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Chapter 8.2 - Improvements

Improvements since last Submission

  • 1.A.3.c: broad revision of activity data for use of solid fuels and biomass in historic steam locomotives

Improvements planned for future submissions

Possible improvement issues that have been identified so far and will be checked in the future are given below:

Over-all inventory / all source categories

  • To prioritise improvements on the basis of the results of the uncertainty analysis, it is planned to determine uncertainty analysis at source category level.

Individual source categories

stationary fuel combustion:

  • evaluation of measurement data on POPs and heavy metal in large combustion plants (1.A.1.a)
  • revision of SO2 emission factors (1.A.1.b)
  • further improvements of PAH Emission factors for small combustion plants

mobile fuel combustion:

  • implementation of abrasive emissions from tyres, brakes and road surface into TREMOD (1.A.3.b vi + vii)
  • validation and revision of approach for abrasive emissions from railways; possible implementation into TREMOD (1.A.3.c)

fugitive emissions:

  • emission factors from natural gas transmission and distribution will be updated according to results of measurement programms (1.B.2.b)

industrial processes:

  • collection of AD for titanium dioxide production and calculation of these emissions
  • Update of some EF for Cement industry

Investigated Review Findings

NECD 2020

Aspect Sector Finding Sumamry CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 NECD 2020 Implemented Official Comment for IIR
General LPS Improve consistency with the latest ePRTR reporting. DE-LPS-GEN-2020-0002 Yes
QA/QC LPS Improve coordinates given, check for collisions DE-LPS-GEN-2020-0004 Yes
QA/QC LPS Make sure each point source reported has unique key build from attributes DE-LPS-GEN-2020-0003 No Germany checked this issue and does not see any reason to change the data. It is unclear, why LPS name, GNFR and stack height should function as a key alternative, in particular because the table already provides the ePRTR ID as an unique and valid key.
Aspect Sector Finding Sumamry CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 NECD 2020 Implemented Official Comment for IIR
Transparency 2C7a Improve Transparency for Cd and Pb emissions from copper production DE-2C7a-2020-0001 Yes
Transparency 3I Improve the transparency of the calculations used for NO emissions from storage of digestate from energy crops. DE-3I-2020-0001 Yes
Transparency LPS Reallocate livestock emissions from GNFR L_AgriOther to K_AgriLivestock DE-LPS-K-2020-0001 Yes
Aspect Sector Finding Sumamry CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 NECD 2020 Implemented Official Comment for IIR
