C 14 11 14 11















49 3.C 14 2 14 4

49 3.C 14 13 17 4

49 3.C 14 11

49 3.C 15 24

49 3.C 17 12

49 3.C 18 1 18 3

49 3.C 18 11 19 6

49 3.C 20 5

49 3.C

49 3.C

49 3.C

49 3.C













49 3.C

49 3.C

49 3.C

49 3.C

49 3.C

49 3.C

50 Printing 3.D.1 5 22 6 26

50 Printing 3.D.1 7 10

50 Printing 3.D.1 9 7 9 17

50 Printing 3.D.1 14 6 14 7

50 Printing 3.D.1 18 23

50 Printing 3.D.1







50 Printing 3.D.1

50 Printing 3.D.1

51 3.D.2 5 1 5 2

51 3.D.2 5

51 3.D.2 6 3 6 3

51 3.D.2 6 6 7 6

51 3.D.2 7 12 7 13

51 3.D.2 17 17 17 22

51 3.D.2

52 Other product use 3.D.3 4 22 4 22


52 Other product use 3.D.3 10 18


Domestic solvent use including fungicides









52 Other product use 3.D.353 Manure management 4.B 1 1 2 2

53 Manure management 4.B 1 1 2 2

53 Manure management 4.B 1 42



53 Manure management 4.B 3 6 3 653 Manure management 4.B 3 1 3 14














53 Manure management 4.B 3 15 4 953 Manure management 4.B 3 18


53 Manure management 4.B 3 2753 Manure management 4.B 3 27

















53 Manure management 4.B 5 2053 Manure management 4.B 6 753 Manure management 4.B 6 13

























53 Manure management 4.B 9 1 4

53 Manure management 4.B 10 1 10 253 Manure management 4.B 10 3 10 353 Manure management 4.B 10 3 10 353 Manure management 4.B 10 3 10 3





































53 Poultry 4.B.09 12 5 31 2


53 Manure management 4.B 12 553 Manure management 4.B 13 1 13 3


















53 Manure management 4.B 17 1453 Manure management 4.B 17 453 Manure management 4.B 18 1 18 1





































53 Manure management 4.B 22 16 22 1753 Manure management 4.B 22 6 22 753 Manure management 4.B 22 9 22 9





53 Manure management 4.B 22 353 Manure management 4.B 22 953 Manure management 4.B 22 16



















53 Manure management 4.B 24 1653 Manure management 4.B 24 753 Manure management 4.B 25 2 26 2







53 Poultry 4.B.09 30 5 30 5

53 Poultry 4.B.09 30 1 30 1

































53 Manure management 4.B 3953 Manure management 4.B 40 2 40 2



































53 Manure management 4.B 53




53 Manure management 4.B










53 Dairy cattle 4.B.01.a

53 Non-dairy cattle 4.B.01.b

53 Sheep 4.B.03

53 Goats 4.B.04

53 Horses 4.B.06

53 Swine 4.B.08

53 Poultry 4.B.09

53 Laying hens 4.B.09.a

53 Broilers 4.B.09.b

53 Turkeys 4.B.09.c

54 Agricultural soils 4.D 1 1 1 154 Agricultural soils 4.D.1 1 18

54 Agricultural soils 4.D 1 23

54 Agricultural soils 4.D 2 10 2 13

54 Agricultural soils 4.D 2 9 2 1254 Agricultural soils 4.D 2 17 2 19

54 Agricultural soils 4.D.1 2 12 2 13


54 Agricultural soils 4.D 254 Agricultural soils 4.D 2 32

54 Agricultural soils 4.D.1 2 4







54 Agricultural soils 4.D.1 3 6 5 1254 Agricultural soils 4.D 3 4 6 654 Agricultural soils 4.D 4 14 4 1454 Agricultural soils 4.D 4 6 4 6






54 Agricultural soils 4.D 4 1254 Agricultural soils 4.D 454 Agricultural soils 4.D.1 4 34

54 Agricultural soils 4.D.1 4 10 14














54 Agricultural soils 4.D.1 6 10 7 1454 Agricultural soils 4.D.1 6 19 7 8






54 Agricultural soils 4.D 6 10 14

54 Agricultural soils 4.D.1 6 1454 Agricultural soils 4.D.1 6 14







54 Agricultural soils 4.D.1 14 14 14 1554 Agricultural soils 4.D 14

54 Agricultural soils 4.D 14








54 Agricultural soils 4.D.1 18 31 23



54 Agricultural soils 4.D

54 Agricultural soils 4.D.1



54 Agricultural soils 4.D.254 Agricultural soils 4.D.2

54 Agricultural soils 4.D.255 Field burning of agricultural wastes 4.F 2 12

55 Field burning of agricultural wastes 4.F 2 2 1255 Field burning of agricultural wastes 4.F 3 15

55 Field burning of agricultural wastes 4.F 4 13 4 15


55 Field burning of agricultural wastes 4.F 4 15







55 Field burning of agricultural wastes 4.F 5 455 Field burning of agricultural wastes 4.F 5 1455 Field burning of agricultural wastes 4.F 5 10






55 Field burning of agricultural wastes 4.F

55 Field burning of agricultural wastes 4.F56 Agriculture other 4.G 1 1 1 1

56 Agriculture other 4.G 2 6 2 7

56 Agriculture other 4.G

56 Agriculture other 4.G

57 Solid waste disposal on land 6.A 1 457 Solid waste disposal on land 6.A 1

57 Solid waste disposal on land 6.A 2 4 2 457 Solid waste disposal on land 6.A 2 14 2 14

57 Solid waste disposal on land 6.A 2 14 2 1457 Solid waste disposal on land 6.A 2 3 2 357 Solid waste disposal on land 6.A 2 4 2 4

57 Solid waste disposal on land 6.A 2 30

57 Solid waste disposal on land 6.A 2 3057 Solid waste disposal on land 6.A 2 2 4

57 Solid waste disposal on land 6.A 3 4 3 5


57 Solid waste disposal on land 6.A 3


57 Solid waste disposal on land 6.A

57 Solid waste disposal on land 6.A

58 Waste-water handling 6.B 1 658 Waste-water handling 6.B 1 6

58 Waste-water handling 6.B 2 7 2 8










58 Waste-water handling 6.B 6 8

58 Waste-water handling 6.B





















59 Clinical waste incineration (d) 6.C.a 6 11

59 Clinical waste incineration (d) 6.C.a 7 13

59 Clinical waste incineration (d) 6.C.a 7


59 Clinical waste incineration (d) 6.C.a 13 4 13 459 Clinical waste incineration (d) 6.C.a 15


59 Waste incineration 6.C

60 Industrial waste incineration (d) 6.C.b 1 19


60 Industrial waste incineration (d) 6.C.b 8 16 8 18


60 Industrial waste incineration (d) 6.C.b 11 3 11 3




61 Municipal waste incineration (d) 6.C.c 3 3


61 Municipal waste incineration (d) 6.C.c 10 1061 Municipal waste incineration (d) 6.C.c 11 3 11 3



61 Municipal waste incineration (d) 6.C.c

61 Municipal waste incineration (d) 6.C.c62 Cremation 6.C.d 7 7

62 Cremation 6.C.d

63 Small scale waste burning 6.C.e 1 18



64 Other waste € 6.D 1 9





64 Other waste € 6.D 5

64 Other waste € 6.D 6 18 7 3

64 Other waste € 6.D

64 Other waste € 6.D67 Forest fires 11.B 1 13

Comment Action taken

Rejected None

Noted

Accepted HCB added to Table 1-1

Rejected

Editorial Done

Editorial Done

Editorial Done

Editorial Done2nd sentence: "IA1b" should read "1A1c". Editorial Done

Editorial Done

Noted

Noted

Proposed decision

The EFs are clearly inadequate and was evidently been reviewed by people with no or little experience in emission inventory compilation

The document is weak in discussing Flue gas treatment impacts on reducing emissions - it is not clear whether emission factors refer to abated or unabated emissions and which abatement technology is used. Also see Comment 10 on this sheet (only Sox and NOx abatement are discussed and no co-benefits)

Modified text to include more detail on PM, some additional detail on abatement added as an appendix

Table 1-1 has no mention of HCB despite that there is a reporting requirement for this substance.

Emissions from cracking and catalyst regeneration are includedin Chapter 1.B.2.a.iv. Suggest combine last 2 sentences to read: "Production processes such as thermal cracking and catalyst regeneration as well as fugitive emissions are covered in Chapter 1.B"

Text modified to clarify scope.

Add NFR code to title to maintain consistency with title 2.1

Insert "1.A.1.b" into section 2.2 title as per that for 2.1 for 1.A.1.a

This paragraph is unclear. Assumeable there should be a reference to 1A1c.

I can agree in general about the semplification in methodologies and in reference to BREEF but the previous release of the chapter was really interesting including a very good description of "combustion mechanism", so "Don't throw out the baby with the bath water"; I propose to maintain the old documentation in the new GB for example as an Appendix!


Some additional text included (on PM control) and selected information included as an appendix

Insert "1.A.1.c" into section 2.2 title as per that for 2.1 for 1.A.1.a

write: "…has typical combustion temperatures…leading to…"

For these paragraphs to be of any use they need to be expanded.

Some slight modifications but readers needing detail should consult BREF

"..up to about 20 MWth.." should read "..from about 20 MWth..."

Text modified to clarify scope.

Noted Text amended

Noted None

Accepted

NotedThe sentence "can achieve" is duplicate Editorial Done

Notedwrite: "…technology.." Editorial Done

Accepted

Noted

Noted None

Accepted Text amended


Not only solid and liquid fuels contains N, biomass should be included in the parentheses.

Natural gas fuelled stationary engines should be mentioned as a potential large emitter.

As usually in the text there are no data about pollutants concentration I propose to delete the paragraph "Mercury concentrations are reported to be in the range of 2 - 5 μg/m3 for natural gas [van der Most & Veldt, 1992, Umweltbundesamt, Germany, 1980]". Why Hg for natural gas and not other pollutants for other fuels?

Text modified to remove data.

Hg levels quoted for natural gas are too high; own data show a mean of about 100 ng/m³

Emission factor removed from text, no new referencable data from EP but previous guidebook factor adopted

The entire chapter on controls in this draft are excerpts from the existing guidebook, however it has been scaled back so that the usefulness has totally vanished.

Some additional text included (on PM control) and selected information included as an appendix

Impacts of control measures on SOx and NOx are discussed, but there is no discussion of particulate control and the co-benefit of these technologies on the reduction of e.g. metals

Short text added on PM abatement

As usually in the text there are no data about pollutants concentration I propose to delete the paragraph " The NOx reduction efficiency can be between 70 and 90 %." Otherwise efficiency must be reported for all technologies in an appropriate Table. This last option is most appropriate.

Some efficiency data from current guidebook chapter added as an appendix

The sentence "If detailed information is available, use it" is generic, I propose "if emissions data coming from continuous stacks measurement are available, use it; otherwise if information coming from periodic measurements are available use it in combination with other information"

The statement, that the default emission factors have been derived from all available data and information, seems rather bold when the vast majority simply refers to the existing guidebook.

Delete the sentence "have been derived from all available data and information"


Noted

Accepted Text amended Correct "sib-bituminous" to "sub-bituminous" Editorial Done

Noted None

Accepted

Editorial table fuels modified

Table 3-5: no Hg emission factor for natural gas. Discuss with EP 7/5/08

Accepted

Accepted Factors provided

Accepted

Discussed with EP 7/5/08

Accepted

Do the term vegetable waste equals agricultural waste?

There is no clear definition of the assumption (power input, technology, abatement) of the Tier 1 methodology. If, as stated, the factors are a simple mean I think this is not appropriate. We cannot evaluate the EFs without reference to a concept of "most used" technology.

Discussed with EP 7/5/08; some detail added and expansion of Tier 2 factors

Delete "have been derived from all available data and information".

We feel Petroleum Coke would be better classified under "hard coal" rather than heavy fuel oil, as it is a solid fuel

Tables 3-3-3-9 are not complete. Emission factors for PAH are shown without indication of species; emission factors for PCDD/F are shown with reference to EPA 1998 but there are a lot European-based data on dioxins emission; no EF for PCB and HCB for all fuels.

Discussed with EP 7/5/08, PAH now speciated, PCDD/F PCB and HCB added where available.

Inconsistencies in the terminology used to describe fuels in different tables

It should be indicated in the tables what TEF system (I-TEF or WHO-TEF) is used for dioxins & furans

Will change with new tables


Table 3-7- 3-9: no PCDD/F emission factors for heavy fuel oil, other liquid fuels and biomass. PAH emission factor for biomass should be checked.

Factors reviewed and modified as appropriate

tier 2 emission factors for stationary engines are missing

Tables 3-11, 3-12, 3-13, 3-14, 3-16, 3-17, 3-19, 3-20: emission factors are shown with reference to the Guidebook 2006. But Guidebook 2006 does not contain exactly the same emission factors; maybe they were recalculated - this should be indicated. Combustion emissions significantly depend on boilers power, but Tier 2 tables do not account this.

Tables revised, source of factors should now be clearer

Tables 3-11, 3-12, 3-13, 3-16, 3-17, 3-19, 3-20 (Tier 2) and Tables 3-3 -3-4 (Tier 1) include same emission factor for PCDD/F with reference to EPA 1998 – a lot of data available for PCDD/F emission from coal combustion in Europe.


No subdivision based on MWt of the plant are reported in Tier 2 methodology (the "old" GB reported this subdivision!); this subdivision can be more relevant that the subdivision between dry bottom and wet bottom reported in the new GB

Discussed with EP 7/5/08; size split retained

Noted

Noted Discussed with EP 7/5/08


Noted

Accepted

Noted

Noted

Noted

Noted Tables revised.

Noted Tables revised

Accepted Tables revised



No subdivision based on technology of combustion (low NOx burner - staged air supply o overfire air) of the plant are reported in Tier 2 methodology (the "old" GB reported this subdivision!); this subdivision can be more relevant that the subdivision between dry bottom and wet bottom reported in the "new" GB

Discussed with EP 7/5/08, some text on abatement efficiency retained as an appendix to maintain information

No complete subdivision based on configuration of burner (wall or tangential) are reported in Tier 2 methodology (the "old" GB reported this subdivision!); this subdivision can be more relevant that the subdivision between dry bottom and wet bottom reported in the "new" GB

No control system specification in Tier 2 methodology (the "old" GB reported this information!);

Unclear NOx emission factors and undefined references, for example for coal the EF is too low compared with the methodology of "old" GB see Table 25 of the B11 chapter. For natural gas the EF is to high compared with the methodology of "old" GB see Table 24 of the B11 chapter controls?

Some factors modified by extension to Tier 2 tables

Unclear SOx emission factors (% S in fuel? ash content in coal?) controls?

Text now includes calculation from fuel S

Unclear CO, COV, HM emission factors, no reference with "old" GB

Some factors modified by extension to Tier 2 tables

PM emission factors unacceptable for Tier 2. In US EPA for example a Dry bottom plant burning Coal with no control has EF = 398,7 while the same plant with baghouse has EF = 3,5. "New" GB (CEPMEIP) report EF = 26. What is the assumption! What is the control system? How can be used this emission factor in Sweden and Albania? How can be used to evaluate future emissions?

Tier 2 factors are now as used in guidebook supplements from 2005/6

CONCLUSION the tables are unclear and unusable, the "interpretation" of the "old" GB EF is an unacceptable simplification

Discussed with EP 7/5/08. More of old guidebook retained.

Table 3-13 (Tier 2): PM and HM emission factors are the same as in the Table 3-4 (Tier 1).

Table 3-15 (Tier 2): emission factors are the same as in the Table 3-5 (Tier 1); no Hg emission factor.

Table 3-18: no PCDD/F emission factors for wood and similar wood wastes.

Table 3-17 (Wet Bottom Boilers) and the Table 3-12 (Dry bottom Boilers): the same emission factors for all technologies - this is not correct.

Table 3-21: no PCDD/F emission factors for wood and similar wood wastes.

Editorial

Editorial

Editorial

Editorial

Accepted Reference included


Noted Discuss with EP 7/5/08

Accepted Done

Accepted Done

Accepted Done

Accepted Done

Accepted Done

Accepted DoneDelete ")" after "V" Editorial DoneAdd "[Concawe, 2007]" after "Concawe" Accepted Done

Noted

Accepted DoneAdd "in Appendix B" after "...comparison" Accepted Done

Rejected

This table 3-22 is an exact duplicate of table 3-24 in chapter 1A4, including the mistake of having a negative TSP emission factor.


In the "Not estimated" list of Table 3-22, PAH's should be deleted


In the "Not estimated" list of Table 3-23, SOx should be deleted


In the "Not estimated" list of Table 3-24, PM should be deleted


Even though this report is a draft version there should not be incomplete references to other chapters, unless the intent is to purposely annoy the reader. This is a recurring problem several times in this draft version.

The industry emission reporting guidance does not provide anydetails of the technologies. Delete "and the industry emissionreporting guidance [Concawe, 2007]".

CONCLUSION the tables are unclear and unusable, the only complete work by Concawe was not used

For guidance add "-see Chapter 1B2c" after "....activities"

For guidance add "-see Chapter 1B2a.iv" after "....units"

For guidance add "-see Chapter 1B2a.iv" after "....releases"

For guidance add "-see Chapter 1B2a.iv" after "....emissions"

Change "reduced" to "eliminated" as NH3 is fully converted

For guidance add "-see Chapter 1B2a.iv" after "....units"

There is a specific paper by Concawe (Report no. 9/05R "Air pollutant emission estimation methods for EPER and PRTR reporting by refineries (revised)") that the consultant don't take into consideration and use an undefined reference US EPA (2000)

Table has been revisited and incorporates Concawe and other sources

Delete "grouped by major fuel types" as only refinery gas EF's given.

Add new paragraph: "Concawe has published a compilation ofrecommended emission factors for reporting by refineries under the E-PRTR requirements [Concawe, 2007]. For combustion the majority of these factors are equivalent to a Tier 2 approach."

Application of these factors by refinery operators is on a facility basis - inclusion of this statement may preclude acceptability of this data at Tier 3

Accepted Done

Noted Text revised

Accepted

Noted

Noted

Following on from comment above, it is proposed that the followingis added after "combustion" at the end of line 34: "units e.g. boilers and process heaters and 'furnaces';"


Tables: - EF for SOx: Providing a fixed EF for SOx does not permitthe benefits of the reduction in fuel sulphur content by refineriesto be captured in inventories. Member State authorities can obtain the mass and average sulphur content of fuels used in refineries, soa simple algorithm should be provided in Tier 2 instead of fixed EF.

Text modified, where member States have facility specifc data they should incorporate in their inventories. Tier 2 could be refinery-specific but this is still an aggregated activity level.

Tables: - there should be consistency in the number of significantfigures used for emission factors. Two significant figures should beused for Tier 2. In Table 4-3 some EF's are given with very high accuracy (e.g. SOx = 349.9) whereas others e.g. heavy metals arerounded to only one significant figure.


Tables: - calculation of upper and lower 95% confidence limits. The calculation of limits in these Tables do not appear to follow the guidance in the cross-cutting Chapter on uncertainities. For example, an EF with Corinair code C would have 95% limits of100% of the EF value (range 50% to 200% - 100% taken as default). Where Concawe has made comments on EF's the upper and lower limit values have been calculated according to these guidelines.

limits revised in updated tables

Table: EF references - there are a number of references to "Guidebook (2006)" and "Guidebook (2006), US EPA (2000)". Concawe strongly considers that an EF derived in some manner (e.g.by taking geometric mean) of upper and lower limit values of a range,as quoted in the Guidebook, should NOT be used where a publishedEF is available from a well established source (e.g. AP-42) whichhas been computed from a large number of measurements. Such a mean value has more scientific basis than one derived from valuesat either end of spread for which the distribution is unknown. That technique is accepted as being valid only where an EF derivedfrom a number of measurements made in the same way is notavailable.

None, but revision of emission factor tables has been done

Noted Text clarified

Noted None

Noted

Noted

Noted

Table Titles: Tables 4-3 through 4-7 all refer solely to "heaters". Thereare other combustion units in refineries e.g. CO boilers, fired waste heat boilers, etc. and heaters are often called 'process furnaces'(see, e.g, text in section 4.1.2) although there is no contact betweenthe fuel and process material.It is proposed, therefore, to help clarify what the EF's are for, the term"Heater" in the titles of the Tables is changed to "Combustion Unit".

Add new paragraph for clarity: "All the Tier 2 emission factorsprovided in Tables 4-3 to 4-8 are for unabated emissions. To estimate emissions where abatement systems are installed, informationon abatement system efficiencies is available in the Refinery BREF[EIPPCB, 2003]". (However, see comment on p 39, line 3)


See earlier note on Concawe report





Rejected

Noted

Noted

Noted

Noted

Comment on table 4-8:- the emission of NMVOC is dependent on the fuel gas composition- in the USA VOCs (that means non methane / non ethane hydrocarbons) are regulated and NOT NMHC (non methane Hydro carbons)- the LCP BREF document 2006 mentions only formaldehyde as hydrocarbon- RECOMMENDATION: the figues on NMVOC in table 4-8 should be taken out and a general comment on the fuel dependancy relating to this emmitent has to be put in the table. Otherwise the figures will lead to big misunderstandings.

We accept that the emission is dependent on fuel composition but combustion and lubricants are also relevant. We also accept that USEPA VOC figure also excludes ethane however, in the absence of other data, it provides a reasonable value for nmVOC. An alternative would be to apply the the USEPA TOC figure. At least one member state applies an emission limit for formaldehyde but inventory is about total nmVOC not individual components.

The value for NOX in the table 4-8 (100 g/GJ) is about 120 mg/Nm3 (at 15% O2). This is about 320 mg/Nm3 at 5% O2. This is far away from the industry recommendation that has been given in the LCP BREF. There it was recommended to introduce 190 mg/Nm3 at 15% O2 for lean burn SG gas engines. This is about 160 g/GJ.

RECOMMENDATION: - correct the value according to industry recommendation. - Furthermore introduce a span for the NOx value.- A value for gas engine that are operated in the gas-diesel-mode is missing. This value has also to be integrated.

The guidebook is not reflecting BAT.





Wrong NFR, it's no clear what table refer! It's crude oil combustion? Where? In a process furnace?

Table 4-9 appears to belong to NFR 1A1c (as shown in table "code"box.


Noted Done where possible


Noted

Editorial

Noted

Done where possible

All the Tier 2 emission factors are for unabated emissions. It wouldbe useful to provide a table of abatement system efficiencies (c.f.tables in 1.B.2.a.v and 1.B.2.a.iv) after the Tier 2 EF tables.

Subchapter 5 1A1c Manufacture of solid fuels: the title and content are not harmonized; only coke manufacture is described.

This section may be misleading. If a refinery has used the Concaweguidance [Concawe, 2007], then the data do not require a QA/QC check as the EF's used would be from well recognised and accepted sources such as EPA AP-42. If facility PRTR data are extrapolated to derive national inventories, there is the danger of serious errors as both the EPER and E-PRTR reporting schemesinclude thresholds. It is proposed that the second and third sentences are switched, text extended and the rest deleted:Thus: "Refinery installations are major facilities and emission data forindividual plants may be available, but possibly for only a limitednumber of pollutants, through a PRTR or another national emission reporting scheme. When the quality of such data is assured by a well developed QA/QC system, it is good practice to use such data.Guidance on estimating refinery emissions has been publishedby the industry sector [Concawe, 2007]"

Tect amended to partly reflect comment.

The heading for this chapter misses the second part "Other energy industries"

Have put in those from old guidebook POPs chapter

CONCLUSION the tables are unclear and unusable

Have put in those from old guidebook POPs chapter

This chapter is very thin. Under "Techniques" only coke manufacture is mentioned. The existing guidebook does not have a separate chapter on neither 1A1b nor 1A1c, this would have been an excellent time to improve that aspect, alas nothing has been done.


RejectedFigure 5-1: error in the title. Editorial Done

Editorial Figure title amended



Done


NotedAppendix B not Appendix 2 Editorial Done

Accepted Revised

It is proposed that there is an additional paragraph on NOx estimation using facility data. "NOx formation is very complex, anddepends on a number of parameters e.g. hydrogen and moisture contents, pre-heat temperature, burner intensity, etc. Amethodology to calculate NOx emissions has been published (in theOil and Gas Journal) and provided in Concawe, 2007 as the recommended method for refineries to use for emission reporting. Where facility data are available, this detailed methodology should beused to obtain more accurate NOx estimates than the fixed value emission factor provided in the Tier 2 approach."

The chapter already refers the reader to Concawe guidance for Tier 3. Additional reference or highlighting of specific pollutants is not necessary.

The decision tree is obviously similar to the one for petroleum refining, however the figure text should reflect the correct chapter.

There is no clear definition of the assumption (power input, technology, abatement) of the Tier 1 methodology. If as stated the factors are a simple mean I think this is not appropriate. We cannot evaluate the EFs without reference to a concept of "most used" technology.

In the tables 5-3, 5-4 not estimate selenium and Heavy metals. It is not correct, because HM includes Se.The same problem for PAH as for other combustion (only summary EF, not by pollutants)

There is no clear definition of the assumption (power input, technology, abatement) of the Tier 1 methodology. If as stated the factors are a simple mean I think this is not appropriate. We cannot evaluated the EFs without reference to a concept of "most used" technology. Only very poor list of pollutants take into account. ? Other liquid fuel?


There is no clear definition of the assumption (power input, technology, abatement) of the Tier 1 methodology. If as stated the factors are a simple mean I think this is not appropriate. We cannot evaluated the EFs without reference to a concept of "most used" technology. Only very poor list of pollutants take into account. ?

Very useful table, however there is no need to separate emissions from GT and gas engines last. The order of the pollutants is also strange, SO2, NOx TSP would be the logical order.

GT and engines moved, no other comments on pollutant order so not changed

This glossary should either be expanded or removed. Some listings in the glossary do not appear previously in the text.

Accepted

Update the reference to the EURELECTRIC guide Editorial Revised

Editorial

Accepted note added to tables

Noted None

Considering the number of times "Guidebook (2006)" is referenced in the text it is quite an accomplishment to have it excluded from the list of references.

References amended - Guidebook 2006 generally replaced by original ref.

Reference list: There are references given in the EF tables of "USEPA (1998)", "US EPA (2000)" and "US EPA (2003)". There areonly two US EPA references in the Reference List, and one of these is for 1987. The other is undated. The Reference List needs toreflect the references in the text and tables.

References will be rationalised

Need to define the calculations & assumptions used to convert emission concentrations into EF and make sure that they are consistent with Appendix C

The NOx values from the Gothenburg Protocol are listed in table B4.These values should be taken out as there os a political decision to review the Gothenburg Protocol. Furthermore these values (for diesel engines) are far beyond BAT.See also:http://www.euromot.org/download/news/positions/stationary_engines/UNECE_CLRTAP_ABC_Analysis_080403.pdf

http://www.euromot.org/download/news/positions/stationary_engines/EIPPCB_BREF_euromot_comment_may_02.pdf

In these position papers emission limit values are recommended. We propose to overtake those emission limit values in table B4.

Noted

Noted

Rejected


Noted References revised

The given BREF NOX value for new and existing stationary gas engines in the table B4 is too low. Correct span should be 20-190 mg/Nm3. Please compare the emission table of the General Environmental Health and Safety (EHS) Guidelines of the World Bank. World Bank has implemented emission limit values that are depending on the engine type, the used fuel, the positioon of the engine etc. We support this strategy as it refers on different emission limit values that are depending of different surrounding operation factors. These factors are also depending on the infrastructure around the engine (water, reagents, fuel quality, etc.).

Please compare page 7 of the document under the following link:

http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/gui_EHSGuidelines2007_GeneralEHS/$FILE/Final+-+General+EHS+Guidelines.pdf

We recommend to distinguish the emission limit values for different engine types.

The range indicated in the comment reflects industry view of BAT; the table is intended to summarise the main BREF AELs and cannot reflect all comments/notes to the Table.

An O2 concentration of 21% instead of 20,9% seems more common; e.g. 21% is used in the informative appendix E of EN 14181

Some sources use 21 (for example standardisation of emission concentrations in the Waste Incineration Directive which, as with the LCPD, includes requirements on CEMS uncertainty and hence was a driver for EN14181), USEPA Method 19 and others use 20.9 for corrections and some others apply values between these figures (for example 20.95 or 20.96). Difference is minor.

convert US EPA method 19 in SI units or replace it by the IEA correlations

units are dscm/J or, dry m3/J

I could not find any HCB emission factors for coal and wood combustion or other relevant sources. See http://reports.eea.europa.eu/EMEPCORINAIR5/en/Sources_of_HCB_emissions.pdf.

Many EF-references are of kind "(Guidebook 2006)". I suggest to refer to original references from the Guidebook 2006.

Noted






Accepted Additional text added

Noted Table included

Noted

Noted

The units in the emission factor tables should be changed depending on pollutant. Main pollutants and particles could be kept in g/GJ, while metals could be listed in mg/GJ, PAH in mikrogram/GJ or mg/GJ and dioxin and other POP's in ng/GJ.

Noted and some factors have been modified

In the chapters concerning stationary combustion there are only given a default emission factor for PAH. But for reporting purposes individual emission factors are needed for the 4 different PAH's.

In the existing guidebook information on the 4 different PAH's is available. A combined PAH emission factor is somewhat useless considering the reporting requirements.

There are a general lack of HCB emission factors in this chapter. It seems that only under waste incineration is an emission factor for HCB provided.

The existing guidebook has a specific chapter on HCB, (and PCB), it would be appropiate if the data in these existing chapters were included and expanded in this revised guidebook.

A lot of the emission factors references to Guidebook 2006 does not seem to correspond correctly.

E.g. NOx emission factor for DBB residual oil listed in table 3-14 as 300 g/GJ. In the existing guidebook the NOx emission factor for residual oil varies between 150 and 296 g/GJ

make clear that Emission factors refer to net calorific values

The emission factors for the stationary gasengines totaly missing.

No mention of stationary engines in the Methods chapter!

If the authors could not be bothered to write something new, they could at least have copied all the text from the existing guidebook.

Accepted

Noted Some modification to text

Accepted

Accepted

Noted

Noted None

Noted Text now includes HCB

Noted

Noted

Accepted

General comments: chapter includes large number of very different processes so will be difficult for usage; there is no indication where to get information for estimation of emission from combustion using proposed methodology (i.e. what fuel and how much it was used for production of a certain ferrous or non-ferrous metal). In this case applicability of it will be low. There are a lot of tables in the chapter which are not applicable, for example, emissions from natural gas combustion in lead or copper production. Assumption that all NOx, SO2, CO, NMVOC emissions are from fuel combustion will lead to significant difficulties in emission inventory and to miss of sources.

Tier 1 factors will remain heat input but Tier 2 will be revised to be based on production which should make chapter more useful

For fuel use in conventional boilers, furnace, engine or other device emission information is referred to Chapters 1A1 and 1A4.

In table 1-1 under iron and steel one is refered to chapter 1A1 with regard to stationary engines this must be a mistake since no guidance on stationary engines is provided in this chapter.

None - combustion chapters now include a stationary engine table

I assume the correct chapter for guidance on mobile sources in industry would be chapter 1A4 Other Mobile and not 1A2.

Amended reference to 1A2fii

Where, if any, should be accounted NOx emissions from catalytic oxidation of ammonia in nitric acid production? Are you provided for this source of NOx emissions in Chapters 1A2 or 2B?

Although NOx arises form oxidation of ammonia emissions are assigned to the process

SOx emissions in this NFR category are calculated only from SOx emissions from the fuel combusted?

Again there are no mention of HCB despite the reporting requirement for this substance.

It's not clear where the EFs come from! Particularly when Guidebook (2006) is quoted it's not true that EFs are present in this form in original reference! If elaboration was performed on original data these must be explained, otherwise the table is unacceptable

Discussed with EP, tables have been amended to clarify



There is any reference about what specific fuels are covered under fuel type named "Derived Fuels" in this Chapter. Are these specific fuels those mentioned in Chapter 1A1, Table 3-2?

Yes, table included from 1A1

Noted

Noted

Noted

Noted

Included

Noted

Noted

Noted

There is no mention to heavy metals in Table 3-5.

The 95% confidence interval for TSP in Table 3-2 is 0-10, while for PM10 and PM2,5 the interval is 0.1-10. Is lower value for TSP correct?






The 95% confidence interval for PM10 in Table 3-2 is 0-2, while for TSP and PM2,5 the interval is 0.02-2. Is lower value for PM10 correct?


Table 3-3: Why Dioxins and Furans emission factors for natural gas have not been estimated? When using Tier 2 method there is an emission factor of 2 I-TEQ ng/GJ for all activities in this NFR category 1A2 with the exception of cement and lime production activities (SNAP codes 030311 and 030312)

Factors now in at Tier 1 - refer to process emissions

In Table 3-4 (Tier 1 approach), there is no emission factor estimated for dioxins and furans when using heavy fuel oil.

Now referenced to combustion chapters

In Chapter 1A1, page 9, lines 31 to 33, it is said that "for natural gas only emissions of mercury are relevant ...". However no emission factors for Hg are indicated in Table 3-13


Tables 3-13, 3-16, 3-19, 3-26, 3-30, 3-34, 3-36, 3-38, 3-41, 3-43: EF for Hg and Pb in column Value are shown as 0, but in column Lower – not 0.






There is any reference about what specific fuels are covered under fuel type named "Other Liquid Fuels" in this Chapter. Are these specific fuels those mentioned in Chapter 1A1, Table 3-2?

Yes, table included from 1A1


Noted

Noted

Noted

Noted

Noted

Noted

Noted Tables have been revised

Noted

In Table 3-5, Dioxins and Furans emission factors have not been estimated for Other Liquid Fuels. However, when using Tier 2 approach there is an emission factor of 5 I-TEQ ng/GJ independently of what is the SNAP activity considered.


Which fuels are considered under the fuel type "Biomass"?

For combustion these are as listed in 1A1 - table now included in text

In general terms it is have not been clarified whether the proposed emission factors correspond to the emissions originated from only the fuels combusted or they also correspond to total emissions originated from the fuels combusted plus those originated from the materials in the contact furnaces. Carificatin of this pont is particularly relevant for the activities in the 1A2 NFR category, as many of its installations are contact furnaces.

Following discussion with EP, Tier 1 is default combustion only, Tier 2 is generally only NOx/SOX/CO with balance of emissions assigned to the process chapters

Only a unknown elaboration on very old GB values. NEW INFORMATION FROM IPPC BREF DON'T TAKEN INTO ACCOUNT. Why only Coke Oven Gas when old GB contains EFs also for blast furnace gas and natural gas? Specific fuel consumptions in GJ/Mg of product MUST BE REPORTED!


Blast furnace cowpers (SNAP 030203): Emission factors proposed only covers coke oven gas combustion (table 3-7), but there are no information available related to other fuels (specially blast furnace gas, but also GLP or natural gas).


EF in tables (Tier 2) for TSP, HM and PCDD/F are the similar for same fuel and different processes, for instance, EF in Tables 3-8, 3-15, 3-27, 3-28, 3-32, 3-40 (fuel is coke or hard coal). The same situation – for Gas, Liquid fuels. How this wss proved? Is it necessary to duplicate tables?

Tables revised following discussion with EP

The production processes described in the guidebook are generic, focussed on applicability for various individual processes. This approach does not take into account the more complex reality of intertwined processes such as Iron and Steel Manufacture. This is especially true for the use of mixed process gases.

Yes but the level of activity detail defines the basis of factors suitable for use at Tier 1 and 2

Table 3-8 Tier 2: it is shown that HM emission factors are from the Guidebook (2006). But in the Table 8.2c of the Guidebook (2006) there are no such emission factors.

EFs old and not validated. PM EFs for 1.A.2 and 2.C.1: as you subdivide combustion and not combustion PM emissions! Use BREF EFs!


Noted

Noted

Noted

Editorial Done

Noted

Noted See earlier comment

Noted Table headings modified

Noted

Accepted





The SNAP code in table 3-10 (030302), and the literal for Technologies/Practices item (Reheating Furnaces) does not match with the heading of the table. Which activity is referred to in this table?



Revised EF tables should be clearer

For Reheating Furnaces (SNAP 030302) there are only emission factors for coke oven gas. What's the matter with the other fuels used in this activity? In Guidebook 2006 there is a wide list of fuels used in this furnaces.


Table 3-12 (Tier 2): error in the title of the table; not coincide with the content (Reheating furnaces); EF for PCDD/F are shown with reference to the Guidebook 2006, but in the Guidebook 2006 there are no such emission factors.

The title refers to "Gray Iron Foundries" but the technology in the table refers to "Reheating Furnaces". However existing GB EFs old and not validated. PM EFs for 1.A.2 and 2.C.1: as you subdivide combustion and not combustion PM emissions! Use BREF EFs!


The SNAP code in table 3-12 (030302), and the literal for Technologies/Practices item (Reheating Furnaces) does not match with the heading of the table. Which activity is referred to in this table? Emission factors in this table are the same as those proposed in Table 3-10.



Tables 3-12 - 3-13 Tier 2: it is known that gray iron in foundries is produced using coke so how EF for natural gas and other liquid fuels were obtained and where they can be applied?

Why "Other Liquid Fuels"? Why these EFs ? USE BREF EFs!


In the existing guidebook default values are provided in g/tonne liquid steel, which perhaps is a better unit for these type of default emission factors.

Tables have been modified to allow use of production activity data at Tier 2

Noted


Noted

Noted

Noted Rounding issue corrected

Table 3-16: same comment as for Table 3-15. Noted

The Hg emission factor proposed in Table 3-13 is 0 g/GJ, while the 95% confidence interval for this pollutant is 0.00001-0.0001


The Pb emission factor proposed in Table 3-13 is 0 g/GJ, while the 95% confidence interval for this pollutant is 0.00003-0.2


Table 3-14: For Primary and Secondary Pb/Zn/Cu production using Natural Gas, it is very surprising that there are no heavy metals emissions (indicated as not applicable), taking into acccount that these are processes with contact and the raw materials obviously content the corresponding Heavy Metals.

Heavy metals now assigned to process emission


The same EF for PM, HM, PCDD/F and PAH are shown in the Tables 3-14 (Pb/Cu/Zn Production), 3-17 (Secondary Aluminium Production) and 3-20 (Alumina/Mg/Ni Production); though technologies are different.


All the chapter "3.3.2.2 Combustion in 1A2b – 1 Non-ferrous metal" it's unclear because I don't understand if take into account the different condition of combustion in roasting and as it's possible to subdivide emissions from fuel and from materials in such a case (see GENERAL PRELIMINARY COMMENT). If it's possible it's necessary to develop specific emission factors not to copy "old" EF that derive from another approach.


In Table 3-15, emission factors for Heavy Metals, Dioxins and Furans and PAH for Primary Pb, Zn and Cu Production using coke are the same as in any other activity in this 1A2 NFR category. In the particular case of Heavy Metals, it seems that emission factors only refers to emissions originated from the fuel combusted and there is no relation to the raw materials used.


Table 3-16 also contains mysterious "0" values. Likewise with table 3-19, table 3-26, table 3-30, table 3-34, table 3-36, table 3-38, table 3-41 and table 3-43.


Noted

Noted

Accepted






The same EF for PM, HM, PCDD/F and PAH are shown in the Tables 3-16 (Pb/Cu/Zn Production) and 3-19 (Secondary Aluminium Production); though technologies are different.


SNAP code in table 3-17 should be 030310 (not 0303)





In Table 3-18, PM10 and PM2.5 emission factors for heavy fuel oil seem to be interchanged (PM2.5 values are higher than PM10)


The same EF for PM, HM and PAH are shown in the Tables 3-18 (Secondary Aluminium Production) and 3-21 (Alumina/Mg/Ni Production); though technologies are different. There are errors of EF for PM10 and PM2.5 in both tables.










In Table 3-21, PM10 and PM2.5 emission factors for heavy fuel oil seem to be interchanged (PM2.5 values are higher than PM10)



Noted

Noted

Noted

Noted

Editorial Done


Noted

All the chapter Combustion in 1A2d – Pulp and 1 paper production is not necessary (emissions are counted in 1.A.1 as boilers)

Boiler plant emissions can use factors from !A1 (or 1A4) butthey are not a 1A1 activity

Particles and metals in table 3-24 are indicated as included elsewhere. Where would that be?


In Table 3-23 the 95% confidence interval for Ni is 0.002-0.0. What is the upper bound of this interval?


Emission factors for dioxins and furans and PAH for wood are the same as for hard coal (or coke) in other activities. Are this emission factors correct? We could not find in Guidebook 2006 this reference for SNAP activity 030321.


In Table 3-24, particulates and heavy metals emission factors for black liquor combustion have the label "IE". Where have these emission factors been included?


What does "IE" for emission factors mean ? Where included ?

Included elsewhere but these references have been removed (not estimated)

Erroneous paragraph numeration 3.3.4 and not 3.3.3.1


Plaster: all the text it's unclear because I don't understand if take into account the different condition of combustion in kiln and as it's possible to subdivide emissions from fuel and from materials in such a case (see GENERAL PRELIMINARY COMMENT). If it's possible it's necessary to develop specific emission factors not to copy "old" EF that derive from another approach (combustion + process).


Noted

Noted

Editorial None

Rejected


For Plaster Furnaces there are only emission factors proposed for natural gas and other liquid fuels. Which emission factors should be used for other fuels like hard coal, heavy fuel oil, petroleum coke, wood, ...?






Cement: all the text it's unclear because I don't understand if take into account the different condition of combustion in kiln and as it's possible to subdivide emissions from fuel and from materials in such a case (see GENERAL PRELIMINARY COMMENT). If it's possible it's necessary to develop specific emission factors not to copy "old" EF that derive from another approach (combustion + process).


Give precise reference to EF rather than Guidebook (2006)


The table design with one fuel per table do not give a general view of EF - all fuels per process in one table

For Cement Production, there are no emission factors proposed for petroleum coke, heavy fuel oil, wood and wood wastes. Petroleum coke is the main fuel used in this activity.



In Table 3-29, Dioxins and Furans emission factors has not been estimated for Nataural Gas. However, whe using Tier 2 approach there is an emission factor of 2 I-TEQ ng/GJ independently of the SNAP activity considered.






Noted

Noted

Noted


Noted

Noted

Table 3-31 Tier 2: no emission factors for PCDD/F which are high for waste combustion.

Waste combustion factors now removed as inappropriate in this chapter

The fuel indicated in Table 3-31 (Hard coal) is wrong. In accordance with the heading it should be "Industrial waste"


Table 3-31: Fuel: Replace "Hard coal" with "Industrial waste"


Lime: all the text it's unclear because I don't understand if take into account the different condition of combustion in kiln and as it's possible to subdivide emissions from fuel and from materials in such a case (see GENERAL PRELIMINARY COMMENT). If it's possible it's necessary to develop specific emission factors not to copy "old" EF that derive from another approach (combustion + process).


Not all fuels used in lime production are covered in the Draft. There are no emission factors for coke, petroleum coke, heavy fuel oil or biomass fuels.



In Table 3-33, Dioxins and Furans emission factors has not been estimated for Nataural Gas. However, whe using Tier 2 approach there is an emission factor of 2 I-TEQ ng/GJ independently of the SNAP activity considered.

UNEP factor adopted at Tier 1, Tier 2 factors will be in process chapters

NOX-EF for Lime kilns seems to be very high since the needed temperatures are much lower than for cement kilns. The different kiln types have very different levels on NOX emissions. (see http://www.umweltbundesamt.at/fileadmin/site/publikationen/REP0128.pdf, page 11)

Thamkyou for providing data, this is good detail on state of the art/BAT but is on a restricted pool of plant. Data from the draft revised CLP BREF doesn't provide fuel-based EFs but indicates a very wide range of emissions and the factors provided in the guidebook are within the range of 'inferred' factors from the BREF data.



Noted

Noted

Noted

Accepted




In Table 3-36, the fuel is described as "Other Liquid Fuels", but probably it is about gas oil. Is this assumption correct?


Asphalt: all the text it's unclear because I don't understand if take into account the different condition of combustion in kiln and as it's possible to subdivide emissions from fuel and from materials in such a case (see GENERAL PRELIMINARY COMMENT). If it's possible it's necessary to develop specific emission factors not to copy "old" EF that derive from another approach (combustion + process). PM from process where is inserted?


In accordance with Guidebook 2006, chapter B3313, "During the production of asphalt concrete considerable amounts of fine particles can be generated".


In Table 3-37 (gas natural combustion in asphalt plants), the emission factor for NMVOC is indicated as estimated elsewhere (IE). Nevertheless, in Table 3-36 (combustion of other liquid fuels) an emission factor of 11.8 g/GJ is mentioned.







Noted


Noted

Noted


Glass: all the text it's unclear because I don't understand if take into account the different condition of combustion in kiln and as it's possible to subdivide emissions from fuel and from materials in such a case (see GENERAL PRELIMINARY COMMENT). If it's possible it's necessary to develop specific emission factors not to copy "old" EF that derive from another approach (combustion + process). PM from process where is inserted? Metals emissions very important for the sector where are inserted?


For Glass Production, the SNAP code indicated is 0303. It is suposed that SNAP codes involved are 030314, 030315, 030316 and 030317.



The fuels considered are Hard Coal, Other Liquid Fuels and Natural Gas. No reference is made to other fuels like heavy fuel oil, petroleum coke or biomass (wood and wood wastes).


Bricks and Tiles: all the text it's unclear because I don't understand if take into account the different condition of combustion in kiln and as it's possible to subdivide emissions from fuel and from materials in such a case (see GENERAL PRELIMINARY COMMENT). If it's possible it's necessary to develop specific emission factors not to copy "old" EF that derive from another approach (combustion + process). PM from process where is inserted?






