Doc Guidebook

8/20/2019 Doc Guidebook

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

There are separate wor!sheets in this file#

- eneral comments# addresses comments that are generic and not specific for a certain chapter - eneral uidance comments# comments addressing eneral uidance chapters" $omments are sorted by chapter- %ectoral - te&tual comments# comments addressing the te&t in one of the technical chapters" $omments are sorted b- %ectoral - F comments# comments addressing emission factors in one of the tables in the technical chapters" $om



Comment

$omment relates to unc chapter (not in the drop menue)# *lease ma!e reference to the re+uirements in the ,,

The formulas do not appear uniform# in some cases the legend is missing"

,n copying te&t from the ,*$$ s. fre+uently inappropriate reference to / inventories remains" This must bechec!ed and corrected everywhere"

The references in Tables don0t have correspondence in reference list" ,t0s often impossible to understand where th

original emission factors are retrieved" The reference# uideboo! (26) or $*,* (23) are not acceptable.they wor! as 4$hinese nested bo&es4# substitute with original references5 Also the reference 4isschedi7!. 234 isnot a reference to the wor! where the user can found F and detailed e&planation of their derivation" Thereference spreme what means# the reference must be to a document where the methodology to derive Fs ise&plained"

The table 8"1 of the model chapter (cement as agreed in 9essau) is not implemented in many chapters (e"gtransport). it provides the necessary overview of where emissions are to be e&pected or not" *lease include asimilar table in all chapters"

,n the bo& 4ma7or changes since previous versions4 please remove the remar! on Tiers and the Thessaloni!imeeting" :n the other hand the comment in this bo& should be chapter specific. for e&ample poit out if methods oemission factoes have been revised (which rarely is included). please add this information" This comment isgeneric to the entire guideboo!"

Figure and table numbering is not harmonised throughout the revised uideboo!. this must be ensured beforepublishing

verywhere where appropriate the new name of the uideboo! must be used (the name change will almostcertainly be approved)

The new uideboo! must clearly describe where emissions of / and *:*s are e&pected emitted (ir note&pected) (this is in line with the scope of the pro7ect)" The version sent out for review has many gaps in thisrespect" Furthermore improvements in information on / and *:*s are e&pected through support by ermany

and the 'etherlands. this information must be included in the ne&t version (prior to the TF,* meeting)The figures do not appear uniform" The e&planation for the blue arrows is missing from time to time (but e"g"$hapter 2"A"1" Figure 2-1 is :;) and in some cases heat (or fuel) are not denoted" %ee below

The draft uideboo! use a mi&ed terminology for substance vs (air) pollutants. please consult the uidelines andharmonise te&t everywhere

The uidelines use the term 4;ey category4 (agreed by TF,*). the < mus be consistent with this decisions (te&and decision trees) (in the current draft both terminologies are used. even within the same chapter. while !eysource is most fre+uently used)

:ne ob7ective of the pro7ect is to facilitate maintenance" 'evertheless. throughout the uidelines there is a lot ofrepetition of information" &amples are definition of T$$$A and reference to the uidelines" *lease ensure thatsuch repetiton as far as possible is avoided"

The uideboo! is endorsed by the $onvention. conse+uently the term *arty is correct (and not %). and the <must be written this way (the current draft not alwyas is)" /owever a statement can be given to e&plain the role ofthe uideboo! under '$" The term 4country4 is neutral

The whole draft needs to undergo a proper =A>=$ by the consultantst. in the draft many references are missing.tables refereces are not correct. terminology (outline>numbering) is inappropriate>inconsistent and copy and pastemista!es ma!es part of the te&t meaningless



*ollutant subscripts eg '/8. %:& ':& etc" *lease standardise across all chapters

eferences- for three authors or more in the te&t use %urname et al (year)" *lease standardise across all chapters

%cientific improvements# ,n the agreement betweeen the $ommission and * in starting this pro7ect some toppriority scientific improvements were setteled" , have loo!ed into a couple of these# i) for solvent use some of theT2 emission factors given are 1? years old (the rest are more than 1) (e"f domestic solvent use. some solventchapters 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 incinerationchapters have not been updated" All these are e&amples of sectors where technology has been changing and it isli!ely that the provided information is outdated" /opefully the consultans can fill these gaps before the ne&t versiois sent for review"

,n some cases different technologies>abatment system are defined introducing Fs for each technology (fore&ample for olume 2$) in some case new technologies>new products are introduced under abatment (fore&ample for olume 8)" ,t0s better to produce alwaays Fs tables (non reductions) with technology>products andput them in section 8"8"2" , thin! the approach must be uni+ue5

$omment relates to unc chapter (not in the drop menue)" *lease cite the last draft uidelines (same comment tobe sec @ of this chapter)

eneral guidance# throughout the chapters 0!ey categories0 is interchangabley used with 0!ey sources0" A variety ocapitalisation is also used# ;ey %ource. !ey sources etc" *lease standardise across all chapters (it should be !ey

category in the '$ conte&t)The number of signicant digits provided throughout the different chapters vary greatly" "g" "1 (ead - esidential- <iomass - Fireplaces) and "12336@ (ead - esidential - %olid fuels - %toves)

A contact address would be e&termely helpful (in order to refer any +uestions to > to report additional evidence)"*robably. the &pert *anel chairs are most appropriate to be mentioned"

'umbering of tables and figures in general guidacne chapters needs standardising" %ometimes Fig 1. Fig 2 etc isused. other times Fig B"1. Fig B"8 is used where B is the section number - *lease standardise across all chapters

,n far too many instances. material copied and pasted from ,*$$ uidelines still contains inappropriate referenceto eg other sections or olumes of the ,**$ docs" *lease chec! and correct across all chapters

Terminology" ,n several general guidance chapters mention is made of reporting obligations for signatories (orsignatory *arties etc) to the various $onvention protocols" The obligations are actually only placed on *arties that

have ratified the protocols (i"e" a number of parties have signed but not ratifed protocols)" *lease correctterminlogy across all general guidance chapters

eneral guidance chapters# references to a *arty to the $onvention should have a capital *" ember %tatesshould also be capitalised" *lease standardise across all chapters

,n many places the 26 draft < cites the previous < for emission factors" ,t was agreed at the A meeting in9ublin that this only would be a last resort (7fr page 8 of the minutes)" This must be updated where the originalreferences are available in the current version of the < (in most cases it is)" Furthermore. the referencing to thecurrent version of the < is different in different chapters"

Chen all tables are e+uipped with a column providing the unit it is incomprehensible why this has not been utilisedto ensure more meaningful emission factors. e"g" 3 mg>D instead of "3 g>D"

eneral guidance# several times $AFE is used with accent on the . please correct to $AF" *lease standardiseacross all chapters%ome general guidance chapters use footnotes to provide reference details. while other references are included inthe reference list" ,f a reference list is included ina chapter avoid use of footnotes"

%tyles - not consistent across general guidance chapters i"e" sometimes evel one headings are A $A*%.sometimes %entence case. sometimes Title $ase" 'eeds to be standardised"

eference list provided in each chapter - should be alphabetical. in ascending date of publication and followingconsistent format i"e" authors (year) Title etc" *lease standardise across all chapters

The references need chec!ing in all general guidance chapters ( sector chapters)" ,n a number of casesreferences appear in the te&t but not in the reference list and vice versa

Abbrevaiations are not always e&plained" , recommend an e&planation in the general volume or separately in thevolume on each sector"



'eed a consistent use of $TA*. TA* or TA* $onvention - all three are used interchangably" *leasestandardise across all chapters (to TA* $onventionG)



Action taken Comments

Accepted

'oted 9one for as far as possible

Accepted 9one for most chapters

Accepted

Accepted 9one

Accepted

Accepted emains to be done" Chat is e&actly meantG

Accepted 9one

Accepted 9one

Accepted

Accepted Try to do this as much as possible

Accepted 9one

Accepted

Accepted 9one se country as much as possible to avoid this issue

Accepted 9one. at least to a large e&tent

Proposeddecision

Try to avoid this as much as possible" $hec! mainlythe chapters for these errors5

As agreed. we will ta!e Fs from (peer-reviewed)literature or at least publicly available references asmuch as we can" /owever. in +uite a number ofcases we don0t have anything better5

, assume it is meant to fill the 4'ot Applicable4 and4'ot stimated4 bo&es with all relevant pollutants"

evised in many cases"$omment about Tiers removed"

Chat is the e&act new nameG ,0m not sure" emainsto be done"

egends to be completed with every formula whereappropriate

The F tables will clearly display if emissions of eachpollutant are e&pected for this source category(according to reporting template)" All contributionsfrom ermany 'etherlands will be included in final

draft"ore e&planations added to thefigures where necessary

Ce0ll try to avoid unneccessary repetition. but must!eep in mind that the uideboo! is over 1@ pages



'oted

e7ected

Accepted 9one

Accepted 9one

Accepted

Accepted

Accepted

Accepted $hec!ed

'oted

Accepted 9one

Accepted 9oneditorial 9one as much as possible

'oted

ditorial 9one

'oted

Accepted $hec!ed

Accepted $hec!ed

Accepted 9one

Accepted 9one

Accepted

%olvent use - All chapters e&cept domestic use (forthis one no new information available) have beensignificanly updated with input from the industry. ,therefore do not agree with this comment"

Fugitives chapter has been updated in consultationwith $:'$AC"Caste incineration - no other new emission factorsavailable"

This approach was presented already in 9essau(ay 2@) and approved for as far as , !now" 'otime to change it now"

$hec!ed. corrected where toomuch digits

6 digits too much. does not reflect the uncertainty ofthe numbers

emains to be done. but decision on this is neededbefore"

9one. B-& used where B issection number

eferencing to old uideboo! harmonised" Ce0ll referto original literature as much as possible"

Footnotes sometimes e&plain more than 7ust thereference"

To be discussed. one glossary might indeed be betterthan separate ones in each chapter



Accepted/armoniHed in chapters asmuch as possible



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Comment Action taken

'oted Amended

Accepted

Accepted

Accepted 'ot sure what this is referring to

'oted Te&t amended

e7ected %elf evident

e7ected

Accepted trac! changed (page 2. lines 83-8J)

e7ected

'oted

AcceptedA0s T/' uropean""" ditorial

typo - change to to in" ditorial

Accepted

uidelines - first time of use properly define and reference ditorial

Accepted Te&t amended

Proposeddecision

*roper references should be given to $ legislation and$onvention etc mentioned in the te&t

, felt Appendi& $ 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 inethodological choice chapter - 7ust present this Fuelsinformation once (i"e" in the more technical ethodologicalchapter)

Appendi& A (pollutants) and Appendi& < (sectors) shouldbe deleted" ,nstead reference should be made to theuidelines which is the single source where thisinformation should be defined" Also helps future-proof thete&t and removes potential user confusion - e"g" alreadythere are inconsistences between the pollutant list withwhat is in the latest uidelines

These sentences should be deleted - not future proof (i"e"will be out of date in ne&t years version of the < already)

idiculous statement# there is a relationship between theresources allocated and the reliability of the emissioninventory

%ome 0scene setting0 is needed. to e&plain the importanceof emission inventories

%'A* is developed by TF,* not T$. in the past therewas a %'A*>':% committe in cooperation between Aand uropstat"

The current uideboo! credits theT$>A

'F was further developed in 26 and 2@ in revisingthe s. please correct

*lease also provide information on the improvementsmade to / and *:*s through the support by ermanyand the 'etherlands

The Tas! Force relies on. and isgrateful for. contribution from anumber of countriesK it would beinvidious to ac!nowledge allcontributions"

*lease specify that only Tier 1 and Tier 2 methods havebeen updated" any needs for updating Tier 8 methodshave been identified. but were outside the scope of thispro7ect"

The previous version referred only to%imple and 9etailed methods. thete&t has been revised"

%'A*J@ was developed by $,T*A or T$>Arespectively G

The current uideboo! credits theT$>A

%ignatories do not have reporting obligations - only partiesthat have ratified do (many *arties have signed but notratified protocols)" 'eeds rewording throughout chapter

Te&t amended to Lcountries thathave ratified $onvention *rotocols

$hange wording of 0updated where necessary0 i"e" not allneeded updates have been done by this pro7ect



typo - hereafter $A9 ditorial%uperscript the footnote reference 1 ditorial

Accepted Te&t amendedtypo - word uideboo! missing ditorial

Accepted

ditorial

'oted Te&t amended"

'oted

Accepted9elete 2? - not future proof ditorial

Accepted

ditorial9elete 0and actors0 - its 7argon ditorialparties should have capital * throuighout chapter ditorial

ditorial eplaced All

Accepted

Accepted

'oted Te&t amended

,nclude info what is the purpos of this section Accepted

e7ected

'oted

$onvention - first time of use please write out formal nameof $onvention. define abbreviation (see general comment)and properly reference

Appendi& A should be dleted" ,t0s already inconsistent withthe latest " se instead te&t such as 0for thosepollutants for which reporting is re+uired as defined in the* reporting guidelines

$orrect typos in these bullets - procedures. users to. levelsof

;yoto protocol and ,**$ uidelines should be properlyreferneced at their first time of use

*lease insert compliance chec!ing under the *rotocols ofthe $onvention and an e&plicit reference to *modelling activities (disopersion and integratedassessment)

$ompliance chec!ing is alreadyincluded" There is reference tosuitability for monitoring" * isnow referenced directly"

*lease delete te&t 4%uch a !nowledgeL4 under rest of thesentence. this does not belong here

missions data is no longer reported to '$%ecretariat (now to $,*)" eword

'$ - reference this and defien abbreviation which is laterused - '$9 etc

*lease use the e&act wording of the last version of theuidelines (consult the %ecretariat)" The term 4emberstates4 must ':T appear. but 4*arties4

*lease chec! - 9efintions of T$$$A elements here needto be identical to the defintions used in the latest draftuidelines

9efinitions are now based on the,*$$ 26 uidelines"

,nclude para on ecalculations - it is very important andshould be highlited

A 'ote has been added to theTransparency definition

consider to change 0this0 to 0relevant0 or 0appropriate0directive

%ection 8 $oncepts are introducedin lines @-J

consider to change 0$oncepts0 to 0lossary0 or channge thesystem of paras instead of alphabetic order group

sysetmetic ( it ta!es some time to undersatand whatsabout )

,ntorduction amended" '"<"eadersmight rightly e&pect a glossary to be

more comprehensive and 9efinitionsis e+ually confusing in this conte&t"

This paragraph states that the guideboo! covers allpollutants. however there are significant shortcomings withregard to /$< and *A/s" The *A/0s have for stationarycombustion been lumped together"

The comment is not relevant to thissection of the uideboo!"



e7ected

Accepted Te&t amended where possible

Accepted eplaced All

Accepted eplaced All

ditorial

'oted*arties0 should be *arty0s ditorialtypo - 0in that helps0 is missing a word(s) ditorial Added 4it4

*lease chec! - use of signatory versus ratified for the $ ditorial*arty T: theL ditorial

ditorialreplace covers with 0designed to0 ditorial changed to 0is designed to cover0

'oted

ditorial

Acceptedreplace gas with pollutant Accepted

Accepted

Accepted Te&t amendment made

Accepted te&t removedTe&t should be under the %cope section 'oted Te&t amended - no longer relevant

e7ected

T': will as a side pro7ect add information on new *:*sfor consideration into future protocols (also resulting fromproduct use)" *lease update the te&t accordingly

The Tas! Force relies on. and isgrateful for. contribution from anumber of countriesK it would beinvidious to ac!nowledge allcontributions"

*lease see general remar! to use of the term 4substance4

vs 4air pollutant4,n accordance with TF,*s decision. the uidelines areusing the term 4!ey category4. please be consistent withthe uidelines

terminology - do not use !ey source" The agreed termunder '$ is !ey category" $orrect here andthroughoput all chapters (also. do not captilisise this term ifused in middle of a sentence)

delete 0actual nature and0 " eproting formats are thesame for all directives . countries 7ust do not need tocomplete columns if not ratified protocols

consider to use 0$AT*0 and 0'$90 inventory instead of

TA* and '$ (trough the whole report)

* prefer TA*. '$ 9irective

used

The * should have been properly refernecedbefore. so donMt need full refernece and weblin! here

*ropose to delet Appendi& < in which case reference tothe Appendi& here should be removed

delete sentence - this is reporting specific and is different

for eg '$" ,nstead use te&t 0 A national total isLeachpollutnat and categories as defined in the repsectivereporting re+uirements

Added 4and category as defined inthe repsective reportingre+uirements4

consider to add sentence li!e 0elevant information shellbe provided in ,,0

delete reference to * uidance - is outdated andreplaced by -*T uideance" ,n any case , didnlKt seeany reference>common approaches with to *>-*Tuidance in later chapters so perhaps should be deleted"

*lease also introduce abatement as it fre+uently used in

compiling air pollutant inventoriesTe&t appears partly repetition of a prev paragrap. pleasestreamline

*refrably introductory te&t should be user manual li!e andnot a novel" ,t is not easy to find in the te&t what the useryou loo!ing after" $onsider to highlit the 0!ey words0 andother options to structure the te&t

'ot practical. would introduce toogreat a change to the style of thedocument"



e7ected

Accepted Footnote 2 added"typo - or ,% missing ditorial

ditorial

Accepted *aragraph deleted"

Accepted Te&t abridged*arties - capital * ditorialreword - secreatriate no longer receives data ditorialuidelines need to be properly referneced ditorial

ditorial

Accepted

'oted

ditorial

$onsider to reference also *% directive ditorial

ditorial

Chat !ind of !ey sources are you refering to. avaerage inurope or G $onsider e&planation as a foonoteG

;ey $atgories are now a defiedconcept in section 8"

,n the $hapter there is a Table 8-8 which provides therating definitions and typical error ranges used in theuideboo!"/owever. there are commonly used ratingdefinitions developed by the% *A" All of the emissionfactors in e"g" A*-32 are given an *A+uality rating" These

have been copied in previous versions of$orinair where*A F0s have been given":ther % institutes. eg A*, alsouse the same +uality codes"/owever. the *A +ualityrating definitions and those in Table 8-8are not the same.and this could cause confusion if the userof the uideboo!is not aware of this",t is proposed that a new paragraph isadded after line 22. page @.7ust before Table 8-8. asfollows#4,t should be noted that the definitions of emissionfactor +uality ratings given in Table 8-8 are not the sameas the definitionsused by the % *A" Chere emissionfactors developed by the % *A or other Americantechnical institutes are used. the % ratings A. < and $can be considered to be e+uivalent to the ratings A. < and$ in Table 8-8" /owever. % ratings 9 and can beconsidered to be e+uivalent to ratings $ and 9 in Table 8-8"The % *A has no e+uivalent to the $orinair rating as allemission factors developed by the *A are frommeasurement andnot from engineeering calculation"4

*lease change te&t to 4L report emission data to the$onvention to fulfil their obligations under the *rotocols"These protocols areL

4elevance4 has not previously been defined (page 3).and needs some more e&planation" The remaining te&t ofthe par appears redundant with previous te&t

To support more easy maintenance , propose not

repeating the information from the uidelines here" Thesame applies to following paragraphs (e"g '$ and'F$$$). the te&t should be made more general

The $onvention on long-rangeLand its abbreviationdoesn0t need defining in every new subsection"

use word pollutnats instead of species (species meanssoemthing else)

missions should be reported in the 'F format for yearB-2 by the 1Ith February each yearK that is not a realistic

propositionK between 1I and 8 of arch will be morerealistic

'o longer relevant - te&t has beenamended

emove bold formatiing for / legislation - this isnMtdone elsewhere

'o longer relevant - te&t has beenamended

9onMt have gapo between ' F$$$ - is not commonlydone



'oted'/8 not ammonia for consistency ditorial

Accepted Footnote removed"

Accepted

e7ectedlegislation. not aw Acceptedtypo in title ditorialthe the ditorial

typo - sources ditorial

e7ected

'oted


There is no mention of the on-going review of the '$9 -the te&t should be updated to reflect this

'o action ta!en. wherever possiblethe mention of time refereced eventshas been avoided for ease of futureupdating"

footnote 2 - has variuos superfluous sub-footnotenumbering included - delete" These documents shouldalso be fully references in the refernece list of the chaptetr

replace should with may" ,t isnMt 7ustified to ma!e such aconclusion here

'o mention of upcoming review of the - - te&tshould be updated to mention this important aspect

'o action ta!en. wherever possiblethe mention of time relative eventshas been avoided for ease of futureupdating"

9etails of the enrty into force of the protocol should begiven

The ;iev protocol . while adopted in28. has yet to come intor force"'o action ta!en. wherever possiblethe mention of time relative eventshas been avoided for ease of futureupdating"

The international *T started at the conference in io deDaneiro in 1JJ2 where all countries were in the so-called

Agenda 21 advised to establish a *ollutant elease andTransfer system" :$9 too! the lead for supporting theseactivities in close cooperation with ',TA and '*chemicals" After a series of regional conferences it wasdecided to focus on more technical support using thee&periences from countries having already a moreestablished *T"

eference to to ',TA and '*chemicals introduced"

,n 2I the tas!force was merged with the ,:$ *Tcoordination group and is now called the *Tcoordination tas!force" seful products are sofar aresource centre built by nvironment $anada and recentlya *T portal (www"*T"net) providing lin!s withinternational and national *T activities and informationsources (also by nvironment $anada)" ,n 2? a the

following documents are e&pected# An overview of +ualitycontrol methods (Australie en %*A). methods forestimating emissions from small and medium siHedenterprises (Finland). and emissions from product use('ordic $ouncil)" Dapan is wor!ing on a paper called%haring and $omparing. ma!ing lin!s between emissionsand statistical data li!e national product or number ofinhabitants



'oted'ot polluting. but pollutant ditorial

Acceptedlater that year0 replace with october 2J Acceptedreplace 13 with 22 Accepteddelete final sentence Acceptedreplace signatories with *arties ditorialembership of the TF,* and the e&pert panelsL Accepted*lease delete 4should allow for maintenance and4. Accepted9elete 4e&pert4 ditorialChat is the 4verification4 panelG 'oted Te&t has been amended

Accepted 9ublin te&t inserted

delete# and will be sub7ect toL etc

'oted te&t removed

ditorial9elete 2? - not future proof ditorial

e7ected

Acceptedse numbering instead of bullets Accepted

Accepted eference to $,* included

$onsider to include headings * . TF,* (and $,*) e7ected

'oted

',TA is in 2? supporting Armenia. $h,le. cuador.*anama and Togo with some plans for further support iniddle America

,nformation not relevant totheuideboo!"

mention that -*T also goes beyond re+uirements ofthe protocol (more polls. strciter thresholds)

Added 4it goes beyond there+uirements of the protocol.

covering more pollutants with stricterthresholds4

The te&t deviates slightly from the panel T: agreed in9ublin. is any difference 7ustifiedG

%entence changed due to earliercomment

*lease consider shortening. e"g describing all TF,*meetings would re+uire an annual update of theintroduction"

reword - maintenance of the technical content of theuideboo! is the responsibility of the TF,* e&pert panels

ma!e bold all the $:,'A,BB so the user can see thedevelopment"From the te&t it is not clear what is thecurrent system" At the end of this section should be clearlydefind how is refered current system and include also infoon new e&tended 'F main sectors"

necessary - this is 0additionalinformation0" uidance on using theuideboo! - and the lin! between'F and %'A* is provided in boththe ,ntroduction and the section onhow to use the uideboo!

te&t not updated" 9elete refernece to T$>A" %tateagain here that TF,* is responsible for the technicalcontent and A for hosting

$onsider to ,nclude para e&plaining the role of the *$entre on mission inventories and *ro7ections ($,*)http#>>www"emep-emissions"at>ceip>

necessary - this is 0additional

information0"

chec! - * is not formed by a protocol , believe (ite&isted before the convention)" eplace formed with0funded via0

The 1J?3 *rotocol on ong-termFinancing of the $ooperative*rogramme for onitoring andvaluation of the ong-rangeTransmission of Air *ollutants inurope (*)K 32 *arties" nteredinto force 2? Danuary 1J??"



Accepted

Accepted Te&t made more generic

Accepted

$apitalise ember %tates 'oted Add ;osovo to the list Accepted

%: report needs proper referencing 'oted

e7ected Appendicies removed

Accepted





e7ected Appendicies removed(b) add""" and emissions from $ultivation of ice e7ected Appendicies removed





Title of chapter and header is spelt wrong" ethodological5 ditorial $hanged title and headers

Accepted references have been revised

9T - 0develops the * emissions inventory basedon emission data from *arties0 - it doesn0t"

delete 'F$$$ and ;yoto and replace with '$ andTA* $onvention

roup %witHerland with ,celand etc and call FTA(uropean free Trade Area countries)

4ember %tates4 already removed infavour of 4*arties4

Te&t amended to ma!e it genericand. as elsewhere in the te&t.mention of dated information sub7etto regular review is avoided"

Appendi& 1 A *ollutants. The list of *:* does not matchwith list of the

,nclude in row 9io&ins# 4e&pressed as 4,nternational To&ic+uivalents4 ,-T=4

,nclude more clear definition of *2"I and *1 (possibly' 12831 standard NO 4real world4 *2"I and *1measurements always include larger particles)"

*lease add the additional *:*s proposed added to theprotocols (consult /ugo at T':)

consider to incclude column with aggregations used frogridding " %ee http#>>www"emep-emissions"at>fileadmin>inhalte>emep>doc>Anne&,,,PPAggregationPPgriddedPPdataPDan2?"doc

, suggest to include in Appendi& < 4%ectors by 'F code4correspon- ding %'A* code

*lease use the latest version. consulting ;atarina (<A-

) Qthere are some smaller differencesR

Table 4Fuel4# For all pollutants e&cept $:2 it doesn0 ma!emuch sense to divide %C into biomass and fossilfractions because emission factors will be available onlyfor total %C"

The claim that the guideboo! includes default emissionfactors for all sources and pollutants where applicable issimply not correct" The guideboo! should containguidance. but many pollutants from many sources arelisted as not estimated"

eneral# please also define natural vs anthropogenic

(included in national totals)*lease append a list of abbreviations (%'A*. TA*.TF,*""")

$hapter contains many cross references to other ,*$$olumes. ,*$$$ uidance sections" All need deleting orrewording



e7ected

typo - uncertainty ditorial

emovals not repoted under TA* convention Accepted removals removed"

$hange 4+uic! and dirty4 to 4simple4 ditorial

Accepted Te&t added

ive a proper reference for the 0present0 uideboo! ditorial

ditorial

Accepted Te&t 9eleted

ditorial

Accepted Te&t 9eleted

Chat does S refer toG $orrect Accepted Te&t 9eleted

'oted Te&t will be clarified


$an sin!s be deleted in '$ conte&t


e7ected



Accepted Figure will be reproduced

Accepted Te&t changed


9ecison tree. please delete reference to sin!s Accepted Figure will be reproduced

The title of the chapter should be added 4and identificationof !ey categories4

Title is included already in theheading bo&"

,nsert te&t stating the +uality criteria of Tier 8 (sent byemail 2@"11"@)

Chat is meant by 4the present <4G *lease redraft to 4theprevious *>$orinair uideboo!L4

9elete these sentences - referencs to the 0present0(e&isting now) < are very confusing for future readersand will be irrelvant onve the updated version is published

To be more clear 4The present uideboo!4 should bereplaced with 4the 2@ *>$:,'A, uideboo!4"

,f this way of describing methods is !ept in the guideboo!the Tier wording has to be changed accordingly

The analysis is based on single pollutants. so this te&twould mean that the inventory compiler would loo! fordecision trees etc in sector chapters for categories and forpollutants"

olume < - incorrect ,**$ cross-reference - delete or

correct

%ection < - incorrect ,**$ cross-reference - delete orcorrect

,nventory anagement is not the proper name of thechapter

This an improved version of the,*$$ =A>=$ chapter with moredetailed guidance on inventorymanagement"

olume A incorrect ,**$ cross-reference - delete orcorrect

olume < - incorrect ,**$ cross-reference - delete or

correctFigure 1 does not print well and is unreadable - repaste inat higher +ualityG

/ inventory compiler reference - incorrect ,**$wording - delete or correct

*lease delete reference to 4greenhouse gas inventory4(comment applies throughout the chapter)



e7ected

ood - captialise ditorial Te&t changed

ditorial Te&t changed

pollutant - , thin! !ey categories is meant ditorial

Anne& 1 - there is no Anne& 1" Appendi& AG ditorial

ditorial

ditorial

typo - particulate ditorial


Accepted

Accepted

Accepted

accepted

accepted

accepted

Add %ection before 2"3"8

eneral# The proposed !ey-category approach (singlehandling of each substance) will lead to the fact thatalmost all categories will be identified as !ey" ,n practicethis would re+uest whether the use of different (simple anddetailed) approaches for one given source category

depending from the substance or the general treatment ofthe entire inventory whit detailed approches" <oth waysproduce avoidable wor!"Ce propose to include a !ind of normation of the releasedemissons e"g" by using accidification potentials (or other4transferring4 parameters li!e for 'F$$$ the use ofC*-values)" This would streamline the results analysisdue to the inclusion of more than one substance in oneapproach"

,t was agreed in 9ublin in :ctoberthat a normation approach shouldnot be applied and each pollutantevaluated in its own right" Accifiyingpotentials would only address asubset of pollutants and would notresolve the issue for otherpollutantsL

, assume the proper reference here is not the 4goodpractice guidance4. please add the correct reference of the

26 uidelines

%ince no 4anne& 14 is available we guess this refers to4Appendi& A4

Approach 2 - add relevant chapter cross reference e"g"%ection 2"B"B

/ow to ta!e cross-correlations into account is not (neitherin the ,*$$ 26) described" An inclusion of a te&t as inthe ,*$$$ 26 p3"@ note 2 should be considered"

table 1 - put in an Appendi& - too long for the body of thete&t

9o once other changes made so notto lose page reference

arge table which does not include very helpfulinformation"


The b footnote should reflect the 'F codes" The cfootnote is irrelevant

*lease compare with latest 'F list and correct asappropriate" *lease chec! table font (appears mi&ed. alsoin the footnote)


Table footnote $- what does this mean in the <conte&tGGG Assessed 7ointly is relevant to /s onlyGG


Footnote to table - b - reference to ,**$ needs deleting orrewording ('FG)


$onsult with&pert*anel

don0t !now what is meant by thiscomment""



incorrect / inventory reference - delete or correct accepted Te&t ammended

accepted Te&t ammended





%uperscript footnote references I and 6 ditorial Te&t ammended

change footnote references to upper case ditorial Te&t ammended

e7ected

accepted te&t will be ammended

emovals relevantGG accepted te&t will be ammended

typo - dispersed ditorial te&t will be ammended


e7ected

incorrect ,*$$ referenceG - there is no Table 8"8 accepted te&t will be ammended

%!ip 4or removals have increased4" accepted te&t will be ammended

%!ip 4or decrease of removals in the future4" accepted te&t will be ammended

*lease ma!e a reference to the ,, accepted te&t will be ammended

accepted &ample will be provided


This section must be adopted to air pollutant inventories# i)reference to sin!s must be removed from the te&t ii) thee+uantions should be substantially simplified when sin!s

are not considered (see the ,*$$ * 2) iii) changereference to / inventories to air pollutants

Footnote 8. there are no '$ emission reporting.please provide the proper reference

The chapter tal!s about reenhousegas inventories" For A*s we do not e&pect 4removals4 so that we can s!ipcalculation of absolute values"

,s sin!>removal anywhere relevant for 'F reporting (,t isnot for 9anish reporting)G ,f not. then change the te&taccordingly"

Are removals relevant to '$ inventory conte&t - if notdelete

%ince the analysis is to be carried out for each pollutant.the pollutant should be in the heading not as a column"

,t helps with the optional step 2 tohave the pollutant as a columnfeature"

Footnote 6 - incorrect / inventory reference - delete orcorrect" %in!s relevantGG

For A*s we do not e&pect 4removals4 so that we can s!ipcalculation of absolute values"

%ince the analysis is to be carried out for each pollutant.the pollutant should be in the heading not as a column"

,t helps with the optional step 2 tohave the pollutant as a columnfeature"

&amples on the actual pollutants and 'F categoriesshould be wor!ed out

A +uarter of this chapter is dedicated to illustrate !eysource analysis. too many pagesG Chy showingcontributions of sources that are not !ey sourcesG ,s thechosen e&ample relevantG



e7ected



!ey categories in bold" 'o they0re notG





ditorial

Appendi& A is not mentioned in the te&t - it needs to be Accepted

'oted Te&t clarified

its not it0s ditorial

'oted

$orrect caption numbering ditorial

The e&ample relates to / when $TA*>'$9reporting does not concerns /"

The e&amples still illustrate theapproach ada+uately

The !ey sources are defined per pollutant in the newuideboo!. when the e&ample illustrates an otherdefinition (!ey sources defined for the different / asC*)"

,t is confusing to display category codes within thee&ample that are not consistent with the recommendedones (cf" table 1). as far as they relates to the new ,*$$categories. from ,*$$ 26 which are not yet appliedeven for 'F$$$ reporting yet"

tables needs to be put in Appendi& - is far too long forbody of the chapter

table 3 - $an we not 7ust have an e&ample relevant for airpollutants instead of /sG

*lease provide an e&ample for an air pollutant inventory

(one substance) rather than this e&ample copied from the/ inventory guidance

$hapter 2"6 &amples of !ey category analysis should bedeleted. if the reference is given in the spec" chapter in the,*$$$ . then it should be refer to that" :therwise ane&amle with the air pollutants should be given5

eneral# Ce propose a reference system instead of+uotation of all these detailed tables 3. I. 6. @. ? (ta!enfrom the 'F$$$ uidelines)"


eferences should be in correct order of date ie ,*$$2 before ,*$$ 26

,s the e&ercise meaningfull and is the results to be usedfor methodology demandsG


,t is now mentioned at the bottom ofsection 2"2

This is a mathematical e&ercise weighing all pollutantsidentically and weighing categories accordingly" (Chat ismeant by the te&t refering to the anne& (page I line @) thatit consolidate the pollutantG)

The e&ample assumes JI treshold for !ey categories butthe !eysource chapter recommends ?"

issue clarified in te&t" There are

limited e&amples for Air *ollutant;ey $ateogrit analysis""

,f the intention is that countries should perform a combinedran!ing of different pollutants it should be addressed in themain chapter and not only as an appendi&"


it was agreed to move it ot an anne&by the A and discussed in 9ublin"



'oted

'oted

'oted will clarify

noted

typo ditorial

already have a Table 3 in the chapter - renumber ditorial

':& ditorial

will clarify

will clarify

4rror5 <oo!mar! not defined4 ditorial pdated contents table

!ey sources should be !ey categories ditorial Amended

Accepted * 2. lines 28 added

Accepted

Full stop missing ditorial Amended

*lease define % (or better rewrite) ditorial % updated to icrosoft

*lease provide reference to * measurement guidance Accepted

Accepted &amples added

The method for combining the !ey category analysisdecribed in Appendi& A is not mentioned nor referenced inthe main chapter"

,t is now mentioned at the bottom ofsection 2"2

Chat is the result of the proposed combining procedure in Anne& 2G $ould this be used to minimise the overallnumber of !ey-categories in the sence of comment 1G"g" by inclusion of all results for the different substancesin these combination procedure" ,t would re+uest atreshold value to identify the 4overall-!ey-categories4"

That was the idea"" To minimise thenumber of !ey categories" ,t wasagreed to offer it as an option only""

*age 82 line 11 states that this combined ran!ing%/:9 be done. however the described approach isonly mentioned as a possible approach"

The individual ran!ing and scoring for the ran! placng canbee seen in the right columns"

Chy the definition of fuels is given in Appendi& <. it is alsogiven in $hapter 1 ,ntroduction Appendic $ FuelsGGG


Chat is this table doing hereG ,t is misplaced and alreadyincluded in the introduction" *lease correct


The same fuel table is already included in *art4,ntroduction4"

ention clearly in introduction that section draws heavilyon ,*$$ - eg as done for chapter time series consistency

,n adopting this to air pollutants. the focus must includeuroean sources. eg urostat and -*Ts>*Ts

Test amended to include specificmention of :%TAT and datareported under the *T

'ote added to Table 2"1 andreference included"

For some of the points the understanding is not very clear", suggest to include some typical e&amples for each pointto increase the usiblity of this list also for 4measurementdummies4



emove bullet point ditorial Amended

*roper references needed for $' standards e7ected

*roper reference needed for ' ,%:>,$L Accepted dited where necessary

ditorial Amended

delete final colon from the title ditorial Amended

Accepted Te&t added to *@ 2"1"1"

Accepted &planatory paragraph added"

ditorial Cill re-assign

'o such sections as 1"3 and 1"I" $hec! and correct ditorial reference corrected

1"8 should be 2" $hec!" ditorial reference corrected

typo - component an air pollutantL reword ditorial

ditorial

ditorial

'o such section - chec! and correct ditorial

typo - insert L0necessary0 to prepare""" ditorial

'o such section as I"2"8 - chec! and correct ditorial

ditorial

typo - to A**U different ditorial

e7ected

ditorial

ditorial

ditorial

ditorial

$' standards are referred to as'

references should be put in ascending date order" seauthor (date) title format throughout (for boo!s as well asarticles)

eneral# guidance on use of *T data is missing andmust be added

eneral# reference to guidance for collection of spatialdata is missing

$hapter contains many cross references to other ,*$$olumes. ,*$$$ uidance sections" All need deleting orrewording

good practice guidance0 is ,*$$ 2" $larify wording -0good practice guidance of the ,*$$26 guidelines0 if thatis what is meant

evise 4is a central component an4 e"g" 4is a centralcomponent of an4

$apital for reporting" *rovide proper reference at firsttime of use

Footnote 2 - :verall rather than overlapG $hec! e+uationnumbering - there is no e+uation I"1" $orrect different fontsiHes within footnote

corrention made to the font and thee+uation number"

%ection numbering - use a 8 digit heading before a 3 digitheading (there is no 2"1"1)

Figure I"2 - correct figure numbering (the I has nomeaningG)





ditorial

<o& numbering - remove I ditorial

+uation numbering emove I from I"2 ditorial

<o& numbering - remove 6 ditorial

ditorial

<o& numbering" section not %ection ditorial

se 8 digit heading numbering ditorial

Accepted note added

<o& numbering ditorial

<o& numbering ditorial

ditorial

Add table numbering ditorial

table numbering - no I ditorial

ditorial



ditorial

table numbering - no I

ditorial

references - arrange in ascending date order ditorial

ditorial

ditorial

Accepted



9efine AF: from figure caption (or delete as notrelevant to '$ inventories)

Add horiHontal lines to table to improve readibility - 8rdcolumn not aligned properly

olumes - incorrect / inventory reference - delete orcorrect

%ince the F:9 has a chapter on =A>=$ the refernce inthe parenteses should presumably be changed from the,*$$ to the F:9 chapter

olumes - incorrect / inventory reference - delete orcorrect

eneral# This chapter has been copied from ,*$$ ls.

and need to be properly review with the ob7ective ofchanging terminology and references to this manual"Furthermore. figure numbering needs to be changed

,f nowhere and for none of the pollutants sin!>removal isactual the te&t should be loo!ed through and revisedaccordingly

%ince 4base year4 might not be precise>uni+ue to the airpollutants the te&t should be loo!ed through>revised"

Foot note added to e&plain <aseUear"



Accepted $hec!ed

Accepted

Accepted 9onencertainties chapter - paragraph not article Accepted $orrected

e7ected

Accepted 9onencertainties chapter - paragraph not article Accepted $orrected

Accepted

Accepted $orrected

Accepted 9eleted

Accepted

ncertainties chapter - eferences not in reference list Accepted

ncertainties chapter - eference not in reference list Accepted

Accepted $orrected

Accepted $orrected



ncertainties chapter - eferences not in reference list Acceptedncertainties chapter - 9elete if Appendi& is empty Accepted 9one

eference to sections and tables does not match thesections and table headings"

ncertainties chapter - There are a number of referencesin the te&t not provided in the references list" $hec! andcorrect

eference sections (main te&t aswell as appendi&) chec!ed andcompleted

ncertainties chapter - incorrect reference draft

28GG pdate to 2? draft or the e&isting final 28

ncertainties chapter - Chy table 6"(1)G $orrectnumbering - 6 is not relevant

ncertainties chapter - incorrect reference draft 28GG pdate to 2? draft or the e&isting final 28

ncertainties chapter - Footnote 3" A number of referencesare provided with no details given in the reference list" Addto reference list or delete"


ncertainties chapter - Fig 8"I" correct numbering - thereare no Figures 1-3

ncertainties chapter - AF: - define or preferabledelete - not relevant to '$ inventories

ncertainties chapter - Add references to reference list" And those in footnote 6



eference sections (main te&t aswell as appendi&) chec!ed and

completedncertainties chapter - Chat are approaches 1 and 2"these are not defined at all in the chapterG $orrect ordelete

ncertainties chapter - 'ot consistent" %ection 8"2"8 doesnot give details of Approaches 1 and 2






'oted

4principles4 not principals Accepted $orrected

Accepted Te&t added

Accepted Te&t modified

Add referencing for ,*$$ documents Accepted

4e&pamnds4 -O 4e&pands4 Accepted

Accepted 9one

Accepted

*lease reference the 2? uidelines Accepted

Accepted 9one

:ne from the data providers would be facility operator Accepted 9one

* eporting guidelines - add proper reference Accepted 9one

According to me all the chapter is very clearK perhaps forbeing more practicable could be appreciated someoperating e&amples related to the management inventoryreport (for e& some sheets related to the main phases(data re+uest>raw data>compilation>=AP=$)) suggesting a

way to include all info as introduced in paragraph 3"6

At this point or>and in the paragraph 2"2 could be betterdistinguished the difference between 4inventory manager4and 4inventory compiler4" As for the first one in page 2 line1J. it0d be specified that also the inventory compiler couldbe an individual or staff. one institution or more institutions",f the inventory manager is e&ternal to the inventory

compiler staff. the last one need generally a chiefinventory compiler staff" *robably in the case of smallgroup they can overlap" Anyway , suggest to point out.also ahead. that the inventory manager (or chief inventorycompiler staff if different) is responsible for the technicalstaff management (how to share resp. if for sectoral ortrasversal topics. how to attribute internal deadline. how tointroduce and guarantee that internal reports in thedifferents steps must be filled etc"). as financial budgetmanagement to guarantee hwPsw. data ac+uisitionavailability. inventory related e&ternal consultants etc"

Footnote 1 - *arty not party" $hec! $ signatory or ratifiedprotocols

eference however should be to the'F$$$ reporting uidelines here"

*lease harmonise with latest version of the draftuidelines (see also comment to the introduction)

These T$$$A criteria have different definitions to those inthe < ,ntroduction5 They should be consistent with theformal definitions in the latest version of the draftuidelines

$opied definitions from the draftguidelines

Added a reference to the still draft

2@ uidelines4,nventory compilers. virtual or real institutions.4 , suggestto substitute with 4,nventory compilers. one o moreinstitutions.4



4detailed energy statistics4 , suggest to remove detailed Accepted 9one

9elete +uite string and replace with fi&ed Accepted 9one

4incventory4 -O4inventory4 Accepted 9one

delete 2nd part of sentence following Authority e7ected

I should be 6" eorder bullets once corrected Accepted 9one

Accepted 9one

Accepted te&t updated

Accepted ,t is good practice to L

9elete bit. replace with rather Accepted 9one

4sectoral inventory4 ,0d suggest to remove sectoral Accepted 9one

Accepted

Table 1. please ma!e e&plicit reference to the ,, Accepted 9one

Figure 3# please change references to $F Accepted 9one

*lease update the te&t for air pollutant inventories e7ected

Accepted 9one

'o such bo&" $orrect or delete Accepted te&t removed

Ce believe that in a te&t bo& li!e thisone the suggestion to harmoniHewith the 'F$$$ is usefulK thelaguage is a bit wee!ened though"

%tyles - not consistent across chapter i"e" sometimes evelone headings are A $A*%. sometimes %entence case.sometimes Title $ase" 'eeds to be standardised"

A bit confusing the reference to year ' and 'V1 (line 22)and to year ' and 'V1 (line 86)" ,t coul be briefly e&tendedthe first sentence 4compiling an inventory is an annualprocess4 (line 1J) by mentionning that activities can

9elete should and replace with may" (,t0s not a re+uirementfor parties)

the figure is very interesting. only few comments" %omesymbols referred to documentation aren0t clear fore&ample 4uni+ue reference4K , suggest to move down4e&plain large changes4 as it could be referred to all theprevious parameters comparison>balance" The legendshould be highlighted to be distinguished from the otherrectanglesK the figure is a bit compressed. there are somete&t characters with different dimensionsK4$F4 and 4'F4compare for the first time in the chapter. maybe can bereferred to general glossary or referred in the te&t

eplaced $F by 'F in twochec!s" ade figure a bit larger"&plain large changes is the first of adifferent !lind of chec!s" Thereforeorder not changed"

The / guidance here can providesupport for air pollution inventories

Table 1. there are no good practice guidance for airpollutant inventories. please change the terminolog



Accepted 9one

typo Accepted 9one

typo O Accepted 9one

replace will with may Accepted 9one

Accepted 9one

Accepted 9one

e7ected *resent te&t is clear

partial te&t - delete Accepted 9one

e7ected

enthoven et al. 23 is not included in 4references4 e7ected ,t is included i nthe references

van elthoven et al for 8 or moe authors Accepted 9one

'A$* missing from reference list - include Accepted $ouldn0t find it. reference removed