Consistency 1A4cii IEF Cd trend since 2007 erratic DE-1A4cii-2018-0001 DE-1A4cii-2018-0001 (ID reused) DE-1A4cii-2018-0001 (ID reused) No All issues regarding the inconsistency of activity data from the National Energy Balance (NEB) can only be resolved as soon as the ongoing internal revision process launched by the provider of the NEB has been finished.
Consistency 1A4ciii Large increase in AD from 2015 to 2016 DE-1A4ciii-2018-0001 DE-1A4ciii-2018-0001 (ID reused) DE-1A4ciii-2018-0001 (ID reused) No All issues regarding the inconsistency of activity data from the National Energy Balance (NEB) can only be resolved as soon as the ongoing internal revision process launched by the provider of the NEB has been finished.
Aspect Sector Finding Sumamry CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 NECD 2020 Implemented Official Comment for IIR
Completeness 2B6 Include the NOx emissions in the next submission. DE-2B6-2017-0001 DE-2B6-2018-0001 DE-2B6-2017-0001 (ID reused) DE-2B6-2017-0001 (ID reused) No Germany will look into possible implementations for this in the future. Not reported 2018.
Completeness 2C1 Potential under-estimate of emissions of HCB DE-2C1-2018-0001 DE-2C1-2018-0001 (ID reused) DE-2C1-2018-0001 (ID reused) Yes Data acquisition for the resolution of this issue will be implemented in the framework of a research project updating several emission factors. The effort is scheduled to start in 2021 and will take about 3 years. Until then, the default emission factor from the EMEP/EEA Guidebook is used.
Completeness 2D3a Emissions of Hg not estimated DE-2D3a-2019-0001 DE-2D3a-2019-0001 (ID reused) No
Completeness 2D3g Report PAHs from 2D3g Chemical Products DE-2D3g-2018-0001 DE-2D3g-2018-0001 (ID reused) DE-2D3g-2018-0001 (ID reused) No A project is planned to collect AD and EF for this emission source with the goal to calculate PAHs emissions. Results will be available in 2021 at the earliest, so emission reporting could not be done before submission 2022.
Completeness 5D2 NMVOC emissions missing although default EFs exist DE-5D2-2019-0001 DE-5D2-2019-0001 (ID reused) Yes Industrial wastewater NMVOC emissions were implemented and are part of the 2021 reporting.
Completeness GRID Add gridded emissions of Cd, Pb, Hg, PCDD/F, PAHs, HCB, PCBs to reporting DE-GRID-GEN-2020-0001 Yes
Completeness LPS Add missing pollutants PAHs, PCBs, PM2.5 DE-LPS-GEN-2020-0001 No Since these pollutants are not in the ePRTR dataset, Germany cannot report them.
Aspect Sector Finding Sumamry CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 NECD 2020 Implemented Official Comment for IIR
Accuracy 2D3a Rationale for not estimating emissions in category 2D3a and notation key selection DE-2D3a-2018-0001 DE-2D3a-2018-0001 (ID reused) DE-2D3a-2018-0001 (ID reused) No Germany is in the process of evaluating data to calculate emissions of Hg from the use of fluorescent tubes.
Accuracy LPS Check emission data for facility “Heyne & Penke Verpackungen GmbH” DE-LPS-E-2020-0001 Yes