There is no emission factor for NMVOC in Table 3-42







Noted


Accepted

Accepted Done

References include only 2 sources. Noted Revised

Noted Revised

The fuels considered are Other Liquid Fuels and Natural Gas. No reference is made to other fuels like Heavy Fuel Oil.


Which SNAP codes are referred to in Tables 3-42 and 3-43?



In "Glossary" section the LPG are included into "Gaseous fuels", while in Chapter 1A1, Table 3-2, the LPG are considered as "Other liquid fuels"

Changed changed to liquid fuels

This glossary should either be expanded or removed. Some listings in the glossary do not appear previously in the text.

A lot of references in the text do not appear in the list of references, e.g. CEPMEIP 2004, CITEPA 2007, Guidebook 2006, CITEPA &ENEA 2007, US EPA 1998, US EPA 2000, US EPA 2003 etc.

Accepted

Noted

Noted

Some general preliminary comment is necessary. This section of the Guidebook and the related "old" chapter are the most critical ones. In the past the structure of the guidebook can give rise to double count of emissions. The new Guidebook have to resolve this problems, but this is not the case.We have two kind of technologies:- the SNAP Group 0301 Combustion in boilers, gas turbines and stationary - the SNAP Groups 0302 Process furnaces without contact and 0303 Processes with contactFor the first group the conditions are very similar to 1.A.1. An very simple example is the following: in the paper industry the main emissions arise from drying processes in which water vapour is used; this vapour come from a boiler, so the emission from this boiler is very similar to emissions in 1.A.1. Where these emissions are allocated? The only "additional" non boilers emissions from 1.A.2 can be emissions from evaporation of organic substances used in paper manufacturing that can evaporate in the drying process. The "new" Guidebook don't take into account these last and report EFs for combustion that can be different from EF in 1.A.1. Then we have a lot of similar cases for example Combustion in Food Industry, Mechanic Industry, ecc. What emissions factors? We need a specific subsection.Next we have old SNAP 0302 and 0303 group and related new chapters. I think in these chapters must be inserted only emissions come from processes in which special condition or the contact between fuel and materials produces different combustion characteristics and different EFs: essentially process furnaces. For these applications, all the existing documentation (and


The table contains some odd 0 values, I assume this is due to the haste with which this document appears to have been drafted.


CONCLUSION: The chapter is unacceptable! All the documentation from BREF ignored also data sent to consultant from EP leader! All the recommendation in EP and from industry about no separation between combustion and processes ignored. All the recommendation of use of product approach ignored.


In addition to this, industrial waste fuels cover a wide variety of materials, as specified in page 6, lines 35 and 36, with different characteristics and composition, so it is not clear if the emission factors proposed should be applied to all industrial waste fuels.

Waste factors now removed

Moreover, there are no emission factors proposed for heavy metals, dioxins and furans and PAH, and emissions for these pollutants are relevant when using industrial waste fuels.


Waste factors now removed

Noted

Noted

Noted

Noted

Noted

Additionally, emission factors for SOx, NOx, NMVOC and CO are the same as for hard coal. Are these emission factors correct?



In addition, the reference for emission factors is Guidebook (2006), but the corresponding chapter for SNAP 030313 only provides emission factors for particles. This comment is also valid for emission factors related to gas natural consumption in Table 3-37.


However, emission factors for particles in Tables 3-36 and 3-37 seems to concern only fuel consumption.


Taking into account that this is a process with contact, these particles emission factors are probably underestimated.


What is the difference between both tables? Where is the NMVOC emission factor for natural gas combustion indicated?


There are only two kind of fuels considered: Other Liquid Fuels and Natural Gas. No reference is made to other fuels like heavy fuel oil.


Noted

Noted

Noted Text amended to clarify

NotedMeaning of LTO-cycles 1? Noted Needs correcting

Noted

Noted

Noted has been emphasised

Noted has been emphasised

Accepted Will expand explanation

Accepted Will expand explanation

Accepted

Accepted

In addition, emission factors for Other Liquid Fuels should be splitted for each fuel considered in this category (gas oil, LPG, ...)


Which emissions (combustion and/or process) are considered in the emission factors proposed? In chapter 2.A.7.d, emission factors for heavy metals and particulates are propposed (in terms of mass of pollutant per unit of production),


and it is not clear if there is a risk of double counting when applying both emission factors.

What are the major changes since earlier versions?

Will outline the main changes

Default methodology has been developped by ICAO concerning APU cf. "Airport Air Quality Guidance Manual" ICAO, April 2007. That could be added within the GB, as far as the fuel used is the aircraft kerozene.

Has been considered and words added under "Auxillary power operations" on p4 of SOD

Within the 2007 EMEP/CORINAIR Guidebook, general information on APU and fuel dumping are provided that may be interesting to keep.

Has been incorporated where appropriate

It must be emphasized, that military aviation is classified as NFR code 1A5 (other) according to agreed EMEP nomenclature.

Please distinguish between sources of emissions belong under this NFR and other (e.g painting belongs to another NFR and should not be ignored)

This should be explained in much more details, and a table should be provided giving a thorough overview of today's situation

Some elaboration on the grouping of NFR categories for each reporting requirement would be useful here.

There is a lot of emission data for turboprops also. Data for the most commonly engine fitted to specific aircraft

updated aviation emission factors have been discussed with MW (Expert Panel member) and incorporated as appropriate

Table 2.1, this table needs update as it is ten years old, and new aircraft must be included

updated aviation emission factors have been discussed with MW (Expert Panel member) and incorporated as appropriate

Accepted has been emphasised

AcceptedWhat Directive do you refer to? Accepted Will expand explanation

Accepted

has been modified

Accepted will reword

Noted will reword

Noted will reword

Noted

Noted has been modifiedThis is not possible to understand! Noted has been modified

Noted has been modified

Military is reporting under a different NFR, while it's methodology is described here

This paragraph was not included in the outline agreed in Dessau. Furthermore if it is to be included it must be updated with new numbers from more recent references. Same with table 2.3 and 2.4. (the same comment applies to other chapters including a similar paragraph)


J Goodwin consulted with expert panel member (MW)

Table 2.2: There is more recent legislation for NOx. Please refer to the

updated the aviation emission regulations have been included.

Table 2.2. Isn't there more up to date information available?

updated the aviation emission regulations have been included.

These tables 2-3 and 2-4, sould be completed with tables relating to internationals emissions. Note : international LTO emissions are part of national NECD emissions, and important issues of emission trends for aviation concern international aviation. For international aviation emissions, e.g. international/domestic ratios could be displayed.


J Goodwin consulted with expert panel member (MW)

The Decision tree needs improving. Surely the first 2 diamond shaped white boxes are needed to use a tier 3 method.


The decision tree is more less impossible to understand. Please use the old decision tree as a basis for the Tier explanations.


Table 3-1 is a complete mess, and is basically wrong!


Footnoe 5, must be changed, it is copied from IPCC (2006) and does not make sense in this context

Please state where military aviation emissions should be reported.

What do you mean by "not reported here". Military aviation is a part of NFR 1A5b along with other military mobile activities.

This text is incomprehensible. Further, it is not in line with the emission reporting Guidelines (for example multilateral operations are NOT excluded from emission totals under LRTAP)

Text taken verbatim from IPCC 2006, need to consult with expert panel

This methodological description is not improving the old "simple method" described in section 4-2 of B851-13. It is assuming that inventory compiliers know how to estimate emissions wothout describing the process.

Some duplication of information with section 3.2.3 Activity data.



Noted


Noted

Noted

Can the default emission factors (table3-3 for domestic LTO) also be used non-IFR fligths domestic LTO? It is not specified whether the defaults are for IFR/VFR. We have an amount of LTO for VFR flights (small aircrafts like PA28,C152,…) and not the amount of flight hours for VFR, and wonder if we can use table 3-3, 3-8 and 3-9 for it.


In table 3-3 (Tier 1 Default Fuel use in LTO), second NFR source (domestic LTO) has as fuel : jet kerosine. Is the value also valid for jet gasoline & aviation gasoline fuel use? Or must there a value be added for further use with tables 3-8 and 3-9?

Is there no reference to these fuel consumption EFs in Table 3-3. Also what is meant by kg/tonne fuel in NFR 1.a.3.a.i(ii). Should it not be kg/LTO?

Information on HM/POPs are missing. Please cite the origin (source) of emission factors from the EMEP-C, emission factors must be tracable (comment applies to many chapters). Furthermore Tier 1 emission factors must be updated, a lot has been changed since these Tier 1 emission factors were derived

EFs have been included where available

I'm not sure that a reference to an EF should be "Calc from Tier 2" in Tables 3-8 and 3-9. This could be described better.

Aviation gasoline is added substantial amounts of lead, please provide information

EFs have been included where available

Data available and necessary to apply Tier 2 method sould be specified. 'The algorithms paragraph 3.3.1 is not detailed enough. Some components of such step by step algorithms is given but in EF paragraph 3.3.2. A global overview of the algoritms is missing.


has been modified in consultation with expert panel member MW

The Tier 2 method should promote using fuel sold statistics : separately domestic and international fuel sold when available. If these separate fuel sold statistics are not available, then estimation method could be used to split domestic and international fuel consumption, as presented in step 1.



It is strange to recommand to use Tier 3 EF within a Tier 2 method. Furthermore, in case of using Tier 2 method, data on cruise distances per aircrafft type are generally not available for using Tier 3 EF (distance dependant).



The link of theses lines with paragraph 3.3.3 Activity data is not clear.


Where does the data in this table originate from? Noted has been modified

Please provide some method description for Tier 2. Noted

Noted

Noted

Editorial

Accepted

Noted

Can emissions factors for airplane types that are disappeared referred to older versions of the guidebook still be used from older versions (for example Concorde in 1996 guidelines)?


EFs used have been discussed with expert panel member, MW

The Tier 2 method is completely wrong! This method cannot use mission distance based factors for cruise - this relates to Tier 3!




In the last part of the box, reference to the EFDB is made, however there is no EFDB for air pollutants!


Footnote 8, this assumption should be reviewed due to more recent knowledge


Table 3-11: It is not acceptable to use the emission factors for LTO provided by the IPCC 2006 guidelines



table 3-11: Footnote (3) does not appear below; there (2) apperas twice. - Please change the 2nd (2) into (3).


Please check if this table has been updated with more recent aircraft and make corrections as appropriate


This paragraph should be more detailed, especially the link with the steps displayed in 3.3.2.


Noted will clarifyTable 3.14. Source? Noted will reference

Noted

Noted

Noted will continue to be

NotedThe sentence is diffucult to understand. Noted will clarify

Where is the table 3.10 ? Noted

NotedIt is both turbo fan and turbo prop engines. Noted should be altered

Noted

Accepted

These are very old data, please update Accepted

Accepted

Why is military described here in section 3.3.5? In with the Tier 2 method? There is no mention of military under the Tier 3 method.

What is the minimum flown distance for an airplane to reach cruise level? Table 3-15 starts at 125 nm. It means dat below 125 nm, an airplane is not cruising yet (in normal average conditions)?

These data are taken verbatim from earlier versions of the guidebook - refer to expert panel

In general the method choice and description should preceed the EF tables. Section 3.4.2 on Tier 3 EFs is on page 25 whilst section 3.4.3.1 on Tier 3A method is on page 29. This makes the chapter very difficult to read.

Have re-organised EF tables

Please explain where the remainer Tier 3 emission factors can be found (currently they are available as a spreadhseet download)

There are no cruise emission factors published on the ICAO website.

These data are taken verbatim from earlier versions of the guidebook - refer to expert panel

Have asked author of previous guidebook

This is not possible to follow, what has it to do with engine independent emission factors? And where is Appendix 1?

should be aircraft type - Appendix 1 is unaltered

For non-IFR flights, we still use emission factors from EPA, AP-42 volume II (1985). Can they still be used? Why are they not included as reference default emission factors (instead of calculating nothing) ?



These method descriptions in sections 3.4.3.1 to 3.4.3.3 should be on page 24 before the EF tables.


The note provides considerations on energy balance for domestic aviation. Similar considerations on energy balance for international aviation sould be also included (taking into account that in case of international aviation, half of international fuel consumption should be compared to fuel sold in the country for international flights).



This section 4.4 has nothing to do with consistent time series and recalculation! It is simply copy and paste from the old chapter section 3.6 "Projections": Even the title has been changed to fit the misplaced content.


Accepted

Accepted Will include Description

Noted

Noted

Noted will clarify

Accepted

Accepted

Accepted

ICAO website.

in the Tables 3-4 and 3-5 is preferable.

This information (including the tables) appears outdatet. What is for example "current level" in Table 4-1? Please update or rewrite

has been discussed with expert panel member MW

It is indeed suprising that there is no specific issue here given the complexity of reporting this category (e.g. differences betwee UNFCCC, LRTAP and NEC reporting), memo items etc. (same remark to navigation/shipping chapter)

What other sources? It is essential to explain where the data comes from

Not changed - taken verbatim from previous version of the guidbook. Refer to expert panel

What is the difference between Annex B and Table 3-11? Are both needed?

has been discussed with expert panel member MW

A large number of references in this chapter are not found in the reference list. (including IPCC (2006) which the method is based on!)

Please also include Tier 2 cruise emission factors (else the method will not work)


Please refer also to general comments summarised in the separate word file "DK Review of guidebook chapters for mobile sources.doc"


Even more important, a lot of references and explanations how data are obtained, are missing.


All military mobile activities (aviation, land based and sailing activities) are classified as 1A5b (equivalent to SNAP code 0801) according to EMEP.



data are available from the current guidebook, both for LTO and cruise distance classes







Please use the simple method description directly from the old guidebook.



These LTO factors are not supported by new cruise emf related to distances, as in the current guidebook version.



Moreover, looking into the IPCC guidelines the LTO factors are very poorly documented.



If we use the IPCC data, we loose the consistency with cruise factors per distance class, and for species like NOx, NMVOC and CO



Accepted Corrected

Noted

Noted CorrectedBadly written. Noted Corrected

Poorly phrased. NotedBadly written, and difficult to follow. Noted Changed

What is section 4? The sentence gives no meaning Noted Sorted

CO is not an Ozone Precursor Rejected

Accepted Corrected

Noted Corrected

Noted Corrected

cruise factors heavily depend on the actual aircraft/engine combination. In some countries, detailed city-pair inventories



are made each year using distances between airports, and for these countries such new data gives less meaning.



So, the strong recommendation is to maintain the "old" LTO (and cruise) emf in order not to introduce errors into the inventories.



The data come from specific simulations made by aircraft emission experts.



and the approach used to obtain the data that is presented in the guidebook.



The schematic diagram (Figure 4.1) in the chapter B851 in the Guidebook should be retained in the new chapter.



Title of chapter should include a reference to buses, ie HDVs and buses instead of "heavy-duty trucks".

What is the difference between 'Overview' and 'General description'?

General Description is part of the Overview.

These paragraphs are rather badly written, and could be improved.

Rejected because this phrase was taken verbatim from existing guidebook, see B710-1 in pdf version

The EEA include CO in their definition of Ozone Precursor http://glossary.eea.europa.eu/EEAGlossary/O/ozone_precursor

Delete 'mobile'. Change 'transportation' to 'transport' (throughout).Change 'vehicles' to 'vehicle'.

Why 'on-road'? The whole chapter refers to road vehicles.

Emissions from exhaust aftertreatment? This is nonsense.

Change to 'The most important pollutants from road vehicles are covered…'.



NotedWhere is this reference? Noted CorrectedShould read 'three-tier'. Noted Corrected

The section 2.1 title is not helpful. NotedWhat is meant by 'positively ignite'? Noted Corrected

Noted Corrected

Figure 2-1 is poor. What purpose does it serve? RejectedFigure 2-1 gives no information. Noted CorrectedThis reference is wrong. Editorial Sorted

Accepted SortedWhere is Table 2-1? Editorial SortedWhere is the Tables 4-7 to 4-29? Editorial Sorted

Editorial Corrected

Editorial Corrected

Accepted Sorted

Accepted Sortedunits for Cd and Pb in table 3-2 are missing. Accepted Corrected

What is the relationship to COPERT? If it has been updated five times why are we now at COPERT 4?

The existing guidebook says it is the 5th update, see B710-2 in pdf version. These lines merely reflect these words - no change made.

Will clarify & align with transport terminology

Which process? One of the combustion processes? Figure 2-1 does not show combustion processes.

used to conceptualise the boundaries of road transport emissions, and is an approach adopted throughout the Guidebook.

It is written that for Tier 1 uses fuel as activity indicator with average fuel specific emission factors. But then in the table 3-2-3.9Ef are g/GJ

Figure 3-1 should read "Decision tree for road transport" not "aviation". I also wonder about the diamond "Is this a key source?". Road transport is always a key-source. There should be added the following statement in p.6 where the figure is introduced: "Road transport is a key-source in all countries. Therefore, the Tier 1 method should only be used in the absence of any more detailed information than fuel statistics. In parallel, in such a case, the country needs to make every effort to collect the detailed statistics required to use a higher Tier method, preferrably Tier 3."

Eq. 1 needs to change to read Ei,j,k where k will refer to fuel (gas, diesel, LPG, NG). Therefore, FCj should change to FCj,k and Efi,j should change to Efi,j,k.

the formula (1) multiply EF [g/kgfuel] for FC (fuel consumption [kg fuel but in the table the emission factor for Tier 1 approach are expressed in terms of g/GJ. There should be one common standard and I suggest that kg of fuel makes more sense

The emission factors are wrong, due to errors in the calculations.

Accepted

units for Cd and Pb in table 3-5 are missing. Accepted Sortedunit for Cd in table 3-6 are missing. Accepted Sortedunit for Cd in table 3-7 are missing. Accepted Sortedunits for Cd and Pb in table 3-9 are missing. Accepted Sortedtable 3-9: unit for Cd and Pb missing Accepted Sorted

Editorial Corrected

Tables 3.2 to 3.9 present emission factors in g/GJ. First, the methodology in p.7 is in g/kg. Second, the values are wrong (they should be ~5 times higher). I understand the editors try to be consistent with IPCC. On the other hand, Eurostat data report all values in tonnes that can be readily converted to kg, without knowing the energy content of fuel. In addition, methodologies Tier 2 and Tier 3 calculate total fuel consumption in kg so why having Tier 1 in GJ? Third, emission values in g/kg fuel are widespread and are published in scientific literature so the reader can compare them to the Guidebook values. All models (Copert, Artemis, even Verit+ in the Netherlands) use fuel mass values. Heavy metals and sulfur are all reported per mass of fuel. The user of any methodology needs now to convert them to GJ! I know of no source that reports emission in g/GJ except for GHGs. But even in the 2006 IPCC Guidelines, N2O and CH4 emission factors for US and Europe are in mg/km. In summary, I find the expression g/GJ awkward and not practical and I strongly reccomend this to be changed back to g/kg fuel.


Sorted - after discussions with Expert Panel we have reverted back to expressing emission factors in units of g/tonne fuel

Tables 3.2 to 3.9 also include emissions of SOx and heavy metals and make reference to Tables 4-XXX. First, as the draft chapter stands now, these tables are A.XXX and not 4.XXX, but please also check my comment below related to the structure of the chapter. Second, why should we provide a default SOx emission factor (equivalent to 40 ppm S in fuel) when S content of fuel is known in each country? None of the countries (except Bulgaria) that are going to use a Tier 1 methodology have average sulfur of 40 ppm!!!! I reccomend we introduce the very simple methodology (two rows) given in section A.6.9 as part of Tier 1 as well. This is all it takes to have the correct estimation of SOx.

Referencing to tables will be corrected. Also comment will be addressed to include a flexible S content variable with a default if none is known.

Tables 3-2 to 3-9 include Default EFs Tier1. The unit used is g/GJ, instead og g/kg of fuel used. It may be worth including both EFs by GY and kg in the final guidebook and a description of the calculation from one to the other.. Also I think the reference AUT 2008 needs to be clarified (exactly a reference to which report?)


Sorted - after discussions with Expert Panel we have reverted back to expressing emission factors in units of g/tonne fuel

All these Tables 3-11 to 3-38 contain EFs for Tier 2. What is the reference for these EFs?

Where is Table 4-6? Editorial Sorted

Accepted Sorted

Accepted Corrected

Noted

Acceptedwhere is section 4.3.3? Editorial SortedThere is no discussion in section 4.3.3! Editorial Sorted

Accepted Sorted

Accepted Sorted

Accepted

Accepted Will be refered to..

References are not old? Accepted

Accepted

Tier 2 method gives EFs by technology, however these technologies are not provided until the Appendix to this FOD.

Tables 3-11 to 3.38 contain the statement "grams of international toxic equivalent" for DIOX and no values. There are such values in Table A.101.

For heavy duty trucks, so many size classe and technology combinations are missing in terms of Tier 2 emission factors.


Changed - comment added regarding what to use for "missing" size/ technology combinations.

Table 3-39 is a good summary. I do not understand why this is only specific to FC and what are the uses it intents to cover.

Corrected It's use has been clarified in the text.

"By applying a trial-and-error-approach..." This sentence is meaningless!


It is a very wrong decision to let Tier 3 be described in an Annex. Tier 3 is what many countries use now.

It is very important that this Tier 3 method has a proper description and overview in the actual chapter as does the Tier 1 & 2 methods. This method is the most used method by inventory compiliers and should not be discussed in an Appendix.

The text in Section 4.4 has nothing to do with consistent time series and recalculation! It is just copy and paste of Section 13 "Temporal disaggregation criteria" from the old chapter.

Heading changed to reflect text provided - now no section on "developing a consistent time series" - Need to decide on the extent of text neded on this

The problem of "tank tourism" it is not mentioned. If it is relevant, fuel balance, as explained here, could not be applied.


This kind of table could be very useful. Why don't put information on the other pollutants?

Where available data will be included. These data were taken verbatim from Table 10-3 of previous guidebook. Analogous data for other pollutants was not provided.

AcceptedReference to Table 4-1 is wrong. Editorial SortedThere is no Table 2-1 in the chapter Editorial Sorted

CO is not an Ozone Precursor Rejected

Accepted Sorted

Accepted Sorted

Accepted

Accepted

Accepted See above

Editorial Sorted

Editorial

Will be the emission factors for buses CNG included into the COPERT IV?

COPERT 4 is a software tool outside the scope of this Guidebook revision. This question will be forwarded to the team at Artistotle University.

The EEA include CO in their definition of Ozone Precursor http://glossary.eea.europa.eu/EEAGlossary/O/ozone_precursor

Section A.2 is not part of the Tier 3 methodology and it is ok to remain as an Annex. However, in other chapters (e.g. non-exhaust PM emissions, evaporation) the sections referring to the contribution of the sector to total emissions are provided as introductory sections before presenting the Tier 1 methodology. So, please be consistent between chapters, where you want this section to be presented (annex or introduction).

Section A.3 should be part of Tier 1 methodology because it just provides definitions of the vehicle classes considered. Section A.4 should be part of Tier 2 methodology because Tier 2 already uses the emission standards classification.

Metodology does not estimate in which category should be included tracotrs with registration number (vehicles). These can not drive on motorway.

Rejected for this version because this phrase was taken verbatim from existing guidebook - comment will be passed to AUT.

Table A.7 now offers no new information and needs to be erased.

Rejected because the guidance we have received is that the existing detailed methodology text should not be changed much at all.

Indeed the current section A.6 should follow as the next section, after A.1

Check format of Figure A.2. The text on the left-most boxes should be vertical and not horizontal.

The sentence is not coherent with the table A.53. The sentence must be "However, some additional reductions need to be applied for vehicle technologies post-Euro 4 (RFij), which are given in Table A. 53"


Editorial

Editorial

Noted

Noted

Noted

Noted Sorted

In the equation (27) replace eHOT;i,Euro1 by eHOT;i,Euro4 to be coherent with table A.53 and Rfij factors


The "ehot;i,Euro 1" value in eq. 27 should be replaced with "ehot;i,Euro 4". the "ecold/ehot|i,Euro 1" value should remain intact.


It is not possible to distinguish between mopeds 2 and 4 strokes?



table A.77, A.78, A.79, A.80 e A.81 it is not possible to define the emission factors in term of emission legislation?




Comments have been considered.

Up to Euro IV: The vehicle categories 7,5-12 & 14-20 & 26-32 tons are missing.

See also comment 284 - Changed - comment added regarding what to use for "missing" size/ technology combinations.

For newer technologies: The vehicle categories 7,5-20 & 26-32 tons are missing.

See also comment 284 - Changed - comment added regarding what to use for "missing" size/ technology combinations.

In general the Annex, who is supposed to treat Tier 3, also repeats the data used for the old simple method.

The old chapter discusses how to treat emission inventories in relation to dispersion models.


Heading changed to reflect text provided - now no section on "developing a consistent time series" - Need to decide on the extent of text neded on this

Accepted Sorted

Accepted Sorted

Accepted Sorted

Accepted

Accepted Sorted

Editorial Sorted

THE TIER 3 METHODOLOGY MUST NOT BE INTRODUCED AS AN ANNEX BUT AS SECTION 3.4, AS ORIGINALLY FORESEEN. NOW THE WHOLE CHAPTER IS A MESS! ALL SECTIONS IN CHAPTER 4 DISCUSS ISSUES OF TIER 3 METHODOLOGY (THEY ARE A COPY OF THE PREVIOUS VERSION OF THE GUIDEBOOK) AND TIER 3 IS ONLY INTRODUCED IN THE ANNEX. MOST REFERENCES REFER TO THE TIER 3 METHOD AND THE TIER 3 IS INTRODUCED AFTER THE REFERENCES AS AN ANNEX! IT IS POINTLESS TO MAKE A DETAILED REVIEW AS THE CHAPTER IS SO BADLY WRITTEN AND STRUCTURED THAT IS MAKES NO SENSE.

The chapter makes a lot of references to sections and tables 4.x. These do not exist because Tier 3 has been annexed. These need not be changed when the editors correct the chapter per my reccomendation above. However, there are many erronous references to tables and figures as the draft version stands now.

In all Tier tables for the road transport not applicable would be POPsAnnex I


The general description and overview could perhaps include tables 1.1 and 1.2 from the Guidebook B710-3.

There is no reference to classification of vehicles such as in the Guidebook table 3.1 B710-7 and Table 3.6 B710-16. All of this information is relevant regardless of which Tier approach is used by inventory compiliers and should be included in the chapter overview or description.

Accepted - cross reference included

General comment. This chapter needs major restructuring. All vehicle classifications, legislation (as described in B710-13 to B710-16) should be included in the text of the chapter before discussion of the different Tier method (1,2 and 3). Improvements are also needed in referencing EF tables and if changes are made to EF units these should be explained clearly. Also there is no bulk CS EFs based on the 2002 work which could be useful for a Tier 1 method. There is no discussion of the contribution road transport makes to total national emissions.

Subsections 6.1 and 6.2 should occur in the same order as the title of Section 6. In addition, the level 3 sections in the report are missing from the table of contents.

This paragraph could read a little better. noted Revised

Accepted

Accepted

Explain what carbon canisters are. Accepted

Accepted Revised

Accepted

Accepted

This paragraph is poorly constructed and not well phrased. How do breathing losses relate to diurnal emissions, hot soak losses and running losses? Do we need to use both 'losses' and 'emissions'? Just use 'emissions'.

Not changed because this was taken verbatim from previous Guidebook version B760(2007) Section 3.1. Will pass comment on to Expert Panel

The last sentence of the para ought to be the first. Again. How do 'breathing losses' relate to the sources mentioned. My understanding is that this is a part of the process which leads to diurnal emissions.

Not changed because this was taken verbatim from previous Guidebook version B760(2007) Section 3.1. Will pass comment on to Expert Panel

Not changed because this was taken verbatim from previous Guidebook version B760(2007) page 1. Will pass comment on to Expert Panel

Process description' is not a good title in my view. It is too vague. I also think that it more or less repeats title 2, and would therefore delete it.


Could be made more transport specific. However, might detract from a common guidebook style.

Figure 2-1 is poor. It could show the different evaporative sources much more clearly (i.e. picture of vehicle, with diurnal losses, hot soak losses and running losses explained).

Maybe worth adding that some studies have identified 'resting emissions' as a separate evaporative source. These result from diffusion, permeation, seepage and minor liquid leaks, and do not need an increase in fuel temperature to occur. Here, I assume that these are already included in the hot-soak and diurnal calculations?

Not changed because this was taken verbatim from previous Guidebook version B760(2007) Section 3.1.3. Will pass comment on to Expert Panel

Poorly written. Should begin 'Diurnal losses are…'. Can I offer something like this >> The increase in ambient temperature which occurs during the daylight hours results in the thermal expansion of the fuel and vapour in the petrol tank. Without an evaporation control system, some of the increased volume of fuel vapour is vented to the atmosphere. At night, when the temperature drops, the vapour contracts and fresh air is drawn into the petrol tank through the vent. This lowers the concentration of hydrocarbons in the vapour space above the liquid petrol, which subsequently leads to additional evaporation. The overall mechanism is also known as ‘tank breathing’.


Editorial

Accepted

Editorial

Editorial

Editorial

Editorial

Again, the wording could be better. Aren't running losses are defined as something like 'the evaporative emissions which occur whilst a vehicle is being driven'? There is always vapour in the fuel tank. Are we talking about additional vapour? Surely there is an increase in the fuel temperature for all vehicle types (e.g. heat from engine and exhaust)?


Does this para refer to vehicle refuelling, fuel delivery, or both. It shoul dbe clearer. Here, it says 'petrol stations'. I'm not sure whether 'gasoline stations' even exists in US English.


In the line 4 we can read: "Without an emission control system, some of the increasing volume of fuel vapor is vented to atmosphere"

Not changed because this was taken verbatim from previous Guidebook version B760(2007) text in section 2.2.1. Will pass comment on to Expert Panel

Change to '…at the same level. However, the test procedure for evaporative emissions increased in severity'.

Not changed because this was taken verbatim from previous Guidebook version B760(2007) text in section 3.3. Will pass comment on to Expert Panel

In general, would prefer the UK English 'petrol' to the US English 'gasoline'. Please use the term 'fuel tank' instead of 'gasoline tank'.

Not changed because this was taken verbatim from previous Guidebook version B760(2007). Will pass comment on to Expert Panel

Change to 'Hot-soak emissions occur when …'. 'Hot-soak' should be hyphenated when used immediately before 'emissions'.


What is the meaning of the Section 2.3 title. It is very vague.


Not changed because this was the heading used in the Guidebook version B760(2007) Heading 3.2. Will pass comment on to Expert Panel

Accepted

CH2.1 is not a unit. Tank breathing again. Editorial

Explain 'SHED'. Accepted

Accepted

Explain what TREMOVE is. Accepted

Accepted

Accepted Sorted

Accepted Sorted

The first sentence is unclear. What does it mean? The distinction between VOCs and NMVOCs also needs to be better explained.



Again, the Section heading (2.4) needs to be more informative.


Not changed because this was the heading used in the Guidebook version B760(2007) Heading 3.3. Will pass comment on to Expert Panel


Table 2-1: In Spain, the percentage contribution of the evaporative emissions to the total emissions from road transport in year 2006 was not 9%, it was 32.7%

Not changed because this was taken verbatim from previous Guidebook version B760(2007) Table 2-1. Will pass comment on to Expert Panel

Not changed because this was taken verbatim from previous Guidebook version B760(2007) text iimmediately above Table 2-1. Will pass comment on to Expert Panel

Some explanation of this Table would be useful. For example, why are evaporative emissions proportionally higher in colder countries than in hotter countries?

Not changed because this was taken verbatim from previous Guidebook version B760(2007) page 1. Will pass comment on to Expert Panel

This is very poor. It does not even relate to road transport. The terms below the equation do not match those in the equation, and no units are given.

What a mess!: This is not the Tier 1 approach for evaporation. You use words like "small combustion installations" and "lime production".

Accepted Corrected

Accepted Sorted

Accepted Sorted

Accepted Sorted

The activity rate for lime production Accepted Sorted

Noted Sorted

Accepted

Accepted Sorted

Accepted Sorted

Accepted Corrected

Noted Sorted

Noted Sorted

Whay 'default'. Can these be changed by the user? Noted Sorted

Sorted

In the decision tree from figure 3.1 the text in the first and second rhomboidal boxes is the same

What is the sense in this chapter of "The Tier 1 approach for process emissions from small combustion installations ...!

We can read: ARproduction = the activity rate for the lime production!

We think it should say "fuel consumption" not "fuel sales"; "fuel sales" could be a good proxy for "fuel consumption" but It is not the same

Tiers classification. Comments are summarized in separate Word document

Decision tree. This is rather poor. The first two 'decisions' contain the same question. In the third 'decision', how is a 'key source' defined? If evap. Is identified as a key source then data collection is recommended. However, the user is then directed to Tier 2. Why not Tier 3, as the requirements for Tier 3 appear to be fulfilled?. The Figure title appears twice.

Decision tree revised markedly to reflect the different tiers, and activity data, required for each

The decision tree is wrong: If the answer is "No" right after start, then you are lead to the same question one more time.

Section 3.2.1 is copied from lime production and does not refer to evaporation

Figure 3-1 has two identical diamonds for Tier 3 and Tier 2

It is questionable if the data in Tables 3-1 to 3-5 are sound. It is recommended to let the original data suppliers make such aggregated figures.

I would imagine that data on fuel sales and data on vehicle licensing statistics are kept by different organisations.

The Tier 1 method proposes evaporation factors in the form g/kg fuel consumed. This was never agreed in the Transport Panel so it has to be discussed. The Tier 1 method proposed by the transport panel only required the total number of cars and trucks operating on gasoline, a temperature range relevant for the country concerned and the DVPE value of the fuel. All this is information that exists in each country. The problem now with Tier 1 is that there is no temperature effect and, therefore, evaporation emissions in Ukraine will be equal to emissions in Algeria! Whatever the method we agree, a temperature correction needs to be introduced for the emission factor. Ambient temperature is not difficult to find in any country!


Sorted

Accepted Amended

Accepted

Accepted Sorted

Accepted

Rejected

Accepted

The Tier 2 method proposes evaporation factors in the form g/kg fuel consumed. This was never discussed in the Transport Panel. The editors should have at least consulted with the transport panel if they wanted to change something from what was agreed. In fact the Tier 2 method proposed is totally anachronistic and is clearly a scientific degradation of the Guidebook. The simple methodology that was proposed in the previous Guidebook is still the original method developed by the CORINAIR 1985 working group and most member states work with it. I strongly reccomend that the simple method of the previous guidebook is used as a Tier 2.


Tables 3-2 to 3-5. Explain 'DVPE'. The names of chemicals do not take capital letters. Should be 'polycyclic aromatic hydrocarbons'. Some of cell contents are cut off

The use of the words 'hot', 'warm' and ;cold' in the terms of the equations is confusing. These need to be explained.

Not changed because this was taken verbatim from previous Guidebook version B760(2007) Simpler methodology. Will pass comment on to Expert Panel

I would imagine that data on fuel sales and data on vehicle licensing statistics are kept by different organisations.

I assume that what we want to calculate is the total national emission. For this, you need to sum over all vehicle categories (Nj). This needs to be incorporated into the equation.

Not changed because this was taken verbatim from previous Guidebook version B760(2007) Equation 1. Will pass comment on to Expert Panel

For consistency with HS and R, why are diurnal emissions not referred to as 'D'?

Not changed because this was taken verbatim from previous Guidebook version B760(2007) Equation 1. Will pass comment on to Expert Panel

It is not entirely clear what a vehicle catgory ('j') actually is. Is it a Euro standard? My first thought was that it related to the descriptions in Tables 3-6 and 3-7, but the problem would then be not having the activity data for these categories. Maybe this is why you include Table 3-11, but I don't think that it is stated explicity. The links between Tables 3-6/3-7 and 3-11 should be stated explicitly.


Accepted Sorted

Accepted

Accepted Reordered and clarified

Accepted

Are these values for a particular country? Noted

The Tier 3 method proposed is a collation of the simple and detailed methodology of the 'old' Guidebook with a mix-up of the emission factors. As it stands now, the whole chapter is a mess and it is impossible to review point by point. Simply put, the Tier 3 text provided makes no sense.

Cold and warm soak/running emissions. According to Equations (2) and (3), these only appear to apply to vehicles with a carburettor. These are likely to be pre-Euro 1 and uncontrolled (i.e. no canister). So why are there lots of emission factors for controlled vehicles in Table 3-6? This shoul dbe explained.



Petrol cars are separated according to whether they have fuel injection or a carburettor, and hence the parameter 'c' (the fraction of vehicles eqipped with a carburettor) needs to be defined. I assume that this is just for pre-Euro 1 vehicles (and possibly Euro 1). Bearing in mind the requirement to combine Tables 3-6 and 3-11, statistics on the fractions by Euro standard should be given to users.


Is the vaopur pressure required? It appears that it isn’t used.



The reference to the Table which contains parking duration distributions (and the Table itself) appears too early in the Chapter. At this point it is not clear to the reader what this means and why it is required.

We don't understand the matrix presented in the table 3-10. From this data, if we compute, for example, the probabilty of the event of not to be parked some time between 1am and 2am hours we obtain 0.9072, this means that the 90% of vehicles are on road at 2am! Without doubt, this is not representative of the Spanish pattern. So, either the numbers from the matrix are wrong, or there is another type of error about the meaning of the matrix as it is explained in the guidebook text.

Comment noted - the data and explanations provided are taken verbatim from Table 6-3 of the previous Guidebook version B760(2007). Will pass comment on to Expert Panel

Not know - the data are taken verbatim from Table 6-3 of the previous Guidebook version B760(2007). Will pass comment on to Expert Panel

Accepted

Accepted Sorted

Accepted

Accepted

How is Section 3.4.6 used? Explain. Accepted

Accepted

Explain 'cats'. Again, at this point it is not clear why fuel tank volume would be required.

Comment noted - the data and explanations provided are taken verbatim from Table 6-3 of the previous Guidebook version B760(2007). Will pass comment on to Expert Panel

At this point I am completely lost. This looks like the start of a more complex 'Tier 4' approach. An explanation of this structure is required. Are sections 3.4.5 to 3.4.12 adjustments to the emissions which have already been calculated to this point? Furthermore, much of the text in these sections repeats the earlier text.

How are the temperatures calculated in Section 3.4.5 used?

Rearranged, but not changed because this was taken verbatim from previous Guidebook version B760(2007) Detailed methodology. Will pass comment on to Expert Panel

Table 3-12. Surely the values in the first column should start at 01:00 and end at 24:00 (or 00:00)? Need to explain that there are 24 intervals in each row because 0.5 hour steps are used over a 12-hour period.

Not changed because this was taken verbatim from previous Guidebook version B760(2007) Detailed methodology. Will pass comment on to Expert Panel


From personal communication from Giorgos Mellios (COPERT team) it appears that the numbers in formulae for parameters a and b are incorrect and they should be replaced by the following figures: a = -11 -0.015*vp +0.065*T; b=0.115-0.00015*vp +0.0001*T; please check it with Giorgos Mellios

NOTED - not changed in this revision because this was taken verbatim from previous Guidebook version B760(2007) Detailed methodology. Will pass comment on to Expert Panel

How is Section 3.4.7 used? Explain. Accepted

Accepted

Accepted

Delete this Section. Accepted

Editorial

There is no section 3.3.3. Accepted Sorted

Accepted


How is Section 3.4.8 used? What is 'permeation and leakage'? Is this a new source? Explain.


The formula in this line has not mathematical meaning, it is not a mathematical formula. The sum over the continuous variable T has not meaning. What is that you want to say?: sum of the formula over the different hours (H1 to H2) considering constant the temperature of each hour, or integral of the formula from T1 to T2? The two things are the same only if the temperature data are discrete (temperature averaged for each hour), but if we apply a continuous function to the maximum and minimum daily temperatures to approximate the hourly variation, the two things are distinct

NOTED - not changed in this revision because this was taken verbatim from previous Guidebook version B760(2007) Detailed methodology. Will pass comment on to Expert Panel

Not deleted, because this was taken verbatim from previous Guidebook version B760(2007) Detailed methodology, Section 8.12. Will pass comment on to Expert Panel

Change to 'Light fuel components tend to be more volatile than heavy ones'.

Not changed because this was taken verbatim from previous Guidebook version B760(2007) Section 9, pB760-15. Will pass comment on to Expert Panel

Some of the topics in Chapter 4 (e.g. gridding, reporting) do not appear to be data quality issues.

No change made - these were the headings provided in the template from TNO. Consult with TNO/Expert panel regarding their retention

Accepted

Section 4.5, which Tier does it refer to? Noted

The reference for COPERT 4 is incorrect. Accepted

noted

noted Sorted

noted Sorted

Noted Sorted

Noted Sorted

noted Sorted

Noted

Some references are needed in this paragraph. Accepted References included

Does this comment apply to all Sections 4.1 to 4.3, or just 4.3? If not, something should be written for Sections 4.1 and 4.2

I believe it does, hence phrase added

Not sure - taken verbatim from Table 10-1 of previous Guidebook version B760(2007). Need to refer question to authors/ Expert Panel

Taken verbatim from Section14 of previous Guidebook version B760(2007). Need to refer comment to authors/ Expert Panel


The Tier 3 method is now a mix of the simple and detailed method from the old chapter?

This is a very serious mistake by the consultants to develop such a new method, without discussing with the data suppliers.

Why do we need to have 3 Tier methodologies? Is it mandatory to have 3 Tiers in the Guidebook? Tier 1 now makes no sense! Again this was never agreed with the Transport panel. Moreover, the methodlogies are again a mess:Why is Table 3-3 part of the Tier 1 since there is no vehicle distinction to Tier 1? Tier 2 has a correction for speed but the emission factors are independent of speed!

Acording the formulae specified in the document for vehicles without control systems it seems the right could be replace "some" by "all"

We have computed the probabilty as follows: the probability of to be parked between H-1 to H hours is the sum from t2=H to t2=H+11 of sum of f(t2,tpark) from tpark=2(t2-H)+1 to t2=24 , being understood that: H+x = (H+x) mod 24 and f(t2, tpark) is the element of matrix at row t2, column tpark.

There appears to be a problem with the NFR code for these sources. Part A of Sector 1 is 'Combustion'. Tyre wear, brake wear and road surface wear are not combustion processes.

This is an inherent problem with the nomenclature for this sub-sector.

Rejected

Noted Altered

Change 'proportion' to 'contribution'. Editorial Altered

Noted

Rejected

Noted

Are there any more recent data? Noted

A discussion of the Tables would be useful. Accepted

Figure 2-1 is poor and is not helpful. Could be much more graphic. Why 'flow diagram'?

used to conceptualise the boundaries of road transport emissions, and is an approach adopted throughout the Guidebook.

'This sector'. Which sector? The three sources, the two NFR codes? Abrasion?

Process description' is not a good title in my view. It is too vague. I also think that it repeats title 2, and would therefore delete it.



Disc brakes are increasingly used in heavy-duty vehicles.

NOTED - not changed in this revision because this was taken verbatim from previous Guidebook version B770(2003) Section 3.2. Will pass comment on to Expert Panel

Section 2.2 title could be more helpful. What exactly does it refer to?



What is the meaning of the Section 2.3 title. It is very vague.

A discussion on emission sources.

It is not possible making an update of the emission estimate?

Not with the same level of completeness. When reporting improves there will be.

Not with the same level of completeness. When reporting improves there will be.

NOTED - not changed in this revision because this was taken verbatim from previous Guidebook version B770(2003) Section 3.2. Will pass comment on to Expert Panel

Some of these data should be updated. Rejected

Surely Tier 2 or Tier 3? Accepted Altered

Noted Sorted

Accepted Altered

Sorted

Accepted Altered

Figure 3-1. Where does Tier 3 fit in? Accepted Sorted

Accepted

Sorted

Accepted Altered

Accepted Altered

Reference codes to be updated. Accepted will be updated

Metrics other than PM10 are included. Accepted Altered

Accepted Altered

Sorted

Noted

Numbers are suitable for indicative purposes. Also not changed in this revision because this was taken verbatim from previous Guidebook version B770(2003) Section 2. Will pass comment on to Expert Panel

Tiers classification. Comments are summarized in separate Word document

The decision tree only explains PM10. But convention needs are TSP and PM2.5 also.

The Tier 1 algorithm resolution is per vehicle classe. But the Tier 1 factors are averaged for all vehicles.


Figure 3-1. PM10 is not a 'species' it is a prticle size metric.

The sum over all vehicle categories should be formally introduced into the equation.

NOTED - not changed in this revision because this was taken verbatim from previous Guidebook version B770(2003) Equation 1. Will pass comment on to Expert Panel

Tables 3-1 to 3-3, is averages only. It is considered a wrong decision not to give data per vehicle classe. Also, TSP and PM2.5 emission factors are needed.


Tables 3-1 and 3-2. The units are clearer as g km-1 vehicle-1. Subscripts required for PM10 and PM2.5.

Tables 3-1 and 3-2. The names of chemicals do not take capital letters. Should be 'polycyclic aromatic hydrocarbons'. Some of cell contents are cut off

This method seems unnecessarily crude. Where do these percentages come from?

The Tier 2 algorithm claims speed dependency. However, no speed dependency is given in the Table 3-4 to 3-15 emission factors.


Table 3-3. Font too large in Table. What are the units?

Table superceded by changed Tables 3-1 and 3-2

Accepted

Where are the values for fs,i and Ss(V)? Sorted

Sorted

Altered

Sorted

Accepted Sorted

Metrics other than TSP are included. Accepted Sorted

Accepted Sorted

Accepted Sorted

Sorted

This could be more helpful. Why is this the case? Noted Sorted

Explain choice of PAHs. Which protocol? Accepted

Accepted

Again, summation over all vehicle categories required.

NOTED - not changed in this revision because this was taken verbatim from previous Guidebook version B770(2003) Equation 1. Will pass comment on to Expert Panel


Where is the speed dependency? Emission factor tables for TSP and PM2.5 are missing.


Is the detailed methodology Tier 2? This is not clear.