,n -O An Accepted 9one

table - data provider# An institutionL Accepted 9one

e7ected 9o not understand this

missions reporting guidelines should be in reference list Accepted 9one

Accepted 9one

e7ected

,n alidation L" 4is4 -O 4,s4 Accepted 9one

Accepted 9one

,*$$ refereences need completeing Accepted 9one

e7ected ,s in data collection issues

9elete protocol provisions as this is confusing (not allprotocols reflect this)" ,nstead refer to the applicable te&t inthe uidelines

,0d suggest to move in the previous part (4institutional4 or4contact person4)

4institutional4 , suggest to change with or to add also4contact>reference person4

4technical4 ,0d suggest to change with software or archiveaspects

A,'% should be mentioned as a !ey source ofverification here (both activity data and emissions)

A,'% is to be fed by national

reported data. rather than the otherway around"

*lease discuss the role of * modellering data forverification purposes

=uality Assurance - %ection 6"I - no such section - deleteor correct

, suggest to enlarge the 4,nventory system4 definition. allthe institution involved in the emission inventoryplanning>compilation>dissemination etc""

,7n our view this is e&actly what ismeant

*eter vanL references should be ordered by surname not

first name" 9ate missing from reference details

*lease discuss the role of *T data in =A>=$ (e"gverification)



Accepted %ee te&t bo&

e7ected 9o not understand this

ditorial

is A%: re+uired ditorial

Accepted eference moved to eference list

e7ected

Accepted

Accepted

emove after !ey spatial data sources 4"4 ditorial

add para on %'A* ditorial

ditorial

ditorial

e7ected Terms left in" ,% added

typo - gross ditorial

Accepted te&t deleted

eneral# many *arties have integrated 'F$$$ andTA*>'$ inventories. but not all" The authors of thecurrent chapter seems to assume the former" This issue(institutional set-up) should be better e&plained. perhapseven in the introduction (see e"g figure I)

eneral# *lease define inventory compiler. under the

$onvention the responsibility lays with the 4designatedemission e&perts4

,nstead of referring to gothenburg. refer instead to theeporting uidelines as the driver for reporting"(technically various < decisions also implement spatialreporting and not 7ust the protocol - its easier 7ust to referto the )

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

styles - different chapter sections are in different fonts"

%tandardise throughout$hapter name might be changed to reflect reporting ofgridded data alsoG - 0%patially disgagregated emissionsmapping0G

$urrent heading is sufficient toinclude gridding"

$hapter could mention in introduction the basic wor! of thechpater was developed by A0s T$>A$$"

%ome areas of additional guidance are missing from thechapter (which the uideboo! consultants agreed tocomplete after ta!ing over responsibility from T$>A$$ forcompletion of the chapter") %pecifically. augmentedinformation on data sources and methods for mappingforest fires. biogenic :$ emissions. shipping and

aviation should be provided and included in the final draftof this chapter"

This guidance will be included in thefinal version"

, suggest to substitute here and after 4I&I !m grid4 wirh4I& I !m24

, suggest to add after 4their dispersion partners4 4andimpact area4

Among 4eneral Terms4 , suggest to !eep terms morerelated to spatial mapping. (such as 'T%. surroggate

etc". ,0d include 4,%4 definition) and remove those as4/94 and 494 for e&ample"

9elete mention of associated proposed directives - its notat all clear which proposed directives are being tal!edabout here



ditorial

"" by an & and y coordinate4s"4 ditorial

Accepted te&t changed

%ay also when the protocol entered into force ditorial

Accepted te&t to be changed

Accepted te&t to be changed

Accepted 'ote added

Appendi& not Anne& 6 ditorial


typo identify toG ditorial

typo delete misses ditorial

Accepted te&t added

/9# /eavy 9uty ehicles are vehicles with a grossvehicle weight of W 8.I !g NNOOOO /eavy 9uty ehiclesare vehicles with a gross vehicle weight of O 8.I !g

,0d try to mention an e&ample for each surrogate resolutionlevel>type and !eeping possibly the same order 4as landuse coverage pecentage by grid. vehicle flow by road lin!.employers number by industrial point. population byadministrative boundary

eferences for the various legislative acts should put inthe references. not in footnotes" 9elete footnote 3 givenearlier comment about the whole table should be deleted

this *% definition is very messy - mi&ing up -*T anduidelines aspects" ather directly refer to the uidelinesas the source where the definitions of *% for reportingunder the convetion and its protocols can be found"ention also that defintions of *% (sectors. thresholdsetc) can differ between different reporting mechanisms"9on0t provide details of the reporting thresholds andpollutants here - instead refer 7ust to the uidelines wherethese are defined" This will help avoid inconsistencies"ention of the -*T reporting thresholds and failitydefintions should be deleted as they confuses the issuetoo much here"

9efinition of *%# anything is written about th e stac!

height. which is also an important parameter for spatiolresolution and the * gridding"

, suggest to mention that also 4trasport emission can behandled sometimes as area soources. for e&ample arcsthat are too numerous or information are not available tobe individually identified as line sources4"

Those cases they can be treated as area sourceas polygon or as area source as grid by the use ofdifferent surrogate variable (for e&ample as percentage of

linear emission density or from fuel balance. as differencebetween total fuel and linear traffic fuel induced)

, suggest to invite compilers to the use when possibile ofthe spatial surrogate used for spatial mapping in previousyears to guarantee consistency



Accepted te&t added

delete and - T%G



'ot 3"2 - should be 3"8 $hec!" ditorial

ditorial

ditorial

Accepted te&t added

not Anne& ,,. it0s Appendi& ditorial

Accepted te&t added

Accepted

Appendi& not Anne& 6 ditorial

$omplete reference list for T,% ditorial

Apmosphere reference - <riggs not <rigg ditorial

Accepted te&t added

As the 4e&ample 14 is a bit far from the referring te&t. ,suggest to include the corresponding page (e"g" &ample1. 4pag J4)

*erhaps the emission total to be distributed is 4emission t4

instead of 4emission i&4, suggest to include in formula note ""to an 4(i)4 specificgeographic feature

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

$hec! - does the latest $:,' provide 3I or moreGandcovers

Dust provide one generic lin! to A dataservice - specificlin!s become outdated

:%TAT has several useful agricultural datasets. e"g"

From the Farm %tructural %urvey

The $:*T refernece can be updated to latest v3manual available on the $:*T website

eference to uidelines should be updated to latest draft.not the Thessalini!i one (or final version when agreed)

There is no mention>consideration given in the chpater tothe gridded 'F 'F which parties are re+uired toreport spatial data in" This is a ma7or omission from thechapter and needs to be corrected" At least some shorte&planation needs to be given on how 'F emissions maybe aggregated to the 'F and reference made to thedraft uidelines where this is defined" ,deally pro&yvariables for each of the 'F sectors should also beprovided


'eed to ensure we respect theboundary between reporting andmethodological guidance"

,t should be noted in the te&t that updated information on gas connections etc may be available from urostat>,Aetc" This should be chec!ed before being stated

%ee previous comment - surrogates should also be givenfor 'F sectors. as this is the minium that some *artieswill be able to do


'eed to ensure we respect theboundary between reporting andmethodological guidance"



'oted

'oted

Figure numbering inconsistent ditorial


Accepted will add


Accepted

ditorial $hanged all to ;ey $ategorieschange 4though4 to 4through4 ditorial

ditorial

ditorialdelete 4data4 ditorial

Accepteddelete 4to4 ditorial 9oesn0t really ma!e a differencechange 4and4 to 4or4 ditorial

ditorial

ditorial

ditorial

ditorial

Accepted Te&t added to paragraph"

/opefully this might enhance the accuracy andconsistency of the reported emission data" ,t would be nicealso to include a section describing this issue in theguideboo!"

Ce recommend. that a common harmoniHed ,% themeon coast line and territorial sea should be available for the

member countries reporting gridded emission data" This toavoid the use of themes with different resolution and levelof generaliHation"

* is e&tening area to the east . consider to provideinfo and add map with e&tended * area

, miss any reference to the various guidance material

developed for % compilation and reporting of /pro7ections under the wor!ing group of the $ climatechange committee" This at least should be referred to"

,ncluded footnote and reference inthe reference section"

Throughout chapter. references need chec!ing (te&t toreference list and vice versa)

Throughout chapter mi&ture of !ey sources. !ey categoriesand different capitalistaion is used - ;ey categories. ;ey$ategories etc" please standardise

4*ro7ections are usually much less certain than the historicinventory and re+uire""" 4

4uidance on tac!ling common problems associated with

gathering appropriate data onL4

9efinition of 4without measures4# what technology hasachieved to date. is confusing" specially comparing withterminology on p"8. l"16# without measures scenariosusually start from a convinient historic year"

modified te&t to remove reference totechnology

Footnote. line1- change 4and4 to 4or4" ine8. delete4resulting4

Footnote 1# ine 1 9elete 2nd 0and0" ine 8 9elete0resulting0 9elete 0resulting0

9elete 0present0 and replace by 0represent0 or 0derive from0or 0reflect0

Footnote# *olicies and easures and can be laws - delete4and4

Co scenario" 'o actual guidance on how this scenarioshould be developed i"e" are emissions to be pro7ectedfrom a base-year based on 9* for e&ampleG



'oted

$hange 4with4 to 4where4 ditorial

$hange 4post the historic year4 to 4are4 ditorial

ditorialduplication of (b) on line 1 and subse+uent lettering ditorial

Accepted Te&t updated

'oted Te&t left unchanged"

'oted Te&t to be updated"

4targets. which has now been superceded"4 ditorial

change 4estimates4 to 4estimated4 ditorial4L based on a range of datasets. includingL4 ditorial



eneric te&t on determining cost-effectiveness is not veryhelpful" %ome guidance on how an costs can bedetermined would be useful"


%ome references will be includedwhere they are available"

Ce do not understand this definition" The starting year isonly 1JJI or 2G :r may be the latest year of historicinventoryG Ce thin! that this should be topic of discussion

in Tallinn on pro7ection e&pert panel"

The description has been e&tendedto include some proposed

methodology for calculation (seesomment in line 16 above"

Te&ted changed due to anothercomment

Te&ted changed due to anothercomment

Te&t nclear. , suggest 0Lscenarios can include theestimation of 4what would have happened4 if the measuresalready implemented since the historic year had not beenimplemented"0

(c) and (d) are a bit vague- it is not clear how they could

differ from the others" ,t might be helpfut to give e&amplesof eachG

,t would be also good practice to clearly define themeasures that the C. Co and Ca scenarios refer"

The definitions used for Cith measures and with additionalmeasures should be fully in line with what is re+uired forfuture reporting under '$ and - (or in the draft* eporting uidelines or draft decisions if this isspecified there)" At present the defintions presented here

differ. and thus need to be harmonsied with thosespecified in the formal reporting re+uirements"

,n the definition for 4Cith easures4 an agreed date.beyond which policies and measures are not considered.should be mentioned" For e&ample. legislation. policiesand measures in place by 81st of 9ecember of theprevious year will only be considered under the 4Citheasures4 scenario" *olicies implemented in the currentyear. when the pro7ection is being prepared should beincluded in the 4Cith Additional easures4 scenario"


,t depends how much detail you want to go into here but.the marginal cost curve in terms of a plot of total +uantityof pollution avoided against the marginal cost of reductionin euros>tonne. is often used"

Future assumptions could also be based on behaviouralchanges or structural changes in society"



ditorial


Accepted Te&t added under 8"?Figure - can0t read the te&t on some sections of this Accepted ade more clear

AcceptedUou could give an e&ample eg road traffic model Accepted te&t added

Accepted te&t clarified

Accepted pdated4An emission factorL4 ditorial

Add a comma after 4;ey %ource4 ditorialeffect ditorialformula is singularK plural is formulae or fomulas Accepted Te&t changedL""and involves ditorialevise sentence beginning at ( Accepted te&t changed

ditorialsector0s ditorialNAds should have upper case 9 ditorial

Accepted Te&t $hanged An emission factor ditorial

e7ected

mission pro7ection scenario should be compiled - eitherscenarios should be plural or the sentence should start4An emissionL4

There can also be regional considerations thatnecessitates that a measure is carried out despite the factthat it does not the biggest emission reduction for the

lowest cost" For e&ample health considerations in urbanareas"

eneric te&t on the use of 4energy models4 to determinebasic growth factors" uidance on which models arerecommended would be useful"

Flow $hart# 9ecision 9iamond 2- The last sentence is 0orare current emission factors ade+uate0 to which ,answered yes and am then told in Tier 2 to use a futureemission factor" , thin! you have to be clearer on what+uestion you answer yes or no to

a!e te&t in the Tier 2 bo& read L""(or ada+uate current emissionfactors)

'ot clear what is the difference between Tier 8 and Tier 2"Tier 2 mentions ta!ing 4reasonable account4 of futureactivity changes" 'ot very specific"

'o caption" Figure poor +uality and unreadable whenprinted" *aste in higher +uality versionG

<e consistent in the use of 0emission factor0 and 0emission

rate0" ,nsert comma after %ource

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

*age @. formula 2 (row 26)# in the denominator is A9n.where in row 88 is A9n N A9sSFn" <ut on page ?. row 1.the formula for A9n is sum of A9t for tN1 to p" ,f we set theformula from page ? to formula 2. then the formula 2 willbe sum of the emission factors for tN1 to p" Ce thin!. thatin formula on page ? (row 1) should be correct A9tNsum of

A9t for tN1 to p (not A9n)"

Te&t definition of Adt changed toclarify that A9t is a sub source of

A9n



Accepted Te&t added4L so that a measureL4 ditorial4L methods. theL4 ditorial

Available - uppercase A ditorialcomma after methods ditorialits measures ditorialneed to be bro!en down Accepted Te&t added

Accepted 9efinition addedF9 is Flue as 9esulphurisationG ditorialF9# abbreviation is not e&plained ditorial

Accepted Te&t added than! you"

Accepted Te&t added to clarify"portray a picture consistent with ditorial $hanged with another commentLin from L ephrase ditorial

Accepted Te&t and reference added"

ditorial

ditorial4The energy related emissions should be chec!edL4 ditorialchange 4matched4 to 4match4 ditorial4L estimates" The overallL4 ditorial

ditorial

, thin! that it is worth stating in general terms that in somecomple& detailed sectors there can be an interractionbetween the emission factors assumed for pollutantcontrol technologies and the pro7ected activity data" For

e&ample in electricity generation the underlying activitydata maybe future electricity demand" The energyconsumption of the power sector must be consistent withthe electricity demand and the efficiency of the future mi&of power stations" The control measures applied (eg F9.%$. carbon capture and storage) will affect the efficiencyof the power stations and hence fuel consumption" Thusthe assumed mi& of emission factors affects the fuelconsumption data" ,n such cases the assumed mi& ofabatement technologies is an input to the model whichpredicts energy consumption"

ither include a definition of %tratification here. or refer toit0s definition somewhere else

*ossible addition to list" $ompare pro7ected trends in data(emissions or activity) with historic trends- if there aresignificant differences then need to e&plain why" This is

based on a general observation that nationalemissions>activity data tend to change gradually (thoughnot always eg '2: emissions in chemical industry)

Ce need some te&t to e&plain what this figure means- alsoit loo!s as if the arrows are displaced

There is nothing in this section referring to best practiceused in historic compilation" ither include a reference toanother section of the uideboo!. or add the followingte&t#

&ample of simplification - arrows need to be re-aligned in

diagram4,t is important to ensure that the resulting emissionpro7ections are consistent with the underlying input data"The following chec!sL4

4L inventory should be consistent with the energy balancefromL4



4The transitionL4 Accepted Te&t modified"

4L pro7ection must be realistic" $hec! for L4 e7ected

'oted Te&t modified"4L are correct. and that revisions are transparent"4 ditorial

4L results and what were the sources of the difference"4 ditorial

e7ected te&t left the samesectors ditorial

Accepted &ample Addedbased on measured ditorial

ditorial4L based on measuredL4 ditorial

4to assume that pro7ections are the same as those forL4 ditorial $hanged from another comment

Accepted %ome te&t added"'eed a heading 4mission factors4 Accepted %ome te&t added"pro7ected ditorial

ditorial

Accepted *aragraph movedtypo ditorialchange 4improve4 to 4improving4 ditorialchange 4are based4 to 4or based4 ditorial

4L employed to ma!e allL4 ditorialThis para is about sensitivities. should it be moved GG Accepted *aragraph moved

Accepted Te&t ammendedchange 4latst4 to 4latest4 ditorial

bullet replaced with moreappropriate te&t"

4L noted" ,f there is a large step change. then methodswill need to be modified"4

ore sensible to use domestic as the e&ample for bothe"g"0s

&ample# The emission limit value defined by the largecombustion plant directive (9irective 21>?>$) for newcoal plant is 2 mg>'m8 ':& as ':2 (X6:2)"

Applying an appropriate volume factor for coal of 863m8>D ('$) gives a pro7ected emission factor of @2"?g>D coal consumed" (eference for the volume factor israham. 9*. %alway . ay. *" %tac! as Flow ate

$alculation for missions eporting - Aguide to $urrent<est *ractice for the :perators of $oal Fired<oilers".*T>@>$322> ay 2@

'eeds re-wording eg" ""no surrogates available for sourcesectors. it is good practice to assume the pro7ected valueis the same as the latest historic yeear"

,ncluding the impact of non-technical measures is

mentioned" 'o guidance on how this +uite comple& tas!could be carried out"

mission pro7ections are always modelled 4and4 are basedonL"

$hanged by another comment to4or4 based

The paragraph is listed under the headline 4ncertainties4.however it seems to be referring to sensitivity. which isdescribed from line 26"

$hanged sentence to ma!e moresense. not in e&actly the waysuggested"

9efine $AT and provide proper reference in referencelist





ditorial



Accepted te&t changedThis isn0t a bullet point ditorial

, note that %ectoral :verview of ethods has been cut 'oted

'oted

'oted

Accepted te&t added

'ot a good e&amples because recent catalytst are notemitted higher '/8" $hoose something simple e"g"aviation

A Co scenario should not be listed as a necessaryactivity for compiling emissions pro7ections"

change 4be in accordance4 to 4have a methodology that is

consistent4

, thin! some more detail is re+uired ie some sort of listrefering to elements discussed in previous sections" eg"values and sources of activity data used. F factors used.emission factors. details of tiers. sector definitions. sectorstratification. assumptions made in deriving future Fs"

Again reference to =A>=$ activities referred to in te&t-chec!ing. energy balances. etc

*roperly define reference for current guideboo!*>TF,* (28) etc

, e&pect there are similar interractions in transport egpro7ected air !m and airccraft mi&K vehicle !m and vehiclemi&"

uidance for pro7ections is very generic" The 26uidance is more comprehensive

4The best practice principles for emission inventorycompilation also apply for pro7ections" Therefore theresulting pro7ections will need to be transparent. accurate.consistent. complete. and comparable"4



Comments Additional note(s)























':T# not all * members are members"

The uidance for *T is regime specific and notinformation of the same generic type as that in the te&t"



Added 4of4

:verlap is meant as this describes the e+uation"





6 is chapter number. this is the format for table>figurenumbering chosen"









Dustin might li!e to chec!

eporting is A%: re+uired""

'eeds new guidelines referenceG

$an we change the chapter nameG

Aviation and 'ational 'avigation methods are alreadyinccluded

This is supposed to include relevant terms used for thechapter"





Cill propose some te&t for thisL

%ee above Cill propose some te&t for thisL

ight want to chec! this is the best way - one of those lin!shas already been updated5

:! but the underlying purpose of the uideboo! is certainlyto assist with reporting (this is why for e&ample it isstructured to 'F which is a reporting re+uirement. and nota methodological re+uirementL)" ,t is indeed strange thatthe chapter doesn0t mention 'F at all given this role ofthe <" %ome information>consideration of 'F needs tobe added"





1JJI and 2 are possible starting years for a C:scenario" :ther years can be chosen"

easures will be different for different %" Ce can not beprescriptive about what measures belong where in the CCAs scenarios" The boundary for C is clearly definedin the C te&t inder items a- f"

9efinitions will be brought into line" /owever. as this is thelatest document in the evolution of our understanding there

may be some enhancements to the definitions in thisdocument over that of the eporting uidance"



Te&t in diagram will be changed"

Te&t definition of Adt changed to clarify that A9t is a sub

source of A9n





more appropriate te&t provided

This e&ample is good because it shows the lin!agesbetween different sectoral data for pro7ections"





Chapter_Name NF_Code

1 nergy industries 1"A"1"a 1 1 2J ?

1 nergy industries 1"A"1"a 1 6I

1 nergy industries 1"A"1 2 2 2 21

1 nergy industries 1"A"1 I ? I 1

1 nergy industries 1"A"1 I 3

1 nergy industries 1"A"1 I 3

1 nergy industries 1"A"1 6 2 6 I

1 nergy industries 1"A"1"a 6 J 12 3

1 nergy industries 1"A"1 6 11 nergy industries 1"A"1 6 2

1 nergy industries 1"A"1"a 6 23

1 nergy industries 1"A"1"a @ ? @ 1I

1 nergy industries 1"A"1"a @ 1J

Chapter _ID

FromPage

ToPage

FromLine

ToLine



1 nergy industries 1"A"1"a ? 2 ? 23

1 nergy industries 1"A"1"a ? 2I J 2

1 nergy industries 1"A"1"a J 82 J 88

1 nergy industries 1"A"1"a J 821 nergy industries 1"A"1"a 1 8@ 1 8@

1 nergy industries 1"A"1"a 1 8 11 ?1 nergy industries 1"A"1"a 1 21

1 nergy industries 1"A"1"a 1

1 nergy industries 1"A"1"a 11 @ 11 ?

1 nergy industries 1"A"1"a 11 18 11 18






1 nergy industries 1"A"1"a 18 1? 18 21

1 nergy industries 1"A"1"a 18 121 nergy industries 1"A"1"a 18 18


1 nergy industries 1"A"1 13 1@

1 nergy industries 1"A"1"a 13 2@

1 nergy industries 1"A"1"a 13 2@

1 nergy industries 1"A"1 1I 1I

1 nergy industries 1"A"1 16 1@

1 nergy industries 1"A"1"a 1?

1 nergy industries 1"A"1 1J 23



1 nergy industries 1"A"1 1J 23

1 nergy industries 1"A"1"a 1J 8 2@ 8











1 nergy industries 1"A"1 21 21




1 nergy industries 1"A"1 2I 2I

1 nergy industries 1"A"1"a 2I 3 2I I

1 nergy industries 1"A"1"a 2I 3



1 nergy industries 1"A"1"a 2? 6 2? 6

1 nergy industries 1"A"1"b 2J 11 2J 18

1 nergy industries 1"A"1"b 2J J 3 2

1 nergy industries 1"A"1"b 2J 26

1 nergy industries 1"A"1"b 2J 2?

1 nergy industries 1"A"1"b 8 1?

1 nergy industries 1"A"1"b 8 21

1 nergy industries 1"A"1"b 8 2I

1 nergy industries 1"A"1"b 8 81 nergy industries 1"A"1"b 81 21 nergy industries 1"A"1"b 81 8



1 nergy industries 1"A"1"b 88 11 88 11

1 nergy industries 1"A"1"b 88 @1 nergy industries 1"A"1"b 83 88



1 nergy industries 1"A"1"b 8I I 8I I

1 nergy industries 1"A"1"b 8I I 8? 8







1 nergy industries 1"A"1"b 8I 3

1 nergy industries 1"A"1"b 86 1 86 1

1 nergy industries 1"A"1"b 8@ 1 8@ 1



1 nergy industries 1"A"1"b 8@ 3 8@ 3

1 nergy industries 1"A"1 8? 8 8? 3

1 nergy industries 1"A"1 8? 8 8? 3

1 nergy industries 1"A"1"b 8? 1 8? 1



1 nergy industries 1"A"1"b 8? 8 8? 8

1 nergy industries 1"A"1"b 8J 1 8J 1




1 nergy industries 1"A"1"b 3 I 3 12

1 nergy industries 1"A"1"c 3 21 3 21





1 nergy industries 1"A"1"b 3 121 nergy industries 1"A"1 32 32

1 nergy industries 1"A"1"c 32 1I 32 1I


1 nergy industries 1"A"1 33 1 33 3





1 nergy industries 1"A"1 36 1I 3@ 11 nergy industries 1"A"1"c 3? 3? 3? 86

1 nergy industries 1"A"1 I1 2 I2 1

1 nergy industries 1"A"1 I2 2 I8 1

1 nergy industries 1"A"1"a I8

1 nergy industries 1"A"1"b I8

1 nergy industries 1"A"1"a I6

1 nergy industries 1"A"1 IJ 2 IJ J



1 nergy industries 1"A"1 IJ 2 IJ J


1 nergy industries 1"A"1"a 68 I

1 nergy industries 1"A









1 nergy industries 1"A"1

1 nergy industries 1"A"1

1 nergy industries 1"A"1"a






2 1"A"2 1 I2

2 1"A"2 2 18 2 13

2 1"A"2 8 1 8 2

2 1"A"2 8 1 8 2

2 1"A"2"c I 82 I 83

2 1"A"2 ? 81 ? 83

2 1"A"2 ? 2@ J 2@

2 1"A"2 12 2 12 2

2 1"A"2 12 I 12 I

anufacturing industries andconstruction (combustion)











2 1"A"2 12 3 12 3

2 1"A"2 12 3 12 3

2 1"A"2 18 2 18 2

2 1"A"2 18 I 18 I

2 1"A"2 18 1 18 1

2 1"A"2 18 1 18 1

2 1"A"2 18 3 18 3

2 1"A"2 18 1 18 2

2 1"A"2 18 3@

2 1"A"2 13 2 13 2


anufacturing industries and

construction (combustion)












2 1"A"2 13 I 13 I

2 1"A"2 13 1 13 1

2 1"A"2 13 1 13 1

2 1"A"2 13 1 13 1

2 1"A"2 13 3 13 3

2 1"A"2 13 13 3? 3

2 1"A"2"a 1I 18 1I 18

2 1"A"2"a 1I 11 2 3

2 1"A"2 1I 3J













2 1"A"2 1I 1 11

2 1"A"2 16 16

2 1"A"2"a 16 8 16 8

2 1"A"2"a 16 6 16 6

2 1"A"2"a 1@ @ 1@ @

2 1"A"2"a 1@ 2 1@ 3

2 1"A"2"a 1@ 2 1@ 3

2 1"A"2"a 1@ I 1@ ?

2 1"A"2 1? 1?

2 1"A"2"a 1? 2 1? 2














2 1"A"2"a 1? 1 1? 2

2 1"A"2"a 1? 1 1? 2

2 1"A"2 1? 1J

2 1"A"2"a 1J 8 1J 8

2 1"A"2"a 1J 1 1J 8

2 1"A"2"a 1J 1 1J 8

2 1"A"2"a 1J 1 1J 8

2 1"A"2"b 2 2 2 3

2 1"A"2"b 2 2 2 3

2 1"A"2 2 26














2 1"A"2"b 2 1 2@ 8

2 1"A"2"b 21 1 21 8

2 1"A"2"b 22 1 22 8

2 1"A"2"b 22 1 22 8

2 1"A"2"b 22 1 22 8

2 1"A"2"b 22 1 22 8

2 1"A"2 22 2I

2 1"A"2"b 28 1 28 8

2 1"A"2"b 28 1 28 8

2 1"A"2"b 23 1 23 8
















2 1"A"2"b 23 1 23 8

2 1"A"2 23 2@

2 1"A"2"b 2I 2 2I 3

2 1"A"2"b 2I 2 2I 3

2 1"A"2"b 2I 2 2I 3

2 1"A"2"b 26 1 26 8

2 1"A"2"b 2@ 1 2@ 8

2 1"A"2"d 2? 2 2? 3

2 1"A"2"d 2? 1 2J I

2 1"A"2"d 2J 8 2J I

2 1"A"2"d 2J 1 2J 2














2 1"A"2"d 2J 1 2J 2

2 1"A"2"d 2J 8 2J I

2 1"A"2 2J 3

2 1"A"2"f"i 8 1 8 1

2 1"A"2"f"i 8 8 8 I

2 1"A"2"f"i 8 2 81 3

2 1"A"2"f"i 8 2 81 3

2 1"A"2"f"i 81 2 81 8

2 1"A"2"f"i 81 2 81 8














2 1"A"2"f"i 82 1 8I 3

2 1"A"2"f"i 82 8 8I 8

2 1"A"2"f"i 82 8 8I 8

2 1"A"2"f"i 82 1 8I 3

2 1"A"2"f"i 88 8 88 I

2 1"A"2"f"i 88 8 88 I

2 1"A"2"f"i 83 1 83 8

2 1"A"2"f"i 83 1 83 8

2 1"A"2 8I 8I

2 1"A"2"f"i 8I 1 8I 8

2 1"A"2"f"i 8I 8















2 1"A"2"f"i 86 1 8J 8

2 1"A"2"f"i 86 1 8J 8

2 1"A"2"f"i 8@ 1 8@ 8

2 1"A"2"f"i 8@ 1 8@ 8

2 1"A"2 8@ 2

2 1"A"2"f"i 8? 2 8? 2

2 1"A"2"f"i 8? 2 8? 2











2 1"A"2"f"i 3 1 3 3

2 1"A"2"f"i 3 1 31 2

2 1"A"2"f"i 3 1 31 2

2 1"A"2"f"i 31 1 31 2

2 1"A"2"f"i 31 1 31 2

2 1"A"2"f"i 32 8 32 8

2 1"A"2"f"i 32 8 32 8










2 1"A"2"f"i 32 1 38 8

2 1"A"2"f"i 32 1 38 8

2 1"A"2"f"i 38 1 38 8

2 1"A"2"f"i 33 1 36 8

2 1"A"2"f"i 33 1 3? 8

2 1"A"2"f"i 3I 2 3I 2

2 1"A"2"f"i 3I 2 3I 2

2 1"A"2"f"i 36 1 36 8

2 1"A"2"f"i 36 1 36 8

2 1"A"2"f"i 3@ 8 3@ 8













2 1"A"2"f"i 3@ 8 3@ 8

2 1"A"2"f"i 3@ 1 3? 8

2 1"A"2"f"i 3@ 1 3? 8

2 1"A"2"f"i 3? 1 3? 8

2 1"A"2 I1 1 I1 1

2 1"A"2 I1 1 I2 1

2 1"A"2 I2 I2

2 1"A"2 I2 2 I2 3












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

8 $ivil aviation 1"A"8"a 1 18 $ivil aviation 1"A"8"a 2 I 2 I

8 $ivil aviation 1"A"8"a 2 J 2 1@

8 $ivil aviation 1"A"8"a 2 J 2 1@

8 $ivil aviation 1"A"8"a 8 13

8 $ivil aviation 1"A"8"a 3 @ 3 1@

8 $ivil aviation 1"A"8"a 3 1? 3 22

8 $ivil aviation 1"A"8"a 3 1J 3 22







8 $ivil aviation 1"A"8"a I

8 $ivil aviation 1"A"8"a 6 1 6 1

8 $ivil aviation 1"A"8"a @ 12 @ 18

8 $ivil aviation 1"A"8"a @ 2 @ 88 $ivil aviation 1"A"8"a @ J @ 1

8 $ivil aviation 1"A"8"a @

8 $ivil aviation 1"A"8"a ? @ ? 18

8 $ivil aviation 1"A"8"a J ? J J

8 $ivil aviation 1"A"8"a J


8 $ivil aviation 1"A"8"a 11

8 $ivil aviation 1"A"8"a 12 31 12 32


8 $ivil aviation 1"A"8"a 18 18 18 2?



8 $ivil aviation 1"A"8"a 18 82 13 188 $ivil aviation 1"A"8"a 13 2J 13 82

8 $ivil aviation 1"A"8"a 13 1? 13 82

8 $ivil aviation 1"A"8"a 13 13 1@ 3

8 $ivil aviation 1"A"8"a 1I 1 1I 2

8 $ivil aviation 1"A"8"a 1I 1 1I 2

8 $ivil aviation 1"A"8"a 1I

8 $ivil aviation 1"A"8"a 1@ 1 1@ 3

8 $ivil aviation 1"A"8"a 1@

8 $ivil aviation 1"A"8"a 1? @ 1? 18

8 $ivil aviation 1"A"8"a 1? 16 1? 1@



8 $ivil aviation 1"A"8"a 1? 28 1? 23

8 $ivil aviation 1"A"8"a 1? 1I 1? 23

8 $ivil aviation 1"A"8"a 1? 2I 2 1

8 $ivil aviation 1"A"8"a 1?

8 $ivil aviation 1"A"8"a 1? 6

8 $ivil aviation 1"A"8"a 1? @








8 $ivil aviation 1"A"8"a 22 8 22 J

8 $ivil aviation 1"A"8"a 22 12 28 ?8 $ivil aviation 1"A"8"a 28

8 $ivil aviation 1"A"8"a 2I 6 26 1

8 $ivil aviation 1"A"8"a 2I 2J


8 $ivil aviation 1"A"8"a 2I 38 $ivil aviation 1"A"8"a 26 I 26 6

8 $ivil aviation 1"A"8"a 26 @ 26 @

8 $ivil aviation 1"A"8"a 26 J 2@8 $ivil aviation 1"A"8"a 26 11

8 $ivil aviation 1"A"8"a 2@ @ 2J 6

8 $ivil aviation 1"A"8"a 2J 18 82 11

8 $ivil aviation 1"A"8"a 81 6 81 J



8 $ivil aviation 1"A"8"a 83 16 83 1@



8 $ivil aviation 1"A"8"a 86 2J 86 8



8 $ivil aviation 1"A"8"a




















3 oad transport (e&haust) 1"A"8"b 1

3 oad transport (e&haust) 1"A"8"b 8 1 8 2

3 oad transport (e&haust) 1"A"8"b 8 8 8 1@3 oad transport (e&haust) 1"A"8"b 8 ? 8 J

3 oad transport (e&haust) 1"A"8"b 8 18 8 133 oad transport (e&haust) 1"A"8"b 8 1J 8 2?

3 oad transport (e&haust) 1"A"8"b 8 28 8 2I




3 oad transport (e&haust) 1"A"8"b 8 8

3 oad transport (e&haust) 1"A"8"b 8 I

3 oad transport (e&haust) 1"A"8"b 8 @


3 oad transport (e&haust) 1"A"8"b 8 1J3 oad transport (e&haust) 1"A"8"b 8 23 oad transport (e&haust) 1"A"8"b 8 21

3 oad transport (e&haust) 1"A"8"b 8 83 oad transport (e&haust) 1"A"8"b 8 88

3 oad transport (e&haust) 1"A"8"b 8 8I

3 oad transport (e&haust) 1"A"8"b 3 23 oad transport (e&haust) 1"A"8"b 33 oad transport (e&haust) 1"A"8"b 3 J

3 oad transport (e&haust) 1"A"8"b 6 2J 6 83 oad transport (e&haust) 1"A"8"b 6 @3 oad transport (e&haust) 1"A"8"b 6 8I



3 oad transport (e&haust) 1"A"8"b @ 1 @ 2

3 oad transport (e&haust) 1"A"8"b @ 1 @ 13

3 oad transport (e&haust) 1"A"8"b @ I 1I ?

3 oad transport (e&haust) 1"A"8"b ? 13 oad transport (e&haust) 1"A"8"b ? 18 ? 18

3 oad transport (e&haust) 1"A"8"b ? 12 1I 8



3 oad transport (e&haust) 1"A"8"b ? 12 1I 8

3 oad transport (e&haust) 1"A"8"b ? 12 1I 83 oad transport (e&haust) 1"A"8"b 11 2 11 23 oad transport (e&haust) 1"A"8"b 12 2 12 23 oad transport (e&haust) 1"A"8"b 18 2 18 23 oad transport (e&haust) 1"A"8"b 1I 8 1I 83 oad transport (e&haust) 1"A"8"b 1I 8

3 oad transport (e&haust) 1"A"8"b 16 2J 81 13 oad transport (e&haust) 1"A"8"b 16 81

3 oad transport (e&haust) 1"A"8"b 16 2J

3 oad transport (e&haust) 1"A"8"b 1@ J 81 2


3 oad transport (e&haust) 1"A"8"b 81 8I

3 oad transport (e&haust) 1"A"8"b 8I J 8I 13 oad transport (e&haust) 1"A"8"b 8I 16 8I 16



3 oad transport (e&haust) 1"A"8"b 8I 16

3 oad transport (e&haust) 1"A"8"b 8I 2

3 oad transport (e&haust) 1"A"8"b 8I 1@

3 oad transport (e&haust) 1"A"8"b 8@ 3

3 oad transport (e&haust) 1"A"8"b 8J ? 8J 1?



3 oad transport (e&haust) 1"A"8"b"iii I8 2I I3 833 oad transport (e&haust) 1"A"8"b I8 83 oad transport (e&haust) 1"A"8"b I8 ?

3 oad transport (e&haust) 1"A"8"b I8 12



3 oad transport (e&haust) 1"A"8"b II

3 oad transport (e&haust) 1"A"8"b I?

3 oad transport (e&haust) 1"A"8"b"iii 68 26 6I 2J

3 oad transport (e&haust) 1"A"8"b 6@

3 oad transport (e&haust) 1"A"8"b @3

3 oad transport (e&haust) 1"A"8"b @6

3 oad transport (e&haust) 1"A"8"b 1 I 1 @

3 oad transport (e&haust) 1"A"8"b 1 @ 1 ?



3 oad transport (e&haust) 1"A"8"b 1

3 oad transport (e&haust) 1"A"8"b 1@ ? 1@ 13

3 oad transport (e&haust) 1"A"8"b 11I 1 11?

3 oad transport (e&haust) 1"A"8"b















I oad transport. gasoline evaporation 1"A"8"b"v 1 81

I oad transport. gasoline evaporation 1"A"8"b"v 2 12 2 13

I oad transport. gasoline evaporation 1"A"8"b"v 2 1J 2 2@

I oad transport. gasoline evaporation 1"A"8"b"v 2 2I 2 2@

I oad transport. gasoline evaporation 1"A"8"b"v 2 @


I oad transport. gasoline evaporation 1"A"8"b"v 2

I oad transport. gasoline evaporation 1"A"8"b"v 8 26 2 2@



I oad transport. gasoline evaporation 1"A"8"b"v 8 2 8 I

I oad transport. gasoline evaporation 1"A"8"b"v 8 @ 8 13

I oad transport. gasoline evaporation 1"A"8"b"v 8 26 8 2@


I oad transport. gasoline evaporation 1"A"8"b"v 8 8J 3 1





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I oad transport. gasoline evaporation 1"A"8"b"v 8 2J



I oad transport. gasoline evaporation 1"A"8"b"v 8 8I

I oad transport. gasoline evaporation 1"A"8"b"v 3 ? 3 1




I oad transport. gasoline evaporation 1"A"8"b"v 3 ?

I oad transport. gasoline evaporation 1"A"8"b"v I I I 11

I oad transport. gasoline evaporation 1"A"8"b"v I 3 I 18


I oad transport. gasoline evaporation 1"A"8"b"v I I I 6


I oad transport. gasoline evaporation 1"A"8"b"v I 1I I 1I


I oad transport. gasoline evaporation 1"A"8"<" I 8 2 1

I oad transport. gasoline evaporation 1"A"8"b"v I






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I oad transport. gasoline evaporation 1"A"8"b"v ?

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I oad transport. gasoline evaporation 1"A"8"b"v J 12 J 18




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I oad transport. gasoline evaporation 1"A"8"b"v 2 ? 2 J








I oad transport. gasoline evaporation 1"A"8"b"v






6 1"A"8"b"vi 1

6 1"A"8"b"vi 2 1 2 1I

6 1"A"8"b"vi 2 28 2 2I

6 1"A"8"b"vi 2 1

6 1"A"8"b"vi 2 13

6 1"A"8"b"vi 2 1@

oad transport. automobile tyre andbra!e wear and road abrasion



oad transport. automobile tyre and

bra!e wear and road abrasionoad transport. automobile tyre andbra!e wear and road abrasion




6 1"A"8"b"vi I 2

6 1"A"8"b"vi 6 8

6 1"A"8"b"vi @ 88

6 1"A"8"b"vi 1 J 12 1

6 1"A"8"b"vi 1 1

6 1"A"8"b"vi 11 1 12 1

6 1"A"8"b"vi 12 1 18 2@

6 1"A"8"b"vi 18 83

6 1"A"8"<", 13 6 2? I

6 1"A"8"b"vii 13

6 1"A"8"b"vii 13 18





bra!e wear and road abrasion











6 1"A"8"b"vi 13

6 1"A"8"b"vi 13

6 1"A"8"b"vi 13 1I

6 1"A"8"b"vii 1I 16

6 1"A"8"b"vi 1I 21 16 2

6 1"A"8"b"vi 1I 21 16 2

6 1"A"8"b"vi 1I 12

6 1"A"8"b"vi 1I 1I

6 1"A"8"b"vi 1I 1J

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6 1"A"8"b"vi 16 6

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6 1"A"8"b"vii 1@ 28

6 1"A"8"b"vi 1@ 13



















6 1"A"8"b"vi 1@ 13

6 1"A"8"b"vi 1@ 16

6 1"A"8"b"vi 1@ 22

6 1"A"8"b"vii 23

6 1"A"8"b"vii 2I

6 1"A"8"b"vii 26

6 1"A"8"b"vi 26 11

6 1"A"8"b"vi 26 1?

6 1"A"8"b"vi 2@ 3

6 1"A"8"b"vi 2? 1













6 1"A"8"b"vii 2J 18 2J 1?

6 1"A"8"b"vi 2J 2 2J 8

6 1"A"8"b"vi 8 8

6 1"A"8"b"vi 6 6

6 1"A"8"b"vii

6 1"A"8"b"vii

6 1"A"8"b"vii

6 1"A"8"b"vii

6 1"A"8"b"vii

6 1"A"8"b"vi

6 1"A"8"b"vi















6 1"A"8"b"vi@ ailways 1"A"8"c 3 16

@ ailways 1"A"8"c 6 1I 6 21

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@ ailways 1"A"8"c 6 J@ ailways 1"A"8"c 6 18

@ ailways 1"A"8"c 6 2

@ ailways 1"A"8"c @ 1? @ 23

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@ ailways 1"A"8"c 11 3

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@ ailways 1"A"8"c 12 22 12 22

@ ailways 1"A"8"c 12 2 12 2@ ailways 1"A"8"c 12 ? 12 ?



@ ailways 1"A"8"c 12 22 12 22

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@ ailways 1"A"8"c 16 1 16 1

@ ailways 1"A"8"c 16 1 16 1

@ ailways 1"A"8"c

@ ailways 1"A"8"c

? 1"A"8"d 8,nter(national) navigation. nationalfishing



? 1"A"8"d 3 82 3 32

? 1"A"8"d 3 82 3 32

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,nter(national) navigation. national

fishing

,nter(national) navigation. nationalfishing








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? 1"A"8"d 8@

? 1"A"8"d 8?

? 1"A"8"d 8?

? 1"A"8"d 8J ?

? 1"A"8"d 8J 81

? 1"A"8"d 8J ?

? 1"A"8"d 8J 81

? 1"A"8"d 8J

? 1"A"8"d 3 1 3 8

? 1"A"8"d 3 23 3 2@

? 1"A"8"d 3 1 3 8

? 1"A"8"d 3 23 3 2@

? 1"A"8"d 3@ 3 3? 2

? 1"A"8"d 3@ 3 3? 2

















? 1"A"8"d 3? 6 3? 11

? 1"A"8"d 3? 6 3? 11

? 1"A"8"d 3? 3J

? 1"A"8"d 3? 26

? 1"A"8"d 3J

? 1"A"8"d I 83 I1 2?









? 1"A"8"d I 83 I1 2?

? 1"A"8"d I8 1 I8 1

? 1"A"8"d I8 1 I8 1






? 1"A"8"d I8 1

? 1"A"8"d I8 1

? 1"A"8"d

? 1"A"8"d


fishing






? 1"A"8"d

? 1"A"8"d


fishing




? 1"A"8"d

? 1"A"8"d

? 1"A"8"d

? 1"A"8"d

? 1"A"8"d

? 1"A"8"d

? 1"A"8"d

? 1"A"8"d

? 1"A"8"d

? 1"A"8"d

J *ipeline compressors 1"A"8"e"i


fishing





fishing








1 %mall combustion 1"A"I 1

1 %mall combustion 1"A"3 2 28 2 28

1 %mall combustion 1"A"3 2 2


1 %mall combustion 1"A"3 8 1J 8 1J





1 %mall combustion 1"A"3 3 @1 %mall combustion 1"A"3 I 86 I 86



1 %mall combustion 1"A"3 @ I @ ?

1 %mall combustion 1"A"3 @ 1? @ 2

1 %mall combustion 1"A"3 ? 88 ? 88

1 %mall combustion 1"A"3 J 6 J ?

1 %mall combustion 1"A"3 13 1I

1 %mall combustion 1"A"3 16 1@ 16 88

1 %mall combustion 1"A"3 1? 1 1? 1





1 %mall combustion 1"A"3 1? @

1 %mall combustion 1"A"3 1J 1 1J 1

1 %mall combustion 1"A"3 1J 18 1J 18

1 %mall combustion 1"A"3"b"i 1J 1 1J 1I

1 %mall combustion 1"A"3 1J 8@

1 %mall combustion 1"A"3 1J

1 %mall combustion 1"A"3 1J 13



1 %mall combustion 1"A"3"b"i 21 22







1 %mall combustion 1"A"3 2I 2

1 %mall combustion 1"A"3"b"i 2@ 2@

1 %mall combustion 1"A"3 2@ 1I 8@ 3



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1 %mall combustion 1"A"3"b"i 2J 1 8@ 2

1 %mall combustion 1"A"3"b"i 2J 1 8@ 2




1 %mall combustion 1"A"3"b"i 8 1 8 2




1 %mall combustion 1"A"3 8I 8I

1 %mall combustion 1"A"3"b"i 8I 8I

1 %mall combustion 1"A"3 8@ 8@

1 %mall combustion 1"A"3"a"i 8@ 1 8@ 3

1 %mall combustion 1"A"3"b"i 8@ 8@

1 %mall combustion 1"A"3 8? 1@ 8? 1?