NECD 2019

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Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Transparency 1A1 Presents its NH3 EF for stationary combustion in the next submission of its IIR, justify the use of these and compare these against the values in 2016 EMEP/EEA Guidebook. DE-1A1-2017-0001 DE-1A1-2018-0001 DE-1A1-2017-0001 (ID reused) No A comparison with default values is not possible
Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Consistency 1A4bii Significant fluctuations in fuel consumption over the time series DE-1A4bii-2019-0001 No
Consistency 1A4cii IEF Cd trend since 2007 erratic DE-1A4cii-2018-0001 DE-1A4cii-2018-0001 (ID reused) No All issues regarding the inconsistency of activity data from the National Energy Balance (NEB) can only be resolved as soon as the ongoing internal revision process launched by the provider of the NEB has been finished.
Consistency 1A4ciii Large increase in AD from 2015 to 2016 DE-1A4ciii-2018-0001 DE-1A4ciii-2018-0001 (ID reused) No All issues regarding the inconsistency of activity data from the National Energy Balance (NEB) can only be resolved as soon as the ongoing internal revision process launched by the provider of the NEB has been finished.
Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Comparability 1A4ai Implied EFs PAHs and PCDD/F are outliers compared to other member states DE-1A4ai-2019-0001 No An improvement of PAH Emission factors is planned. Currently a measurement Project is running.
Completeness 1A2a NE reported for Cadmium although a default EF is available DE-1A2a-2019-0001 Yes
Completeness 1A2b NE reported for some pollutants although default EFs are available DE-1A2b-2019-0002 Yes
Completeness 1A2b NA is reported for HCB 1990 DE-1A2b-2019-0001 No
Completeness 1A3b PCB emissions missing for all years although default emission factors are available DE-1A3b-2019-0001 Yes emissions calculated based on default EF
Completeness 1A3c Update notation key from NE to NA DE-1A3c-2019-0001 Yes
Completeness 2B3 Include the NOx emissions in the next submission preferably using a country specific method to account for the specific technologies and abatement equipment applied. DE-2B3-2017-0001 DE-2B3-2018-0001 DE-2B3-2017-0001 (ID reused) Yes
Completeness 2B6 Include the NOx emissions in the next submission. DE-2B6-2017-0001 DE-2B6-2018-0001 DE-2B6-2017-0001 (ID reused) No Germany will look into possible implementations for this in the future. Not reported 2018.
Completeness 2C1 Potential under-estimate of emissions of HCB DE-2C1-2018-0001 DE-2C1-2018-0001 (ID reused) Yes Data acquisition for the resolution of this issue will be implemented in the framework of a research project updating several emission factors. The effort is scheduled to start in 2021 and will take about 3 years. Until then, the default emission factor from the EMEP/EEA Guidebook is used.
Completeness 2D3a Emissions of Hg not estimated DE-2D3a-2019-0001 No
Completeness 2D3g Report PAHs from 2.D.3.g Chemical Products DE-2D3g-2018-0001 DE-2D3g-2018-0001 (ID reused) No A project is planned to collect AD and EF for this emission source with the goal to calculate PAHs emissions. Results will be available in 2021 at the earliest, so emission reporting could not be done before submission 2022.
Completeness 5A Include NMVOC and PM2.5 emissions from 5.A in its next submission. DE-5A-2017-0001 DE-5A-2018-0001 DE-5A-2017-0001 (ID reused) Yes Implemented in 2020 reporting. Although only the reporting of NMVOC and PM2.5 emissions was requested, Germany decided to additionally report PM10 and TSP.
Completeness 5C2 Emission are not estimated for PCDD/F, Pb and Cd although default EFs are available DE-5C2-2019-0001 Yes Default-EF used, emissions reported.
Completeness 5D2 NMVOC emissions missing although default EFs exist DE-5D2-2019-0001 No Ongoing process
Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Accuracy 1A1a Include the revised estimate of activity data and emissions for biogas in its next submission. DE-1A1a-2017-0003 DE-1A1a-2018-0001 DE-1A1a-2017-0003 (ID reused) Yes Implemented in 2020 submission
Accuracy 2D3a Rationale for not estimating emissions in category 2D3a and notation key selection DE-2D3a-2018-0001 DE-2D3a-2018-0001 (ID reused) No Germany is in the process of evaluating data to calculate emissions of Hg from the use of fluorescent tubes.
Accuracy 3B Tier 1 method used for key category DE-3B-2019-0001 Yes Implemented in 2020 reporting