This is all badly explained. What is this section (3.3.2) about? Where is the speed dependence? Check that the Table titles match the contents.


Metrics other than TSP are included. This is all badly explained. What is this section (3.3.2) about?

In Tier 3 (Table 3-16), the particulate fractions for other sizes than PM10 are listed for tyre wear. But these fractions should be available from the beginning to support also Tier 1 and 2 calculations.

In Tier 3 (Table 3-17), the particulate fractions for other sizes than PM10 are listed for brake wear. But these fractions should be available from the beginning to support also Tier 1 and 2 calculations.

The Tier 3 methodology for road surface wear is missing.


NOTED - not changed in this revision because this was taken verbatim from previous Guidebook version B770(2003) Section 9. Will pass comment on to Expert Panel

Should be Table 3-19. Not all the substances listed are elements - some of them are ions.

Sorted regarding table referenced - Phrase "Different elements" not changed because this was taken verbatim from previous Guidebook version B770(2003) Section 9. Will pass comment on to Expert Panel

Accepted

Accepted Title changed

Why is there no text under 4.1 and 4.2? Accepted Headings deleted

noted

What is 'method 3'? Editorial Sorted

Noted

Sorted

Sorted

Sorted

Why have HM and POPs not been included? noted

Table 3-19 needs to be improved. As stated above, some of the 'elements' are actually ions. The nomenclature is not consistent (eg. Mg2+ but SO4--. Subscripts and superscripts are required for the ions. The term 'elemental speciation' is used incorrectly. The word 'brake' is spelt incorrectly. What is the meaning of blank cells?

NOTED - not changed in this revision because this table is taken verbatim from Table 13 of the previous Guidebook version B770(2003). Will pass comment on to Expert Panel

The text in Section 4.4 has nothing to do with consistent time series and recalculation! It is more or less the same text as Section 13 "Temporal disaggregation criteria" from the old chapter.

Are the EFs really for asphalt? This is rather specific.

NOTED - not changed in this revision because this is taken verbatim from Section 11 of the previous Guidebook version B770(2003). Will pass comment on to Expert Panel

See http://www.ssb.no/emner/01/04/10/rapp_emissions/rapp_200738_en/rapp_200738_en.pdf, page 41-44

Expert panel to be made aware of these data.

It is a mistake to make such averages, since the number of vehicles per classe is known from the road transport exhaust inventory.


In Tier 3, the expressions for heavy duty load and axles (tyre wear), heavy duty load (brake wear), and speed (all vehicle classes) are present.


However, the speed corrections was to be used in Tier 2.


The old chapter briefly discusses how to treat emission inventories in relation to dispersion models.


Information from old chapter is included, hence nothing has been lost.

NOTED - not changed in this revision because this is taken verbatim from the previous Guidebook version B770(2003). Will pass comment on to Expert Panel

Accepted

AcceptedWhat Directive do you refer to? Accepted Done

Accepted Done

Accepted Done

Accepted DoneWhat is the reference for SO2? Accepted Done

Noted Done

What is "H"? Noted Done

Noted DonePM0.95?? Editorial Done

factor 'H' in equation is not specified Noted Done

Accepted Done

Accepted Done

Accepted DoneA table for line haul locomotives is missing Accepted Done

Noted Done

Noted Done

Noted Done

Emissions other then PM See http://www.ssb.no/emner/01/04/10/rapp_emissions/rapp_200738_en/rapp_200738_en.pdf, page 39-41

NOTED - not changed in this revision because this is taken verbatim from the previous Guidebook version B770(2003). Will pass comment on to Expert Panel


relevant information will be included where appropriate and time permits.

This is just messy key words, not fit for a documentation report

What is the source of the EFs in tables 3-1, 3-2 and 3-3 in this FOD? Also, how is Tier 1 EFs approx 20 times greater than Tier 2 EFs?

There must be errors somewhere in the emission factor tables; It is not possible with such differences between Tier 1 and Tier 2!

Refers reader to RT chapter, but then on following page, refers reader to the off-road section - which is correct or are both relevant?

Table shows Efs in g/GJ of fuel - where do hours come into this??

same data in tables 3-2 and 3-3 whereas table for line haul locomotives is missing

Table 3-2 and Table 3-3 are the same except for the technology name! They are titled Tier 2 and the next line says Tier 1!

General comment - where are the Efs for line haul locomotives?

"(e.g., EX-TREMIS (Chiffi, Fiorello, Schrooten, De Vlieger (2008); RAILI…"

"(e.g., EX-TREMIS (Chiffi, Fiorello, Schrooten, De Vlieger (2008); RAILI…"

The EX-TREMIS railways inventory contains time series 1980-2005 and projections (up to 2030) for locomotives and railcars specific activity data (passenger/freight train km and gross hauled tonne km) as well as for energy consumption and emission factors. Please, send us a request to have a view on the preliminary data (a password is needed) - the project will be concluded by the 30 of April 2008

Noted Done

Noted Done

Noted Done

The emission factors are still missing. Noted Done

Noted Done

Accepted Done

Accepted Doneplease add "EX-TREMIS 2008" Accepted Done

Noted Done

Accepted Doneplease add "EX-TREMIS 2008" Accepted Done

Please quote the EX-TREMIS project, founded by the JRJ-IPTS of Seville and carried aout by TRT and VITO, and provide the weblink to users in the same page http://www.ex-tremis.eu/ - EX-TREMIS combines statistics from different sources and calculate emission factors for specific engine types for each of the 27 EU countries (excluding Malta and Cyprus that have no railways)

The EX-TREMIS railways inventory contains time series 1980-2005 and projections (up to 2030) for locomotives and railcars specific activity data (passenger/freight train km and gross hauled tonne km) as well as for energy consumption and emission factors.

Please quote the EX-TREMIS project, founded by the JRJ-IPTS of Seville and carried aout by TRT and VITO, and provide the weblink to users in tha same page http://www.ex-tremis.eu/ - EX-TREMIS combines statistics from different sources and calculate emission factors for specific engine types for each of the 27 EU countries (excluding Malta and Cyprus that have no railways)

What units are the emissions shown in, in the USEPA table?

Paragraph not clear. For example, "bio-diesel can be used in all diesel engines with slight or no modification" - is this true for 100% biodiesel? Are trains currently running on B2 - B5?

please refer to "gross hauled tonne kilometre (GhTK)"

according to Regulation 91/2003, from the beginning of 2003 all railway undertakings (not only the "principal") shall report their traffic data to Eurostat. Moreover, train movements (national, international and transit train km) are reported considering only the distance covered on the national territory of the reporting country. By using operating data, double counting problem may be avoided. In EX-TREMIS some technical notes to data sources will be made available to compilers/users.

please refer to "gross hauled tonne kilometre (GhTK)"

Noted Done

Accepted Doneemisison factors for additives?? Noted DoneThe number of the chapter is missing Accepted Done

Accepted Done

Accepted Done

Accepted Done

Accepted Done

Noted done

Noted Done

according to Regulation 91/2003, from the beginning of 2003 all railway undertakings (not only the "principal") shall report their traffic data to Eurostat. Moreover, train movements (national, international and transit train km) are reported considering only the distance covered on the national territory of the reporting country. By using operating data, double counting problem may be avoided.

This is just copy and paste from the IPCC 2006 guidelines.

Please add the reference "EX-TREMIS project - Railways Inventory. For information see the website http://www.ex-tremis.eu/ and Final Report: Chiffi, Fiorello, Schrooten, De Vlieger, EX-TREMIS, Exploring non-road Transport Emissions in Europe, JRC-IPTS (2008)"

Please add the reference "EX-TREMIS project - Railways Inventory. For information see the website http://www.ex-tremis.eu/ and Final Report: Chiffi, Fiorello, Schrooten, De Vlieger, EX-TREMIS, Exploring non-road Transport Emissions in Europe, JRC-IPTS (2008)"

General comment - chapter refers to diesel and sometimes to gas oil - use one or the other perhaps as otherwise confusing…


Table 2.1, please harmonise with IPCC 2006 Guidelines

the distinction beteween domestic (coastal) and international shipping in terms of "activity" is not so difficoult to extrapolate. Activity data in EU are collected and provided to Eurostat by all member states according to the Maritime Statistics Directive (Council Directive 96/64/EC). In the Eurostat Newcronos Maritime Database it is possible to find quarterly statistics both for passengers and goods (collections mar_pa_qm_detl and mar_go_qm_detl) spiltted by direction (inw, outw), partner entity and type of cargo. These collecions refers fo main ports only (but 90% of the total traffic). It is possible to consider the total traffic (mar_pa_aa and mag_go_aa) of passenger and goods of all ports by direction and use it for adding the missing quota to detailed collections. References and methodologies for doing it are in EX-TREMIS (2008).

Noted Done

Can't access website


Noted Done

please update

Noted

Accepted Done

Noted Done

Noted done

the distinction beteween domestic (coastal) and international shipping in terms of "activity" is not so difficoult to extrapolate. Activity data in EU are collected and provided to Eurostat by all member states according to the Maritime Statistics Directive (Council Directive 96/64/EC). In the Eurostat Newcronos maritime database it is possible to find quarterly statistics both for passengers and goods (collections mar_pa_qm_detl and mar_go_qm_detl) spiltted by direction (inw, outw), partner entity and type of cargo. These collecions refers fo main ports only (but 80/90% of the total traffic). It is possible to consider the total traffic (mar_pa_aa and mag_go_aa) of passenger and goods of all ports by direction and use it for adding the missing quota to detailed collections. References and methodologies for doing it are in EX-TREMIS (2008).

Please delete, this is not possible to understand/is incorrect/refers to Member States (not Parties)


I disagree with the comment

Also the EX-TREMIS methodology gives an allocation of emissions according to the type of traffic


Also the EX-TREMIS methodology gives an allocation of emissions according to the type of traffic


Footnote: I can't find the reference for the Entec reports anywhere in the chapter.

Please remove or update (this was not in the original outline agreed by TFEIP/is outdated)


What does the terms in bracket [ ] mean? Has this text been updated in accordance with latest IMO regulations?

Table 3.1 and 3.2, please provide original references for emission factors (not EMEP-C) (same with the subsequent tables)

Eurostat collection of vessel traffic (quarterly data, main ports, number and gross tonnage of vessels, by type and size of vessels and inwards direction - mar_tf_qm) provides country statistics for 7 groups of ship types and 22 GT size classes. References are in EX-TREMIS (2008). Please, quote the website. In case, request us a tecnical note on this issue

Eurostat collection of vessel traffic (quarterly data, main ports, number and gross tonnage of vessels, by type and size of vessels and inwards direction - mar_tf_qm) provides country statistics for 7 groups of ship types and 22 GT size classes. References are in EX-TREMIS (2008). Please, quote the website.

Noted Done

Noted Done

Noted Can't access website

Noted Can't access website

Noted Done

Noted Done

What is the origin of this table? Noted Guidebook 2006

Table 3-27: Source? Noted Guidebook 2006

Table 3-27: Source? Noted Guidebook 2006

Where does the data in Table 3-27 come from? Noted Guidebook 2006

Noted Done

All table references are wrong Noted Done

Where does the data in Table 3-29 come from? Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Please check the table references Noted Done

also on the EX-TREMIS website Can't access website


also on the EX-TREMIS website Can't access website

Not only NOx emissions are engine specific, but also PM emissions (see EMS protocols).

Not only NOx emissions are engine specific, but also PM emissions (see EMS protocols).

The calculation formula gives no meaning. Instead of M(fuel sold, engine type) it should


fuel instead of mass: which unit of measure? Mj or tonnes?

EX-TREMIS provides a similar tables or additional parameters in the website (i.e. differentiated conversion factors or weighted EF)

EX-TREMIS provides a similar tables or additional parameters in the website (i.e. differentiated conversion factors or weighted EF)

Activity data has to be segmented per activity type (different EF for hotelling, manoeuvring and cruising in TIER2).

Activity data has to be segmented per activity type (different EF for hotelling, manoeuvring and cruising in TIER2).

Entec 2002? I can't find this reference in the chapter

Table 3-29: Please include the units in the table text

Why is the TIER3 methodology not very well suited to show annual trends in emissions?

The EF - only cruise based now - should be a weighted average EF of cruising, manoeuvring and hotelling.

Why is the TIER3 methodology not very well suited to show annual trends in emissions?

The EF - only cruise based now - should be a weighted average EF of cruising, manoeuvring and hotelling.


we may add such tables on EX-TREMIS. Do you think this may solve problems to compilers or help them?




Noted Done

Noted Done

Accepted done

Accepted done

Accepted Done

we may add such tables on EX-TREMIS. Do you think this may solve many problems to compilers?


I think we should have to quote the relevant facilities provided by the Eurostat Newcronos database. See the comment 11. We have assembled some technical notes for working with Eurostat data and produce/derive ship movements. Please, request us these notes if you think that a paragraph should be added here.

I think we should have to quote the relevant facilities provided by the Eurostat Newcronos database. See the comment 11. We have assembled some technical notes for working with Eurostat data and produce/derive ship movements. Plese, request us these notes if you think that a paragraph should be added here.

The most comprehensive and detailed source of information for Ferry, Ro-Ro, HS craft and cruise ships is the ShipPax database (please visit www.shippax.se for more infos and in particular the webpage http://www.shippax.se/page/page.asp?id=14). I think that the "Thomas Cook…" source is not a good reference.

The most comprehensive and detailed source of information for Ferry, Ro-Ro, HS craft and cruise ships is the ShipPax database (please visit www.shippax.se for more infos and in particular http://www.shippax.se/page/page.asp?id=14). I think that the "Thomas Cook…" source is not a good reference.

This par seems to have been copied from the 2006 GLs; it mentioned the 2006 GLs and makes reference to multilateral operations, this is not in line with the LRTAP reporting Guidelines. Please revise

We have built a distance table (mainly for international traffic) from/to each maritime coastal areas (MCAs) of EU countries to/from EU MCAs, all Mediterranean and Baltic third countries and to 13 overseas areas, namely Black Sea, Arabian Gulf, Red Sea, Indian Sub Continent, Australasia, Far East - China & Japan, South & East Africa, West Africa, US Atlantic & Canada - Great Lakes, Central America – Caribbean, South America – Atlantic, US & Canada – Pacific, South America - Pacific. Do you think this table proveded on the webste could help compilers? The table refers to one sole reference port per country


Accepted done

Consider for Tier 3

Consider for Tier 3

Consider for Tier 3

This section 4.4 has nothing to do with consistent time series and recalculation! It is simply copy and paste from the old chapter section 3.5 "Projections".

EX-TREMIS performed an analysis on historical data (1980-2005) and gives on a country basis activity data (tonne-miles and ship-miles movements by type of ship/engine and by OD), emission factors and total emissions. The EF are differentiated according to the characteristics of the visiting fleet calling at seaports of each country. Please, inform us and request our interim report or the outline of the final report of EX-TREMIS.


EX-TREMIS performed an analysis on historical data (1980-2005) and gives on a country basis activity data (tonne-miles and ship-miles movements by type of ship/engine and by OD), emission factors and total emissions. The EF are differentiated according to the characteristics of the visiting fleet calling at seaports of each country. Please, inform us and request our interim report or the outline of the final report of EX-TREMIS.


Replace the column Consumption at full power (tonne/day) as a function of gross tonnage (GT) with the following values: C = 12,0724+0,0012* GT -1,1501E-8*GT2+4,6484E-14*GT3 C = 7,2194+0,0015*GT-9,1885E-9*GT2+2,6803E-14*GT3C = -2,2602+0,0049*GT-1,6401E-7*GT2+1,7394E-12*GT3C = 0,0919+0,0038*GT-6,1565E-8*GT2+6,7917E-13*GT3C = 6,3501+0,0013*GT+1,6852E-7*GT2-6,2691E-12*GT3+ 5,699E-17*GT4C = 5,2159+0,0034*GT-3,373E-8*GT2+2,062E-13*GT3C = -9,735+0,0486*GT-4,6603E-6*GT2+1,3911E-10*GT3C = -2,2602+0,0049*GT-1,6401E-7*GT2+1,7394E-12*GT3C = .42682 + .00100*GTC = 1,0857+0,0259*GT-1,0279E-5*GT2+1,6828E-9*GT3C = 1,2744+0,0062*GT-6,4603E-7*GT2+5,5193E-11*GT3C = 1,2744+0,0062*GT-6,4603E-7*GT2+5,5193E-11*GT3C = 8,2909+0,0018*GT-4,4908E-8*GT2+4,8931E-14*GT3 SEE ANNEX PAPER FOR DETAILS


Accepted Done

Accepted Done

Accepted Done

Accepted

Consider for Tier 3

Add the reference: "Trozzi C., Vaccaro R. (2006), Methodologies for estimating air pollutant emissions from ships: a 2006 update, Environment & Transport, 2th International Scientific Symposium(including 15th conference Transport and Air Pollution), Reims, France : 12-14 June 2006

Please insert the EX-TREMIS reference or website: EX-TREMIS project - Maritme Inventory - for information see the website http://www.ex-tremis.eu/ and Final Report: Chiffi, Fiorello, Schrooten, De Vlieger, EX-TREMIS, Exploring non-road Transport Emissions in Europe, JRC-IPTS (2008).

Please insert the EX-TREMIS reference or website: EX-TREMIS project - Maritme Inventory - for information see the website http://www.ex-tremis.eu/ and Final Report: Chiffi, Fiorello, Schrooten, De Vlieger, EX-TREMIS, Exploring non-road Transport Emissions in Europe, JRC-IPTS (2008).

It's impossible to verify Efs without clear reference about source of data. No correspondence between Table and references!

TIER1&2 are bunker fuel based methodologies, TIER3 is an activity based methodology. For instance for Belgium, there is a difference of a factor 35 between a bunker fuel and an activity based methodology (Inventory and forecasting of maritime emissions in the Belgian sea territory, an activity-based emission model, Atmospheric Environment, Volume 42, Issue 4, February 2008, Pages 667-676, Liesbeth Schrooten, Ina De Vlieger, Luc Int Panis, Karel Styns and Rudi Torfs). It is possible to make a TIER1&2 activity based methodology (transforming EUROSTAT statistics into activities) on findings in Ex-TREMIS - EX-TREMIS project - Maritme Inventory - for information see the website http://www.ex-tremis.eu/ and Final Report: Chiffi, Fiorello, Schrooten, De Vlieger, EX-TREMIS, Exploring non-road Transport Emissions in Europe, JRC-IPTS (2008).


Consider for Tier 3

Consider for Tier 3

The emission factors used are aggregated emission factors from ENTEC. The TIER3 methodology can be made even more desaggregated by using even more desaggregated emission factors from EMS (AVV, TNO-MEP, RIZA, MARIN, CE-Delft, Haskoning, Emissieregistratie en –Monitoring Scheepvaart, DGG, November 2003). The ENTEC emission factors are predefined for MCR 85% and 20%, as for EMS you can use your country specific MCR and create your own country specific emission factor. A comparison of both sources would be usefull. The EMS protocols are in Dutch, but you can find relevant documentation in English in the MOPSEA report (http://www.belspo.be/belspo/home/publ/pub_ostc/EV/rappEV43_en.pdf) and the Ex-TREMIS project (see comment above for link).


TIER1&2 are bunker fuel based methodologies, TIER3 is an activity based methodology. For instance for Belgium, there is a difference of a factor 35 between a bunker fuel and an activity based methodology (Inventory and forecasting of maritime emissions in the Belgian sea territory, an activity-based emission model, Atmospheric Environment, Volume 42, Issue 4, February 2008, Pages 667-676, Liesbeth Schrooten, Ina De Vlieger, Luc Int Panis, Karel Styns and Rudi Torfs). It is possible to make a TIER1&2 activity based methodology (transforming EUROSTAT statistics into activities) on findings in Ex-TREMIS - EX-TREMIS project - Maritme Inventory - for information see the website http://www.ex-tremis.eu/ and Final Report: Chiffi, Fiorello, Schrooten, De Vlieger, EX-TREMIS, Exploring non-road Transport Emissions in Europe, JRC-IPTS (2008).


Consider for Tier 3

Noted Done

Accepted Done

Accepted Done

Noted Done

Accepted Done

Noted Done

Noted Done

Noted Done

then we are not able to make the calculations! Noted Done

Accepted

Will amend tables (

The emission factors used are aggregated emission factors from ENTEC. The TIER3 methodology can be made even more desaggregated by using even more desaggregated emission factors from EMS (AVV, TNO-MEP, RIZA, MARIN, CE-Delft, Haskoning, Emissieregistratie en –Monitoring Scheepvaart, DGG, November 2003). The ENTEC emission factors are predefined for MCR 85% and 20%, as for EMS you can use your country specific MCR and create your own country specific emission factor. A comparison of both sources would be usefull. The EMS protocols are in Dutch, but you can find relevant documentation in English in the MOPSEA report (http://www.belspo.be/belspo/home/publ/pub_ostc/EV/rappEV43_en.pdf) and the Ex-TREMIS project (see comment above for link).



It is very confusing to read this chapter. Practically all the references to tables in the text

are wrong, and some tables are even missing. Also references are given to an important sources of information (Entec study)

which we can't find in the list of reference. And even more important, the chapter

doesn't print the crusial information from Entec. Inventory makers are asked to look them up themselves.

Because so much remains to be done in this chapter, the reviewers are wasting a lot of time.

be M(fuel sold, fuel type, engine type), in order to have the same resolution as for EF.

When this basis is correct, you can make summations afterwards.

I suggest to include a description of typical devices, e.g.: modified RollsRoyce airplane turbines with cap. of about 30 MW , fed by natural gas. Someone even have low-Nox technologies.

There is no reference either in the Tier 1 or 2 tables for the NFR 1A5a.It would be correct, if EF for this NFR not available (or the same asfor other NFR in this chapter), it would be specified in the text.

Accepted Text modified

Noted HCB included

Accepted

Noted None

Noted

Noted None

Rejectedexplain 'autonomy' - or use different term Accepted Modified

In table 1-1 (and furtheron) the term 'non-residential heating' is introduced. This term is highly confusing, and requires change. Please avoid (throughout the text) as much as possible this kind of negative definition. Here use "commercial/institutional heating" instead. Also the term "other" should be avoided and may only be used when explicitely defined as NFR term.

Fishing is not covered in the small combustion chapter and should therefore be removed from the list of activities covered. Again there is no mention of HCB in table 1-1.

Subdividing this sector needs to be done in a consistent manner, in order not to confuse a reader. The list as presented now is an ambiguous mixture of NFR attributions (but note my comment [1] above) and techniques (CHP)

Text modified to align technologies more with NFR

The only pathway of interest (emissions from combustion) is not described in Fig. 2-1

In consequence to comment [2], subsections within the section 2.2 should be consistent to the sub-division first introduced in Page 3/line 10-12. Furthermore, levels of sub-types are not clear or consistent (example below, comment [6]). Finally, techniques and sub-types need to match emission factors presented. I.e., differentiating between 'open fireplaces' and 'partly closed fireplaces' is only useful when also emission factors are being presented (This example being chosen here for simplicity, but the point is applicable throughout). A national expert should be able to find the type of installation operative in his/her country according to the description in the list of techniques, and then look up an appropriate emission factor. Ideally, for each type of appliance an own set of emission factors is presented by fuel. Of course this will not always be possible - but in the current text there is almost no such connection.

Text modified to align more closely with NFR, tier 1 factors are on fuel basis so no technology relevance; Tier 2 has more disaggregation but not a full split as this would be unmanageable but there are more appliance-specific details in Appendix

Strong chapter on techniques (Chapter 2.2). One would wish that all chapters were on this high level. However the subchapter on CHP should be expanded.

figure 2-1: wrong title (…contribution from railways…)

Comment for wrong chapter - have taken into account in 1A3

Accepted Text modified to clarify

Accepted Text modified to address

Accepted Text included

Accepted Done

Accepted Text modified

Noted

Noted Text modified

Accepted Text order modified

Rejected

Accepted

Accepted Done

Stove types can not be differentiated by the description presented. This is widely the case for the whole list of stove types. Criteria used to form subcategories are very ambiguous (from fuel type - 'pellet' to appication 'cooking' and further to abatement 'catalytic')

Finish stove' and 'Russian stove' may not be expressions that are very helpful to describe stove types outside particular countries which apply these terms. It is o.k. to use those as a support, but one should not expect this is sufficient explanation

Authors may wish to refer to the fact that - while there exist stoves predominantly constructed for specific fuels - there are also multi-fuel stoves. These stoves are popular in some countries as they are able to burn waste - a considerable emission problem

A very simple statement would help an expert to understand which type his installation belongs to: "Boilers are devices which heat water"

Automatic feeder systems are also available for wood logs. The advantage of automatic systems is that they minimize handling errors (primary/secondary air, constant combustion temeratures, …)

Condensing boilers may achieve efficiencies even above 100% - this is basically their feat. For an expert using this guidebook, one could make it esier to identify such an installation: "condensing boilers require a chimney resistant to the liquid condensate".

Accepted but detail not needed here.

When the potential for large dioxin emission is mentioned it would only be natural to also address the possible formation of other POPs notably HCB.

Primary measures can be presented in a more systematic way: modifed fuels / modified heater / modified combuation

Figure 3-1 does not contain any information specific for small combustion - why is it here then?

It is a generic decision tree but the elements are relevant to small combustion plant

I strongly disagree: if we limit a country's contribution to Tier 1 already at this stage, we should forget about the whole effort. Applying default emission factors to IEA (and similar) statistics can be done much more reliably in a centralized manner, and in fact has been done already (see GAINS model)

Text modified slightly but Tier 2/1 may be the most appropriate with (unlike some other sectors) Tier 3 only being achievable using the model or hybrid approach .

In row 11 - AR fuel consumption, but in the row 14 - AR production -activity rate for the lime production

Noted

Rejected

Noted

Noted

Accepted

Noted



Accepted

Accepted

Accepted

Noted

It would be better if these tables 3-1 to 3-12 refering to Tier 1 were listed in order from 1a4a, 1a4b and 1a4c etc. Also what size boilers to these EFs relate to 20-50 MW or <20 MW?

See comment [1] above: avoid 'other', instead use 'medium/light liquid fuels'

Based on NAPFUE fuel classifications

Here and elsewhere: If the range presented for emission factors extends over two orders of magnitude, reporting has very little meaning

The selected fuel groupings for residential and non-residential combustion seems less than ideal. Biomass should be divided into wood and straw.

At Tier 1 we have brought together by main fuel classifications

Common comment for Tier 1 and Tier 2 tables: emission factors are shown with reference to Guidebook 2006. But most of emission factors do not coincide with the factors in the Guidebook 2006. Especially large differences are for SOx, CO, NMVOC, PCDD/F, PAH. No emission factors for indicator PAH while Guidebook 2006 includes them.


It would be possible to include corresponding SNAP codes in the allTier 1 and 2 tables

Table format is fixed to reflect NFR but SNAP also provided

In table 3-2 (and all other Tier 1-2 tables) the total PAH emission factor is resulted, but according to requirements of reporting Guideline it is necessary to report separately on four substances

In the table 3-2 (and all other Tier 1-2 tables) from row "Not estimate" would be deleted "POPs" and into row "Not applicable" include Annex I POPs (by each substance).

Table 3-5: error in Pb and Hg emission factor (in column Value are shown as 0, but in column Lower – not 0).

Rounding/significant figure issue

Several values listed as "0" in table 3-5 and 3-6. Lack of HCB emission factor as well as detailed PAH emission factors are a problem.


In the table 3-5, row fuel name - "Other Liquid Fuels". It is not clear - other, excepting residual fuel oil, or "other oil" (according to fuel defini

Include summary table of fuel classes

Table 3-6: error in Pb emission factor (in column Value are shown as 0, but in column Lower – not 0).


The dioxin emission seems to refer to the emission factor for advanced fireplaces in the existing guidebook. A general tier 1 emission factor should probably be somewhat higher.


In table 3-6, upper estimate for Se is below the recommended value; in tab. 3-7, several metals exhibit an upper estimate of '0'


Noted Text modified

Noted

Noted

Noted

Accepted

In the table substitute "Solid fuel" with "Coal fuel" Noted

Accepted

Noted

Noted

Accepted

Noted

In table 3-5 the fuel name is "Heavy Fuel Oil". According to fuel definition in the new reporting guideline it must be "Residual Fuel Oil"In other combustion chapters the same.

It seems odd that all particles from biomass combustion in the non-residential sector is assumed to be PM2.5.


Again Tier 2, Tanles 3-14 to 3-26 seem to start with residential (1a4a) and then move onto Other sectors (1a4a and 1a4c). Also there is no information about thermal size of combustion plant here.

Table 3-13 amended slightly, note that NFR has no size distinction

in table 3-13 and subsequent tables: provide emission factors to instllations as they have been described in section 2.2 - see comment [4]

Addressed where possible.

solid' fuel is first mentioned here - put this way it would comprise also biomass; use 'coal' (as in the previous part of this chapter) or 'solid fossil fuels'

Text amended to include 1A1a fuel types

See earlier note on fuel classification - don't want to preclude coke and other solid fuels

The tables contain a very large number of emission factors quoted as Guidebook (2006) but with different values. It's impossible to present similar tables ! Some examples are reported in EF_comments.


CONCLUSION: ALL THE TABLES MUST BE REVISED

The existing guidebook list a dioxin emission factor of 800 ng/GJ for standard fireplaces and 300 for advanced fireplaces. Therefore the emission factor of 350 ng/GJ with reference to the existing guidebook seems wrong.

In table 3-16 the EF for CO is 0.01 g/GJ? Surely this is a mistake. In the next table 3-17 CO has an EF of 1000g/GJ, or 100,000 greater.


Tables 3-17, 3-18, 3-20: heavy metals emission factors should be rounded.


Table 3-20: errors in EF for PM2.5 (in column Value are shown as 0, but in column Lower – not 0).


The dual reference system is confusing. Either the reference is the exisisting guidebook or it is CITEPA. Several of the listed emission factors does not correspond to the values in the existing guidebooks values for stoves liquid fuels.


Table 3-23: errors in EF for PM10 and PM2.5 (in column Value are shown as 0, but in column Lower – not 0); EF for TSP should be checked.


Noted

Noted

Accepted Table included

Accepted Text deleted

Noted

Accepted

Accepted

Noted

Most values in table 3-22 refers to the existing guidebook, however several of the listed emission factors do not correspond to the emission factors provided for wood burning boilers in the existing guidebook.


Table 3-26: value EF and 95% confidence interval are the same for TSP, As, Cd, Cr, Hg, Pb.


CO seems to be to high for a diesel engine (liquid fired) in table 3-26. In the tables 3-24 and 3-25 turbines running on gas and oil are included. In these two table als gas engines should be introduced so that the NOx values are comparable between different prime mover technologies.

See also:http://www.euromot.org/download/news/positions/stationary_engines/Future_stationary_engine_emission_legislation_Nov04.pdf

http://www.euromot.org/download/news/positions/stationary_engines/EIPPCB_BREF_euromot_comment_may_02.pdf

Why is there no default emission factors given for natural gas fired reciprocating engines. It would seem that a large part of the fuel use for sttionary engines would be natural gas.

Suggest to do it the other way round - data reported to the UNFCCC will have no focus on wood consumption and thus will likely provide unreliable numbers. Instead: Results on wood consumption provided here should be made use of for the UNFCCC submission also.

The Tier 3 method needs more elaboration. Should inventory compiliers use the technology based EFs in Appendix A or not? These EFs tables should not be placed in an Appendix if they are part of the Tier 3 methodology.

The choice of methodology is up to the country, the significance of the source and the resources available.

This glossary should either be expanded or removed.

Some sources listed as references in the chapter are missing from the list of references, e.g. CITEPA 2007, Gustavsson et al. 1993, CEPMEIP 2004, DTI 2005, Guidebook 2006.

I suggest to indicate if emissions factors are based on field measurements (real conditions) or stationary conditions which e.g. is the case for (BLT) 1999 to BLT (2005). Additionally It would be useful to know how many ovens/boilers have been measured and if the emission factors are representative for e.g. a specific technology which is typical for a country or region.

We have no additional data - these are as provided in B216

Editorial Ref modified

Editorial Ref corrected

Editorial

NotedThe title of the tables are not visible. Editorial Done

Editorial Done

Noted

Noted Final checking needed

Noted

Noted

BLT (2005/2)Hyperlink does not point to a specific document: http://www.blt.bmlf.gv.at/menu/index_e.htm.

Please correct reference to "Österreichische Emissionsinventur für Stau*b*" and "Umwe*l*tbundesamt"

Appendix B dos not add much additional information to appendix C of Chapter 1A1 (they are widely identically). I suggest to just add a table with typical reference O2 concentrations and the 2 Diagrams and add a reference to chapter 1A1.

Agree but they are separate chapters, not sure we can split out the appendix.

Reference O2 concentration of wood is often 13%. I suggest to add a line for this to the diagrams.

Not changed, there are many reference O2 levels eg 7, 10 or 11 national preferences apply. EN303 (boilers <300kW) is 10%

The tables are unreadable as they are partly off the page.

Emissions that are related to different engine types are missing e.g. Spark Ignition engine (gas mode).We recommend to refer on page 102 of the following document:

http://www.ymparisto.fi/download.asp?contentid=3708&lan=fi

Furthemore the French limits for Dual Fuel stationary engines are missing. These should be added.

Other details: I reckon a final proofreading will be performed to take care of a number of editing issues (incomplete sentences, abbreviations presented but not explained in Tab 4-4, citations (CITEPA 2007), and similar)

Lack of line numbering of the chapter on small combustion will result in fewer line number referrals.

As reference is made to Chapter 1A4, should we understand that industrial engines are the same than engines in Commercial, Institutional and Residential sectors? Does it matter the power of the engine?

Small CHP for public power uses the same technology as non-residential CHP. Gas turbines can often be larger than 50 MWth but engines are generally smaller (usually a lot smaller).

Not relevant to 1A4tion in the new reporting guideline) Comment corrupted ?

None

Noted Done

Accepted Done

What is the number of this directive? Noted Done

Rejected Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Taking into account that raw materials have also sulphur content, where are the net SOx emissions estimated for cement and lime production?: either in 1.A.2.f or in NFR categories 2.A.1 and 2.A.2?

For instance the emission factors for CO, SO2, TSP etc.

Don't see where this is referred to

What are the total net SOx emissions, taking into account the three components: gross SOx from fuel, gross SOx from raw materials and SOx captured by raw materials?

This is wrong and confusing. The SNAP group 080100 contains military activities (and different fuel types), please refer to error 1d.

You must show tables for each NRMM directive and explain what they contain.

Where is there a precise definition of equipment level and equipment type? This must be highlighted.

Tables for 1A2fii (industry machinery) and 1A4a ii (Commercial/Institutional: Mobile) emission factors are missing.

It is necessary to explain, that only agriculture and forestry machinery are behind the figures.

Table 3-3: The categorisation of recreational craft is wrong. These types of vessels must be included

This sentence gives no meaning. A lot of diesel fuel is being used by stationary engine, and to assume all

The LPG fuel type is also present. In fact, you may consider to use the term fuel/engine type.

Please be aware that recreational craft and military vehicles must be treated differently

Table 3-13 to 3-16: The figures in this table relates only to recreational craft. Tables 3-13 (diesel) and 3-15 (4-stroke gasoline) concerns the emission level prior to the directive 2003/44 emission standards.

You have forgotten two tables for 2-stroke gasoline boats, relating to emission levels before directive 2003/44, and for directive 2003/44 emission levels.

Still missing is three emission factor tables for diesel fuelled equipment in the NFR sector 1A4aii

This section is essential for inventory makers in order to allocate fuel into emission layers, but it gives no guidance at all.

Noted Done

Noted Done

Noted Done

Chapter; Non road mobile sources and machinery Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

A study from 1993 is not recently made. Nothing has been done to update this part of the text.

Since there is still no updates in this part, I really have no opinion.

This table is full of errors. Please use the tables directly from the old guidebook.


There are many serious mistakes in this chapter. Some of them relates to 1) errors in NFR code categorisation

and 2) errors in computed emission factors when transferring from g/tonnes of fuel to g/GJ.

Error 1a): The data that is stated for 1A5b (Other) in the new chapter has nothing to do with military activities!

These data, submitted by Morten Winther are valid for boats, and hence represent recreational craft. The SNAP code for recreational craft is 0803,

which is specificly mentioned in the old guidebook. Following the CLRTAP transfer procedure between SNAP and NFR codes,

recreational craft are further classified as part of Navigation 1A3d (agreed by all member states).

If we want recreational craft to be included in this chapter, it is necessary to include the code 1A3d ii (National Navigation) in the table on Page 1.

Error 1b) In the EMEP Draft 2007 guidelines for estimating and reporting guidelines the NFR category 1A4a ii (Commercial/Institutional: Mobile) now appears.

This category must be included in the table on Page 1.

Error 1c): The category 1A4c iii (Agriculture/Forestry/Fishing: National Fishing is treated in the Navigation chapter.

Hence this code should be deleted from the table on Page 1.

Error 1d): Military mobile activities are NFR grouped as 1A5b (other), and contains aviation, land based and sailing activities.

If you want to present emf for military in this chapter you must produce completely new figures, or perhaps repeat the data from the old guidebook.

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Error 2): A calculation error has been made in all the emission factor tables, when transferring from g/tonnes to g/GJ.

In the spreadsheets provided by Morten Winther, g/GJ related emf are calculated. Please use these factors instead.

Serious omission: the information on test procedures from the old chapter must be included (and updated) in the new chapter

It is no help for inventory makers to have such vague description

The Tier 1 figures in the Tables 3-2 to 3-8 are all wrong. Please use the factors from Morten Winther, directly.

Fishing vessels are treated in the Navigation chapter.

in the sector 1A3d (Navigation). This follows the correct transfer between SNAP (0803)

and the NFR (1A3d) category. In the current version of the guidebook, SNAP 0803

is clearly described as inland waterways, containing also the activities by recreational craft.

It is a very big mistake not to follow the nomenclature agreed by the inventory community.

If you want to present emf for military you must produce completely new figures, or perhaps repeat the data from the old guidebook.

fuel being used in NRMM would introduce a serious error in the inventories.

Tables: Inventory makers must have the information of which sales year relates to which emission layers.

Tables: Tier 2 emission factors prior to stage I must be split into three technology levels (<1981, 1981-1990, 1991-stage I) instead of applying one average.

The differences between layers are too big to ignore. You must use the data provided by Morten Winther.

Tables 3-14 (diesel) and 3-16 (4-stroke gasoline) concerns the emission level corresponding with the directive 2003/44 emission standards.

It has nothing to do with military equipment! You are mixing up all definitions.

In addition, the Table 3-14 to 3-16 captions include the NFR category 1A4c: Please stress that it is the recreational craft part of Navigation we are dealing with here.

These data I calculated for you also, as a part of our agreement.

Noted Done

Noted Done

Noted Done

Noted Done

Noted Done

Editorial Done

Accepted Done

Accepted Done

Editorial Done

Accepted

Accepted

Accepted

Accepted Done

In the text the reference is Tsibulski not Tisbulski. Editorial Done

Accepted Added to references

Noted

1) You must provide some kind of information, for instance %-values, which distributes fuel consumption as a function of engine age for each NFR code.

Such distribution functions can be derived from the Winther & Nielsen database.

2) You must also provide information of which sales year relates to which emission layers.

You can find these data in the relevant directives, or alternatively derive aggregated sales year information from the Winther & Nielsen database.

3) Finally, you must provide information of average engine life times for the different NFR codes. This can be derived from the Winther & Nielsen database.

Change as "The extraction and treatment of coal result mainly in emissions of methane."

Delete the sentence "This sector was estimated to account for 22% of the total national CH4 emissions in the UK in 1991 (Gilham, 1994)." It's an old data not relevant for the GB.

Change as However, also NMVOC, PM and CO2 are emitted

Change "methane emission" with "firedamp release"

Delete from not applicable: "TSP, PM10; PM2.5; Pb; Cd; Hg; As; Cr; Cu; Ni; Se; Zn;" Put in Not estimated:: "TSP, PM10; PM2.5; Pb; Cd; Hg; As; Cr; Cu; Ni; Se; Zn;"



Insert after the title: "A Tier 3 methodology for emission factors estimate for open dust sources at coal mines can be found in US EPA AP42 in Chapter 11.9 Western Surface Coal Mining (US EPA, 1998)"

Insert the reference: US EPA, 1998 AP 42, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources, Fifth Edition, Volume I, Chapter 11.9 Western Surface Coal Mining, 1998

There are no guidance of storage of solid fuel. Should particle emission from coal storage be estimated and if so there should be a default emission factor made available.

Are you sure PCB = 2 g (it's not mg?) Accepted

Accepted Done

Accepted Done

Accepted Done

Accepted Done

Accepted Sentence added


Noted

Noted

Noted

Accepted

Noted

Noted

EF removed, not applicable here

Add the sentence "In this category can be included Coal Handling And Storage. For this A Tier 3 methodology for emission factors estimate can be found in US EPA AP42 in Chapter 13.2.4 Aggregate Handling And Storage Piles (US EPA, 2006)"

Insert the reference: US EPA, 2006 AP 42, Compilation of Air Pollutant Emission Factors, Volume 1: Stationary Point and Area Sources, Fifth Edition, Volume I, Chapter 13.2.4 Aggregate Handling And Storage Piles, 2006

Why is venting included in this chapter? It should be placed in the chapter 1B2c VENTING and flaring.

delete "or liquefied gas": it's included in subsequent 2.1.8 paragraph

insert a comment about "oil pumps" and indicate where Emission from these are computed, particularly when pumps are fuelled by oil (as in the case of ships pumping of oil at maritime terminal"

insert a paragraph about "gas compressor station" and indicate where Emission from these are computed

The references are very old. The newest one is more than 20 years old. It should be discussed whether the data are still valid.

I can only agree with the inserted comment, that better data should be available. This issue should however had been solved prior to releasing a first order draft.

I am unable to reproduce the resulting emission factor in table 3-2 based on the current values in the existing guidebook. The comment states that the geometric mean from distribution has been added based on table 8.17 in the existing guidebook.

Very strange sentence since the inserted comment contradicts the meaning of the sentence.

Comment removed; is wrong

insert a Tier 2 evaluation for 050601Pipelines and 050603 Distribution networks; I think it's a priority

The values in the existing guidebook varies greatly from 0.091 to 3.2, therefore just taking a geometric mean of all values listed without an accompanying explanation does not seem appropriate.

Noted

Noted

Accepted

Accepted Done

Accepted Done

Erase Table 3-23 as must be included in 1.B.2.a.v Rejected

Accepted Done

A couple of the references are not used in the text. Accepted

Volume title correctly: 1.B.2.a.i, 1.B.2.b. Noted

Noted

Accepted Done

Accepted Figure updated

Accepted Donereplace "unit units" with "unit" Editorial Done

Editorial Done

Accepted Done

Accepted Updated to 0.4

The values in the existing guidebook varies greatly from 0.001 to 3.1, therefore just taking a geometric mean of all values listed without an accompanying explanation does not seem appropriate.

The values in the existing guidebook varies greatly from 0.009 to 3.1, therefore just taking a geometric mean of all values listed without an accompanying explanation does not seem appropriate. The value of 3.1 stems from Romania and seems like an outlier

As mentioned this chapter is directly copy/paste from the existing guidebook. A lot of data concerns venting, this information should be moved to the correct chapter.

I would suggested to move factors for venting to 1.B.2.c.

delete all the point 3.4.2.5 Oil loading and transport must be included in 1.B.2.a.v

Clarify Table 3-24 (in the text erroneous indicated as Table 8.18): must be included in 1.B.2.a.v and review the text consequently

Checked; some references removed

Considering the values in that table covers only distribution the emission factor seems low.

Delete "Passant, 1993" This reference is no longer given and theEPA reference is wholly adequate.

Figure 2-1: The notation of Heat and its emission is missing from the chart. See 2nd comment above.

In Table 3-2, Section "Abatement Technologies" the use of thephrase "Primary cyclone......." may be misleading. To avoid confusion, it is recommended that the abatement technology isdescribed as "Cyclone systems installed internally within the regenerator".

Title of Table 3-3 requires amendment as it currently reads ".......reforming unit units". Delete the word "unit".

change "3.3.2.7 Diffuse emissions" with "3.3.2.7 Gasoline storage. For depots of gasoline in refinery refer to Tier3"

In Table 3-6, the Upper Confidence Limit looks incorrect. The samepollutant and EF are given in the Tier 1 Table 3-1, with an upperlimit of 0.4 instead of 0.6 given in this Table.

Rejected

Accepted Done

Accepted Done

Accepted Done

Accepted Done

Accepted Done

Accepted Done

Editorial Done

Editorial Done

References should be (US EPA, 1995, CEN, 2008) Accepted DoneReference should be "US EPA (1995)" Accepted DoneReference should be "CEN (2008)" Accepted Done

Accepted Done

Accepted Done

replace "This section provides Tier 3 information for refineries.

Proposed changed text to clarify where the cyclones are installed:"The basic catalytic cracking regenerator design normally incorporates, inside the regenerator vessel, cyclone systems to separate the catalyst particles from the hydrocarbon vapours.Additional cyclones systems and/or electrostatic precipitators maybe installed external to the regenerator to abate further the particulate emissions".

In Table 3-7, the reference for "partial burn with CO boiler" is wrong. This is not given in CONCAWE 3/07. The oxidation value of 99.5%is given in the Commission Decision of 29-01-04 on GHG's- see OJ No. L59, 26.02.2004 (comment later re p24)

In Table 3-7, the reference for "full burn regeneration" is wrong. This is not given in CONCAWE 3/07. The oxidation value of 99.5%is given in the Commission Decision of 29-01-04 on GHG's- see OJ No. L59, 26.02.2004 (comment later re p24)

In Table 3-7, the reference for "additional cyclone stages" is wrong. This is not given in CONCAWE 3/07. A reference to the RefineryBREF should be given i.e. "European Commission (2003)"

In Table 3-7, the reference for "electrostatic precipitators" is wrong. This is not given in CONCAWE 3/07. A reference to the RefineryBREF should be given i.e. "European Commission (2003)"

In Table 3-7, to clarify where the "Additional cyclone stages" arelocated, it is recommended to change this to "Additional cyclonestages installed external to the regenerator"

Should this equation be numbered i.e. be equation "(9)"?