1 %mall combustion 1"A"3 3I 36

1 %mall combustion 1"A"3 36 3?

1 %mall combustion 1"A"3 3J 1 @1 1

1 %mall combustion 1"A"3 @8 1

1 %mall combustion 1"A"3 ?8 1

1 %mall combustion 1"A"3 ?3 1

1 %mall combustion 1"A"3 ?J 1 ?J 61 %mall combustion 1"A"3 J 1 JI 1

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1 %mall combustion 1"A"3



1 %mall combustion 1"A"31 %mall combustion 1"A"3

1 %mall combustion 1"A"3"b"i

1 %mall combustion 1"A"I

11 1"A"2"f"ii J 23 J 26

11 1"A"2"f"ii 18 1 18 18

11 1"A"2"f"ii 18 1I

11 1"A"2"f"ii 13

'on-road mobile sources andmachinery






11 1"A"2"f"ii 1I

11 1"A"2"f"ii 16

11 1"A"2"f"ii 1@

11 1"A"2"f"ii 22 6 22 ?

11 1"A"2"f"ii 28 11

11 1"A"2"f"ii 28 18

11 1"A"2"f"ii 2? 81

11 1"A"2"f"ii 2? 81

11 1"A"2"f"ii 8@

11 1"A"2"f"ii 8@ I

11 1"A"2"f"ii 8? 16

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11 1"A"2"f"ii 3 1@

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















'on-road mobile sources and

machinery






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

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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



machinery'on-road mobile sources andmachinery




machinery





machinery











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

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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 $oal mining and handling 1"<"1"a 2 6 2 6



















12 $oal mining and handling 1"<"1"a 2 6 2 ?


12 $oal mining and handling 1"<"1"a 2 1@ 2 1@

12 $oal mining and handling 1"<"1"a @ 11 @ 11

12 $oal mining and handling 1"<"1"a J 3 J 3

12 $oal mining and handling 1"<"1"a J ? J ?




12 $oal mining and handling 1"<"1"a

18 %olid fuel transformation 1"<"1"b J 13 J 13

13 :ther (please specify) 1"<"1"c 2 1 2 1

13 :ther (please specify) 1"<"1"c 2 1 2 1



1I 1"<"2"b 2 18 2 18

1I 1"<"2"a"i I @ I @

1I 1"<"2"a"i I J I J

1I 1"<"2"a"i I 26 6 2I

1I 1"<"2"b J 1I J 1@

1I 1"<"2"b 12 12 12 1@

1I 1"<"2"b 12 1I 12 1@

1I 1"<"2"a"i 13 6 13 6

1I 1"<"2"a"i 13 3 13 3

1I 1"<"2"a"i 1I 1 1I 8

1I 1"<"2"b 1I ? 1I J

1I 1"<"2"b 16 1 16 2

&ploration production. transport of oiland natural gas














1I 1"<"2"b 1@ 23 2I 13

1I 1"<"2"a"i 1? 8 1? 23

1I 1"<"2"a"i 22 1 28 1?

1I 1"<"2"a"i 28 1J 23 8

1I 1"<"2"a"i 28 1J 23 8

1I 1"<"2"b 2@ 2?

1I 1"<"2"a"i

1I 1"<"2"b

16 efining > storage 1"<"2"a"iv 2 ?

16 efining > storage 1"<"2"a"iv 8 2

16 efining > storage 1"<"2"a"iv 18 616 efining > storage 1"<"2"a"iv 13 2 13 8


16 efining > storage 1"<"2"a"iv 1I 21 1I 21


16 efining > storage 1"<"2"a"iv 1@ 1? 1@ 1?








&ploration production. transport of oil

and natural gas



16 efining > storage 1"<"2"a"iv 1@ ? 1@ 1

16 efining > storage 1"<"2"a"iv 1@ 2





16 efining > storage 1"<"2"a"iv 2 1?



16 efining > storage 1"<"2"a"iv 22 616 efining > storage 1"<"2"a"iv 22 @

16 efining > storage 1"<"2"a"iv 22 @



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16 efining > storage 1"<"2"a"iv 28 2 28 I16 efining > storage 1"<"2"a"iv 28 1

16 efining > storage 1"<"2"a"iv 23






16 efining > storage 1"<"2"a"iv 231@ 9istribution of oil products 1"<"2"a"v 1

1@ 9istribution of oil products 1"<"2"a"v 8 1

1@ 9istribution of oil products 1"<"2"a"v 3 2@ 3 2@1@ 9istribution of oil products 1"<"2"a"v 3 2J


1@ 9istribution of oil products 1"<"2"a"v I 2

1@ 9istribution of oil products 1"<"2"a"v @ 1 @ 1

1@ 9istribution of oil products 1"<"2"a"v @ J1@ 9istribution of oil products 1"<"2"a"v @ 2@

1@ 9istribution of oil products 1"<"2"a"v @ 881@ 9istribution of oil products 1"<"2"a"v ? @

1@ 9istribution of oil products 1"<"2"a"v ? 121@ 9istribution of oil products 1"<"2"a"v ? 1?1@ 9istribution of oil products 1"<"2"a"v ? 211@ 9istribution of oil products 1"<"2"a"v ? 81@ 9istribution of oil products 1"<"2"a"v ? 8J1@ 9istribution of oil products 1"<"2"a"v J 21@ 9istribution of oil products 1"<"2"a"v J 111@ 9istribution of oil products 1"<"2"a"v J 82

1@ 9istribution of oil products 1"<"2"a"v 11 ? 12 121@ 9istribution of oil products 1"<"2"a"v 11 1@

1@ 9istribution of oil products 1"<"2"a"v 12 ?





1@ 9istribution of oil products 1"<"2"a"v 13 I

1@ 9istribution of oil products 1"<"2"a"v 1I 2

1@ 9istribution of oil products 1"<"2"a"v 1I I

1@ 9istribution of oil products 1"<"2"a"v 1I 6

1@ 9istribution of oil products 1"<"2"a"v 16 I 1? 11



1@ 9istribution of oil products 1"<"2"a"v 1@ 2

1@ 9istribution of oil products 1"<"2"a"v 1@ 3

1@ 9istribution of oil products 1"<"2"a"v 1? 18 1J J

1@ 9istribution of oil products 1"<"2"a"v 1? I1@ 9istribution of oil products 1"<"2"a"v 1? 161@ 9istribution of oil products 1"<"2"a"v 1? 21



1@ 9istribution of oil products 1"<"2"a"v 1? 21@ 9istribution of oil products 1"<"2"a"v 1J 2

1@ 9istribution of oil products 1"<"2"a"v 1J 1J

1@ 9istribution of oil products 1"<"2"a"v 2 6 2 1

1@ 9istribution of oil products 1"<"2"a"v 2 1 2 1J

1@ 9istribution of oil products 1"<"2"a"v 2 I

1@ 9istribution of oil products 1"<"2"a"v 21 ? 21 J1@ 9istribution of oil products 1"<"2"a"v 21 1J1@ 9istribution of oil products 1"<"2"a"v 21 21


1@ 9istribution of oil products 1"<"2"a"v 21 J1@ 9istribution of oil products 1"<"2"a"v 22 12 22 1J

1@ 9istribution of oil products 1"<"2"a"v 22 1@

1@ 9istribution of oil products 1"<"2"a"v 22 2I






1? eothermal energy e&traction 1"<"2"a"vi 8 81 8 88

1? eothermal energy e&traction 1"<"2"a"vi 3 8 3 31? eothermal energy e&traction 1"<"2"a"vi 3 11 3 11

1? eothermal energy e&traction 1"<"2"a"vi I 1 I 1

1J enting and flaring 1"<"2"c 3 1@ 3 26

1J enting and flaring 1"<"2"c 6 16 6 1@



1J enting and flaring 1"<"2"c 6 1? 6 2

1J enting and flaring 1"<"2"c ? 13 ? 13

1J enting and flaring 1"<"2"c ? 11 J @1J enting and flaring 1"<"2"c J 1 J @

1J enting and flaring 1"<"2"c 1 13 1 1I

1J enting and flaring 1"<"2"c 1 1J 1 21

1J enting and flaring 1"<"2"c 1 2

1J enting and flaring 1"<"2"c 11 81J enting and flaring 1"<"2"c 12 2 12 21



1J enting and flaring 1"<"2"c

1J enting and flaring 1"<"2"c

2 $ement production 2"A"1 1 1 1 1

2 $ement production 2"A"1 1 1?

2 $ement production 2"A"1 1 1?

2 $ement production 2"A"1 I 26 I 2@

2 $ement production 2"A"1 I 13 I 2I

2 $ement production 2"A"1 I 2I I 2I

2 $ement production 2"A"1 I 6

2 $ement production 2"A"1 I 2@ 6 I



2 $ement production 2"A"1 J I J 1

2 $ement production 2"A"1 J 2 J 2

2 $ement production 2"A"1 J 2 12 8

2 $ement production 2"A"1 J 12






2 $ement production 2"A"1 11 ? 11 J




2 $ement production 2"A"1 18 132 $ement production 2"A"1 16 18

2 $ement production 2"A"1 16 1I

2 $ement production 2"A"1 1@ 1@

2 Total industrial processes 2

2 $ement production 2"A"1






21 ime production 2"A"2 ? 2 ? 2

21 ime production 2"A"2 ? ?



21 ime production 2"A"2 ? 1

21 ime production 2"A"2 J 2 18 8

22 imestone and dolomite use 2"A"8 1 3

22 imestone and dolomite use 2"A"8 2 21 2 22

22 imestone and dolomite use 2"A"8 2 J

22 imestone and dolomite use 2"A"8 8 1I

22 imestone and dolomite use 2"A"8 8 1J



28 %oda ash production and use 2"A"3 1 6

28 %oda ash production and use 2"A"3 2 1I 2 16

28 %oda ash production and use 2"A"3 2 2I

28 %oda ash production and use 2"A"3 3 2 3 2

28 %oda ash production and use 2"A"3 3 3

28 %oda ash production and use 2"A"3 3 1 3 228 %oda ash production and use 2"A"3 I 2 I J

28 %oda ash production and use 2"A"3 I 3 I I



28 %oda ash production and use 2"A"3 I @ I @

23 Asphalt roofing 2"A"I 1 1 1 1

23 Asphalt roofing 2"A"I 2 I 2 6

23 Asphalt roofing 2"A"I 2 1@

23 Asphalt roofing 2"A"I 8 11

23 Asphalt roofing 2"A"I I 1


23 Asphalt roofing 2"A"I @ 2 @ 2

23 Asphalt roofing 2"A"I ? 3 ? 3


23 Asphalt roofing 2"A"I



2I oad paving with asphalt 2"A"6 1 1 1J 1J

2I oad paving with asphalt 2"A"6 3 2

2I oad paving with asphalt 2"A"6 @ 1I ? 8

2I oad paving with asphalt 2"A"6 18 8

26 2"A"@"a 1 I

2@ $onstruction and demolition 2"A"@"b 8 11 3 3

2@ $onstruction and demolition 2"A"@"b

2? 2"A"@"c 8 23

2? 2"A"@"c 3 1I

2? 2"A"@"c 6 16

2J 2"A"@"d 1 8@

2J 2"A"@"d 1 1 8@ 1

=uarrying and mining of mineralsother than coal

%torage. handling and transport ofmineral products



:ther mineral products (*leasespecify the sources included>e&cludedin the notes column to the right)




2J 2"A"@"d 8 82 8 83

2J 2"A"@"d 3 I 3 @

2J 2"A"@"d I 22 I 22

2J 2"A"@"d @ 8? @ 31

2J 2"A"@"d 11 1J

2J 2"A"@"d 12 81 12 83

2J 2"A"@"d 13 21 13 22

2J 2"A"@"d 1I 6 1I ?

2J 2"A"@"d 1? 3 1? ?

2J 2"A"@"d 2 16

2J 2"A"@"d 22 2 22 2


:ther mineral products (*lease

specify the sources included>e&cludedin the notes column to the right)













2J 2"A"@"d 22 2 8

2J 2"A"@"d 22 8

2J 2"A"@"d 23 2 23 2

2J 2"A"@"d 23 2I

2J 2"A"@"d 23 2 8 2

2J 2"A"@"d 2I 2I

2J 2"A"@"d 2@ 2@

2J 2"A"@"d 2@ 8












2J 2"A"@"d 2@ 8

2J 2"A"@"d 2@ 8

2J 2"A"@"d 81

2J 2"A"@"d 8I 1J

2J 2"A"@"d 86 8@

8 $hemical industry 2"< 2 J



8 $hemical industry 2"< 8

8 $hemical industry 2"< 8

8 $hemical industry 2"<"1 I J I J

8 $hemical industry 2"<"2 6 1 6 1








8 $hemical industry 2"<"I"a ? 1@ ? 1@8 $hemical industry 2"< J 88 J 83


8 $hemical industry 2"<"1 18 16 18 1@

8 $hemical industry 2"<"1 18 18 18 1I

8 $hemical industry 2"< 18 I 18 I

8 $hemical industry 2"< 18 J 18 I

8 $hemical industry 2"< 18 @ 18 11


8 $hemical industry 2"<"8 13 J 13 J

8 $hemical industry 2"<"3 1I 1 1I 2

8 $hemical industry 2"<"I 1I 13 1I 1I

8 $hemical industry 2"<"I"a 1I 13 1I

8 $hemical industry 2"<"1 1@ 2I 1@ 2I



8 $hemical industry 2"<"1 1@ 28 1@ 2I

8 $hemical industry 2"<"1 1@ 28 1@ 2I

8 $hemical industry 2"<"1 1? 8 1? 8

8 $hemical industry 2"<"2 1? @ 1? J

8 $hemical industry 2"<"2 1J 3 1J 6


8 $hemical industry 2"<"2 22 J 22 11



8 $hemical industry 2"<"I"a 23 @

8 $hemical industry 2"<"I"a 2I 1 2I 8

8 $hemical industry 2"<"I"a 26 3 26 6

8 $hemical industry 2"<"I"a 2? 1@ 2? 1@



8 $hemical industry 2"<"I"a 2? 8 2? 8


8 $hemical industry 2"<"I"a 8 1 81 88 $hemical industry 2"<"I"a 81 18 81 18

8 $hemical industry 2"<"I"a 81 6 81 J


8 $hemical industry 2"< 8I 8I

8 $hemical industry 2"<"I"a 86 3 86 38 $hemical industry 2"< 8@ 8@



8 $hemical industry 2"< 8@ 18

8 $hemical industry 2"< 8? J

8 $hemical industry 2"< 8J 1 8J 1?

8 $hemical industry 2"<"I"a 8J 1 88 $hemical industry 2"<"I"a 32 1@ 38 8



8 $hemical industry 2"<"I"a 32 16 1@

8 $hemical industry 2"< 38 1J 33 1I

8 $hemical industry 2"<"I"a 38 2 8


8 $hemical industry 2"<"I"a 3I 1 8

8 $hemical industry 2"<"I"a 36 1 88 $hemical industry 2"<"I"a 3? 8 3? J

8 $hemical industry 2"<"I"a 3? J 3? J

8 $hemical industry 2"<"I"a 3? 3 6

8 $hemical industry 2"<"I"a 3? @ J



8 $hemical industry 2"<"I"a 3? 1

8 $hemical industry 2"<"I"a 3J 21 23

8 $hemical industry 2"<"I"a I 6 I 6

8 $hemical industry 2"<"I"a I2 1 I2 1

8 $hemical industry 2"<"I"a I2 @

8 $hemical industry 2"<"I"a I8 2 I8 J

8 $hemical industry 2"<"I"a I8 1 8

8 $hemical industry 2"<"I"a I8

8 $hemical industry 2"<"I"a I88 $hemical industry 2"<"I"a II 11 II 11

8 $hemical industry 2"<"I"a I@

8 $hemical industry 2"< I? I?

8 $hemical industry 2"< I? 6

8 $hemical industry 2"< IJ 1 IJ 1J8 $hemical industry 2"< 61 28




8 $hemical industry 2"<"1 68 6 68 ?

8 $hemical industry 2"<"1 68 2

8 $hemical industry 2"<"I"a 63 1J 63 21

8 $hemical industry 2"<"I"a 6I 6 6I 6

8 $hemical industry 2"<"I"a 6I 3

8 $hemical industry 2"<"I"a 6I ?



8 $hemical industry 2"<"I"a 6@ 8 3

8 $hemical industry 2"<"I"a 6@ I @

8 $hemical industry 2"<"I"a 6J 1 2



8 $hemical industry 2"< 16 @

8 $hemical industry 2"<"1

81 ,ron and steel production 2"$"1 1 61



81 ,ron and steel production 2"$"1 I 21


81 ,ron and steel production 2"$"1 11 J


81 ,ron and steel production 2"$"1 11 8681 ,ron and steel production 2"$"1 12 1@



81 ,ron and steel production 2"$"1 13 11 1I J

81 ,ron and steel production 2"$"1 16 3 1@ 2

81 ,ron and steel production 2"$"1 1? J81 ,ron and steel production 2"$"1 21 6

81 ,ron and steel production 2"$"1 22 1? 22 1?


81 ,ron and steel production 2"$"1 22

81 ,ron and steel production 2"$"1 2I 11 2I 11




81 ,ron and steel production 2"$"1 2I 2@

81 ,ron and steel production 2"$"1 2I J 2@ 6

81 ,ron and steel production 2"$"1 2I J 2@ 6

81 ,ron and steel production 2"$"1 26 8 26 8

81 ,ron and steel production 2"$"1 26 8 26 8

81 ,ron and steel production 2"$"1 26 @ 26 @

81 ,ron and steel production 2"$"1 26 @ 26 @

81 ,ron and steel production 2"$"1 26 2@

81 ,ron and steel production 2"$"1 2@ 8 2@ 8






81 ,ron and steel production 2"$"1 2@ ? 8 8

81 ,ron and steel production 2"$"1 2? 18 2? 18

81 ,ron and steel production 2"$"1 2? 2?

81 ,ron and steel production 2"$"1 2? 2?81 ,ron and steel production 2"$"1 2? 12 2? 18

81 ,ron and steel production 2"$"1 2? 8




81 ,ron and steel production 2"$"1 83 I 83 I






81 ,ron and steel production 2"$"1 8I 8I



81 ,ron and steel production 2"$"1 86 8?

81 ,ron and steel production 2"$"1 8@ 8?

81 ,ron and steel production 2"$"1 8@ 8?

81 ,ron and steel production 2"$"1 32 2? II 3

81 ,ron and steel production 2"$"1 II I I6 16

81 ,ron and steel production 2"$"1

81 ,ron and steel production 2"$"1

82 Ferroalloys production 2"$"2 1 6



82 Ferroalloys production 2"$"2 3 28 3 28

82 Ferroalloys production 2"$"2 3 22 3 28

88 Aluminium production 2"$"8 2 2


88 Aluminium production 2"$"8 1 1 1 2

88 Aluminium production 2"$"8 1 2 18 I












88 Aluminium production 2"$"8 13


83 $opper production 2"$"I"a 1 16


83 $opper production 2"$"I"a 2 8 2 3

83 $opper production 2"$"I"a 3 I

83 $opper production 2"$"I"a @ @

83 $opper production 2"$"I"a @ @



83 $opper production 2"$"I"a @ 13 @ 1I

83 $opper production 2"$"I"a @ 1I J 2

83 $opper production 2"$"I"a ? 1

83 $opper production 2"$"I"a J J

83 $opper production 2"$"I"a J 1 J 2


83 $opper production 2"$"I"a 1 1 1 2

83 $opper production 2"$"I"a
















8I ead production 2"$"I"b 1 21



8I ead production 2"$"I"b 6 8 16 3

8I ead production 2"$"I"b ? ?

8I ead production 2"$"I"b ? 16



8I ead production 2"$"I"b ? 16

8I ead production 2"$"I"b J J






8I ead production 2"$"I"b 1I 1I

86 'ic!el production 2"$"I"c 1 ?

86 'ic!el production 2"$"I"c 2 2



86 'ic!el production 2"$"I"c 2 6 2 ?

86 'ic!el production 2"$"I"c 3 18 3 18

86 'ic!el production 2"$"I"c 3 3

86 'ic!el production 2"$"I"c 3 ? 3 J

86 'ic!el production 2"$"I"c ? ?

8@ Yinc production 2"$"I"d 1 2


8@ Yinc production 2"$"I"d 2 1 2 11


8@ Yinc production 2"$"I"d I I



8@ Yinc production 2"$"I"d @ @

8@ Yinc production 2"$"I"d @ @ @ ?

8@ Yinc production 2"$"I"d ? 88 ? 83

8@ Yinc production 2"$"I"d J 2 J 2

8@ Yinc production 2"$"I"d J 12

8@ Yinc production 2"$"I"d J 1I












8@ Yinc production 2"$"I"d 1I 8 1I 3



8@ Yinc production 2"$"I"d 1? 1@ 1? 1?

8@ Yinc production 2"$"I"d







8? 2"$"I"e 1 ?

8? 2"$"I"e 3 3

8? 2"$"I"e @ @

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3 *ulp and paper 2"9"1 2 1I

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3 *ulp and paper 2"9"1 16 2 16 2

3 *ulp and paper 2"9"1 16 2

3 *ulp and paper 2"9"1 1@ 8 1@ 8

3 *ulp and paper 2"9"1 1@ 1

3 *ulp and paper 2"9"1 1? 8 1? 8

3 *ulp and paper 2"9"1

31 Food and drin! 2"9"2 11 2 12 2

31 Food and drin! 2"9"2 11 23

31 Food and drin! 2"9"2 16 @ 16 @

:ther metal production (*leasespecify the sources included>e&cludedin the notes column to the right)



%torage. handling and transport ofmetal products (*lease specify thesources included>e&cluded in thenotes column to the right)



31 Food and drin! 2"9"2 1@ 8 1@ 3

31 Food and drin! 2"9"2 1@ I 1@ @31 Food and drin! 2"9"2 1? 3 1? 3

31 Food and drin! 2"9"2 22 23

38 *roduction of *:*s 2" 1 8

38 *roduction of *:*s 2" 1 1 8 1638 *roduction of *:*s 2" 8 8

38 *roduction of *:*s 2"38 *roduction of *:*s 2"

33 $onsumption of *:*s and /s 2"F 1 1

33 $onsumption of *:*s and /s 2"F 6 6

36 *aint application 8"A 8 J 8 13

36 *aint application 8"A 8 13 8 1I

36 *aint application 8"A 8 2? 8 2?



36 *aint application 8"A ? @ J 13

36 *aint application 8"A J 13 J 13

36 *aint application 8"A 1 2I 1 26

36 *aint application 8"A 1 2I 1 2636 *aint application 8"A 1 26 1 2636 *aint application 8"A 11 1 11 236 *aint application 8"A 11 1 11 236 *aint application 8"A 11 1 11 236 *aint application 8"A 11 1 11 236 *aint application 8"A 11 1 11 236 *aint application 8"A 11 1 11 236 *aint application 8"A 11 1 11 2

36 *aint application 8"A 11 1 11 236 *aint application 8"A 11 1 11 236 *aint application 8"A 11 1 11 2

36 *aint application 8"A 11 1 11 2

36 *aint application 8"A 11 1

36 *aint application 8"A 12 81 12 8@





36 *aint application 8"A 12 1I 12 1J

36 *aint application 8"A 12 1I 12 1J



36 *aint application 8"A 1I I 16 I





36 *aint application 8"A 16 22 1@ 3

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36 *aint application 8"A 1@ 8 1@ @

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36 *aint application 8"A 83 1@ 83 83



36 *aint application 8"A 83 1@ 83 83

36 *aint application 8"A 83 1 83 @

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36 *aint application 8




36 *aint application 8"A






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3@ 9egreasing 8"<"1

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3J 8"$ 13 2 13 3

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3J 8"$ 1@ 12

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I8 9airy cattle 3"<"1"a

I8 'on-dairy cattle 3"<"1"b

I8 %heep 3"<"8

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I8 /orses 3"<"6

I8 %wine 3"<"?

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I3 Agricultural soils 3"9 1 1 1 1I3 Agricultural soils 3"9"1 1 1?

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I3 Agricultural soils 3"9"1 2 1@ 2 2

I3 Agricultural soils 3"9 2I3 Agricultural soils 3"9 2 82

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I3 Agricultural soils 3"9 8 1I 8 1II3 Agricultural soils 3"9 8 1 8 1



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I3 Agricultural soils 3"9 3 1J 3 1J



I3 Agricultural soils 3"9"1 3 1I 3 21

I3 Agricultural soils 3"9 3 12I3 Agricultural soils 3"9 3I3 Agricultural soils 3"9"1 3 83



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I3 Agricultural soils 3"9

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II Field burning of agricultural wastes 3"F 2 12



II Field burning of agricultural wastes 3"F 2 2 12II Field burning of agricultural wastes 3"F 8 1I

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I6 Agriculture other 3"

I@ %olid waste disposal on land 6"A 1 3I@ %olid waste disposal on land 6"A 1

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I@ %olid waste disposal on land 6"A 2 13 2 13I@ %olid waste disposal on land 6"A 2 8 2 8I@ %olid waste disposal on land 6"A 2 3 2 3

I@ %olid waste disposal on land 6"A 2 8

I@ %olid waste disposal on land 6"A 2 8I@ %olid waste disposal on land 6"A 2 2 3



I@ %olid waste disposal on land 6"A 8 3 8 I

I@ %olid waste disposal on land 6"A 8 @ 8 @

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I@ %olid waste disposal on land 6"A 3 1? 3 1?

I@ %olid waste disposal on land 6"A

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IJ $linical waste incineration (d) 6"$"a 6 11



IJ $linical waste incineration (d) 6"$"a @ 18

IJ $linical waste incineration (d) 6"$"a @

IJ $linical waste incineration (d) 6"$"a J

IJ $linical waste incineration (d) 6"$"a 18 3 18 3IJ $linical waste incineration (d) 6"$"a 1I

IJ $linical waste incineration (d) 6"$"a 1@

IJ Caste incineration 6"$

6 ,ndustrial waste incineration (d) 6"$"b 1 1J

6 ,ndustrial waste incineration (d) 6"$"b 8 8

6 ,ndustrial waste incineration (d) 6"$"b ? 16 ? 1?

6 ,ndustrial waste incineration (d) 6"$"b J J



6 ,ndustrial waste incineration (d) 6"$"b 11 8 11 8



6 ,ndustrial waste incineration (d) 6"$"b 1@ 1@

61 unicipal waste incineration (d) 6"$"c 8 8


61 unicipal waste incineration (d) 6"$"c 1 161 unicipal waste incineration (d) 6"$"c 11 8 11 8



61 unicipal waste incineration (d) 6"$"c

61 unicipal waste incineration (d) 6"$"c62 $remation 6"$"d @ @

62 $remation 6"$"d



68 %mall scale waste burning 6"$"e 1 1?

68 %mall scale waste burning 6"$"e I 1I

68 %mall scale waste burning 6"$"e J J

63 :ther waste Z 6"9 1 J

63 :ther waste Z 6"9 2 2

63 :ther waste Z 6"9 I 6

63 :ther waste Z 6"9 I @

63 :ther waste Z 6"9 I @

63 :ther waste Z 6"9 I

63 :ther waste Z 6"9 6 1? @ 8

63 :ther waste Z 6"9

63 :ther waste Z 6"96@ Forest fires 11"< 1 18



Comment Action taken

e7ected 'one

'oted

Accepted /$< added to Table 1-1

e7ected

ditorial 9one

ditorial 9one

ditorial 9one

ditorial 9one2nd sentence# 4,A1b4 should read 41A1c4" ditorial 9one

ditorial 9one

'oted

'oted

Proposeddecision

The Fs are clearly inade+uate and was evidentlybeen reviewed by people with no or little

e&perience in emission inventory compilation

The document is wea! in discussing Flue gastreatment impacts on reducing emissions - it is notclear whether emission factors refer to abated orunabated emissions and which abatementtechnology is used" Also see $omment 1 on thissheet (only %o& and ':& abatement are discussedand no co-benefits)

odified te&t to includemore detail on *. someadditional detail onabatement added as anappendi&

Table 1-1 has no mention of /$< despite that

there is a reporting re+uirement for this substance"

missions from crac!ing and catalyst regenerationare includedin $hapter 1"<"2"a"iv" %uggestcombine last 2 sentences to read# 4*roductionprocesses such as thermal crac!ing and catalystregeneration as well as fugitive emissions arecovered in $hapter 1"<4

Te&t modified to clarifyscope"

Add 'F code to title to maintain consistency withtitle 2"1

,nsert 41"A"1"b4 into section 2"2 title as per that for2"1 for 1"A"1"a

This paragraph is unclear" Assumeable there

should be a reference to 1A1c"

, can agree in general about the semplification inmethodologies and in reference to <F but theprevious release of the chapter was reallyinteresting including a very good description of4combustion mechanism4. so 49on0t throw out thebaby with the bath water4K , propose to maintainthe old documentation in the new < for e&ampleas an Appendi&5

$onsult with&pert *anel

%ome additional te&tincluded (on * control)and selected informationincluded as an appendi&

,nsert 41"A"1"c4 into section 2"2 title as per that for2"1 for 1"A"1"a

write# 4Lhas typical combustion temperaturesLleading toL4

For these paragraphs to be of any use they needto be e&panded"

%ome slight modificationsbut readers needing detailshould consult <F

4""up to about 2 Cth""4 should read 4""fromabout 2 Cth"""4

Te&t modified to clarifyscope"



'oted Te&t amended

'oted 'one

Accepted

'otedThe sentence 4can achieve4 is duplicate ditorial 9one

'otedwrite# 4Ltechnology""4 ditorial 9one

Accepted

'oted

'oted 'one

'ot only solid and li+uid fuels contains '. biomassshould be included in the parentheses"

'atural gas fuelled stationary engines should bementioned as a potential large emitter"

As usually in the te&t there are no data aboutpollutants concentration , propose to delete theparagraph 4ercury concentrations are reported tobe in the range of 2 - I [g>m8 for natural gas Qvander ost eldt. 1JJ2. mweltbundesamt.ermany. 1J?R4" Chy /g for natural gas and notother pollutants for other fuelsG

Te&t modified to removedata"

/g levels +uoted for natural gas are too highK owndata show a mean of about 1 ng>m\

mission factor removedfrom te&t. no newreferencable data from *but previous guideboo!factor adopted

The entire chapter on controls in this draft aree&cerpts from the e&isting guideboo!. however ithas been scaled bac! so that the usefulness hastotally vanished"

%ome additional te&tincluded (on * control)and selected informationincluded as an appendi&

,mpacts of control measures on %:& and ':& arediscussed. but there is no discussion of particulatecontrol and the co-benefit of these technologies onthe reduction of e"g" metals

%hort te&t added on *abatement

As usually in the te&t there are no data aboutpollutants concentration , propose to delete theparagraph 4 The ':& reduction efficiency can bebetween @ and J "4 :therwise efficiency mustbe reported for all technologies in an appropriateTable" This last option is most appropriate"

%ome efficiency data fromcurrent guideboo! chapteradded as an appendi&

The sentence 4,f detailed information is available.use it4 is generic. , propose 4if emissions datacoming from continuous stac!s measurement areavailable. use itK otherwise if information comingfrom periodic measurements are available use it incombination with other information4






'oted

Accepted Te&t amended$orrect 4sib-bituminous4 to 4sub-bituminous4 ditorial 9one

'oted 'one

Accepted

ditorial table fuels modified

Table 8-I# no /g emission factor for natural gas" 9iscuss with * @>I>?

Accepted

Accepted Factors provided

Accepted

The statement. that the default emission factorshave been derived from all available data andinformation. seems rather bold when the vastma7ority simply refers to the e&isting guideboo!"

9elete the sentence 4have been derived from allavailable data and information4

9o the term vegetable waste e+uals agriculturalwasteG

There is no clear definition of the assumption(power input. technology. abatement) of the Tier 1methodology" ,f. as stated. the factors are a simplemean , thin! this is not appropriate" Ce cannotevaluate the Fs without reference to a concept of4most used4 technology"

9iscussed with * @>I>?Ksome detail added ande&pansion of Tier 2 factors

9elete 4have been derived from all available dataand information4"

Ce feel *etroleum $o!e would be better classified

under 4hard coal4 rather than heavy fuel oil. as it isa solid fuel

Tables 8-8-8-J are not complete" mission factorsfor *A/ are shown without indication of speciesKemission factors for *$99>F are shown withreference to *A 1JJ? but there are a loturopean-based data on dio&ins emissionK no Ffor *$< and /$< for all fuels"

9iscussed with * @>I>?.*A/ now speciated.*$99>F *$< and /$<added where available"

,nconsistencies in the terminology used to describefuels in different tables

,t should be indicated in the tables what TFsystem (,-TF or C/:-TF) is used for dio&ins

furans

Cill change with new

tables$onsult with&pert *anel

Table 8-@- 8-J# no *$99>F emission factors forheavy fuel oil. other li+uid fuels and biomass" *A/emission factor for biomass should be chec!ed"

Factors reviewed andmodified as appropriate

tier 2 emission factors for stationary engines aremissing

Tables 8-11. 8-12. 8-18. 8-13. 8-16. 8-1@. 8-1J. 8-2# emission factors are shown with reference tothe uideboo! 26" <ut uideboo! 26 doesnot contain e&actly the same emission factorsKmaybe they were recalculated - this should beindicated" $ombustion emissions significantlydepend on boilers power. but Tier 2 tables do notaccount this"

Tables revised. source offactors should now beclearer



9iscussed with * @>I>?

Accepted

'oted

'oted 9iscussed with * @>I>?


'oted

Accepted

'oted

'oted

Tables 8-11. 8-12. 8-18. 8-16. 8-1@. 8-1J. 8-2(Tier 2) and Tables 8-8 -8-3 (Tier 1) include sameemission factor for *$99>F with reference to *A1JJ? ] a lot of data available for *$99>F emissionfrom coal combustion in urope"


'o subdivision based on Ct of the plant arereported in Tier 2 methodology (the 4old4 <reported this subdivision5)K this subdivision can bemore relevant that the subdivision between drybottom and wet bottom reported in the new <

9iscussed with * @>I>?KsiHe split retained

'o subdivision based on technology of combustion(low ':& burner - staged air supply o overfire air)of the plant are reported in Tier 2 methodology (the4old4 < reported this subdivision5)K thissubdivision can be more relevant that thesubdivision between dry bottom and wet bottom

reported in the 4new4 <

9iscussed with * @>I>?.some te&t on abatementefficiency retained as anappendi& to maintain

information

'o complete subdivision based on configuration ofburner (wall or tangential) are reported in Tier 2methodology (the 4old4 < reported thissubdivision5)K this subdivision can be more relevantthat the subdivision between dry bottom and wetbottom reported in the 4new4 <

'o control system specification in Tier 2methodology (the 4old4 < reported thisinformation5)K

nclear ':& emission factors and undefinedreferences. for e&ample for coal the F is too lowcompared with the methodology of 4old4 < seeTable 2I of the <11 chapter" For natural gas the Fis to high compared with the methodology of 4old4< see Table 23 of the <11 chapter controlsG

%ome factors modified bye&tension to Tier 2 tables

nclear %:& emission factors ( % in fuelG ashcontent in coalG) controlsG

Te&t now includescalculation from fuel %

nclear $:. $:. / emission factors. noreference with 4old4 <

%ome factors modified bye&tension to Tier 2 tables

* emission factors unacceptable for Tier 2" ,n% *A for e&ample a 9ry bottom plant burning$oal with no control has F N 8J?.@ while thesame plant with baghouse has F N 8.I" 4'ew4 <($*,*) report F N 26" Chat is theassumption5 Chat is the control systemG /ow canbe used this emission factor in %weden and

AlbaniaG /ow can be used to evaluate futureemissionsG

Tier 2 factors are now asused in guideboo!supplements from 2I>6



'oted

'oted Tables revised"

'oted Tables revised

Accepted Tables revised



ditorial

ditorial

ditorial

ditorial

Accepted eference included


'oted 9iscuss with * @>I>?

Accepted 9one

Accepted 9one

Accepted 9one

Accepted 9one

Accepted 9one

Accepted 9one9elete 4)4 after 44 ditorial 9one

Add 4Q$oncawe. 2@R4 after 4$oncawe4 Accepted 9one

$:'$%,:' the tables are unclear andunusable. the 4interpretation4 of the 4old4 < F isan unacceptable simplification

9iscussed with * @>I>?"ore of old guideboo!retained"

Table 8-18 (Tier 2)# * and / emission factorsare the same as in the Table 8-3 (Tier 1)"

Table 8-1I (Tier 2)# emission factors are the sameas in the Table 8-I (Tier 1)K no /g emission factor"

Table 8-1?# no *$99>F emission factors for woodand similar wood wastes"

Table 8-1@ (Cet <ottom <oilers) and the Table 8-12 (9ry bottom <oilers)# the same emission factorsfor all technologies - this is not correct"

Table 8-21# no *$99>F emission factors for woodand similar wood wastes"

This table 8-22 is an e&act duplicate of table 8-23in chapter 1A3. including the mista!e of having a

negative T%* emission factor"


tables,n the 4'ot estimated4 list of Table 8-22. *A/0sshould be deleted

Cill change with newtables

,n the 4'ot estimated4 list of Table 8-28. %:&should be deleted


,n the 4'ot estimated4 list of Table 8-23. * shouldbe deleted


ven though this report is a draft version thereshould not be incomplete references to otherchapters. unless the intent is to purposely annoythe reader" This is a recurring problem severaltimes in this draft version"

The industry emission reporting guidance does notprovide anydetails of the technologies" 9elete 4andthe industry emissionreporting guidance Q$oncawe.2@R4"

$:'$%,:' the tables are unclear andunusable. the only complete wor! by $oncawe wasnot used

For guidance add 4-see $hapter 1<2c4 after4""""activities4

For guidance add 4-see $hapter 1<2a"iv4 after4""""units4

For guidance add 4-see $hapter 1<2a"iv4 after

4""""releases4For guidance add 4-see $hapter 1<2a"iv4 after4""""emissions4

$hange 4reduced4 to 4eliminated4 as '/8 is fullyconverted

For guidance add 4-see $hapter 1<2a"iv4 after4""""units4



'oted

Accepted 9one Add 4in Appendi& <4 after 4"""comparison4 Accepted 9one

e7ected

Accepted 9one

'oted Te&t revised

Accepted

'oted

There is a specific paper by $oncawe (eport no"J>I 4Air pollutant emission estimation methodsfor * and *T reporting by refineries(revised)4) that the consultant don0t ta!e intoconsideration and use an undefined reference %*A (2)

Table has been revisitedand incorporates $oncaweand other sources

9elete 4grouped by ma7or fuel types4 as onlyrefinery gas F0s given"

Add new paragraph# 4$oncawe has published acompilation ofrecommended emission factors forreporting by refineries under the -*Tre+uirements Q$oncawe. 2@R" For combustionthe ma7ority of these factors are e+uivalent to aTier 2 approach"4

Application of thesefactors by refineryoperators is on a facilitybasis - inclusion of thisstatement may precludeacceptability of this data atTier 8

Following on from comment above. it is proposedthat the followingis added after 4combustion4 at the

end of line 83# 4units e"g" boilers and processheaters and 0furnaces0K4


Tables# - F for %:&# *roviding a fi&ed F for %:&does not permitthe benefits of the reduction in fuelsulphur content by refineriesto be captured ininventories" ember %tate authorities can obtainthe mass and average sulphur content of fuelsused in refineries. soa simple algorithm should beprovided in Tier 2 instead of fi&ed F"

Te&t modified. wheremember %tates havefacility specifc data theyshould incorporate in theirinventories" Tier 2 couldbe refinery-specific but thisis still an aggregatedactivity level"

Tables# - there should be consistency in thenumber of significantfigures used for emissionfactors" Two significant figures should beused forTier 2" ,n Table 3-8 some F0s are given with veryhigh accuracy (e"g" %:& N 83J"J) whereas otherse"g" heavy metals arerounded to only onesignificant figure"


Tables# - calculation of upper and lower JIconfidence limits" The calculation of limits in theseTables do not appear to follow the guidance in thecross-cutting $hapter on uncertainities" Fore&ample. an F with $orinair code $ would haveJI limits of1 of the F value (range I to2 - 1 ta!en as default)" Chere $oncawehas made comments on F0s the upper and lowerlimit values have been calculated according tothese guidelines"

limits revised in updatedtables



'oted

'oted Te&t clarified

'oted 'one

'oted

'oted

Table# F references - there are a number ofreferences to 4uideboo! (26)4 and 4uideboo!(26). % *A (2)4" $oncawe stronglyconsiders that an F derived in some manner(e"g"by ta!ing geometric mean) of upper and lower

limit values of a range.as +uoted in the uideboo!.should ':T be used where a publishedF isavailable from a well established source (e"g" A*-32) whichhas been computed from a large numberof measurements" %uch a mean value has morescientific basis than one derived from valuesateither end of spread for which the distribution isun!nown" That techni+ue is accepted as beingvalid only where an F derivedfrom a number ofmeasurements made in the same way isnotavailable"

'one. but revision ofemission factor tables hasbeen done

Table Titles# Tables 3-8 through 3-@ all refer solelyto 4heaters4" Thereare other combustion units inrefineries e"g" $: boilers. fired waste heat boilers.etc" and heaters are often called 0processfurnaces0(see. e"g. te&t in section 3"1"2) althoughthere is no contact betweenthe fuel and processmaterial",t is proposed. therefore. to help clarifywhat the F0s are for. the term4/eater4 in the titlesof the Tables is changed to 4$ombustion nit4"

Add new paragraph for clarity# 4All the Tier 2emission factorsprovided in Tables 3-8 to 3-? arefor unabated emissions" To estimate emissionswhere abatement systems are installed.informationon abatement system efficiencies isavailable in the efinery <FQ,**$<. 28R4"(/owever. see comment on p 8J. line 8)


%ee earlier note on$oncawe report





'oted

e7ected

'oted

'oted



$omment on table 3-?#- the emission of ':$ is dependent on the fuelgas composition- in the %A :$s (that means non methane > non

ethane hydrocarbons) are regulated and ':T'/$ (non methane /ydro carbons)- the $* <F document 26 mentions onlyformaldehyde as hydrocarbon- $:'9AT,:'# the figues on ':$ intable 3-? should be ta!en out and a generalcomment on the fuel dependancy relating to thisemmitent has to be put in the table" :therwise thefigures will lead to big misunderstandings"

Ce accept that theemission is dependent onfuel composition butcombustion and lubricantsare also relevant" Ce alsoaccept that %*A :$figure also e&cludesethane however. in theabsence of other data. itprovides a reasonablevalue for nm:$" An

alternative would be toapply the the %*A T:$figure" At least onemember state applies anemission limit forformaldehyde butinventory is about totalnm:$ not individualcomponents"

The value for ':B in the table 3-? (1 g>D) isabout 12 mg>'m8 (at 1I :2)" This is about 82mg>'m8 at I :2" This is far away from theindustry recommendation that has been given inthe $* <F" There it was recommended tointroduce 1J mg>'m8 at 1I :2 for lean burn% gas engines" This is about 16 g>D"

$:'9AT,:'#- correct the value according to industryrecommendation"- Furthermore introduce a span for the ':& value"- A value for gas engine that are operated in thegas-diesel-mode is missing" This value has also to

be integrated"

The guideboo! is not

reflecting <AT"





'oted

'oted

'oted 9one where possible


'oted

ditorial

'oted



Crong 'F. it0s no clear what table refer5 ,t0s crudeoil combustionG ChereG ,n a process furnaceG

Table 3-J appears to belong to 'F 1A1c (asshown in table 4code4bo&"


All the Tier 2 emission factors are for unabatedemissions" ,t wouldbe useful to provide a table ofabatement system efficiencies (c"f"tables in1"<"2"a"v and 1"<"2"a"iv) after the Tier 2 F tables"

%ubchapter I 1A1c anufacture of solid fuels# thetitle and content are not harmoniHedK only co!e

manufacture is described"

This section may be misleading" ,f a refinery hasused the $oncaweguidance Q$oncawe. 2@R. thenthe data do not re+uire a =A>=$ chec! as the F0sused would be from well recognised and acceptedsources such as *A A*-32" ,f facility *T dataare e&trapolated to derive national inventories.there is the danger of serious errors as both the* and -*T reporting schemesincludethresholds" ,t is proposed that the second and thirdsentences are switched. te&t e&tended and the restdeleted#Thus# 4efinery installations are ma7orfacilities and emission data forindividual plantsmay be available. but possibly for only alimitednumber of pollutants. through a *T oranother national emission reporting scheme"Chen the +uality of such data is assured by a welldeveloped =A>=$ system. it is good practice touse such data"uidance on estimating refineryemissions has been publishedby the industrysector Q$oncawe. 2@R4

Tect amended to partlyreflect comment"

The heading for this chapter misses the secondpart 4:ther energy industries4

/ave put in those from oldguideboo! *:*s chapter

$:'$%,:' the tables are unclear andunusable

/ave put in those from oldguideboo! *:*s chapter



9one where possible

e7ectedFigure I-1# error in the title" ditorial 9one

ditorial Figure title amended



9one


This chapter is very thin" nder 4Techni+ues4 onlyco!e manufacture is mentioned" The e&istingguideboo! does not have a separate chapter onneither 1A1b nor 1A1c. this would have been ane&cellent time to improve that aspect. alas nothinghas been done"


,t is proposed that there is an additional paragraphon ':& estimation using facility data" 4':&formation is very comple&. anddepends on anumber of parameters e"g" hydrogen and moisturecontents. pre-heat temperature. burner intensity.etc" Amethodology to calculate ':& emissions hasbeen published (in the:il and as Dournal) andprovided in $oncawe. 2@ as the recommendedmethod for refineries to use for emission reporting"Chere facility data are available. this detailedmethodology should beused to obtain more

accurate ':& estimates than the fi&ed valueemission factor provided in the Tier 2 approach"4

The chapter already refersthe reader to $oncaweguidance for Tier 8"

Additional reference or

highlighting of specificpollutants is not necessary"

The decision tree is obviously similar to the one forpetroleum refining. however the figure te&t shouldreflect the correct chapter"

There is no clear definition of the assumption(power input. technology. abatement) of the Tier 1methodology" ,f as stated the factors are a simplemean , thin! this is not appropriate" Ce cannotevaluate the Fs without reference to a concept of4most used4 technology"

,n the tables I-8. I-3 not estimate selenium and/eavy metals" ,t is not correct. because /includes %e"The same problem for *A/ as forother combustion (only summary F. not bypollutants)

There is no clear definition of the assumption(power input. technology. abatement) of the Tier 1methodology" ,f as stated the factors are a simplemean , thin! this is not appropriate" Ce cannotevaluated the Fs without reference to a conceptof 4most used4 technology" :nly very poor list of

pollutants ta!e into account" G :ther li+uid fuelG

$onsult with

&pert *anel

There is no clear definition of the assumption(power input. technology. abatement) of the Tier 1methodology" ,f as stated the factors are a simplemean , thin! this is not appropriate" Ce cannotevaluated the Fs without reference to a conceptof 4most used4 technology" :nly very poor list ofpollutants ta!e into account" G



'oted Appendi& < not Appendi& 2 ditorial 9one

Accepted evised

Accepted

pdate the reference to the $T,$ guide ditorial evised

ditorial

Accepted note added to tables

'oted 'one

ery useful table. however there is no need toseparate emissions from T and gas engines last"The order of the pollutants is also strange. %:2.':& T%* would be the logical order"

T and engines moved.no other comments onpollutant order so notchanged

This glossary should either be e&panded or

removed" %ome listings in the glossary do notappear previously in the te&t"

$onsidering the number of times 4uideboo!(26)4 is referenced in the te&t it is +uite anaccomplishment to have it e&cluded from the list ofreferences"

eferences amended -uideboo! 26 generallyreplaced by original ref"

eference list# There are references given in theF tables of 4%*A (1JJ?)4. 4% *A (2)4and 4% *A (28)4" There areonly two % *Areferences in the eference ist. and one of these

is for 1J?@" The other is undated" The eferenceist needs toreflect the references in the te&t andtables"

eferences will berationalised

'eed to define the calculations assumptionsused to convert emission concentrations into Fand ma!e sure that they are consistent with

Appendi& $

The ':& values from the othenburg *rotocol arelisted in table <3"These values should be ta!en out as there os a

political decision to review the othenburg*rotocol" Furthermore these values (for dieselengines) are far beyond <AT"%ee also#http#>>www"euromot"org>download>news>positions>stationaryPengines>'$P$TA*PA<$PAnalysisP?38"pdf

http#>>www"euromot"org>download>news>positions>stationaryPengines>,**$<P<FPeuromotPcommentPmayP2"pdf

,n these position papers emission limit values arerecommended" Ce propose to overta!e those

emission limit values in table <3"



'oted

'oted

e7ected


The given <F ':B value for new and e&istingstationary gas engines in the table <3 is too low"$orrect span should be 2-1J mg>'m8" *leasecompare the emission table of the eneral

nvironmental /ealth and %afety (/%) uidelinesof the Corld <an!" Corld <an! has implementedemission limit values that are depending on theengine type. the used fuel. the positioon of theengine etc" Ce support this strategy as it refers ondifferent emission limit values that are dependingof different surrounding operation factors" Thesefactors are also depending on the infrastructurearound the engine (water. reagents. fuel +uality.etc")"

*lease compare page @ of the document under thefollowing lin!#

http#>>www"ifc"org>ifce&t>enviro"nsf>Attachments<yTitle>guiP/%uidelines2@Peneral/%>^F,>FinalV-VeneralV/%Vuidelines"pdf

Ce recommend to distinguish the emission limitvalues for different engine types"

The range indicated in the

comment reflects industryview of <ATK the table isintended to summarise themain <F As andcannot reflect allcomments>notes to theTable"

An :2 concentration of 21 instead of 2.Jseems more commonK e"g" 21 is used in theinformative appendi& of ' 131?1

%ome sources use 21 (fore&ample standardisation ofemission concentrations inthe Caste ,ncineration9irective which. as withthe $*9. includesre+uirements on $%uncertainty and hence wasa driver for '131?1).%*A ethod 1J andothers use 2"J forcorrections and someothers apply valuesbetween these figures (fore&ample 2"JI or 2"J6)"9ifference is minor"

convert % *A method 1J in %, units or replace itby the ,A correlations

units are dscm>D or. drym8>D

, could not find any /$< emission factors for coaland wood combustion or other relevant sources"%eehttp#>>reports"eea"europa"eu>*$:,'A,I>en>%ourcesPofP/$<Pemissions"pdf"



'oted eferences revised

'oted






Accepted Additional te&t added

'oted Table included

'oted

'oted

any F-references are of !ind 4(uideboo!26)4" , suggest to refer to original referencesfrom the uideboo! 26"

The units in the emission factor tables should bechanged depending on pollutant" ain pollutants

and particles could be !ept in g>D. while metalscould be listed in mg>D. *A/ in mi!rogram>D ormg>D and dio&in and other *:*0s in ng>D"

'oted and some factorshave been modified

,n the chapters concerning stationary combustionthere are only given a default emission factor for*A/" <ut for reporting purposes individualemission factors are needed for the 3 different*A/0s"

,n the e&isting guideboo! information on the 3different *A/0s is available" A combined *A/emission factor is somewhat useless consideringthe reporting re+uirements"

There are a general lac! of /$< emission factorsin this chapter" ,t seems that only under wasteincineration is an emission factor for /$<provided"

The e&isting guideboo! has a specific chapter on/$<. (and *$<). it would be appropiate if the datain these e&isting chapters were included ande&panded in this revised guideboo!"