NECD 2018

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Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Transparency 1A1 Presents its NH3 EF for stationary combustion in the next submission of its IIR, justify the use of these and compare these against the values in 2016 EMEP/EEA Guidebook. DE-1A1-2017-0001 DE-1A1-2018-0001 DE-1A1-2017-0001 (ID reused) No A comparison with default values is not possible
Transparency 1A1b Include the country specific EFs for combustion in refineries in the relating chapter of its IIR to improve transparency. § 55 DE-1A1b-2017-0001 DE-1A1b-2018-0001 No Emission factors are under revision. New emission factors will be included in the IIR following completion of the running refinery project.
Transparency 1A3bi Incorrect notation keys for activity data DE-1A3bi-2018-0002 Yes notation keys replaced by activity data values
Transparency 1A3bv Incorrect notation keys for HCB and PCB emissions DE-1A3bv-2018-0001 Yes 'NE' replaced by 'NA' as suggested by the TERT
Transparency 2D3d Include explanation on recalculation to 1994 in the next submission. DE-2D3d-2017-0001 DE-2D3d-2018-0001 Yes Was reported in submission 2019.
Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Consistency 1A4cii IEF Cd trend since 2007 erratic DE-1A4cii-2018-0001 DE-1A4cii-2018-0001 (ID reused) No All issues regarding the inconsistency of activity data from the National Energy Balance (NEB) can only be resolved as soon as the ongoing internal revision process launched by the provider of the NEB has been finished.
Consistency 1A4cii Inconsistent AD values NFR vs. IIR DE-1A4cii-2018-0001 Yes no more inconsistency between NFR and IIR
Consistency 1A4ciii Large increase in AD from 2015 to 2016 DE-1A4ciii-2018-0001 DE-1A4ciii-2018-0001 (ID reused) No All issues regarding the inconsistency of activity data from the National Energy Balance (NEB) can only be resolved as soon as the ongoing internal revision process launched by the provider of the NEB has been finished.
Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Comparability 5C Hg EF is 100 times smaller than the default value proposed in the 2016 EMEP/EEA Guidebook and the Cd and Pb EF are 1000 times smaller than the default values proposed in the 2016 EMEP/EEA Guidebook DE-5-2018-0001 Yes References to research Projects of CS-EF added
Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Completeness 1B2aiv Potential under-estimate of emissions of Hg, Cd, PCDD/F DE-1B2aiv-2018-0001 No Metal and PCDD/F emissions are not considered as fugitive. If IE would be used nevertheless one can assume there are such fugitives. Germany suggest to keep the notation key NA.
Completeness 2B3 Include the NOx emissions in the next submission preferably using a country specific method to account for the specific technologies and abatement equipment applied. DE-2B3-2017-0001 DE-2B3-2018-0001 DE-2B3-2017-0001 (ID reused) Yes
Completeness 2B6 Include the NOx emissions in the next submission. DE-2B6-2017-0001 DE-2B6-2018-0001 DE-2B6-2017-0001 (ID reused) No Germany will look into possible implementations for this in the future. Not reported 2018.
Completeness 2C1 Potential under-estimate of emissions of HCB DE-2C1-2018-0001 DE-2C1-2018-0001 (ID reused) No please see table for NECD 2019 (with the same ID)
Completeness 2C3 Include NOx from aluminium production in the next submission to improve completeness and comparability. DE-2C3-2017-0001 DE-2C3-2018-0002 Yes Germany carefully assessed the situation regarding this issue and concluded, that no substantial NOx emission are to be expected from this source. But in order to avoid an underestimation Germany implemented the default EF of the emission guidebook 2019.
Completeness 2C3 Potential under-estimate of emissions of HCB DE-2C3-2018-0001 Yes Data acquisition for the resolution of this issue will be implemented in the framework of a research project updating several emission factors. The effort is scheduled to start in 2021 and will take about 3 years. Until then, the default emission factor from the EMEP/EEA Guidebook is used.
Completeness 2D3g Report PAHs from 2D3g Chemical Products DE-2D3g-2018-0001 DE-2D3g-2018-0001 (ID reused) No A project is planned to collect AD and EF for this emission source with the goal to calculate PAHs emissions. Results will be available in 2021 at the earliest, so emission reporting could not be done before submission 2022.
Completeness 5A Include NMVOC and PM2.5 emissions from 5A in its next submission. DE-5A-2017-0001 DE-5A-2018-0001 DE-5A-2017-0001 (ID reused) Yes Implemented in 2020 reporting. Although only the reporting of NMVOC and PM2.5 emissions was requested, Germany decided to additionally report PM10 and TSP.
Completeness 5D Include the estimation of NMVOC emissions from wastewater treatment plant in its next submission. DE-5D-2017-0001 DE-5D-2018-0001 Yes
Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Accuracy 1A1a Include the revised estimate of activity data and emissions for biogas in its next submission. DE-1A1a-2017-0003 DE-1A1a-2018-0001 DE-1A1a-2017-0003 (ID reused) Yes Implemented in 2020 submission
Accuracy 2D3a Rationale for not estimating emissions in category 2D3a and notation key selection DE-2D3a-2018-0001 DE-2D3a-2018-0001 (ID reused) No Germany is in the process of evaluating data to calculate emissions of Hg from the use of fluorescent tubes.