Should this equation be numbered i.e. be equation "(10)"?

Add new paragraph: "A recent development is the use of hand-held optical imaging devices to detect leaking components permitting surveys to be undertaken more quickly (Epperson et al., 2007)."

There are issues on double counting which are highlighted on page 1,lines 9 to 17. Suggest repeat here.

Reference should be "US EPA (1995)" Accepted DoneReference should be "US EPA (1995)" Accepted Done

Accepted DoneReference should be "US EPA (1995)" Accepted Done

Accepted Done

Accepted Done

Accepted Done

Accepted Done

Accepted DoneNo EF for SNAP 050402 Noted

Current text in this paragraph should be deleted and replaced: Reason: optical remote sensing techniques can only measure emissions over a very short time period e.g. a few hours. Emissions from refinery sources generally vary widely with time, e.g. floating roof tank emissions are highly dependent on wind speed. It is not valid, therefore, to extrapolate these short term measurements to calculate refinery annual emission inventories asthis would result in significant errors. It is proposed that the It is proposed that the following text is inserted in its place:"Remote sensing using optical gas imaging may be used to identify,for example, if any external floating roof storage tanks are operating outside of the performance bounds for which emission factors are valid, permitting focussed maintenanceto ensure that factors can then be used for these sources forinventory purposes."

Reference EPA 1993 is incorrect. It should be: "United StatesEnvironmental Protection Agency (US EPA) 1995. Protocol forEquipment Leak Emission Estimates. EPA-453/R-95-017. Officeof Air Quality Planning and Standards, Research Triangle Park,North Carolina"

Reference CEN (2005) should be updated as this Standard is now published as EN 15446, 2008.

The reference US EPA 1994 is not referred to in the chapter. It should be removed from the list.

If the proposed text addition above (p 22, line 7) is accepted, thenthere is the need for a new reference: "Epperson, D et al. "Derivationof new emission factors for quantification of mass emissions whenusing optical gas imaging for detecting leaks". Journal of the Air andWaste Management Association (JAWMA), Vol. 57, Issue No. 9,September 2007".

A new reference is required for Table 3-7 (see comments above). This is: "European Commission (2004), "Commission decisionof 29 January 2004 establishing guidelines for the monitoring andreporting of greenhouse gas emissions pursuant to Directive2003/87/EC of the European Parliament and of the Council (2004/156/EC). Official Journal of the European Communities No. L59, 26.02.2004"

Noted

RejectedDirective number is 94/63/EC, not 63/94/EC Editorial DoneDirective number is 94/63/EC, not 63/94/EC Editorial Done

Accepted Done

Editorial Done

Editorial DoneDirective number is 94/63/EC, not 63/94/EC Editorial Done

Editorial DoneDirective number is 94/63/EC, not 63/94/EC Editorial Done

Editorial DoneDirective number is 94/63/EC, not 63/94/EC Editorial DoneDirective number is 94/63/EC, not 63/94/EC Editorial DoneDirective number is 94/63/EC, not 63/94/EC Editorial DoneDirective number is 94/63/EC, not 63/94/EC Editorial DoneDirective number is 94/63/EC, not 63/94/EC Editorial DoneDirective number is 94/63/EC, not 63/94/EC Editorial DoneChange "reportedly" to "reported". Editorial Done

AcceptedDirective number is 94/63/EC, not 63/94/EC Editorial Done

Accepted

The figure is nice. A similar one should be provided for marine terminals or include marine terminals in the present figure 2.1

Add the reference: ARPAT (2007) Agenzia Regionale per la Protezione Ambientale della Toscana, Monitoraggio delle aree geotermiche. Rapporto Finale, Anno 2006, Novembre 2007

Propose change "There are two major sources ..." to "There are three sources ....". Reasons: following the statement are listed three sources, of which only one (standing storage emissions) issignificant.

Replace "into a cargo tank truck" with "into a cargo tank truck or ship"

Add "occur when" at start of this line to follow on from line 8.

Reference should be "European Commission, 2006" not "EIPPCB, 2005"

Should be "European Commission, 2006" not "EIPPCB, 2005"

AR - gasoline production statistic (p. 11, row 8). On the p.12, row 12 - amount of gasoline sold should be used as activity statistics

Descriptions harmonized; gasoline sold is relevant activity here

Give a definition of oil product. What products have to be included? gasoline, gas oil, fuel oil, aviation gasoline, distillate oil ….?

Description made more clear

What is throughput : crude oil ? Something else? Define please. Provide also some default values for average vapour pressures for the different products from crude oil to naphtha, gasoline, gas oil…


Gasoline considered here, has been added to text







Accepted Correct here

Accepted Done

Accepted

Accepted

Accepted

Editorial Done

Add "is" between ".....pressure" and "the vapour ..." Editorial DoneTable title should be 3-12 Editorial DoneDirective number is 94/63/EC, not 63/94/EC Editorial Done

Accepted DoneWhy it is not throughput but gasoline? Noted

Noted

Rejected

Accepted







In the table 3-6 SNAP 050501 or 050401 (marine terminals?)

references should not be guide book 2006 but CONCAWE 2007




What is throughput in service station stations, gasoline and gas oil? Provide default vapour pressures or explain how to get them

Reference made to US EPA description





Replace "previously contained gasoline" with "previously contained crude oil, gasoline or other highly volatile products"


the efficiency of 98 % is too optimistic in real life the efficiency is lower. 90 to 95 would be more reasonable.

Concawe considered the methodology as obsolete! Replace all with the sentence "For depots of gasoline in refinery refer to Tier3"

This explanation comes too late. However not only gasoline is volatile. Aviation gasoline, Naphtha, crude oil are stored and displaced. They have to be considered. Gas oil could be considered if necessary in countries with high temperature.

Accepted

Accepted DoneDirective number is 94/63/EC, not 63/94/EC Editorial DoneShould be Table 3-13 Editorial Done

Accepted Done

Editorial DonePropose move to Section 4.2 Accepted Done

Accepted Done

Editorial Done

Editorial Done

Accepted Done

Accepted Done

The efficiency of 90 % is too optimistic. From studies carried out in France the efficiency for a station with an active system working correctly is 80 %. You have also to consider that due to poor maintenance, most active systems become less efficient and some of them are out of service. If you do not have statistics on the % of active systems working correctly, an average efficiency taking into account the systems out of service can be 60%. The EGTEI document (see the EGTEI web site) describes this situation. This situation is common in Europe. Germany and Switzerland have recently implemented the use of self controlled active systems (the equipment of existing stations should be finalised in Germany this year and 10 % of service stations are already equipped in Switzerland.). Only with such systems, the efficiency can rise up to 90 %.

Comment taken into account; some text on this added and reference to EGTEI made

Delete "For example, it will use a knowledge of equipment components fitted in the refinery to provide estimates of process fugitive emissions." as this example is not relevant to this NFR.

The text currently in 4.5 seems more appropriate here than in 4.5

Change "For storage ..." to "For example, for storage ..."

Add "refinery" before "storage" to clarify what is in 040104.

Add "terminals and " between "marketing" and "depots" to ensureall facilities are captured.

Glossary: Stage I Controls - "terminals (dispatch stations)" should be replaced by "refinery dispatch stations".

Glossary: True Vapour Pressure - suggest add "See section 3.3.2.1"at the end of the definition as the formula to calculate TVP is giventhere.

Glossary: Vapour Destruction Unit (VDU). Delete this definition, asVDUs are not described in the text as not permitted in EU.

Rejected

Accepted DoneDelete! Rejected

Rejected

Accepted

Accepted

Noted

" with : "For storage tank emissions Concawe report suggests the use of the latest edition of API documents for Floating Roof Tanks (API,2003), and Vertical Fixed Roof Tanks (API, 2002). For Aboveground Horizontal Tanks, Concawe report suggests to use the latest edition of U.S. EPA methodology (U.S.EPA, 1995). Note that this reference normally contains the latest version of previously quoted API methodologies. An emission calculation software is available from the US EPA via their website, http://www.epa.gov, or on a CD-ROM(U.S.EPA, 2005). This CD also contains the EPA publication (U.S.EPA, 1995) and API documents (API 2002; 2003)."

replace "Most emission factors are taken from the Guide to Geothermal Energy and the Environment (Geothermal Energy Association, 2007), available via http://www.geo-energy.org/publications/reports/Environmental%20Guide.pdf." with "Emission factors results from measurement performed by the environmental protection agency of Toscana region, Italy (ARPAT, 2006). The region is the main Europe producer of this kind of energy.

Due to differences in chemical composition of geothermal fluid, site dependent emission factors obtained by sampling is suggested.

Added to text as a preferable option

Since the authors, judging by the inserted comment, do not know, what is meant, I will take a crack at solving the mystery. My best bet is that line 19-20 and line 21-22 should also be part of the bulletpoints, then it all makes sense!!

Thanks! Now it makes more sense.

Is there a particular resaon why the emission factor are expreesed in g/Sm3, or is it just because that is the units used in the existing guidebook? g/Nm3 og g/GJ could be used.

All updated to g/Nm3 for harmonization.

Despite all the mentions of venting, this table is about flaring not venting. Data stems from the existing guidebook, where the quality is C and not D as mentioned in the inserted comment.


Table heading updated. Quality rating updated, therefore uncertainty range updated as well.

If the factors only are applicable for Norway, the relevance of having them in the guidebook would seem miniscule.

RejectedNo need to repeat a completely identical table. Rejected

Accepted Sentence removed

Accepted Fixed

Accepted Fixed

Accepted FixedWhy no glossary for this chapter? Noted

Accepted

Noted

Accepted Done

replace "For the types of storage tanks used to store volatile liquids at refineries, emission estimation methodologies are provided by the US EPA (EPA, 2006). These methodologies require information on the tank contents, size, shell colour, floating roof fitting types and number, etc., on a tank-by-tank basis. Emission calculation software utilizing the algorithms in the US EPA publication is available on the EPA website http://www.epa.gov, or on a CD-ROM (EPA, 2005). " with "For storage tank emissions Concawe report suggests the use of the latest edition of API documents for Floating Roof Tanks (API,2003), and Vertical Fixed Roof Tanks (API, 2002). For Aboveground Horizontal Tanks, Concawe report suggests to use the latest edition of U.S. EPA methodology (U.S.EPA, 1995). Note that this reference normally contains the latest version of previously quoted API methodologies. An emission calculation software is available from the US EPA via their website, http://www.epa.gov, or on a CD-ROM(U.S.EPA, 2005). This CD also contains the EPA publication (U.S.EPA, 1995) and API documents (API 2002; 2003)."

The sentence about uncertainty makes no sense. No quality codes are provided in this chapter, so comparison with the uncertainties chapter is rather difficult.

PM10 should be removed from the table and placed under NA or NE.

In the "Not Applicable" list for Table 3-5, PM10 is given. However,this is also shown in the Table as "NE". Should it be listed,therefore, in the "Not Estimated" list?

In Table 3-5, the following pollutants should be deleted from the"Not Applicable" list as EF's are provided: PM10, Pb, Cd, Hg, As, Cr. Cu, Ni and Zn.

An emission factor of 0 is clearly not acceptable, either there is an emission factor or the pollutant should be listed as not applicable.

All EFs that are equal to zero removed, moved to NA or NE according to reporting template

The CO and NMVOC emission factors are a factor 10 lower from the reference chosen compared to the other references in the existing guidebook. At least a note explaining the comparatively low values should be offered.

Erase 30311 Cement (is included in B1 Energy) and erase (decarbonising) from 40612

Noted

Accepted Two new tables introduced

Noted

Noted

Accepted Statement corrected

Noted

Noted

Rejected

Rejected

Rejected

Chapter contains scarce information necessary for emission inventory from cement production. There are 5 short tables with only PM emission factors. Chapter should be supplemented and updated.

Proposals: two Tier 2 tables applicable for EECCA countries were suggested for the Guidebook: for wet and dry cement production with averaged levels of abatement.

"This chapter only considers emission of particulate matter from cement plants, which is mainly the PM from pre- and aftertreatment". If this is the case, where can we find the emission factors of the pre- and aftertreatment processes?

For many of the pollutants listed in the mentioned lines the BREF states that a significant contribution comes from the materials processed.

In this statement, the ammonia appears as an important pollutant to be considered in the cement production but, in the rest of the document, the ammonia does not appear and in the tables is treated like " not applicable ".

Subchapter 2.3 Emissions contains long list of pollutants emitted during cement productions and processes are described but Tier 1 and Tier 2 Tables 3-1-3-3 gives only particulate emission factors.

The text concerning emissions of SOX originating from fuels or raw material can be misunderstood.

Erase "For Tier 1 the emissions of NOx, CO, NMVOC, SOx, heavy metals and POPs can be assumed to be mainly due to the combustion of the solid and waste fuels and will be included in the emission factors used for chapter 1.A.2.f.i. To avoid double counting estimates should be made in the chapter 1.A.2.f.i. In the Tier 1 approach they will, as far as they originate from the chemical composition of the raw meal, be reported as “Not Estimated”."

Move B(a)P, B(b)F, B(k)F, CO, DIOX, HCB, Indeno, NMVOC, NOX, SOx, from Not estimated to Not applicable

Erase Tier 2 (is a copy of Tier 1) because it generates confusion

Rejected

Rejected

Noted

Rejected

Noted

"and the algorithm in equation (3) reduces to:" Editorial

Noted

Noted

NotedDelete "from" Editorial

Accepted

Noted

Accepted

Where is the equation (3) in the document? Accepted

Tables 3-1-3-3: these tables include only 3 emission factors each which are the same. Tier 2 tables for wet and dry processes include the same factors for different cement production processes and same with Tier 1 – this is not true and contradicts to Tier 2 approach determination. Reworking of EF tables is necessary.

Tables 3-1-3-3: there are no emission factors for heavy metals; it is shown that they are accounted in 1.A.2. But it is known that heavy metals are emitted with particles. So it assumed that cement particulate do not contains heavy metals? And it is assumed that only particulate is abated while heavy metals are emitted unabated?

Table 3.1: EF seem to be too high, if quarry is excluded as presented in Figure 2-1

No need to present the same default EF in three tables: 3-1, 3-2 and 3-3

"The Tier 1 emission factors have been used in the Tier 2 approach as well". This sentences amounts to say that there is no Tier 2 approach for the wet kiln process!

Equation numbering corrected

"The feeding of dry material into the kiln will however typically result in higher emissions of dust as compared to the wet kiln process".

" ..the Tier 2 emission factors for the dry kiln process in Table 3-3 are the same as the Tier 1 default emission factors presented in Table 3-1". This sentences amounts to say that there is no Tier 2 approach for the dry kiln process!

Descriptions of algorithms occupy 2 pages while only 3 factors available; what is the usefulness of these algorithms?

Table 4-1: How does this table correspond to tables 3-27 - 3-31 (1A2)? Present the correspondance between the different units

Simplest correspondance included plus a reference to the BREF if more detailed information is requested

References contain only 4 sources including 2 BREFs: it is too short.

The indication I.E. for the pollutants present also in Combustion activities is ambiguous; it's not clear if there are part of process emissions evaluated in combustion or if there are combustion emissions

Indication removed from all chapters; now in NE

Equation numbering corrected

Noted

Noted

Accepted NH3 in NE instead of NA

Noted

Noted

Accepted

Noted

Accepted Done

Rejected

Accepted

Accepted Added to chapter

We consider that this is a very serious drawback for process emission estimation in this sector (key source for many pollutants as heavy metals from the very kilned raw materials (whose emission factors do not appear at all))

for many of the pollutants listed in the mentioned lines the BREF states that a significant contribution comes from the materials processed.

It is considered that the ammonia in not an important pollutant to be considered in the cement production?

We consider that this is a very serious drawback for process emission estimation in this sector (key source for many pollutants as heavy metals from the very kilned raw materials (whose emission factors do not appear at all))

So the question arises: where are you allocating these emissions and what are the corresponding emission factors, if their emissions have not been computed in the combustion activity (1.A.2.f.i), and there is not information on them in this process actvity?

The proposed EF are very high compared with BREF use TSP from BREF and estimate fraction of PM10 and PM2,5

Replaced with BREF factors

It is assumed that heavy metals are mainly due to fuel combustion so they are accounted in 1.A.2.f.i. So it supposed that lime particulate do not contains heavy metals? And abatement affects particulate and not affects heavy metals?


Table 3.1: EF seem to be too high, if quarry is excluded as presented in Figure 2-1

Delete: EFs very old; substitute with controlled / no controlled TSP from BREF and estimate fraction of PM10 and PM2,5

Chapter contains mainly headings, algorithms and table without emission factors. It should be supplemented.

Some headings removed to make more readable

Nevertheless a decision tree is possible: For Germany we have the question clarified whether information from sectors limestone used are available. With "Yes" like in Germany all calculations are made in sectorspecific chapters, so 2.A.3 shows only "IE". With "No" an estimation under 2.A.3 is necessary. In Germany we have made for verification a limestone balance with the full set of production and use and so identified gaps, which were closed in different sectors.

Decision tree and some text on this issue added to chapter

It is not mentioned that heating emission is taken into consideration in 1.A.2.c.

Noted

Noted

Noted

Noted

Noted

Editorial Done

Editorial Done

Round the EFs value. Ammonia lower value = 0,6 Accepted Done

Accepted Corrected

Accepted CorrectedDelete: no clear, no necessary Rejected

Accepted Done

Accepted

Noted

Accepted Corrected to 3.C

Accepted

Accepted

Accepted

Accepted Done

Accepted Done

See comments to german limestone balance before.




11 subchapters of the chapter consist only of heading and comment: No specific issues. Maybe it will be better not to show this chapter at this stage at all?

Some of the multiple headings removed

Correct the mentioned BREF and write "… is available in the BREF "Large volume inorganic chemicals - solids and others (European Commission, 2007)

Correct the word "Boudart reaction" into "Boudouard reaction"

Table 3-1: emission factors are with 6 digits after point – it is too much.

table 3-1: the emission for NH3 given in the BREF is 0.6-1.5 (LVIC-SAO, chapter 2.3.3.5)

The BREF documents don't present emission limit values, but BAT-associated emission levels (BAT-AELs) - delete the sentence "This section provides emission limit values (ELVs) as defined in the BREF document"

Can't find the cieted value for NH3 in the BREF - cite correct or delete value.

Error - value should not have appeared here. Removed.

Interpretation is correct as Asphalt Roofing Materials

"...with the exception of asphalt blowing, which is inventoried separately under NFR source category 1.A.2.f.i".

Figure 2-1: The notation for Heat or Fuel and its emission are missing.

Table 1-3: Mostly the production data are included in quadrat m. I would recommend the inclusion of factor-information from this, as well.

Decision tree is proper for production only, emissions of application seem to be relevant are in Germany calculated too. The decision tree has to refer to the complete number of application of roofing materials.

The proposed EFs from old GB are obsolete: there are a new US EPA chapter in AP42


Accepted Done

Accepted

Accepted Corrected

Accepted Added to figure.

Editorial Corrected

Accepted Done

Noted

Editorial Corrected

Table 3-1 and 3-2 are exchanged Rejected

AR production -activity rate for the lime production Editorial Corrected

Editorial Corrected

Editorial Corrected


The reference is obsolete new one is U.S. Environmental Protection Agency (U.S. EPA), 1995. “11.2 Asphalt Roofing” Compilation of Air Pollutant Emission Factors: Stationary Point and Area Sources. AP-42, Fifth Edition. Office of Air Quality Planning and Standards, Research Triangle Park, North Carolina.

Old reference replaced by new one

This statement is not correct because asphalt blowing should be in NFR source category 3.C.

The chapter is wrong! The content can be appropriate for activity 030313 Asphalt Concrete Plants (that was expired from new GB), but EF and reference are old, a new AP42 chapter was produced. The chapter following my interpretation refers to asphalt application on road! and concern VOC emissions (see US EPA AP42 chapter 4.5).


Some information from 030313 used as well. There appears to be overlap between the two chapters in the previous Guidebook and also the EPA reference given in this comment.My best guess is that both the Mix Asphalt plants and the asphalt application on road should be taken into account. Chapter has therefore not been subsequently updated.

Figure 2-2: Heat and its emission are missing from the chart.

Here seems a mix-up to be: reference to cement and lime are not useful.

The emissions factor indicates a mass rate of about 20%, what is not usually, please see under EF_comments.

Chapter consists of mainly headings. It includes one table with 3 PM emission factors (for all mining processes) which seem underestimated. List of References includes one source.

AR - not lime production (page 3, row 11), but floor area of the building construsted (page 4, row 3 or p.3 row 21)

AR - the activity rate for the storage, handling and transport

In Glossary table - AR production -activity rate for the lime productionThe right definition as on the page 4, row 15

Noted

Noted

Noted

Accepted Done

Accepted Done

Accepted

Noted

Accepted

Noted

Noted

Noted

This chapter includes 6 sources, 5 connected with glass production: Flat Glass, Container Glass, Glass Wool, Other Glass, Glass (decarbonizing). Why they were not included in a separate chapter “Glass production” like Limestone and Dolomite taking into account contribution into heavy metals emission?

Please, make sure to use the most up-to-date sources for technical information and emission factors

According to a not yet published research project on emission factors of the german glass and mineral wool industry, 35% cullet is used in the flat glass production

Please, provide updated information on preheating or remove the word currently in line 7 since the source is 11 years old!

please, provide the source to table 2-2. Furthermore, VDI 2578 on the emission control in glass works provides more detailed information on the energy demand of carious glass types and furnaces

Please, provide updated information on soda lime glass manufacturing via electric heating or remove the word currently in line 39 since the source is 11 years old!

Text updated for as far as new information available; old information removed

About 8 pages of the chapter are devoted to reduction measures for NOx and SO2; this is not balanced with other chapters especially taking into consideration that gases are not accounted in 2.A.7.d chapter.

Please, update the information on fuel staging in Germany

Obvious outdated information removed, no updated information available

Please, update the information on Low-NOx in Germany


Please, update the information on Oxyfuel-using furnaces. In western Europe TV-glass is not produced anymore and could therefore be deleted from the listing expect for the case that the producing plants in eastern Europe are using Oxyfuel.


Please, update the information on SCR. There is no TV-glass production Germany anymore. Therefore, remove the listing in line 5


Editorial Corrected

VOC emissions see EPA AP42 Noted

Accepted All corrected

Noted

Noted

Noted

Rejected

Noted

Noted

AR production -activity rate for the lime production, not correctedwould be glass production (page 22, row 2 or 5)

In all tables PAH by substance included into row "not estimate"and to row "not applicable" as PAHIt would be more correct if Tier tables in all chapters have been madein identical format (sequence of rows):NFRSNAP (if applicable)FuelPollutantsTechnologies (for Tier 2-3)Region (for Tier 2-3)Abatement technologies (for Tier 2-3)NENA

The heavy metal EF refer to the Guidebook (2006) - some in general and some to Jockel (2001). However, for lead crystal glass the general EF is used instead of EF for special glass (e.g. lead crystal)?

HM EFs removed where not applicable

Tables 3-2 to 3-10 contain emission factors which seem to be too high (by approximately factor 10 and more) according to the preliminary final report of a research project on emission factors of the German glass und mineral fibre industry. The report is expected to be published in May 2008. Some examples are listed in the EF-comments spread sheet. They refer to the year 2005 and sum up energy- and production-related emissions.

Tables 3-2, 3-3 (Tier 2): PM and HM EF for Flat glass and Container glass are the same: this is not true because technologies are different.

Tables 3-2 to 3-10 contain emission factors for which the reference year is not mentioned. Please, add this information. Furthermore, to our knowledge it is very common to use the metal classes I to III. Therefore, they should be used in the handbook as well.

It is stated that “Heavy metal emission factors from the Tier 1 table for this source category are added to the table in order to fill the gap” – methodologically this is not good because as declared Tier 2 is more sophisticated approach which provide more accurate estimates; generally Tier 1 tables should originate from Tier 2.

Table 3-5: heavy metals emission factors are the same as in Tier 1 Table 3-1 while TSP EF is different.

Tables 3-11-3-12: errors (not lime production). Editorial Corrected

Noted

Accepted

Editorial Corrected

Editorial Corrected

Visschedijk (2004) is missing in the References Editorial Added

Noted

Noted

Noted

Noted

spelling mistake: correct "gassified" into "gasified" Editorial processed

Subchapter 3.3.2.5 includes 5 tables (3-6 – 3-10) with the same HM EF for different types of glass. This is not true: every type of glass has different content of HM thus emissions will be different; differentiation is especially important for lead crystal glass.

Tables 3-6 – 3-10: Guidebook 2006 as referenced in these tables does not contain such emission factors.

All checked. EFs removed where not applicable.

In the tables 3-11, 12 (glass production) the NFR code is 2.A.2 - lime production, would be 2.A.7.d

Glossary, AR production - the AR for the lime production??

The SNAP for the organic chemical industry is absolutely not adapted and not representative of all productions of chemicals substances. The list of products from SNAP 040501 to 040526 is not sufficient. The problem is also liked to the fact that products accounted under different SNAP code, are produced by the same process (ethylene and propylene are the best example)

The problem of carrying our emission inventories for the organic chemical industry is related to the decrease in the availability in statistics. Most of the production of products considered in the SNAP are not available in current national statistics.

the first SNAP 040501 and 040502 represent the same process, the steam cracker. See the description in the EGTEI document as example.


SNAP 0405025 and SNAP 040526 should not exist. There are redundant with SNAP 060306 if this one becomes speciality organic chemical industry

SNAP 040622 should also related to the speciality organic chemistry

Accepted processedfootnote 5 is not existing below Editorial not foundcorrect reference to the BREF is missing Accepted processed

Rejected

Editorial processed LVIC AAF

Editorial processed

Editorial processed

Editorial not found

Editorial processed

Accepted Processed

Rejected

Rejected procesed

Rejected

Rejected

Rejected

Figure 2-4: Please correct "Adsorption" into "Absorption"

Ammonia Tier1: I don't found correspondence with quoted BREF values

table 3-1, column "reference": what does LVC ACF mean: define reference (Probably you mean the BERF "Large Volume Inorganic Chemicals - Ammonia, Acids and Fertilisers" (LVIC - AAF) December 2006?)

the paragraph mentions only two primary sources of pollutants, but in the table 3-1 below you find three pollutants

spelling mistake: correct "Tier 2 ort Tier 3" into "Tier 2 or Tier 3"

put in a space between "tier 1" and " emission factors"

write "Tier" always in the same spelling: either with a capital (see line 1 to 5 on the same page) or in lower cases.

Nitric Acid Tier1: It's better to use BREF average value: 10.000

Adipic Acid Tier 1:Why no values when can be found in US EPA AP45?

table 3-4: the upper and lower value can not be found in the refered BREF. Table 7.10 of LVIC SAO shows the emission factors for different abatement technology you refer to as tier 2 (s. table 3-16)

table 3-5: delete table 3-5, because of to many very different production processes in 2 B 5

Table 3-5; delete this table; it is impossible to create a emission factor for the whole chemical industry

Ammonia Tier2: Use IPPC BREF value and introduce also Tables for controlled process from IPPC BREF

Accepted processed

Accepted processed

Rejected

Accepted Processed

Accepted processed

Accepted processed

Accepted processed

Rejected

Editorial processed

Accepted prcocessed

Noted

Accepted processed

Ammonium Nitrate EFs from US EPA AP45 Accepted processed

table 3-6: the conventional as well as advanced processes are not abatement technologies, but process technologies - expand the text in line 2, column 6 with the text from line 8, column 2 and delete the text in ine 8, column 2

table 3-6: the reference of the values given here is the guidebook 2006 - but there are no datas! The reference for NOx (CO?) seems to be LVIC AAF, table 2.7? Define the reference of the data

Ammonia Tier2: Introduce also Tables for controlled process from IPPC BREF

Nitric Acid: erase table 3-8, for unspecified process use Tier 1

table 3-10: please define why the value is below the range

table 3-13: only the value of 5000 refers to French and German plants, the range of 100-1000 refers to US plants - define how to use value and range (why is the range lower than the value?)

table 3-15: referring to the guidebook 2006 the data for the extended absorption does also apply for medium and high pressure processes - add in line 6/column 2 medium and high pressure processes

Adipic Acid Tier 2:Why no emission when values can be found in US EPA AP45?

table 3-18: line 6, column 2: change "withuUsage" into "with usage "

the SNAP classification 040303 belongs to the group of metallproduction and not to the chemical processes - 2B5a doesn't include either the silicium production nor synthetic amorphes silica and silicates - please check this issue.

In the last line you write, that TSP has not been estimated - but in line 11 you have a value for TSP - please check

table 3-21: line 9 says that decomposition plants are included - but table 3-22 is covering the decomposition plants. Change "Including" into e.g. "without Decomposition plants"

Accepted Processed

NPK fertiliser: NH3 old Corinair EF Rejected Processed

NotedUrea: PM, PM10, PM2,5 from US EPA AP45 Accepted processed

Noted

Accepted processed

Accepted processed

Chlorine production: Use BREF values Accepted processedTable 3-36: emission factor for Cd is missed. Noted

Ammonium Sulphate: NH3 value from old Corinair references, COV from Economopoulos, 93, PM from EPA

There are not emission factors for NPK fertilisers production.

In this lines the dimension unites for TSP and NH3 are in the range of kg/t, but while using the same numerical value you have in table 3-28 the dimension unit g/t. Please check the dimensions/values.

table 3-29: The BREF LVIC-SAO is cited incorrect (s. also Excel sheet "EF_Comments". I also couldn't find in the BREF emission values for PM10 and PM2,5. Please cite accurately.

Chlorine production. Table 3-33 Tier 2: Hg emission is shown as NE – it need to be estimated taking into account contribution of Chlorine production by this method into mercury emissions.

Accepted

Noted

Accepted processed

Accepted acceptedPolyethylene: use BREF values Noted

Rejected

Naphtha is not the unique feedstock in Europe for steam cracking.

Added note on other feedstocks

The list of products provided is not complete. Please provide all possible products to avoid double counting by not specialists.

In France in 2005 the emission is different as the volumes produced are different. The emission factors provided for ethylene and propylene are the correct one to represent the emissions of the steam crackers if we are able to allocate the emissions of the steam cracker in all the different types of products manufactured by this process. In the Netherlands ethylene and propylene represent only 49 % of the total products coming from the steam crackers. What are the other products? Add an explanation to consider them in SNAP 040527 if the product is not considered in an other item of the SNAP. If you do not recommend to proceed as above, the emissions of the steam crackers are not correctly estimated

Table 3-37; BREF LVOC: range from 0,03 to 6 kg/t ethen and not 0,4 to 10 in table 3-37.

Table 3-41; BREF Polymers: range (LDPE) 0,7 to 1,1 kg/t for new plants and 1,1 to 2,1 kg/t for existing plants and not 2 to 3 kg/t

Accepted

Rejected

Rejected

Rejected

NotedPolystyrene, Wrong reference: data from BREF Noted

Noted

Rejected

Accepted processed

Rejected

Accepted processed

Noted

Noted

Accepted processed

Accepted Processed

The EGTEI document on chemical industry presents emissions from the suspension PVC process developed with the industry organisation. The emission factors could be used.

processed, accepted for NMVOC, TSP EF's unmodified

Table 3-42; BREF Polymers: range (HDPE) 0,3 to 0,5 kg/t for new plants and 0,5 to 1,8 kg/t for existing plants and not 1 to 3 kg/t.

Table 3-43; BREF Polymers: range 18 to 45 g/t S-PVC and not 18 to 100

Table 3-44; BREF Polymers: range 100 to 500 g/ t E-PVC and not 18 to 1000

Table 3-45; in BREF Polymers the emission factor for PP is in the range of HDPE (see above)

Polystyrene, Wrong VOC EF: correct BREF value 3200

Table 3-48; BAT for HIPS is about 85 g/t (BREF Polymers)

Table 3-49: BREF Polymers: range (EPS) 0,45 to 0,7 kg/t

Table 3-47; BAT for GPPS is about 85 g/t (BREF Polymers)

Table 3-50: BREF Polymers: range (E-SBR) 0,17 to 0,37 kg /t

Styrene Butadiene Rubber very lower VOC from BREF (170-540)

Ethylene oxide: wrong reference and incomplete data

BREF LVOC: in the case of tratment by oxidation the emissions are considered to be zero

Formaldehyde: the reference was wrong BREF but not polymers

Accepted processed

Table 3-56: The reference is wrong (BREF LVOC) Accepted processed

Table 3-57: the reference is wrong (BREF LVOC) Accepted processedEthylbenzene: EF from BREF ? Accepted Processed

Table 3-61; Please add LVOC as reference Rejected

Noted

NotedNot clear Noted

Accepted processed

Accepted processed

Accepted processed

Accepted processed

Accepted processed

Accepted processed

Table 3-55:BREF LVOC reportet emissions of about 0,11 or 3 to 5 kg/t. The reference BREF Polymers is wrong.

made a reference to the BREF instead

Table 3-63: EF for POPs pesticides production is shown zero. It is written that “emissions of all the different pesticides are assumed to be neglible compared to product”. But Chapter “2. E Production of POPs” contain EFs for all POPs pesticides (10 kg/Mg product).


As said before the SNAP 040527 has to be completed to give examples. In France as example, all chemical production which can not be classified in the previous SNAP are put under this SNAP "other" and their emissions represent a large amount of total emissions of the organic chemical industry (30 % at least)

Is this chapter useful? Nothing is given to try to estimate the amount of organic chemical products stored per t of production. There are no statistics on the quantity of organic chemicals stored. A way to estimate them should be useful.

table 4-1: the BAT-associated emission value referred to the BREF LVIC-AAF is not for NH3 but for NOx - write "NOx" instead of NH3; please define also the reference (LVIC-AAF)

table 4-2: the BAT-associated emission value referred to the BREF LVIC-AAF is not for NH3 but for NOx - write "NOx" instead of NH3

title of the table: the EF given apply not only for conventional reforming processes, but also for reduced primary reforming - add reduced primary reforming processes (LVIC-AAF, table 2.13)

table 4-4: instead of "SO2" write "SOx as SO2" (s. reference and text above)

tab. 4-6 (Heading): table 4-6 refers to the sulfate process and not the chloride process - correct heading into "sulfate process"

The given BAT value for SO2 is not only for drying but for the total emission level to air (s. LVIC-SAO, Chapter 3.5.1, No. 14). Therefore add the data to table 4-5

Accepted processed

Noted

Rejected

Rejected

BAT emission factor for E-SBR: 0,17 to 0,37 kg/t Accepted processed

Accepted processed

Noted

Noted

Accepted Done

Accepted Done

Figure 2-3: Explanation for the blue arrow missing Accepted

Figure 2-4: Explanation missing for the blue arrow Accepted

Accepted Corrected

Accepted Corrected

Editorial CorrectedTypo in the middle of the line. Correctly: agents. Editorial Corrected

The given BAT value for SO2 is not only for drying but for the total emission level to air (s. LVIC-SAO, Chapter 3.5.2, No. 18). Therefore add the data to table 4-6

BAT emission factor for S-PVC: 18 to 45 g/t and E-PVC: 100 to 500 g/t

BAT emission factor for LDPE: 0,7 to 1,1 kg/t for new plants and 1,1 to 2,1 kg/t for existing plants ; BAT emission factor for HDPE: 0,3 to 0,5 kg/t for new plants and 0,5 to 1,8 kg/t for existing plants

BAT emission factor for GPPS: 85 g/t; HIPS: 85 g/t and EPS: 0,45 to 0,7 kg/t

References: Please add: IPPC BREF Polymers - IPPC Reference Document on Best Available Techniques - Polymers, October 2006

Except in some country where the industry is not present, the chemical industry is often a large emitter of pollutants

all tables: use units consistently (Mg, t, ton: e.g. in table 3-1 you use kg/t, in table 3-2 you use g/Mg, in table 3-5 you use kg/ton


Chapter describes all processes in ferrous metals industry thus very complicated and difficult for usage.

Figure 2-1: Notatin for blast furnace gas missing. Instead of coal injection I recommend coke or natural gas injection.

Figure 2-2: The "metallurgical coke"in the top left arrow is incorrect. Correctly: "Coking coal."

More info provided in caption

More info provided in caption

"...auxiliary reducing agent" should be amended with "and as a fuel…"

"It leaves…" should be replaced with: "It and other fuels leaves…"

Letter missing at the beginning of the line. Correctly: Top of the …

Accepted Checked and corrected

Editorial Corrected

Accepted Corrected

Accepted Corrected

Editorial CorrectedNo legend provided for formuila. See row 1. Accepted Legend added

Rejected Corrected

Noted

tab 3-1 NFR Source cat. Should be 2.C.1 not 2.A.1 Editorial Corrected

Subdivide Sinter from pellets as in IPPC BREF Accepted

Rejected

Accepted

Accepted EFs added

Accepted


Rejected


Rejected

Contradictions: Here 1.9% is mentioned, but on page 7/18 it says: "… be reduced less than 1%"

In section 2.2.4. the order: BOF, OHF, EAF, while in the others it is: OHF, BHF, EAF. The letter is preferred.

The agent for reheating is not mentioned in the description, e.g. coke oven gas.

The heavy metal content of furnace gas is not mentioned. Table 3-14 (3/13) does include it.

"… sulfurdioxide…" should be written as sulfur dioxid.

As there are iron & steel installations that have only some plant (for example no coke production or no sinter and so on) it's not possible to have a set of overall emission factors; please use also for Tier 1 the subdivision used for Tier 2.

Table 3-1: emission factor for chromium is overestimated.

Pellets added as separate Tier 2 using EFs from BREF

Convert the data in g/kg sinter using appropriate change factor to compare with "state of the art" EFs

Subchapter 3.3.2.1: for sinter production it appears that effect of different systems of control onto heavy metals is different depending on metal and for some of them more advanced system leads to increase of emissions.

Espreme factors checked. Some inconsistencies remain however.

Why are the EFs of TSP, PM10 and PM2.5 not estimated in the tables 3.3, 3.4, 3.5 and 3.6 ?

In table 3.2 the EF of Pb is 0,5 g/Mg sinter product, while the EFs in the tables 3.3,3.4 and 3.5 are higher. Is that correct ?






Accepted Corrections in units made

Rejected

Rejected



Accepted Tables removed

Accepted

Noted

Accepted CorrectedUnit PM10 and PM2.5 not correct Accepted Corrected

Accepted

Noted

Tables 3-3-3-6: because Table 3-2 is also named Tier 2 these tables might be considered as Tier 3. But they includes only heavy metals and POPs – no PM; error in units (should be ‘sinter’ instead of ‘pig iron’; should be ‘μg TEQ/Mg’ instead of ‘μg /Mg‘); SNAP code is shown as 030301 while in Table 3-1 as 040209, except 030301. Tables are not harmonized with Tables 3-1 and 3-2: thus in the Table 3-3 (Controlled by wFGD) – emission factors for Cr, Ni, Pb and PCDD/F more high than in the Table 3-2 while for PCB – lower 2000 times; dioxins are the same in all tables.





Erase Table 3-8 and Table 3-9: are in contrast with Table 3-7

PM emission factors are very high if compared with BREF data (a factor 10)! BREF EF must be taken into account.

Factors replaced with BREF values.

Heavy metals emission factors in the Table 3-7 are generally underestimated especially for Cd, Pb, Zn, but for Cr they are overestimated (taking into account properties of metals).

Table 3-7: there are errors in unit for PM10 and PM2.5.

Table 3-7 provides EF for pig iron production, for the whole process starting from the charging of the blast furnace to the tapping of pig iron. Table 3-8 and Table 3-9 provide EF for the charging and tapping individually. But emission factors in these tables are not harmonized.

Tables 3-8 and 3-9 removed because they generate confusion and are not complete and rather old anyway

Error in units in Tables 3-10-3-13 for PCDD/F – should be μg TEQ/Mg; tables do not contain PM emission factors; emission factors were taken from ESPREME without analysis of applicability; they look very low and probably contain systematic error in units.

PM EFs added. ESPREME data checked for errors.

Accepted Table corrected

Accepted Tables included

Accepted

Noted

Noted

Rejected

Accepted Unit corrected.

Accepted


Tables 3-1– 3-21: error in units – should be ‘steel’. Accepted Corrected

Accepted


Table 3-14: table should be revised: it is shown that the table is for Uncontrolled conditions but PM emission factors are too low and lower than HM emission factors; HM emission factors are partially from Guidebook 2006, and partially – from CEPMEIP so overall table is heterogeneous and not reliable; error in units – should be ‘steel’.

Proposals:Tier 2 emission factors table is suggested applicable for EECCA countries for typical levels of dust abatement (95-96%).

Basic Oxygen Furnace: NOx and CO occurs from oxidation process (see BREF for description of process and EFs): THESE EMISSION MUST BE INCLUDED AS THEY ARE NOT "COMBUSTION" EMISSIONS (NO FUEL ONLY OXYGEN)

NOx and CO EFs added to table

Table 3-15: HM emission factors look underestimated.

It is shown that “Most emission factors are taken from the BREF document for Best Available Technologies in the Iron and Steel Industry (European Commission, 2001) but this reduce applicability of emission factors.

Electric Furnace Steel Plant: NOx and CO occurs only in small portion due to adding of coal in scrab as input to electric furnace (see BREF for description of process and EFs): I THINK ALSO THESE EMISSION MUST BE INCLUDED, THEY ARE ONLY IN LIMITED QUANTITY "COMBUSTION" EMISSIONS

Table 3-16: error in units for benzo(a)pyrene. TSP emission factor is underestimated.

Table 3-18: emission factor for lead is higher than in the Table 3-15 (typical conditions).


Proposals: tier 2 emission factors table are suggested applicable for EECCA countries for typical levels of dust abatement (97.5%).

Tables 3-19-3-21: error in unit – should be ‘steel’; units for PCDD/F should be checked. Heavy metals emission factors among tables were not harmonized: thus EF for Electric Arc Furnaces with bag filter (Table 3-20) are higher than with ESP (Table 3-19).

PCDD/F emission factor corrected. Espreme factors checked, but some inconsistencies remain.

Proposals: tier 2 emission factors table is suggested applicable for EECCA countries for typical levels of dust abatement (bag filter, about 99%)

Accepted

Accepted Inserted as separate Tier 2

Noted

Accepted

Noted

Ferroalloys production: use PM EFs from BREF Accepted

Accepted

In the list of main pollutants PAH are not included. Accepted

Noted

Accepted

Accepted Added to tables

Noted

Noted

I propose to erase all this old materials: it's not TIER3

All this old information removed

3.4.2.5 Rolling mills. This activity must be in Tier 2 with BREF EFs

It’s not clear why some pollutants are in "1.B.2. Industrial Processes" section and not in "1.B.1. Energy" section while are combustion related. For example in sinter plant the EF for sinter plant in Table 3.2 is fuel related as explained in quoted reference ("The combustion process is not homogenous and is incomplete, resulting in significant quantities of polycyclic aromatic hydrocarbons (PAHs) being produced.").

In the Tables erase the row relative to NOx, CO, NMVOC and SOx and put these pollutants in the box "Not applicable" in conformity with other chapters

Harmonized with Reporting Template

Chapter consists mainly of headings. It includes one table with one emission factor: this is not enough for inventory of emissions from this sector.

The notation keys given in Table 3-1 for Total PAH (NE) do not correspond to the notation keys given for the PAHs included in PAH-4 (NA).



Table 3-1: no EF for dioxins/furans; no EF for PAH except benso(a)pyrene.



SOx, NOx and VOC comes from process and are not evaluated elsewhere. Insert EF here from IPPC BREF. See BREF for details of the process emissions description.

Tables 3-1, 3-2, 3-3: benzo(a)pyrene EF are the same for Tier 1 and Tier 2 for both technologies of primary aluminium production: this is not so.

Tables 3-1, 3-2 and 3-3 include CO emission factor while other gases are estimated in the chapter 1.A.2

Accepted

Accepted Added

Accepted

Noted Corrected

Accepted

Accepted Added

Noted

Accepted Corrected

Accepted Corrected


Accepted

Accepted

Noted

The EF given for benzo(a)pyrene is not valid for the PreBake-process.

EF removed, other EFs (Netherlands contribution for POPs) used instead

In the BREF-document SO2 and NOx emissionfactors (from sulfur and nitrogen in the anodes) are given. These emission factors might be useful for estimating emissions using higher Tier than Tier 1.



Tables 3-2, 3-3 and 3-4: PM emission factors shown the same for primary (both technologies) and secondary aluminium production. This is not so.



In the BREF-document SO2 and NOx emissionfactors (from sulfur and nitrogen in the anodes) are given. These emission factors might be useful for estimating emissions using higher Tier than Tier 1.

Table 3-4: no EF for dioxins/furans (important for secondary aluminium); no EF for PAH.

tab 3-4 NFR Source cat. Should be 2.C.3 not 2.C.1 also in tab 3-3

The legend for Table 4-3 refers to emission factors for primary aluminium production. In row four in the table it says "Secondary aluminium....."

Proposals: tier 2 emission factor tables are suggested for primary (limited control and advanced control) and secondary copper production in EECCA based upon average values of unabated dust emissions, emission control levels and content of metals in dust.

It is shown that emissions from secondary copper production are considered in the Chapter 1.A.2.b. But Table 3-3 proposes EF for secondary copper production, Tier 1 (Table 3-1) emission factors are for all copper.

Sentence removed, not applicable here!

"The emissions from the production of secondary copper are due to energy use only and therefore treated in the combustion chapter 1.A.2.b".