A lot of the emission factors references touideboo! 26 does not seem to correspondcorrectly"

"g" ':& emission factor for 9<< residual oil listedin table 8-13 as 8 g>D" ,n the e&istingguideboo! the ':& emission factor for residual oilvaries between 1I and 2J6 g>D

ma!e clear that mission factors refer to netcalorific values

The emission factors for the stationary gasenginestotaly missing"

'o mention of stationary engines in the ethodschapter5

,f the authors could not be bothered to writesomething new. they could at least have copied all

the te&t from the e&isting guideboo!"



Accepted

'oted %ome modification to te&t

Accepted

Accepted

'oted

'oted 'one

'oted Te&t now includes /$<

'oted

'oted

eneral comments# chapter includes large numberof very different processes so will be difficult forusageK there is no indication where to getinformation for estimation of emission from

combustion using proposed methodology (i"e" whatfuel and how much it was used for production of acertain ferrous or non-ferrous metal)" ,n this caseapplicability of it will be low" There are a lot oftables in the chapter which are not applicable. fore&ample. emissions from natural gas combustionin lead or copper production" Assumption that all':&. %:2. $:. ':$ emissions are from fuelcombustion will lead to significant difficulties inemission inventory and to miss of sources"

Tier 1 factors will remainheat input but Tier 2 will berevised to be based onproduction which shouldma!e chapter more useful

For fuel use in conventional boilers. furnace.engine or other device emission information isreferred to $hapters 1A1 and 1A3"

,n table 1-1 under iron and steel one is refered tochapter 1A1 with regard to stationary engines thismust be a mista!e since no guidance on stationaryengines is provided in this chapter"

'one - combustionchapters now include astationary engine table

, assume the correct chapter for guidance onmobile sources in industry would be chapter 1A3:ther obile and not 1A2"

Amended reference to1A2fii

Chere. if any. should be accounted ':& emissionsfrom catalytic o&idation of ammonia in nitric acidproductionG Are you provided for this source of':& emissions in $hapters 1A2 or 2<G

Although ':& arises formo&idation of ammoniaemissions are assigned tothe process

%:& emissions in this 'F category are calculatedonly from %:& emissions from the fuel combustedG

Again there are no mention of /$< despite thereporting re+uirement for this substance"

,t0s not clear where the Fs come from5 *articularlywhen uideboo! (26) is +uoted it0s not true thatFs are present in this form in original reference5 ,felaboration was performed on original data thesemust be e&plained. otherwise the table isunacceptable

9iscussed with *. tableshave been amended toclarify





Accepted

'oted

'oted

'oted

'oted

,ncluded

'oted

There is any reference about what specific fuelsare covered under fuel type named 49erivedFuels4 in this $hapter" Are these specific fuelsthose mentioned in $hapter 1A1. Table 8-2G

Ues. table included from1A1

The JI confidence interval for T%* in Table 8-2is -1. while for *1 and *2.I the interval is

"1-1" ,s lower value for T%* correctG


tables



,t0s not clear where the Fs come from5 *articularlywhen uideboo! (26) is +uoted it0s not true thatFs are present in this form in original reference5 ,felaboration was performed on original data thesemust be e&plained. otherwise the table is

unacceptable

9iscussed with *. tableshave been amended to

clarifyThe JI confidence interval for *1 in Table 8-2is -2. while for T%* and *2.I the interval is"2-2" ,s lower value for *1 correctG


Table 8-8# Chy 9io&ins and Furans emissionfactors for natural gas have not been estimatedGChen using Tier 2 method there is an emissionfactor of 2 ,-T= ng>D for all activities in this 'Fcategory 1A2 with the e&ception of cement andlime production activities (%'A* codes 8811 and8812)

Factors now in at Tier 1 -refer to process emissions

,n Table 8-3 (Tier 1 approach). there is no emission

factor estimated for dio&ins and furans when usingheavy fuel oil"

'ow referenced tocombustion chapters

,n $hapter 1A1. page J. lines 81 to 88. it is saidthat 4for natural gas only emissions of mercury arerelevant """4" /owever no emission factors for /gare indicated in Table 8-18


Tables 8-18. 8-16. 8-1J. 8-26. 8-8. 8-83. 8-86. 8-8?. 8-31. 8-38# F for /g and *b in column alueare shown as . but in column ower ] not "






'oted

'oted

There is no mention to heavy metals in Table 8-I"

'oted

'oted

'oted

'oted

'oted



There is any reference about what specific fuelsare covered under fuel type named 4:ther i+uidFuels4 in this $hapter" Are these specific fuelsthose mentioned in $hapter 1A1. Table 8-2G

Ues. table included from1A1


,n Table 8-I. 9io&ins and Furans emission factorshave not been estimated for :ther i+uid Fuels"/owever. when using Tier 2 approach there is anemission factor of I ,-T= ng>D independently ofwhat is the %'A* activity considered"


Chich fuels are considered under the fuel type4<iomass4G

For combustion these areas listed in 1A1 - table nowincluded in te&t

,n general terms it is have not been clarifiedwhether the proposed emission factors correspondto the emissions originated from only the fuelscombusted or they also correspond to totalemissions originated from the fuels combustedplus those originated from the materials in thecontact furnaces" $arificatin of this pont isparticularly relevant for the activities in the 1A2'F category. as many of its installations are

contact furnaces"

Following discussion with*. Tier 1 is defaultcombustion only. Tier 2 isgenerally only':&>%:B>$: with balanceof emissions assigned to

the process chapters

:nly a un!nown elaboration on very old <values" 'C ,'F:AT,:' F: ,**$ <F9:'0T TA;' ,'T: A$$:'T" Chy only $o!e:ven as when old < contains Fs also for blastfurnace gas and natural gasG %pecific fuelconsumptions in D>g of product %T <*:T95


<last furnace cowpers (%'A* 828)# missionfactors proposed only covers co!e oven gascombustion (table 8-@). but there are noinformation available related to other fuels

(specially blast furnace gas. but also * ornatural gas)"

9iscussed with *. tables

have been amended toclarify

F in tables (Tier 2) for T%*. / and *$99>F arethe similar for same fuel and different processes.for instance. F in Tables 8-?. 8-1I. 8-2@. 8-2?. 8-82. 8-3 (fuel is co!e or hard coal)" The samesituation ] for as. i+uid fuels" /ow this wssprovedG ,s it necessary to duplicate tablesG

Tables revised followingdiscussion with *



'oted

'oted Tables have been revised

'oted

'oted

'oted

'oted

ditorial 9one

'oted

The production processes described in theguideboo! are generic. focussed on applicabilityfor various individual processes" This approachdoes not ta!e into account the more comple&reality of intertwined processes such as ,ron and%teel anufacture" This is especially true for the

use of mi&ed process gases"

Ues but the level of activitydetail defines the basis offactors suitable for use at

Tier 1 and 2Table 8-? Tier 2# it is shown that / emissionfactors are from the uideboo! (26)" <ut in theTable ?"2c of the uideboo! (26) there are nosuch emission factors"

Fs old and not validated" * Fs for 1"A"2 and2"$"1# as you subdivide combustion and notcombustion * emissions5 se <F Fs5


Fs old and not validated" * Fs for 1"A"2 and2"$"1# as you subdivide combustion and notcombustion * emissions5 se <F Fs5


Fs old and not validated" * Fs for 1"A"2 and

2"$"1# as you subdivide combustion and notcombustion * emissions5 se <F Fs5

9iscussed with *. tables

have been amended toclarify

The %'A* code in table 8-1 (882). and theliteral for Technologies>*ractices item (eheatingFurnaces) does not match with the heading of thetable" Chich activity is referred to in this tableG



evised F tables shouldbe clearer

For eheating Furnaces (%'A* 882) there areonly emission factors for co!e oven gas" Chat0sthe matter with the other fuels used in this activityG,n uideboo! 26 there is a wide list of fuels usedin this furnaces"


Table 8-12 (Tier 2)# error in the title of the tableK notcoincide with the content (eheating furnaces)K Ffor *$99>F are shown with reference to theuideboo! 26. but in the uideboo! 26 thereare no such emission factors"

The title refers to 4ray ,ron Foundries4 but thetechnology in the table refers to 4eheatingFurnaces4" /owever e&isting < Fs old and notvalidated" * Fs for 1"A"2 and 2"$"1# as yousubdivide combustion and not combustion *emissions5 se <F Fs5




'oted %ee earlier comment

'oted Table headings modified

'oted

Accepted

'oted


The %'A* code in table 8-12 (882). and theliteral for Technologies>*ractices item (eheatingFurnaces) does not match with the heading of thetable" Chich activity is referred to in this tableGmission factors in this table are the same asthose proposed in Table 8-1"



Tables 8-12 - 8-18 Tier 2# it is !nown that gray ironin foundries is produced using co!e so how F fornatural gas and other li+uid fuels were obtainedand where they can be appliedG

Chy 4:ther i+uid Fuels4G Chy these Fs G %<F Fs5


,n the e&isting guideboo! default values are

provided in g>tonne li+uid steel. which perhaps is abetter unit for these type of default emissionfactors"

Tables have been modifiedto allow use of productionactivity data at Tier 2

The /g emission factor proposed in Table 8-18 is g>D. while the JI confidence interval for thispollutant is "1-"1


The *b emission factor proposed in Table 8-18 is g>D. while the JI confidence interval for thispollutant is "8-"2


Table 8-13# For *rimary and %econdary *b>Yn>$uproduction using 'atural as. it is very surprisingthat there are no heavy metals emissions(indicated as not applicable). ta!ing into acccountthat these are processes with contact and the rawmaterials obviously content the corresponding/eavy etals"

/eavy metals nowassigned to processemission


The same F for *. /. *$99>F and *A/ areshown in the Tables 8-13 (*b>$u>Yn *roduction).8-1@ (%econdary Aluminium *roduction) and 8-2(Alumina>g>'i *roduction)K though technologies

are different"


tables



'oted

'oted

'oted ounding issue corrected

Table 8-16# same comment as for Table 8-1I" 'oted

'oted

All the chapter 48"8"2"2 $ombustion in 1A2b ] 1'on-ferrous metal4 it0s unclear because , don0tunderstand if ta!e into account the differentcondition of combustion in roasting and as it0spossible to subdivide emissions from fuel and frommaterials in such a case (see 'A*,,'AU $:'T)" ,f it0s possible it0snecessary to develop specific emission factors notto copy 4old4 F that derive from anotherapproach"


,n Table 8-1I. emission factors for /eavy etals.9io&ins and Furans and *A/ for *rimary *b. Ynand $u *roduction using co!e are the same as inany other activity in this 1A2 'F category" ,n theparticular case of /eavy etals. it seems thatemission factors only refers to emissionsoriginated from the fuel combusted and there is no

relation to the raw materials used"


the process chaptersTable 8-16 also contains mysterious 44 values"i!ewise with table 8-1J. table 8-26. table 8-8.table 8-83. table 8-86. table 8-8?. table 8-31 andtable 8-38"


the process chaptersThe /g emission factor proposed in Table 8-16 is g>D. while the JI confidence interval for thispollutant is "1-"1




The same F for *. /. *$99>F and *A/ areshown in the Tables 8-16 (*b>$u>Yn *roduction)and 8-1J (%econdary Aluminium *roduction)Kthough technologies are different"


%'A* code in table 8-1@ should be 881 (not

88)


tables,n $hapter 1A1. page J. lines 81 to 88. it is saidthat 4for natural gas only emissions of mercury arerelevant """4" /owever no emission factors for /gare indicated in Table 8-1@

%'A* code in table 8-1? should be 881 (not88)




'oted

Accepted


'oted

'oted

,n Table 8-1?. *1 and *2"I emission factorsfor heavy fuel oil seem to be interchanged (*2"Ivalues are higher than *1)


The same F for *. / and *A/ are shown inthe Tables 8-1? (%econdary Aluminium *roduction)and 8-21 (Alumina>g>'i *roduction)K thoughtechnologies are different" There are errors of Ffor *1 and *2"I in both tables"


%'A* code in table 8-1J should be 881 (not88)


The /g emission factor proposed in Table 8-1J is g>D. while the JI confidence interval for thispollutant is "1-"1


The *b emission factor proposed in Table 8-1J is g>D. while the JI confidence interval for thispollutant is "8-"2



Following discussion with*. Tier 1 is defaultcombustion only. Tier 2 isgenerally only':&>%:B>$: with balanceof emissions assigned tothe process chapters

,n Table 8-21. *1 and *2"I emission factorsfor heavy fuel oil seem to be interchanged (*2"Ivalues are higher than *1)



All the chapter $ombustion in 1A2d ] *ulp and 1paper production is not necessary (emissions arecounted in 1"A"1 as boilers)

<oiler plant emissions canuse factors from 5A1 (or1A3) butthey are not a 1A1activity

*articles and metals in table 8-23 are indicated asincluded elsewhere" Chere would that beG


,n Table 8-28 the JI confidence interval for 'i is"2-"" Chat is the upper bound of thisintervalG




'oted

'oted

ditorial 9one


'oted

'oted

mission factors for dio&ins and furans and *A/for wood are the same as for hard coal (or co!e) inother activities" Are this emission factors correctGCe could not find in uideboo! 26 thisreference for %'A* activity 8821"


,n Table 8-23. particulates and heavy metalsemission factors for blac! li+uor combustion havethe label 4,4" Chere have these emission factorsbeen includedG


Chat does 4,4 for emission factors mean G Chereincluded G

,ncluded elsewhere butthese references havebeen removed (notestimated)

rroneous paragraph numeration 8"8"3 and not

8"8"8"1,n $hapter 1A1. page J. lines 81 to 88. it is saidthat 4for natural gas only emissions of mercury arerelevant """4" /owever no emission factors for /gare indicated in Table 8-2I

*laster# all the te&t it0s unclear because , don0tunderstand if ta!e into account the differentcondition of combustion in !iln and as it0s possibleto subdivide emissions from fuel and frommaterials in such a case (see 'A*,,'AU $:'T)" ,f it0s possible it0snecessary to develop specific emission factors not

to copy 4old4 F that derive from another approach(combustion V process)"

Following discussion with*. Tier 1 is defaultcombustion only. Tier 2 isgenerally only':&>%:B>$: with balance

of emissions assigned tothe process chapters

For *laster Furnaces there are only emissionfactors proposed for natural gas and other li+uidfuels" Chich emission factors should be used forother fuels li!e hard coal. heavy fuel oil. petroleumco!e. wood. """G


The /g emission factor proposed in Table 8-26 is g>D. while the JI confidence interval for this

pollutant is "1-"1


tablesThe *b emission factor proposed in Table 8-26 is g>D. while the JI confidence interval for thispollutant is "8-"2




'oted

ditorial 'one

e7ected


'oted

$ement# all the te&t it0s unclear because , don0tunderstand if ta!e into account the differentcondition of combustion in !iln and as it0s possibleto subdivide emissions from fuel and frommaterials in such a case (see 'A*,,'AU $:'T)" ,f it0s possible it0s

necessary to develop specific emission factors notto copy 4old4 F that derive from another approach(combustion V process)"

Following discussion with*. Tier 1 is defaultcombustion only. Tier 2 isgenerally only

':&>%:B>$: with balanceof emissions assigned tothe process chapters

ive precise reference to F rather thanuideboo! (26)


The table design with one fuel per table do not givea general view of F - all fuels per process in onetable

For $ement *roduction. there are no emissionfactors proposed for petroleum co!e. heavy fueloil. wood and wood wastes" *etroleum co!e is themain fuel used in this activity"


,n $hapter 1A1. page J. lines 81 to 88. it is saidthat 4for natural gas only emissions of mercury arerelevant """4" /owever no emission factors for /gare indicated in Table 8-2J

,n Table 8-2J. 9io&ins and Furans emission factorshas not been estimated for 'ataural as"/owever. whe using Tier 2 approach there is anemission factor of 2 ,-T= ng>D independently of

the %'A* activity considered"


tablesThe /g emission factor proposed in Table 8-8 is g>D. while the JI confidence interval for thispollutant is "1-"1




Table 8-81 Tier 2# no emission factors for *$99>Fwhich are high for waste combustion"

Caste combustion factorsnow removed asinappropriate in thischapter

The fuel indicated in Table 8-81 (/ard coal) is

wrong" ,n accordance with the heading it should be4,ndustrial waste4


Table 8-81# Fuel# eplace 4/ard coal4 with4,ndustrial waste4




'oted

'oted


'oted

'oted

ime# all the te&t it0s unclear because , don0tunderstand if ta!e into account the differentcondition of combustion in !iln and as it0s possibleto subdivide emissions from fuel and frommaterials in such a case (see 'A*,,'AU $:'T)" ,f it0s possible it0s

necessary to develop specific emission factors notto copy 4old4 F that derive from another approach(combustion V process)"

Following discussion with*. Tier 1 is defaultcombustion only. Tier 2 isgenerally only

':&>%:B>$: with balanceof emissions assigned tothe process chapters

'ot all fuels used in lime production are covered inthe 9raft" There are no emission factors for co!e.petroleum co!e. heavy fuel oil or biomass fuels"


,n $hapter 1A1. page J. lines 81 to 88. it is said

that 4for natural gas only emissions of mercury arerelevant """4" /owever no emission factors for /gare indicated in Table 8-88

,n Table 8-88. 9io&ins and Furans emission factorshas not been estimated for 'ataural as"/owever. whe using Tier 2 approach there is anemission factor of 2 ,-T= ng>D independently ofthe %'A* activity considered"

'* factor adopted atTier 1. Tier 2 factors will bein process chapters

':B-F for ime !ilns seems to be very high sincethe needed temperatures are much lower than forcement !ilns" The different !iln types have verydifferent levels on ':B emissions" (seehttp#>>www"umweltbundesamt"at>fileadmin>site>publi!ationen>*12?"pdf. page 11)

Tham!you for providingdata. this is good detail on

state of the art><AT but ison a restricted pool ofplant" 9ata from the draftrevised $* <F doesn0tprovide fuel-based Fs butindicates a very widerange of emissions andthe factors provided in theguideboo! are within therange of 0inferred0 factorsfrom the <F data"

The /g emission factor proposed in Table 8-83 is g>D. while the JI confidence interval for this

pollutant is "1-"1


tablesThe *b emission factor proposed in Table 8-83 is g>D. while the JI confidence interval for thispollutant is "8-"2




'oted

'oted

'oted

Accepted


,n Table 8-86. the fuel is described as 4:ther i+uid

Fuels4. but probably it is about gas oil" ,s thisassumption correctG



Asphalt# all the te&t it0s unclear because , don0tunderstand if ta!e into account the differentcondition of combustion in !iln and as it0s possibleto subdivide emissions from fuel and frommaterials in such a case (see 'A*,,'AU $:'T)" ,f it0s possible it0snecessary to develop specific emission factors notto copy 4old4 F that derive from another approach(combustion V process)" * from process where isinsertedG


,n accordance with uideboo! 26. chapter<8818. 49uring the production of asphalt concreteconsiderable amounts of fine particles can begenerated4"


,n Table 8-8@ (gas natural combustion in asphaltplants). the emission factor for ':$ isindicated as estimated elsewhere (,)"'evertheless. in Table 8-86 (combustion of otherli+uid fuels) an emission factor of 11"? g>D ismentioned"


,n $hapter 1A1. page J. lines 81 to 88. it is saidthat 4for natural gas only emissions of mercury arerelevant """4" /owever no emission factors for /gare indicated in Table 8-8@

The /g emission factor proposed in Table 8-8? is g>D. while the JI confidence interval for thispollutant is "1-"1


The *b emission factor proposed in Table 8-8? is

g>D. while the JI confidence interval for thispollutant is "8-"2




'oted


'oted

'oted


lass# all the te&t it0s unclear because , don0tunderstand if ta!e into account the differentcondition of combustion in !iln and as it0s possibleto subdivide emissions from fuel and frommaterials in such a case (see 'A*,,'AU $:'T)" ,f it0s possible it0snecessary to develop specific emission factors notto copy 4old4 F that derive from another approach(combustion V process)" * from process where isinsertedG etals emissions very important for thesector where are insertedG


For lass *roduction. the %'A* code indicated is88" ,t is suposed that %'A* codes involved are8813. 881I. 8816 and 881@"


,n $hapter 1A1. page J. lines 81 to 88. it is saidthat 4for natural gas only emissions of mercury arerelevant """4" /owever no emission factors for /gare indicated in Table 8-8J

The fuels considered are /ard $oal. :ther i+uidFuels and 'atural as" 'o reference is made toother fuels li!e heavy fuel oil. petroleum co!e orbiomass (wood and wood wastes)"


<ric!s and Tiles# all the te&t it0s unclear because ,don0t understand if ta!e into account the differentcondition of combustion in !iln and as it0s possible

to subdivide emissions from fuel and frommaterials in such a case (see 'A*,,'AU $:'T)" ,f it0s possible it0snecessary to develop specific emission factors notto copy 4old4 F that derive from another approach(combustion V process)" * from process where isinsertedG






There is no emission factor for ':$ in Table 8-32







'oted


Accepted

Accepted 9one

eferences include only 2 sources" 'oted evised

'oted evised



The fuels considered are :ther i+uid Fuels and'atural as" 'o reference is made to other fuelsli!e /eavy Fuel :il"


Chich %'A* codes are referred to in Tables 8-32and 8-38G



,n 4lossary4 section the * are included into4aseous fuels4. while in $hapter 1A1. Table 8-2.the * are considered as 4:ther li+uid fuels4

$hanged changed to li+uidfuels

This glossary should either be e&panded orremoved" %ome listings in the glossary do notappear previously in the te&t"

A lot of references in the te&t do not appear in thelist of references. e"g" $*,* 23. $,T*A2@. uideboo! 26. $,T*A 'A 2@. %

*A 1JJ?. % *A 2. % *A 28 etc"



Accepted

'oted

'oted

evaporate in the drying process" The 4new4uideboo! don0t ta!e into account these last andreport Fs for combustion that can be differentfrom F in 1"A"1" Then we have a lot of similarcases for e&ample $ombustion in Food ,ndustry.echanic ,ndustry. ecc" Chat emissions factorsGCe need a specific subsection"'e&t we have old %'A* 82 and 88 group andrelated new chapters" , thin! in these chaptersmust be inserted only emissions come fromprocesses in which special condition or the contactbetween fuel and materials produces differentcombustion characteristics and different Fs#essentially process furnaces" For theseapplications. all the e&isting documentation (andfor e&ample <F of the ,**$ directive) reportsFs in g pollutants>!g product" Also statistical dataare available for production and not for energyconsumption of single product (for e&ample areavailable sinter production and fuel consumption iniron steel industry but not fuel consumption in

sinter plant)" ,f the fuel approach is mandatorythen# 1" ,t0s necessary to develop specific emissionfactors. only from fuel. not to copy 4old4 F thatderive from another approach (e&ample % *Aapproach. that ta!e into account the overallprocess 2" %pecific fuel consumptions in D>g ofproduct %T < *:T9" ,'F:AT,:'B,%T% A'9 $A' < T,9 ,' ,**$<F 9:$'T"


The table contains some odd values. , assumethis is due to the haste with which this documentappears to have been drafted"


$:'$%,:'# The chapter is unacceptable5 Allthe documentation from <F ignored also datasent to consultant from * leader5 All therecommendation in * and from industry about noseparation between combustion and processesignored" All the recommendation of use of productapproach ignored"


,n addition to this. industrial waste fuels cover awide variety of materials. as specified in page 6.lines 8I and 86. with different characteristics andcomposition. so it is not clear if the emissionfactors proposed should be applied to all industrial

waste fuels"

Caste factors now

removedoreover. there are no emission factors proposedfor heavy metals. dio&ins and furans and *A/. andemissions for these pollutants are relevant whenusing industrial waste fuels"


Caste factors nowremoved



'oted

'oted

'oted

'oted

'oted

Additionally. emission factors for %:&. ':&.

':$ and $: are the same as for hard coal" Are these emission factors correctG




,n addition. the reference for emission factors isuideboo! (26). but the corresponding chapterfor %'A* 8818 only provides emission factorsfor particles" This comment is also valid foremission factors related to gas naturalconsumption in Table 8-8@"


/owever. emission factors for particles in Tables 8-86 and 8-8@ seems to concern only fuelconsumption"


Ta!ing into account that this is a process with

contact. these particles emission factors areprobably underestimated"



Chat is the difference between both tablesGChere is the ':$ emission factor for naturalgas combustion indicatedG


There are only two !ind of fuels considered# :theri+uid Fuels and 'atural as" 'o reference ismade to other fuels li!e heavy fuel oil"




'oted

'oted

'oted Te&t amended to clarify

'otedeaning of T:-cycles 1G 'oted 'eeds correcting

'oted

'oted

'oted has been emphasised

'oted has been emphasised

Accepted Cill e&pand e&planation

Accepted Cill e&pand e&planation

Accepted

,n addition. emission factors for :ther i+uid Fuels

should be splitted for each fuel considered in thiscategory (gas oil. *. """)



Chich emissions (combustion and>or process) areconsidered in the emission factors proposedG ,nchapter 2"A"@"d. emission factors for heavy metalsand particulates are propposed (in terms of massof pollutant per unit of production).


and it is not clear if there is a ris! of doublecounting when applying both emission factors"

Chat are the ma7or changes since earlierversionsG

Cill outline the mainchanges

9efault methodology has been developped by,$A: concerning A* cf" 4Airport Air =ualityuidance anual4 ,$A:. April 2@" That could beadded within the <. as far as the fuel used is theaircraft !eroHene"

/as been considered andwords added under4Au&illary poweroperations4 on p3 of %:9

Cithin the 2@ *>$:,'A, uideboo!.general information on A* and fuel dumping areprovided that may be interesting to !eep"

/as been incorporatedwhere appropriate

,t must be emphasiHed. that military aviation is

classified as 'F code 1AI (other) according toagreed * nomenclature"

*lease distinguish between sources of emissionsbelong under this 'F and other (e"g paintingbelongs to another 'F and should not beignored)

This should be e&plained in much more details.and a table should be provided giving a thoroughoverview of today0s situation

%ome elaboration on the grouping of 'Fcategories for each reporting re+uirement would beuseful here"

There is a lot of emission data for turboprops also"9ata for the most commonly engine fitted tospecific aircraft

updated aviation emissionfactors have beendiscussed with C(&pert *anel member)and incorporated asappropriate



Accepted

Accepted has been emphasised

AcceptedChat 9irective do you refer toG Accepted Cill e&pand e&planation

Accepted

has been modified

Accepted will reword

'oted will reword

'oted will reword

'oted

Table 2"1. this table needs update as it is ten yearsold. and new aircraft must be included

updated aviation emissionfactors have beendiscussed with C(&pert *anel member)and incorporated asappropriate

ilitary is reporting under a different 'F. while it0smethodology is described here

This paragraph was not included in the outlineagreed in 9essau" Furthermore if it is to beincluded it must be updated with new numbersfrom more recent references" %ame with table 2"8and 2"3" (the same comment applies to otherchapters including a similar paragraph)


D oodwin consulted withe&pert panel member(C)

Table 2"2# There is more recent legislation for ':&"*lease refer to the

updated the aviationemission regulations havebeen included"

Table 2"2" ,sn0t there more up to date informationavailableG

updated the aviationemission regulations havebeen included"

These tables 2-8 and 2-3. sould be completed withtables relating to internationals emissions" 'ote #international T: emissions are part of national'$9 emissions. and important issues ofemission trends for aviation concern internationalaviation" For international aviation emissions. e"g"international>domestic ratios could be displayed"


D oodwin consulted withe&pert panel member(C)

The 9ecision tree needs improving" %urely the first

2 diamond shaped white bo&es are needed to usea tier 8 method"


The decision tree is more less impossible tounderstand" *lease use the old decision tree as abasis for the Tier e&planations"


Table 8-1 is a complete mess. and is basicallywrong5


Footnoe I. must be changed. it is copied from,*$$ (26) and does not ma!e sense in thisconte&t

*lease state where military aviation emissions

should be reported"Chat do you mean by 4not reported here4" ilitaryaviation is a part of 'F 1AIb along with othermilitary mobile activities"

This te&t is incomprehensible" Further. it is not inline with the emission reporting uidelines (fore&ample multilateral operations are ':T e&cludedfrom emission totals under TA*)

Te&t ta!en verbatim from,*$$ 26. need toconsult with e&pert panel



'oted has been modifiedThis is not possible to understand5 'oted has been modified

'oted has been modified



'oted


'oted

This methodological description is not improvingthe old 4simple method4 described in section 3-2 of<?I1-18" ,t is assuming that inventory compiliers!now how to estimate emissions wothoutdescribing the process"

%ome duplication of information with section 8"2"8 Activity data"

$an the default emission factors (table8-8 fordomestic T:) also be used non-,F fligthsdomestic T:G ,t is not specified whether thedefaults are for ,F>F" Ce have an amount ofT: for F flights (small aircrafts li!e *A2?.$1I2.L) and not the amount of flight hours for F. andwonder if we can use table 8-8. 8-? and 8-J for it"


,n table 8-8 (Tier 1 9efault Fuel use in T:).second 'F source (domestic T:) has as fuel #

7et !erosine" ,s the value also valid for 7et gasoline aviation gasoline fuel useG :r must there a valuebe added for further use with tables 8-? and 8-JG

,s there no reference to these fuel consumptionFs in Table 8-8" Also what is meant by !g>tonnefuel in 'F 1"a"8"a"i(ii)" %hould it not be !g>T:G

,nformation on />*:*s are missing" *lease citethe origin (source) of emission factors from the*-$. emission factors must be tracable(comment applies to many chapters)" Furthermore

Tier 1 emission factors must be updated. a lot hasbeen changed since these Tier 1 emission factorswere derived

Fs have been includedwhere available

,0m not sure that a reference to an F should be4$alc from Tier 24 in Tables 8-? and 8-J" This couldbe described better"

Aviation gasoline is added substantial amounts oflead. please provide information

Fs have been includedwhere available

9ata available and necessary to apply Tier 2method sould be specified" 0The algorithmsparagraph 8"8"1 is not detailed enough" %omecomponents of such step by step algorithms is

given but in F paragraph 8"8"2" A global overviewof the algoritms is missing"


has been modified in

consultation with e&pertpanel member C

The Tier 2 method should promote using fuel soldstatistics # separately domestic and internationalfuel sold when available" ,f these separate fuel soldstatistics are not available. then estimation methodcould be used to split domestic and internationalfuel consumption. as presented in step 1"


has been modified inconsultation with e&pertpanel member C



'oted

Chere does the data in this table originate fromG 'oted has been modified

*lease provide some method description for Tier 2" 'oted

'oted

'oted

ditorial

,t is strange to recommand to use Tier 8 F withina Tier 2 method" Furthermore. in case of using Tier2 method. data on cruise distances per aircraffttype are generally not available for using Tier 8 F(distance dependant)"



The lin! of theses lines with paragraph 8"8"8 Activity data is not clear"



$an emissions factors for airplane types that aredisappeared referred to older versions of theguideboo! still be used from older versions (fore&ample $oncorde in 1JJ6 guidelines)G


Fs used have beendiscussed with e&pertpanel member. C

The Tier 2 method is completely wrong5 Thismethod cannot use mission distance based factorsfor cruise - this relates to Tier 85




,n the last part of the bo&. reference to the F9< ismade. however there is no F9< for air pollutants5


Footnote ?. this assumption should be revieweddue to more recent !nowledge


Table 8-11# ,t is not acceptable to use the emissionfactors for T: provided by the ,*$$ 26guidelines



table 8-11# Footnote (8) does not appear belowKthere (2) apperas twice" - *lease change the 2nd(2) into (8)"




Accepted

'oted

'oted will clarifyTable 8"13" %ourceG 'oted will reference

'oted

'oted

'oted will continue to be

'otedThe sentence is diffucult to understand" 'oted will clarify

Chere is the table 8"1 G 'oted

'oted,t is both turbo fan and turbo prop engines" 'oted should be altered

'oted

Accepted

*lease chec! if this table has been updated withmore recent aircraft and ma!e corrections asappropriate


This paragraph should be more detailed. especiallythe lin! with the steps displayed in 8"8"2"


Chy is military described here in section 8"8"IG ,nwith the Tier 2 methodG There is no mention ofmilitary under the Tier 8 method"

Chat is the minimum flown distance for anairplane to reach cruise levelG Table 8-1I starts at12I nm" ,t means dat below 12I nm. an airplane isnot cruising yet (in normal average conditions)G

These data are ta!enverbatim from earlierversions of the guideboo!- refer to e&pert panel

,n general the method choice and descriptionshould preceed the F tables" %ection 8"3"2 onTier 8 Fs is on page 2I whilst section 8"3"8"1 on

Tier 8A method is on page 2J" This ma!es thechapter very difficult to read"

/ave re-organised Ftables

*lease e&plain where the remainer Tier 8 emissionfactors can be found (currently they are availableas a spreadhseet download)

There are no cruise emission factors published onthe ,$A: website"

These data are ta!enverbatim from earlierversions of the guideboo!- refer to e&pert panel

/ave as!ed author ofprevious guideboo!

This is not possible to follow. what has it to do withengine independent emission factorsG And whereis Appendi& 1G

should be aircraft type - Appendi& 1 is unaltered

For non-,F flights. we still use emission factorsfrom *A. A*-32 volume ,, (1J?I)" $an they still beusedG Chy are they not included as referencedefault emission factors (instead of calculatingnothing) G



These method descriptions in sections 8"3"8"1 to8"3"8"8 should be on page 23 before the F tables"


The note provides considerations on energybalance for domestic aviation" %imilarconsiderations on energy balance for internationalaviation sould be also included (ta!ing into accountthat in case of international aviation. half ofinternational fuel consumption should becompared to fuel sold in the country forinternational flights)"




These are very old data. please update Accepted

Accepted

Accepted

Accepted Cill include 9escription

'oted

'oted

'oted will clarify

Accepted

Accepted

Accepted

,$A: website"

in the Tables 8-3 and 8-I is preferable"


This section 3"3 has nothing to do with consistenttime series and recalculation5 ,t is simply copy andpaste from the old chapter section 8"6

4*ro7ections4# ven the title has been changed tofit the misplaced content"



This information (including the tables) appearsoutdatet" Chat is for e&ample 4current level4 inTable 3-1G *lease update or rewrite

has been discussed withe&pert panel member C

,t is indeed suprising that there is no specific issuehere given the comple&ity of reporting this category(e"g" differences betwee 'F$$$. TA* and'$ reporting). memo items etc" (same remar! tonavigation>shipping chapter)

Chat other sourcesG ,t is essential to e&plainwhere the data comes from

'ot changed - ta!enverbatim from previous

version of the guidboo!"efer to e&pert panel

Chat is the difference between Anne& < and Table8-11G Are both neededG

has been discussed withe&pert panel member C

A large number of references in this chapter arenot found in the reference list" (including ,*$$(26) which the method is based on5)

*lease also include Tier 2 cruise emission factors(else the method will not wor!)


*lease refer also to general commentssummarised in the separate word file 49; eviewof guideboo! chapters for mobile sources"doc4


ven more important. a lot of references ande&planations how data are obtained. are missing"


All military mobile activities (aviation. land basedand sailing activities) are classified as 1AIb(e+uivalent to %'A* code ?1) according to*"



data are available from the current guideboo!. both

for T: and cruise distance classes

$onsult with

&pert *anel

has been modified inconsultation with e&pert

panel member C







Accepted $orrected

'oted

'oted $orrected<adly written" 'oted $orrected

*oorly phrased" 'oted<adly written. and difficult to follow" 'oted $hanged

Chat is section 3G The sentence gives no meaning 'oted %orted

*lease use the simple method description directlyfrom the old guideboo!"



These T: factors are not supported by newcruise emf related to distances. as in the currentguideboo! version"



oreover. loo!ing into the ,*$$ guidelines theT: factors are very poorly documented"



,f we use the ,*$$ data. we loose the consistencywith cruise factors per distance class. and forspecies li!e ':&. ':$ and $:



cruise factors heavily depend on the actualaircraft>engine combination" ,n some countries.detailed city-pair inventories



are made each year using distances betweenairports. and for these countries such new data

gives less meaning"

$onsult with

&pert *anel


panel member C%o. the strong recommendation is to maintain the4old4 T: (and cruise) emf in order not to introduceerrors into the inventories"



The data come from specific simulations made byaircraft emission e&perts"



and the approach used to obtain the data that ispresented in the guideboo!"



The schematic diagram (Figure 3"1) in the chapter<?I1 in the uideboo! should be retained in the

new chapter"

$onsult with

&pert *anel


panel member CTitle of chapter should include a reference tobuses. ie /9s and buses instead of 4heavy-dutytruc!s4"

Chat is the difference between 0:verview0 and0eneral description0G

eneral 9escription is partof the :verview"

These paragraphs are rather badly written. andcould be improved"

e7ected because thisphrase was ta!en verbatim

from e&isting guideboo!.see <@1-1 in pdf version



$: is not an :Hone *recursor e7ected

Accepted $orrected

'oted $orrected

'oted $orrected

'otedChere is this referenceG 'oted $orrected%hould read 0three-tier0" 'oted $orrected

The section 2"1 title is not helpful" 'otedChat is meant by 0positively ignite0G 'oted $orrected

'oted $orrected

Figure 2-1 is poor" Chat purpose does it serveG e7ectedFigure 2-1 gives no information" 'oted $orrectedThis reference is wrong" ditorial %orted

Accepted %ortedChere is Table 2-1G ditorial %ortedChere is the Tables 3-@ to 3-2JG ditorial %orted

The A include $: intheir definition of :Hone*recursorhttp#>>glossary"eea"europa"eu>Alossary>:>oHoneP precursor

9elete 0mobile0" $hange 0transportation0 to0transport0 (throughout)"$hange 0vehicles0 to0vehicle0"

Chy 0on-road0G The whole chapter refers to roadvehicles"

missions from e&haust aftertreatmentG This isnonsense"

$hange to 0The most important pollutants fromroad vehicles are coveredL0"


e7ected because thisphrase was ta!en verbatimfrom e&isting guideboo!.see <@1-1 in pdf version

Chat is the relationship to $:*TG ,f it has beenupdated five times why are we now at $:*T 3G

The e&isting guideboo!says it is the Ith update.see <@1-2 in pdf version"These lines merely reflectthese words - no changemade"

Cill clarify align withtransport terminology

Chich processG :ne of the combustion

processesG Figure 2-1 does not show combustionprocesses"

used to conceptualise theboundaries of roadtransport emissions. and isan approach adoptedthroughout the uideboo!"

,t is written that for Tier 1 uses fuel as activityindicator with average fuel specific emission

factors" <ut then in the table 8-2-8"Jf are g>D



ditorial $orrected

ditorial $orrected

Accepted %orted

Accepted %ortedunits for $d and *b in table 8-2 are missing" Accepted $orrected

Figure 8-1 should read 49ecision tree for roadtransport4 not 4aviation4" , also wonder about thediamond 4,s this a !ey sourceG4" oad transport isalways a !ey-source" There should be added the

following statement in p"6 where the figure isintroduced# 4oad transport is a !ey-source in allcountries" Therefore. the Tier 1 method should onlybe used in the absence of any more detailedinformation than fuel statistics" ,n parallel. in such acase. the country needs to ma!e every effort tocollect the detailed statistics re+uired to use ahigher Tier method. preferrably Tier 8"4

+" 1 needs to change to read i.7.! where ! willrefer to fuel (gas. diesel. *. ')" Therefore. F$7should change to F$7.! and fi.7 should change tofi.7.!"

the formula (1) multiply F Qg>!gfuelR for F$ (fuelconsumption Q!g fuel but in the table the emissionfactor for Tier 1 approach are e&pressed in termsof g>D" There should be one common standardand , suggest that !g of fuel ma!es more sense

The emission factors are wrong. due to errors inthe calculations"

Tables 8"2 to 8"J present emission factors in g>D"First. the methodology in p"@ is in g>!g" %econd.the values are wrong (they should be _I timeshigher)" , understand the editors try to beconsistent with ,*$$" :n the other hand. urostatdata report all values in tonnes that can be readilyconverted to !g. without !nowing the energycontent of fuel" ,n addition. methodologies Tier 2and Tier 8 calculate total fuel consumption in !g sowhy having Tier 1 in DG Third. emission values ing>!g fuel are widespread and are published inscientific literature so the reader can comparethem to the uideboo! values" All models ($opert.

