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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
NECD 2018
NECD 2017
CLRTAP 2014
CLRTAP 2010
Aspect | Sector | Finding summary | CLRTAP 2010 | CLRTAP 2014 | NECD 2017 | NECD 2018 | NECD 2019 | NECD 2020 | NECD 2021 | Implemented? | Official Comment for IIR |
---|---|---|---|---|---|---|---|---|---|---|---|
General | Provide a PDF version of the IIR for offline use and to better facilitate the review process | § 6 9 11 28 | § 17 | No | The current Wiki platform isn't able to export a whole site to PDF. But we can provide an offline HTML version with full navigation. | ||||||
Aspect | Sector | Finding summary | CLRTAP 2010 | CLRTAP 2014 | NECD 2017 | NECD 2018 | NECD 2019 | NECD 2020 | NECD 2021 | Implemented? | Official Comment for IIR |
QA/QC | Fully implement the QA/QC system for the air pollutant emission inventory. If possible implement a unified QA/QC system for reporting to CLRTAP and UNFCCC. | § 21 24 62 74 88 105 | § 37 44f | No | Ongoing discussion | ||||||
QA/QC | Widen the use of the existing QA/QC system used for the set of activity data as well as the methods and emission factors for GHGs for the needs of CLRTAP/NECD inventories and providing further details on its implementation in the IIR (general and sectoral descriptions). | § 33 40 | § 16 69 84 87 103 105 | No | Ongoing discussion | ||||||
Aspect | Sector | Finding summary | CLRTAP 2010 | CLRTAP 2014 | NECD 2017 | NECD 2018 | NECD 2019 | NECD 2020 | NECD 2021 | Implemented? | Official Comment for IIR |
Transparency | Inaccuracies were found in the use of notation keys and it is recommended to justify the use of notation keys in the IIR for each particular sector. | § 38 | § 19 | Partly | Information tables for NE & IE were added to the completeness chapter of the current IIR | ||||||
Transparency | Provide more detailed information on the rationale for recalculations at a sectoral level to compliment the information already provided in the recalculation tables per pollutant. | § 30 43 90 107 | Yes | ||||||||
Transparency | 1A2a\1A2b\2C | For iron & steel there is a mix of reporting under 1A2a (PM & CO) 2C1 (NOx SOx VOC NH3) and “NE” (HMs and POPs). For non ferrous metals similar issues are observed. The recommendation is to explain the rationale for reporting in different source categories as well the rationale for NEs. NE reporting should be avoided as much as possible e.g. by applying Guidebook Tier 1 EFs. | § 48 49 | Yes | The reporting in the different source categories is explained in the IIR. | ||||||
Transparency | 1A2gviii | The ERT recommends that Germany include details of the units of AD used in its estimations as this was not always the case. | § 51 | Yes | |||||||
Transparency | 1A3b | Explain in more detail the emission calculation for road transport not only by saying that HBEFA and TREMOD are used but giving more information including an overview of emission factors in the next versions of the IIR. | § 65 | § 72 | Yes | ||||||
Transparency | 1A4 | Provide more detail on the emission factors used including their applicability for the different years and sub-categories of the time series. Find EFs to estimate emissions for heavy metals (for example: using tier 1 in the EMEP Guidebook inventories in other countries). | § 52 | Yes | |||||||
Transparency | 3B | The ERT recommends including in the IIR information on the complete time series of the activity data description of emission drivers recalculations and improvements for the agriculture sector. | § 86 94 | Yes | |||||||
Transparency | 5A\5B\5C | Since all incineration is reported under energy add information about the methodology used for different types of waste incineration under NFR 1. In NFR 6C use the notation key “IE” instead of “NO” and to explain the use of the notation key in the IIR. | § 103 110 111 112 | § 136 | Yes | Information on methods used for estimation of energy-related is reported in NFR 1. Germany considers NO to be correct and explains the situation in its IIR. Cremation estimation is explained now. | |||||
Aspect | Sector | Finding summary | CLRTAP 2010 | CLRTAP 2014 | NECD 2017 | NECD 2018 | NECD 2019 | NECD 2020 | NECD 2021 | Implemented? | Official Comment for IIR |
Consistency | 1A1\1A2 | In the IIR in the “Short description” for 1A1 and 1A2 Germany presents a tier 2 or 3 approach. However during the review Germany indicated that only the tier 2 approach was used. This needs correction in the IIR (was agreed by Germany to do this) | § 47 | § 54 | Yes | ||||||
Consistency | 1A5 | The IIR says Tier 1 method is used for 1A5 but it is actually Tier 2/3. This should be corrected in the IIR. | § 53 | Yes | |||||||
Consistency | 3B | The activity data (animal numbers) is coming from various sources and some corrections are being done. It is recommended that Germany includes a table in the IIR showing the livestock numbers from different sources and the type of elaboration/correction that has been done. | § 94 | Yes | |||||||