In the sector 2.3 Emissions SO2 emission are mainly considered in spite of the fact that gaseous emissions are not estimated in this chapter; scarce information about PM emission.

Noted

Accepted

Accepted Corrected

Rejected

Noted

Accepted Corrected

Accepted Corrected

Accepted

Accepted Corrected

Accepted Corrected

Accepted CorrectedSame comment for tables 3-2 and 3-3. Noted

Accepted Harmonized

Noted

Accepted Corrected

Subchapter 3.2.2: methods of estimation of Tier 1 emission factors are not described and in general common table for primary and secondary copper looks artificial.

Table 3-1: error in unit (aluminium is shown); emission factors for heavy metals seem underestimated especially for Pb; no emission factor for Zn; no emission factor for copper while copper production is the main source of copper emission; emission factor for PCDD/F looks overestimated.

Unit corrected. Cu EF added.

The emission factors are expressed in terms of mass of pollutant per mass of aluminium produced. Please take into account that the activity considered is copper production.

SOx, NOx and VOC comes from process and are not evaluated elsewhere. Insert EF here from IPPC BREF. See BREF for details of the process emissions description.

Chapter not contains technologically specific emission factors as necessary: only tables for primary and secondary copper with the same errors (see comment to the table 3-1).

Table 3-2: error in title: not Tier 1, but it is Tier 2; Error in unit (aluminium is shown); no EF for Zn and Cu.

The title of the table 3-2 refers to Tier 1 when it should be Tier 2.

Table 3-3: error in unit (not ‘aluminium’); no EF for Zn and Cu.

Unit corrected. EF for Cu added, for Zn no information available.

Warning: the emission factor value considered for Pb matches with one of the 95% confidence interval value, is this correct?

The 95% confidence interval for Cr in Table 3-1 is 0-0, but the emission factor proposed is 16 g/Mg aluminium.

The title of the table 3.3 refers to Tier 1 when it should be Tier 2.

In Table 3-1, emission factors for As, Cd, Cr, Hg, Ni and Pb do not coincide with the values that appears in the indicated reference (ESPREME).

The PST, PM10 and PM2.5 emissions factors that appears in Table 3-2 for Tier 2 are the same that appears in Table 3-1 for Tier 1.

The 95% confidence interval for Cr in Table 3-2 is 0-0, but the emission factor proposed is 21 g/Mg aluminium.

Accepted Harmonized

Accepted Harmonized

Accepted Corrected

Noted

Accepted Corrected

Noted

Accepted Cu EF added

Accepted Corrected

Noted

Accepted Corrected

Noted

Rejected

Noted

Rejected

In Table 3-3, emission factors for As, Cd, Ni and Pb do not match with the values that appears in the indicated reference (ESPREME).

In Table 3-2, emission factors for As, Cd, Cr, Ni and Pb do not match with the values that appears in the indicated reference (ESPREME).

Dioxins and furans are indicated as not estimated but there is an emission factor proposed in Table 3-1.

In Table 3-1, for SOx, NOx, NMVOC and CO, emissions are indicated as estimated elsewhere. Where are these emissions estimated? In the case of SOx, are not process emissions (other than those related to the fuel consumption) that should be computed in this Chapter 2C5a?

This statement does not match with the presence of the table 3-3, which presents emissions factors for secondary copper production.

Same comment for subsequent tables in this Chapter.

In addition, as a big surprise, there is no Cu emission factor for the very copper production, although there are emission factors for other heavy metals.

PCB is indicated as not applicable but there is an emission factor proposed in the Table 3-1.

General comment: chapter should be substantially reworked. Necessity and methods of aggregation of primary and secondary lead production should be discussed.

Chapter should be edited: 'Lime production' (P.5), 'Cement production' (P.5), "Cement industry" (P.4), 'Production of cement' (P.6), 'Zinc production' (P.2), 'Copper plants" (P.18) et. al. are not considered here.

Table 3-1: HM emission factors are underestimated; no EF for zinc; principals of Tier 1 EF calculation should be discussed.

SOx and NOx comes from process and are not evaluated elsewhere. Insert EF here from IPPC BREF. See BREF for details of the process emissions description.

Table 3-2: there are no differences with Tier 1 table for PM, but large differences for HM.

Tier 2 Tables 3-2 – 3-10: emission factors in the tables were not harmonized, i.e relations between dust and HM were not accounted (HM emission factors can’t be higher than PM; abatement affects PM similar way as most HM. Applicability of proposed emission factors is limited because no geographical indications are given for technologies distribution.

Text in section added to make it more clear that PM factors are generic, not specific for the technology


Accepted

Noted

Table 3-6: the same comment as for Table 3-5. Noted

Noted

Noted

Noted

Noted

Noted

Accepted

Proposals: two Tier 2 emission factors for primary lead tables were prepared applicable for EECCA: first – for low level of abatement (about 98%) and second – for high level (>99%).One emission factors table was prepared for secondary lead production (abatement <99%).

Table 3-3: not understandable: if it is a BAT table why EF for HM are higher than in the Table 3-2 (Typical abatement); lead emission factor is higher than for TSP.

All ESPREME factors checked again for errors

Table 3-5: EF for TSP is the same as in the Table 3-3 (BAT), but for HM emission factors are significantly lower than in Table 3-3. Lead emission factor is underestimated.



Table 3-7 (secondary lead): PM EF is the same as in the Table 3-2 (primary lead) and in the Table 3-1 (Tier 1). PM emission factors are underestimated. PCB and PCDD/F emission factors – errors in units.


Table 3-8: HM emission factors are higher for BAT than for typical abatement (Table 3-7).


Tables 3-8 - 3-10: PM emission factors are the same for different technologies but HM emission factors are different. Dependence of HM emission factors from abatement is not understandable.


Table 3-9: HM emission factors are higher for ESP than for typical abatement (Table 3-7).


Proposals: chapter should be significantly supplemented and reworked. Tier 2 region-specific and technology-specific tables are necessary.

It is shown that only primary zinc emissions are considered but emission factors also for secondary are included in the tables 3-5-3-8.

Accepted Sentence removed

Rejected

Noted

Accepted

Noted

Accepted EECCA tables included.

Accepted

Accepted

Accepted

Noted

Noted Unit errors corrected

It is written, that ‘Emissions from nickel production are not significant, since the contribution to the total national emissions is thought to be insignificant, i.e. less than 1 % of the national emissions of any pollutant’. It is not right: in Russian Federation according to rough estimates about 1 mln. tons of SO2 are emitted annually from nickel production – about 20% of national total.

SOx, CO, VOC and NOx comes from process and are not evaluated elsewhere. Insert SOx and CO EF here from IPPC BREF. See BREF for details of the process emissions description.

SOx included in this chapter

Table 3-1 (Tier 1) should be updated: it includes only 2 emission factors: for TSP and Ni. These factors if considered EMEP-wide are underestimated. During nickel production other heavy metals are emitted.

It is written, that 'Emissions of SOx, NOx, NMVOC and CO are due to the combustion activities and subsequently treated in source category 1.A.2.b' . This is not so: in nickel production from sulphidic ore SO2 emission is not due to combustion activities so should be treated in 2.C.5.c chapter.

SOx included in this chapter

References include only one source (IPPC BREF) - it is not enough.

Proposals: chapter need to be substantionally reworked. Two Tier 2 emission factors Tables for primary zinc production by electrochemical technology were prepared applicable for EECCA: first – for low level of abatement (about 90%) and second – for high level (>99%). Electrochemical technology is dominant in the EECCA countries zinc industry (more than 90% of total primary zinc).

It is shown, that the most important pollutants emitted from these processes are heavy metals (particularly zinc) – but there are no emission factors for zinc in the Tables 3-1 – 3-8.

Zn EFs added to each table

"This chapter only discusses primary zinc production. Secondary zinc production causes only emissions from combustion activities and is therefore treated in chapter 1.A.2.b".


"The most important pollutants emitted from these processes are heavy metals (particularly zinc)".


Subchapter 2.4 Controls: no description of abatement systems.

Table 3-1 (Tier 1): heavy metals emission factors are significantly underestimated; no EF for Cu; no EF for Zn which is the main pollutant from zinc production; EF for PCB and PCDD/F are dubious. Error in unit for PCDD/F.

Accepted Corrected

Accepted

Noted

Noted

Accepted

Accepted

Accepted

Noted

Accepted

Accepted

Accepted

Accepted

Accepted

PCB is indicated as not applicable but there is an emission factor proposed in the Table 3-1.

It is written that “This section provides technology specific emission factors for the two techniques … the electrochemical process and the thermal smelting process” but below there are no descriptions of these technologies and no emission factors.

Sentence removed, no specific EFs for these processes available!

In Table 3-2, why are used the emission factors for Tier 1 from ESPREME like emission factors for Tier 2?


Tables 3-2, 3-5: PM emission factors for primary (Table 3-2) and secondary (Table 3-5) zinc are the same while technologies are different.

Tables 3-2-3-8 Tier 2: tables were not harmonized with Tier 1 table and with each other; PM emission levels do not correspond HM emissions and sometimes lower than HM emission factors; no zinc emission factors.


Table 3-3 (BAT technologies table): emission factors for Cd and Pb are higher than for typical abatement; emission factor for Cr appeared not included in Table 3-2.


In Table 3-3, 95% confidence interval values for Cd, Cr, Hg and Pb do not match with the values that appears in the indicated reference (ESPREME).


Table 3-4: PM emission factors are the same as in the Table 3-3 but HM emission factors are lower 4 orders of magnitude.

In Table 3-4, 95% confidence interval values for Cd, Cr, Hg and Pb do not match with the values that appears in the indicated reference (ESPREME).


Table 3-5: PM emission factors are the same as for primary zinc which is not true; HM emission factors are underestimated; no Zn emission factor.


In Table 3-5, 95% confidence interval values for As, Cd, Hg and Pb do not match with the values that appears in the indicated reference (ESPREME).


Table 3-6: BAT technology, but HM emission factors compared with typical abatement (Table 3-5) are 2-3 order of magnitude higher, PM – the same, PCB and PCDD/F – lower.


In Table 3-6, emission factors for As, Cd, Hg and Pb do not match with the values that appears in the indicated reference (ESPREME).


Accepted

Accepted

Accepted Corrected

Accepted Corrected

Accepted

Accepted

Accepted Corrected

Accepted

Noted

Noted

Noted Error corrected

Accepted Corrected

References include only one source. Noted

In Table 3-7, 95% confidence interval values for As, Cd, Cr, Hg and Pb do not match with the values that appears in the indicated reference (ESPREME).


In Table 3-8, 95% confidence interval values for As, Cd, Cr, Hg and Pb do not match with the values that appears in the indicated reference (ESPREME).


Table 3-9: abatement efficiencies for modern plant is shown lower than for conventional installations. Error: not ‘Lead production’ but ‘Zinc production’.

The information that is showed in Table 3-9 is for lead production, not for zinc production.

It is written that Tier 2 tables were compiled using country data from Table 3-10. But data in Tier 2 tables do not correspond to the data in the Table 3-10. It is not clear enough how Tier 2 tables were obtained and for what countries data was used. Region-specific emission factors are necessary.

New EFs inserted from ESPREME, they are now used in all Tier 2.

In Table 3-1, for SOx, NOx, NMVOC and CO, emissions are indicated as estimated elsewhere. Where are these emissions estimated? Same comment for subsequent tables in this Chapter.

Dioxins and furans are indicated as not estimated but there is an emission factor proposed in Table 3-1.

In Table 3-1, emission factors for As, Hg and Pb do not match with the values that appears in the indicated reference (ESPREME).


This statement does not match with the presence of the Tables 3-5, 3-6, 3-7 and 3-8, which presents emissions factors for secondary zinc production.

This statement does not match with the rest of the capitule because there is no Zn emission factor.

Chapter consists of 8 pages and one table Tier 1 emission factors for source category 2.C.5.c Nickel production (probably error) with one emission factor (for TSP). This is not enough for emission estimation from Other metals production. Chapter should be supplemented.

Table 3-1: the title and content of the table are not harmonized.

transport of "cement" is not correct Accepted Corrected

Accepted Done

Accepted Done

NotedTHE should be written as the. Accepted Correctedusing annual national total cement production? Editorial CorrectedAR - national total cement production??? Editorial Corrected

Accepted Corrected

Accepted Corrected

Accepted Corrected

Accepted Done

Accepted Corrected

Noted

Noted

Accepted

Accepted Corrected

Accepted Corrected

Accepted Correctedreplace kg/Mg meat etc with kg/Mg product Accepted Done

Noted

Noted

Instead of "…hardwood…" I recommend wood or cellulose-bearing materials

Instead of "…wood…" I would recommend "wood or other cellulose-bearing materials…"

It is not described where ensillary fuel used in recovery furnace (e.g. oil) should be taken into consideration. See also page 7, lines 5-6.

Kraft process: the values for NMVOC and SOX are wrongly copied from BREF

Table 3-2, for TSP, PM10, PM2,5 unit is kg/Mg coal produced?

Acid sulphite process : the values for PM are wrongly copied from BREF

Table 3-1: I would recommend "air dried pulp" instead of "dried pulp".

Neutral sulphite semi-chemical process: wrong reference (see the text)

Several polutants are given in the EF-tables to be NA. From Swedish experiences there are emissions of metals, NH3 and also some PAH-4 and dioxins from the process (Kraft and acid sulphite) why the notation should be NE.

Reporting template now used to automatically fill NA and NE boxes.

Tables 3-7, 3-8, 3-9: kg/MG alcohol: what concentration of alcohol?

It is unclear when Table 7-9 and when Table 28-32 should be used.

Some descriptive text added in beginning of Tier 2 section

Cakes, biscuits and breakfast cereals: wrong copy EF from old GB: verify

In table 3-19 instead of SNAP 040605 must be SNAP 040627 (meat..)

In table 3-20 instead of SNAP 040605 must be SNAP 040625 (sugar)

Tables 3-28 to 3-22: kg/hl alcohol: what concentration of alcohol?

Chapter should be significantly supplemented taking into consideration importance of POPs production for total POPs emission. Now it consists of 3 pages and one table with similar emission factors for all POPs which are not grounded. Chapter should also include production of POPs-containing products like PCB transformers, capacitors, dyers etc. which is important for retrospective emission assessment.

NotedThere are no any references. Noted

NotedWho is the expert for expert judgement Noted

Noted

Noted

Accepted

It's not clear where leather finishing is included

Accepted

Noted

Accepted

Accepted Updated

AcceptedEU directive 2004/42/EC ((Decopaint directive") Accepted Directive addedthird column 10th row: 150 Acceptedthird column second row: 75 Accepted

What confidence can we give to this chapter? Very poor at first view. This chapter has to be worked more deeply. What is the definition of products used in the table 3.1.

Due to increase pressure on Member states for providing emission inventories for POP, the quality of this chapter is too low.

Chapter is based upon chapter “Electrical equipment with PCB” from the Guidebook 2006 which was reduced. Chapter need to be significantly supplemented and reworked (maybe with division into a few chapters) to show overall picture of consumption of POPs and heavy metals.

Table 3-1: table should be revised - it is not reliable, for instance it shows emission factors 1 kg/ton from consumption of heavy metals like Cr or Ni which is not understandable.

This section is not very clear. What do you to say ? '"Pharmaceutical products manufacturing (SNAP 060306)" does not correspond to "application of coatings during the manufacture of a number of other industrial products"

Pharmaceutical products manufacturing removed from this list


substitute "for architectural or furniture applications"

In the discussion of emissions there is no indication what happens with VOC's emitted from cleaning equipemtn, brushes, guns, rollers, etc. Dilution is also mentioned marginally but it might be quite important. It certainly should be clear if this is included or not. In case of emission factors later shown from the model the model developers should be asked if the factors include these components or refer only to solvent in paint.

I would suggest to apply an uniform emission factor of 95 % for open applications instead of 100%

These products are covered by the Product Directive 2004/42/EC on the limitation of emissions of volatile organic compounds due to the use of organic solvents in certain paints and varnishes… When EGTEI document was done, the directive was not yet implemented.

The results of this are the Solvent Emissions Directive (1999/13/EC) and the Product Directive (2004/42/EC). This latter regulation will be….

Updated. Decopaint directive added to text.

third column third row: 400 Acceptedthird column fifth row: 400 Acceptedthird column sixth row: 75 Acceptedthird column seventh row: 450 Acceptedthird column 8th row: 150 Acceptedthird column 9th row: 400 Acceptedfourth column 10th row: 130 Acceptedfourth column 9th row: 300 Accepted

Accepted Values corrected

Accepted Values corrected

Accepted Directive mentioned

Accepted Text added


Accepted Text updated accordingly




Some of the values table 2-2 are not correct. The right ones are in Annex II B of the Decopaint directive (2004/42/EC)

VOC content limit values in table 2.2 have to be modified according to the Product Directive mentioned above

Mention the EU Solvents Emissions Directive 1999/13/EC for this sector

Solvent Directive 1999/13/EC mentions that: "coating activities which cannot be applied under contained conditions (as shipbuilding, aircraft painting) may be exempted from emission limit values : the reduction scheme is then to be used, unless it is demonstrated that this option is not technically and economically feasible. In this case, the operator must demonstrate to the satisfaction of the competent authority that the BAT is being used.


Car repairing is regulated under the Product Directive 2004/42/EC and was removed from the Solvent emissions Directive 1999/13/EC

Please quote the regulations of the Decopaint directive for Car repairing (2004/42/EC, Annex II B).

VOC contents in paints used for car repairing are regulated by the Product Directive 2004/42/EC : only 1 phase which came into force in 2007 (see table of VOC content in the Directive)


Accepted

Noted

Noted

Accepted

Accepted CorrectedDecorative paints (060103 + 060104) Rejected

Noted


Noted

In the equation the activity rate refers to the application of paint while later in line 13 on page 15 it says that national production data are used. I think this is wrong, in time of multinational consortia producing vertain paints in few locations and distributing them to many countries we cannot rely on production figures, not too mention stocks changins from year to year and exports outside Europe or imports. I think one needs to refer her to the paint use and industrial associations need to be consulted for this data. They do exist and are available for most countries, for the others one wouldhave to make assessment based on per capita use of paint or something like that which I think would still give better result than production figures.

Text adapted, discussion should be about paint used

Should emission factor be distinguished according to the year : 1990, 2000 and 2010 (after implementation of the Directive) : if yes, data are available from CEPE. CITEPA has this type of information.

I would go for even more caution when suggesting as a default value a 2000 average Europen number. I think it could be better to refer to developed and developing coutnries and try to develop two factors at least. We need to remember that there are very often historical or cultural differences, say how and from what materials the houses are built, e.g. if one compares Scandinavia and Mediterranean countries, the construction materials are so different that the standard typical paint applications must be different. I feel these things should be mentioned. This type of information will be useful also for the Tier 1 approach. All that in spite of that fact that I do agree that the 95% conf.int does cover that largely.

In the tables 3-1 to 3-3 the development of the Tier 1 emission factors must be further explained.

Description on how Tier 1 has been derived has been updated

…. Member States to bring decorative or vehicle refinishing paint products …..

Specific EF for 1990, 2000 and 2010 are available from CEPE and have been used in RAINS

Again the issue of production versus use. Please make sure this is consitent, while for cars, coated area, etc, it is ok for decorative paint is not the right appraoch.

The sector "industrial coating applications" is very wide : SNAP codes should be precised

Noted

Rejected

Rejected

Accepted

Rejected

Rejected

Accepted Corrected

Don’t refer to abatement documents that preceed the Product Directive 2004/42/EC from April 2004. The actual abatement regulations in EU-27 should be from that publication onwards. The EGTEI and RAINS/GAINS nomenclature used here is not applicable for DECO.

The sentence "products containing 50 wt-% solvent" is not compatible with EF replace with "products containing 25 wt-% solvent" or correct EF

The sentence "products containing 50 wt-% solvent" is not compatible with EF replace with "products containing 25 wt-% solvent" or correct EF

The EF in not applicable; where we can found the data m2 coated. The EF in this form can be useful to estimate the new paint technology penetration but non the emissions. EF MUST be expressed as g/t of paint or g/t product. Consideration about transfer efficiency of paint on object can be useful to estimate future paint consumption but not for emission inventory. Eventually maintain g/m2 for emissions but define default value for m2/t as surface painted for tonnes of products. This default values can be extracted from original EF source.

Version calculated in terms of g/kg paint applied. Conversion factor mentioned in text.

The EF is wrong!! The value is referred to g/m2! And for this is valid the previous comment: where we can found the data m2 coated. The EF in this form can be useful to estimate the new paint technology penetration but non the emissions. EF must be expressed as g/t of paint. Consideration about transfer efficiency of paint on object can be useful to estimate future paint consumption but not for emission inventory.


Error corrected. EF should be g/m2 indeed

There is an emission factor of 200 kg/Mg for Leather Finishing from BREF that must be taken into account!


I don't think these are always "abatement", new technology/new products are often considered. It's better produce EFs tables (non reductions) with technology/products and put them in section 3.3.2 as in others chapters of GB. I think the approach must be unique!

The table is not applicable. At statistical level is not known the m2 of wood painted. We need EFs for tonne of paint.

For wire, area is not the relevant activity which is the mass of wire coated

Accepted Added to the BAT section

Accepted

Noted

Accepted

Noted

Rejected

Noted

Noted

Noted

Noted

The BAT reference is only applicable to the deco products applied in a factory (installation). The majority of the volume in DECO, however, is going into profeesional use (painters) and do-it-yourself. For that majority (~75%) there is no accepted BAT.

Coating of agricultural and construction equipment: this falls in the industrial coating application (not the decorative coating application)

Moved to Industrial coating application

I think in this chapter should be described methodologies to ensure time consistency and recalcualtion and not methodologies to generate temporally resolved emission data sets

Text removed; does indeed not belong here

What is the meaning of time series? I believed that it is about emission s changing from year to year and so here the issues of changing emissions factors owing to technological change and legislation might be touched upon. As is it is a very difernt story. Verify.


It probably does not belong here as I think wood preservation is a separate chapter and is not part of coating. Suggest ot simply delete.

Removed; belongs in wood preservation chapter

Coating of plastic parts is defined separately in the BREF: it should be added somewhere and the place is in the industrial coating.

For all source categories: National import, export and production statictics for single chemicals can be used as activity data. Used amounts can be differentiated into activities and facilities.

Emission factors can be applied for use of single chemicals in products and/or activities.

With respect to harmonization to Directive 1999/13/EC, which is e.g. employed in performing emission projections: In many technologies a solvent consumption is warranted at facility level. cont. below

continued from above, This requires knowledge on Tier 3 level, which may not be avaliable. The guideline could suggest how to differentiate a total use amount of solvent on a facility level.

Noted

Accepted EF added

Accepted

Noted


FYI: Norway is adopting a different approach to estimating emissions from the use of solvent containing products than the ones described in the Guidebook. Like in the Swedish inventory, volume data from the national Product Register on the solvents themselves is used. Emission factors are specific for combinations of product types and industrial sectors. The 2008 Guidebook does not provide us with information that can be used in the emission model directly. However, the information provided may help to correctly allocate emission figures (pertaining to the combinations of product type and industrial sectors) into the different source categories and help us to improve our emission factors. More information on the new Norwegian model on NMVOC emissions from the use of solvent containing products can be provided on demand.

NO EFs for paint application: boat building (SNAP 06 01 06) - Important in some countries, there is an EF from BREF!

More information is required in relation to the emission factors from EGTEI. A specific reference is required to the background documentation in the GAINS model so that emission factor values can be examined for applicability to national circumstance. The emission factors are not clear in terms of their derivation. The units differ between sources. A common emission factor unit would be helpful.

Description on how Tier 1 has been derived has been updated, reference to GAINS for documentation

A very important refernce is missing I think. It is "DECOPAINT - Study on the Potential for Reducing Emissions of Volatile Organic Compounds (VOC) Due To The Use Of Decorative Paints and Varnishes for Professional and Non-professional Use", EC DG Environment Tender E1/ETU/980084, June 2000. I believe it is available from the Commission web site. This wouldbe very valuable for the section on decorative paints, even if it was certainly used by EGTEI group.

Mentioned in the text as an interesting background document

Cleaning products to be considered are only organic solvents. This has to be precised. Many products used for degreasing do not produce NMVOC

Accepted

NO EFs for Electronic components manufacturing Noted

Rejected

Accepted

Accepted Number placed in text

Noted


Accepted

Noted

Noted

More information is required in relation to the emission factors from EGTEI. A specific reference is required to the background documentation in the GAINS model so that emission factor values can be examined for applicability to national circumstance. The referecence to EGTEI for this sector is to a document published in 2005 and not 2003 as indicated. In respect of dry cleaning i suggest reverting to the old simple methodology approach rather than an emission factor based on kg of garment cleaned.

Reference corrected; old methodology put back but only as a "reference" methdology, industry has insisted on removing information because it was outdated!

The old GB emission factors for units in operation can be useful as Tier 1 meth and must be maintained in the new GB

I think in this chapter should be described methodologies to ensure time consistency and recalcualtion and not methodologies to generate temporally resolved emission data sets


In the "old" Guidebook is present an EF in kg/inhabitant year that can be useful for countries with no other information. Transfer the EF in new GB please.

In this Chapter 60301 (Polyester processing) should be also considered

It is not correct to say that all these activities are insignificant. According to characteristic of the industry and member states, several of these activities are significant.

In the expanded polystyrene, pentane is the most often blowing agent used. In extruded polystyrene other types of chemicals are used. In polyurethane CFC were used but presently other types of blowing agents are used. In polyurethane, the types of blowing agents used depend on the final use of the foam. Butane, pentane can be used as many substitutes of CFC such as HFC and HCFC. Some polyurethane foams can be expanded directly with CO2 resulting from a reaction between polyols and water.

Information added to chapter

The description is a little bit too old . A description of the present situation would be necessary.

The title of the paragraph does not correspond to the SNAP 060306 definition (manufacturing of pharmaceutical product) We agree and support the extension of the scope of SNAP 060306. The speciality organic chemical industry aims at producing different types of chemical products including pharmaceutical products but not only.

Accepted Quote fixed

Explanations coming from EGTEI to be cited Accepted Quote fixed



Accepted

Accepted


Give the list of products to be considered. Accepted

the title is not the correct one Editorial Corrected

Rejected

This chapter is outdated Noted

Editorial Corrected

Noted

the description comes from the EGTEI document which is not quoted.

For expanded polystyrene, pentane is exclusively used.

F11, F12 are forbidden today and cannot be used anymore. Give the names of the present blowing agents.

The reduction techniques available for polystyrene and polyurethane are different. It would be useful to distinguish the two applications. For polystyrene, low pentane content expandable polystyrene can be used (4.5 to 5 %) but just for some specific application. Emissions can be captured and treated by oxidation.


Add on techniques can be used. Applications exists in several countries. Oxidation techniques are the most often used techniques but waste gases containing pentane can be also destroyed in a boiler.


The EC Directive has been implemented but many member states have their own regulation going further the EC directive. Polyurethane foam processing, Polystyrene foam processing, asphalt blowing, the non pharmaceutical part of the speciality chemical industry are not covered by this directive.

Small list of products added, but is not complete

Here is a strong mistake. The suspension process is a process to produce the PVC from VC monomers. In this chapter only PVC processing has to be considered. All the paragraph has to be removed if no data are available for PVC processing.


The confidence interval should correspond to something like 55 to 65 g / kg.

In Table 3-6 is meant pharmaceutical products manufacturing

An emission factors of 50 kg/ton of product (from two factory in Italy) can also be proposed

Accepted

Noted

Noted


Accepted Corrected

Noted

the title is the correct one Editorial Corrected

Noted

Accepted EF added

Noted

Noted

the title of the table if not the correct one. For rubber it is possible to distinguish tyre production and other rubber processing. For tyre the EGTEI default emission factor is 10g/ kg rubber processed. This emission factor is larger for other application. The 8 proposed if perhaps underestimated.

Title updated; rubber production now also includes tyre production

In the SNAP Code should be only considered "Asphalt blowing " a special asphalt production process and not the application of asphalt. The emissionsfactors are very outdated and very large!!! The asphalt application is considered under 40610 and SNAP 40611


The definition of solvent used is the same as the definition used by the EC directive 99/13. It corresponds to new solvents or bought solvents + solvents recycled. It has to be reminded that in the EC directive fugitive emissions are expressed in % compared to solvent used. .


The definition of asphalt should be provided. Does it included only the hydrocarbons or hydrocarbons + all additives and ingredient used (stones…)?

Give the list of products to be considered. In fact they are at east paints, varnishes, glues, inks. In fact this emission factor comes from EGTEI which provides the emission factors for solvent borne products, water based products which can be used by experts if they have the knowledge on the share of each type of products.

Under 60314 should not be considered Tyre manufacturing. This is considered under rubber processing. Under 60314 is considered the manufacturing of solvent containing products

This description is the same for all the speciality fine chemical industry. Lower rates of emissions can be achieved in the newest plants. In existing ones also. Check if we stay with a definition of pharmaceutical products or use the speciality chemical industry?

NO EF (and NO TABLE!!) for 060313 Leather Tanning

An emission factor for 060311 Adhesive Tape Manufacturing is present in BREF

NO EF (and NO TABLE!!) for 060312 Textile Finishing

US EPA insert a lot of other fiber manufacturing activities that must be evaluated: ryanoin, acetate, acrylic, nylon, etc.

Noted

Accepted

Noted

Noted

Noted

Accepted Other processes added

Accepted Corrected

Rejected

Editorial

Editorial

Rejected

NO EF (and NO TABLE!!) for 060301 Polyester Processing there are data from EPA AP 42.MUST BE INSERTED!!


Most of this information can be founded by direct uses of plant data.

More information is required in relation to the emission factors from EGTEI. A specific reference is required to the background documentation in the GAINS model so that emission factor values can be examined for applicability to national circumstance. Emission factors for each sub sector could be presented in one table.

Link to GAINS website provided where background info can be found

But this process has to be considered in chapter 2B

There is a good description of the suspension process in EGTEI

In polyurethane foam manufacturing a large part of VOC emissions is due to the use of solvents for cleaning moulds and blowing instruments.

This section only concerns heatset web offset, being only one of the three groups of printing porcesses addressed in the previous section. This should be clearly mentioned. The other two processes should also be adressed.

newspapers are not printed in rotogravure. Mention magazines, brochures, and catalogues

This section is dangerous and absolutely useless. The two halves of the industry (i.e. a) everything to do with publications and b) everything to do with packaging) are completely independent of each other; different techniques, different markets, different import and export positions, different solvents etc etc. It is wrong to put them in the same boat. This section must be deleted. It is as of vehicle refinishing (i.e. painting) and solvent consumption in shipbuilding (i.e. also painting) are taken together.

I table 3.8 the line 'technoclogy/process'reads 'heatset offset'. This should be publication gravure.

"audits" could be replaced by "solvent management plan"

I don't think these are always "abatement", often new technology/new products are considered. It's better produce EFs tables (non reductions) with technology/products and put them in section 3.3.2 as in others chapters of GB. I think the approach must be unique!

Noted

Rejected

Accepted

Accepted

Accepted

Accepted Added

Accepted

Accepted Added

Editorial

Accepted Section headings renamed

Accepted

Rejected

In general, 2 other processes could be added: sheet fed and coldset offset. EF and abetment efficiencies have been defined by P. Verspoor for the revision of RAINS. CITEPA has also data on these emissions.

Suggest using the previous simple methodlogy approach and presenting emission factors in one table.

Figure 3-1 seems to be copied into several documents but it is not always appropriate. This is such case where including TIER 3 on chart is not of relevance.

Decision tree and corresponding text updated

Figure 3.1, decision tree is not correct: the facility level for domesticsector not available and no Tier 3 for this NFR.

Decision tree and corresponding text updated

Tier 1 default emission factors is incoherent with Tier 2 as EF (Tier 1) < SUM (EFs(Tier2)) and different from old one. Change Tier1 or remove Tier 2


Althogh the two approaches presented in the algorithm are principally applicable here, the formulation (obioviously copied in several chapters) is not appropriatre, specifically talking here about industry is not what this sector is exactly about, it is use of products and their characteristics (formulation=solvent content) and then shares in total use are of interest. Please adapt accordingly.

Description updated according to comments

cooling liquid (ethylene glycol) may also contribute to emissions

This must be a missunderstanding. What are these 'add on ' measures that couldbe applied here, a little incinerator in the bathroom to burn the VOCs from the hairspray used? Apologies for trying to be funny :-)

Corrected; abatement indeed not applicable as such

An important and very useful reference is missing and certainbly it could be used for improvement of the chapter - BIPRO, 2002. "Screening study to identify reductions in VOC emissions due to the restrictions in the VOC content of products" -Final report for the European Commission.

should read "2.1.2.3 Organic solvent borne preservatives"

Why is "adhesive tape" the unique sector described in Industrial application of adhesives. Many other type of application are existing.

Could it be possible to define which sectors are considered in IND_OS

Reference to GAINS added for documentation

When it is said that 3 sectors have the same activity units (Mg product used), it is not totally exact as we have Mg of glue, Mg of seed and Mg of others… how do you deal with these differences? Give examples.

Accepted

Editorial

Notedadd all subsections to the table of contents Editorial Done

Editorial

Accepted

Accepted

Accepted Done

Accepted DoneOverview too short, gives too little information Accepted Overview expanded

Accepted Overview expanded

Accepted Done

Accepted

Rejected

Accepted Done

Accepted

Why is "use of shoes" a source of NMVOC? The manufacture of shoes is a source of NMVOC, but the "use of shoes" is a source of PM!!!

Update: must be manufacturing of shoes, not use of shoes. Moved to chapter 3.C as well

The title should be Wood preservation and not Fat, edible and non edible oil extraction

In this Chapter is not considered (forgotten) glass and mineral wool enduction

sometimes (e.g. p 18, l 33) there is only one subsection 3.3.1, but no 3.3.2; subsections need at least two chapters

Not sure about this, I don't see the need, but can Nicola discuss with Tinus

Equations and legends: inconsistent notation, not in line with IUPAC

Nicola, this was mentioned earlier so probably done by now

The chapter is difficult to read. It is not a really whole ist a summary previous chapters.Title should be expanded to livestock husbandry and manure. Nobody would search for PM emissions in manure management. The structure is not suitable for agriculture. PM is not really integrated and is added only.

The structure has been revised and hopefully is now much more accessible

maybe it would be useful to say that N2O emissions, even if part of the N mass-flow emission cycle, are not considered here because GHG

it must be specified that the emissions from grazing animals have to be calculated but not (??) reported under chapter 4B. In the general scheme of the chapters it appear they are under 4D

Expand overview to give more background information

To avoid misunderstanding it should be pointed out, that the emission from grassing animals has to be reported in NFR category 4D2c

Table 1-1 shows that NOx emission from the agricultural sector contribute by 1.8% of total NOx. This indicate the important of develop a Tier 1 methodology. Is is possible to recommend a Tier 1 approach based on the reference of the data given in table 1-1?

Simple Tier 1 approach now included

There is no mention of NH3 being produced from urine except for the comment in brackets on line 23. It woul read better for the non-ag expert if a sentince on NH3 from urine and faeces began the paragraph

No longer relevant as we have revised these sections

"a small percentage of this N (is in the form of) urea or NH4+…………"

Suggest re-wording the overview. Appears as if some text was deleted and as a consequence its structure does not read well

Overview revised and expanded

Rejected

Acceptedadd: for EU-27 Accepted Done

Rejected

Accepted Done

Rejected

Accepted Done

Process description is too short Accepted

AcceptedAn example of "movements activities"? Accepted That text now deleted

Rejected

Accepted DoneThe reference = Van Faassen and Van Dijk Accepted Done

Sentence incorrect Accepted

Accepted

Accepted

Accepted Done

Accepted Have done

Accepted Have done

Suggest moving this comment to the bottom of the page as a footnote

Footnotes are irritating to the reader

The reference Jarvis etal doesn't cover pigs. For pigs 70% of N is in urine and 90% of urine-N = urea-N.

Reference for pigs now included

add N2O and CH4 to the emissions created from manure

No longer relevant due to re-structure of chapter

There is no abbreviation expansion for TSP. This concerns the whole text. I suggest to add the glossary of all abbreviations in chapter 4B

"in particular (the) handling of manures as……………"


Groenestein, C.M. and H.G. van Faassen, 1996. Volatilization of ammonia, nitrous oxide and nitric oxide in deep-litter systems for fattening pigs. Journal of Agricultural Engineering Research 65: 269-274

Process descriptions now expanded

Provide more information about processes (put extended description in an appendix)

More information provided on processes and clearly linked with supplementary data in Appendix

It is correct that only a small percent of faeces is NH4+, but the sentence needs further development, because most manure is managed in a combination of urine and faces (both slurry and solid waste). The sentence need to clarify that the TAN content i in solid based stable systems contains large amounts of TAN (30-50%). So the NH3 emission is not "sufficient small".

This section is dealing with 'fresh' N excreta, so comment not releveant, but revision of chapter now gives more explanatory text.

please change Van Fassen and Van Dyke into Van Faassen and Van Dijk

This entire section has been revised

ist obvious that PM belonges not to manure mangement

There is now a separate section for PM

Dust mainly origins from poultry and pig farms. Dust from poultry houses is mainly caused by feathers and manure, dust in pig houses mainly comes from feed, skin particles, faeces and bedding (Aarnink & Ellen, 2007, see www.dustconf.com)

Nicola, can you please locate the reference and insert

" e.g. at pasture or on yards, and (in) animal (housing)……"

Replace with text from original final draft, which was structured according to pollutant


Appendix A2.2.3 ?? Rejected

Rejected

Delete activity Rejected

on animal? Rejected

Rejected

Rejected

Rejected

Accepted

Rejected

Accepted Change made

RejectedFigure 2-1 appears twice Accepted DoneAuthors not cited in chapter 5 Accepted Reference now given

Rejected

RejectedDammgen and Hutchings is not in References Accepted Reference now included

Accepted Reference now included

Rejectedreference? Accepted Reference added

Accepted Have done

Accepted Have done

Noted

Incomprehensible comment

Repace "NIMVOC inventory is further complicated……." with "Estimates of NMVOC emissions are further complicated………."

That sentence has been deleted

Section has been re-written

Section has been re-written

Delete "The" from "The significant emissions of PM…….."


"The types of feed consumed will have a major affect (on) emissions"


Order of items does not seem logical, better follow order of figure 2-1


TAN needs proper explanation first, unless TAN is introduced earlier? Also mention UAN

Explanation now give, including UAN

Add after building: and the storage system. I think it shoud be included here instead of in line 26

This section re-written to include original text

Delete -the storage system- and add -ventilation system-. The latter is very important in determining air velocity and thus emission of ammonia

"the height and density of (the) canopy of the crop or grassland"


General: Distuinguish between indoor and outdoor storage like you did on the previous page in summing up important elements. Distuinguishing is very important because reduction strategies for indoor storage are totally different from outdoor storage. Indoor storage is a component of the housing system.

The figure is to illustrate the principals.

General: I assume the symbols for variables are scientifically correct, but it is also very confusing, I got lost. Please find better solution

The figure has not confused other reviewers

Can't find "Dämmgen and Hutchings, 2007) at the reference-list

the treatment of manure (i.e.: aeration, separation, composting) is not cited here neither considered in the following

These are not major sources and not explicitly accounted for in the methodology



A good idea to clarified that the NMVOC is related to the methane in manure.

Rejectedthe number of Figure 2-1 is double Accepted Done

Accepted

AcceptedFigure should be shown in 2.1 before Accepted If the figure remains

Rejected May delete the figure

Rejected

Rejected

Accepted Text now amended

Accepted Sentence clarified

Replace "Excreta" with "excreta" Rejected

Accepted Done

Accepted Comment deleted

Rejected

See remark 5 Accepted

Rejected2.4.4 written 2 times Editorial Done

Rejectedadd after N: and/or TAN Accepted TAN inserted

Odour (of pigs) can be characterised by 20 main components (putting those compounds together creates artificial odour). The formulation used in these lines suggest something else. Please check.

Do not agree with the comment, we already state that most of the emission is from 20 compounds

There are two figure 2.1. Some explanation is needed for this figure in page 7.

Same comment as 16 and 19 above

This chapter only covers NH3. Please expand on other compounds or incorporate in 2.4.1 (which then should become 2.3.1)

We have revised this section

Figure 2-1; should consider to show a figure based on different compounds instead of production states.

It is not possible "reducing the rate of transformation of TAN to NH4". This is incorrect. NH4 is part of TAN. It is possible to change the distribution between NH3 and NH4 by altering pH.

NH4 is part of TAN, but not all of it

If animal feed is silage, NH3 can emit. If not taken into account as losses, please note so

replace -mainly from feed- with not only from excreta, but also from feed, animal skin, flees or plumage and bedding

between brackets: two third of the total. Of what? Total NMVOC?


better to say also that the measures to reduce emissions are listed and explained in Appendix A3

why manure drying via conveyor belts would reduce PM emissions?

list measures to reduce NH3 emissions (e.g. reduction of air contact, lowering of the pH value) instead of manure management stages where NH3 emissions can be reduced

Not the purpose of the Guidebook to give detailed appraisal of abatement techniques

We have revised this section

Not all NH3-emission-reducing techniques in housing systems reduce odour emission (Mol, G. and N.W.M. Ogink (2004). The effect of two ammonia emission reducing pig housing systems on odour emission. 2nd IWA Conference on Odour & VOCs: Measurement, Regulation and Control Techniques, Singapore. Published in: Water Science and Technology, 2004, issue 4, p.335-340)

We do not state that all techniques to reduce NH3 emissions reduce odour. We state that techniques with reduce either or odour can reduce NMVOC. Have changed 'can' to 'may'

Cleaning the air with air scrubbers is also an abatement option (optional as BAT)

Scubbers are now mentioned elsewhere

Editorial Done

Accepted

Rejected

Acceptedbefore this line insert a heading: Ammonia Editorial DoneSection title 'Ammonia' is missing Editorial DoneSection title 'Ammonia' is missing Editorial Done

Accepted

Rejected

Accepted Text restored

Accepted Text restored

Accepted

Accepted Tier 1 approach added

Editorial

Rejected


Delete "way" from "The latter is the most effective way"

In the expert Group of Ammonia Abatement (UNECE) air scrubbers are considered to be category 1 abatement options. Some information on effectivity in: Melse, R.W. and N. W. M. Ogink (2005). Air Scrubbing Techniques for Ammonia and Odor Reduction at Livestock Operations: Review of On-Farm Research in the Netherlands. Transactions of the ASAE. Vol. 48(6): 2303-2313. Text amended to report air

scrubbers as category 1

the abatement means are theoretical but not applicable or state of art

We do not suggest otherwise

Decision tree: ask first if it is a key source and then the other questions (tier 3 available, MMS distribution available, etc.)

Nicola, can you please amend

The dafault emission factors include emissions from grazing animals? (better to specify)

We now state the EF includes grazing for ruminants

I think it will be easier for the user to work with one document instead of looking for information/explanation in IPCC (2006)

We provide all the information needed, the reference to IPCC is to enable access to more detail.

Restore text from original draft but removing the discussion of emission factors

Restore text from original draft but removing the discussion of emission factors

It could be useful to add the exact reference to IPCC 2006. Example. I suppose it is refered to Chapter 10 section 10.2

The chapter is already in the reference list, and we have added the section to the reference

General remark: NO emissions from manure mangement are not presented (only an estimate is said to be presented in the section on ammonia emissions for losses during storage (step 10 page 22 with reference to an Appendix Table 5.9 which cannot be found; it seems to be the Table on p 57). However, no NO emf is presented for manure application to soil??

Average Annual Population or as IPCC2006 Annual Average Population?

Has already been taken out - discuss with J

Is it required to distinguish between time in stable and time on grass in Tier 1? I assume that the Tier 1 EF for NH3 given in Table 3-1 to 3-15 only includes the emission in stable? EF for NMVOC and PM - is it for 365 days in stable?

It is stated in the text the EF includes grazing emissions based on average grazing periods

Could supply with a sentence like "No Tier 1 approach is available for emission of NOx"

Appendix A3.1.4?? Rejected

Accepted

Editorial Done

Noted

Noted This is 4D

AcceptedInconsistent citation of references. Editorial Has already changed

Noted

Dammgen et al 2008 is not in References Accepted

Accepted

Accepted


A lot of misunderstanding and miscommunication can be caused by the definition of the activity data. Definition of AAP is not in agreement with p. 4 lines 23-26. I do not think it is appropriate to deal with this matter only with referring to IPCC 2006 for fuller explanation.

AAP now defined consistently

Delete "in tables" from "Netherlands, Denmark and Germany in tables…."

PM10 and PM2.5 are higher for FYM (straw based) than for liquid systems. Please make a differentiation

Specify in the text which regions is applicable the EF

References used to proposing new EFs are not published and not available yet. The National Inventory Report of a single country can be considered a scientific reference?

Published references now provided for the EFs from each national inventory

PM10 EF values presented seem to be not in line with values used by the Netherlands for several animal categories. However, since the basis for the pm10 emf is rather unclear it is very hard to make a good comparison. See below questions on categories included and on the time spend in the meadow:• It is unclear where the calves and piglets are included. Eg for cattle it is unclear whether dairy cattle only includes female adult dairy cows or also young (dairy) cattle? And what animal numbers should be used if dairy cattle is a mixed category? Since calves have a much lower emission factor their emission will be overestimated if the presented emf for other cattle should be used. The same remark can be made for swine: in what category should the piglets (weaners) be included? (specifiek place in the tekst: page 12, line 5 to page 13, line 3 and page 14, line 7 to page 15, line 5)

The text will be corrected to Dammgen 2007 - Nicola

In table 3-1 to 3-14 concerning the PM2.5 emission referees to "Dämmgen et al., 2008" - this reference is not on the reference list.