Artemis. even eritV in the 'etherlands) use fuelmass values" /eavy metals and sulfur are allreported per mass of fuel" The user of any

methodology needs now to convert them to D5 ,!now of no source that reports emission in g>De&cept for /s" <ut even in the 26 ,*$$uidelines. '2: and $/3 emission factors for %and urope are in mg>!m" ,n summary. , find thee&pression g>D aw!ward and not practical and ,strongly reccomend this to be changed bac! tog>!g fuel"


%orted - after discussionswith &pert *anel we havereverted bac! toe&pressing emissionfactors in units of g>tonnefuel



Accepted

units for $d and *b in table 8-I are missing" Accepted %ortedunit for $d in table 8-6 are missing" Accepted %ortedunit for $d in table 8-@ are missing" Accepted %ortedunits for $d and *b in table 8-J are missing" Accepted %ortedtable 8-J# unit for $d and *b missing Accepted %orted

ditorial $orrectedChere is Table 3-6G ditorial %orted

Accepted %orted

Accepted $orrected

'oted

Acceptedwhere is section 3"8"8G ditorial %orted

Tables 8"2 to 8"J also include emissions of %:&and heavy metals and ma!e reference to Tables 3-BBB" First. as the draft chapter stands now. thesetables are A"BBB and not 3"BBB. but please also

chec! my comment below related to the structureof the chapter" %econd. why should we provide adefault %:& emission factor (e+uivalent to 3 ppm% in fuel) when % content of fuel is !nown in eachcountryG 'one of the countries (e&cept <ulgaria)that are going to use a Tier 1 methodology haveaverage sulfur of 3 ppm5555 , reccomend weintroduce the very simple methodology (two rows)given in section A"6"J as part of Tier 1 as well" Thisis all it ta!es to have the correct estimation of %:&"

eferencing to tables willbe corrected" Alsocomment will beaddressed to include afle&ible % content variablewith a default if none is!nown"

Tables 8-2 to 8-J include 9efault Fs Tier1" Theunit used is g>D. instead og g>!g of fuel used" ,tmay be worth including both Fs by U and !g inthe final guideboo! and a description of thecalculation from one to the other"" Also , thin! thereference AT 2? needs to be clarified (e&actlya reference to which reportG)


%orted - after discussionswith &pert *anel we havereverted bac! toe&pressing emissionfactors in units of g>tonnefuel

All these Tables 8-11 to 8-8? contain Fs for Tier 2"Chat is the reference for these FsG

Tier 2 method gives Fs by technology. howeverthese technologies are not provided until the

Appendi& to this F:9"

Tables 8-11 to 8"8? contain the statement 4gramsof international to&ic e+uivalent4 for 9,:B and novalues" There are such values in Table A"11"

For heavy duty truc!s. so many siHe classe andtechnology combinations are missing in terms ofTier 2 emission factors"


$hanged - commentadded regarding what touse for 4missing4 siHe>technology combinations"

Table 8-8J is a good summary" , do not understandwhy this is only specific to F$ and what are theuses it intents to cover"

$orrected ,t0s use hasbeen clarified in the te&t"

4<y applying a trial-and-error-approach"""4 Thissentence is meaningless5

e7ected because thisphrase was ta!en verbatimfrom e&isting guideboo!.see <@1-8@ in pdf version



There is no discussion in section 3"8"85 ditorial %orted

Accepted %orted

Accepted %orted

Accepted

Accepted Cill be refered to""

eferences are not oldG Accepted

Accepted

Acceptedeference to Table 3-1 is wrong" ditorial %ortedThere is no Table 2-1 in the chapter ditorial %orted

$: is not an :Hone *recursor e7ected

,t is a very wrong decision to let Tier 8 bedescribed in an Anne&" Tier 8 is what manycountries use now"

,t is very important that this Tier 8 method has aproper description and overview in the actualchapter as does the Tier 1 2 methods" Thismethod is the most used method by inventorycompiliers and should not be discussed in an

Appendi&"

The te&t in %ection 3"3 has nothing to do withconsistent time series and recalculation5 ,t is 7ustcopy and paste of %ection 18 4Temporaldisaggregation criteria4 from the old chapter"

/eading changed to reflectte&t provided - now nosection on 4developing aconsistent time series4 -'eed to decide on thee&tent of te&t neded onthis

The problem of 4tan! tourism4 it is not mentioned"

,f it is relevant. fuel balance. as e&plained here.could not be applied"

e7ected because thisphrase was ta!en verbatimfrom e&isting guideboo!.see <@1-31 in pdf version

This !ind of table could be very useful" Chy don0tput information on the other pollutantsG

Chere available data willbe included" These datawere ta!en verbatim fromTable 1-8 of previousguideboo!" Analogous

data for other pollutantswas not provided"

Cill be the emission factors for buses $'included into the $:*T ,G

$:*T 3 is a softwaretool outside the scope ofthis uideboo! revision"This +uestion will beforwarded to the team at

Artistotle niversity"

The A include $: intheir definition of :Hone*recursorhttp#>>glossary"eea"europa"eu>Alossary>:>oHoneP precursor



Accepted %orted

Accepted %orted

Accepted

Accepted

Accepted %ee above

ditorial %orted

ditorial

ditorial

%ection A"2 is not part of the Tier 8 methodologyand it is o! to remain as an Anne&" /owever. inother chapters (e"g" non-e&haust * emissions.evaporation) the sections referring to thecontribution of the sector to total emissions areprovided as introductory sections beforepresenting the Tier 1 methodology" %o. please beconsistent between chapters. where you want thissection to be presented (anne& or introduction)"

%ection A"8 should be part of Tier 1 methodologybecause it 7ust provides definitions of the vehicleclasses considered" %ection A"3 should be part ofTier 2 methodology because Tier 2 already usesthe emission standards classification"

etodology does not estimate in which categoryshould be included tracotrs with registrationnumber (vehicles)" These can not drive onmotorway"

e7ected for this versionbecause this phrase wasta!en verbatim frome&isting guideboo! -comment will be passed to

AT"

Table A"@ now offers no new information andneeds to be erased"

e7ected because theguidance we havereceived is that thee&isting detailedmethodology te&t shouldnot be changed much atall"

,ndeed the current section A"6 should follow as the

ne&t section. after A"1

$hec! format of Figure A"2" The te&t on the left-most bo&es should be vertical and not horiHontal"

The sentence is not coherent with the table A"I8"The sentence must be 4/owever. some additionalreductions need to be applied for vehicletechnologies post-uro 3 (Fi7). which are given inTable A" I84


AT"

,n the e+uation (2@) replace e/:TKi.uro1 bye/:TKi.uro3 to be coherent with table A"I8 andfi7 factors


AT"



ditorial

'oted

'oted

'oted

'oted %orted

The 4ehotKi.uro 14 value in e+" 2@ should bereplaced with 4ehotKi.uro 34" the 4ecold>ehot`i.uro14 value should remain intact"


AT"

,t is not possible to distinguish between mopeds 2and 3 stro!esG



AT"

table A"@@. A"@?. A"@J. A"? e A"?1 it is not possibleto define the emission factors in term of emissionlegislationG



AT"


$omments have beenconsidered"

p to uro ,# The vehicle categories @.I-12 13-2 26-82 tons are missing"

%ee also comment 2?3 -$hanged - commentadded regarding what touse for 4missing4 siHe>technology combinations"

For newer technologies# The vehicle [email protected] 26-82 tons are missing"

%ee also comment 2?3 -$hanged - commentadded regarding what touse for 4missing4 siHe>technology combinations"

,n general the Anne&. who is supposed to treat Tier8. also repeats the data used for the old simplemethod"

The old chapter discusses how to treat emissioninventories in relation to dispersion models"


/eading changed to reflectte&t provided - now nosection on 4developing aconsistent time series4 -'eed to decide on the

e&tent of te&t neded onthis



Accepted %orted

Accepted %orted

Accepted %orted

Accepted

Accepted %orted

T/ T, 8 T/:9::U %T ':T <,'T:9$9 A% A' A''B <T A% %$T,:'8"3. A% :,,'AU F:%'" ':C T/C/: $/A*T ,% A %%5 A %$T,:'%

,' $/A*T 3 9,%$%% ,%%% :F T, 8T/:9::U (T/U A A $:*U :F T/*,:% %,:' :F T/ ,9<::;)

A'9 T, 8 ,% :'U ,'T:9$9 ,' T/ A''B" :%T F'$% F T: T/T, 8 T/:9 A'9 T/ T, 8 ,%,'T:9$9 AFT T/ F'$% A% A'

A''B5 ,T ,% *:,'T%% T: A; A 9TA,9,C A% T/ $/A*T ,% %: <A9UC,TT' A'9 %T$T9 T/AT ,% A;%': %'%"

The chapter ma!es a lot of references to sectionsand tables 3"&" These do not e&ist because Tier 8has been anne&ed" These need not be changedwhen the editors correct the chapter per myreccomendation above" /owever. there are manyerronous references to tables and figures as thedraft version stands now"

,n all Tier tables for the road transport notapplicable would be *:*sAnne& ,


The general description and overview couldperhaps include tables 1"1 and 1"2 from theuideboo! <@1-8"

There is no reference to classification of vehiclessuch as in the uideboo! table 8"1 <@1-@ andTable 8"6 <@1-16" All of this information isrelevant regardless of which Tier approach is usedby inventory compiliers and should be included inthe chapter overview or description"

Accepted - cross referenceincluded

eneral comment" This chapter needs ma7orrestructuring" All vehicle classifications. legislation(as described in <@1-18 to <@1-16) should beincluded in the te&t of the chapter before

discussion of the different Tier method (1.2 and 8)",mprovements are also needed in referencing Ftables and if changes are made to F units theseshould be e&plained clearly" Also there is no bul!$% Fs based on the 22 wor! which could beuseful for a Tier 1 method" There is no discussionof the contribution road transport ma!es to totalnational emissions"



ditorial %orted

This paragraph could read a little better" noted evised

Accepted

Accepted

&plain what carbon canisters are" Accepted

Accepted evised

Accepted

%ubsections 6"1 and 6"2 should occur in the sameorder as the title of %ection 6" ,n addition. the level8 sections in the report are missing from the tableof contents"

This paragraph is poorly constructed and not wellphrased" /ow do breathing losses relate to diurnalemissions. hot soa! losses and running lossesG9o we need to use both 0losses0 and 0emissions0GDust use 0emissions0"

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)%ection 8"1" Cill passcomment on to &pert*anel

The last sentence of the para ought to be the first" Again" /ow do 0breathing losses0 relate to thesources mentioned" y understanding is that this

is a part of the process which leads to diurnalemissions"

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)%ection 8"1" Cill pass

comment on to &pert*anel

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@) page1" Cill pass comment onto &pert *anel

*rocess description0 is not a good title in my view",t is too vague" , also thin! that it more or less

repeats title 2. and would therefore delete it"

$onsult with

&pert *anel

$ould be made moretransport specific"/owever. might detractfrom a common guideboo!

style"Figure 2-1 is poor" ,t could show the differentevaporative sources much more clearly (i"e" pictureof vehicle. with diurnal losses. hot soa! losses andrunning losses e&plained)"

aybe worth adding that some studies haveidentified 0resting emissions0 as a separateevaporative source" These result from diffusion.permeation. seepage and minor li+uid lea!s. anddo not need an increase in fuel temperature tooccur" /ere. , assume that these are already

included in the hot-soa! and diurnal calculationsG

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)%ection 8"1"8" Cill passcomment on to &pert

*anel



Accepted

ditorial

Accepted

ditorial

ditorial

ditorial

*oorly written" %hould begin 09iurnal losses areL0"$an , offer something li!e this OO The increase inambient temperature which occurs during thedaylight hours results in the thermal e&pansion of

the fuel and vapour in the petrol tan!" Cithout anevaporation control system. some of the increasedvolume of fuel vapour is vented to the atmosphere"

At night. when the temperature drops. the vapourcontracts and fresh air is drawn into the petrol tan!through the vent" This lowers the concentration ofhydrocarbons in the vapour space above the li+uidpetrol. which subse+uently leads to additionalevaporation" The overall mechanism is also !nownas tan! breathingM"

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)%ection 8"1"1" Cill passcomment on to &pert*anel

Again. the wording could be better" Aren0t runninglosses are defined as something li!e 0theevaporative emissions which occur whilst a vehicleis being driven0G There is always vapour in the fueltan!" Are we tal!ing about additional vapourG%urely there is an increase in the fuel temperaturefor all vehicle types (e"g" heat from engine ande&haust)G


9oes this para refer to vehicle refuelling. fueldelivery. or both" ,t shoul dbe clearer" /ere. it says0petrol stations0" ,0m not sure whether 0gasolinestations0 even e&ists in % nglish"


,n the line 3 we can read# 4Cithout an emissioncontrol system. some of the increasing volume offuel vapor is vented to atmosphere4

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@) te&t insection 2"2"1" Cill passcomment on to &pert*anel

$hange to 0Lat the same level" /owever. the test

procedure for evaporative emissions increased inseverity0"

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@) te&t insection 8"8" Cill pass


,n general. would prefer the ; nglish 0petrol0 tothe % nglish 0gasoline0" *lease use the term 0fueltan!0 instead of 0gasoline tan!0"

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)" Cillpass comment on to&pert *anel



ditorial

Accepted

$/2"1 is not a unit" Tan! breathing again" ditorial

&plain 0%/90" Accepted

Accepted

$hange to 0/ot-soa! emissions occur when L0"0/ot-soa!0 should be hyphenated when used

immediately before 0emissions0"

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)%ection 8"1"8" Cill passcomment on to &pert

*anel

Chat is the meaning of the %ection 2"8 title" ,t isvery vague"


'ot changed because thiswas the heading used inthe uideboo! version<@6(2@) /eading 8"2"Cill pass comment on to&pert *anel

The first sentence is unclear" Chat does it meanGThe distinction between :$s and ':$s alsoneeds to be better e&plained"

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@) te&t in

section 8"2" Cill passcomment on to &pert*anel

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@) te&t insection 8"2" Cill passcomment on to &pert*anel

Again. the %ection heading (2"3) needs to be moreinformative"


'ot changed because thiswas the heading used inthe uideboo! version<@6(2@) /eading 8"8"Cill pass comment on to&pert *anel

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@) te&t insection 8"8" Cill passcomment on to &pert*anel

Table 2-1# ,n %pain. the percentage contribution ofthe evaporative emissions to the total emissionsfrom road transport in year 26 was not J. itwas 82"@

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@) Table2-1" Cill pass commenton to &pert *anel



&plain what T: is" Accepted

Accepted

Accepted %orted

Accepted %orted

Accepted $orrected

Accepted %orted

Accepted %orted

Accepted %orted

The activity rate for lime production Accepted %orted

'oted %orted

Accepted

Accepted %orted

Accepted %orted

Accepted $orrected

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@) te&tiimmediately above Table2-1" Cill pass comment

on to &pert *anel

%ome e&planation of this Table would be useful"For e&ample. why are evaporative emissionsproportionally higher in colder countries than inhotter countriesG

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@) page1" Cill pass comment onto &pert *anel

This is very poor" ,t does not even relate to roadtransport" The terms below the e+uation do notmatch those in the e+uation. and no units aregiven"

Chat a mess5# This is not the Tier 1 approach for

evaporation" Uou use words li!e 4small combustioninstallations4 and 4lime production4"

,n the decision tree from figure 8"1 the te&t in thefirst and second rhomboidal bo&es is the same

Chat is the sense in this chapter of 4The Tier 1approach for process emissions from smallcombustion installations """5

Ce can read# Aproduction N the activity rate forthe lime production5

Ce thin! it should say 4fuel consumption4 not 4fuelsales4K 4fuel sales4 could be a good pro&y for 4fuel

consumption4 but ,t is not the same

Tiers classification" $omments are summariHed inseparate Cord document

9ecision tree" This is rather poor" The first two0decisions0 contain the same +uestion" ,n the third0decision0. how is a 0!ey source0 definedG ,f evap" ,sidentified as a !ey source then data collection isrecommended" /owever. the user is then directedto Tier 2" Chy not Tier 8. as the re+uirements forTier 8 appear to be fulfilledG" The Figure title

appears twice"

9ecision tree revisedmar!edly to reflect thedifferent tiers. and activity

data. re+uired for eachThe decision tree is wrong# ,f the answer is 4'o4right after start. then you are lead to the same+uestion one more time"

%ection 8"2"1 is copied from lime production anddoes not refer to evaporation

Figure 8-1 has two identical diamonds for Tier 8and Tier 2



'oted %orted

'oted %orted

'oted %orted

%orted

%orted

Accepted Amended

Accepted

,t is +uestionable if the data in Tables 8-1 to 8-Iare sound" ,t is recommended to let the originaldata suppliers ma!e such aggregated figures"

, would imagine that data on fuel sales and data onvehicle licensing statistics are !ept by differentorganisations"

Chay 0default0" $an these be changed by theuserG

The Tier 1 method proposes evaporation factors inthe form g>!g fuel consumed" This was neveragreed in the Transport *anel so it has to bediscussed" The Tier 1 method proposed by thetransport panel only re+uired the total number ofcars and truc!s operating on gasoline. atemperature range relevant for the countryconcerned and the 9* value of the fuel" All thisis information that e&ists in each country" The

problem now with Tier 1 is that there is notemperature effect and. therefore. evaporationemissions in !raine will be e+ual to emissions in

Algeria5 Chatever the method we agree. atemperature correction needs to be introduced forthe emission factor" Ambient temperature is notdifficult to find in any country5


The Tier 2 method proposes evaporation factors inthe form g>!g fuel consumed" This was neverdiscussed in the Transport *anel" The editorsshould have at least consulted with the transport

panel if they wanted to change something fromwhat was agreed" ,n fact the Tier 2 methodproposed is totally anachronistic and is clearly ascientific degradation of the uideboo!" Thesimple methodology that was proposed in theprevious uideboo! is still the original methoddeveloped by the $:,'A, 1J?I wor!ing groupand most member states wor! with it" , stronglyreccomend that the simple method of the previousguideboo! is used as a Tier 2"


Tables 8-2 to 8-I" &plain 09*0" The names ofchemicals do not ta!e capital letters" %hould be0polycyclic aromatic hydrocarbons0" %ome of cell

contents are cut off

The use of the words 0hot0. 0warm0 and Kcold0 in theterms of the e+uations is confusing" These need tobe e&plained"

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)%impler methodology" Cillpass comment on to&pert *anel



Accepted %orted

Accepted

e7ected

Accepted

Accepted %orted

Accepted

, would imagine that data on fuel sales and data onvehicle licensing statistics are !ept by differentorganisations"

, assume that what we want to calculate is the totalnational emission" For this. you need to sum overall vehicle categories ('7)" This needs to beincorporated into the e+uation"

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)+uation 1" Cill passcomment on to &pert*anel

For consistency with /% and . why are diurnalemissions not referred to as 090G

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)+uation 1" Cill passcomment on to &pert*anel

,t is not entirely clear what a vehicle catgory (070)actually is" ,s it a uro standardG y first thoughtwas that it related to the descriptions in Tables 8-6and 8-@. but the problem would then be not havingthe activity data for these categories" aybe this iswhy you include Table 8-11. but , don0t thin! that itis stated e&plicity" The lin!s between Tables 8-6>8-@and 8-11 should be stated e&plicitly"


The Tier 8 method proposed is a collation of thesimple and detailed methodology of the 0old0uideboo! with a mi&-up of the emission factors"

As it stands now. the whole chapter is a mess andit is impossible to review point by point" %imply put.the Tier 8 te&t provided ma!es no sense"

$old and warm soa!>running emissions" Accordingto +uations (2) and (8). these only appear toapply to vehicles with a carburettor" These areli!ely to be pre-uro 1 and uncontrolled (i"e" nocanister)" %o why are there lots of emission factorsfor controlled vehicles in Table 8-6G This shoul dbee&plained"



*etrol cars are separated according to whether

they have fuel in7ection or a carburettor. and hencethe parameter 0c0 (the fraction of vehicles e+ippedwith a carburettor) needs to be defined" , assumethat this is 7ust for pre-uro 1 vehicles (andpossibly uro 1)" <earing in mind the re+uirementto combine Tables 8-6 and 8-11. statistics on thefractions by uro standard should be given tousers"




Accepted eordered and clarified

Accepted

Are these values for a particular countryG 'oted

Accepted

Accepted %orted

,s the vaopur pressure re+uiredG ,t appears that it

isnMt used"

$onsult with

&pert *anel

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)%impler methodology" Cillpass comment on to

&pert *anelThe reference to the Table which contains par!ingduration distributions (and the Table itself) appearstoo early in the $hapter" At this point it is not clearto the reader what this means and why it isre+uired"

Ce don0t understand the matri& presented in thetable 8-1" From this data. if we compute. fore&ample. the probabilty of the event of not to bepar!ed some time between 1am and 2am hourswe obtain "J@2. this means that the J ofvehicles are on road at 2am5 Cithout doubt. this isnot representative of the %panish pattern" %o.either the numbers from the matri& are wrong. orthere is another type of error about the meaning ofthe matri& as it is e&plained in the guideboo! te&t"

$omment noted - the dataand e&planations providedare ta!en verbatim fromTable 6-8 of the previousuideboo! version<@6(2@)" Cill passcomment on to &pert*anel

'ot !now - the data areta!en verbatim from Table6-8 of the previousuideboo! version<@6(2@)" Cill passcomment on to &pert*anel

&plain 0cats0" Again. at this point it is not clear whyfuel tan! volume would be re+uired"

$omment noted - the dataand e&planations providedare ta!en verbatim fromTable 6-8 of the previousuideboo! version<@6(2@)" Cill passcomment on to &pert*anel

At this point , am completely lost" This loo!s li!e

the start of a more comple& 0Tier 30 approach" Ane&planation of this structure is re+uired" Aresections 8"3"I to 8"3"12 ad7ustments to theemissions which have already been calculated tothis pointG Furthermore. much of the te&t in thesesections repeats the earlier te&t"



Accepted

Accepted

/ow is %ection 8"3"6 usedG &plain" Accepted

Accepted

/ow is %ection 8"3"@ usedG &plain" Accepted

Accepted

/ow are the temperatures calculated in %ection8"3"I usedG

earranged. but notchanged because this wasta!en verbatim fromprevious uideboo!version <@6(2@)9etailed methodology"

Cill pass comment on to&pert *anel

Table 8-12" %urely the values in the first columnshould start at 1# and end at 23# (or #)G'eed to e&plain that there are 23 intervals in eachrow because "I hour steps are used over a 12-hour period"

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)9etailed methodology"Cill pass comment on to&pert *anel

earranged. but notchanged because this wasta!en verbatim fromprevious uideboo!version <@6(2@)9etailed methodology"Cill pass comment on to&pert *anel

From personal communication from iorgosellios ($:*T team) it appears that thenumbers in formulae for parameters a and b areincorrect and they should be replaced by thefollowing figures# a N -11 -"1ISvp V"6ISTKbN"11I-"1ISvp V"1STK please chec! it

with iorgos ellios

':T9 - not changed inthis revision because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)9etailed methodology"Cill pass comment on to

&pert *anel

earranged. but notchanged because this wasta!en verbatim fromprevious uideboo!version <@6(2@)9etailed methodology"Cill pass comment on to&pert *anel

/ow is %ection 8"3"? usedG Chat is 0permeationand lea!age0G ,s this a new sourceG &plain"

earranged. but notchanged because this was

ta!en verbatim fromprevious uideboo!version <@6(2@)9etailed methodology"Cill pass comment on to&pert *anel



Accepted

9elete this %ection" Accepted

ditorial

There is no section 8"8"8" Accepted %orted

Accepted

Accepted

%ection 3"I. which Tier does it refer toG 'oted

The reference for $:*T 3 is incorrect" Accepted

The formula in this line has not mathematicalmeaning. it is not a mathematical formula" Thesum over the continuous variable T has notmeaning" Chat is that you want to sayG# sum ofthe formula over the different hours (/1 to /2)

considering constant the temperature of each hour.or integral of the formula from T1 to T2G The twothings are the same only if the temperature dataare discrete (temperature averaged for each hour).but if we apply a continuous function to thema&imum and minimum daily temperatures toappro&imate the hourly variation. the two things aredistinct

':T9 - not changed inthis revision because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)9etailed methodology"Cill pass comment on to&pert *anel

'ot deleted. because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)9etailed methodology.

%ection ?"12" Cill passcomment on to &pert*anel

$hange to 0ight fuel components tend to be morevolatile than heavy ones0"

'ot changed because thiswas ta!en verbatim fromprevious uideboo!version <@6(2@)%ection J. p<@6-1I" Cillpass comment on to&pert *anel

%ome of the topics in $hapter 3 (e"g" gridding.reporting) do not appear to be data +uality issues"

'o change made - thesewere the headingsprovided in the templatefrom T':" $onsult withT':>&pert panelregarding their retention

9oes this comment apply to all %ections 3"1 to 3"8.or 7ust 3"8G ,f not. something should be written for%ections 3"1 and 3"2

, believe it does. hencephrase added

'ot sure - ta!en verbatimfrom Table 1-1 ofprevious uideboo!version <@6(2@)" 'eedto refer +uestion toauthors> &pert *anel

Ta!en verbatim from%ection13 of previousuideboo! version<@6(2@)" 'eed to refercomment to authors>&pert *anel



noted

noted %orted

noted %orted

'oted %orted

'oted %orted

noted %orted

'oted

%ome references are needed in this paragraph" Accepted eferences included

e7ected

'oted Altered

$hange 0proportion0 to 0contribution0" ditorial Altered


The Tier 8 method is now a mi& of the simple anddetailed method from the old chapterG

This is a very serious mista!e by the consultants todevelop such a new method. without discussingwith the data suppliers"

Chy do we need to have 8 Tier methodologiesG ,sit mandatory to have 8 Tiers in the uideboo!GTier 1 now ma!es no sense5 Again this was neveragreed with the Transport panel" oreover. themethodlogies are again a mess#Chy is Table 8-8part of the Tier 1 since there is no vehicledistinction to Tier 1G Tier 2 has a correction forspeed but the emission factors are independent ofspeed5

Acording the formulae specified in the documentfor vehicles without control systems it seems theright could be replace 4some4 by 4all4

Ce have computed the probabilty as follows# theprobability of to be par!ed between /-1 to / hoursis the sum from t2N/ to t2N/V11 of sum off(t2.tpar!) from tpar!N2(t2-/)V1 to t2N23 . beingunderstood that# /V& N (/V&) mod 23 and f(t2.tpar!) is the element of matri& at row t2. columntpar!"

There appears to be a problem with the 'F code

for these sources" *art A of %ector 1 is0$ombustion0" Tyre wear. bra!e wear and roadsurface wear are not combustion processes"

This is an inherent

problem with thenomenclature for this sub-sector"

Figure 2-1 is poor and is not helpful" $ould bemuch more graphic" Chy 0flow diagram0G

used to conceptualise theboundaries of roadtransport emissions. and isan approach adoptedthroughout the uideboo!"

0This sector0" Chich sectorG The three sources. the

two 'F codesG AbrasionG

*rocess description0 is not a good title in my view",t is too vague" , also thin! that it repeats title 2.and would therefore delete it"


$ould be made moretransport specific"/owever. might detractfrom a common guideboo!style"



'oted

e7ected

'oted

Are there any more recent dataG 'oted

A discussion of the Tables would be useful" Accepted

%ome of these data should be updated" e7ected

%urely Tier 2 or Tier 8G Accepted Altered

'oted %orted

Accepted Altered

%orted

9isc bra!es are increasingly used in heavy-dutyvehicles"

':T9 - not changed inthis revision because thiswas ta!en verbatim fromprevious uideboo!version <@@(28)%ection 8"2" Cill pass


%ection 2"2 title could be more helpful" Chate&actly does it refer toG


$ould be made moretransport specific"/owever. might detractfrom a common guideboo!style"

Chat is the meaning of the %ection 2"8 title" ,t isvery vague"

A discussion on emissionsources"

,t is not possible ma!ing an update of the emission

estimateG

'ot with the same level ofcompleteness" Chenreporting improves there

will be"'ot with the same level ofcompleteness" Chenreporting improves therewill be"

':T9 - not changed inthis revision because thiswas ta!en verbatim fromprevious uideboo!version <@@(28)%ection 8"2" Cill passcomment on to &pert

*anel

'umbers are suitable forindicative purposes" Alsonot changed in thisrevision because this wasta!en verbatim fromprevious uideboo!version <@@(28)%ection 2" Cill passcomment on to &pert*anel

Tiers classification" $omments are summariHed inseparate Cord document

The decision tree only e&plains *1" <utconvention needs are T%* and *2"I also"

The Tier 1 algorithm resolution is per vehicleclasse" <ut the Tier 1 factors are averaged for allvehicles"




Accepted Altered

Figure 8-1" Chere does Tier 8 fit inG Accepted %orted

Accepted

%orted

Accepted Altered

Accepted Altered

eference codes to be updated" Accepted will be updated

etrics other than *1 are included" Accepted Altered

Accepted Altered

%orted

'oted

Accepted

Chere are the values for fs.i and %s()G %orted

%orted

Altered

Figure 8-1" *1 is not a 0species0 it is a prticlesiHe metric"

The sum over all vehicle categories should beformally introduced into the e+uation"

':T9 - not changed in

this revision because thiswas ta!en verbatim fromprevious uideboo!version <@@(28)+uation 1" Cill passcomment on to &pert*anel

Tables 8-1 to 8-8. is averages only" ,t is considereda wrong decision not to give data per vehicleclasse" Also. T%* and *2"I emission factors areneeded"


Tables 8-1 and 8-2" The units are clearer as g !m-1 vehicle-1" %ubscripts re+uired for *1 and

*2"I"Tables 8-1 and 8-2" The names of chemicals donot ta!e capital letters" %hould be 0polycyclicaromatic hydrocarbons0" %ome of cell contents arecut off

This method seems unnecessarily crude" Cheredo these percentages come fromG

The Tier 2 algorithm claims speed dependency"

/owever. no speed dependency is given in theTable 8-3 to 8-1I emission factors"


Table 8-8" Font too large in Table" Chat are theunitsG

Table superceded bychanged Tables 8-1 and 8-2

Again. summation over all vehicle categories

re+uired"

':T9 - not changed inthis revision because thiswas ta!en verbatim fromprevious uideboo!version <@@(28)+uation 1" Cill passcomment on to &pert

*anel$onsult with&pert *anel

Chere is the speed dependencyG mission factortables for T%* and *2"I are missing"


,s the detailed methodology Tier 2G This is notclear"




%orted

Accepted %orted

etrics other than T%* are included" Accepted %orted

Accepted %orted

Accepted %orted

%orted

This could be more helpful" Chy is this the caseG 'oted %orted

&plain choice of *A/s" Chich protocolG Accepted

Accepted

Accepted

This is all badly e&plained" Chat is this section(8"8"2) aboutG Chere is the speed dependenceG$hec! that the Table titles match the contents"


etrics other than T%* are included" This is allbadly e&plained" Chat is this section (8"8"2)aboutG

,n Tier 8 (Table 8-16). the particulate fractions forother siHes than *1 are listed for tyre wear" <utthese fractions should be available from thebeginning to support also Tier 1 and 2 calculations"

,n Tier 8 (Table 8-1@). the particulate fractions forother siHes than *1 are listed for bra!e wear"<ut these fractions should be available from thebeginning to support also Tier 1 and 2 calculations"

The Tier 8 methodology for road surface wear ismissing"


':T9 - not changed inthis revision because thiswas ta!en verbatim fromprevious uideboo!version <@@(28)%ection J" Cill passcomment on to &pert*anel

%hould be Table 8-1J" 'ot all the substances listedare elements - some of them are ions"

%orted regarding tablereferenced - *hrase49ifferent elements4 notchanged because this wasta!en verbatim fromprevious uideboo!version <@@(28)%ection J" Cill passcomment on to &pert*anel

Table 8-1J needs to be improved" As stated above.some of the 0elements0 are actually ions" Thenomenclature is not consistent (eg" g2V but%:3--" %ubscripts and superscripts are re+uired forthe ions" The term 0elemental speciation0 is usedincorrectly" The word 0bra!e0 is spelt incorrectly"Chat is the meaning of blan! cellsG

':T9 - not changed in

this revision because thistable is ta!en verbatimfrom Table 18 of theprevious uideboo!version <@@(28)" Cillpass comment on to&pert *anel



Accepted Title changed

Chy is there no te&t under 3"1 and 3"2G Accepted /eadings deleted

noted

Chat is 0method 80G ditorial %orted

'oted

%orted

%orted

%orted

Chy have / and *:*s not been includedG noted

Accepted

The te&t in %ection 3"3 has nothing to do withconsistent time series and recalculation5 ,t is moreor less the same te&t as %ection 18 4Temporaldisaggregation criteria4 from the old chapter"

Are the Fs really for asphaltG This is ratherspecific"

':T9 - not changed inthis revision because thisis ta!en verbatim from%ection 11 of the previousuideboo! version<@@(28)" Cill passcomment on to &pert*anel

%ee

http#>>www"ssb"no>emner>1>3>1>rappPemissions>rappP2@8?Pen>rappP2@8?Pen"pdf. page 31-33

&pert panel to be madeaware of these data"

,t is a mista!e to ma!e such averages. since thenumber of vehicles per classe is !nown from theroad transport e&haust inventory"


,n Tier 8. the e&pressions for heavy duty load anda&les (tyre wear). heavy duty load (bra!e wear).and speed (all vehicle classes) are present"


/owever. the speed corrections was to be used inTier 2"


The old chapter briefly discusses how to treatemission inventories in relation to dispersionmodels"


,nformation from oldchapter is included. hencenothing has been lost"

':T9 - not changed inthis revision because thisis ta!en verbatim from theprevious uideboo!version <@@(28)" Cillpass comment on to&pert *anel

missions other then * %eehttp#>>www"ssb"no>emner>1>3>1>rappPemissions>rappP2@8?Pen>rappP2@8?Pen"pdf. page 8J-31

':T9 - not changed inthis revision because thisis ta!en verbatim from theprevious uideboo!version <@@(28)" Cillpass comment on to&pert *anel



AcceptedChat 9irective do you refer toG Accepted 9one

Accepted 9one

Accepted 9one

Accepted 9oneChat is the reference for %:2G Accepted 9one

'oted 9one

Chat is 4/4G 'oted 9one

'oted 9one*"JIGG ditorial 9one

factor 0/0 in e+uation is not specified 'oted 9one

Accepted 9one

Accepted 9one

Accepted 9one A table for line haul locomotives is missing Accepted 9one

'oted 9one

'oted 9one

'oted 9one


relevant information will beincluded whereappropriate and timepermits"

This is 7ust messy !ey words. not fit for a

documentation reportChat is the source of the Fs in tables 8-1. 8-2and 8-8 in this F:9G Also. how is Tier 1 Fsappro& 2 times greater than Tier 2 FsG

There must be errors somewhere in the emissionfactor tablesK ,t is not possible with suchdifferences between Tier 1 and Tier 25

efers reader to T chapter. but then on followingpage. refers reader to the off-road section - whichis correct or are both relevantG

Table shows fs in g>D of fuel - where do hourscome into thisGG

same data in tables 8-2 and 8-8 whereas table forline haul locomotives is missing

Table 8-2 and Table 8-8 are the same e&cept forthe technology name5 They are titled Tier 2 and thene&t line says Tier 15

eneral comment - where are the fs for line haul

locomotivesG

4(e"g". B-T,% ($hiffi. Fiorello. %chrooten. 9elieger (2?)K A,,L4

4(e"g". B-T,% ($hiffi. Fiorello. %chrooten. 9elieger (2?)K A,,L4

The B-T,% railways inventory contains timeseries 1J?-2I and pro7ections (up to 28) forlocomotives and railcars specific activity data(passenger>freight train !m and gross hauled tonne!m) as well as for energy consumption andemission factors" *lease. send us a re+uest tohave a view on the preliminary data (a password isneeded) - the pro7ect will be concluded by the 8 of

April 2?



'oted 9one

'oted 9one

'oted 9one

The emission factors are still missing" 'oted 9one

'oted 9one

Accepted 9one

Accepted 9oneplease add 4B-T,% 2?4 Accepted 9one

'oted 9one

Accepted 9oneplease add 4B-T,% 2?4 Accepted 9one

*lease +uote the B-T,% pro7ect. founded bythe DD-,*T% of %eville and carried aout by TTand ,T:. and provide the weblin! to users in thesame page http#>>www"e&-tremis"eu> - B-T,%combines statistics from different sources and

calculate emission factors for specific engine typesfor each of the 2@ countries (e&cluding altaand $yprus that have no railways)

The B-T,% railways inventory contains timeseries 1J?-2I and pro7ections (up to 28) forlocomotives and railcars specific activity data(passenger>freight train !m and gross hauled tonne!m) as well as for energy consumption andemission factors"

*lease +uote the B-T,% pro7ect. founded by

the DD-,*T% of %eville and carried aout by TTand ,T:. and provide the weblin! to users in thasame page http#>>www"e&-tremis"eu> - B-T,%combines statistics from different sources andcalculate emission factors for specific engine typesfor each of the 2@ countries (e&cluding altaand $yprus that have no railways)

Chat units are the emissions shown in. in the%*A tableG

*aragraph not clear" For e&ample. 4bio-diesel canbe used in all diesel engines with slight or nomodification4 - is this true for 1 biodieselG Aretrains currently running on <2 - <IG

please refer to 4gross hauled tonne !ilometre(hT;)4

according to egulation J1>28. from thebeginning of 28 all railway underta!ings (notonly the 4principal4) shall report their traffic data tourostat" oreover. train movements (national.

international and transit train !m) are reportedconsidering only the distance covered on thenational territory of the reporting country" <y usingoperating data. double counting problem may beavoided" ,n B-T,% some technical notes todata sources will be made available tocompilers>users"

please refer to 4gross hauled tonne !ilometre(hT;)4



'oted 9one

Accepted 9oneemisison factors for additivesGG 'oted 9oneThe number of the chapter is missing Accepted 9one

Accepted 9one

Accepted 9one

Accepted 9one

Accepted 9one

'oted done

according to egulation J1>28. from thebeginning of 28 all railway underta!ings (notonly the 4principal4) shall report their traffic data tourostat" oreover. train movements (national.international and transit train !m) are reportedconsidering only the distance covered on the

national territory of the reporting country" <y usingoperating data. double counting problem may beavoided"

This is 7ust copy and paste from the ,*$$ 26guidelines"

*lease add the reference 4B-T,% pro7ect -ailways ,nventory" For information see thewebsite http#>>www"e&-tremis"eu> and Final eport#$hiffi. Fiorello. %chrooten. 9e lieger. B-T,%.&ploring non-road Transport missions in urope.

D$-,*T% (2?)4

*lease add the reference 4B-T,% pro7ect -ailways ,nventory" For information see thewebsite http#>>www"e&-tremis"eu> and Final eport#$hiffi. Fiorello. %chrooten. 9e lieger. B-T,%.&ploring non-road Transport missions in urope.D$-,*T% (2?)4

eneral comment - chapter refers to diesel andsometimes to gas oil - use one or the otherperhaps as otherwise confusingL

*lease refer also to general comments

summarised in the separate word file 49; eviewof guideboo! chapters for mobile sources"doc4

Table 2"1. please harmonise with ,*$$ 26uidelines



'oted 9one

'oted 9one

$an0t access website


'oted 9one

please update

the distinction beteween domestic (coastal) andinternational shipping in terms of 4activity4 is not sodifficoult to e&trapolate" Activity data in arecollected and provided to urostat by all memberstates according to the aritime %tatistics 9irective($ouncil 9irective J6>63>$)" ,n the urostat'ewcronos aritime 9atabase it is possible to find+uarterly statistics both for passengers and goods(collections marPpaP+mPdetl andmarPgoP+mPdetl) spiltted by direction (inw. outw).partner entity and type of cargo" These collecionsrefers fo main ports only (but J of the totaltraffic)" ,t is possible to consider the total traffic(marPpaPaa and magPgoPaa) of passenger andgoods of all ports by direction and use it for addingthe missing +uota to detailed collections"eferences and methodologies for doing it are in

B-T,% (2?)"

the distinction beteween domestic (coastal) andinternational shipping in terms of 4activity4 is not sodifficoult to e&trapolate" Activity data in arecollected and provided to urostat by all memberstates according to the aritime %tatistics 9irective($ouncil 9irective J6>63>$)" ,n the urostat'ewcronos maritime database it is possible to find+uarterly statistics both for passengers and goods(collections marPpaP+mPdetl and

marPgoP+mPdetl) spiltted by direction (inw. outw).partner entity and type of cargo" These collecionsrefers fo main ports only (but ?>J of the totaltraffic)" ,t is possible to consider the total traffic(marPpaPaa and magPgoPaa) of passenger andgoods of all ports by direction and use it for addingthe missing +uota to detailed collections"eferences and methodologies for doing it are inB-T,% (2?)"