Aspect | Sector | Finding summary | CLRTAP 2010 | CLRTAP 2014 | NECD 2017 | NECD 2018 | NECD 2019 | NECD 2020 | NECD 2021 | Implemented? | Official Comment for IIR |
Completeness | Emissions prior to 1990 are not reported. | § 27 | § 24 | Yes | |||||||
Completeness | 1A2a\1A2b\1A4\1B1a | Some emissions are not estimated for some pollutants: heavy metals and POPs for 1A2a particulates heavy metals and POPs for 1A2b heavy metals for 1A4 and NMVOC for 1B1a. The ERT recommends Germany to use the Guidebook default EFs if no other method is available. | § 36 | Partly | |||||||
Completeness | 1A3a | NH3 reported as NE. Recommendation to investigate the emissions or report as NO if emissions do not occur. | § 68 | Yes | The notation key 'NE' is used only for ammonia from aviation gasoline (as recommended in the 2016 EMEP Guidebook). For jet kerosene emissions are estimated. | ||||||
Completeness | 1B1a | In 2010 “NE” is indicated for particulates and “NA” for NMVOC but the Guidebook has EFs. It is recommended that Germany identifies the type of coal mining using the EFs from the EMEP Guidebook or other references to estimate emissions for this sector. In 2014 NMVOC was reported as NE and the ERT recommends Germany to describe why NE is reported (emissions assumed negligible). | § 54 | Yes | |||||||
Completeness | 2C1 | Include emissions for dioxins and heavy metals based on new research project. | § 80 81 | Yes | |||||||
Completeness | 3D | The ERT encourages Germany to estimate PM10 and PM2.5 emissions for 3D in future submissions following the EMEP/EEA Guidebook recommendations. | § 98 | Yes | |||||||
Completeness | 5A\5C\5D | The inventory regarding Waste is currently not complete with missing estimates for several source categories. | § 102 | § 134 135 | Yes | Industrial wastewater emissions implemented since 2021 reporting. Solid waste emissions implemented since 2020 reporting. Domestic wastewater emissions implemented since 2018 reporting. 5.C completed | |||||
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 | |||||
Completeness | 6 | Consider currently missing sources: NH3 emissions from Cats and Dogs from Zoo animals and human ammonia emissions etc. | § 116 | No | |||||||
Aspect | Sector | Finding summary | CLRTAP 2010 | CLRTAP 2014 | NECD 2017 | NECD 2018 | NECD 2019 | NECD 2020 | NECD 2021 | Implemented? | Official Comment for IIR |
Accuracy | Implement a (qualitative and quantitative) uncertainty analysis and use the results to prioritize improvements to the inventory | § 20 24 | § 32 44e 85 | Yes | |||||||
Accuracy | 1A1b\1A1c\2 | Improvement from Tier 2 to Tier 3 using plant-specific data for some industrial processes including cement production as well as for large combustion plants (e.g. 1A1b 1A1c) | § 19 41 45 46 | Partly | Included for large combustion plants no plant-specific data for cement production | ||||||
Accuracy | 2A1 | Cement production is a key source for Hg HCB and for NOx PM10 and PAH but Tier 1 is used. The ERT encourages Germany to use plant-specific data collected as part of the LCPD IPPC and E-PRTR to develop a tier 2 or 3 methodology in the near future and to document these in its IIR. | § 79 | § 88 | Yes | plant-specific data approach is not planned | |||||
Accuracy | 2L | Include results of ongoing research project to improve from Tier 1 to higher Tier methodology. | § 82 83 | Yes | |||||||
Accuracy | 3B | There were errors in the calculation of N excretion rates it is recommended that Germany corrects this. | § 97 | Yes | |||||||
Aspect | Sector | Finding summary | CLRTAP 2010 | CLRTAP 2014 | NECD 2017 | NECD 2018 | NECD 2019 | NECD 2020 | NECD 2021 | Implemented? | Official Comment for IIR |
Comparability | 1A2\2 | Germany reports emissions from sugar production in source category 2D2. It is recommended to report these emissions under 1A2e and include a more detailed description of the sub-categories the methodology used the source of activity data the source of EFs and consistency across the time series (1990-2008). | § 50 | Yes | Reporting of NMVOC and PM emissions from sugar production in 2H2 (used to be 2D2) is correct according to the Inventory Guidebook 2016. | ||||||
Comparability | 1A3di(ii)\1A4ciii | Emissions reported as IE. The ERT encourages Germany to make separate emission estimates for these sectors in future IIR reports and in the meantime a separate summary table of all categories (fully or partially reported as IE) and where they have been moved would be beneficial. | § 69 | Yes | |||||||
Comparability | 1A4aii | Emissions for main pollutants were reported as IE. The ERT encourages the Party to investigate further statistical resources for missing estimates in this sector and include a progress report within the next IIR. | § 67 | Yes |