The text will be corrected to Dammgen 2007 - Nicola

In table 3-1 to 3-15 Propose one table for each compounds - then it is more easy to compare the emission levels for all livestock categories.

We have restored such tables to the text

Accepted

Editorial

Editorial

I would prefer fewer tables in the text Accepted

Accepted

Accepted

Accepted

Accepted Text changed

Accepted Text changed

Accepted

Rejected

Accepted

Editorial

Tables: References inconsistent with Chapter 5 Editorial

The emission factors for NMVOC and PM are given in incorrect units (kg NH3!). This is valid for all tables. Both "a-1" and "per AAP" is used. The same nomenclation should be used all over, eg. either "a-1" or "per annum"

Nicola, can you please make these corrections in the tables

the unit has to be differentiated by pollutants (not always kgNH3 a-1 per AAP)

Will change with new tables (what are we doing about tables?!

General remark: Incorrect units used in Tables for most pollutants except NH3 (all units are expressed as kg NH3)


Concise summary tables now provided

Remove tables to an appendix (correcting the EFs for PM where appropriate) and replace the text and tables from the original draft, adding more information about EFs

Have replaced text and tables from original draft. Have not yet placed template tables into Appendix as we need to agree this with TNO

Tables are confusing and should be presented in a condensed form.


the Reidy et al, 2007 reference is insufficient, it does not contain the specified NH3 emission factors. Please give more references

It is not appropriate to insert large numbers of references in the text, the full list is now given in the Appendix.

Please indicate in the text that all animal manure is surface applied

Please indicate in the text that all manure storages are open

the tables are not the best, previous solution had been better

Agree, but we need to agree with TNO

The detailed tables provided even though numerous are user friendly and allow the user to be able to calculate upper and lower estimates of emissions for each gas. It may be possible to included all the info in one large table however, it may become too cluttered and diificult to use. There appears to be some discrepancies with the livestock categories used in 4B and 4D. Suggest a closer look at the discriptions in the emission factor database especially for cattle sub-categories.

This is not the view of the great majority of respondents, and for the final version we propose having the detailed tables in the Appendix

Remove tables to an appendix (correcting the EFs for PM where appropriate) and replace the text and tables from the original draft, adding more information about EFs

Have done this. Nicola, can you please see to EF corrections

I am afraid the units for NMVOC, PM10,PM2,5 are not quite clear for me - for all these parameters is "kg NH3 per AAP"correct? This concerns tables 3.1 to 3.15



Editorial

Accepted Done

Rejected

Accepted More references given

Accepted

Check units of Table 3-1 Editorialsame comment as for dairy cattle Noted

Noted

Noted

change units for NMVOC, PM10, PM2.5 from NH3 into appropiate units


Explain abbreviation "AAP" (explanation comes in the next section, but should be given when AAP is used for the first time)

Why are the last two rows relevant? The same remarks goes for every table 3-.

Can't change the table template

The reference publication Reidy et al, 2007 is mentioned as basis for the values presented in the Guidelines 2008 draft for tier 1 NH3 emf (on pages 12 till 17 in Tables 3-1 till 3-15) and for tier 2 NH3 (on pages 24 till 31 in Tables 3-16 till 3-30). However, it only provides some (not all, yard values are not included) tier 2 data for dairy cows and fattening pigs. It is unclear what is the basis for the tier 1 emf for all animal categories (not even for dairy cattle and fattening pigs the chosen defaults are presented in Reidy et al, 2007). Also is it unclear what is the basis for the tier 2 emf for other animal categories than dairy cows and fattening pigs and for the tier 2 Yard emf for dairy cows and fattening pigs. It is recommended to make clear what the basis is for all chosen emf (to provide information on the publications where these data originate from). (specifiek place in the tekst: page 12, line 5 to page 17, line 2 and page 24, line 16 to page 31, line 2)

Table 3.1 and all other. 95% confidence interval is often the same and should prefrenctially be given as +-xx%. Especially to avoid upper emission levels above 100.

Nicola, can you please see to this


PM is higher for FYM then for liquid systems fattening pigs

PM10 EF values presented seem to be not in line with values used by the Netherlands for several animal categories. However, since the basis for the pm10 emf is rather unclear it is very hard to make a good comparison. See below questions on categories included and on the time spend in the meadow:• Pm10 EF values in Tables are not always clearly based on table A3-5 in appendix: eg eg for fattening pigs, sows and laying hens in Table A3-5 2 different values are presented for 2 different housing types, while in Table 3-8 en 3-9 (page 14 and 15) only one (mean?) value is presented for the different systems.

Noted

Noted

Accepted

Rejected Not for Tier 1Cleaning period: the unit (in day) is lacking Accepted Unit inserted

Accepted Definition insertedn-places: add usually occupied Accepted Definition expanded

Accepted average' inserted

Accepted

Accepted

Accepted

Editorial Done

please lower PM2.5 because these figures are now higher then PM10

PM is higher for FYM then for liquid systems for sows

For PM10 (Table 3-12) emf are provided for all manure management systems. Since there are big differences in the two manure management systems cages and perchery) it is recommended to provide emf for the two management systems.

The distinction between cages and perchery is in the new table

please differentiate within poultry for solid (bedding) and liquid systems

better to add in the table also a definition of n-round = average number of production cycles per year

Empty period: I prefer to add "average" duration during the year….

The link to “FAO Production Yearbook” is: http://faostat.fao.org/ Under item “Latest news” FAO Statistical Yearbooks 2005/2006 (issue 1 and issue 2) are available.Issue 1: http://www.fao.org/statistics/yearbook/vol_1_1/index.asp and Issue 2: http://www.fao.org/statistics/yearbook/vol_1_2/index.asp (Livestock numbers are available from Issue 1, Table A9).

Please note that the yearbook is updated on an annual basis. Providing the URL http://faostat.fao.org/ is probably the best.(Just a thought regarding section 3.2.3 Activity Data (line 4-6)… if a country do not carry out annual surveys on animal numbers how would ESTAT or FAO get these numbers?)

References included. Thanks to the reviewer

Check definition with earlier explanations on p 4 (line 23-26) and p. 11 (line 26)

Text amended to be consistent

Sometimes the two sources of activity data information do not match. EUROSTAT information for european countries is updated every year and have definitive data available. FAOSTAT important source, but nowadays data available only till 2004 year. Probably the best is to encourage at first national statistics and after other sources.

Have amended wording slightly to reflect the comment

Same comment: define is using Average Annual population or annual average population

Rejected

Accepted

Rejected"present on a particular day (will)……….." Editorial Done

Editorial

"seasonal production cycle(s), ……" Rejected

Editorial DoneTable 3-1 (to Table 3-15) Editorial Doneafter the word "rounds" specify per year Accepted Done

Third method seems second method Rejecteddefault data for N excretion: where? Accepted Reference to table given

Rejected

Accepted

Rejected

No information on application required? Rejected

Are there no activity data on storage and spreading to be mentioned here?

No, statement made that default based on surface application and open stores

The formula should be elaborated further. For most animal types AAP is given in the national statistis. For animals having a life cycle> 1year, the cencus in most countries thus takes into account empty places. The formula is therefore more a correction formula for amimals haveing a life cycle <1year. The same is valid for the subsequent formulas.

This section has been re-written to make clearer

I prefer to have the methodology to estimate animal number/acivity data before the methodology for EF

The TNO chapter structure does not allow this

(A)nnual agricultural cenus (data) can supply (this information)

Sentence changed with other comments

Grammar was already correct

"is seaonal or because the (housing) is being cleaned"

No, there are three methods

The basis for a Tier 2 approach is mentioned in line 14-16. In these calculations it’s not exactly clear if a breakdown of the different livestock categories (cattle, pigs etc.) into sub-categories (e.g. sows, piglets etc.) is taken into account. However from sections 3.3.1 “Algorithm” + 3.3.2 “Technology Specific Emission Factors” it appears that different livestock sub-categories are taken into account. Perhaps the introduction of section 3.3 could be a bit clearer on this.

Text has been substantially revised so comment no longer relevant (Step 1 onward)

For PM emission is mentioned that "For grazing animals… the grazing season and the daily grazing time is needed" BUT at page 9,7 is written that PM emission from "cattle, pigs ect…. are considered to be negligible during grazing"??

The time spent grazing is needed in order to accurately estimate the time spent in the building where most emissions take place. This is now made clear.

Suggest deleting the heading PM and begin the paragraphs as follows: " In the case of PM, information is required……………."

The guidebook template requires clear sub-headings

Text amended in response to previous comment to state that default based on surface application and open stores

Rejected

Rejected

Rejected

Rejected

Rejected

section 2.1.1 where is it? Editorial

"PM" - misprint ? Noted

Accepted

Accepted

Accepted

See comment to page 17 line 19. Accepted

Accepted Done

Accepted

PH = pH Accepted

Acceptedafter N excretion: add : and TAN or UAN Accepted done

Accepted Nicola is dealing with this

Accepted Changed to mN excretedafter milk add "eggs or offspring" Accepted Done

Accepted

Rejected

activity data listed under the heading PM are not only required for PM emission estimates but for the other gases as well

Yes, to confirm specific requirements for PM

emphasis only on livestock numbers; much more activity data are needed for an accurate inventory; give those more room in the chapter

Yes, but this is for Tier 1, the need for activity data emphasised in Tiers 2 and 3

information on manure treatment is needed, please add this to the list

Manure treatment is not a major factor in national emissions

formulate stronger e.g "Tier 2 is RECOMMENDED" instead of "proposed"

Text has changed and the passage referred to removed.

Why is PM mentioned separately, this infromation is also needed for other components?

Yes, to confirm specific requirements for PM

Changed with earlier comment

Not sure about this - J please could you take a look

In which way are soil PH included?? - is this shown in figure 2-1 (process scheme)?

Reference to soil pH deleted

Remove this Tier 2 description and replace with the text from the original draft (i.e. With more explanation and without the formating errors)

The original text has been re-inserted, with some improvements

Remove this Tier 2 description and replace with the text from the original draft (i.e. With more explanation and without the formating errors)

Duplicate of row 103 above?


This chapter heading can be left out. Instaead emphasize that Tier 2 is just ammonia (although already mentioned in line 32).

"the types of stores in which (manure) is kept……….."



I do not understand why you mention soil PH? Key variables are not shown in Figure 2-1

Reference to soil pH deleted

Table 3-1, section 3.3.1 and also many times in the following: the ref is wrong or lacking

mexcreted is not a self-explaining symbol for total nitrogen excreted, it seems total matter excreted, it would be better to use mNexcreted, by analogy with mTAN

It seems to me, references to Tables 3-1 and Paragraph 3.3.1 are wrong

Nicola, can you check table references once we finish the text

I would prefer to find IPCC equations10.32,10.33 right in the Guidebook,

We should avoid simply repeating IPCC text

Accepted

Accepted changed to 'kg a-1 N'

Table 3-1 does not exist in that form Editorial

Rejected

Accepted

Acceptedmfaeces: definition? Accepted Defined

Accepted Same symbols now used

Rejected

Where is table 3-3? Editorial

check subscripts Editorial

And how should we calculate x(Nfaeces)? Accepted

Rejectedany references for the value of fmin? Accepted Reference inserted

Rejectedmbedding don't appear in the formulas… Rejected It appears in Eq 23any references for the value of fimm? Accepted Reference inserted

Where are Tables 3-3 and 5.9? Editorial

Rejected

The source of the stepwise approach should be cited.

The derivation of the approach is given in section 3.2.2.1

Treatment of units: "kg N a-1" means kilogram newton per year!

Need to sort out the tables in these steps

in IPCC organic matter is defined as Volatile Solids: wy not to use the same here?

The sentence referred to has been superceded

it is not clear how do you use xfaeces and xurine: I suppose xurine is not the same as xslurry and x faeces is not the same as xFYM. So it is not clear how to translate xfaeces and xurine in mTAN;


proportion of total excreta or proportion of total N in excreta? (is the assumption that Nitrogen split in the same way as mass into faeces and urine?)


use the same symbols in the text and in the formulas: mTAN_slurry is mbuild_slurry,TAN? Etc.

I would prefer to see IPCC equations10.24 right in the Guidebook

Reference to equation no longer made


J - there is now a missing equation - would you like me to renumber these?

This section amended to make clearer

I would prefer step 7 to be grazing. This manure is not in storage

To make step 7 grazing would interrupt the sequence from excretion through housing to storage and then to application.

at this point of the calculation xFYM is the proportion (without bedding!) of manure excreted, handled as FYM. I believe it woul be better specify that the proportion is in mass (kg/kg) and that it doesn't take into account the bedding material…

Have checked formulae and they do account for bedding


Table 3-3 shows Tier 1 emission factor for Other Cattle on slurry which give no relevans in the text describtion.

Nicola, when re-drafting complete please check accuracy of references to Tables

Rejected

Appendix Table 5.9?? Rejected

Appendix Table 5.3?? RejectedDo you have a refence for 0.68? Accepted Reference insertedDo you have a refence for 0.1? Accepted Reference inserted

mm (storage,org) or mm (storage, N)? Accepted" it does (however) require much more………." Editorial Done

Rejected

Rejected

the active axcel file is necessary!! Accepted

Does Appendix B exist? Rejected

Do there exist an Appendix B? Rejected

RejectedWher is Figure 1-1? Editorial Done

Rejected

Accepted

Accepted

same remark regarding the terrible table Accepted

Accepted





mm storage N, correction made



Would a formula not normally be written as: Kg NH3-N a-1 ??

Not according to one of the other reviewers

It was supplied for the review!



The ammonia emission report unit in NFR is NH3 and not NH3-N

Which is what we have written!?

As the EF is a percentage of TAN, there is no reason to differentiate in EF yard and for grazing between dairy cows and other cattle

The evidence we have indicates that there is a reason

Remove tables to an appendix and replace the text and tables from the original draft, adding more information about EFs




The concise tables have been restored and we propose the template tables go to the Appendix

To many tables - all data could relativly simple be represented in one or two tables without missing important information.


Rejected

Accepted

Accepted

Editorial

Rejected

Rejected

EditorialFigure 1-1 not presented in the document Editorial Donesame comment as for dairy cattle Rejected And the same riposte

not "Other cows" but "other cattle" Editorial

Rejected Source of EF now given

Rejected Source of EF givenThere is no EF for outdoor sows? Accepted EF added using UK data

Rejected

Rejected

Table 3-29 - no data for "other poultry"?? Editorial

Only emission factors for dairy cows and other cows are included. Emission factors for other cattle sub-categories are required here. See comment 14 for further issues.

The Guidebook only needs to cover the NFR codes. Section 3.4, Tier 3 states that 'if data are available, emission calculations may be made for a greater number of livestock categories than listed under Tier 2'.

Remove tables to an appendix and replace the text and tables from the original draft, adding more information about EFs

Have re-inserted text and concise tables

The chosen tier 2 default emf NH3 in the Tables 3-16 till 3-30 on pages 24 till 31 seem to be an average of the figures presented in the appendices page 48 till 50 (Table A3-1 a till d). However there are some deviations: Yard emf are not available in the appendix Tables and a figure of 0.15 is presented for broilers (one value only for the Netherlands), while in Table 3-28 a value of 17 is presented. What's the basis for this figure?

Further footnotes now added to new summary tables

Check proper width of cells. Why are last two rows relevant?


Now it is NH3-N conversion despite the formula consists of "Estorage, NH3". It should be changed in all formuals to "Estorage, NH3-N".

This equation no longer in chapter

All tables has the unit as %TAN. It should preferentially be "% of TAN" and no 95% upperlimit above 100%

We think the meaning is clear

All tables could be written more easily. To much unnessary data



the EF for yard is extremely high and not explainable, so please adjust to 53

the EF for grazing is too high, so please change into 10

Is the manure of the laying hens considered always as solid manure and not slurry?

We do not think there is enough evidence to discriminate

broilers and other poultry are mostly kept on solid manure systems, so here no need for EF liquid systems

I cannot see that we have an EF for broiler slurry (?)


(Table 3-29 Other poultry) no figures are included. Accepted Corrected

Rejected

Rejected

Check Values and confidence interval in table Accepted

Rejectedadd a reference to Appendix A3 Accepted Done

Rejected

Accepted Text now amended

Accepted

Rejected

Rejected

after "storage" add "and after field application" Accepted

Accepted Have done

Accepted

Rejected

(Table 3-27) emf are provided for all manure management systems. However, since these figures are based on the Appendix tables it turns out that only solid manure is included. Since liquid manure systems (cages) still exist and since their emf are different from solid manure systems, also liquid manure management emf should be provided.

Not enough evidence to differentiate

please make a differentiation into solid (bedding) and liquid.

Not enough evidence to differentiate

Nicola, can you please see to this

3.3.3 Abatement: why not Controls as in section 2.4? Abatments seems more appropriate to end-of-pipe techniques…

This section is specific to the incorporation of abatement techniques in the calculation

As it seems to me, table 10.19 of IPCC chapter 10 Default N excretion data is necessary to be included in the Guidebook

All inventory makers surely have IPCC available as well (and can look the default values up)

As it seems to me, paragraphs 3.3.3 and 3.3.4 are not complited

No technique to reduce emissions in livestock houses? In the ILF BREF there is a long list of BATs for animal houses..

The section now makes reference to housing techniques in UNECE and BREF docs

The EF for inside storage and outside storage differ, mainly due to differences in temperature. Moreover by removing the manure quicker to outside, is an abatement technique. As I do not have the data from Reidy et al, I cannot check the presented EF. If necessary I will be helpful to elaborate this in more detail.

I dont't understand why this section is here and not within 3.2.3

The intention was to put information on activity data specific to the Tier with that Tier

And manure application inserted

Reinsert sections for the different polluntants. Remove second paragraph (not valid for all abatement measures (eg optimised feeding)

Refer to IPCC data on manure management systems

Table in Appendix gives cross reference to IPCC definitions

Likely the choosen approach is that most of the animal manure does not stay for a long time inside the animal house and is stored outside.

Fair commenr, but text already covers this

Rejected

Accepted DoneReinsert sections for the different polluntants. Accepted Have done

add abatement measures from the house Accepted

Accepted done

I cannot find these notes in the Tables? Acceptedcheck subscripts Editorial Done

Abatement deals with ammonia only Rejected

Rejected Formula no longer used


Accepted Paragraph re-worded

AcceptedMentioned an example of double counting. Accepted Example now given

Accepted Changed as suggested

Accepted Example now given

Accepted

Accepted

Accepted

also in Mol and Ogink 2004 (see also remark 22) Rejected No need for actionMS(T,S) ?? Rejected These terms are defined

This reviewer has the opinion that a lot of European animal production systems store their manure inside the animal house

Contradicts previous comment

Referer to Appendiks A - chapter A.3.1 for further information

Reader referred to Appendix and other documents

not only housing activity data are relevante, but storage and spreading as well; please add these

The concise tables have the footnotes

Because there is only a Tier 2 method for ammonia

Is the formula correct? The value calculated is my view an implied emission factor and not an EF for abated techonlogy. N_abatement is not defined.

see remark 13 about differentiation of inside and outside storage

Emissions are not solely governed by fouled area. Change formulation?

There is no restriction on the form of Tier 3, provided it can supply estimates that are more accurate than Tie 2.

Have re-worded to make this point.

Same comment: for european countries the best cross check is to be done with EUROSTAT information. FAOSTAT statistics at this moment are not updated.

Probably an example of "manure management sub-categories within the livestock categories" could be useful. Otherwise, define it in Figue 3.1 or at page 18 line 27 where this term is used.

There is also a figure for overall uncertainty in the Netherlands, using a Tier 3 approach. The Dutch uncertainty is 17% (TNO, 2004)

Quoted uncertainty now included, Nicola, can you please find the full reference

TNO, 2004. Uncertainty assessment of NOx, SO2 and NH3 emissions in the Netherlands, TNO report R 2004/100, TNO, Apeldoorn

Quoted uncertainty now included

In the text is mentioned "Consequently, there are large uncertainties associated with the default EF for this source". BUt no NOx defalut value is recommended - not even for Tier1 methodology.

Text reworded to refer to emission estimates, not specific EF

Accepted

Accepted

Accepted

Accepted

Notedno overview for ammonia? Accepted Now added

Noted

I miss some further describtion for NH3 and NOx Accepted Now added

Rejected

Accepted

Accepted

Rejected

Noted

Accepted Have done

Accepted

Caption: "aerodynamic" instead of "airodynamic" Noted

it is not clear from the previous methodology that the emissions from grazing animals have to be reported under 4D. How could you do it in the case of tier1 methodology? If I understood it correctly, it is necessary to highligh somewhere else that you make the calculation under chapter 4B and to report the results under chapter 4D

This has now been made clearer at the beginning of the chapter

why are these sentences reported under "external review?

The statement has been deleted

Has this been copied directly from the IPCC guidelines? It contradicts the statement p3, l 1 - 9 where all NH3 emissions are reported under manure management and not under soils.

The statement has been deleted

All references should be available on the internet at EEA homepage

Nicola, can you check this with TNO

van Fassen etc should read: Van Faassen, H.G. and Van Dijk, H. 1987. Manure etc In: H.G. Van der Meer, R.J. Unwin, T.A. Van Dijk and G.C. Ennik etc

Reference seems to have been removed

PM definitions are not target orientatet.Its a mixture of differnt defin. Ist to separate why in the past other defin. Are used and which will be used in the future. The relevant difference in comparision with gases should be explained.Its nice to see my figure(A1-1)but no quoting?

Amount of science in the Guidebook is just right, but it is better to place it in one place, it is unimportant where -in the main body text or in appendix

The revision now gives a more coherent balance between chapter and Appendix

the Appendix is toolong.The author could not decide wether he gives information(scientific(in the body or the appendix.

The Appendix is now shorter

General: Why is this information in the appendix and other information in text. When is it background information and when not? Choice is not clear and seems arbitrarely. Please explain protocol or change the way information is presented without shattering.

We have restored much of the explanatory text to the main chapter and now think the division between text and Appendix is coherent.

The appendices are misplaced and should be included at the end of the agriculture chapter (i.e. after 4G) in future drafts.

It makes more sense to have the Appendices closer to the main text

A clear guidebook definition of "Inhalable dust" and "Respirable dust" are needed.

Discuss with JG - put into the GG chapters

Appendices will require revision, since some material will be moved from the current appendices back into the body of the text

Appendices will require revision, when comments above have been taken into account

Appendices have been revised

J - is this correct? Is this your graph to change?

Rejected

Rejected"measured" instead of "made" Editorial Done

Noted

Accepted

Rejectedlandspreading instead of spreading Accepted done

Accepted Reference now given

Accepted Sentence expanded

Accepted Reference now givenAsterix and "a/" not explained Accepted Now explained

Accepted

Rejected

This paragraph appears to be misplaced. Suggest re-wording

Panel Chairs are happy with text

why the information here are related only to grazing?

Because this is the Appendix where we include specific additional information

• For cattle housing system values on pm10 EF are lower for litter (=solid manure=FYM) compared to slurry. This is in contradiction with the text on page 44 line 38 (section PM), which says that it is expected to find higher pm10 emissions from litter compared to slurry. This was also found comparing English dairy cows with litter to German dairy cows in cubicles (slurry).Directly below this alinea (page 45 line 8) this is once more contradicted by the remark that cubicle houses (slurry based) give higher pm10 emissions compared to litter based systems (depending on several factors). This is in line with the presented pm10 emf. However, no reference is presented here. Where are the default pm10 values presented based on then?It is recommended to rewrite this text to present a clear line of reasoning.

In a deep litter system PM emissions can be reduced by 50% because the dust is incorporated into the bed and held there because of moist. Activity of animals will not have an effect anymore: CIGR-working group No 13 "Climatization Environmental Control in Animal Housing". 1994. Aerial environment inanimal housing. Concentrations in and emissions from farm buildings. CIGR-rapport Report Series No.94.1, CEMAGREF, Groupement de Rennes, Rennes Cedex, France, 116 pp.:

Have incorporated comment. Nicola, could you ask TNO for the full reference to CIGR 13, authors etc, it seems to have got cut off in cell H 48

Why this sentence is here and not at page 46 under Reduce emissions during and after landspreading?

Because this is where we discuss management

please give the source of table A2.1, Expert Group on Ammonia Abatement

"Emissions following (the) spreading (of) manures….."

please give the source of table A2.2, Expert Group on Ammonia Abatement

it has to be specified which values are expressed as %TAN or % total N

TAN, Table heading corrected

Table A3-1 Where is the note explenation? Reference?

The notes are redundant and have been deleted

Rejected

Accepted Now added

Accepted

Accepted All countries now full text

AcceptedNumbers in heading not explained Rejected Numbers now deleted

Accepted Made clear it is % TAN

The notes in the table (1,2,3 in the first row of the table) are not explained

The notes are redundant and have been deleted

Table A3-1 There is no text ontroducing the table. In which way can this table be used?

For NH3 as far as dairy cows and fattening pigs are considered, the figures presented in the appendices should be the same as those presented in the publication of Reidy et al, 2007. In general this seems to be the case. However, there are some deviations. Some examples: in Appendix Table A3-1 b storage a figure of 19.2 is presented for dairy cows in the Netherlands, while in the Reidy et al, 2007 publication a value of 16.3 is presented (for both models). Is the value of 19.2 wrong or is it based on another publication? in Appendix Table A3-1 grazing for the Netherlands and the UK a figure of 13.3 and 7.7 is presented for dairy cows respectively, while in the Reidy et al, 2007 publication a figure of 13.6 and 10.0 is presented. in Appendix Table A3-1 housing for the UK a figure of 33.2 is presented for fattening pigs, while in the Reidy et al, 2007 publication a figure of is presented. We recommend to present and provide all references used.

References for each national Inventory now given in the Appendix

Use full text or abbreviations of countries, not both (Netherlands = NL and not Nl)

the title of table A3.1 is misleading with repect to the EF, or it is % of TAN either % of total N available. Maybe an additional column is desirable. Please give also the corresponding references

Heading clarified, references given

Are the emission factors expressed as %TAN or total N available.

Accepted

Accepted

Accepted

Noted

Noted

Noted

Noted

Noted

Hyphenation "Fattening pigs" Rejected

Rejected

For PM10:• It seems from table A3-5 that the EF for dairy cattle are valid for dairy cattle with a weight of 500 kg. So if there is information on the mean weight of cattle categories a recalculation could be made. However, Table A3-3 and A3-5 are not in line with eachother: according to Table A3-3 calves have a weight from 50-100 kg, while in Table A3-5 they have a weight of 150kg. Beef cattle is not mentioned in Table A3-3. Since young cattle in this Table has a weight between 450 and 650 they cannot be compared with the beef cattle in Table A3-5 (weight of 350 kg).• It is unclear what transfer factor should be used. For young cattle it says in Table A3-3 0.6 till 1.2; so for the lower weight of 450 kg the lower transfer factor of 0.6 should be used. But in Table A3-5 for beef cattle with a weight of 350 kg a conversion factor of 0.7 is used!• For cattle it is unclear whether in the EF pm10 presented the time spend in the meadow is taken into account? If it is, how has this been done. And if it hasn't how should this be done?

The tables are now consistent in their use of livestock weights

please change the liveweight for calves into 50 to 300 kg

calf weight now 50-150, transfer factors scaled accordingly

Transformation factors for poultry don't make sense?

These factors are explained in the text above. The uncertainty and need for more work are acknowledged

this reviewer does not agree with the conversion factor of 1.0 for poultry. Takay et al, 1998 gives information over the conversion factors even for poultry.

"Seedorf and Hartung, unpubliched" - can´t find this reference on the reference list.

the conversion factor for fattening pigs is here 0.16 and in table A3.3 0.12. Please change it into 0.12

A lot of EF values for PM2.5 are physically impossible. RD is measured as PM5.0 and should therefore be higher then PM2.5. So, please lower the PM2.5 values for dairy cattle, beef cattle, calves and weaners

as a consequence of the remark on conversion factor of 1.0, the PM10 and PM2.5 values for laying hens and broilers should be lower

Not hyphenated anywhere else

What are information in Table A3-7, Table A3-9, Table A3 and Tbales on page 57 used for??

To provide supplementary information

Accepted Done

Accepted

Rejected

Accepted

Accepted

Rejected

Accepted

Rejected

Accepted

Units for PM are wrong not kg NH3 Editorial

Editorial

Passive composting: for the IPCC equivalent seems more appropriate "Composting - passive windrow"

What is reference for the values in this table? As a General comment I want to add that literature references are sometimes given, but not always.

Table heading now given and referred to in text.

I suggest to consider including all IPCC references right in the text

It should be considered to move some of the more scientific description in appendix to the main text. E.g. explaining why the NMVOC emission is an important environmental issue.

Have restored much of the text to the main chapter

It is nessary to explain much more in detail the difference between Tier 1 and Tier 2 in the emission factors because they are so fundamentally different. Is NH3 in Tier 1 converted to NH3 from NH3-N? Spend much more space on explaining the emission factors in Tier 2 and the difference between slurry and solid. Explain why NH3-N is used in Tier 2 compared to Tier 1.

The restoration of text now gives more explanation

It is a big confusion between NH3-N and NH3. Sometimes is NH3 reported and sometimes is NH3-N reported. Please clarify.

There is no confusion, Tier 2 calculations have to be as N, but reporting has to be NH3-N

The chapter on manure management is not very well written. There is a strong need for clear references, a better explanation of the complex system with N and ammonia. It looks like that there should be no dublicate between this guidebook and the IPCC 2006However, for clarification there could be some tables on Nex for typical animal types. Stabletype distribution from the RAINS dataset etc. to give more information on the basic situation in many countries. And reduce the number of tables because they are really unessesary in many cases.

Much of the original text has been restored to improve clarity

General comment. National agriculture inventory consistency (CLRTAP-UNFCCC): Is this new CORINAIR update methodology (Tier2) for manure management compatible with the IPCC 2006?

General: Reference to Appendix A (see Appendix A) is not consequently done looking at corresponding chapters in the appendix, please check. Also check table numbers

These cross references have been corrected. Nicola, when finished can you double-check.


General: References to tables and figures in the text are not correct, please check.


General: I miss Table with notations Editorial

Rejected

Rejected

Rejected

Rejected

Rejected

Rejected

Rejected

Rejected

Rejected

Rejected

NF3 4.D.1 is not agricultural soils. It should be 4.D Accepted DoneInconsistent citation of references. Accepted Done


Accordning to the reporting purposes Tier 1 and Tier 2 methodologies will be used. For comparision needs it will be necessary to recalculate the emission values

Don't understand what is meant by the comment. It is no more than a statement not appearing to require an answer.












Don't understand what is meant by the comment.


Don't understand what is meant by the comment.





Rejected

Accepted

RejectedEditorial comment not removed Accepted Done

Noted

Accepted

In the overview harvesting is missing Accepted Harvest mentioned in 2.1.4this appendix is missing Accepted

Emissions occur from both soil and crops! Rejected

Accepted

Noted

Add more detail about processes Rejectedadd also in the heading: for EU-27 Accepted Done

Noted Done

Accepted

Accepted

Acceptedexplain the variables Accepted Now doneA paragraph on NO emissions is missing Accepted Now insertedappendix 4, where is it? Noted Included in this version

Same remarks in generall as given for 4.B. I am not happy with th PM

In the absence of concrete suggestions for improvement..

Specify where have to be reported emissions from grazing animals. It is not clear if they have to be calculated and reported under 4B or calculated under 4B but reported under 4D. The same for manure application

Text inserted to explain and cross-reference

NFR 4D and CRF 4D codes do not include the same source categories: Application of manure to soil and production of animal manure in the meadow is not included in NFR 4D while it is included in CRF 4D.

Clear explanation given in text

Persistent Organic Pollutants - what could this e.g. include?

In the overview emission from legumes is mentioend. In the text separat NH3 emission from legumes are only included in Tier 3 approach - is that correct?

EF for legumes now restored

Text already includes crops

Reference to the chapter where they are dealt with is missing.

the PM10 emissions reported in the table = 0 are in contrast with the sentence page 23 line 33. Does the value = 0 in the table mean that the emissions are not estimated?

Have changed data using updated webdab emissions sent by Anne Wagner. NMVOC emissions are now at 4% of total so is in contrast to what it said in the previous paragraph.

The detail is found in the text below

Delete process diagram - deal with processess by pollutant not source

Good figure to give an overview, but maybe more useful to describe the different emission sources based on each substance.

Earlier text now restored as appropriate

The Emission section should be expanded and structured according to pollutant not source. Include some of the omitted text from earlier drafts


Needs much more scientific background information on emission of NO, NMVOC and PM.


and soils' should be added to title Accepted

The appendices have disappeared! Accepted

Noted Included in this version

Accepted Now deleted

Accepted yes.

Acceptednothing found about Pm Accepted Text restoredCAN not explained Accepted It is now

Noted

No longer relevant section has changed.

Possibly no longer relevant?

A paragraph on PM emissions from soil cultivation is missing

Suggest removing the sentence "The effects of Efs from grassland……"

NH3 emission from growing crops are mentioned in section 2.2.3. Are this NH3 emission short after apllication of fertiliser included in the recommended Tier 2 emission factors?

This reviewer does not understand why a double EF for grassland is needed in comparison with arable land. There are also arguments that the EF for arable land is higher due to for instance the absence of a canopy. Please give more explanation.

More explanation now given in text

In the suggested protocol, the NH3 emission factor for N fertilizer application to grassland is a factor 2 greater than for arable land. The higher emission factor for grassland is based on reviews by Van der Weerden and Jarvis (1997) and Harrison and Webb (2001). However, the study of Van der Weerden and Jarvis (1997) is a paper in which flux measurements on grasslands were carried out. In this paper, there is only one reference of a study on arable land, i.e.. a study of Black et al. (1984) in New Zealand in which losses from urea applied to grassland and arable land were compared. The paper of Harrison and Webb (2001) is a review paper. However, they only refer to the paper of Van der Weerden and Jarvis (1997). Thus, the difference in the emission factor between grassland and arable land is based on only study. By contrast, in a review Bouwman et al. (2002) of 148 research papers it was concluded that the mean NH3 emission from grassland is 20% lower than for upland crops (the balanced median showed almost no difference). This paper was not used for the guidebook.Thus, there is no firm scientific basis to use different emission factors for grasslands and arable land. The grassland area in Europe is high and therefore the underpinning of higher emission factors for grassland must be scientifically sound. Moreover, from a theoretical point of view (i.e. the effect of crop on wind speed and thereby on NH3 emission) it may be expected that there are arable cropping systems with lower emissions (i.e. when N fertilizer is applied to high crops or when N fertilizer is incorporated) and higher emissions (i.e. when N fertilizer is applied to the bare soil just after planting or seeding).

Rejected

Tier 1 method for unfertilised legumes is missing Accepted

Rejected Not Tier 1

Accepted Text amendedThe 3 in NH3 should be subscripted Accepted Done

Accepted

Rejected

Accepted

Accepted

Accepted

why the Efs of the different fertilizers which where reported in the old CORINAIR handbook are not used here? The consumption of the different fertilizers is normally available at a national level, so a better estimate is possible

Tier 1 agreed with Panel Chairs

The EF for legumes now in the text

Deafault values in the body of the text and detailed tables according to the needs as an appendix.

According to EFMA consumption for 2006/, urea is the third most used, after CAN and AN

Use chemical notation not words (e.g. for ammonia)

Section has been re-written but instances of words rather than chemical notation

The unit for NMVOC is defined as kg NMVOC/kg crop - is it kg harvest crop?? The equation (page 6, line 7-8) is mentioned use of crop area (ha??)

Reference now made to the Appendix where more information is provided.

A default emf of 2.57 kg NO per kg fertilizer-N applied is presented (reference Steinbrecher et al, 2008). It seems the wrong unit is used here. If 2.57% is meant (= 25.7 g/kg fertilizer N) it is not clear how this could be in line with the value of 0.7 % NO-N (equals 0.9 % NO/kg fertilizer = 9 g NO/kg fertilizer) presented by Stehfest and Bouwman (2006) and until now also presented in the Guidebook.The value of 0.7 is the fertilizer induced emf, but in the former Guidebook also for cultures without direct fertilizer (but with crop residues and indirect emissions as a consequence of ammonia-N deposition and N-leaching from fertilizer use) this value is recommended to be used.

Why is this value presented with 2 decimal places; this seems unrealistic concerning the high uncertainty for NO measurements.

Nicola,please change in template to 2.6

General remark on NH3: Appendices A1-A4 are not included, so information on assumptions is not available.

Appendices are now in the chapter

Rejected

Noted

More specific on NH3 (Table 3-1) Tier 1 values are no longer presented for other fertilizer types than urea. For countries where urea is not commonly used as fertilizer and where not enough data are available to use the tier 2 method also tier 1 emf for the different types of fertilizer should be available. In the former guidebook also tier 1 emf were presented for other fertilizer types (p90 table 4.1 of the Guidebook). It is recommended present tier 1 emf for the different types of fertilizer. This could be the former emission factors or new tier 1 emf derived for different fertilizer types from the tier 2 values.

In the past the urea emf was 0.15 NH3-N (equals 0.18 NH3 per kg fertilizer N applied). Based on the current proposed tier 2 method for urea emf the mean value would be 0.23 (mean of lowest and highest values for all regions and for grass and arable land: (0.11 + 0.35)/2). For region B it should be 0. 21 ((0.14 + 0.28)/2): What's the basis for 0.22?

On basis of table 3-1 in the proposed Guidelines it is unclear whether the proposed PM10 emission factor should only be applied to arable land or also to grassland (at the presentation in Dublin also hay making was mentioned; this seems to refer to grassland) and whether the application of fertilizer and pesticide use is included. It is recommended to make this clear.

Accepted

Rejected

NotedNo equation for Tier 2 methodology? Accepted Equation now restored

Noted done

The basis for the presented TSP, pm10 and pm2,5 emf (Table 3-1) should be the reference publication Vd Hoek and Hinz (2007). However, this basis cannot be found there: No basis at all presented for TSP and pm2,5 emf For pm10 emf the basis is unclear. From Table 3 in the Reference publication it seems that for pm10 the highest value (eg 4.56 kg pm10/ha for oat with no reduction applied of for redeposition of pm10 on the field) is picked to be used as a default for pm10 (4.5 in Table 3-1). However, this is not clearly explained and some questions rise if this is the case:-Why is the average value of 0.25 (for soil cultivation) in Reference Table 3 (and discussed in the text on page 18) not in line with the figures on soil cultivation presented in Table 2? Here even with wet soil conditions the total pm10 emf for soil cultivation is 5,2 kg/ha. That's a factor 20 higher!-Why is no correction term applied for rapid near source deposition?-Why are the harvesting emf in Table 3 lower (between 2.0 and 3.4 kg pm10/ha) compared to the values presented in the text on p 18 (lowest value 3.3; highest 6.9). -What's the basis for the values for cleaning and drying in Table 3

The reference publication (vd Hoek & Hinz, 2007) mentioned is not easily attainable; I had to approach one of the authors to get it. On basis of the reference it seems hay making is not included. Fertilizer use seems to be included, but it is not clear. Pesticide use is not included. It is recommended to make the references available.

A revision of the guidebook should include the newest knowledge and lead to more accurate inventory. I was surprised that the NH3 Tier1 methodology is simpler than given in the old guidebook and the emission factor is only based on use of urea.

Equations and legends: inconsistent notation, not in line with IUPAC

Rejected

Noted

Accepted

Noted

limiting fertilizer to urea only is a step backwards Accepted New Tier 1 EF developed

AcceptedUnit for particulates should be kg ha-1 a-1. Accepted Done

Accepted

RejectedTier 2 equation is missing Accepted Done

In tables 3-1 to 3-14 emission factors for NH3 are presented for the different fertilizer types. It suggested that these emission factors are all derived from Harrison & Webb (2001) and Van der Weerden and Jarvis (1997). However, the quantification of the effects of temperature and pH on the emission factors is not found in these papers.In the review paper of Bouwman et al. (2002) effects of crop type, fertilizer type, application mode, N application rate, temperature, pH, and other soil properties on NH3 emission are statistically assessed. This paper maybe a valuable source for the guidebook.Reference: Bouwman et al. (2002) Estimation of global NH3 volatilization loss from synthetic fertilizers and animal manure applied to arable lands and grasslands. Global Biogeochemical Cycles 16.

Please indicate clearly in the text that the NH3 emission = 17/14 * EF.

The NO emission is 2.57 kg NO per kg fertilizer N applied. This means that more N is lost than the N input by the fertilizer. This is quite impossible because about 50% of the N fertilizer is taken up by the crop

The EF should be g/kg - Nicola, can you please amend in the template table.

It is necessary to explain in the text how the EF for TSP, PM10 and PM2.5 are derived. If necessary the reviewer will assist.

I do not agree with the use of the urea EF as the default EF. The previous approach in the simpe methodology in the old Guidebook should be maintained. Even though the use of urea according to world fertiliser consumption statistics is currently approx 50% of total N consumed, it does not warrant its use as the default. Many counties use urea only in the spring when weather conditions are wet and cold and therefore emissions are low. Using urea as a default in such circumstances would lead to a gross over estimation of emission levels.

at which depth the soil temperature has to be measured?

Text amended to make clear it is air temperature

More explanation on how to use and apply new proposed EF is needed as done also in tier2 4B.

Accepted

Accepted

Accepted

Rejected

Acceptedabatement without note with PM concern Accepted Text restored

Activity without concern of PM, area treated, yields Rejected

section 2.1.1 where is it? Accepted

Rejected

Rejectedsoil N content: where is it used? Accepted Now deleted

Rejected

Accepted

Accepted

Accepted

Accepted

Tier 2 emissions should be calculated using the actual spring temperature. Replace equatoin and the original compact version of equation parameters. Example emission factor tables could be put into an appendix

Original compact table now restored

It is a bit confusing with so many tables showing the emission factor for Tier 2 - mineral fertiliser. Is it possible to reduce the number of tables? Instead of a table for each fertiliser type, it could be chosen to show a table from each temperature region A, B or C (t >13 C, T=6-13 C or t < 6 C).


Concise tables have been restored.

Controlling emissions has already been covered on p 4 and 5

Yes, but this explains how account may be taken in calculating emissions

Using AN instead of urea may reduce The NO emission. Definition of AN??

Abbreviation now defined at first point of mention

Text changed, no longer relevant

This section has been added

The sentence on expert judgement is not related to consisten time series, maybe more to Uncertainty

In this specific case expert judgement may be needed for a consistent time series

It is not necessary a specific chapter 4.5.1, put the sentence under line 21

This is the agreed format for each Guidebook chapter

Is the mentioned uncertainty range (+-50%) for all substances exept from NMVOC? The uncertainty range for NO and PM emission is properly much higher?

To explain the differences between the default value and tha national value, a robust bacground information and documentation for the default value is needed. Otherwise you do not support and promote the meber states to use national values.

Don't understand the point that is being made

is the temperature, which is necessary for tier 2, the air or the soil temperature?

Air temperature now specified in the text

IFA - please write the name of the organisation (maybe in chapter 5 "Glossary"). Are data from this organisation available for all member states for free??

Now given in full in the reference list

The reference list include a lot of references which is not mentioned in the main text. I prosume this list include the references from the appendices!

The references have now been sorted following the various revisions of the text.

Citation inconsistent (e.g. "and") Accepted

Accepted

Accepted

Accepted Not Tier 1

Accepted

Noted

Noted Not Tier 1No guidelines available? Rejected No page reference given

Rejected No page reference givenInconsistent citation of references. Accepted

NotedAR is not defined Accepted Done

Accepted

EF for NH3 missing from table Accepted

Citations were consistent in that two authors used "and" and more than one author was bloggs et al

For NO the reference Stehfest and Bouwman (2006) is included in the references (however misspelled as Stefest and Bowman), but not mentioned in the text.

Spelling in reference list corrected and relevant text restored

Missing Appendix A! There are links to this a couple of places. It’s hard to judge references to activity data when the appendix is missing.


By reading of the draft I really missed the appendices - especially because the main text does not content many references or scientific explanations. At my point of view more specific scientific description and explanation is needed in the main chapter. It is very important to know the scientific documentation for the default value.The guidebook should not only be useful to calculate the emission inventory,but also a guideline to find more scientific information to check the conditions are comparable with the conditions in the member states and to encourage member states to continue the work to develop more accurate inventory with national data.

That each answer max can be 255 characters is very frustrating


It is rather strange to find an NFR 4D2 here (animal production) since this source is not included in NFR4D but in NFR4B

To my knowledge is there no EU-regulation on agr. waste burning, only national legislation. This should be verfied. The text indicate that it is very easy to burn agr. crop residues and waste in Denmark. This is not the case. Burning of plant residue has been prohibited i Denmark since 1990 and may only takes place in connection with continuos cultivation of seed grass.

We know, the object was to point out that under some circumstances burning may take place

Couldn’t the link to “FAO Production Yearbook (FAO, 1991)” be updated?

Yes, up-to-date reference given

J - should there be any Efs for NH3 in this chapter?

A source published in 1991 is inadequate. Accepted

Noted

Noted

Noted

Noted

Accepted

Accepted

NotedWhere is nitrogen mentioned? NotedSouce in not in the table Accepted

Noted

Editorial

Editorial

Table 3.2 is dublicated Rejected

Yes, up-to-date reference given

Table 3-1. There should not be different units in a table, ie.kg/ kg dry matter and kg/ tonne. It will give errors in the reporting

The comment specifically refers to agricultural activity data, so reference to forest fires is irrelevant

Table 3-1. There are errors in the data. Generally contains crop residues (straw) 0,3% N or eqv. to 1.2% NOx after burning if all N is emitted as NOx. Tier 1 indicates that 24% is NOx or that at lot of inert N2 is conveted to NOx.

Because they are not needed for the calculation

If default N/C ratios are given in the IPCC guidelines why aren't they included in table 3.2 which have the same origin?