*lease delete. this is not possible to understand>isincorrect>refers to ember %tates (not *arties)


, disagree with thecomment

Also the B-T,% methodology gives an

allocation of emissions according to the type oftraffic


Also the B-T,% methodology gives anallocation of emissions according to the type oftraffic


Footnote# , can0t find the reference for the ntecreports anywhere in the chapter"

*lease remove or update (this was not in theoriginal outline agreed by TF,*>is outdated)




'oted

Accepted 9one

'oted 9one

'oted done

'oted 9one

'oted 9one

'oted $an0t access website

'oted $an0t access website

'oted 9one

'oted 9one

Chat is the origin of this tableG 'oted uideboo! 26

Table 8-2@# %ourceG 'oted uideboo! 26

Table 8-2@# %ourceG 'oted uideboo! 26

Chere does the data in Table 8-2@ come fromG 'oted uideboo! 26

'oted 9one

Chat does the terms in brac!et Q R meanG /as thiste&t been updated in accordance with latest ,:regulationsG

Table 8"1 and 8"2. please provide originalreferences for emission factors (not *-$)(same with the subse+uent tables)

urostat collection of vessel traffic (+uarterly data.main ports. number and gross tonnage of vessels.by type and siHe of vessels and inwards direction -marPtfP+m) provides country statistics for @ groupsof ship types and 22 T siHe classes" eferencesare in B-T,% (2?)" *lease. +uote thewebsite" ,n case. re+uest us a tecnical note on thisissue

urostat collection of vessel traffic (+uarterly data.main ports. number and gross tonnage of vessels.by type and siHe of vessels and inwards direction -marPtfP+m) provides country statistics for @ groups

of ship types and 22 T siHe classes" eferencesare in B-T,% (2?)" *lease. +uote thewebsite"

'ot only ':& emissions are engine specific. butalso * emissions (see % protocols)"

'ot only ':& emissions are engine specific. butalso * emissions (see % protocols)"

The calculation formula gives no meaning" ,nsteadof (fuel sold. engine type) it should


fuel instead of mass#which unit of measureG 7or tonnesG

B-T,% provides a similar tables or additionalparameters in the website (i"e" differentiated

conversion factors or weighted F)B-T,% provides a similar tables or additionalparameters in the website (i"e" differentiatedconversion factors or weighted F)

Activity data has to be segmented per activity type(different F for hotelling. manoeuvring andcruising in T,2)"

Activity data has to be segmented per activity type(different F for hotelling. manoeuvring andcruising in T,2)"

ntec 22G , can0t find this reference in thechapter



All table references are wrong 'oted 9one

Chere does the data in Table 8-2J come fromG 'oted 9one

'oted 9one

'oted 9one

'oted 9one

'oted 9one

'oted 9one

*lease chec! the table references 'oted 9one

also on the B-T,% website $an0t access website


also on the B-T,% website $an0t access website


'oted 9one

'oted 9one

Table 8-2J# *lease include the units in the tablete&t

Chy is the T,8 methodology not very well suitedto show annual trends in emissionsG

The F - only cruise based now - should be aweighted average F of cruising. manoeuvring andhotelling"

Chy is the T,8 methodology not very well suitedto show annual trends in emissionsG

The F - only cruise based now - should be aweighted average F of cruising. manoeuvring andhotelling"


we may add such tables on B-T,%" 9o youthin! this may solve problems to compilers or helpthemG



we may add such tables on B-T,%" 9o youthin! this may solve many problems to compilersG


, thin! we should have to +uote the relevantfacilities provided by the urostat 'ewcronosdatabase" %ee the comment 11" Ce haveassembled some technical notes for wor!ing withurostat data and produce>derive ship movements"*lease. re+uest us these notes if you thin! that aparagraph should be added here"

, thin! we should have to +uote the relevantfacilities provided by the urostat 'ewcronosdatabase" %ee the comment 11" Ce haveassembled some technical notes for wor!ing withurostat data and produce>derive ship movements"

*lese. re+uest us these notes if you thin! that aparagraph should be added here"



Accepted done

Accepted done

Accepted 9one

Accepted done

$onsider for Tier 8

The most comprehensive and detailed source ofinformation for Ferry. o-o. /% craft and cruiseships is the %hip*a& database (please visitwww"shippa&"se for more infos and in particular thewebpage http#>>www"shippa&"se>page>page"aspG

idN13)" , thin! that the 4Thomas $oo!L4 source isnot a good reference"

The most comprehensive and detailed source ofinformation for Ferry. o-o. /% craft and cruiseships is the %hip*a& database (please visitwww"shippa&"se for more infos and in particularhttp#>>www"shippa&"se>page>page"aspGidN13)" ,thin! that the 4Thomas $oo!L4 source is not agood reference"

This par seems to have been copied from the 26sK it mentioned the 26 s and ma!esreference to multilateral operations. this is not in

line with the TA* reporting uidelines" *leaserevise

Ce have built a distance table (mainly forinternational traffic) from>to each maritime coastalareas ($As) of countries to>from $As.all editerranean and <altic third countries and to18 overseas areas. namely <lac! %ea. Arabianulf. ed %ea. ,ndian %ub $ontinent. Australasia.Far ast - $hina Dapan. %outh ast Africa.Cest Africa. % Atlantic $anada - reat a!es.$entral America ] $aribbean. %outh America ]

Atlantic. % $anada ] *acific. %outh America -*acific" 9o you thin! this table proveded on thewebste could help compilersG The table refers toone sole reference port per country


This section 3"3 has nothing to do with consistenttime series and recalculation5 ,t is simply copy andpaste from the old chapter section 8"I4*ro7ections4"

B-T,% performed an analysis on historicaldata (1J?-2I) and gives on a country basis

activity data (tonne-miles and ship-milesmovements by type of ship>engine and by :9).emission factors and total emissions" The F aredifferentiated according to the characteristics of thevisiting fleet calling at seaports of each country"*lease. inform us and re+uest our interim report orthe outline of the final report of B-T,%"




$onsider for Tier 8

$onsider for Tier 8

Accepted 9one

B-T,% performed an analysis on historicaldata (1J?-2I) and gives on a country basisactivity data (tonne-miles and ship-milesmovements by type of ship>engine and by :9).emission factors and total emissions" The F aredifferentiated according to the characteristics of thevisiting fleet calling at seaports of each country"*lease. inform us and re+uest our interim report orthe outline of the final report of B-T,%"


eplace the column $onsumption at full power(tonne>day) as a function of gross tonnage (T)with the following values# $ N [email protected] -1.1I1-?ST2V3.63?3-13ST8$ N @.21J3V.1IST-J.1??I-JST2V2.6?8-13ST8$ N -2.262V.3JST-1.631-@ST2V1.@8J3-12ST8$ N .J1JV.8?ST-6.1I6I-?ST2V6.@J1@-18ST8$ N [email protected] I.6JJ-1@ST3$ N I.21IJV.83ST-8.8@8-?ST2V2.62-18ST8$ N [email protected]?6ST-3.668-6ST2V1.8J11-1ST8$ N -2.262V.3JST-1.631-@ST2V1.@8J3-12ST8$ N "326?2 V "1ST

$ N [email protected]@J-IST2V1.6?2?-JST8$ N [email protected]@ST2VI.I1J8-11ST8$ N [email protected]@ST2VI.I1J8-11ST8$ N ?.2JJV.1?ST-3.3J?-?ST2V3.?J81-13ST8 % A''B *A* F: 9TA,%


Add the reference# 4TroHHi $". accaro " (26).ethodologies for estimating air pollutantemissions from ships# a 26 update. nvironment Transport. 2th ,nternational %cientific%ymposium(including 1Ith conference Transport and Air*ollution). eims. France # 12-13 Dune 26



Accepted 9one

Accepted 9one

Accepted

$onsider for Tier 8

*lease insert the B-T,% reference orwebsite# B-T,% pro7ect - aritme ,nventory -for information see the website http#>>www"e&-tremis"eu> and Final eport# $hiffi. Fiorello.%chrooten. 9e lieger. B-T,%. &ploringnon-road Transport missions in urope. D$-

,*T% (2?)"

*lease insert the B-T,% reference orwebsite# B-T,% pro7ect - aritme ,nventory -for information see the website http#>>www"e&-tremis"eu> and Final eport# $hiffi. Fiorello.%chrooten. 9e lieger. B-T,%. &ploringnon-road Transport missions in urope. D$-,*T% (2?)"

,t0s impossible to verify fs without clear referenceabout source of data" 'o correspondence betweenTable and references5

T,12 are bun!er fuel based methodologies.T,8 is an activity based methodology" Forinstance for <elgium. there is a difference of afactor 8I between a bun!er fuel and an activitybased methodology (,nventory and forecasting ofmaritime emissions in the <elgian sea territory. anactivity-based emission model. Atmosphericnvironment. olume 32. ,ssue 3. February 2?.*ages 66@-6@6. iesbeth %chrooten. ,na 9elieger. uc ,nt *anis. ;arel %tyns and udi Torfs)",t is possible to ma!e a T,12 activity basedmethodology (transforming :%TAT statistics

into activities) on findings in &-T,% - B-T,% pro7ect - aritme ,nventory - forinformation see the website http#>>www"e&-tremis"eu> and Final eport# $hiffi. Fiorello.%chrooten. 9e lieger. B-T,%. &ploringnon-road Transport missions in urope. D$-,*T% (2?)"




$onsider for Tier 8

$onsider for Tier 8

The emission factors used are aggregatedemission factors from 'T$" The T,8methodology can be made even moredesaggregated by using even more desaggregatedemission factors from % (A. T':-*. ,YA.A,'. $-9elft. /as!oning. missieregistratie en

]onitoring %cheepvaart. 9. 'ovember 28)"The 'T$ emission factors are predefined for$ ?I and 2. as for % you can use yourcountry specific $ and create your own countryspecific emission factor" A comparison of bothsources would be usefull" The % protocols arein 9utch. but you can find relevant documentationin nglish in the :*%A report(http#>>www"belspo"be>belspo>home>publ>pubPostc>>rapp38Pen"pdf) and the &-T,% pro7ect

(see comment above for lin!)"

$onsult with

&pert *anel

T,12 are bun!er fuel based methodologies.T,8 is an activity based methodology" Forinstance for <elgium. there is a difference of afactor 8I between a bun!er fuel and an activitybased methodology (,nventory and forecasting ofmaritime emissions in the <elgian sea territory. anactivity-based emission model. Atmosphericnvironment. olume 32. ,ssue 3. February 2?.*ages 66@-6@6. iesbeth %chrooten. ,na 9elieger. uc ,nt *anis. ;arel %tyns and udi Torfs)"

,t is possible to ma!e a T,12 activity basedmethodology (transforming :%TAT statisticsinto activities) on findings in &-T,% - B-T,% pro7ect - aritme ,nventory - forinformation see the website http#>>www"e&-tremis"eu> and Final eport# $hiffi. Fiorello.%chrooten. 9e lieger. B-T,%. &ploringnon-road Transport missions in urope. D$-,*T% (2?)"




$onsider for Tier 8

'oted 9one

Accepted 9one

Accepted 9one

'oted 9one

Accepted 9one

'oted 9one

'oted 9one

'oted 9one

then we are not able to ma!e the calculations5 'oted 9one

Accepted

The emission factors used are aggregatedemission factors from 'T$" The T,8methodology can be made even moredesaggregated by using even more desaggregatedemission factors from % (A. T':-*. ,YA.A,'. $-9elft. /as!oning. missieregistratie en

]onitoring %cheepvaart. 9. 'ovember 28)"The 'T$ emission factors are predefined for$ ?I and 2. as for % you can use yourcountry specific $ and create your own countryspecific emission factor" A comparison of bothsources would be usefull" The % protocols arein 9utch. but you can find relevant documentationin nglish in the :*%A report(http#>>www"belspo"be>belspo>home>publ>pubPostc>>rapp38Pen"pdf) and the &-T,% pro7ect

(see comment above for lin!)"

$onsult with

&pert *anel


,t is very confusing to read this chapter" *racticallyall the references to tables in the te&t

are wrong. and some tables are even missing" Alsoreferences are given to an important sources ofinformation (ntec study)

which we can0t find in the list of reference" And

even more important. the chapter doesn0t print the crusial information from ntec",nventory ma!ers are as!ed to loo! them upthemselves"

<ecause so much remains to be done in thischapter. the reviewers are wasting a lot of time"

be (fuel sold. fuel type. engine type). in order tohave the same resolution as for F"

Chen this basis is correct. you can ma!esummations afterwards"

, suggest to include a description of typicaldevices. e"g"# modified ollsoyce airplaneturbines with cap" of about 8 C . fed by naturalgas" %omeone even have low-'o& technologies"



Cill amend tables (


'oted /$< included

Accepted

'oted 'one

'oted

'oted 'one

There is no reference either in the Tier 1 or 2tables for the 'F 1AIa",t would be correct. if Ffor this 'F not available (or the same asfor other'F in this chapter). it would be specified in thete&t"

,n table 1-1 (and furtheron) the term 0non-residential heating0 is introduced" This term ishighly confusing. and re+uires change" *leaseavoid (throughout the te&t) as much as possiblethis !ind of negative definition" /ere use4commercial>institutional heating4 instead" Also theterm 4other4 should be avoided and may only beused when e&plicitely defined as 'F term"

Fishing is not covered in the small combustionchapter and should therefore be removed from thelist of activities covered" Again there is no mentionof /$< in table 1-1"

%ubdividing this sector needs to be done in aconsistent manner. in order not to confuse areader" The list as presented now is an ambiguousmi&ture of 'F attributions (but note my commentQ1R above) and techni+ues ($/*)

Te&t modified to aligntechnologies more with'F

The only pathway of interest (emissions fromcombustion) is not described in Fig" 2-1

,n conse+uence to comment Q2R. subsections within

the section 2"2 should be consistent to the sub-division first introduced in *age 8>line 1-12"Furthermore. levels of sub-types are not clear orconsistent (e&ample below. comment Q6R)" Finally.techni+ues and sub-types need to match emissionfactors presented" ,"e". differentiating between0open fireplaces0 and 0partly closed fireplaces0 isonly useful when also emission factors are beingpresented (This e&ample being chosen here forsimplicity. but the point is applicable throughout)" Anational e&pert should be able to find the type ofinstallation operative in his>her country accordingto the description in the list of techni+ues. and thenloo! up an appropriate emission factor" ,deally. foreach type of appliance an own set of emissionfactors is presented by fuel" :f course this will notalways be possible - but in the current te&t there isalmost no such connection"

Te&t modified to align moreclosely with 'F. tier 1factors are on fuel basis sono technology relevanceKTier 2 has moredisaggregation but not afull split as this would beunmanageable but thereare more appliance-specific details in Appendi&

%trong chapter on techni+ues ($hapter 2"2)" :newould wish that all chapters were on this high level"/owever the subchapter on $/* should bee&panded"



e7ectede&plain 0autonomy0 - or use different term Accepted odified

Accepted Te&t modified to clarify

Accepted Te&t modified to address

Accepted Te&t included

Accepted 9one


'oted

'oted Te&t modified

Accepted Te&t order modified

e7ected

figure 2-1# wrong title (Lcontribution fromrailwaysL)

$omment for wrongchapter - have ta!en intoaccount in 1A8

%tove types can not be differentiated by thedescription presented" This is widely the case forthe whole list of stove types" $riteria used to formsubcategories are very ambiguous (from fuel type -0pellet0 to appication 0coo!ing0 and further toabatement 0catalytic0)

Finish stove0 and 0ussian stove0 may not bee&pressions that are very helpful to describe stovetypes outside particular countries which applythese terms" ,t is o"!" to use those as a support.but one should not e&pect this is sufficiente&planation

Authors may wish to refer to the fact that - whilethere e&ist stoves predominantly constructed forspecific fuels - there are also multi-fuel stoves"These stoves are popular in some countries asthey are able to burn waste - a considerableemission problem

A very simple statement would help an e&pert tounderstand which type his installation belongs to#4<oilers are devices which heat water4

Automatic feeder systems are also available forwood logs" The advantage of automatic systems isthat they minimiHe handling errors(primary>secondary air. constant combustiontemeratures. L)

$ondensing boilers may achieve efficiencies evenabove 1 - this is basically their feat" For ane&pert using this guideboo!. one could ma!e itesier to identify such an installation# 4condensingboilers re+uire a chimney resistant to the li+uidcondensate4"

Accepted but detail notneeded here"

Chen the potential for large dio&in emission ismentioned it would only be natural to also addressthe possible formation of other *:*s notably /$<"

*rimary measures can be presented in a moresystematic way# modifed fuels > modified heater >

modified combuation

Figure 8-1 does not contain any informationspecific for small combustion - why is it here thenG

,t is a generic decision treebut the elements arerelevant to smallcombustion plant



Accepted

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'oted

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'oted

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'oted



Accepted

Accepted

, strongly disagree# if we limit a country0scontribution to Tier 1 already at this stage. weshould forget about the whole effort" Applyingdefault emission factors to ,A (and similar)statistics can be done much more reliably in acentraliHed manner. and in fact has been done

already (see A,'% model)

Te&t modified slightly butTier 2>1 may be the mostappropriate with (unli!esome other sectors) Tier 8only being achievableusing the model or hybrid

approach "

,n row 11 - A fuel consumption. but in the row 13 - A production -activity rate for the lime production

,t would be better if these tables 8-1 to 8-12refering to Tier 1 were listed in order from 1a3a.1a3b and 1a3c etc" Also what siHe boilers to theseFs relate to 2-I C or W2 CG

%ee comment Q1R above# avoid 0other0. instead use0medium>light li+uid fuels0

<ased on 'A*F fuelclassifications

/ere and elsewhere# ,f the range presented for

emission factors e&tends over two orders ofmagnitude. reporting has very little meaning

The selected fuel groupings for residential andnon-residential combustion seems less than ideal"<iomass should be divided into wood and straw"

At Tier 1 we have broughttogether by main fuelclassifications

$ommon comment for Tier 1 and Tier 2 tables#emission factors are shown with reference touideboo! 26" <ut most of emission factors donot coincide with the factors in the uideboo!26" specially large differences are for %:&. $:.':$. *$99>F. *A/" 'o emission factors for

indicator *A/ while uideboo! 26 includesthem"


,t would be possible to include corresponding%'A* codes in the allTier 1 and 2 tables

Table format is fi&ed toreflect 'F but %'A* alsoprovided

,n table 8-2 (and all other Tier 1-2 tables) the total*A/ emission factor is resulted. but according tore+uirements of reporting uideline it is necessaryto report separately on four substances

,n the table 8-2 (and all other Tier 1-2 tables) fromrow 4'ot estimate4 would be deleted 4*:*s4 and

into row 4'ot applicable4 include Anne& , *:*s (byeach substance)"

Table 8-I# error in *b and /g emission factor (incolumn alue are shown as . but in column ower

] not )"ounding>significant figureissue

%everal values listed as 44 in table 8-I and 8-6"ac! of /$< emission factor as well as detailed*A/ emission factors are a problem"




Accepted

'oted

'oted Te&t modified

'oted

'oted

'oted Addressed where possible"

Accepted

,n the table substitute 4%olid fuel4 with 4$oal fuel4 'oted

Accepted

'oted

'oted

,n the table 8-I. row fuel name - 4:ther i+uidFuels4" ,t is not clear - other. e&cepting residualfuel oil. or 4other oil4 (according to fuel defini

,nclude summary table offuel classes

Table 8-6# error in *b emission factor (in columnalue are shown as . but in column ower ] not)"


The dio&in emission seems to refer to the emissionfactor for advanced fireplaces in the e&istingguideboo!" A general tier 1 emission factor shouldprobably be somewhat higher"


,n table 8-6. upper estimate for %e is below therecommended valueK in tab" 8-@. several metalse&hibit an upper estimate of 00


,n table 8-I the fuel name is 4/eavy Fuel :il4" According to fuel definition in the new reportingguideline it must be 4esidual Fuel :il4,n othercombustion chapters the same"

,t seems odd that all particles from biomass

combustion in the non-residential sector isassumed to be *2"I"


Again Tier 2. Tanles 8-13 to 8-26 seem to start withresidential (1a3a) and then move onto :thersectors (1a3a and 1a3c)" Also there is noinformation about thermal siHe of combustion planthere"

Table 8-18 amendedslightly. note that 'F hasno siHe distinction

in table 8-18 and subse+uent tables# provideemission factors to instllations as they have beendescribed in section 2"2 - see comment Q3R

solid0 fuel is first mentioned here - put this way itwould comprise also biomassK use 0coal0 (as in theprevious part of this chapter) or 0solid fossil fuels0

Te&t amended to include1A1a fuel types

%ee earlier note on fuelclassification - don0t wantto preclude co!e and othersolid fuels

The tables contain a very large number ofemission factors +uoted as uideboo! (26) butwith different values" ,t0s impossible to presentsimilar tables 5 %ome e&amples are reported inFPcomments"


$:'$%,:'# A T/ TA<% %T <,%9

The e&isting guideboo! list a dio&in emission factorof ? ng>D for standard fireplaces and 8 foradvanced fireplaces" Therefore the emission factorof 8I ng>D with reference to the e&istingguideboo! seems wrong"



Accepted

'oted

'oted

'oted

Accepted Table included

Accepted Te&t deleted

,n table 8-16 the F for $: is "1 g>DG %urelythis is a mista!e" ,n the ne&t table 8-1@ $: has anF of 1g>D. or 1. greater"


Tables 8-1@. 8-1?. 8-2# heavy metals emissionfactors should be rounded"


Table 8-2# errors in F for *2"I (in column

alue are shown as . but in column ower ] not)"


The dual reference system is confusing" ither thereference is the e&isisting guideboo! or it is$,T*A" %everal of the listed emission factorsdoes not correspond to the values in the e&istingguideboo!s values for stoves li+uid fuels"


Table 8-28# errors in F for *1 and *2"I (incolumn alue are shown as . but in column ower

] not )K F for T%* should be chec!ed"Cill change with newtables

ost values in table 8-22 refers to the e&istingguideboo!. however several of the listed emissionfactors do not correspond to the emission factorsprovided for wood burning boilers in the e&istingguideboo!"


Table 8-26# value F and JI confidence intervalare the same for T%*. As. $d. $r. /g. *b"


$: seems to be to high for a diesel engine (li+uidfired) in table 8-26" ,n the tables 8-23 and 8-2Iturbines running on gas and oil are included" ,n

these two table als gas engines should beintroduced so that the ':& values are comparablebetween different prime mover technologies"

%ee also#http#>>www"euromot"org>download>news>positions>stationaryPengines>FuturePstationaryPenginePemissionPlegislationP'ov3"pdf

http#>>www"euromot"org>download>news>positions>stationaryPengines>,**$<P<FPeuromotPcommentPmayP2"pdf

Chy is there no default emission factors given for

natural gas fired reciprocating engines" ,t wouldseem that a large part of the fuel use for sttionaryengines would be natural gas"

%uggest to do it the other way round - datareported to the 'F$$$ will have no focus onwood consumption and thus will li!ely provideunreliable numbers" ,nstead# esults on woodconsumption provided here should be made use offor the 'F$$$ submission also"



'oted

Accepted

Accepted

'oted

ditorial ef modified

ditorial ef corrected

ditorial

'otedThe title of the tables are not visible" ditorial 9one

ditorial 9one

The Tier 8 method needs more elaboration" %houldinventory compiliers use the technology based Fsin Appendi& A or notG These Fs tables should notbe placed in an Appendi& if they are part of the Tier8 methodology"

The choice ofmethodology is up to thecountry. the significance ofthe source and theresources available"

This glossary should either be e&panded or

removed"%ome sources listed as references in the chapterare missing from the list of references. e"g"$,T*A 2@. ustavsson et al" 1JJ8. $*,*23. 9T, 2I. uideboo! 26"

, suggest to indicate if emissions factors are basedon field measurements (real conditions) orstationary conditions which e"g" is the case for(<T) 1JJJ to <T (2I)" Additionally ,t would beuseful to !now how many ovens>boilers have beenmeasured and if the emission factors are

representative for e"g" a specific technology whichis typical for a country or region"

Ce have no additional

data - these are asprovided in <216

<T (2I>2)/yperlin! does not point to a specificdocument#http#>>www"blt"bmlf"gv"at>menu>inde&Pe"htm"

*lease correct reference to 4sterreichischemissionsinventur fr %tauSbS4 and4mweSlStbundesamt4

Appendi& < dos not add much additionalinformation to appendi& $ of $hapter 1A1 (they arewidely identically)" , suggest to 7ust add a table with

typical reference :2 concentrations and the 29iagrams and add a reference to chapter 1A1"

Agree but they areseparate chapters. not

sure we can split out theappendi&"

eference :2 concentration of wood is often 18", suggest to add a line for this to the diagrams"

'ot changed. there aremany reference :2 levelseg @. 1 or 11 nationalpreferences apply" '88(boilers W8!C) is 1

The tables are unreadable as they are partly offthe page"



'oted

'oted Final chec!ing needed

'oted

'oted

'ot relevant to 1A3tion in the new reporting guideline) $omment corrupted G

'one

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Accepted 9one

Chat is the number of this directiveG 'oted 9one

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missions that are related to different engine typesare missing e"g" %par! ,gnition engine (gas mode)"Ce recommend to refer on page 12 of thefollowing document#

http#>>www"ymparisto"fi>download"aspGcontentidN8@?lanNfi

Furthemore the French limits for 9ual Fuelstationary engines are missing" These should beadded"

:ther details# , rec!on a final proofreading will beperformed to ta!e care of a number of editingissues (incomplete sentences. abbreviationspresented but not e&plained in Tab 3-3. citations($,T*A 2@). and similar)

ac! of line numbering of the chapter on small

combustion will result in fewer line numberreferrals"

As reference is made to $hapter 1A3. should weunderstand that industrial engines are the samethan engines in $ommercial. ,nstitutional andesidential sectorsG 9oes it matter the power ofthe engineG

%mall $/* for publicpower uses the sametechnology as non-residential $/*" asturbines can often belarger than I Cth butengines are generallysmaller (usually a lotsmaller)"

Ta!ing into account that raw materials have alsosulphur content. where are the net %:& emissionsestimated for cement and lime productionG# eitherin 1"A"2"f or in 'F categories 2"A"1 and 2"A"2G

For instance the emission factors for $:. %:2.T%* etc"

9on0t see where this isreferred to

Chat are the total net %:& emissions. ta!ing intoaccount the three components# gross %:& fromfuel. gross %:& from raw materials and %:&captured by raw materialsG

This is wrong and confusing" The %'A* group

?1 contains military activities (and differentfuel types). please refer to error 1d"

Uou must show tables for each ' directiveand e&plain what they contain"

Chere is there a precise definition of e+uipmentlevel and e+uipment typeG This must behighlighted"



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$hapterK 'on road mobile sources and machinery 'oted 9one

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Tables for 1A2fii (industry machinery) and 1A3a ii($ommercial>,nstitutional# obile) emission factorsare missing"

,t is necessary to e&plain. that only agriculture andforestry machinery are behind the figures"

Table 8-8# The categorisation of recreational craftis wrong" These types of vessels must be included

This sentence gives no meaning" A lot of dieselfuel is being used by stationary engine. and toassume all

The * fuel type is also present" ,n fact. you mayconsider to use the term fuel>engine type"

*lease be aware that recreational craft and militaryvehicles must be treated differently

Table 8-18 to 8-16# The figures in this table relatesonly to recreational craft" Tables 8-18 (diesel) and8-1I (3-stro!e gasoline) concerns the emission

level prior to the directive 28>33 emissionstandards"

Uou have forgotten two tables for 2-stro!e gasolineboats. relating to emission levels before directive28>33. and for directive 28>33 emission levels"

%till missing is three emission factor tables fordiesel fuelled e+uipment in the 'F sector 1A3aii

This section is essential for inventory ma!ers inorder to allocate fuel into emission layers. but itgives no guidance at all"

A study from 1JJ8 is not recently made" 'othinghas been done to update this part of the te&t"

%ince there is still no updates in this part. , reallyhave no opinion"

This table is full of errors" *lease use the tablesdirectly from the old guideboo!"

*lease refer also to general commentssummarised in the separate word file 49; eview

of guideboo! chapters for mobile sources"doc4There are many serious mista!es in this chapter"%ome of them relates to 1) errors in 'F codecategorisation

and 2) errors in computed emission factors whentransferring from g>tonnes of fuel to g>D"

rror 1a)# The data that is stated for 1AIb (:ther)in the new chapter has nothing to do with militaryactivities5



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These data. submitted by orten Cinther are validfor boats. and hence represent recreational craft"The %'A* code for recreational craft is ?8.

which is specificly mentioned in the old guideboo!"Following the $TA* transfer procedure between

%'A* and 'F codes.recreational craft are further classified as part of'avigation 1A8d (agreed by all member states)"

,f we want recreational craft to be included in thischapter. it is necessary to include the code 1A8d ii('ational 'avigation) in the table on *age 1"

rror 1b) ,n the * 9raft 2@ guidelines forestimating and reporting guidelines the 'Fcategory 1A3a ii ($ommercial>,nstitutional# obile)now appears"

This category must be included in the table on

*age 1"rror 1c)# The category 1A3c iii(Agriculture>Forestry>Fishing# 'ational Fishing istreated in the 'avigation chapter"

/ence this code should be deleted from the tableon *age 1"

rror 1d)# ilitary mobile activities are 'Fgrouped as 1AIb (other). and contains aviation.land based and sailing activities"

,f you want to present emf for military in thischapter you must produce completely new figures.

or perhaps repeat the data from the old guideboo!"rror 2)# A calculation error has been made in allthe emission factor tables. when transferring fromg>tonnes to g>D"

,n the spreadsheets provided by orten Cinther.g>D related emf are calculated" *lease use thesefactors instead"

%erious omission# the information on testprocedures from the old chapter must be included(and updated) in the new chapter

,t is no help for inventory ma!ers to have suchvague description

The Tier 1 figures in the Tables 8-2 to 8-? are allwrong" *lease use the factors from ortenCinther. directly"

Fishing vessels are treated in the 'avigationchapter"

in the sector 1A8d ('avigation)" This follows thecorrect transfer between %'A* (?8)

and the 'F (1A8d) category" ,n the currentversion of the guideboo!. %'A* ?8



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ditorial 9one

is clearly described as inland waterways.containing also the activities by recreational craft"

,t is a very big mista!e not to follow thenomenclature agreed by the inventory community"

,f you want to present emf for military you mustproduce completely new figures. or perhaps repeatthe data from the old guideboo!"

fuel being used in ' would introduce aserious error in the inventories"

Tables# ,nventory ma!ers must have theinformation of which sales year relates to whichemission layers"

Tables# Tier 2 emission factors prior to stage , mustbe split into three technology levels (W1J?1. 1J?1-1JJ. 1JJ1-stage ,) instead of applying oneaverage"

The differences between layers are too big toignore" Uou must use the data provided by ortenCinther"

Tables 8-13 (diesel) and 8-16 (3-stro!e gasoline)concerns the emission level corresponding with thedirective 28>33 emission standards"

,t has nothing to do with military e+uipment5 Uouare mi&ing up all definitions"

,n addition. the Table 8-13 to 8-16 captions includethe 'F category 1A3c# *lease stress that it is therecreational craft part of 'avigation we are dealingwith here"

These data , calculated for you also. as a part ofour agreement"

1) Uou must provide some !ind of information. forinstance -values. which distributes fuelconsumption as a function of engine age for each'F code"

%uch distribution functions can be derived from theCinther 'ielsen database"

2) Uou must also provide information of whichsales year relates to which emission layers"

Uou can find these data in the relevant directives.

or alternatively derive aggregated sales yearinformation from the Cinther 'ielsen database"

8) Finally. you must provide information of averageengine life times for the different 'F codes" Thiscan be derived from the Cinther 'ielsendatabase"

$hange as 4The e&traction and treatment of coalresult mainly in emissions of methane"4



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Accepted

Accepted

Accepted 9one

,n the te&t the reference is Tsibuls!i not Tisbuls!i" ditorial 9one

Accepted Added to references

'oted

Are you sure *$< N 2 g (it0s not mgG) Accepted

Accepted 9one

Accepted 9one

9elete the sentence 4This sector was estimated toaccount for 22 of the total national $/3emissions in the ; in 1JJ1 (ilham. 1JJ3)"4 ,t0san old data not relevant for the <"

$hange as /owever. also ':$. * and $:2are emitted

$hange 4methane emission4 with 4firedamprelease4

9elete from not applicable# 4T%*. *1K *2"IK*bK $dK /gK AsK $rK $uK 'iK %eK YnK4 *ut in 'otestimated## 4T%*. *1K *2"IK *bK $dK /gK AsK$rK $uK 'iK %eK YnK4

9elete from not applicable# 4T%*. *1K *2"IK*bK $dK /gK AsK $rK $uK 'iK %eK YnK4 *ut in 'otestimated## 4T%*. *1K *2"IK *bK $dK /gK AsK$rK $uK 'iK %eK YnK4

9elete from not applicable# 4T%*. *1K *2"IK*bK $dK /gK AsK $rK $uK 'iK %eK YnK4 *ut in 'ot

estimated## 4T%*. *1K *2"IK *bK $dK /gK AsK$rK $uK 'iK %eK YnK4

,nsert after the title# 4A Tier 8 methodology foremission factors estimate for open dust sources atcoal mines can be found in % *A A*32 in$hapter 11"J Cestern %urface $oal ining (%*A. 1JJ?)4

,nsert the reference# % *A. 1JJ? A* 32.$ompilation of Air *ollutant mission Factors.olume 1# %tationary *oint and Area %ources. Fifth

dition. olume ,. $hapter 11"J Cestern %urface$oal ining. 1JJ?

There are no guidance of storage of solid fuel"%hould particle emission from coal storage beestimated and if so there should be a defaultemission factor made available"

F removed. notapplicable here

Add the sentence 4,n this category can be included$oal /andling And %torage" For this A Tier 8methodology for emission factors estimate can befound in % *A A*32 in $hapter 18"2"3

Aggregate /andling And %torage *iles (% *A.26)4

,nsert the reference# % *A. 26 A* 32.$ompilation of Air *ollutant mission Factors.olume 1# %tationary *oint and Area %ources. Fifthdition. olume ,. $hapter 18"2"3 Aggregate/andling And %torage *iles. 26



Accepted 9one

Accepted 9one

Accepted %entence added


'oted

'oted

'oted

Accepted

'oted

'oted

'oted

'oted

Chy is venting included in this chapterG ,t shouldbe placed in the chapter 1<2c 'T,' andflaring"

delete 4or li+uefied gas4# it0s included insubse+uent 2"1"? paragraph

insert a comment about 4oil pumps4 and indicatewhere mission from these are computed.particularly when pumps are fuelled by oil (as inthe case of ships pumping of oil at maritimeterminal4

insert a paragraph about 4gas compressor station4and indicate where mission from these arecomputed

The references are very old" The newest one ismore than 2 years old" ,t should be discussedwhether the data are still valid"

, can only agree with the inserted comment. thatbetter data should be available" This issue should

however had been solved prior to releasing a firstorder draft"

, am unable to reproduce the resulting emissionfactor in table 8-2 based on the current values inthe e&isting guideboo!" The comment states thatthe geometric mean from distribution has beenadded based on table ?"1@ in the e&istingguideboo!"

ery strange sentence since the inserted commentcontradicts the meaning of the sentence"

$omment removedK iswrong

insert a Tier 2 evaluation for I61*ipelines andI68 9istribution networ!sK , thin! it0s a priority

The values in the e&isting guideboo! varies greatlyfrom "J1 to 8"2. therefore 7ust ta!ing a geometricmean of all values listed without an accompanyinge&planation does not seem appropriate"

The values in the e&isting guideboo! varies greatlyfrom "1 to 8"1. therefore 7ust ta!ing a geometricmean of all values listed without an accompanyinge&planation does not seem appropriate"

The values in the e&isting guideboo! varies greatlyfrom "J to 8"1. therefore 7ust ta!ing a geometricmean of all values listed without an accompanyinge&planation does not seem appropriate" The valueof 8"1 stems from omania and seems li!e anoutlier



Accepted

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Accepted 9one

rase Table 8-28 as must be included in 1"<"2"a"v e7ected

Accepted 9one

A couple of the references are not used in the te&t" Accepted

olume title correctly# 1"<"2"a"i. 1"<"2"b" 'oted

'oted

Accepted 9one

Accepted Figure updated

Accepted 9onereplace 4unit units4 with 4unit4 ditorial 9one

ditorial 9one

Accepted 9one

Accepted pdated to "3

e7ected

As mentioned this chapter is directly copy>pastefrom the e&isting guideboo!" A lot of data concernsventing. this information should be moved to thecorrect chapter"

, would suggested to move factors for venting to1"<"2"c"

delete all the point 8"3"2"I :il loading and transportmust be included in 1"<"2"a"v

$larify Table 8-23 (in the te&t erroneous indicatedas Table ?"1?)# must be included in 1"<"2"a"v andreview the te&t conse+uently

$hec!edK some referencesremoved

$onsidering the values in that table covers only

distribution the emission factor seems low"

9elete 4*assant. 1JJ84 This reference is no longergiven and the*A reference is wholly ade+uate"

Figure 2-1# The notation of /eat and its emission ismissing from the chart" %ee 2nd comment above"

,n Table 8-2. %ection 4Abatement Technologies4the use of thephrase 4*rimary cyclone"""""""4 maybe misleading" To avoid confusion. it isrecommended that the abatement technologyisdescribed as 4$yclone systems installed

internally within the regenerator4"

Title of Table 8-8 re+uires amendment as itcurrently reads 4"""""""reforming unit units4" 9eletethe word 4unit4"

change 48"8"2"@ 9iffuse emissions4 with 48"8"2"@asoline storage" For depots of gasoline inrefinery refer to Tier84

,n Table 8-6. the pper $onfidence imit loo!sincorrect" The samepollutant and F are given inthe Tier 1 Table 8-1. with an upperlimit of "3instead of "6 given in this Table"

replace 4This section provides Tier 8 informationfor refineries"



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ditorial 9one

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eferences should be (% *A. 1JJI. $'. 2?) Accepted 9one

eference should be 4% *A (1JJI)4 Accepted 9oneeference should be 4$' (2?)4 Accepted 9one

Accepted 9one

*roposed changed te&t to clarify where thecyclones are installed#4The basic catalytic crac!ingregenerator design normally incorporates. insidethe regenerator vessel. cyclone systems toseparate the catalyst particles from thehydrocarbon vapours"Additional cyclones systemsand>or electrostatic precipitators maybe installede&ternal to the regenerator to abate further theparticulate emissions4"

,n Table 8-@. the reference for 4partial burn with $:boiler4 is wrong" This is not given in $:'$AC8>@" The o&idation value of JJ"Iis given in the$ommission 9ecision of 2J-1-3 on /0s- see:D 'o" IJ. 26"2"23 (comment later re p23)

,n Table 8-@. the reference for 4full burnregeneration4 is wrong" This is not given in$:'$AC 8>@" The o&idation value of JJ"Iisgiven in the $ommission 9ecision of 2J-1-3 on/0s- see :D 'o" IJ. 26"2"23 (commentlater re p23)

,n Table 8-@. the reference for 4additional cyclonestages4 is wrong" This is not given in $:'$AC8>@" A reference to the efinery<F should begiven i"e" 4uropean $ommission (28)4

,n Table 8-@. the reference for 4electrostaticprecipitators4 is wrong" This is not given in$:'$AC 8>@" A reference to the efinery<F

should be given i"e" 4uropean $ommission(28)4

,n Table 8-@. to clarify where the 4Additionalcyclone stages4 arelocated. it is recommended tochange this to 4Additional cyclonestages installede&ternal to the regenerator4

%hould this e+uation be numbered i"e" be e+uation4(J)4G

%hould this e+uation be numbered i"e" be e+uation4(1)4G

Add new paragraph# 4A recent development is theuse of hand-held optical imaging devices to detectlea!ing components permitting surveys to beunderta!en more +uic!ly (pperson et al". 2@)"4



Accepted 9oneeference should be 4% *A (1JJI)4 Accepted 9oneeference should be 4% *A (1JJI)4 Accepted 9one

Accepted 9oneeference should be 4% *A (1JJI)4 Accepted 9one

Accepted 9one

Accepted 9one

Accepted 9one

Accepted 9one

There are issues on double counting which arehighlighted on page 1.lines J to 1@" %uggest repeathere"

$urrent te&t in this paragraph should be deletedand replaced# eason# optical remote sensingtechni+ues can only measure emissions over avery short time period e"g" a few hours" missionsfrom refinery sources generally vary widely withtime. e"g" floating roof tan! emissions are highlydependent on wind speed" ,t is not valid. therefore.to e&trapolate these short term measurements tocalculate refinery annual emission inventoriesasthis would result in significant errors" ,t isproposed that the ,t is proposed that the following

te&t is inserted in its place#4emote sensing usingoptical gas imaging may be used to identify.fore&ample. if any e&ternal floating roof storage tan!sare operating outside of the performance boundsfor which emission factors are valid. permittingfocussed maintenanceto ensure that factors canthen be used for these sources forinventorypurposes"4

eference *A 1JJ8 is incorrect" ,t should be#4nited %tatesnvironmental *rotection Agency(% *A) 1JJI" *rotocol for+uipment ea!mission stimates" *A-3I8>-JI-1@" :fficeof

Air =uality *lanning and %tandards. esearchTriangle *ar!.'orth $arolina4

eference $' (2I) should be updated as this%tandard is now published as ' 1I336. 2?"

The reference % *A 1JJ3 is not referred to inthe chapter" ,t should be removed from the list"

,f the proposed te&t addition above (p 22. line @) isaccepted. thenthere is the need for a newreference# 4pperson. 9 et al" 49erivationof newemission factors for +uantification of massemissions whenusing optical gas imaging for

detecting lea!s4" Dournal of the Air andCasteanagement Association (DACA). ol" I@. ,ssue'o" J.%eptember 2@4"



Accepted 9one'o F for %'A* I32 'oted

'oted

e7ected9irective number is J3>68>$. not 68>J3>$ ditorial 9one

9irective number is J3>68>$. not 68>J3>$ ditorial 9one

Accepted 9one

ditorial 9one

ditorial 9one9irective number is J3>68>$. not 68>J3>$ ditorial 9one

ditorial 9one9irective number is J3>68>$. not 68>J3>$ ditorial 9one

ditorial 9one9irective number is J3>68>$. not 68>J3>$ ditorial 9one9irective number is J3>68>$. not 68>J3>$ ditorial 9one9irective number is J3>68>$. not 68>J3>$ ditorial 9one9irective number is J3>68>$. not 68>J3>$ ditorial 9one9irective number is J3>68>$. not 68>J3>$ ditorial 9one9irective number is J3>68>$. not 68>J3>$ ditorial 9one$hange 4reportedly4 to 4reported4" ditorial 9one

Accepted9irective number is J3>68>$. not 68>J3>$ ditorial 9one

Accepted

A new reference is re+uired for Table 8-@ (seecomments above)" This is# 4uropean$ommission (23). 4$ommission decisionof 2JDanuary 23 establishing guidelines for themonitoring andreporting of greenhouse gasemissions pursuant to 9irective28>?@>$ of the

uropean *arliament and of the $ouncil(23>1I6>$)" :fficial Dournal of the uropean$ommunities 'o" IJ. 26"2"234

The figure is nice" A similar one should be providedfor marine terminals or include marine terminals inthe present figure 2"1

Add the reference# A*AT (2@) AgenHiaegionale per la *roteHione Ambientale dellaToscana. onitoraggio delle aree geotermiche"apporto Finale. Anno 26. 'ovembre 2@

*ropose change 4There are two ma7or sources """4to 4There are three sources """"4" easons#following the statement are listed three sources. ofwhich only one (standing storage emissions)issignificant"

eplace 4into a cargo tan! truc!4 with 4into a cargotan! truc! or ship4

Add 4occur when4 at start of this line to follow onfrom line ?"

eference should be 4uropean $ommission.