NECD 2017

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Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Transparency 1A1 Presents its NH3 EF for stationary combustion in the next submission of its IIR, justify the use of these and compare these against the values in 2016 EMEP/EEA Guidebook. DE-1A1-2017-0001 DE-1A1-2018-0001 DE-1A1-2017-0001 (ID reused) No A comparison with default values is not possible
Transparency 1A1a Improves the transparency of its IIR regarding PM2.5 shares used for each fuel (solid fuels (coal and lignite) and gaseous fuels, but also biomass if relevant). DE-1A1a-2017-0001 Yes
Transparency 1A1b Include the country specific EFs for combustion in refineries in the relating chapter of its IIR to improve transparency. § 55 DE-1A1b-2017-0001 DE-1A1b-2018-0001 No Emission factors are under revision. New emission factors will be included in the IIR following completion of the running refinery project.
Transparency 1A2gviii Improve the transparency of the IIR to explain its assumptions on the PM2.5 fraction used for each fuel and particularly for liquid fuels, biomass and other fuels. DE-1A2gviii-2017-0001 Yes
Transparency 2A1 Include the explanation and rationale for using two sets of activity data to be included in the IIR for the next submission. DE-2A1-2017-0001 Yes
Transparency 2C Update the SO2 emission factors for 2C5, 2C6 and 2C7a for the next submission to reflect the individual production activities and to include more transparent information on primary vs. secondary production of lead, zinc and copper in the IIR. DE-2C-2017-0001 Yes
Transparency 2D3d Include explanation on recalculation to 1994 in the next submission. DE-2D3d-2017-0001 DE-2D3d-2018-0001 Yes Was reported in submission 2019.
Transparency 3B Include the information for the proportional of NO-N and N2 and the reference in the IIR to improve transparency. DE-3B-2017-0002 Yes
Transparency 3B2 Mention that NFR 3B2 includes lambs and also explain the lower EF NMVOC used for lambs. Furthermore, the TERT recommend that Germany in IIR mentioned that pullets are included in NFR 3B4giv other poultry. DE-3B2-2017-0004 Yes
Transparency 3F Include more information in the IIR for the next submission, referring to the specific law and clarifying from which year the ban came into force. Furthermore, it is recommended to inform whether there are derogations for field burning under certain circumstances or for certain crop types. DE-3F-2017-0001 Yes
Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Consistency 1A2 Use the right notation keys in the NFR tables for its next submissions. (1A2 Stationary Combustion in Manufacturing Industries and Construction, PM2.5, 2005-2015) DE-1A2-2017-0001 Yes
Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Comparability 3Da1 Use the updated emission factors available in the 2016 EMEP/EEA Guidebook (Table 3.2) for the next submission. DE-3Da1-2017-0001 Yes
Completeness 2B10a Investigate whether flaring occurs in relation to carbide production e.g. by contacting the single producer of carbide. DE-2B10a-2017-0002 Yes Flaring is a common destruction technic in chemical industry. But no information exists to assign flaring quantities to a single installation.
Completeness 2B3 Include the NOx emissions in the next submission preferably using a country specific method to account for the specific technologies and abatement equipment applied. DE-2B3-2017-0001 DE-2B3-2018-0001 DE-2B3-2017-0001 (ID reused) Yes
Completeness 2B6 Include the NOx emissions in the next submission. DE-2B6-2017-0001 DE-2B6-2018-0001 DE-2B6-2017-0001 (ID reused) No Germany will look into possible implementations for this in the future. Not reported 2018.
Completeness 2C3 Include NOx from aluminium production in the next submission to improve completeness and comparability. DE-2C3-2017-0001 DE-2C3-2018-0002 Yes Germany carefully assessed the situation regarding this issue and concluded, that no substantial NOx emission are to be expected from this source. But in order to avoid an underestimation Germany implemented the default EF of the emission guidebook 2019.
Completeness 3Da2b Include the emission from sewage sludge applied to agricultural soils in the next submission. DE-3Da2b-2017-0001 Yes
Completeness 5A Include NMVOC and PM2.5 emissions from 5A in its next submission. DE-5A-2017-0001 DE-5A-2018-0001 DE-5A-2017-0001 (ID reused) Yes Implemented in 2020 reporting. Although only the reporting of NMVOC and PM2.5 emissions was requested, Germany decided to additionally report PM10 and TSP.
Completeness 5D Include the estimation of NMVOC emissions from wastewater treatment plant in its next submission. DE-5D-2017-0001 DE-5D-2018-0001 Yes
Completeness 5E Although the Guidebook has methods for car and house fires in Chapter 6, it may be more transparent to include these in Chapter 7 as Chapter 6D is more focused on compost and sludge. The ERT encourages Germany to consider including some of these emissions in the next submissions. § 116 §139 DE-5A-2017-0003 Yes
Aspect Sector Finding summary CLRTAP 2010 CLRTAP 2014 NECD 2017 NECD 2018 NECD 2019 Implemented Official Comment for IIR
Accuracy 1A1a Include the revised estimate of activity data and emissions for biogas in its next submission. DE-1A1a-2017-0003 DE-1A1a-2018-0001 DE-1A1a-2017-0003 (ID reused) Yes Implemented in 2020 submission

CLRTAP 2010 & 2014

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2014

2010