Tier 2 does not appear to provide the basis of better estimates than Tier 1. Remove Tier 2

Default data is not taken from IPCC 2006 but from IPCC GPG 2000

J - have changed this in track changes, is this the correct reference?

The source data is taken from IPCC guidebook, GPG 2000 and not from IPCC 2006. Crop/crop residues has been changed very much from GPG 2000 to IPCC 2006. See Table 11.2 i the new guidelines for data. GPG 2000 is not appropriate for European conditions.The authors of these UNCEC-guidelines should read Strehler and Stützle. The paper is about utilisable biomass and not field burning and based primarily on conditions in the praerie in the US.The figure should be used vith caution especially under European conditions where there is other crop/crop residue ratios due to high fertilisation rates.

Three years average should not be used if we want to model the emissions in short time spans. Should then forest fires be averaged over three years too? Averaging is not in line with the new IPCC guidelines

Tables should be combined. Omit superfluous information.

The value is app. the same as for Tier 1, but now it is in g/GJ not in kg/kg dry matter. See my comment page 4 line 1.

Changed back to kg/kg dry matter

Three different Units are used for the same source (wheat straw). This is also true for the other tables

Changed back to kg/kg dry matter

I can't see what this person is talking about

Noted

Noted

AcceptedIncorrect SNAP Accepted

Noted

Noted

Why should Tier 3 be aggregated at a sub-national scale to fine grid scale if the data/model is superior. It is a direct copy from IPCCC 2006 and maybe not valid for UNECE conditions.

The chapter was based on the information available

General: The chapter gives an impression of lack of agricultural knowledge and is more or less a copy and paste of the IPCC guidelines

No, I sourced the data from 2006

The mentioned cases in the text are seldom, and it is very difficult to burn rotten straw, so the importance is very limited.

My mistake, in converting from %, these EF are all x10 too big. Can you please reduce

This statement is indeed very surpising given that many pesticices are considered as POPs (where agriculture use is the only source). Please properly explain POPs in the context of this chapter

NFR category include SNAP 1006 "Use of pesticides and limestone" - but in the text "overview" is mentioned that this sector ia a "catch all" for the agricultural sector. So this NFR category covers more than SNAP 1006. In the Danish inventory this sector covers sewage sludge, which are used as fertiliser and applied on agricultural soils.

Noted

NotedThe chapter is incomplete. Noted

Accepted Doneadd ", NH3" after "CO" Accepted Done

Accepted Donesubstitute "very minor" with "minor" Accepted Doneadd ", NH3" after "CO" Accepted Done

Accepted Corrected

Accepted Correctedtoo less explanation, only reference to GHG Noted

For use of pesticides no method is provided. New methods are available in the Netherlands and the EU which could be refered to: Nie (2002), Linden et all (2006), and Linden et all (2008; in preperation)

Nie DS de (eds), 2002Emissie-evaluatie MJP-G 2000; Achtergronden en berekeningen van emissies van gewasbeschermingsmiddelen[ Emissions of plant protection products to the environment. Evaluation of the policy goals of the Long-term Crop Protection Plan ] RIVM Rapport 716601004

Linden AMA van der, Beelen P van, Berg GA van den, Boer M de, Gaag DJ van der, Groenwold JG, Huijsmans JFM, Kalf DF, Kool SAM de, Kruijne R, Merkelbach RCM, Snoo GR de, Vijftigschild RAN, Vijver MG, Wal AJ van der Evaluatie duurzame gewasbescherming 2006: milieu[Midterm evaluation of the plant protection policy of the Netherlands; environment ]RIVM rapport 607016001

In preperatationLinden AMA van der, Groenwold JG, Kruijne R, Luttik R, Merkelbach RCMDutch Environmental Indicator for plant protection products, version 2Input, calculation and aggregation proceduresRIVM Report 607600002/2008

Chapter should be supplemented: now in contains headings, one table without EF, one literature source.

Add: "Also PM emissions from waste handling are generated but no estimate of emission factors is available."

Add: "Also PM emissions from waste handling are generated but no estimate of emission factors is available."

An incomplete and unexplained algorithm is given for emissions from pulp and paper only?

why process emissions from pulp and paper in this connection ?

Accepted Done

Accepted Done

Noted

Accepted Added to references

Accepted

Noted

The chapter is incomplete. See examples below Noted

Accepted

Accepted

Noted

Noted

substitute "Emissions are considered to be negligible in most cases." With "Small quantity of NMVOC and nitrate compounds are emitted. For NMVOC US EPA evaluate that 98,7% of landfill gas is methane and 1,3% other VOCs such as perchloroethylene, pentane buthane, etc. (EPA, 1990). Also PM emissions from waste handling are generated but no estimate of emission factors is available."

change position of NH3, TSP, PM10 and PM2,5 in "not estimated" section

no emission factors estimated or applicable. Not even for NMVOC and CO ...I miss some support.

NMVOC estimated now from UK inventory

US EPA (1990), Air Emissions Species Manual, Volume I; Volatile Organic Compounds Species profiles, Second Edition, EPA-4502-90-001a, United States Environmental Protection Agency, Office of Air Quality Planning and Standards, January 1990

An estimate of NMVOC emissions from landfills was made using an emission factor of 0.01 t NMVOC/ t methane produced which is equivalent to 5.65g NMVOC/ m3 landfill gas (UK inventory, 2004).

EF used as Tier 1 default EF

EF should be defined depending on the kind of waste deposited

Chapter should be supplemented: now it contains 2 tables, including one table with one emission factor (for NH3) and list of References with 2 sources.


Chapter discussed in meeting with C&I Expert Panel Leader. Latrines moved to Tier 2. Tier 1 EF for NMVOC estimated from one of the suggested papers.

An aspect of importance not described in this chapter is the importance of industrial effluents to the sewer system and i.e.contribution to the centralised WWTPs and i.e. NMVOC emissions.

NMVOC from WWTP mentioned

NMVOC emissions may occur during sewage collection and are very dependent upon treatment processes at different stages at the WWTPs (see refs row23-35))

Some text about this issue has been added

The chapter states that it focusses on biological treatment plants, however, the text deals in no detail with biological processes and dephosphorization is a chemical process

Text taken from former GB; adapted to fit better in revised chapter

The chapter states that 'NMVOC and NH3 is of minor and only of local importance' as compared to landfills where these emission are referred to as 'emitted in smal quantities'.

Noted

Noted

Accepted

Accepted

Accepted

Noted

Accepted

Noted

Noted

From the Inventory of U.S. Greenhouse Gas Emissions, however, it may be observed that the emission of NMVOC from wastwater treatment processes are a factor two of the estimated emisions from landfills; ranging from 57 to 68 Gg/yr in 1990 and 2001.

Information on NMVOC added; see other comments

The text on latrines (http://reports.eea.europa.eu/EMEPCORINAIR4/en/B9107vs2.1.pdf) are overpresented compared to section 2.1 considering the relevance of the two activities

change position of NH3, and NMVOC in "not estimated" section

Erase NH3 EF and related information and change position of NH3 and NMVOC in "not estimated" section

Done following discussions with C&I EP. A Tier 1 for NMVOC has also been derived

I don't think the similarity of latrines with animals was correct and then latrines are not equal to "waste water treatment plants". Substitute "The default emission factor for ammonia from waste water handling is provided in Table 3-1. It is equal to the estimated emission factor for ammonia from latrines, which has been determined from the similarity between latrines and open storage of animal manure in lagoons or ponds (Guidebook, 2006)." with "Also NH3 and NMVOC emissions from waste water handling are generated but no estimate of emission factors is available."

Done following discussions with C&I EP. A Tier 1 for NMVOC has also been derived

Air emissions of POPs as well as NMVOCs, CO and ammonia are occurring eventhough maybe at insignificant levels, still not very well investigated. However some scientific studies do adress such emissions.

Some info added to chapter; see earlier comments

Examples from the scientific literature documenting such emissions of aromatic and halogenated compounds from urban WWTPs are Sree et al, 2000


Oskouie,A.K., Lordi, D.T., Granato, T.C. and Kollia, L. (2008). Plant-specific correlations to predict the total VOC emissions from wastewater treatment plants.Atmospheric Environment, In Press, Corrected Proof, Available online 13 February 2008.


Baillod, C., Crittenden, J.C., Mihelic, R., Rogers, T.N., Grady, C.P.L., 1990. Critical evaluation of the state of technologies for predicting the transport and fate of toxic compounds in wastewater facilities. WPCF research Foundation Project 90-1. CAAA. U.S. EPA, 1990.


Noted

Noted

Noted

Noted

Noted

Noted

Noted

Noted

Noted

Noted

Noted

Corsi, R.L., Card, T.R., 1991. Estimation of VOC emissions using the Baste model. Environmental Progress 10 (4), 290.


Dobbs, R.A., Wang, L., Govind, R., 1989. Sorption of toxic organic compounds on wastewater solids: correlation with fundamental properties. Environmental Science and Technology 23 (9), 1092.


Easter et al.. Odor and air emissions control using biotechnology for both collection and wastewater treatment systems. Chemical Engineering Journal, Volume 113, Issues 2-3, 20 October 2005, Pages 93-104


Escalasa et al. Time and space patterns of volatile organic compounds in a sewage treatment plant.Water Research 37 (2003) 3913-3920


In urban areas, VOC emissions from WWTPs may be a significant fraction of the total hydrocarbon emissions


whereas the corresponding NMVOC emissions from whole Austria were reported as 5% (25000 t yr) of the total anthropogenic NMVOC emissions.


more focus should be given to Urban wastewater treatment plants and separate industrial wastewater treatment plants.(see references as commnt to list of reference below, page 6 line 8)


According to the IPPC guidelines such releases into the domestic sewer system should be included in the 'Waste water treatment in residential/commercial sectors'.


Air emissions of NMVOC prevails in pre-treatment and primary clarifiers, whereas biodegradation and sorption compete in aerobic biological reactors... Air emission prevails in secondary clarifiers (e.g. Escalas et al. 2003, Water Research 37, 3913–3920).


Most plants have highly techological developed primary, secodary and tertiary treatment processes including mechanical, chemical, biological anaerocic and aerobic processes and emission may occur at several stages of treatment.


Reference for inspiration: P. Tata, J. Witherspoon and C. Lue-Hing, Editors, VOC Emissions from Wastewater Treatment Plants: Characterization, Control and Compliance, Lewis Publishers, Boca Raton, USA (2003) ISBN 1-56676-820-9, p. 415


Noted

Noted

Noted

Noted

Noted

Noted

Noted

Noted

Accepted Corrected

BOD characterisation , which is the main source for NMVOC emission, is totally missing in analogy to the missing precess descriptions which are potential for NVVOC emissions as well as POPs.


Reference for statements in row 26 to 28: Atasoy et al. (2004).The estimation of NMVOC emissions from an urban-scale wastewater treatment plant. Water Research,Volume 38, 3265-3274


latrines are not relevant at all for many European countries

NMHC or non-methane VOC may occur for controlled as well as uncontrolled aeration processes.

Sree, U., Bauer, H., Fuerhacker, M., Ellinger, R., Schmidt, H. and Puxbaum, H. (2000). Hydrocarbons Emissions From A Municipalwastewater Treatment Pilot Plant In Vienna. Water, Air, & Soil Polution, 124, 177-186


Schmid, ´H., Bauer, H., Ellinger, R., Fuerhacker, M., Sree, U. and Puxbaum, H. (2001). Emissions of NO, TVOC, CO2, and aerosols from a pilot-scale wastewater treatment plant with intermittent aeration Atmospheric Environment, 35, 1697-1702.


Wua, B.-Z., Fenga, T.-Z., Sreea,U., Chiuc, K.-H. and Loa, J.-G. (2006). Sampling and analysis of volatile organics emitted from wastewater treatment plant and drain system of an industrial science park. Analytica Chimica Acta , 576, 100-111


For example, NMVOC contribution from WWTPs in Vienna, as an urban area, was estimated to be around 7.5% of the total anthropogenic NMVOC emissions …


Glossary, AR production - the AR for the lime production?

Tables 3-1– 3-6: HCB and PCB emission factors are the same (in spite of the abatement); NOx, CO and SOx EF are not harmonized, as well as TSP. For example: TSP EF in the Table 3-1 (Tier 1) is the same with EF in the tables 3-4, 3-5 and 3-6 (Tier 2, different abatement, including BAT).


Differences in abatement; literature references are not complete. This causes differences. How else to deal with this???

Table 3-1. According to the UNEP Toolkit PCDD/F EF value of 0,525 mg for the high control equipment efficiency


Table 3-2. PCCD/F EF is 40 mg I-TEQ/Mg waste. There is no contrudictions in values of these two tables?


AcceptedError of table 3-9 Accepted Corrected

Accepted Corrected

Figure 2-1: scheme is too simplified. Rejected

Accepted Done

Noted

Table 4-1: PCDD/F emission factor – error in units. Accepted Corrected

Figure 2-1: scheme is too simplified. Rejected

Abetment factors are derived from EPA not controlled/controlled EFs. These abetments cannot be used for Table 3-6 EFs, related to EU BAT technologies . Also dioxins abatement table is not present in the text and is related to unabated EF different from Table 3-6 one. Please introduce unabated EFs or all the pollutants or erase the entire chapter!

Corrected; abatement factors only applicable to EPA factors in Tables 3-2 and 3-3!

Table 4-1. It is correct PCDD/F emission factor unit - mg/Nm3?

Are emissions from flared landfil gas (the part of the gas not used for energy purposes) missing? Norway reports these emissions under 6C


Industrial waste is extremely heterogenous group with very different levels of emissions from their combustion. But in the chapter industrial waste considered without differentiation even at Tier 2 level. Chapter should be supplemented.


No new info available, therefore addition of more Tier 2 methods could not be done. Issue has been discussed with C&I EP.

Change "Much of the information on pollutant emissions has been reported as emission concentrations rather than emission factors. These have been converted using a specific flue gas volume of 5000 m3 at 11% O2 per tonne of waste. " with "Emission factors for heavy metals are assumed to be the same as for clinical waste incineration."

Table 3-1: EF for TSP and PM seem very low; EF for Pb, Hg and Zn are higher than EF for TSP.


Data are from Table 8.2.2 of old GB and are assumed to be the same as for clinical waste incineration Use the same EFs of Tier 1 in Table 3.1 Replace the chapter with "Technology specific emission factors are not available for this source category. "


Table 3-2 (Uncontrolled): PCDD/F, HCB, PCB and PAH emission factors are the same as in the Table 3-1 (Tier 1 – typical situation) but TSP and HM emission factors are more high. EF for PCDD/F – need to be updated (UNEP Chemicals Standartized Toolkit, 2005 might be for instance used).


Table 3-3: TSP and PM emission factors seem to be overestimated.

Rejected

NO TABLE ? Rejected

Table 4-1: PCDD/F emission factor – error in units. Accepted Corrected

Noted

Table 3-1: emission factors need to be updated Noted

Accepted

Noted

Accepted Corrected

Accepted Corrected

Noted

Noted

Noted

Noted

Rejected

Tables 3-1, 3-2 should be updated, for instance EF for PCDD/F from the UNEP Chemicals Standartized Toolkit (2005).

Tables 3-1 (Tier 1) and 3-2 (Tier 2) were not harmonized: EF for PCDD/F, HCB, PCB and PAH compounds are the same while EF for TSP and HM are more high in Tier 2. If Tier 2 factors are the same as Tier 1 what are the reasons to include in the chapter choice of methods procedure?


Tables 3-4 – 3-16 which are shown as Tier 3 tables can be hardly considered as Tier 3: they are out-of date (main reference - EPA 1995) and do not provide emission factors for complete list of installations and types of wastes.


There are still only default emission factors for priority metals. No emission factors for other metals are included.

Waste incineration could potentionally be a large emission source of the other metals therefore guidance on these metals should be included.


It should be possible to provide some rough guidance on the particle size distribution, so that PM10 and PM2.5 can be estimated.

Chapter should be supplemented: it include only Open burning of agricultural wastes, while other types of open burning are also important source of emission especially POPs.

Link to more detailed methods of AP42 inserted

Tables 3-1– 3-10: error in unit for PM10. Emission factors for PCDD/F need to be updated.

Table 3-4: title of the table do not coincide with the content (Orchard crops – in the title; Leaf Burning – in the table).

Chapter should be supplemented: now there are 4 tables with one EF for NH3. No references.

Figure 2-1: Process scheme consists of one box and three arrows and do not provide any information about the processes.


Table 3-1 (Tier 1) and Table 3-3 include the same NH3 EF for compost production.

Table 3-2 (Tier 1) and Table 3-4 (Tier 2) include the same NH3 EF for sludge spreading.

lots of EF seem to be missing, for ex. NMVOC or total PAH

original references should be named (not Guidebook 2006)

Accepted Done

Noted

NotedNo emission factors for PM, HM and POPs. Noted

Data are the same as Tier 1. Replace the chapter with "Technology specific emission factors are not available for this source category. "

Are emissions from car and house fires missing? See EF_Comments

Are emissions from tobacco missing? See EF_Comments

Comments

Inlude HCB and other POPs

Covered by next comment

The contractors and indeed many of the individuals in the project team have many years experience in support of inventories and combustion emissions. If this is an unsupported comment it is neither constructive nor factual.

The factors represent a wide range of technologies, for most pollutants there will be varying degrees of abatement and in some instances the factors could represent unabated emission. In terms of an emission inventory the key issue is whether they can represent a national emission. At Tier 1 and Tier 2 inclusion of factors for specific abatement technologies is achievable but would require many tables and is considered inappropriate.

Note that 1B2a.iv covers fugitive releases from refining, venting and flaring from oil-refining are 1B2c & d respectively.

Text and indeed emission factors from the previous chapter could be included as an appendix but including the whole chapter is not appropriate. Where the expert panel feels that more text would be helpful then I propose to ask them to determine what should be included (as an appendix).

I accept that more detail can be provided but it is intended as general information only - we can go into detail but there is information elsewhere such as the LCP BREF.

Firetube boilers more typically at sizes lower than 20 MWth.

text in prentheses modified to state 'mainly relevant to solid and liquid fuels'. Gaseous fuels can contain nitrogen compounds but natural gas contains nitrogen as N2 other nitrogen compounds are only present at trace levels (compared to biomass, coal and fuel oil).

Some emission factors are high but whether they are a large emitter depends on overall technology mix. This section is about formation of Nox in general rather than for different technologies).

As taken from the previous guidebook. Please note commentary elsewhere on mercury in gas.

The text was in the original guidebook but may have been contrary to the guidebook EF which was omitted in compilation. Guidebook factor has been restored.

Much of the detail in the current chapter is not relevant to someone preparing a national inventory. The BREF provides relevant data.

As stated in the introduction to 3.3 details are in the BREF. Inclusion of SO2, NOX but not PM is not consistent but it reflects the original guidebook where PM controls were considered, as commented, with heavy metals controls.

Abatement efficiencies are indicative only - efficiencies are dependent on a range of factors and emission reductions, particulary for retrofit applications, are very variable.

Generic text, note that it is not just about emission data; more detailed approaches may also need to address fuel use.

Yes, 'all' is unlikely and there will always be new data to consider.


European PCDD/F data ?

Guidebook factor missed, also data in Ap-42.

Asked for European-based data.

The technology used will differ for each country and will change over time. A representative factor for all users is not achievable, these factors provide a first or second level estimating tool for the sector.


Note this also applies to 'other liquid fuels' which includes refinery gas - these are NAPFUE classifications.

An oversight, technology identified but failed to include table

We accept that combustion emissions can depend on combustion unit size but, there has to be a degree of simplification otherwise the number of tables becomes unmanageable.

Dry and wet bottom boiler classifications are as used in current guidebook but it is recognised that these are not the only technology distinctions

See previous comment

Abatement efficiencies are dependent on a range of factors and reductions, particulary for retrofit applications are very variable.

These dsitinctions are not in current guidebook but are in AP-42 and are reasonable distinctions for unabated plant (with downfiring as a potential additional technology). However, these technologies are less relevant for new and abated plant.

The factors do not represent a specific level of emission control, where countries have knowledge of abatement levels then this knowledge should be used to develop appropriate country-specific emission factors.

Some inconsistencies - incorrect mapping of some factors in database ?

Some inconsistencies - incorrect mapping of some factors in database ?

Where Tier 2 and Tier 1 defaults are the same then we don't have data to provide a Tier 2 factor and have included Tier 1

Where there no data to provide a Tier 2 factor, we have included Tier 1 data

It was not the intent

Have taken out this table

Is this correct?

The work by Concawe is referenced and tables have been revisited to incorporate relevant data

Note that Concawe references are generally to USEPA

see other comments on Concawe data

Is this right - perhaps one for Justin/Tinus

see other related comments



The terminology used is not ideal but combustion unit would not be appropriate either (it could be used to describe engines, gas turbines, conceivably flares). Suggest process furnace may be more appropriate.

In general this is correct but there are significant ranges which indicate that some abatement measures are present.



Not sure what table this refers to but tables revised

We accept that the emission is dependent on fuel composition but combustion and lubricants are also relevant. We also accept that USEPA VOC figure also excludes ethane however, in the absence of other data, it provides a reasonable value for nmVOC. An alternative would be to apply the the USEPA TOC figure. At least one member state applies an emission limit for formaldehyde but inventory is about total nmVOC not individual components.

Title modified but, we have no data for other activities

The completeness or othewise of facility emission reporting is a key issue but is not unique to refineries. Further guidance is provided in cross-cutting chapters.

Can the expert panel provide any further input on coke manufacture outside iron & steel plant or other manufactured solid fuel processes

See row 57

see above

Calculated with reference to USEPA Method 19

Add a footnote ?

I think this may be a timing issue, FOD may have been completed shortly before document finalised

Where the references are for AP42, the dates refer to the chapter dates rather than the current edition.

Done

See earlier notes re engines

Not at Tier 1 but is needed at Tier 2

Not clear what this comment is about

2B

Yes (for combustion)

See 133

Note that emission is not generally associated with combustion processes in 1A2 and may be assigned to the process emission

Where we have broadly similar fuels we have provided the same emission factors rather than provide no factors

Yes, this is correct but the Tier 1 and Tier 2 default factors are for application to a wide range of technologies with aggregated activity data. The compexity of individual furnace fuel mix is more consistent with a Tier 3 approach.

see above

see above

Actually table revised

See 169

The table titles were incorrect, these factors are for heating/reheating

These are assigned through NFR 2 emission guidance

See earlier

Yes, this would be impossible.

Emissions should not be included in 1A1

Use tier 1

However note that for cement the Tier 2 tables will include all emissions except PM

Not possible according to editorial requirements. However such data can be found in BREF documents

Petcoke is a fuel but by no means the major fuel in all countries

In general PCDD/F emissions are not increased by use of waste in cement kilns (if applying BAT)

In the absence of facility-specific data or specific fuels then use Tier 1

Yes, other liquid fuel includes gas oil

metals should be assigned to process.

At Tier 1 we have brought together by main fuel classifications

Text and tables now modified to reflect discussion with EP leader

Suggest applying same factors as for coal in cement kilns

see above

update

include especially the last suggestion

rejected

could be improved

There are some errors: e.g. we should divide emissions by LTO and Cruise not by take off and landing; it could be improved

In my view default EF should refer only to IFR flight

see the comment above (row 38)



I agree with the comment. In Tier 2 it is not sufficient clear how to estimate cruise emissions (domestic and international): the suggested methodology could be reported with a complete example (taking in account an average domestic and international distance for the country).In my view data needed for the Tier 2 are n° of flight by type of aircraft and by domestic/international; total fuel consumption (if possible domestic and international separately); average national distances for domestic and international flights. So the first step should be to estimate LTO fuel consumption for domestic and international, and cruise fc for domestic on the basis of tables 3.11, 3.12 and 3.15. International cruise fuel consumption should be calculated anyway by difference with the total FC in the energy balance. Step 3 probably is the first step, step 4 the second one and step 1 and step 2 are a results of the method. In my knowledge no countries have information n fuel consumption distinguished by domestic and international; also Tier 3 methodologies, as Pagoda model by EUROCONTROL, estimated the fuel consumption on the basis of the distance of the flights because FC on single trip are not collected because of confidentiality.

I disagree with the comment in general; if the IPCC 2006 guidelines report new emission factors before not available in my view they should be used

It is correct, emission from military mobile, including aviation, are reported in 1A5B with exception for those referring to multilateral operation that shoul be reported in memo items

It could be useful to describe the Tier 2

Done

Equation is correct as it is

will clarify

will clarify

will check and clarify units need correcting

will check and clarify units need correctingwill clarify

Will be clarified

will correct

will correct

will correct

Need to add EFs where appropriateNeed to add EFs where appropriate

will check and clarify units need correcting and linking to EF tables.



Will incorporate where appropriate to the tier methodology or reference given to detailed datasets.



Units will be added.

Will clarify

Will clarifyWill add

Will clarifyWill clarify






Will clarifyWill add

Will add

Will add

Will clarify

Will review

Will update

Will update


Will be redrafted to fit with Guidebook and reference made to IPCC 2006

Will update

Will update

Will update

Will incorporate where appropriate

Can't find any later data on ship fleet make up.

clarified

Will include originals

Will update

Will update

Will update

Will update

Need clarifying





Will clarify reference




Will include reference




Will clarify

Will clarify

Will clarify

Will clarify








Will revise

Will revise

Will revise


will be deleted




Will incorporate

Will incorporate

Will incorporate






Tables will be revised and clarified

References will be added

will incorporate

Will be clarified

Will be clarified

Will be clarified

Will be clarified

As applied to 1A4a/c


Diagram is generic

Some removal of detail, no additional CHP detail

Agreed at Overview and Table 1-1, subsequent use modified to align with NFR terminology

Accepted but, tried to retain much of the original text (B216) as it has only recently been revised. The technologies are not all NFR sector specific.

Not sure these comments are being held together that I can follow the references made.

HCB emissions very uncertain

These technology descriptions are largely taken from the existing chapter

accepted however waterheaters are also devices which heat water ! EuP ecodesign Lots 1 and 2 are distinguishable on this basis.

Tier 1 is based on fuel not technology

several coments here, tables reviewed

The factors for some of these activities are highly uncertain, this is partly due to the movement away from technology to fuel categories but also reflects variability in source data.

Some more obvious splitting included.

Additional data in appendix

many tables have been revised#

To be improved

To be revised

The factors were in the appendix of B216 of the 2006/7 guidebook. If they can help a country elaborate the emissions better and the country has resources to do this, then why not use them ?

The BLT test reports are type-approval tests for use in Austria and other countries.

Winiwarter reference

Can we do as a x-reference

BAT figures ?

This is a fair point but we have tried to avoid applying different sizes as the number of tables will become unmanageable for the guidance.

??

1A2 ?

will clarify

Will include summary table of limits

will clarify

These are described in 2.2.

Table labelling is miss leading and will be corrected.

Will be clarified in a footnote

will clarify

will clarify

Will add

Will update

Will update

Will update

Will elaborate

Will update

Table will be revised

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

Will update

We'll follow the reporting template on this issue.



Relates to Tier 3 methodology comment

We don't have any information for this… consult with EP

Not true. Gas distribution must be in this chapter.

Not sure what is meant here.

Not sure what is meant here.

For full reference see later comment

Still to do if there is time

I suppose this comment is applicable to chapter 1.B.2.a.vi. Reference added therein; not here since it is not referred to

These values could indeed be useful for the Guidebook, but we don't have them and cannot find easily.



A reference for this…?



Not sure. Were listed under 050501 in former Guidebook


This chapter has been drafted in close cooperation with Concawe.

Explanation is not too late - this is the section for activity data.

Don't know what this is applicable to

Why?

Tier 1 & Tier 2 must be as complete as possible

What table is this comment about?

Cannot find text at indicated location. Furthermore, this text has been added by Concawe themselves.

In this chapter! What is the question here?

Tier 2 EFs from EECCA now inserted

We think that this is probably not the majority. And since we cannot split we chose to report these in the combustion chapter

Emission expected in reporting template from source category 1.A.2.f.i, therefore emission factor in that chapter (either factor itself or a Not Estimated). Will be corrected in final draft

PM is in process chapter (2.A.1), emission factors of all other pollutants are in 1.A.2. Description describes complete cement production process, since we want to be complete in this respect.

Don't know what is meant by "misunderstood". In which way?

No idea why this should be removed. I don't see any reason to do so.

Not Estimated / Not Applicable are filled using the reporting template. There is NOx and SOx from process, but it has not been estimated here and included in the combustion SOx in chapter 1.A.2.f.i.

EECCA data now inserted as Tier 2

We think most HMs from cement are from the fuels rather than the raw meal and therefore they are accounted for in 1A2. Everything is emitted together from the kiln (process & combustion), but we have to make a split somewhere.

Needed for electronic emission factor database, EFs not the same anymore in Final Draft

Indication I.E. will not be presented anymore in the final draft

Chapter mainly important for GHGs, as indicated

Probably also a significant contribution is from the fuels. The question is which one is the most significant, since a split is not possible. We think the majority is from combustion.

Ammonia emissions treated in combustion chapter 1A2fi (according to reporting template); should not be a NA

These are accounted for in the combustion chapter, as indicated. See chapter 1.A.2.

We anticipate that dust is mainly from the processes and HMs are mainly from the fuel combustion. Could be updated, but only if HMs are in majority from the process (which we do not think is true).

Error made when copying value - will be correctedWhy?

To be added

Must be chapter 3.C, not 1.A.2.f.i (I think this is also the point made in the comment, although I'm not sure?)

Good suggestion, unfortunately I could not easily find a conversion factor.

Decision tree updated to include product use besides production. Don't know what else to change.

Dates back to 1995 while old Guidebook uses 1994. All EFs the same, so I think this is not newer.



This issue has been identified as a problem from the beginning of the project. Needs to be discussed, I think!

Table 3-2 does not exist. Comment not applicable here.

Source = Expert judgement

We have to stick to the NFR structure, which does not identify glass as a separate source category.

We don't have any better information. If provided, we would like to include this.




All consistent tables will be produced for the final draft

True, but no figures available to quantify this

NMVOC EFs from combustion and treated in chapter 1.A.2

Would be a nice report to use in a next version, but since not published yet it will be difficult to incorporate this now. Many emission factors have been revised following other comments however.

I'm not sure what is meant: Since all references have a year, I think the person commenting refers to which year the EFs are valid for. Our Tier 2 EFs do in principle not have a reference year, because they are technology-based.We don't use a class I-III for HMs in the Guidebook.

True, but if these more accurate EFs are not available they cannot be used.

Probably this is indeed not correct, but unfortunatly complete information is not available from literature. We have to deal with what we have.

no suggestion for

SNAP 040622 is Explosives manufacturing

Complete information is not available from literature. We have to deal with what we have.

Sentence needs to be added to the preceding section saying that all tables have been made complete by adding Tier 1 EFs where Tier 2 EFs for that specific technology were not available

The 040501 and 040502 were separate chapters in old guidebook, but indeed referring tot the same naftacracking process - this is mentioned in the text also .. Question on the expert panel to combine the both SNAPS to one paragraph?

060306 is on pharmaceutical products, action asked from task force on SNAP

Suggested is BAT associated emission levels.

BREF LVIC AAF 2007: The tail gas composition depends on the applied process conditions. Table 3.3 gives an overview of tail gas properties .. Used 200 - 4000 Nm3 / ton and 200 - 4000 mg/Nm3 .. Results in 620 - 13.200 g / ton - Guidebook values: 10.000 with lower upper 5000 and 15000

Adipic acid production is relevant for emissions of greenhouse gasses (N2O), but not considered significant or a key source for other air emissions included in the protocols.

The source is indeed Table 7.10 in BREF LVIC SAO "Emission sources and data on typical dust emissions from the Austrian plant at different process stages "- because we need a Tier 1 we made a aggregated EF from the different pprocess stages

The Guidebook has to give Tier 1 EF's for all NFR's… including this one. This table therefore includes Tier 1 emission factors for the NFR Other chemical industry, generated with Eurostat and EPER data – shoud be used with care, and is a very rough estimate! ..

The Guidebook has to give Tier 1 EF's for all NFR's… including this one. This table therefore includes Tier 1 emission factors for the NFR Other chemical industry, generated with Eurostat and EPER data – shoud be used with care, and is a very rough estimate! ..

There is already a separate BAT reference in the chapter on BAT for Ammonia

SNAP paragraph on Silicium production removed

the both processes, steam reforming and partial oxidation are controlled processes

This seems a left over from the former version of the Guidebook .. Will be corrected, we now assume a lower value of 2000

This seems a left over from the former version of the Guidebook .. Will be correctedit is actually the other way round, 5000 refers to US plants we will use a value in the range for the European plants - 500

see comment on TIER 1 EF comment .. Not a key source

TSP and NH3: compiled new EF's from the different unit operations listed in EPA42, considering also new developments in taking upper and lower limits

please provide us with a suitable EF

Note:Used the EPA AP42 (1996) reference instead , same values old chapter B443 guidebook states: A specific methodology for these activities has not been prepared because the contribution to total national emissions is thought to be currently insignificant, i.e. less than 1% of national emissions of any pollutant (2006)reference to: COV from Economopoulos -> not clear!

old chapter B443 guidebook states: A specific methodology for these activities has not been prepared because the contribution to total national emissions is thought to be currently insignificant, i.e. less than 1% of national emissions of any pollutant (2006)

We received a TIER 1 EF from ESPREME - chlorine-Tier 1 (not in FOD) we will use

mercury cell: compiled an EF from the current emission levels cell room ventilation 0.17 - 1.93, proces exhaust 0.01 - 1.0 g , Caustic soda after the decomposer: 0.009 - 0.05 and storage: 2.6 -> 3: (1 to 6), these correspond with the ESPREME value, which is included in the revision

Where to find this list?

BREF LVOC: Suitablefeedstocks for olefins production range from light gases (e.g. ethane and LPGs) to the refineryliquid products (naphtha, gas-oil). Heavier feedstocks generally give a higher proportion of coproducts(propylene, butadiene, benzene) and need larger / more complex plants. A large proportion of Europe’s propylene demand (and all of the butadiene demand) can besatisfied by the steam cracking of naphtha and gas-oil. The balance of propylene demand isessentially supplied from extraction of propylene from refinery Fluidised Catalytic Cracker offgasand imports. There is one PDH (propane dehydrogenation) plant in Europe, but it is onlyeconomic when propane prices are low. A similar process for butadiene production (by thedehydrogenation of n-butane) is also available but is not used in Europe where there is generallya surplus of butadiene from steam cracking.

Correct, use the EF's from the BREF, Table 7.5 summarises the principle pollutants and their sources, together with the range of emission levels met in most European crackers.

Eliminated the other table for proylene .. We do not expect however that the EF of 0.6 underestimates the emissions .. Most European plants are having lower emissions

Information from the BREF LVOC were Ethylene is an illustrative process

Suggested is BAT associated emission and consumption levels. Current emissions are:BREF Polymers, Table 3.9: Emission and consumption data of LDPE plants: LDPE European Average (benchmark 1999 average) 2400 g/tVOC to air emissions in grams per tonne of product (g/t). VOC includes all hydrocarbon and other organic compounds including fugitive emissions . We will include this information in the BAT chapter

Suggested is BAT associated emission and consumption levels. Current emissions are:BREF Polymers, Table 3.11: Emission and consumption data of HDPE plantsHDPE European Average (benchmark 1999 average) 2300 g/tVOC to air emissions in grams per tonne of product (g/t). VOC includes all hydrocarbon and other organic compounds including fugitive emissions. We will include this information in the BAT chapter

Suggested is BAT associated emission levels. There is also an split view on BAT which resuts in higher BAT values. We will include this information in the BAT chapter

Suggested is BAT associated emission levels. There is also an split view on BAT which resuts in higher BAT values. We will include this information in the BAT chapter

BREF states that 85g/t is only for the top50% facilities ..European average is 120 g/t .. EF will therefore not be adapted, reference will be made to the BREF (Table 4.12: Emission and consumption data per tonne of product of HIPS plants) in stead of Guidebook 2006

BREF states that 85g/t is only for the top50% facilities ..European average is 120 g/t .. EF will therefore not be adapted, reference will be made to the BREF (Table 4.10: Emission and consumption data per tonne of product from GPPS plants) in stead of Guidebook 2006

what information to use then?

plakken in excel

. For more information see also the BREF document on Large Volume Organic Chemicals where the production of acrylonitrile is described as one of the illustrative processes

These should indeed be consistent .. Propose to adapt the approach on neglible emissions with production comparde to product use

what units are most suitable?

Suggested is BAT associated emission and consumption levels. Current emissions are:BREF Polymers, Table 3.9: Emission and consumption data of LDPE plants: LDPE European Average (benchmark 1999 average) 2400 g/tVOC to air emissions in grams per tonne of product (g/t). VOC includes all hydrocarbon and other organic compounds including fugitive emissions . We will include this information in the BAT chapter

BREF states that 85g/t is only for the top50% facilities ..European average is 120 g/t .. EF will therefore not be adapted, reference will be made to the BREF (Table 4.10: Emission and consumption data per tonne of product from GPPS plants) in stead of Guidebook 2006

new table in BAT chapter, referring to table Table 7.3: Emission and consumption data from ESBR plants (per tonne of product)

Sentence on this to be added

Sentence on this to be added

A Tier 1 is required for every NFR. It may be useful however to stress in the text that the Tier 1 can only be used for an Integrated Iron and Steel facility with all the subfacilities on site.

Comment not understood; suggested to list all EFs in g/kg or in another unit?



Tier system here a bit different: iron/steel industry seperated in 3: sinter/pellets, pig iron and steel for Tier 2. Different technologies identified within each of these. Problem with inconsistent values appears because of different references. Try to avoid this as much as possible, but will not be complete unavoidable!



Why?

ESPREME data to be checked

ESPREME data to be checked

Majority is still combustion, I suppose. Since we have always put NOx/SOx/CO/etc. in combustion when combustion and process must be separated, I think it's better to keep this approach here as well.

Not anymore

Split has been agreed with Expert Panel. Some of the pollutants are process- and combustion-related and it's not possible to split. A choice must be made where to allocate these emissions, which has been done.

Unfortunately BREF does not provide generic factors for Tier 1, only for different ferroalloys and subprocesses within the ferroalloy production. Furthermore, the overview in the BREF is not complete. Therefore difficult to use in the Guidebook and not included.Also not included in Tier 2 because of non-completeness, but references made.

NFR does not distinguish Primary/Secondary, so at Tier 1 level we cannot separate them

Primary and secondary copper production are process with contact, therefore we should treat these similarly to cement and lime production.

Should be in combustion cahpter 1.A.2.f.i.

Same as for copper production: process with contact

Comment is true, but not too much can be done at this stage. EFs from different references have been combined and this causes inconsistencies (most obvious between PM and HMs). However we cannot just simply scale down the PM with HM, that is too simple. I think however that this is an issue that needs further discussion in the future.

Combining information from different references and completing Tier 2 tables with typical EFs causes this problem. There is no simple way to solve this however.







Comment refers to wrong chapter. Correction made in zinc chapter (2.C.5.d)

Same as for copper production: process with contact

No more data available!

Look at this issue (same as in copper/lead)

CHECK ESPREME DATA

Check for Zn EF; other comments noted




Should be in combustion cahpter 1.A.2.f.i.

No info on this available.

No info on this available.

Fuel combustion in 1A2 as indicated multiple times in chapter

We use the reporting template as the master to check whether emission are expected or not.

Chapter needs to be discussed. Where to collect all this information?If no information is found, I suggest to move all relevant pollutants to NE and delete the emission factors, since they're all wrong!

Check this and add some text to make this clear.

Chapter needs to be discussed. Where to collect all this information?If no new information is found, I propose to delete all obviously wrong EFs and move to NE

I do not know where this should be allocated, discuss with EP

Only NFR is considered here, not SNAP

Mention this somewhere in the description? These can be considered technology-specific in a way

Should be paint used, not paint produced. Update necessary!

Values correct according to EGTEI

Values correct according to EGTEI

Discuss with EP, conversion factor difficult to find

Will be added. Should this be in chapter 3.A?

What to use if EGTEI and/or GAINS data cannot be used?

Check if default value is available in EGTEI document to recalculate in terms of mass of paint

We have considered this, but then we get huge numbers of tables (>100) which will make the document practically non-readable

Table does not provide EFs, only abatement efficiencies. Tier 2 EFs will be revised (g/kg paint).

Perhaps we can add some wording on this in Tier 3

Perhaps we can add some wording on this in Tier 3

This is not in Executive Summary of BREF document (where the other text is taken from). Cannot find.

Cannot be Tier 1 since the old factors are technology specific; these new factors have been derived in contact with industrial representatives

Must be checked, what is meant here?

This is too vague. Reference needed for changing numbers.

How to deal with this? Differs significantly from present value and unreferenced, so left out.

Source needs discussion with EP

EF to be added to chapter

Published in 1982, outdated?

Source needs discussion. What is meant here? EFs indeed seem too high, but no other information available!?

Cannot find proper EFs in AP42

Don't know what text this comment is applicable to



Printing is one NFR, therefore a Tier 1 EF is necessary

This has been considered, but would generate many tables with all just one EF and therefore expand the document quite heavily.

Table structure cannot be changed at this stage

Problem is that references are different. How to solve this?

Product masses can be added to obtain some kind of generic EF

Emissions mentioned in the text should be in the table as well (as NE in this case since no numbers are available)

No idea what the point is here; we would be happy even with a Tier 1!

This solution looks quite ok to me

Tier 1 represents averaged factors, Tier 2 tables are basically uncontrolled factors (reduction efficiency to be applied when abatement is in place). Discuss if also Tier 1 should be unabated.

This is the uncontrolled one. In Tier 2, abatement efficiencies should be applied when in operation, while in Tier 1 there is an "averaged" factor (already accounting for an average abatement)

Must be ng I-TEQ/Nm3

How to define differentiation and where to find EFs?

What more can be said? It's just burning of waste…

Discuss with Expert Panel!


What more can be said? It's just burning of waste…

A sentence will be added to make clear that the abatement efficiencies are to be applied to the US EPA factors only; the type 1/2/3 factors already have their abatement in there

To be discussed; I don't know how to take this into account

Problem: TSP from BREF while HM EFs from former GB (values are much older and therefore higher). Obviously HM EFs should be updated, but where to find EFs?

This again raises the question how to deal with Tier 2 in this chapter

Comment not understood

Consult EP: should we remove this or leave it in?


Discuss if factors are available; where to find

No indication given on where to find this information.

Unit will be corrected.

Table to be corrected

There is no original reference for this factor

EF for PCDD/F from UNEP already used; if more updates necessary then please specify which ones to update and where to find EFs!

Extra information in Tier 2 available is only the unabated-abated EFs; Tier 2 uses unabated factors where available (you can use abatement efficiencies where applicable) while Tier 1 makes a best estimate when no better info is available

Remove scheme? It does not provide information, because a variety of process may occur within this source category. Left in for now.

If EFs are provided, we are happy to include them!