264 not 4,**$<. 2I4

%hould be 4uropean $ommission. 264 not4,**$<. 2I4

A - gasoline production statistic (p" 11. row ?)" :n

the p"12. row 12 - amount of gasoline sold shouldbe used as activity statistics

9escriptions harmoniHedK

gasoline sold is relevantactivity here

ive a definition of oil product" Chat productshave to be includedG gasoline. gas oil. fuel oil.aviation gasoline. distillate oil L"G

9escription made moreclear



Accepted $orrect here

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ditorial 9one

Add 4is4 between 4"""""pressure4 and 4the vapour """4 ditorial 9oneTable title should be 8-12 ditorial 9one9irective number is J3>68>$. not 68>J3>$ ditorial 9one

Chat is throughput # crude oil G %omething elseG9efine please" *rovide also some default valuesfor average vapour pressures for the differentproducts from crude oil to naphtha. gasoline. gasoilL


asoline considered here.has been added to te&t







Chat is throughput # crude oil G %omething elseG9efine please" *rovide also some default valuesfor average vapour pressures for the different

products from crude oil to naphtha. gasoline. gasoilL






,n the table 8-6 %'A* II1 or I31 (marineterminalsG)

references should not be guide boo! 26 but$:'$AC 2@




Chat is throughput in service station stations.gasoline and gas oilG *rovide default vapourpressures or e&plain how to get them

eference made to %*A description


eference made to %*A description

Chat is throughput in service station stations.gasoline and gas oilG *rovide default vapour

pressures or e&plain how to get them

eference made to %

*A descriptioneplace 4previously contained gasoline4 with4previously contained crude oil. gasoline or otherhighly volatile products4



Accepted 9oneChy it is not throughput but gasolineG 'oted

'oted

e7ected

Accepted

Accepted

Accepted 9one9irective number is J3>68>$. not 68>J3>$ ditorial 9one%hould be Table 8-18 ditorial 9one

Accepted 9one

ditorial 9one*ropose move to %ection 3"2 Accepted 9one

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ditorial 9one


the efficiency of J? is too optimistic in real lifethe efficiency is lower" J to JI would be more

reasonable"$oncawe considered the methodology asobsolete5 eplace all with the sentence 4Fordepots of gasoline in refinery refer to Tier84

This e&planation comes too late" /owever not onlygasoline is volatile" Aviation gasoline. 'aphtha.crude oil are stored and displaced" They have tobe considered" as oil could be considered ifnecessary in countries with high temperature"

The efficiency of J is too optimistic" Fromstudies carried out in France the efficiency for astation with an active system wor!ing correctly is? " Uou have also to consider that due to poormaintenance. most active systems become lessefficient and some of them are out of service" ,fyou do not have statistics on the of activesystems wor!ing correctly. an average efficiencyta!ing into account the systems out of service canbe 6" The T, document (see the T,web site) describes this situation" This situation iscommon in urope" ermany and %witHerlandhave recently implemented the use of selfcontrolled active systems (the e+uipment ofe&isting stations should be finalised in ermanythis year and 1 of service stations are alreadye+uipped in %witHerland")" :nly with such systems.the efficiency can rise up to J "

$omment ta!en intoaccountK some te&t on thisadded and reference toT, made

9elete 4For e&ample. it will use a !nowledge ofe+uipment components fitted in the refinery toprovide estimates of process fugitive emissions"4as this e&ample is not relevant to this 'F"

The te&t currently in 3"I seems more appropriatehere than in 3"I

$hange 4For storage """4 to 4For e&ample. forstorage """4

Add 4refinery4 before 4storage4 to clarify what is in313"

Add 4terminals and 4 between 4mar!eting4 and4depots4 to ensureall facilities are captured"



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Accepted 9one9elete5 e7ected

e7ected

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Accepted

lossary# %tage , $ontrols - 4terminals (dispatchstations)4 should be replaced by 4refinery dispatchstations4"

lossary# True apour *ressure - suggest add4%ee section 8"8"2"14at the end of the definition asthe formula to calculate T* is giventhere"

lossary# apour 9estruction nit (9)" 9eletethis definition. as9s are not described in thete&t as not permitted in "

4 with # 4For storage tan! emissions $oncawereport suggests the use of the latest edition of A*,documents for Floating oof Tan!s (A*,.28).and ertical Fi&ed oof Tan!s (A*,. 22)" For

Aboveground /oriHontal Tan!s. $oncawe reportsuggests to use the latest edition of "%" *Amethodology ("%"*A. 1JJI)" 'ote that this

reference normally contains the latest version ofpreviously +uoted A*, methodologies" An emissioncalculation software is available from the % *Avia their website. http#>>www"epa"gov. or on a $9-:("%"*A. 2I)" This $9 also contains the*A publication ("%"*A. 1JJI) and A*,documents (A*, 22K 28)"4

replace 4ost emission factors are ta!en from theuide to eothermal nergy and the nvironment(eothermal nergy Association. 2@). availablevia http#>>www"geo-energy"org>publications>reports>nvironmental2uide"pdf"4 with 4mission factors results frommeasurement performed by the environmentalprotection agency of Toscana region. ,taly (A*AT.26)" The region is the main urope producer ofthis !ind of energy"

9ue to differences in chemical composition ofgeothermal fluid. site dependent emission factorsobtained by sampling is suggested"

Added to te&t as apreferable option

%ince the authors. 7udging by the insertedcomment. do not !now. what is meant. , will ta!e acrac! at solving the mystery" y best bet is that

line 1J-2 and line 21-22 should also be part of thebulletpoints. then it all ma!es sense55

Than!s5 'ow it ma!esmore sense"

,s there a particular resaon why the emission factorare e&preesed in g>%m8. or is it 7ust because thatis the units used in the e&isting guideboo!G g>'m8og g>D could be used"

All updated to g>'m8 forharmoniHation"



'oted

e7ected'o need to repeat a completely identical table" e7ected

Accepted %entence removed

Accepted Fi&ed

Accepted Fi&ed

Accepted Fi&edChy no glossary for this chapterG 'oted

9espite all the mentions of venting. this table isabout flaring not venting" 9ata stems from thee&isting guideboo!. where the +uality is $ and not9 as mentioned in the inserted comment"


Table heading updated"=uality rating updated.therefore uncertaintyrange updated as well"

,f the factors only are applicable for 'orway. therelevance of having them in the guideboo! would

seem miniscule"

replace 4For the types of storage tan!s used tostore volatile li+uids at refineries. emissionestimation methodologies are provided by the %*A (*A. 26)" These methodologies re+uireinformation on the tan! contents. siHe. shell colour.floating roof fitting types and number. etc". on atan!-by-tan! basis" mission calculation softwareutiliHing the algorithms in the % *A publication is

available on the *A website http#>>www"epa"gov.or on a $9-: (*A. 2I)" 4 with 4For storagetan! emissions $oncawe report suggests the useof the latest edition of A*, documents for Floatingoof Tan!s (A*,.28). and ertical Fi&ed oofTan!s (A*,. 22)" For Aboveground /oriHontalTan!s. $oncawe report suggests to use the latestedition of "%" *A methodology ("%"*A. 1JJI)"'ote that this reference normally contains thelatest version of previously +uoted A*,methodologies" An emission calculation software isavailable from the % *A via their website.http#>>www"epa"gov. or on a $9-:("%"*A.2I)" This $9 also contains the *A publication

("%"*A. 1JJI) and A*, documents (A*, 22K28)"4

The sentence about uncertainty ma!es no sense"'o +uality codes are provided in this chapter. socomparison with the uncertainties chapter is ratherdifficult"

*1 should be removed from the table andplaced under 'A or '"

,n the 4'ot Applicable4 list for Table 8-I. *1 isgiven" /owever.this is also shown in the Table as4'4" %hould it be listed.therefore. in the 4'ot

stimated4 listG

,n Table 8-I. the following pollutants should bedeleted from the4'ot Applicable4 list as F0s areprovided# *1. *b. $d. /g. As. $r" $u. 'i and Yn"



Accepted

'oted

Accepted 9one

'oted

Accepted Two new tables introduced

'oted

'oted

Accepted %tatement corrected

'oted

'oted

An emission factor of is clearly not acceptable.either there is an emission factor or the pollutantshould be listed as not applicable"

All Fs that are e+ual toHero removed. moved to'A or ' according toreporting template

The $: and ':$ emission factors are a factor1 lower from the reference chosen compared to

the other references in the e&isting guideboo!" Atleast a note e&plaining the comparatively lowvalues should be offered"

rase 8811 $ement (is included in <1 nergy)and erase (decarbonising) from 3612

$hapter contains scarce information necessary foremission inventory from cement production" Thereare I short tables with only * emission factors"$hapter should be supplemented and updated"

*roposals# two Tier 2 tables applicable for $$Acountries were suggested for the uideboo!# for

wet and dry cement production with averagedlevels of abatement"

4This chapter only considers emission ofparticulate matter from cement plants. which ismainly the * from pre- and aftertreatment4" ,f thisis the case. where can we find the emission factorsof the pre- and aftertreatment processesG

For many of the pollutants listed in the mentionedlines the <F states that a significant contributioncomes from the materials processed"

,n this statement. the ammonia appears as animportant pollutant to be considered in the cementproduction but. in the rest of the document. theammonia does not appear and in the tables istreated li!e 4 not applicable 4"

%ubchapter 2"8 missions contains long list ofpollutants emitted during cement productions andprocesses are described but Tier 1 and Tier 2Tables 8-1-8-8 gives only particulate emissionfactors"

The te&t concerning emissions of %:B originating

from fuels or raw material can be misunderstood"



e7ected

e7ected

e7ected

e7ected

e7ected

'oted

e7ected

'oted

4and the algorithm in e+uation (8) reduces to#4 ditorial

'oted

'oted

rase 4For Tier 1 the emissions of ':&. $:.':$. %:&. heavy metals and *:*s can beassumed to be mainly due to the combustion ofthe solid and waste fuels and will be included inthe emission factors used for chapter 1"A"2"f"i" Toavoid double counting estimates should be madein the chapter 1"A"2"f"i" ,n the Tier 1 approach theywill. as far as they originate from the chemicalcomposition of the raw meal. be reported as 'otstimated"4

ove <(a)*. <(b)F. <(!)F. $:. 9,:B. /$<. ,ndeno.':$. ':B. %:&. from 'ot estimated to 'otapplicable

rase Tier 2 (is a copy of Tier 1) because itgenerates confusion

Tables 8-1-8-8# these tables include only 8emission factors each which are the same" Tier 2tables for wet and dry processes include the samefactors for different cement production processesand same with Tier 1 ] this is not true andcontradicts to Tier 2 approach determination"ewor!ing of F tables is necessary"

Tables 8-1-8-8# there are no emission factors forheavy metalsK it is shown that they are accountedin 1"A"2" <ut it is !nown that heavy metals areemitted with particles" %o it assumed that cement

particulate do not contains heavy metalsG And it isassumed that only particulate is abated whileheavy metals are emitted unabatedG

Table 8"1# F seem to be too high. if +uarry ise&cluded as presented in Figure 2-1

'o need to present the same default F in threetables# 8-1. 8-2 and 8-8

4The Tier 1 emission factors have been used in theTier 2 approach as well4" This sentences amountsto say that there is no Tier 2 approach for the wet!iln process5

+uation numbering

corrected4The feeding of dry material into the !iln willhowever typically result in higher emissions of dustas compared to the wet !iln process4"

4 ""the Tier 2 emission factors for the dry !ilnprocess in Table 8-8 are the same as the Tier 1default emission factors presented in Table 8-14"This sentences amounts to say that there is no Tier2 approach for the dry !iln process5



'oted9elete 4from4 ditorial

Accepted

'oted

Accepted

Chere is the e+uation (8) in the documentG Accepted

'oted

'oted

Accepted '/8 in ' instead of 'A

'oted

'oted

Accepted

9escriptions of algorithms occupy 2 pages whileonly 8 factors availableK what is the usefulness ofthese algorithmsG

Table 3-1# /ow does this table correspond totables 8-2@ - 8-81 (1A2)G *resent thecorrespondance between the different units

%implest correspondanceincluded plus a reference

to the <F if moredetailed information isre+uested

eferences contain only 3 sources including 2<Fs# it is too short"

The indication ,"" for the pollutants present also in$ombustion activities is ambiguousK it0s not clear ifthere are part of process emissions evaluated incombustion or if there are combustion emissions

,ndication removed fromall chaptersK now in '

+uation numberingcorrected

Ce consider that this is a very serious drawbac!for process emission estimation in this sector (!eysource for many pollutants as heavy metals fromthe very !ilned raw materials (whose emissionfactors do not appear at all))

for many of the pollutants listed in the mentionedlines the <F states that a significant contributioncomes from the materials processed"

,t is considered that the ammonia in not animportant pollutant to be considered in the cementproductionG

Ce consider that this is a very serious drawbac!for process emission estimation in this sector (!eysource for many pollutants as heavy metals fromthe very !ilned raw materials (whose emissionfactors do not appear at all))

%o the +uestion arises# where are you allocatingthese emissions and what are the correspondingemission factors. if their emissions have not beencomputed in the combustion activity (1"A"2"f"i). andthere is not information on them in this processactvityG

The proposed F are very high compared with

<F use T%* from <F and estimate fractionof *1 and *2.I

eplaced with <Ffactors

,t is assumed that heavy metals are mainly due tofuel combustion so they are accounted in 1"A"2"f"i"%o it supposed that lime particulate do not containsheavy metalsG And abatement affects particulateand not affects heavy metalsG




'oted

Accepted 9one

e7ected

Accepted

Accepted Added to chapter

'oted

'oted

'oted

'oted

'oted

ditorial 9one

ditorial 9one

ound the Fs value" Ammonia lower value N .6 Accepted 9one

Accepted $orrected

Accepted $orrected9elete# no clear. no necessary e7ected

Accepted 9one

Table 8"1# F seem to be too high. if +uarry ise&cluded as presented in Figure 2-1

9elete# Fs very oldK substitute with controlled > nocontrolled T%* from <F and estimate fraction of*1 and *2.I

$hapter contains mainly headings. algorithms and

table without emission factors" ,t should besupplemented"

%ome headings removedto ma!e more readable

'evertheless a decision tree is possible# Forermany we have the +uestion clarified whetherinformation from sectors limestone used areavailable" Cith 4Ues4 li!e in ermany allcalculations are made in sectorspecific chapters.so 2"A"8 shows only 4,4" Cith 4'o4 an estimationunder 2"A"8 is necessary" ,n ermany we havemade for verification a limestone balance with thefull set of production and use and so identified

gaps. which were closed in different sectors"

9ecision tree and somete&t on this issue added to

chapter ,t is not mentioned that heating emission is ta!eninto consideration in 1"A"2"c"

%ee comments to german limestone balancebefore"




11 subchapters of the chapter consist only of

heading and comment# 'o specific issues" aybeit will be better not to show this chapter at thisstage at allG

%ome of the multipleheadings removed

$orrect the mentioned <F and write 4L isavailable in the <F 4arge volume inorganicchemicals - solids and others (uropean$ommission. 2@)

$orrect the word 4<oudart reaction4 into4<oudouard reaction4

Table 8-1# emission factors are with 6 digits after

point ] it is too much"table 8-1# the emission for '/8 given in the <Fis "6-1"I (,$-%A:. chapter 2"8"8"I)

The <F documents don0t present emission limitvalues. but <AT-associated emission levels (<AT-

As) - delete the sentence 4This section providesemission limit values (s) as defined in the<F document4



Accepted

'oted

Accepted $orrected to 8"$

Accepted

Accepted

Accepted

Accepted 9one

Accepted 9one

Accepted 9one

Accepted

Accepted $orrected

$an0t find the cieted value for '/8 in the <F -cite correct or delete value"

rror - value should nothave appeared here"emoved"

,nterpretation is correct as Asphalt oofingaterials

4"""with the e&ception of asphalt blowing. which is

inventoried separately under 'F source category1"A"2"f"i4"

Figure 2-1# The notation for /eat or Fuel and itsemission are missing"

Table 1-8# ostly the production data are includedin +uadrat m" , would recommend the inclusion offactor-information from this. as well"

9ecision tree is proper for production only.emissions of application seem to be relevant are inermany calculated too" The decision tree has torefer to the complete number of application ofroofing materials"

The proposed Fs from old < are obsolete# thereare a new % *A chapter in A*32



The reference is obsolete new one is "%"nvironmental *rotection Agency ("%" *A).1JJI" 11"2 Asphalt oofing $ompilation of Air*ollutant mission Factors# %tationary *oint and

Area %ources" A*-32. Fifth dition" :ffice of Air=uality *lanning and %tandards. esearchTriangle *ar!. 'orth $arolina"

:ld reference replaced bynew one

This statement is not correct because asphaltblowing should be in 'F source category 8"$"



Accepted Added to figure"

ditorial $orrected

Accepted 9one

'oted

ditorial $orrected

Table 8-1 and 8-2 are e&changed e7ected

A production -activity rate for the lime production ditorial $orrected

ditorial $orrected

ditorial $orrected

'oted

'oted

The chapter is wrong5 The content can beappropriate for activity 8818 Asphalt $oncrete*lants (that was e&pired from new <). but F andreference are old. a new A*32 chapter wasproduced" The chapter following my interpretationrefers to asphalt application on road5 and concern:$ emissions (see % *A A*32 chapter 3"I)"


%ome information from8818 used as well"There appears to beoverlap between the two

chapters in the previousuideboo! and also the*A reference given in thiscomment"y best guess is that boththe i& Asphalt plants andthe asphalt application onroad should be ta!en intoaccount" $hapter hastherefore not beensubse+uently updated"

Figure 2-2# /eat and its emission are missing fromthe chart"

/ere seems a mi&-up to be# reference to cementand lime are not useful"

The emissions factor indicates a mass rate ofabout 2. what is not usually. please see underFPcomments"

$hapter consists of mainly headings" ,t includesone table with 8 * emission factors (for all miningprocesses) which seem underestimated" ist ofeferences includes one source"

A - not lime production (page 8. row 11). but floorarea of the building construsted (page 3. row 8 orp"8 row 21)

A - the activity rate for the storage. handling andtransport

,n lossary table - A production -activity rate forthe lime productionThe right definition as on thepage 3. row 1I

This chapter includes 6 sources. I connected withglass production# Flat lass. $ontainer lass.lass Cool. :ther lass. lass (decarboniHing)"Chy they were not included in a separate chapterlass production li!e imestone and 9olomiteta!ing into account contribution into heavy metalsemissionG

*lease. ma!e sure to use the most up-to-datesources for technical information and emissionfactors



'oted

Accepted 9one

Accepted 9one

Accepted

'oted

Accepted

'oted

'oted

'oted

ditorial $orrected

:$ emissions see *A A*32 'oted

According to a not yet published research pro7ecton emission factors of the german glass andmineral wool industry. 8I cullet is used in the flatglass production

*lease. provide updated information on preheating

or remove the word currently in line @ since thesource is 11 years old5

please. provide the source to table 2-2"Furthermore. 9, 2I@? on the emission control inglass wor!s provides more detailed information onthe energy demand of carious glass types andfurnaces

*lease. provide updated information on soda limeglass manufacturing via electric heating or removethe word currently in line 8J since the source is 11years old5

Te&t updated for as far asnew information availableKold information removed

About ? pages of the chapter are devoted toreduction measures for ':& and %:2K this is notbalanced with other chapters especially ta!ing intoconsideration that gases are not accounted in2"A"@"d chapter"

*lease. update the information on fuel staging inermany

:bvious outdatedinformation removed. noupdated informationavailable

*lease. update the information on ow-':& inermany


*lease. update the information on :&yfuel-usingfurnaces" ,n western urope T-glass is notproduced anymore and could therefore be deletedfrom the listing e&pect for the case that theproducing plants in eastern urope are using:&yfuel"


*lease. update the information on %$" There isno T-glass production ermany anymore"Therefore. remove the listing in line I


A production -activity rate for the lime production.

not correctedwould be glass production (page 22.row 2 or I)



Accepted All corrected

'oted

'oted

'oted

e7ected

'oted

'oted

Tables 8-11-8-12# errors (not lime production)" ditorial $orrected

,n all tables *A/ by substance included into row4not estimate4and to row 4not applicable4 as *A/,twould be more correct if Tier tables in all chaptershave been madein identical format (se+uence ofrows)#'F%'A* (ifapplicable)Fuel*ollutantsTechnologies (for Tier 2-

8)egion (for Tier 2-8)Abatement technologies (forTier 2-8)''A

The heavy metal F refer to the uideboo! (26)- some in general and some to Doc!el (21)"/owever. for lead crystal glass the general F isused instead of F for special glass (e"g" leadcrystal)G

/ Fs removed wherenot applicable

Tables 8-2 to 8-1 contain emission factors whichseem to be too high (by appro&imately factor 1and more) according to the preliminary final reportof a research pro7ect on emission factors of theerman glass und mineral f ibre industry" Thereport is e&pected to be published in ay 2?"%ome e&amples are listed in the F-commentsspread sheet" They refer to the year 2I and sumup energy- and production-related emissions"

Tables 8-2. 8-8 (Tier 2)# * and / F for Flatglass and $ontainer glass are the same# this is nottrue because technologies are different"

Tables 8-2 to 8-1 contain emission factors forwhich the reference year is not mentioned" *lease.add this information" Furthermore. to our

!nowledge it is very common to use the metalclasses , to ,,," Therefore. they should be used inthe handboo! as well"

,t is stated that /eavy metal emission factors fromthe Tier 1 table for this source category are addedto the table in order to fill the gap ]methodologically this is not good because asdeclared Tier 2 is more sophisticated approachwhich provide more accurate estimatesK generallyTier 1 tables should originate from Tier 2"

Table 8-I# heavy metals emission factors are thesame as in Tier 1 Table 8-1 while T%* F isdifferent"



'oted

Accepted

ditorial $orrected

ditorial $orrected

isschedi7! (23) is missing in the eferences ditorial Added

'oted

'oted

'oted

'oted

spelling mista!e# correct 4gassified4 into 4gasified4 ditorial processed

Accepted processed

%ubchapter 8"8"2"I includes I tables (8-6 ] 8-1)with the same / F for different types of glass"This is not true# every type of glass has differentcontent of / thus emissions will be differentKdifferentiation is especially important for leadcrystal glass"

Tables 8-6 ] 8-1# uideboo! 26 as referencedin these tables does not contain such emissionfactors"

All chec!ed" Fs removedwhere not applicable"

,n the tables 8-11. 12 (glass production) the 'Fcode is 2"A"2 - lime production. would be 2"A"@"d

lossary. A production - the A for the limeproductionGG

The %'A* for the organic chemical industry isabsolutely not adapted and not representative ofall productions of chemicals substances" The list ofproducts from %'A* 3I1 to 3I26 is notsufficient" The problem is also li!ed to the fact thatproducts accounted under different %'A* code.are produced by the same process (ethylene andpropylene are the best e&ample)

The problem of carrying our emission inventoriesfor the organic chemical industry is related to thedecrease in the availability in statistics" ost of theproduction of products considered in the %'A* arenot available in current national statistics"

the first %'A* 3I1 and 3I2 represent thesame process. the steam crac!er" %ee thedescription in the T, document as e&ample"


%'A* 3I2I and %'A* 3I26 should note&ist" There are redundant with %'A* 686 ifthis one becomes speciality organic chemicalindustry

%'A* 3622 should also related to the specialityorganic chemistry

Figure 2-3# *lease correct 4Adsorption4 into4Absorption4



footnote I is not e&isting below ditorial not foundcorrect reference to the <F is missing Accepted processed

e7ected

ditorial processed ,$ AAF

ditorial processed

ditorial processed

ditorial not found

ditorial processed

Accepted *rocessed

e7ected

e7ected procesed

e7ected

e7ected

e7ected

Ammonia Tier1# , don0t found correspondence with+uoted <F values

table 8-1. column 4reference4# what does $ A$Fmean# define reference (*robably you mean the

<F 4arge olume ,norganic $hemicals - Ammonia. Acids and Fertilisers4 (,$ - AAF)9ecember 26G)

the paragraph mentions only two primary sourcesof pollutants. but in the table 8-1 below you findthree pollutants

spelling mista!e# correct 4Tier 2 ort Tier 84 into4Tier 2 or Tier 84

put in a space between 4tier 14 and 4 emissionfactors4

write 4Tier4 always in the same spelling# either witha capital (see line 1 to I on the same page) or in

lower cases"

'itric Acid Tier1# ,t0s better to use <F averagevalue# 1"

Adipic Acid Tier 1#Chy no values when can befound in % *A A*3IG

table 8-3# the upper and lower value can not befound in the refered <F" Table @"1 of ,$ %A:shows the emission factors for different abatementtechnology you refer to as tier 2 (s" table 8-16)

table 8-I# delete table 8-I. because of to manyvery different production processes in 2 < I

Table 8-IK delete this tableK it is impossible tocreate a emission factor for the whole chemicalindustry

Ammonia Tier2# se ,**$ <F value andintroduce also Tables for controlled process from,**$ <F



Accepted processed

Accepted processed

e7ected

Accepted *rocessed

Accepted processed

Accepted processed

Accepted processed

e7ected

ditorial processed

Accepted prcocessed

'oted

Accepted processed

Ammonium 'itrate Fs from % *A A*3I Accepted processed

table 8-6# the conventional as well as advancedprocesses are not abatement technologies. butprocess technologies - e&pand the te&t in line 2.column 6 with the te&t from line ?. column 2 anddelete the te&t in ine ?. column 2

table 8-6# the reference of the values given here is

the guideboo! 26 - but there are no datas5 Thereference for ':& ($:G) seems to be ,$ AAF.table 2"@G 9efine the reference of the data

Ammonia Tier2# ,ntroduce also Tables forcontrolled process from ,**$ <F

'itric Acid# erase table 8-?. for unspecified processuse Tier 1

table 8-1# please define why the value is belowthe range

table 8-18# only the value of I refers to Frenchand erman plants. the range of 1-1 refersto % plants - define how to use value and range(why is the range lower than the valueG)

table 8-1I# referring to the guideboo! 26 thedata for the e&tended absorption does also applyfor medium and high pressure processes - add inline 6>column 2 medium and high pressureprocesses

Adipic Acid Tier 2#Chy no emission when valuescan be found in % *A A*3IG

table 8-1?# line 6. column 2# change 4withusage4

into 4with usage 4

the %'A* classification 388 belongs to thegroup of metallproduction and not to the chemicalprocesses - 2<Ia doesn0t include either thesilicium production nor synthetic amorphes silicaand silicates - please chec! this issue"

,n the last line you write. that T%* has not beenestimated - but in line 11 you have a value for T%*- please chec!

table 8-21# line J says that decomposition plantsare included - but table 8-22 is covering the

decomposition plants" $hange 4,ncluding4 into e"g"4without 9ecomposition plants4



Accepted *rocessed

'*; fertiliser# '/8 old $orinair F e7ected *rocessed

'otedrea# *. *1. *2.I from % *A A*3I Accepted processed

'oted

Accepted processed

Accepted processed

$hlorine production# se <F values Accepted processedTable 8-86# emission factor for $d is missed" 'oted

Ammonium %ulphate# '/8 value from old $orinairreferences. $: from conomopoulos. J8. *from *A

There are not emission factors for '*; fertilisers

production"

,n this lines the dimension unites for T%* and '/8are in the range of !g>t. but while using the samenumerical value you have in table 8-2? thedimension unit g>t" *lease chec! thedimensions>values"

table 8-2J# The <F ,$-%A: is cited incorrect(s" also &cel sheet 4FP$omments4" , alsocouldn0t find in the <F emission values for*1 and *2.I" *lease cite accurately"

$hlorine production" Table 8-88 Tier 2# /gemission is shown as ' ] it need to be estimatedta!ing into account contribution of $hlorineproduction by this method into mercury emissions"



Accepted

'oted

Accepted processed

Accepted accepted*olyethylene# use <F values 'oted

'aphtha is not the uni+ue feedstoc! in urope forsteam crac!ing"

Added note on otherfeedstoc!s

The list of products provided is not complete"*lease provide all possible products to avoiddouble counting by not specialists"

,n France in 2I the emission is different as thevolumes produced are different" The emissionfactors provided for ethylene and propylene are thecorrect one to represent the emissions of thesteam crac!ers if we are able to allocate theemissions of the steam crac!er in all the differenttypes of products manufactured by this process" ,nthe 'etherlands ethylene and propylene representonly 3J of the total products coming from thesteam crac!ers" Chat are the other productsG Addan e&planation to consider them in %'A* 3I2@ ifthe product is not considered in an other item ofthe %'A*" ,f you do not recommend to proceed asabove. the emissions of the steam crac!ers are notcorrectly estimated

Table 8-8@K <F :$# range from .8 to 6 !g>t

ethen and not .3 to 1 in table 8-8@"



e7ected

Accepted

e7ected

e7ected

e7ected

'oted*olystyrene. Crong reference# data from <F 'oted

'oted

e7ected

Accepted processed

Table 8-31K <F *olymers# range (9*) .@ to1.1 !g>t for new plants and 1.1 to 2.1 !g>t fore&isting plants and not 2 to 8 !g>t

The T, document on chemical industrypresents emissions from the suspension *$process developed with the industry organisation"The emission factors could be used"

processed. accepted for':$. T%* F0sunmodified

Table 8-32K <F *olymers# range (/9*) .8 to.I !g>t for new plants and .I to 1.? !g>t fore&isting plants and not 1 to 8 !g>t"

Table 8-38K <F *olymers# range 1? to 3I g>t %-*$ and not 1? to 1

Table 8-33K <F *olymers# range 1 to I g> t-*$ and not 1? to 1

Table 8-3IK in <F *olymers the emission factorfor ** is in the range of /9* (see above)

*olystyrene. Crong :$ F# correct <F value82

Table 8-3?K <AT for /,*% is about ?I g>t (<F*olymers)

Table 8-3J# <F *olymers# range (*%) .3I to.@ !g>t



e7ected

Accepted processed

'oted

'oted

Accepted processed

Accepted *rocessed

Accepted processed

Table 8-I6# The reference is wrong (<F :$) Accepted processed

Table 8-I@# the reference is wrong (<F :$) Accepted processedthylbenHene# F from <F G Accepted *rocessed

Table 8-61K *lease add :$ as reference e7ected

'oted

'oted'ot clear 'oted

Table 8-3@K <AT for **% is about ?I g>t (<F*olymers)

Table 8-I# <F *olymers# range (-%<) .1@to .8@ !g >t

%tyrene <utadiene ubber very lower :$ from<F (1@-I3)

thylene o&ide# wrong reference and incompletedata

<F :$# in the case of tratment by o&idationthe emissions are considered to be Hero

Formaldehyde# the reference was wrong <F butnot polymers

Table 8-II#<F :$ reportet emissions of

about .11 or 8 to I !g>t" The reference <F*olymers is wrong"

made a reference to the<F instead

Table 8-68# F for *:*s pesticides production isshown Hero" ,t is written that emissions of all thedifferent pesticides are assumed to be negliblecompared to product" <ut $hapter 2" *roduction of *:*s contain Fs for all *:*spesticides (1 !g>g product)"


As said before the %'A* 3I2@ has to becompleted to give e&amples" ,n France ase&ample. all chemical production which can not beclassified in the previous %'A* are put under this%'A* 4other4 and their emissions represent alarge amount of total emissions of the organicchemical industry (8 at least)

,s this chapter usefulG 'othing is given to try toestimate the amount of organic chemical productsstored per t of production" There are no statisticson the +uantity of organic chemicals stored" A wayto estimate them should be useful"



Accepted processed

Accepted processed

Accepted processed

Accepted processed

Accepted processed

Accepted processed

Accepted processed

'oted

e7ected

e7ected

<AT emission factor for -%<# .1@ to .8@ !g>t Accepted processed

Accepted processed

table 3-1# the <AT-associated emission valuereferred to the <F ,$-AAF is not for '/8 butfor ':& - write 4':&4 instead of '/8K pleasedefine also the reference (,$-AAF)

table 3-2# the <AT-associated emission valuereferred to the <F ,$-AAF is not for '/8 but

for ':& - write 4':&4 instead of '/8

title of the table# the F given apply not only forconventional reforming processes. but also forreduced primary reforming - add reduced primaryreforming processes (,$-AAF. table 2"18)

table 3-3# instead of 4%:24 write 4%:& as %:24 (s"reference and te&t above)

tab" 3-6 (/eading)# table 3-6 refers to the sulfateprocess and not the chloride process - correctheading into 4sulfate process4

The given <AT value for %:2 is not only for drying

but for the total emission level to air (s" ,$-%A:.$hapter 8"I"1. 'o" 13)" Therefore add the data totable 3-I

The given <AT value for %:2 is not only for dryingbut for the total emission level to air (s" ,$-%A:.$hapter 8"I"2. 'o" 1?)" Therefore add the data totable 3-6

<AT emission factor for %-*$# 1? to 3I g>t and -*$# 1 to I g>t

<AT emission factor for 9*# .@ to 1.1 !g>t fornew plants and 1.1 to 2.1 !g>t for e&isting plants K<AT emission factor for /9*# .8 to .I !g>t fornew plants and .I to 1.? !g>t for e&isting plants

<AT emission factor for **%# ?I g>tK /,*%# ?I g>t

and *%# .3I to .@ !g>t

eferences# *lease add# ,**$ <F *olymers -,**$ eference 9ocument on <est AvailableTechni+ues - *olymers. :ctober 26



'oted

'oted

Accepted 9one

Accepted 9one

Figure 2-8# &planation for the blue arrow missing Accepted

Figure 2-3# &planation missing for the blue arrow Accepted

Accepted $orrected

Accepted $orrected

ditorial $orrectedTypo in the middle of the line" $orrectly# agents" ditorial $orrected

Accepted $hec!ed and corrected

ditorial $orrected

Accepted $orrected

Accepted $orrected

ditorial $orrected'o legend provided for formuila" %ee row 1" Accepted egend added

e7ected $orrected

'oted

tab 8-1 'F %ource cat" %hould be 2"$"1 not 2"A"1 ditorial $orrected

%ubdivide %inter from pellets as in ,**$ <F Accepted

&cept in some country where the industry is notpresent. the chemical industry is often a largeemitter of pollutants

all tables# use units consistently (g. t. ton# e"g" intable 8-1 you use !g>t. in table 8-2 you use g>g. intable 8-I you use !g>ton


$hapter describes all processes in ferrous metalsindustry thus very complicated and difficult forusage"

Figure 2-1# 'otatin for blast furnace gas missing",nstead of coal in7ection , recommend co!e ornatural gas in7ection"

Figure 2-2# The 4metallurgical co!e4in the top leftarrow is incorrect" $orrectly# 4$o!ing coal"4

ore info provided incaption

ore info provided incaption

4"""au&iliary reducing agent4 should be amendedwith 4and as a fuelL4

4,t leavesL4 should be replaced with# 4,t and otherfuels leavesL4

etter missing at the beginning of the line"$orrectly# Top of the L

$ontradictions# /ere 1"J is mentioned. but onpage @>1? it says# 4L be reduced less than 14

,n section 2"2"3" the order# <:F. :/F. AF. while inthe others it is# :/F. </F. AF" The letter is

preferred"The agent for reheating is not mentioned in thedescription. e"g" co!e oven gas"

The heavy metal content of furnace gas is notmentioned" Table 8-13 (8>18) does include it"

4L sulfurdio&ideL4 should be written as sulfurdio&id"

As there are iron steel installations that haveonly some plant (for e&ample no co!e productionor no sinter and so on) it0s not possible to have a

set of overall emission factorsK please use also forTier 1 the subdivision used for Tier 2"

Table 8-1# emission factor for chromium isoverestimated"

*ellets added as separateTier 2 using Fs from<F



e7ected

Accepted

Accepted Fs added

Accepted


e7ected


e7ected

Accepted $orrections in units made

e7ected

e7ected



$onvert the data in g>!g sinter using appropriatechange factor to compare with 4state of the art4Fs

%ubchapter 8"8"2"1# for sinter production it appearsthat effect of different systems of control ontoheavy metals is different depending on metal and

for some of them more advanced system leads toincrease of emissions"

spreme factors chec!ed"

%ome inconsistenciesremain however"

Chy are the Fs of T%*. *1 and *2"I notestimated in the tables 8"8. 8"3. 8"I and 8"6 G

,n table 8"2 the F of *b is .I g>g sinter product.while the Fs in the tables 8"8.8"3 and 8"I arehigher" ,s that correct G

spreme factors chec!ed"%ome inconsistenciesremain however"


$onvert the data in g>!g sinter using appropriate

change factor to compare with 4state of the art4Fs



Tables 8-8-8-6# because Table 8-2 is also namedTier 2 these tables might be considered as Tier 8"

<ut they includes only heavy metals and *:*s ]no *K error in units (should be sinterM instead ofpig ironMK should be [g T=>gM instead of [g>g)K %'A* code is shown as 881 while inTable 8-1 as 32J. e&cept 881" Tables arenot harmoniHed with Tables 8-1 and 8-2# thus inthe Table 8-8 ($ontrolled by wF9) ] emissionfactors for $r. 'i. *b and *$99>F more high thanin the Table 8-2 while for *$< ] lower 2 timesKdio&ins are the same in all tables"







Accepted Tables removed

Accepted

'oted

Accepted $orrectednit *1 and *2"I not correct Accepted $orrected

Accepted

'oted

Accepted Table corrected

Accepted Tables included

Accepted

'oted

'oted

rase Table 8-? and Table 8-J# are in contrast withTable 8-@

* emission factors are very high if compared with<F data (a factor 1)5 <F F must be ta!eninto account"

Factors replaced with<F values"

/eavy metals emission factors in the Table 8-@ are

generally underestimated especially for $d. *b.Yn. but for $r they are overestimated (ta!ing intoaccount properties of metals)"

Table 8-@# there are errors in unit for *1 and*2"I"

Table 8-@ provides F for pig iron production. forthe whole process starting from the charging of theblast furnace to the tapping of pig iron" Table 8-?and Table 8-J provide F for the charging andtapping individually" <ut emission factors in thesetables are not harmoniHed"

Tables 8-? and 8-Jremoved because theygenerate confusion andare not complete andrather old anyway

rror in units in Tables 8-1-8-18 for *$99>F ]should be [g T=>gK tables do not contain *emission factorsK emission factors were ta!en from%* without analysis of applicabilityK theyloo! very low and probably contain systematicerror in units"

* Fs added"%* data chec!edfor errors"

Table 8-13# table should be revised# it is shownthat the table is for ncontrolled conditions but *emission factors are too low and lower than /emission factorsK / emission factors are partially

from uideboo! 26. and partially ] from$*,* so overall table is heterogeneous andnot reliableK error in units ] should be steelM"

*roposals#Tier 2 emission factors table issuggested applicable for $$A countries fortypical levels of dust abatement (JI-J6)"

<asic :&ygen Furnace# ':& and $: occurs fromo&idation process (see <F for description ofprocess and Fs)# T/% ,%%,:' %T <,'$99 A% T/U A ':T 4$:<%T,:'4,%%,:'% (': F :'U :BU')

':& and $: Fs added totable

Table 8-1I# / emission factors loo!underestimated"

,t is shown that ost emission factors are ta!enfrom the <F document for <est AvailableTechnologies in the ,ron and %teel ,ndustry(uropean $ommission. 21) but this reduceapplicability of emission factors"



e7ected

Accepted nit corrected"

Accepted


Tables 8-1] 8-21# error in units ] should be steelM" Accepted $orrected

Accepted


Accepted

Accepted ,nserted as separate Tier 2

'oted

Accepted

'oted

lectric Furnace %teel *lant# ':& and $: occursonly in small portion due to adding of coal in scrabas input to electric furnace (see <F fordescription of process and Fs)# , T/,'; A%:T/% ,%%,:' %T < ,'$99. T/U

A :'U ,' ,,T9 =A'T,TU

4$:<%T,:'4 ,%%,:'%Table 8-16# error in units for benHo(a)pyrene" T%*emission factor is underestimated"

Table 8-1?# emission factor for lead is higher thanin the Table 8-1I (typical conditions)"


*roposals# tier 2 emission factors table aresuggested applicable for $$A countries fortypical levels of dust abatement (J@"I)"

Tables 8-1J-8-21# error in unit ] should be steelMKunits for *$99>F should be chec!ed" /eavymetals emission factors among tables were notharmoniHed# thus F for lectric Arc Furnaces withbag filter (Table 8-2) are higher than with %*(Table 8-1J)"

*$99>F emission factorcorrected" spremefactors chec!ed. but someinconsistencies remain"

*roposals# tier 2 emission factors table issuggested applicable for $$A countries fortypical levels of dust abatement (bag filter. aboutJJ)

, propose to erase all this old materials# it0s notT,8

All this old informationremoved

8"3"2"I olling mills" This activity must be in Tier 2with <F Fs

,tMs not clear why some pollutants are in 41"<"2",ndustrial *rocesses4 section and not in 41"<"1"nergy4 section while are combustion related" Fore&ample in sinter plant the F for sinter plant inTable 8"2 is fuel related as e&plained in +uotedreference (4The combustion process is nothomogenous and is incomplete. resulting insignificant +uantities of polycyclic aromatic

hydrocarbons (*A/s) being produced"4)",n the Tables erase the row relative to ':&. $:.':$ and %:& and put these pollutants in thebo& 4'ot applicable4 in conformity with otherchapters

/armoniHed witheporting Template

$hapter consists mainly of headings" ,t includesone table with one emission factor# this is notenough for inventory of emissions from this sector"



Ferroalloys production# use * Fs from <F Accepted

Accepted

,n the list of main pollutants *A/ are not included" Accepted

'oted

Accepted

Accepted Added to tables

'oted

'oted

Accepted

Accepted Added

Accepted

'oted $orrected

The notation !eys given in Table 8-1 for Total *A/(') do not correspond to the notation !eys givenfor the *A/s included in *A/-3 ('A)"



Table 8-1# no F for dio&ins>furansK no F for *A/e&cept benso(a)pyrene"



%:&. ':& and :$ comes from process and arenot evaluated elsewhere" ,nsert F here from ,**$<F" %ee <F for details of the processemissions description"

Tables 8-1. 8-2. 8-8# benHo(a)pyrene F are thesame for Tier 1 and Tier 2 for both technologies ofprimary aluminium production# this is not so"

Tables 8-1. 8-2 and 8-8 include $: emission factor

while other gases are estimated in the chapter1"A"2

The F given for benHo(a)pyrene is not valid forthe *re<a!e-process"

F removed. other Fs('etherlands contributionfor *:*s) used instead

,n the <F-document %:2 and ':&emissionfactors (from sulfur and nitrogen in theanodes) are given" These emission factors mightbe useful for estimating emissions using higherTier than Tier 1"

The notation !eys given in Table 8-2 for Total *A/

(') do not correspond to the notation !eys givenfor the *A/s included in *A/-3 ('A)"


Tables 8-2. 8-8 and 8-3# * emission factorsshown the same for primary (both technologies)and secondary aluminium production" This is notso"



Accepted

Accepted Added

'oted

Accepted $orrected

Accepted $orrected


Accepted

Accepted

'oted

'oted

Accepted



,n the <F-document %:2 and ':&emissionfactors (from sulfur and nitrogen in the

anodes) are given" These emission factors mightbe useful for estimating emissions using higherTier than Tier 1"

Table 8-3# no F for dio&ins>furans (important forsecondary aluminium)K no F for *A/"

tab 8-3 'F %ource cat" %hould be 2"$"8 not 2"$"1also in tab 8-8

The legend for Table 3-8 refers to emission factorsfor primary aluminium production" ,n row four in thetable it says 4%econdary aluminium"""""4

*roposals# tier 2 emission factor tables aresuggested for primary (limited control andadvanced control) and secondary copperproduction in $$A based upon average valuesof unabated dust emissions. emission controllevels and content of metals in dust"

,t is shown that emissions from secondary copperproduction are considered in the $hapter 1"A"2"b"<ut Table 8-8 proposes F for secondary copperproduction. Tier 1 (Table 8-1) emission factors arefor all copper"

%entence removed. notapplicable here5

4The emissions from the production of secondarycopper are due to energy use only and thereforetreated in the combustion chapter 1"A"2"b4"


,n the sector 2"8 missions %:2 emission aremainly considered in spite of the fact that gaseousemissions are not estimated in this chapterKscarce information about * emission"

%ubchapter 8"2"2# methods of estimation of Tier 1emission factors are not described and in generalcommon table for primary and secondary copperloo!s artificial"

Table 8-1# error in unit (aluminium is shown)Kemission factors for heavy metals seemunderestimated especially for *bK no emissionfactor for YnK no emission factor for copper whilecopper production is the main source of copperemissionK emission factor for *$99>F loo!soverestimated"

nit corrected" $u Fadded"



Accepted $orrected

e7ected

'oted

Accepted $orrected

Accepted $orrected

Accepted

Accepted $orrected

Accepted $orrected

Accepted $orrected

%ame comment for tables 8-2 and 8-8" 'oted

Accepted /armoniHed

'oted

Accepted $orrected

Accepted /armoniHed

Accepted /armoniHed

Accepted $orrected

The emission factors are e&pressed in terms ofmass of pollutant per mass of aluminiumproduced" *lease ta!e into account that the activityconsidered is copper production"

%:&. ':& and :$ comes from process and arenot evaluated elsewhere" ,nsert F here from ,**$

<F" %ee <F for details of the processemissions description"

$hapter not contains technologically specificemission factors as necessary# only tables forprimary and secondary copper with the sameerrors (see comment to the table 8-1)"

Table 8-2# error in title# not Tier 1. but it is Tier 2Krror in unit (aluminium is shown)K no F for Ynand $u"

The title of the table 8-2 refers to Tier 1 when it

should be Tier 2"Table 8-8# error in unit (not aluminiumM)K no F forYn and $u"

nit corrected" F for $uadded. for Yn noinformation available"

Carning# the emission factor value considered for*b matches with one of the JI confidenceinterval value. is this correctG

The JI confidence interval for $r in Table 8-1 is-. but the emission factor proposed is 16 g>galuminium"

The title of the table 8"8 refers to Tier 1 when itshould be Tier 2"

,n Table 8-1. emission factors for As. $d. $r. /g. 'iand *b do not coincide with the values thatappears in the indicated reference (%*)"

The *%T. *1 and *2"I emissions factors thatappears in Table 8-2 for Tier 2 are the same thatappears in Table 8-1 for Tier 1"

The JI confidence interval for $r in Table 8-2 is-. but the emission factor proposed is 21 g>galuminium"

,n Table 8-8. emission factors for As. $d. 'i and *b

do not match with the values that appears in theindicated reference (%*)"

,n Table 8-2. emission factors for As. $d. $r. 'iand *b do not match with the values that appearsin the indicated reference (%*)"

9io&ins and furans are indicated as not estimatedbut there is an emission factor proposed in Table8-1"



'oted

Accepted $orrected

'oted

Accepted $u F added

Accepted $orrected

'oted

Accepted $orrected

'oted

e7ected

'oted

e7ected

,n Table 8-1. for %:&. ':&. ':$ and $:.emissions are indicated as estimated elsewhere"Chere are these emissions estimatedG ,n the caseof %:&. are not process emissions (other thanthose related to the fuel consumption) that should

be computed in this $hapter 2$IaG

This statement does not match with the presenceof the table 8-8. which presents emissions factorsfor secondary copper production"

%ame comment for subse+uent tables in this$hapter"

,n addition. as a big surprise. there is no $uemission factor for the very copper production.although there are emission factors for other heavymetals"

*$< is indicated as not applicable but there is an

emission factor proposed in the Table 8-1"eneral comment# chapter should be substantiallyrewor!ed" 'ecessity and methods of aggregationof primary and secondary lead production shouldbe discussed"

$hapter should be edited# 0ime production0 (*"I).0$ement production0 (*"I). 4$ement industry4 (*"3).0*roduction of cement0 (*"6). 0Yinc production0 (*"2).0$opper plants4 (*"1?) et" al" are not consideredhere"

Table 8-1# / emission factors areunderestimatedK no F for HincK principals of Tier 1

F calculation should be discussed"%:& and ':& comes from process and are notevaluated elsewhere" ,nsert F here from ,**$<F" %ee <F for details of the processemissions description"

Table 8-2# there are no differences with Tier 1 tablefor *. but large differences for /"

Tier 2 Tables 8-2 ] 8-1# emission factors in thetables were not harmoniHed. i"e relations betweendust and / were not accounted (/ emissionfactors canMt be higher than *K abatement affects* similar way as most /" Applicability of

proposed emission factors is limited because nogeographical indications are given for technologiesdistribution"

Te&t in section added to

ma!e it more clear that *factors are generic. notspecific for the technology




Accepted

'oted

Table 8-6# the same comment as for Table 8-I" 'oted

'oted

'oted

'oted

'oted

'oted

Accepted

*roposals# two Tier 2 emission factors for primarylead tables were prepared applicable for $$A#first ] for low level of abatement (about J?) andsecond ] for high level (OJJ)":ne emissionfactors table was prepared for secondary leadproduction (abatement WJJ)"

Table 8-8# not understandable# if it is a <AT tablewhy F for / are higher than in the Table 8-2(Typical abatement)K lead emission factor is higherthan for T%*"

All %* factorschec!ed again for errors

Table 8-I# F for T%* is the same as in the Table8-8 (<AT). but for / emission factors aresignificantly lower than in Table 8-8" ead emissionfactor is underestimated"

Te&t in section added toma!e it more clear that *factors are generic. notspecific for the technology

Te&t in section added to

ma!e it more clear that *factors are generic. notspecific for the technology

Table 8-@ (secondary lead)# * F is the same asin the Table 8-2 (primary lead) and in the Table 8-1(Tier 1)" * emission factors are underestimated"*$< and *$99>F emission factors ] errors inunits"


Table 8-?# / emission factors are higher for <AT

than for typical abatement (Table 8-@)"

Te&t in section added toma!e it more clear that *factors are generic. not

specific for the technology

Tables 8-? - 8-1# * emission factors are thesame for different technologies but / emissionfactors are different" 9ependence of / emissionfactors from abatement is not understandable"


Table 8-J# / emission factors are higher for %*than for typical abatement (Table 8-@)"


*roposals# chapter should be significantlysupplemented and rewor!ed" Tier 2 region-specificand technology-specific tables are necessary"

,t is shown that only primary Hinc emissions areconsidered but emission factors also for secondaryare included in the tables 8-I-8-?"



Accepted %entence removed

e7ected

'oted

Accepted

'oted

Accepted $$A tables included"

Accepted

Accepted

Accepted

'oted

,t is written. that missions from nic!el productionare not significant. since the contribution to thetotal national emissions is thought to beinsignificant. i"e" less than 1 of the nationalemissions of any pollutantM" ,t is not right# inussian Federation according to rough estimates

about 1 mln" tons of %:2 are emitted annuallyfrom nic!el production ] about 2 of nationaltotal"

%:&. $:. :$ and ':& comes from process andare not evaluated elsewhere" ,nsert %:& and $:F here from ,**$ <F" %ee <F for details ofthe process emissions description"

%:& included in thischapter

Table 8-1 (Tier 1) should be updated# it includesonly 2 emission factors# for T%* and 'i" Thesefactors if considered *-wide areunderestimated" 9uring nic!el production otherheavy metals are emitted"

,t is written. that 0missions of %:&. ':&. ':$and $: are due to the combustion activities andsubse+uently treated in source category 1"A"2"b0 "This is not so# in nic!el production from sulphidicore %:2 emission is not due to combustionactivities so should be treated in 2"$"I"c chapter"

%:& included in thischapter

eferences include only one source (,**$ <F)- it is not enough"

*roposals# chapter need to be substantionally

rewor!ed" Two Tier 2 emission factors Tables forprimary Hinc production by electrochemicaltechnology were prepared applicable for $$A#first ] for low level of abatement (about J) andsecond ] for high level (OJJ)" lectrochemicaltechnology is dominant in the $$A countriesHinc industry (more than J of total primary Hinc)"

,t is shown. that the most important pollutantsemitted from these processes are heavy metals(particularly Hinc) ] but there are no emissionfactors for Hinc in the Tables 8-1 ] 8-?"