Chapter_Name NFR_Code Pollutant

1 Energy industries 1.A.1 3-14 SOx 349.9 20

1 Energy industries 1.A.1 3-14 NMVOC 10 2.3

1 Energy industries 1.A.1 3-14 As 0.0125 0.004

1 Energy industries 1.A.1 3-14 Cd 0.025 0.00121 Energy industries 1.A.1 3-14 Cr 0.0625 0.0151 Energy industries 1.A.1 3-14 Cu 0.025 0.0121 Energy industries 1.A.1 3-14 Hg 0.025 01 Energy industries 1.A.1 3-14 Ni 0.875 1.03

1 Energy industries 1.A.1 3-14 Pb 0.0325 0.00461 Energy industries 1.A.1 3-14 Zn 0.025 0.049

1 Energy industries 1.A.1 3-14 PM10

1 Energy industries 1.A.1 3-15 SOx 0.25

1 Energy industries 1.A.1 3-15 CO 15 39

1 Energy industries 1.A.1 3-15 NMVOC 10 2.6

1 Energy industries 1.A.1 3-15 PM10 0.2 0.89

1 Energy industries 1.A.1 3-15 TSP 0.2 0.89

1 Energy industries 1.A.1 3-15 PM2.5 0.2 0.89

1 Energy industries 1.A.1 B4 NOx 75 200

1 Energy industries 1.A.1 B4 NOx 400

1 Energy industries 1.A.1 B4 NOx 1600

Chapter_ID

TableNumber

PresentValue

ProposedValue

1 Energy industries 1.A.1.b 4-3 SOx 349.9 20

1 Energy industries 1.A.1.b 4-3 CO 30 15

1 Energy industries 1.A.1.b 4-3 NMVOC 10 0.84

1 Energy industries 1.A.1.b 4-3 Cd 0.001 0.00121 Energy industries 1.A.1.b 4-3 Cr 0.01 0.0151 Energy industries 1.A.1.b 4-3 Cu 0.01 0.012

1 Energy industries 1.A.1.b 4-3 Pb 0.005 0.00461 Energy industries 1.A.1.b 4-3 Zn 0.05 0.049

1 Energy industries 1.A.1.b 4-3 PM10

1 Energy industries 1.A.1.b 4-4 SOx 30 201 Energy industries 1.A.1.b 4-4 NMVOC 1.3 0.65

1 Energy industries 1.A.1.b 4-4 As 0.002 0.0018

1 Energy industries 1.A.1.b 4-4 Cd 0.001 0.0014

1 Energy industries 1.A.1.b 4-4 Cr 0.001 0.0014

1 Energy industries 1.A.1.b 4-4 Cu 0.003 0.0027

1 Energy industries 1.A.1.b 4-4 Hg 0.001 0.0014

1 Energy industries 1.A.1.b 4-4 Ni 0.001 0.0014

1 Energy industries 1.A.1.b 4-4 Pb 0.004 0.0041

1 Energy industries 1.A.1.b 4-4 Zn 0.002 0.0018

1 Energy industries 1.A.1.b 4-4 PM10 2 3.2

1 Energy industries 1.A.1.b 4-5 SOx 2 20


1 Energy industries 1.A.1.b 4-5 NMVOC 1.8 1.51 Energy industries 1.A.1.b 4-5 As 0.03 0.00003

1 Energy industries 1.A.1.b 4-5 Cd 0.01 0.000011 Energy industries 1.A.1.b 4-5 Cr 0.09 0.00009

1 Energy industries 1.A.1.b 4-6 SOx 100 20


1 Energy industries 1.A.1.b 4-6 NMVOC 2 2.6

1 Energy industries 1.A.1.b 4-6 As 0.0003 0.00034

1 Energy industries 1.A.1.b 4-6 Cd 0.001 0.00071

1 Energy industries 1.A.1.b 4-6 Cr 0.003 0.0027

1 Energy industries 1.A.1.b 4-6 Cu 0.002 0.0022

1 Energy industries 1.A.1.b 4-6 Hg 0.0001 8.6E-05

1 Energy industries 1.A.1.b 4-6 Ni 0.004 0.0036

1 Energy industries 1.A.1.b 4-6 Pb 0.002 0.0018

1 Energy industries 1.A.1.b 4-6 PM10 0.89

1 Energy industries 1.A.1.b 4-7 SOx 100


1 Energy industries 1.A.1.b 4-7 NMVOC 3.1 2.6

1 Energy industries 1.A.1.b 4-7 PM10 0.9 0.89

1 Energy industries 1.A.1.b 4-7 TSP 1.1 0.89

1 Energy industries 1.A.1.b 4-7 PM2.5 0.4 0.89

1 Energy industries 1.A.1.b 4-8 NOx 100 400

1 Energy industries 1.A.1.b 4-8 SOx 100


1 Energy industries 1.A.1.b 4-8 NMVOC 3.1 56

1 Energy industries 1.A.1.b 4-8 PM10 0.9 0.037

1 Energy industries 1.A.1.b 4-8 TSP 1.1 0.037

1 Energy industries 1.A.1.b 4-8 PM2.5 0.4 0.0371 Energy industries 1.A.1.b 4-2 Arsenic 0.0001 0.000341 Energy industries 1.A.1.b 4-2 Cadmium 0.0001 0.000711 Energy industries 1.A.1.b 4-2 Chromium 0.0002 0.002741 Energy industries 1.A.1.b 4-2 Mercury 0.0001 8.6E-051 Energy industries 1.A.1.b 4-2 Nickel 0.0036 0.00361 Energy industries 1.A.1.b 4-2 Lead 0.0018 0.00179

1 Energy industries 1.A.1.b 4-3 Arsenic 0.004 3.98

1 Energy industries 1.A.1.b 4-3 Cadmium 0.001 1.2

1 Energy industries 1.A.1.b 4-3 Chromium 0.01 14.8

1 Energy industries 1.A.1.b 4-3 Mercury

1 Energy industries 1.A.1.b 4-3 Nickel 1 1030

1 Energy industries 1.A.1.b 4-3 Lead 0.005 4.56

1 Energy industries 1.A.1.b 4-4 Arsenic 0.002 1.81

1 Energy industries 1.A.1.b 4-4 Cadmium 0.001 1.36

1 Energy industries 1.A.1.b 4-4 Chromium 0.001 1.36

1 Energy industries 1.A.1.b 4-4 Mercury 0.001 1.36

1 Energy industries 1.A.1.b 4-4 Nickel 0.001 1.36

1 Energy industries 1.A.1.b 4-4 Lead 0.004 4.07

1 Energy industries 1.A.1.b 4-x Arsenic 3.98

1 Energy industries 1.A.1.b 4-x Cadmium 1.2

1 Energy industries 1.A.1.b 4-x Chromium 14.8

1 Energy industries 1.A.1.b 4-x Mercury

1 Energy industries 1.A.1.b 4-x Nickel 1030

1 Energy industries 1.A.1.b 4-x Lead 4.56

1 Energy industries 1.A.1.b 4-x Arsenic



1 Energy industries 1.A.1.b 4-x Mercury 7.31

1 Energy industries 1.A.1.b 4-x Nickel 79.3


1 Energy industries 1.A.1.b 4-x Arsenic 0.343



1 Energy industries 1.A.1.b 4-x Mercury 0.086

1 Energy industries 1.A.1.b 4-x Nickel 3.6


1 Energy industries 1.A.1.a 3.23 CO 1 1.5

1 Energy industries 1.A.1.a 3.23 NMVOC 0.2 0.19

1 Energy industries 1.A.1.a 3.23 PM10 10 2

1 Energy industries 1.A.1.a 3.23 Cd 0.002 0.0022

1 Energy industries 1.A.1.a 3.23 Ni 0.0005 0.00054

1 Energy industries 1.A.1.a 3-3 Dioxins

1 Energy industries 1.A.1.a 3-3

1 Energy industries 1.A.1.a 3-3 TSP 40 20

1 Energy industries 1.A.1.a 3-3 PM10 30 15

1 Energy industries 1.A.1.a 3-3 PM2.5 10 5

1 Energy industries 1.A.1.a 3-3 NMVOC 30 0.4






1 Energy industries 1.A.1.a 3-5 PM10


1 Energy industries 1.A.1.a 3-6 TSP

1 Energy industries 1.A.1.a 3-7 SOx 350 250

1 Energy industries 1.A.1.a 3-7 Arsenic 0.01 0.002

1 Energy industries 1.A.1.a 3-7 Cadmium 0.01 0.002

1 Energy industries 1.A.1.a 3-7 Chromium 0.03 0.008

1 Energy industries 1.A.1.a 3-7 Mercury 0.008 0.0003

1 Energy industries 1.A.1.a 3-7 Nickel 0.7 0.2







































1 Energy industries 1.A.1.a 3-20 Dioxins1 Energy industries 1.A.1.a 3-22 TSP -0.8

1 Energy industries 1.A.1.a 3-22 SOx 0.25

1 Energy industries 1.A.1.a 3-22 NMVOC 1.6 1

1 Energy industries 1.A.1.a 3-22 PM10 0.2 0.911 Energy industries 1.A.1.a 3-22 TSP 0.2 0.911 Energy industries 1.A.1.a 3-22 PM2.5 0.2 0.91

1 Energy industries 1.A.1.a 3-23 SOx 14.2 20

1 Energy industries 1.A.1.a 3-23 Pb 0.006 0.0063


1 Energy industries 1.A.1.a 3-24 SOx 0.5 20

1 Energy industries 1.A.1.a 3-24 CO 10 39

1 Energy industries 1.A.1.a 3-24 NMVOC 2.5 1

1 Energy industries 1.A.1.a 3-24 PM10 2 0.911 Energy industries 1.A.1.a 3-24 TSP 3 0.911 Energy industries 1.A.1.a 3-24 PM2.5 1 0.91

1 Energy industries 1.A.1.a 3-25 TSP1 Energy industries 1.A.1.a 3-3 Arsenic 0.004 0.005021 Energy industries 1.A.1.a 3-3 Cadmium 0.0002 0.000931 Energy industries 1.A.1.a 3-3 Chromium 0.003 0.030711 Energy industries 1.A.1.a 3-3 Mercury 0.002 0.003291 Energy industries 1.A.1.a 3-3 Nickel 0.005 0.009161 Energy industries 1.A.1.a 3-3 Lead 0.008 0.023331 Energy industries 1.A.1.a 3-4 Arsenic 0.004 0.01731 Energy industries 1.A.1.a 3-4 Cadmium 0.0002 0.015371 Energy industries 1.A.1.a 3-4 Chromium 0.00281 0.030711 Energy industries 1.A.1.a 3-4 Mercury 0.003 0.001251 Energy industries 1.A.1.a 3-4 Nickel 0.005 0.05991 Energy industries 1.A.1.a 3-4 Lead 0.008 0.053571 Energy industries 1.A.1.a 3-7 Arsenic 0.01 1.011471 Energy industries 1.A.1.a 3-7 Cadmium 0.01 1.589451 Energy industries 1.A.1.a 3-7 Chromium 0.03 23.11931 Energy industries 1.A.1.a 3-7 Mercury 0.008 0.135961 Energy industries 1.A.1.a 3-7 Nickel 0.7 23.11931 Energy industries 1.A.1.a 3-7 Lead 0.025 4.334871 Energy industries 1.A.1.a x-x Hg(0) 0.51 Energy industries 1.A.1.a x-x Hg(II) 0.41 Energy industries 1.A.1.a x-x Hg(p) 0.1

6 1.A.3.b.vi 3-19 As 0.8 3.8

6 1.A.3.b.vi 3-19 Cd 2.6 4.73

6 1.A.3.b.vi 3-19 Cr 12.4 23.825

6 1.A.3.b.vi 3-19 Ni 33.6 29.85

Road transport, automobile tyre and brake wear




6 1.A.3.b.vi 3-19 Pb 107 176.26

6 1.A.3.b.vi 3-19 As 10 67.5

6 1.A.3.b.vi 3-19 Cd 13.2038 22.3778

6 1.A.3.b.vi 3-19 Cr 669.234 2310.99

6 1.A.3.b.vi 3-19 Ni 463.144 326.515

6 1.A.3.b.vi 3-19 Pb 3126.03 6071.81

6 1.A.3.b.vi 3-5 TSP 0.0096 0.06209

6 1.A.3.b.vi 3-5 PM10 0.0064 0.00931

6 1.A.3.b.vi 3-5 PM2,5 0.0035 0.0005

6 1.A.3.b.vi 3-7 TSP 0.041 0.34928

6 1.A.3.b.vi 3-7 PM10 0.027 0.02794

6 1.A.3.b.vi 3-7 PM2,5 0.015 0.0014













6 1.A.3.b.vi 3-9 TSP 0.011 0.00907

6 1.A.3.b.vi 3-9 PM10 0.0073 0.00798

6 1.A.3.b.vi 3-9 PM2,5 0.0039 0.00404

6 1.A.3.b.vi 3-11 TSP 0.048 0.04273

6 1.A.3.b.vi 3-11 PM10 0.032 0.03762

6 1.A.3.b.vi 3-11 PM2,5 0.017 0.0190310 Small combustion 1.A.4.b 3-5 Arsenic 0.0003 10.889110 Small combustion 1.A.4.b 3-5 Cadmium 0.001 17.111410 Small combustion 1.A.4.b 3-5 Chromium 0.002 248.89310 Small combustion 1.A.4.b 3-5 Mercury 0 1.2005910 Small combustion 1.A.4.b 3-5 Nickel 0.01 248.89310 Small combustion 1.A.4.b 3-5 Lead 0 46.667410 Small combustion 1.A.4.b 3-6 Arsenic 0.0005 0.0001710 Small combustion 1.A.4.b 3-6 Cadmium 0.001 0.0001710 Small combustion 1.A.4.b 3-6 Chromium 0.002 0.0133310 Small combustion 1.A.4.b 3-6 Mercury 0.0005 0.0096710 Small combustion 1.A.4.b 3-6 Nickel 0.002 0.0001710 Small combustion 1.A.4.b 3-6 Lead 0 0.0009710 Small combustion 1.A.4.b.i 3-5 Mercury 0 0.110 Small combustion 1.A.4.b.i 3-5 Lead 010 Small combustion 1.A.4.b.i 3-6 Lead 0 40

10 Small combustion 1.A.4.b.i 3-14 TSP 550 350

10 Small combustion 1.A.4.b.i 3-14 PM10 530 330

10 Small combustion 1.A.4.b.i 3-14 PM2,5 531 330







10 Small combustion 1.A.4.b.i 3-14 Copper 0.019 0.02

10 Small combustion 1.A.4.b.i 3-14 Mercury 0.0007 0.001

10 Small combustion 1.A.4.b.i 3-14 Chromium 0.001 0.01

10 Small combustion 1.A.4.b.i 3-14 NMVOC 800 600

10 Small combustion 1.A.4.b.i 3-15 SOX 0.7 0

10 Small combustion 1.A.4.b.i 3-15 2 1.510 Small combustion 1.A.4.b.i 3-15 TSP 0.2 0.510 Small combustion 1.A.4.b.i 3-15 PM10 0.2 0.510 Small combustion 1.A.4.b.i 3-15 PM2,5 0.2 0.5

10 Small combustion 1.A.4.b.i 3-16 NOX 120 50

10 Small combustion 1.A.4.b.i 3-16 CO 320 10

10 Small combustion 1.A.4.b.i 3-16 SOX 0.01 6000

10 Small combustion 1.A.4.b.i 3-16 HM10 Small combustion 1.A.4.b.i 3-20 PM2.5 0 1010 Small combustion 1.A.4.b.i 3-24 TSP -0.8 0.810 Small combustion 1.A.4.b.i x-x Hg(0) 0.510 Small combustion 1.A.4.b.i x-x Hg(II) 0.310 Small combustion 1.A.4.b.i x-x Hg(p) 0.2

13 Solid fuel transformation 1.B.1.b 3-1 PM10 100

13 Solid fuel transformation 1.B.1.b 3-1 PM2,5 90

16 Refining / storage 1.B.2.a.iv 3-6 NMVOC 0.2 0.2

16 Refining / storage 1.B.2.a.iv 3-7 PM10 0.8 0.618 Geothermal energy extraction 1.B.2.a.vi 3-1 NOX 0

Dioxins and Furans

18 Geothermal energy extraction 1.B.2.a.vi 3-1 SOX 1618 Geothermal energy extraction 1.B.2.a.vi 3-1 NH3 300 210018 Geothermal energy extraction 1.B.2.a.vi 3-1 PST 018 Geothermal energy extraction 1.B.2.a.vi 3-1 PM10 018 Geothermal energy extraction 1.B.2.a.vi 3-1 PM2,5 018 Geothermal energy extraction 1.B.2.a.vi 3-1 Hg 0.2 0.4418 Geothermal energy extraction 1.B.2.a.vi 3-1 As 0.02519 Venting and flaring 1.B.2.c 3-3 NOx 4 3.7

20 Cement production 2.A.1 x-x Hg(0) 0.8

20 Cement production 2.A.1 x-x Hg(II) 0.15

20 Cement production 2.A.1 x-x Hg(p) 0.05

23 Soda ash production and use 2.A.4 tab. 3-1 NH3 0.3873 1

25 Road paving with asphalt 2.A.6 No. 3-6 NMVOC 200 30

29 Other mineral products 2.A.7.d 3-2 SOx 0 1900

29 Other mineral products 2.A.7.d 3-2 Arsenic 0.12 0.08

29 Other mineral products 2.A.7.d 3-2 Cadmium 0.15 0.068

29 Other mineral products 2.A.7.d 3-2 Chromium 2.4 0.08

29 Other mineral products 2.A.7.d 3-2 Copper 0.6 0.007

29 Other mineral products 2.A.7.d 3-2 Mercury 0.05 0.003

29 Other mineral products 2.A.7.d 3-2 Nickel 1.9 0.74

29 Other mineral products 2.A.7.d 3-2 Lead 12 0.4

29 Other mineral products 2.A.7.d 3-2 Selenium 18 0.15

29 Other mineral products 2.A.7.d 3-2 Zinc 11 0.366

29 Other mineral products 2.A.7.d Table 3-2 PM2.5 320 10.8

29 Other mineral products 2.A.7.d Table 3-2 PM10 360 19.6

29 Other mineral products 2.A.7.d Table 3-2 Se 18 1.36

30 Chemical industry 2.B.5.a 3-x Arsenic

30 Chemical industry 2.B.5.a 3-x Cadmium

30 Chemical industry 2.B.5.a 3-x Chromium

30 Chemical industry 2.B.5.a 3-x Nickel30 Chemical industry 2.B.5.a x-x Hg(p) 0

31 Iron and steel production 2.C.1 3-2 Lead 0.5 3.54308

31 Iron and steel production 2.C.1 3-2 Arsenic 0.02 0.01789

31 Iron and steel production 2.C.1 3-2 Cadmium 0.009 0.00394

31 Iron and steel production 2.C.1 3-2 Chromium 0.02 2.3

31 Iron and steel production 2.C.1 3-2 Nickel 0.009 0.08947

31 Iron and steel production 2.C.1 3-2 Mercury 0.05 0.01838

31 Iron and steel production 2.C.1 3-x Cadmium 0.21766

31 Iron and steel production 2.C.1 3-x Chromium 2.3

31 Iron and steel production 2.C.1 3-x Mercury 0.05059

31 Iron and steel production 2.C.1 3-x Nickel 0.72553

31 Iron and steel production 2.C.1 3-x Lead 2.61191

31 Iron and steel production 2.C.1 3-x Arsenic 0.40069



31 Iron and steel production 2.C.1 3-x Mercury 0.00137



31 Iron and steel production 2.C.1 3-x Nickel 10

31 Iron and steel production 2.C.1 x-x Hg(0) 0.7

31 Iron and steel production 2.C.1 x-x Hg(II) 0.3

31 Iron and steel production 2.C.1 3-x Mercury 0.0001431 Iron and steel production 2.C.1 x-x Hg(p) 0

31 Iron and steel production 2.C.1 3-x Arsenic

31 Iron and steel production 2.C.1 3-x Arsenic 0.01451


31 Iron and steel production 2.C.1 3-x Lead 300

31 Iron and steel production 2.C.1 3-x Nickel


31 Iron and steel production 2.C.1 3-x Arsenic


31 Iron and steel production 2.C.1 3-x Chromium

31 Iron and steel production 2.C.1 3-x Mercury



31 Iron and steel production 2.C.1 3-x Arsenic 30



31 Iron and steel production 2.C.1 3-x Mercury

31 Iron and steel production 2.C.1 3-x Cadmium

34 Copper production 2.C.5.a 3-1 Arsenic 39 38.7632

34 Copper production 2.C.5.a 3-1 Cadmium 12 11.4866

34 Copper production 2.C.5.a 3-1 Chromium 16 16.0136

34 Copper production 2.C.5.a 3-1 Mercury 0.023 0.02335

34 Copper production 2.C.5.a 3-1 Nickel 14 14.439

34 Copper production 2.C.5.a 3-2 Cadmium 15 14.5531

34 Copper production 2.C.5.a 3-1 Lead 160 159.566

34 Copper production 2.C.5.a 3-2 Chromium 21 21.3515

34 Copper production 2.C.5.a 3-2 Mercury 0.031 0.03113

34 Copper production 2.C.5.a 3-2 Nickel 19 19.2101

34 Copper production 2.C.5.a 3-2 Lead 170 174.637

34 Copper production 2.C.5.a 3-x Arsenic 1.37223

34 Copper production 2.C.5.a 3-x Cadmium 2.28705

34 Copper production 2.C.5.a 3-x Chromium

34 Copper production 2.C.5.a 3-x Mercury

34 Copper production 2.C.5.a 3-x Nickel 0.12579

34 Copper production 2.C.5.a 3-x Lead 114.352

34 Copper production 2.C.5.a 3-2 Arsenic 51 51.2268

35 Lead production 2.C.5.b 3-x Mercury

35 Lead production 2.C.5.b 3-x Nickel

35 Lead production 2.C.5.b 3-x Lead 425.926

35 Lead production 2.C.5.b 3-x Cadmium 1.10153

35 Lead production 2.C.5.b 3-x Arsenic 3.45147

35 Lead production 2.C.5.b 3-x Chromium35 Lead production 2.C.5.b 3-1 Arsenic 0.89 0.8741735 Lead production 2.C.5.b 3-1 Cadmium 0.33 0.3256335 Lead production 2.C.5.b 3-1 Chromium 035 Lead production 2.C.5.b 3-1 Mercury 0.7 0.6940735 Lead production 2.C.5.b 3-1 Nickel 035 Lead production 2.C.5.b 3-1 Lead 120 115.903

35 Lead production 2.C.5.b 3-2 Arsenic 0.015 0.01507

35 Lead production 2.C.5.b 3-2 Cadmium 0.067 0.067

35 Lead production 2.C.5.b 3-2 Chromium 0

35 Lead production 2.C.5.b 3-2 Mercury 0.93 0.92542

35 Lead production 2.C.5.b 3-2 Nickel 0

35 Lead production 2.C.5.b 3-2 Lead 13 12.5621

35 Lead production 2.C.5.b x-x Hg(0) 0.84

35 Lead production 2.C.5.b x-x Hg(II) 0.1

35 Lead production 2.C.5.b x-x Hg(p) 0.06

37 Zinc production 2.C.5.d 3-2 Nickel 037 Zinc production 2.C.5.d 3-1 Arsenic 0.12 0.1195637 Zinc production 2.C.5.d 3-1 Cadmium 2.5 2.5331937 Zinc production 2.C.5.d 3-1 Chromium 037 Zinc production 2.C.5.d 3-1 Mercury 3.8 3.7857837 Zinc production 2.C.5.d 3-1 Nickel 037 Zinc production 2.C.5.d 3-1 Lead 14 14.0846

37 Zinc production 2.C.5.d 3-2 Arsenic 0

37 Zinc production 2.C.5.d 3-2 Cadmium 2.4 2.43188

37 Zinc production 2.C.5.d 3-2 Mercury 5 5.04556

37 Zinc production 2.C.5.d 3-2 Lead 17 17.0232

37 Zinc production 2.C.5.d 3-x Arsenic 0.47826

37 Zinc production 2.C.5.d 3-x Cadmium 2.83712

37 Zinc production 2.C.5.d 3-x Chromium

37 Zinc production 2.C.5.d 3-x Mercury 0.00645

37 Zinc production 2.C.5.d 3-x Nickel

37 Zinc production 2.C.5.d 3-x Lead 5.26895

37 Zinc production 2.C.5.d 3-2 Chromium 0

37 Zinc production 2.C.5.d x-x Hg(0) 0.8

37 Zinc production 2.C.5.d x-x Hg(II) 0.15

37 Zinc production 2.C.5.d x-x Hg(p) 0.05

46 Paint application 3.A.3 3-3 NMVOC 200 380



46 Paint application 3.A new COV 125

47 Degreasing 3.B.1 new COV 740

52 Other product use 3.D.3 new COV 5.5

59 Clinical waste incineration 6.C MNVOC 0

59 Clinical waste incineration 6.C SO2 0.02

59 Clinical waste incineration 6.C CO 0.04

59 Clinical waste incineration 6.C Paricles 0.14

59 Clinical waste incineration 6.C x-x Hg(p) 0.2

59 Clinical waste incineration 6.C CH4 0.37

59 Clinical waste incineration 6.C N2O 0.0015

59 Clinical waste incineration 6.C HM

59 Clinical waste incineration 6.C x-x Hg(0) 0.2

59 Clinical waste incineration 6.C x-x Hg(II) 0.6

59 Clinical waste incineration 6.C Nox 0.17

60 Industrial waste incineration (d) 6.C.b 3-1 Cadmium 3 0.10158

60 Industrial waste incineration (d) 6.C.b 3-1 Chromium 0.3

60 Industrial waste incineration (d) 6.C.b 3-1 Mercury 35 0.08665

60 Industrial waste incineration (d) 6.C.b 3-1 Nickel 56 0.13544

60 Industrial waste incineration (d) 6.C.b 3-1 Lead 0.1 1.25766

60 Industrial waste incineration (d) 6.C.b 3-1 Arsenic 0.05 0.01645

64 Other waste 6.D

64 Other waste 6.D tobacco

house and care fires

TSP, HM and dioxin

NOx, NMVOC, CO, TSP, PAH,HM and dioxin

Reference

19.9 20 Accepted

1.8 2.8 Noted

0.002 0.008 Noted

0.0006 0.0024 Accepted0.005 0.045 API Publication 348 (rated D) Rejected0.004 0.036 API Publication 348 (rated D) Rejected

API Publication 348 (not detected) Rejected0.33 3.1 API Publication 348 (rated D) Rejected

0.0023 0.0092 Rejected0.016 0.15 API Publication 348 (rated D) Rejected

Noted

Accepted

23 55 Accepted

1.3 5.2 Accepted

0.53 1.3 Accepted

0.53 1.3 Accepted

0.53 1.3 Accepted

Noted

Noted

Noted

LowerLimit

UpperLimit

Proposed decision

Chemistry, assuming all sulphur converted (values to be multiplied with S = wt% S in fuel)

US EPA AP-42 Ch 1.3, Table 1.3-3 (rated A)

US EPA AP-42 Ch 1.3, Table 1.3-11 (rated C)



US EPA AP-42 provides algorithm relating PM to sulphur content

Page 8, line 17 of this chapter states sulphur in natural gas is negligible. If this proposal is not accepted, then the algorithm 20*S should be used - see above.

US EPA AP-42 Ch 1.4, Table 1.4-1 (rated B)



AP-42 (as above) states that all PM < 1 micron


See: http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/gui_EHSGuidelines2007_GeneralEHS/$FILE/Final+-+General+EHS+Guidelines.pdf

For dual fuel engines operated with gas, overtake World Bank proposal, see General EHS Guidelines: http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/gui_EHSGuidelines2007_GeneralEHS/$FILE/Final+-+General+EHS+Guidelines.pdf

For gas diesel engines, see: http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTitle/gui_EHSGuidelines2007_GeneralEHS/$FILE/Final+-+General+EHS+Guidelines.pdf

19.9 20 Noted

12 18 Noted

0.67 1 Noted

0.0006 0.0024 Noted0.005 0.045 API Publication 348 (rated D) Noted0.004 0.036 API Publication 348 (rated D) Noted

0.0023 0.0092 Noted0.016 0.15 API Publication 348 (rated D) Noted

Noted

19.9 20 Noted0.52 0.78 E-PRTR Noted

0.0006 0.0054 Accepted

0.0007 0.0042 Noted

0.0007 0.0042 Accepted

0.0009 0.0081 Noted

0.0007 0.0042 Noted

0.0007 0.0042 Noted

0.0014 0.012 Noted

0.0006 0.0054 Noted

1 9.6 Noted

19.9 20 Noted

8 32 Accepted

0.49 4.4 Noted1.5E-05 0.00006 Guidebook, 2006 gives units as g/TJ Accepted






US EPA AP-42 provides algorithm relating PM to sulphur content


US EPA AP-42 Ch 1.3, Table 1.3-10 (rated D); ; present value rounded up to one significant figure

US EPA AP-42 Ch 1.3, Table 1.3-10 (rated D); present value rounded up to one significant figure







US EPA AP-42 Ch 1.3, Table 1.3-10 (rated D)




5E-06 0.00002 Guidebook, 2006 gives units as g/TJ Noted4.5E-05 0.00018 Guidebook, 2006 gives units as g/TJ Noted

19.9 20 Noted

23 55 Noted

1.3 5.2 Noted

0.00011 0.001 Noted

0.00024 0.0021 Noted

0.0014 0.0054 Noted

0.0011 0.0044 Noted

4.3E-05 0.00017 Noted

0.0018 0.0072 Noted

0.0009 0.0036 Noted

0.53 1.3 Noted

Noted

23 55 Noted

1.3 5.2 Noted

0.53 1.3 Noted

0.53 1.3 Noted

0.53 1.3 Noted

240 560 Noted


US EPA AP-42 Ch 1.4, Table 1.4-1 (rated B); Assuming refinery gas equivalent to natural gas

US EPA AP-42 Ch 1.4, Table 1.4-2 (rated C); Assuming refinery gas equivalent to natural gas

API Publication 348 (rated D); present value rounded up to one significant figure

API Publication 348 (rated D); present value rounded up to one significant figure

API Publication 348 (rated C); present value rounded up to one significant figure

API Publication 348 (rated c); present value rounded up to one significant figure




US EPA AP-42 Ch 1.4, Table 1.4-2 (rated B); assuming refinery gas equivalent to natural gas








Noted

160 380 Noted

28 110 Noted

0.011 0.11 Noted

0.011 0.11 Noted

0.011 0.11 Noted0.0002 0.0005 ESPREME-Table 25 Noted0.0005 0.001 ESPREME-Table 25 Noted

0.001 0.004 ESPREME-Table 25 Noted0.00005 0.00015 ESPREME-Table 25 Noted

0.002 0.006 ESPREME-Table 25 Noted0.0012 0.0021 ESPREME-Table 25 Noted

2 6 Noted

0.8 1.5 Noted

10 20 Noted

Accepted

500 1500 Accepted

3 7 Noted

1.5 2.5 Noted

1 1.8 Accepted

1 1.8 Accepted

1 1.8 Accepted

1 1.8 Noted

3 6 Noted

2 6 Accepted

0.8 1.5 Noted

10 20 Noted

Noted







ESPREME-Table 24 (called in the FOD under Tier 2)



ESPREME-Table 24 (called in the FOD under Tier 2) (not in FOD)









ESPREME-gas turbines-destillate oil-table 26 (not in FOD)




500 1500 Noted

3 7 Noted

Noted

1 5 Noted

3 9 Noted

4 10 Noted

50 100 Noted

10 20 Noted

0.2 0.5 Noted

0.5 1.2 Noted

1.5 4 Noted

0.05 0.15 Noted

2 5 Noted

1 3 Noted

0.7 3 Noted

0.1 0.6 Noted

0.5 4 Noted

0.001 0.0044 Noted

0.00025 0.0011 Noted



ESPREME-gas turbines-natural gas and refinery fuel gas-table 27 (not in FOD)












US EPA AP-42 Ch 3.1, Table 3.1-1 (rated C); present value rounded up to one significant figure

Present value rounded up to one significant figure

US EPA AP-42 Ch 3.1, Table 3.1-2a (rated C)



Noted

Noted

2 Noted

Noted

Noted

Accepted

Accepted

2 Accepted

Accepted

Accepted

EF are much too high being based on 1998 data; according to own measurements on power plants the majority of dioxins/furans are not detectable; we suggest to use the EURELECTRIC data of 6E-10

As the EURELECTRIC data are based on more actual measurements the ranges of the EF should be extended to include the EURELECTRIC EF; they should also include the EF calculated in appendix B

The proposed EF seems too high - under the LCPD plant >500 MW(thermal) have an ELV of 50 mg/Nm3 (17.5 g/GJ), so the suggested value would seem more appropriate. According to our data, the lower 95% confidence intervals for TSP are too high. We recommend

Recalculated from proposed TSP EF factor


EF seems very high - NMVOC emission generally related to combustion conditions and is often below instrument detection limits. Suggest using EURELECTRIC value of 0.4





Accepted

0.02 Accepted

Accepted

0.1 Accepted

Accepted

0.001 Accepted

0.001 Accepted

0.005 Accepted

0.0002 Accepted

0.1 Accepted

Accepted


Lower 95% confidence limit value for PM10 is lower than that of PM2.5 - suggest that they should be the same


Lower 95% confidence limit value for TSP is lower than that of PM10 - suggest that they should be the same

Limit for sulphur in fuel oil is 1% - this equates to an emission of around 250 g/GJ

EF given appears to be for a 1.5% sulphur fuel - as fuel sulphur has decreased so has the heavy metal content. Suggest using the EURELECTRIC value of 0.002 g/GJ






0.1 Accepted

Accepted

Accepted

2 Accepted

Accepted

Accepted

Accepted

2 Accepted

Accepted

Accepted

Accepted



It should be stated which TEF factors are used (I-TEF or WHO-TEF)?









Accepted

2 Accepted

Accepted

Accepted

2 Accepted

Accepted

Accepted

Accepted

Accepted

2 Accepted









EF seems very high - NMVOC emission generally related to combustion conditions and is often below instrument detection limits. Suggest using EURELCETRIC value of 0.4


Accepted

Accepted

Accepted

Accepted

2 Accepted

Accepted

Accepted

Accepted

Accepted

2 Accepted

Accepted

Accepted













Accepted

2 Noted

Noted

Noted

Notednegative value? Noted

Noted

0.5 2 Noted

0.45 1.8 Noted0.45 1.8 Assuming all PM < 1 micron Noted0.45 1.8 Assuming all PM < 1 micron Noted

19.9 20 Noted

0.003 0.013 Noted

0.1 Noted

19.9 20 Noted

30 47 Noted

EF are probably too high being based on 1998 data; we have not measured these on fluidised bed plants but the values are likely to be similar to those from PF plants so we suggest using the EURELECTRIC data of 6E-10




EF are probably too high being based on 1998 data; we have not measured these on fluidised bed plants but the values are likely to be similar to those from PF plants so we suggest using the EURELECTRIC data of 6E-10

Page 8, line 17 of this chapter states sulphur in natural gas is negligible.







US EPA AP-42 Ch 3.1, Table 3.1-1 (rated A); assumed refinery gas equivalent to natural gas

0.5 2 Noted

0.45 1.8 Noted0.45 1.8 Assuming all PM < 1 micron Noted0.45 1.8 Assuming all PM < 1 micron Noted

0.1 Noted0.0035 0.007 ESPREME Noted

0.00047 0.0014 ESPREME Noted0.02142 0.04285 ESPREME Noted0.00235 0.0047 ESPREME Noted0.00583 0.01458 ESPREME Noted

0.0175 0.035 ESPREME Noted0.00439 0.02196 ESPREME Noted0.00439 0.02635 ESPREME Noted0.00779 0.03897 ESPREME Noted0.00062 0.0025 ESPREME Noted0.02196 0.13174 ESPREME Noted0.01757 0.10539 ESPREME Noted0.72248 1.44496 ESPREME Noted0.72248 2.88991 ESPREME Noted16.5138 33.0276 ESPREME Noted0.09064 0.36257 ESPREME Noted7.22479 43.3487 ESPREME Noted2.16744 6.50231 ESPREME Noted

0.4 0.6 ESPREME Noted0.3 0.5 ESPREME Noted

0.05 0.2 ESPREME Noted

1.6 6 Noted

1.4 9 Noted

2 61 Noted

2.4 63 Noted

US EPA AP-42 Ch 3.1, Table 3.1-2a (rated C); assuming refinery gas equivalent to natural gas


Lower 95% confidence limit value for TSP is lower than that of PM10 - suggest that they should be the same

Hjortenkrans et al. 2007, Uexküll et al. 2005, Warner et al. 2002, Westerlund 2001, Legret & Pagotto 1999, Stechmann 1993, Hildemann et al. 1991, Heinrichs 1993




6.3 670 Noted

10 130 Noted

1.5 57 Noted

114.938 8050 Noted

80 660 Noted

120 20000 Noted

0.017 0.12 Noted

0.00255 0.018 Noted

0.00014 0.00096 Noted

0.034 0.768 Noted

0.00272 0.06144 Noted

0.00014 0.00307 Noted







TNO 2001, BUWAL 1992, Gebbe et al. 1997, CARB 1993, Garben et al. 1996, Baumann 1997, Legret and Pagotto 1999, Lükewille et al. 2001






0.00179 0.02 Noted

0.00158 0.01761 Noted

0.0008 0.00891 Noted

0.00347 0.09 Noted

0.00306 0.07924 Noted

0.00155 0.04009 Noted7.77791 15.5558 ESPREME Noted7.77791 31.1116 ESPREME Noted177.781 355.561 ESPREME Noted

0.8004 3.20158 ESPREME Noted77.7791 466.674 ESPREME Noted23.3337 70.0012 ESPREME Noted0.00011 0.00028 ESPREME Noted0.00011 0.00028 ESPREME Noted0.00889 0.02222 ESPREME Noted0.00556 0.01667 ESPREME Noted0.00011 0.00028 ESPREME Noted0.00056 0.00167 ESPREME Noted

0.03 0.1 Guidebook 2006. unit mg/GJ NotedNoted

Guidebook 2006, unit mg/GJ Noted

Accepted

Accepted

Accepted

Garg et al. 2000, Legret&Pagotto 1999, Warner et al. 2002, Rauterberg-Wulff 1998, Johansson et al. 1998, Westerlund 2001, Buwal 2001, TNO 2001






ERROR IN COPY FROM "OLD" GB or wrong reference


ERROR IN COPY FROM "OLD" GB *** Proposed value > PM10 one

Accepted

Accepted

Accepted

Accepted

Noted

NotedEF of old GB has less uncertainty NotedEF of old GB has less uncertainty NotedEF of old GB has less uncertainty Noted

Noted

Noted

Noted

NotedGuidebook 2006, unit g/GJ Noted

Accepted0.4 0.6 ESPREME Noted0.2 0.4 ESPREME Noted0.1 0.3 ESPREME Noted

45 180 Accepted

40 160 Accepted

0.1 0.4 Accepted

0.3 0.9 Accepted0 ARPAT, 2007 Accepted





I WE SPEAK ABOUT "NATURAL" GAS EF=0, if we speak of other gases (i.e. LPG) then mut be declared


It's inaudite that consultant it's not able to copy "old" in "new" Efs




estimated fraction of PM by US EPA data

estimated fraction of PM by US EPA data

Upper limit as per Table 3-1 of this NFR

Refinery BREF provides a range of abatementefficiencies for cyclones between 30% and 90%Propose lower limit set to BREF value.Propose default efficiency is taken at mid range

Accepted800 9000 ARPAT, 2007 Accepted

ARPAT, 2007 AcceptedARPAT, 2007 AcceptedARPAT, 2007 Accepted

0.26 1.3 ARPAT, 2007 Accepted0.02 0.045 ARPAT, 2007 Accepted

Guidebook 2006 Accepted

0.7 0.9 ESPREME Rejected



0.6 1.5 Accepted

Accepted

1360 2170 Accepted

0.18 Accepted

0.25 Accepted

0.01 0.13 Accepted

0.011 Accepted

ARPAT, 2007 Note that the proposed value is wrong! The reference quoted say: "While geothermal plants do not emit sulfur dioxide directly, once hydrogen sulfide is released as a gas into the atmosphere, it spreads into the air and eventually changes into

BREF "Large Volume Inorganic Chemicals - Solids and Other Industry (LVIC - SAO) October 2006, chapter 2.3.3.5), unit kg/ton

used EF of german NIR, referenced on VDI 2283 Aufbereitungsanlagen für Asphaltmischgut

Average of measurements coming from members of the federation (only flat glass)

Average of measurements coming from members of the federation (only flat glass), lower limit = below detection limit




0.039 Accepted

0.54 0.97 Accepted

0.23 0.68 Accepted

0.02 0.4 Accepted

0.13 0.56 Accepted

Accepted

Accepted

Accepted

Accepted

Accepted

Accepted

AcceptedESPREME-Chlor alkali production Accepted

1.78944 5.36831 Accepted

0.00895 0.02684 Accepted

0.00179 0.00537 Accepted

1.15 3.45 Accepted

0.05368 0.16105 Accepted

0.01225 0.03676 Accepted

0.14511 0.29021 Accepted

1.15 3.45 Accepted






unpublished report on emission factors of the German glas and mineral fibre industry for the year 2005



ESPREME - chlorine-Tier 1 (not in FOD)




ESPREME-(called in the FOD under Tier 2)






ESPREME - Electric arc -Tier 1 (not in FOD)


0.03794 0.05691 Accepted

0.21766 1.0883 Accepted

1.0883 4.35318 Accepted

0.26713 0.53426 Accepted

0.05343 0.08014 Accepted

1.53333 3.06667 Accepted

0.00069 0.00206 Accepted

0.06678 0.66782 Accepted

2.67128 6.67819 Accepted

8 15 Accepted



6.89E-05 0.00021 AcceptedESPREME Rejected

Accepted

0.00726 0.02177 Rejected

1.15 3.45 Accepted

200 500 Accepted

Rejected

0.0003 0.00091 Accepted

Rejected

9E-05 0.00015 Accepted

Rejected

Rejected

0.0048 0.00719 Accepted




ESPREME - Basic oxygen-Tier 1 (not in FOD)






ESPREME - open hearth furnace-Tier 1 (not in FOD)

ESPREME -pig iron-Tier 1 (not in FOD)







ESPREME - cast iron-Tier 1 (not in FOD)





0.0018 0.0042 Accepted

20 50 Accepted

0.5 1.5 Accepted

1.53333 3.83333 Accepted

Rejected

Rejected

26.3385 52.9057 Accepted

9.01773 18.6072 Accepted

10.9184 21.8367 Accepted

0.01557 0.03891 Accepted

8.74614 21.8725 Accepted

11.6425 23.2849 Accepted

101.613 275.472 Accepted

14.5578 29.1156 Accepted

0.02075 0.05189 Accepted

11.6425 29.1062 Accepted

116.425 291.062 Accepted

0.57176 2.05834 Accepted

1.14352 4.57409 Accepted







ESPREME - primary copper-Tier 1 The unit (g/Mg) aluminium should be corrected in g/Mg copper





ESPREME - primary copper-Tier 1 (called in the FOD under Tier 2) - The unit (g/Mg aluminium) should be corrected in g/Mg copper






ESPREME - secondary copper-Tier 1 (not in FOD)


Rejected

Rejected

0.05718 0.17153 Accepted

57.1762 228.705 Accepted

34.9274 69.8548 Accepted

Rejected

Rejected

146.871 587.485 Accepted

0.73436 2.93742 Accepted

2.20307 5.14049 Accepted

Rejected0.5583 1.3002 ESPREME - primary lead-Tier 1 Accepted

0.22128 0.80973 ESPREME - primary lead-Tier 1 AcceptedESPREME - primary lead-Tier 1 Rejected

0.55525 0.83288 ESPREME - primary lead-Tier 1 AcceptedESPREME - primary lead-Tier 1 Rejected

42.9988 159.433 ESPREME - primary lead-Tier 1 Accepted

0.01005 0.0201 Accepted

0.05025 0.1005 Accepted

Rejected

0.74034 1.11051 Accepted

Rejected

8.37472 16.7494 Accepted

0.7 0.9 ESPREME-primary lead Rejected








ESPREME - secondary lead-Tier 1 (not in FOD)






ESPREME - primary lead-Tier 1 (called in the FOD under Tier 2)






Rejected0.0608 0.18239 ESPREME - primary zinc-Tier 1 Accepted

1.13487 3.93152 ESPREME - primary zinc-Tier 1 AcceptedESPREME - primary zinc-Tier 1 Rejected

1.51447 6.05709 ESPREME - primary zinc-Tier 1 AcceptedESPREME - primary zinc-Tier 1 Rejected

4.45843 27.5613 ESPREME - primary zinc-Tier 1 Accepted

Rejected

0.97275 3.89101 Accepted

2.01822 8.07289 Accepted

4.86376 34.0463 Accepted

0.24318 0.72955 Accepted

1.62121 4.05304 Accepted

Accepted

0.00323 0.00968 Accepted

Accepted

3.24243 8.10607 Accepted

Accepted

0.7 0.9 ESPREME-zinc Rejected



5 1900

ESPREME - primary zinc-Tier 1 (called in the FOD under Tier 2)





ESPREME - secondary zinc-Tier 1 (not in FOD)







The Emission factor is specific for Germany; Reference: J. Theloke. NMVOC-Emissionen aus der Lösemittelanwendung und Möglichkeiten zu ihrer Minderung. Fort-schritt-Berichte VDI Reihe 15 Nr. 252. Düsseldorf: VDI-Verlag, (Dissertation), 2005


66 530

60 200

Accepted

Accepted

Accepted

Rejected

Accepted

Accepted

Accepted


Rejected





g/m2 European Commission (2006d), Integrated Pollution Prevention and Control (IPPC), Reference Document on Best Available Techniques (BREF) for the Surface Treatment of Metals and Plastics, August 2006

electronic components kg/t wafer Carlo Trozzi (Private Communication, 2008)

g/m2 060311 Adhesive Tape Manufacturing (BREF)

http://www.ssb.no/emner/01/04/10/rapp_emissions/rapp_200738_en/rapp_200738_en.pdf page 110, tabel 7.2, unit = kg/ton





Rejected

Accepted



Accepted

0.04837 0.14511 ESPREME Accepted

ESPREME Rejected





Accepted

Accepted


http://www.ssb.no/emner/01/04/10/rapp_emissions/rapp_200738_en/rapp_200738_en.pdf page 110, tabel 7.2


http://www.ssb.no/emner/01/04/10/rapp_emissions/rapp_200738_en/rapp_200738_en.pdf, page 112

http://www.ssb.no/emner/01/04/10/rapp_emissions/rapp_200738_en/rapp_200738_en.pdf page 112


Replaced with AP42 Efs

Replaced with AP42 Efs

Replaced with AP42 EfsReplaced with AP42 EfsReplaced with AP42 EfsReplaced with AP42 EfsReplaced with AP42 Efs

Replaced with AP42 EfsReplaced with AP42 Efs

Robert - please can you look into this

Robert - please can you look into this

Done

Done

Done

Done

Done

Need to address Sulphur emissions - will replace with S = wt%S in fuel and default EF using default sulphur content (made explicit in text)

I-TEF

See first comment

See first comment

See first comment

See first comment

See first comment

Not included at this stage. Could be done at later stage.
















Done

Done

Done







Old' Guidebook references will all be updated and referenced to original source



Done

Done

Done

Done

Updated

Updated

Updated

UpdatedValue = 0, so not taken into account





UpdatedUpdatedValue = 0, so not taken into accountValue = 0, so not taken into accountValue = 0, so not taken into accountUpdatedUpdatedUpdated

95% confidence interval estimated

Not included yet. Is not one of the pollutants in the protocol. Perhaps this can be included in separate (not Tier 1/2 tables) somewhere in the text?





accepted ESPREME list only EF's for mercury



accepted ESPREME list only EF's for mercuryaccepted

Value = 0

No value

No value

No value

No value

No value



No value

No value

No value

No value

No value

No value

No value

No value

No value

No value

No value




No value

No value

No value

No value

No value

No value




Not included for now. GAINS weighted average over all countries seems more appropriate as Tier 1

Should we use this as the Tier 1? Or the weighted average of GAINS as we have now?

Added to chapter and database

Added to chapter and database I suppose NMVOC is meant (COV?)

Added to chapter and database

No idea what this means

Inserted

Inserted

Inserted

GHG





I suppose NMVOC is meant (COV?)EF is for boat building


GHG

HMs included where EF available

Inserted

Inserted

No new value suggested

BREF value used instead

Inserted

Inserted

Inserted

EFs included

EFs included



Documents

List 2.xls