Yn Fs added to eachtable

4This chapter only discusses primary Hincproduction" %econdary Hinc production causes only

emissions from combustion activities and istherefore treated in chapter 1"A"2"b4"


4The most important pollutants emitted from theseprocesses are heavy metals (particularly Hinc)4"


%ubchapter 2"3 $ontrols# no description ofabatement systems"



'oted nit errors corrected

Accepted $orrected

Accepted

'oted

'oted

Accepted

Accepted

Accepted

'oted

Accepted

Accepted

Accepted

Table 8-1 (Tier 1)# heavy metals emission factorsare significantly underestimatedK no F for $uK noF for Yn which is the main pollutant from HincproductionK F for *$< and *$99>F are dubious"rror in unit for *$99>F"

*$< is indicated as not applicable but there is an

emission factor proposed in the Table 8-1"

,t is written that This section provides technologyspecific emission factors for the two techni+ues Lthe electrochemical process and the thermalsmelting process but below there are nodescriptions of these technologies and no emissionfactors"

%entence removed. nospecific Fs for theseprocesses available5

,n Table 8-2. why are used the emission factors forTier 1 from %* li!e emission factors for Tier2G


Tables 8-2. 8-I# * emission factors for primary(Table 8-2) and secondary (Table 8-I) Hinc are thesame while technologies are different"

Tables 8-2-8-? Tier 2# tables were not harmoniHedwith Tier 1 table and with each otherK * emissionlevels do not correspond / emissions andsometimes lower than / emission factorsK noHinc emission factors"


Table 8-8 (<AT technologies table)# emissionfactors for $d and *b are higher than for typicalabatementK emission factor for $r appeared notincluded in Table 8-2"


,n Table 8-8. JI confidence interval values for$d. $r. /g and *b do not match with the valuesthat appears in the indicated reference(%*)"


Table 8-3# * emission factors are the same as inthe Table 8-8 but / emission factors are lower 3orders of magnitude"

,n Table 8-3. JI confidence interval values for$d. $r. /g and *b do not match with the valuesthat appears in the indicated reference(%*)"


Table 8-I# * emission factors are the same as forprimary Hinc which is not trueK / emission factorsare underestimatedK no Yn emission factor"


,n Table 8-I. JI confidence interval values for As. $d. /g and *b do not match with the valuesthat appears in the indicated reference(%*)"




Accepted

Accepted

Accepted

Accepted

Accepted $orrected

Accepted $orrected

Accepted

Accepted

Accepted $orrected

Accepted

'oted

'oted

Table 8-6# <AT technology. but / emissionfactors compared with typical abatement (Table 8-I) are 2-8 order of magnitude higher. * ] thesame. *$< and *$99>F ] lower"


,n Table 8-6. emission factors for As. $d. /g and

*b do not match with the values that appears inthe indicated reference (%*)"

spreme factors chec!ed"

%ome inconsistenciesremain however"

,n Table 8-@. JI confidence interval values for As. $d. $r. /g and *b do not match with thevalues that appears in the indicated reference(%*)"


,n Table 8-?. JI confidence interval values for As. $d. $r. /g and *b do not match with thevalues that appears in the indicated reference(%*)"


Table 8-J# abatement efficiencies for modern plant

is shown lower than for conventional installations"rror# not ead productionM but Yinc productionM"

The information that is showed in Table 8-J is forlead production. not for Hinc production"

,t is written that Tier 2 tables were compiled usingcountry data from Table 8-1" <ut data in Tier 2tables do not correspond to the data in the Table 8-1" ,t is not clear enough how Tier 2 tables wereobtained and for what countries data was used"egion-specific emission factors are necessary"

'ew Fs inserted from%*. they are nowused in all Tier 2"

,n Table 8-1. for %:&. ':&. ':$ and $:.emissions are indicated as estimated elsewhere"Chere are these emissions estimatedG %amecomment for subse+uent tables in this $hapter"

9io&ins and furans are indicated as not estimatedbut there is an emission factor proposed in Table8-1"

,n Table 8-1. emission factors for As. /g and *b donot match with the values that appears in theindicated reference (%*)"


This statement does not match with the presenceof the Tables 8-I. 8-6. 8-@ and 8-?. which presentsemissions factors for secondary Hinc production"

This statement does not match with the rest of thecapitule because there is no Yn emission factor"



'oted rror corrected

Accepted $orrected

eferences include only one source" 'oted

transport of 4cement4 is not correct Accepted $orrected

Accepted 9one

Accepted 9one

'otedT/ should be written as the" Accepted $orrectedusing annual national total cement productionG ditorial $orrected

A - national total cement productionGGG ditorial $orrected

Accepted $orrected

Accepted $orrected

Accepted $orrected

Accepted 9one

Accepted $orrected

'oted

'oted

Accepted

Accepted $orrected

$hapter consists of ? pages and one table Tier 1emission factors for source category 2"$"I"c 'ic!elproduction (probably error) with one emissionfactor (for T%*)" This is not enough for emissionestimation from :ther metals production" $haptershould be supplemented"

Table 8-1# the title and content of the table are notharmoniHed"

,nstead of 4LhardwoodL4 , recommend wood orcellulose-bearing materials

,nstead of 4LwoodL4 , would recommend 4woodor other cellulose-bearing materialsL4

,t is not described where ensillary fuel used inrecovery furnace (e"g" oil) should be ta!en intoconsideration" %ee also page @. lines I-6"

;raft process# the values for ':$ and %:B arewrongly copied from <F

Table 8-2. for T%*. *1. *2.I unit is !g>g coalproducedG

Acid sulphite process # the values for * arewrongly copied from <F

Table 8-1# , would recommend 4air dried pulp4instead of 4dried pulp4"

'eutral sulphite semi-chemical process# wrongreference (see the te&t)

%everal polutants are given in the F-tables to be'A" From %wedish e&periences there areemissions of metals. '/8 and also some *A/-3and dio&ins from the process (;raft and acid

sulphite) why the notation should be '"

eporting template nowused to automatically fill

'A and ' bo&es"Tables 8-@. 8-?. 8-J# !g> alcohol# whatconcentration of alcoholG

,t is unclear when Table @-J and when Table 2?-82should be used"

%ome descriptive te&tadded in beginning of Tier2 section

$a!es. biscuits and brea!fast cereals# wrong copyF from old <# verify



Accepted $orrected

Accepted $orrectedreplace !g>g meat etc with !g>g product Accepted 9one

'oted

'oted

'otedThere are no any references" 'oted

'otedCho is the e&pert for e&pert 7udgement 'oted

'oted

'oted

Accepted

,t0s not clear where leather finishing is included

Accepted

,n table 8-1J instead of %'A* 36I must be%'A* 362@ (meat"")

,n table 8-2 instead of %'A* 36I must be%'A* 362I (sugar)

Tables 8-2? to 8-22# !g>hl alcohol# what

concentration of alcoholG

$hapter should be significantly supplementedta!ing into consideration importance of *:*sproduction for total *:*s emission" 'ow it consistsof 8 pages and one table with similar emissionfactors for all *:*s which are not grounded"$hapter should also include production of *:*s-containing products li!e *$< transformers.capacitors. dyers etc" which is important forretrospective emission assessment"

Chat confidence can we give to this chapterG ery

poor at first view" This chapter has to be wor!edmore deeply" Chat is the definition of productsused in the table 8"1"

9ue to increase pressure on ember states forproviding emission inventories for *:*. the +ualityof this chapter is too low"

$hapter is based upon chapter lectricale+uipment with *$< from the uideboo! 26which was reduced" $hapter need to be

significantly supplemented and rewor!ed (maybewith division into a few chapters) to show overallpicture of consumption of *:*s and heavy metals"

Table 8-1# table should be revised - it is notreliable. for instance it shows emission factors 1!g>ton from consumption of heavy metals li!e $ror 'i which is not understandable"

This section is not very clear" Chat do you to say G04*harmaceutical products manufacturing (%'A*686)4 does not correspond to 4application ofcoatings during the manufacture of a number ofother industrial products4

*harmaceutical productsmanufacturing removedfrom this list


substitute 4for architectural or furnitureapplications4



'oted

Accepted

Accepted pdated

Accepted directive 23>32>$ ((9ecopaint directive4) Accepted 9irective addedthird column 1th row# 1I Acceptedthird column second row# @I Acceptedthird column third row# 3 Acceptedthird column fifth row# 3 Acceptedthird column si&th row# @I Acceptedthird column seventh row# 3I Acceptedthird column ?th row# 1I Accepted

third column Jth row# 3 Acceptedfourth column 1th row# 18 Acceptedfourth column Jth row# 8 Accepted

Accepted alues corrected

Accepted alues corrected

Accepted 9irective mentioned

Accepted Te&t added

,n the discussion of emissions there is noindication what happens with :$0s emitted fromcleaning e+uipemtn. brushes. guns. rollers. etc"9ilution is also mentioned marginally but it mightbe +uite important" ,t certainly should be clear ifthis is included or not" ,n case of emission factorslater shown from the model the model developersshould be as!ed if the factors include thesecomponents or refer only to solvent in paint"

, would suggest to apply an uniform emissionfactor of JI for open applications instead of1

These products are covered by the *roduct9irective 23>32>$ on the limitation of emissionsof volatile organic compounds due to the use oforganic solvents in certain paints and varnishesLChen T, document was done. the directive

was not yet implemented"The results of this are the %olvent missions9irective (1JJJ>18>$) and the *roduct 9irective(23>32>$)" This latter regulation will beL"

pdated" 9ecopaintdirective added to te&t"

%ome of the values table 2-2 are not correct" Theright ones are in Anne& ,, < of the 9ecopaintdirective (23>32>$)

:$ content limit values in table 2"2 have to bemodified according to the *roduct 9irectivementioned above

ention the %olvents missions 9irective1JJJ>18>$ for this sector

%olvent 9irective 1JJJ>18>$ mentions that#4coating activities which cannot be applied undercontained conditions (as shipbuilding. aircraftpainting) may be e&empted from emission limitvalues # the reduction scheme is then to be used.unless it is demonstrated that this option is nottechnically and economically feasible" ,n this case.the operator must demonstrate to the satisfactionof the competent authority that the <AT is beingused"




Accepted Te&t updated accordingly




Accepted

'oted


$ar repairing is regulated under the *roduct9irective 23>32>$ and was removed from the%olvent emissions 9irective 1JJJ>18>$

*lease +uote the regulations of the 9ecopaint

directive for $ar repairing (23>32>$. Anne& ,,<)"

:$ contents in paints used for car repairing areregulated by the *roduct 9irective 23>32>$ #only 1 phase which came into force in 2@ (seetable of :$ content in the 9irective)


,n the e+uation the activity rate refers to theapplication of paint while later in line 18 on page1I it says that national production data are used" ,thin! this is wrong. in time of multinationalconsortia producing vertain paints in few locationsand distributing them to many countries we cannotrely on production figures. not too mention stoc!schangins from year to year and e&ports outsideurope or imports" , thin! one needs to refer her tothe paint use and industrial associations need tobe consulted for this data" They do e&ist and areavailable for most countries. for the others onewouldhave to ma!e assessment based on percapita use of paint or something li!e that which ,thin! would still give better result than production

figures"

Te&t adapted. discussionshould be about paint

used%hould emission factor be distinguished accordingto the year # 1JJ. 2 and 21 (afterimplementation of the 9irective) # if yes. data areavailable from $*" $,T*A has this type ofinformation"



'oted

Accepted

Accepted $orrected9ecorative paints (618 V 613) e7ected

'oted


'oted

'oted

e7ected

e7ected

, would go for even more caution when suggestingas a default value a 2 average uropennumber" , thin! it could be better to refer todeveloped and developing coutnries and try to

develop two factors at least" Ce need toremember that there are very often historical orcultural differences. say how and from whatmaterials the houses are built. e"g" if onecompares %candinavia and editerraneancountries. the construction materials are sodifferent that the standard typical paint applicationsmust be different" , feel these things should bementioned" This type of information will be usefulalso for the Tier 1 approach" All that in spite of thatfact that , do agree that the JI conf"int doescover that largely"

,n the tables 8-1 to 8-8 the development of the Tier1 emission factors must be further e&plained"

9escription on how Tier 1

has been derived hasbeen updated

L" ember %tates to bring decorative or vehiclerefinishing paint products L""

%pecific F for 1JJ. 2 and 21 are availablefrom $* and have been used in A,'%

Again the issue of production versus use" *leasema!e sure this is consitent. while for cars. coatedarea. etc. it is o! for decorative paint is not the rightappraoch"

The sector 4industrial coating applications4 is verywide # %'A* codes should be precised

9onMt refer to abatement documents that preceedthe *roduct 9irective 23>32>$ from April 23"The actual abatement regulations in -2@ shouldbe from that publication onwards" The T, andA,'%>A,'% nomenclature used here is notapplicable for 9$:"

The sentence 4products containing I wt-solvent4 is not compatible with F replace with4products containing 2I wt- solvent4 or correctF

The sentence 4products containing I wt-solvent4 is not compatible with F replace with4products containing 2I wt- solvent4 or correctF



Accepted

e7ected

e7ected

Accepted $orrected

Accepted Added to the <AT section

Accepted

'oted

The F in not applicableK where we can found thedata m2 coated" The F in this form can be usefulto estimate the new paint technology penetrationbut non the emissions" F %T be e&pressed as

g>t of paint or g>t product" $onsideration abouttransfer efficiency of paint on ob7ect can be usefulto estimate future paint consumption but not foremission inventory" ventually maintain g>m2 foremissions but define default value for m2>t assurface painted for tonnes of products" This defaultvalues can be e&tracted from original F source"

ersion calculated in termsof g>!g paint applied"$onversion factormentioned in te&t"

The F is wrong55 The value is referred to g>m25 And for this is valid the previous comment# wherewe can found the data m2 coated" The F in thisform can be useful to estimate the new painttechnology penetration but non the emissions" Fmust be e&pressed as g>t of paint" $onsiderationabout transfer efficiency of paint on ob7ect can beuseful to estimate future paint consumption but notfor emission inventory"


rror corrected" F shouldbe g>m2 indeed

There is an emission factor of 2 !g>g foreather Finishing from <F that must be ta!eninto account5


, don0t thin! these are always 4abatement4. newtechnology>new products are often considered" ,t0sbetter produce Fs tables (non reductions) withtechnology>products and put them in section 8"8"2as in others chapters of <" , thin! the approach

must be uni+ue5The table is not applicable" At statistical level is not!nown the m2 of wood painted" Ce need Fs fortonne of paint"

For wire. area is not the relevant activity which isthe mass of wire coated

The <AT reference is only applicable to the decoproducts applied in a factory (installation)" Thema7ority of the volume in 9$:. however. is goinginto profeesional use (painters) and do-it-yourself"For that ma7ority (_@I) there is no accepted <AT"

$oating of agricultural and construction e+uipment#this falls in the industrial coating application (notthe decorative coating application)

oved to ,ndustrial coatingapplication

, thin! in this chapter should be describedmethodologies to ensure time consistency andrecalcualtion and not methodologies to generatetemporally resolved emission data sets

Te&t removedK doesindeed not belong here



Accepted

'oted

e7ected

'oted

'oted

'oted

'oted

'oted

Accepted F added

Chat is the meaning of time seriesG , believed thatit is about emission s changing from year to yearand so here the issues of changing emissionsfactors owing to technological change andlegislation might be touched upon" As is it is a verydifernt story" erify"


,t probably does not belong here as , thin! woodpreservation is a separate chapter and is not partof coating" %uggest ot simply delete"

emovedK belongs inwood preservation chapter

$oating of plastic parts is defined separately in the<F# it should be added somewhere and theplace is in the industrial coating"

For all source categories# 'ational import. e&portand production statictics for single chemicals canbe used as activity data" sed amounts can bedifferentiated into activities and facilities"

mission factors can be applied for use of single

chemicals in products and>or activities"Cith respect to harmoniHation to 9irective1JJJ>18>$. which is e"g" employed in performingemission pro7ections# ,n many technologies asolvent consumption is warranted at facility level"cont" below

continued from above. This re+uires !nowledge onTier 8 level. which may not be avaliable" Theguideline could suggest how to differentiate a totaluse amount of solvent on a facility level"

FU,# 'orway is adopting a different approach toestimating emissions from the use of solventcontaining products than the ones described in theuideboo!" i!e in the %wedish inventory. volumedata from the national *roduct egister on thesolvents themselves is used" mission factors arespecific for combinations of product types andindustrial sectors" The 2? uideboo! does notprovide us with information that can be used in theemission model directly" /owever. the informationprovided may help to correctly allocate emissionfigures (pertaining to the combinations of product

type and industrial sectors) into the differentsource categories and help us to improve ouremission factors" ore information on the new'orwegian model on ':$ emissions from theuse of solvent containing products can be providedon demand"

': Fs for paint application# boat building (%'A*6 1 6) - ,mportant in some countries. there isan F from <F5



Accepted

'oted


Accepted

': Fs for lectronic components manufacturing 'oted

e7ected

Accepted

Accepted 'umber placed in te&t

'oted

ore information is re+uired in relation to theemission factors from T," A specific referenceis re+uired to the bac!ground documentation in theA,'% model so that emission factor values canbe e&amined for applicability to nationalcircumstance" The emission factors are not clear in

terms of their derivation" The units differ betweensources" A common emission factor unit would behelpful"

9escription on how Tier 1has been derived has

been updated. referenceto A,'% fordocumentation

A very important refernce is missing , thin!" ,t is49$:*A,'T - %tudy on the *otential foreducing missions of olatile :rganic$ompounds (:$) 9ue To The se :f 9ecorative*aints and arnishes for *rofessional and 'on-professional se4. $ 9 nvironment Tender1>T>J??3. Dune 2" , believe it is availablefrom the $ommission web site" This wouldbe very

valuable for the section on decorative paints. evenif it was certainly used by T, group"

entioned in the te&t as

an interesting bac!grounddocument

$leaning products to be considered are onlyorganic solvents" This has to be precised" anyproducts used for degreasing do not produce':$

ore information is re+uired in relation to theemission factors from T," A specific referenceis re+uired to the bac!ground documentation in theA,'% model so that emission factor values can

be e&amined for applicability to nationalcircumstance" The referecence to T, for thissector is to a document published in 2I and not28 as indicated" ,n respect of dry cleaning isuggest reverting to the old simple methodologyapproach rather than an emission factor based on!g of garment cleaned"

eference correctedK oldmethodology put bac! butonly as a 4reference4methdology. industry hasinsisted on removinginformation because it wasoutdated5

The old < emission factors for units in operationcan be useful as Tier 1 meth and must bemaintained in the new <

, thin! in this chapter should be describedmethodologies to ensure time consistency andrecalcualtion and not methodologies to generatetemporally resolved emission data sets


,n the 4old4 uideboo! is present an F in!g>inhabitant year that can be useful for countrieswith no other information" Transfer the F in new< please"

,n this $hapter 681 (*olyester processing)should be also considered




Accepted

'oted

'oted

Accepted =uote fi&ed

&planations coming from T, to be cited Accepted =uote fi&ed



Accepted

Accepted

,t is not correct to say that all these activities areinsignificant" According to characteristic of theindustry and member states. several of theseactivities are significant"

,n the e&panded polystyrene. pentane is the mostoften blowing agent used" ,n e&truded polystyreneother types of chemicals are used" ,n polyurethane$F$ were used but presently other types ofblowing agents are used" ,n polyurethane. thetypes of blowing agents used depend on the finaluse of the foam" <utane. pentane can be used asmany substitutes of $F$ such as /F$ and /$F$"%ome polyurethane foams can be e&pandeddirectly with $:2 resulting from a reaction betweenpolyols and water"

,nformation added tochapter

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 tothe %'A* 686 definition (manufacturing ofpharmaceutical product) Ce agree and support thee&tension of the scope of %'A* 686" Thespeciality organic chemical industry aims atproducing different types of chemical productsincluding pharmaceutical products but not only"

the description comes from the T, documentwhich is not +uoted"

For e&panded polystyrene. pentane is e&clusivelyused"

F11. F12 are forbidden today and cannot be usedanymore" ive the names of the present blowingagents"

The reduction techni+ues available for polystyreneand polyurethane are different" ,t would be usefulto distinguish the two applications" For polystyrene.low pentane content e&pandable polystyrene canbe used (3"I to I ) but 7ust for some specific

application" missions can be captured andtreated by o&idation"


Add on techni+ues can be used" Applicationse&ists in several countries" :&idation techni+uesare the most often used techni+ues but wastegases containing pentane can be also destroyed ina boiler"





ive the list of products to be considered" Accepted

the title is not the correct one ditorial $orrected

e7ected

This chapter is outdated 'oted

ditorial $orrected

'oted

Accepted

'oted

'oted

The $ 9irective has been implemented but manymember states have their own regulation goingfurther the $ directive" *olyurethane foamprocessing. *olystyrene foam processing. asphaltblowing. the non pharmaceutical part of thespeciality chemical industry are not covered by this

directive"

%mall list of productsadded. but is not complete

/ere is a strong mista!e" The suspension processis a process to produce the *$ from $monomers" ,n this chapter only *$ processinghas to be considered" All the paragraph has to beremoved if no data are available for *$processing"


The confidence interval should correspond tosomething li!e II to 6I g > !g"

,n Table 8-6 is meant pharmaceutical productsmanufacturing

An emission factors of I !g>ton of product (fromtwo factory in ,taly) can also be proposed

the title of the table if not the correct one" Forrubber it is possible to distinguish tyre productionand other rubber processing" For tyre the T,default emission factor is 1g> !g rubber

processed" This emission factor is larger for otherapplication" The ? proposed if perhapsunderestimated"

Title updatedK rubberproduction now alsoincludes tyre production

,n the %'A* $ode should be only considered4Asphalt blowing 4 a special asphalt productionprocess and not the application of asphalt" Theemissionsfactors are very outdated and verylarge555 The asphalt application is considered under361 and %'A* 3611


The definition of solvent used is the same as thedefinition used by the $ directive JJ>18" ,tcorresponds to new solvents or bought solvents V

solvents recycled" ,t has to be reminded that in the$ directive fugitive emissions are e&pressed in compared to solvent used" "


The definition of asphalt should be provided" 9oesit included only the hydrocarbons or hydrocarbonsV all additives and ingredient used (stonesL)G




Accepted $orrected

'oted

the title is the correct one ditorial $orrected

'oted

Accepted F added

'oted

'oted

'oted

Accepted

'oted

'oted

'oted

ive the list of products to be considered" ,n factthey are at east paints. varnishes. glues. in!s" ,nfact this emission factor comes from T, whichprovides the emission factors for solvent borneproducts. water based products which can be used

by e&perts if they have the !nowledge on theshare of each type of products"

nder 6813 should not be considered Tyremanufacturing" This is considered under rubberprocessing" nder 6813 is considered themanufacturing of solvent containing products

This description is the same for all the specialityfine chemical industry" ower rates of emissionscan be achieved in the newest plants" ,n e&istingones also" $hec! if we stay with a definition ofpharmaceutical products or use the specialitychemical industryG

': F (and ': TA<55) for 6818 eatherTanning

An emission factor for 6811 Adhesive Tapeanufacturing is present in <F

': F (and ': TA<55) for 6812 Te&tileFinishing

% *A insert a lot of other fiber manufacturingactivities that must be evaluated# ryanoin. acetate.acrylic. nylon. etc"

': F (and ': TA<55) for 681 *olyester

*rocessing there are data from *A A* 32"%T< ,'%T955


ost of this information can be founded by directuses of plant data"

ore information is re+uired in relation to theemission factors from T," A specific referenceis re+uired to the bac!ground documentation in theA,'% model so that emission factor values canbe e&amined for applicability to nationalcircumstance" mission factors for each sub sectorcould be presented in one table"

in! to A,'% websiteprovided wherebac!ground info can befound

<ut this process has to be considered in chapter2<

There is a good description of the suspensionprocess in T,

,n polyurethane foam manufacturing a large part of:$ emissions is due to the use of solvents forcleaning moulds and blowing instruments"



Accepted :ther processes added

Accepted $orrected

e7ected

ditorial

ditorial

e7ected

'oted

e7ected

Accepted

Accepted

This section only concerns heatset web offset.being only one of the three groups of printingporcesses addressed in the previous section" Thisshould be clearly mentioned" The other twoprocesses should also be adressed"

newspapers are not printed in rotogravure" ention

magaHines. brochures. and catalogues

This section is dangerous and absolutely useless"The two halves of the industry (i"e" a) everything todo with publications and b) everything to do withpac!aging) are completely independent of eachotherK different techni+ues. different mar!ets.different import and e&port positions. differentsolvents etc etc" ,t is wrong to put them in thesame boat" This section must be deleted" ,t is as ofvehicle refinishing (i"e" painting) and solventconsumption in shipbuilding (i"e" also painting) are

ta!en together"

, table 8"? the line 0technoclogy>process0reads0heatset offset0" This should be publication gravure"

4audits4 could be replaced by 4solventmanagement plan4

, don0t thin! these are always 4abatement4. oftennew technology>new products are considered" ,t0sbetter produce Fs tables (non reductions) withtechnology>products and put them in section 8"8"2as in others chapters of <" , thin! the approachmust be uni+ue5

,n general. 2 other processes could be added#sheet fed and coldset offset" F and abetmentefficiencies have been defined by *" erspoor forthe revision of A,'%" $,T*A has also data onthese emissions"

%uggest using the previous simple methodlogyapproach and presenting emission factors in onetable"

Figure 8-1 seems to be copied into severaldocuments but it is not always appropriate" This issuch case where including T, 8 on chart is notof relevance"

9ecision tree andcorresponding te&tupdated

Figure 8"1. decision tree is not correct# the facilitylevel for domesticsector not available and no Tier 8for this 'F"

9ecision tree andcorresponding te&tupdated

Tier 1 default emission factors is incoherent withTier 2 as F (Tier 1) W % (Fs(Tier2)) anddifferent from old one" $hange Tier1 or removeTier 2




Accepted

Accepted Added

Accepted

Accepted Added

ditorial

Accepted %ection headings renamed

Accepted

e7ected

Accepted

ditorial

'otedadd all subsections to the table of contents ditorial 9one

ditorial

Accepted

Althogh the two approaches presented in thealgorithm are principally applicable here. theformulation (obioviously copied in severalchapters) is not appropriatre. specifically tal!inghere about industry is not what this sector ise&actly about. it is use of products and their

characteristics (formulationNsolvent content) andthen shares in total use are of interest" *leaseadapt accordingly"

9escription updatedaccording to comments

cooling li+uid (ethylene glycol) may also contributeto emissions

This must be a missunderstanding" Chat are these0add on 0 measures that couldbe applied here. alittle incinerator in the bathroom to burn the :$sfrom the hairspray usedG Apologies for trying to befunny #-)

$orrectedK abatementindeed not applicable assuch

An important and very useful reference is missingand certainbly it could be used for improvement ofthe chapter - <,*:. 22" 4%creening study toidentify reductions in :$ emissions due to therestrictions in the :$ content of products4 -Finalreport for the uropean $ommission"

should read 42"1"2"8 :rganic solvent bornepreservatives4

Chy is 4adhesive tape4 the uni+ue sectordescribed in ,ndustrial application of adhesives"any other type of application are e&isting"

$ould it be possible to define which sectors areconsidered in ,'9P:%

eference to A,'%added for documentation

Chen it is said that 8 sectors have the sameactivity units (g product used). it is not totallye&act as we have g of glue. g of seed and gof othersL how do you deal with thesedifferencesG ive e&amples"

Chy is 4use of shoes4 a source of ':$G Themanufacture of shoes is a source of ':$. butthe 4use of shoes4 is a source of *555

pdate# must bemanufacturing of shoes.not use of shoes" ovedto chapter 8"$ as well

The title should be Cood preservation and not Fat.edible and non edible oil e&traction

,n this $hapter is not considered (forgotten) glass

and mineral wool enduction

sometimes (e"g" p 1?. l 88) there is only onesubsection 8"8"1. but no 8"8"2K subsections need atleast two chapters

'ot sure about this. , don0tsee the need. but can'icola discuss with Tinus

+uations and legends# inconsistent notation. notin line with ,*A$

'icola. this was mentionedearlier so probably doneby now



Accepted

Accepted 9one

Accepted 9one:verview too short. gives too little information Accepted :verview e&panded

Accepted :verview e&panded

Accepted 9one

Accepted

e7ected

Accepted 9one

Accepted

e7ected

Acceptedadd# for -2@ Accepted 9one

e7ected

Accepted 9one

e7ected

The chapter is difficult to read" ,t is not a reallywhole ist a summary previous chapters"Title shouldbe e&panded to livestoc! husbandry and manure"'obody would search for * emissions in manuremanagement" The structure is not suitable foragriculture" * is not really integrated and is

added only"

The structure has beenrevised and hopefully isnow much more

accessiblemaybe it would be useful to say that '2:emissions. even if part of the ' mass-flowemission cycle. are not considered here because/

it must be specified that the emissions fromgraHing animals have to be calculated but not (GG)reported under chapter 3<" ,n the general schemeof the chapters it appear they are under 39

&pand overview to give more bac!ground

informationTo avoid misunderstanding it should be pointedout. that the emission from grassing animals has tobe reported in 'F category 392c

Table 1-1 shows that ':& emission from theagricultural sector contribute by 1"? of total ':&"This indicate the important of develop a Tier 1methodology" ,s is possible to recommend a Tier 1approach based on the reference of the data givenin table 1-1G

%imple Tier 1 approachnow included

There is no mention of '/8 being produced fromurine e&cept for the comment in brac!ets on line

28" ,t woul read better for the non-ag e&pert if asentince on '/8 from urine and faeces began theparagraph

'o longer relevant as wehave revised thesesections

4a small percentage of this ' (is in the form of)urea or '/3VLLLL4

%uggest re-wording the overview" Appears as ifsome te&t was deleted and as a conse+uence itsstructure does not read well

:verview revised ande&panded

%uggest moving this comment to the bottom of thepage as a footnote

Footnotes are irritating tothe reader

The reference Darvis etal doesn0t cover pigs" Forpigs @ of ' is in urine and J of urine-' N

urea-'"

eference for pigs now

included

add '2: and $/3 to the emissions created frommanure

'o longer relevant due tore-structure of chapter

There is no abbreviation e&pansion for T%*" Thisconcerns the whole te&t" , suggest to add theglossary of all abbreviations in chapter 3<

4in particular (the) handling of manuresasLLLLL4




Accepted 9one

*rocess description is too short Accepted

Accepted An e&ample of 4movements activities4G Accepted That te&t now deleted

e7ected

Accepted 9oneThe reference N an Faassen and an 9i7! Accepted 9one

%entence incorrect Accepted

Accepted

Accepted

Accepted 9one

Accepted /ave done

Accepted /ave done

Appendi& A2"2"8 GG e7ected

e7ected

9elete activity e7ected

on animalG e7ected

roenestein. $"" and /"" van Faassen. 1JJ6"olatiliHation of ammonia. nitrous o&ide and nitrico&ide in deep-litter systems for fattening pigs"Dournal of Agricultural ngineering esearch 6I#26J-2@3

*rocess descriptions now

e&panded

*rovide more information about processes (pute&tended description in an appendi&)

ore information providedon processes and clearlylin!ed with supplementarydata in Appendi&

,t is correct that only a small percent of faeces is'/3V. but the sentence needs furtherdevelopment. because most manure is managedin a combination of urine and faces (both slurryand solid waste)" The sentence need to clarify thatthe TA' content i in solid based stable systemscontains large amounts of TA' (8-I)" %o the'/8 emission is not 4sufficient small4"

This section is dealing with0fresh0 ' e&creta. socomment not releveant.but revision of chapter nowgives more e&planatoryte&t"

please change an Fassen and an 9y!e into anFaassen and an 9i7!

This entire section hasbeen revised

ist obvious that * belonges not to manuremangement

There is now a separatesection for *

9ust mainly origins from poultry and pig farms"9ust from poultry houses is mainly caused byfeathers and manure. dust in pig houses mainlycomes from feed. s!in particles. faeces andbedding (Aarnin! llen. 2@. seewww"dustconf"com)

'icola. can you pleaselocate the reference andinsert

4 e"g" at pasture or on yards. and (in) animal(housing)LL4

eplace with te&t from original final draft. whichwas structured according to pollutant


,ncomprehensible

commentepace 4',:$ inventory is furthercomplicatedLL"4 with 4stimates of ':$emissions are further complicatedLLL"4

That sentence has beendeleted

%ection has been re-written

%ection has been re-written



e7ected

e7ected

e7ected

Accepted

e7ected

Accepted $hange made

e7ectedFigure 2-1 appears twice Accepted 9one

Authors not cited in chapter I Accepted eference now given

e7ected

e7ected9ammgen and /utchings is not in eferences Accepted eference now included

Accepted eference now included

e7ectedreferenceG Accepted eference added

Accepted /ave done

Accepted /ave done

'oted

e7ectedthe number of Figure 2-1 is double Accepted 9one

Accepted

9elete 4The4 from 4The significant emissions of*LL""4


4The types of feed consumed will have a ma7oraffect (on) emissions4


:rder of items does not seem logical. better followorder of figure 2-1


TA' needs proper e&planation first. unless TA' isintroduced earlierG Also mention A'

&planation now give.including A'

Add after building# and the storage system" , thin!it shoud be included here instead of in line 26

This section re-written toinclude original te&t

9elete -the storage system- and add -ventilationsystem-" The latter is very important in determiningair velocity and thus emission of ammonia

4the height and density of (the) canopy of the cropor grassland4


eneral# 9istuinguish between indoor and outdoorstorage li!e you did on the previous page insumming up important elements" 9istuinguishing isvery important because reduction strategies forindoor storage are totally different from outdoorstorage" ,ndoor storage is a component of thehousing system"

The figure is to illustratethe principals"

eneral# , assume the symbols for variables arescientifically correct. but it is also very confusing. ,got lost" *lease find better solution

The figure has notconfused other reviewers

$an0t find 49mmgen and /utchings. 2@) at thereference-list

the treatment of manure (i"e"# aeration. separation.composting) is not cited here neither considered inthe following

These are not ma7orsources and not e&plicitlyaccounted for in themethodology



A good idea to clarified that the ':$ is related

to the methane in manure"

:dour (of pigs) can be characterised by 2 maincomponents (putting those compounds togethercreates artificial odour)" The formulation used inthese lines suggest something else" *lease chec!"

9o not agree with thecomment. we already statethat most of the emissionis from 2 compounds

There are two figure 2"1" %ome e&planation isneeded for this figure in page @"

%ame comment as 16 and1J above



AcceptedFigure should be shown in 2"1 before Accepted ,f the figure remains

e7ected ay delete the figure

e7ected

e7ected

Accepted Te&t now amended

Accepted %entence clarified

eplace 4&creta4 with 4e&creta4 e7ected

Accepted 9one

Accepted $omment deleted

e7ected

%ee remar! I Accepted

e7ected2"3"3 written 2 times ditorial 9one

e7ectedadd after '# and>or TA' Accepted TA' inserted

ditorial 9one

This chapter only covers '/8" *lease e&pand onother compounds or incorporate in 2"3"1 (whichthen should become 2"8"1)

Ce have revised thissection

Figure 2-1K should consider to show a figure basedon different compounds instead of production

states"

,t is not possible 4reducing the rate oftransformation of TA' to '/34" This is incorrect"'/3 is part of TA'" ,t is possible to change thedistribution between '/8 and '/3 by altering p/"

'/3 is part of TA'. but notall of it

,f animal feed is silage. '/8 can emit" ,f not ta!eninto account as losses. please note so

replace -mainly from feed- with not only frome&creta. but also from feed. animal s!in. flees orplumage and bedding

between brac!ets# two third of the total" :f whatG

Total ':$G'o longer relevant due tore-structure of chapter

better to say also that the measures to reduceemissions are listed and e&plained in Appendi& A8

why manure drying via conveyor belts wouldreduce * emissionsG

list measures to reduce '/8 emissions (e"g"reduction of air contact. lowering of the p/ value)instead of manure management stages where '/8emissions can be reduced

'ot the purpose of theuideboo! to give detailedappraisal of abatementtechni+ues

Ce have revised thissection

'ot all '/8-emission-reducing techni+ues inhousing systems reduce odour emission (ol. "and '"C"" :gin! (23)" The effect of twoammonia emission reducing pig housing systemson odour emission" 2nd ,CA $onference on :dour :$s# easurement. egulation and $ontrolTechni+ues. %ingapore" *ublished in# Cater%cience and Technology. 23. issue 3. p"88I-83)

Ce do not state that alltechni+ues to reduce '/8emissions reduce odour"Ce state that techni+ueswith reduce either or odourcan reduce ':$"/ave changed 0can0 to0may0

$leaning the air with air scrubbers is also anabatement option (optional as <AT)

%cubbers are nowmentioned elsewhere

9elete 4way4 from 4The latter is the most effectiveway4



Accepted

e7ected

Acceptedbefore this line insert a heading# Ammonia ditorial 9one%ection title 0Ammonia0 is missing ditorial 9one%ection title 0Ammonia0 is missing ditorial 9one

Accepted

e7ected

Accepted Te&t restored

Accepted Te&t restored

Accepted

Accepted Tier 1 approach added

ditorial

e7ected


,n the e&pert roup of Ammonia Abatement('$) air scrubbers are considered to becategory 1 abatement options" %ome informationon effectivity in# else. "C" and '" C" " :gin!(2I)" Air %crubbing Techni+ues for Ammonia and:dor eduction at ivestoc! :perations# eview of:n-Farm esearch in the 'etherlands"Transactions of the A%A" ol" 3?(6)# 288-2818" Te&t amended to report air

scrubbers as category 1

the abatement means are theoretical but notapplicable or state of art

Ce do not suggestotherwise

9ecision tree# as! first if it is a !ey source and thenthe other +uestions (tier 8 available. %distribution available. etc")

'icola. can you pleaseamend

The dafault emission factors include emissionsfrom graHing animalsG (better to specify)

Ce now state the Fincludes graHing forruminants

, thin! it will be easier for the user to wor! with onedocument instead of loo!ing forinformation>e&planation in ,*$$ (26)

Ce provide all theinformation needed. thereference to ,*$$ is toenable access to moredetail"

estore te&t from original draft but removing thediscussion of emission factors

estore te&t from original draft but removing thediscussion of emission factors

,t could be useful to add the e&act reference to,*$$ 26" &ample" , suppose it is refered to$hapter 1 section 1"2

The chapter is already inthe reference list. and wehave added the section tothe reference

eneral remar!# ': emissions from manuremangement are not presented (only an estimate issaid to be presented in the section on ammoniaemissions for losses during storage (step 1 page22 with reference to an Appendi& Table I"J whichcannot be foundK it seems to be the Table on p I@)"/owever. no ': emf is presented for manureapplication to soilGG

Average Annual *opulation or as ,*$$26 Annual Average *opulationG

/as already been ta!enout - discuss with D

,s it re+uired to distinguish between time in stableand time on grass in Tier 1G , assume that the Tier1 F for '/8 given in Table 8-1 to 8-1I onlyincludes the emission in stableG F for ':$and * - is it for 86I days in stableG

,t is stated in the te&t theF includes graHingemissions based onaverage graHing periods

$ould supply with a sentence li!e 4'o Tier 1approach is available for emission of ':&4



Appendi& A8"1"3GG e7ected

Accepted

ditorial 9one

'oted

'oted This is 39

Accepted,nconsistent citation of references" ditorial /as already changed

'oted

9ammgen et al 2? is not in eferences Accepted

Accepted

Accepted

,ncomprehensiblecomment

A lot of misunderstanding and miscommunicationcan be caused by the definition of the activity data"9efinition of AA* is not in agreement with p" 3 lines

28-26" , do not thin! it is appropriate to deal withthis matter only with referring to ,*$$ 26 forfuller e&planation"

AA* now definedconsistently

9elete 4in tables4 from 4'etherlands. 9enmar! andermany in tablesL"4

*1 and *2"I are higher for FU (straw based)than for li+uid systems" *lease ma!e adifferentiation

%pecify in the te&t which regions is applicable theF

eferences used to proposing new Fs are notpublished and not available yet" The 'ational

,nventory eport of a single country can beconsidered a scientific referenceG

*ublished references now

provided for the Fs fromeach national inventory

*1 F values presented seem to be not in linewith values used by the 'etherlands for severalanimal categories" /owever. since the basis for thepm1 emf is rather unclear it is very hard to ma!ea good comparison" %ee below +uestions oncategories included and on the time spend in themeadow# ,t is unclear where the calves and piglets are

included" g for cattle it is unclear whether dairycattle only includes female adult dairy cows or alsoyoung (dairy) cattleG And what animal numbersshould be used if dairy cattle is a mi&ed categoryG%ince calves have a much lower emission factortheir emission will be overestimated if thepresented emf for other cattle should be used" Thesame remar! can be made for swine# in whatcategory should the piglets (weaners) be includedG(specifie! place in the te!st# page 12. line I topage 18. line 8 and page 13. line @ to page 1I. lineI)

The te&t will be correctedto 9ammgen 2@ - 'icola

,n table 8-1 to 8-13 concerning the *2"I emissionreferees to 49mmgen et al". 2?4 - this referenceis not on the reference list"

The te&t will be correctedto 9ammgen 2@ - 'icola

,n table 8-1 to 8-1I *ropose one table for eachcompounds - then it is more easy to compare theemission levels for all livestoc! categories"

Ce have restored suchtables to the te&t



Accepted

ditorial

ditorial

, would prefer fewer tables in the te&t Accepted

Accepted

Accepted

Accepted



Accepted

e7ected

Accepted

ditorial

The emission factors for ':$ and * aregiven in incorrect units (!g '/85)" This is valid forall tables" <oth 4a-14 and 4per AA*4 is used" Thesame nomenclation should be used all over. eg"either 4a-14 or 4per annum4

'icola. can you pleasema!e these corrections inthe tables

the unit has to be differentiated by pollutants (notalways !g'/8 a-1 per AA*)


tables (what are we doingabout tablesG5

eneral remar!# ,ncorrect units used in Tables formost pollutants e&cept '/8 (all units aree&pressed as !g '/8)

Cill change with newtables (what are we doingabout tablesG5

$oncise summary tablesnow provided

emove tables to an appendi& (correcting the Fsfor * where appropriate) and replace the te&t andtables from the original draft. adding more

information about Fs

/ave replaced te&t andtables from original draft"/ave not yet placedtemplate tables into

Appendi& as we need to

agree this with T':Tables are confusing and should be presented in acondensed form"


the eidy et al. 2@ reference is insufficient. itdoes not contain the specified '/8 emissionfactors" *lease give more references

,t is not appropriate toinsert large numbers ofreferences in the te&t. thefull list is now given in the

Appendi&"

*lease indicate in the te&t that all animal manure issurface applied

*lease indicate in the te&t that all manure storagesare open

the tables are not the best. previous solution hadbeen better

Agree. but we need toagree with T':

The detailed tables provided even thoughnumerous are user friendly and allow the user tobe able to calculate upper and lower estimates ofemissions for each gas" ,t may be possible toincluded all the info in one large table however. itmay become too cluttered and diificult to use"There appears to be some discrepancies with thelivestoc! categories used in 3< and 39" %uggest acloser loo! at the discriptions in the emission factor

database especially for cattle sub-categories"

This is not the view of thegreat ma7ority ofrespondents. and for thefinal version we proposehaving the detailed tables

in the Appendi&emove tables to an appendi& (correcting the Fsfor * where appropriate) and replace the te&t andtables from the original draft. adding moreinformation about Fs

/ave done this" 'icola.can you please see to Fcorrections

, am afraid the units for ':$. *1.*2.I arenot +uite clear for me - for all these parameters is4!g '/8 per AA*4correctG This concerns tables8"1 to 8"1I




Tables# eferences inconsistent with $hapter I ditorial

ditorial

Accepted 9one

e7ected

Accepted ore references given

Accepted

$hec! units of Table 8-1 ditorialsame comment as for dairy cattle 'oted

'oted


change units for ':$. *1. *2"I from '/8into appropiate units


&plain abbreviation 4AA*4 (e&planation comes inthe ne&t section. but should be given when AA* isused for the first time)

Chy are the last two rows relevantG The sameremar!s goes for every table 8-"

$an0t change the tabletemplate

The reference publication eidy et al. 2@ ismentioned as basis for the values presented in theuidelines 2? draft for tier 1 '/8 emf (on pages12 till 1@ in Tables 8-1 till 8-1I) and for tier 2 '/8(on pages 23 till 81 in Tables 8-16 till 8-8)"

/owever. it only provides some (not all. yardvalues are not included) tier 2 data for dairy cowsand fattening pigs" ,t is unclear what is the basisfor the tier 1 emf for all animal categories (not evenfor dairy cattle and fattening pigs the chosendefaults are presented in eidy et al. 2@)" Also isit unclear what is the basis for the tier 2 emf forother animal categories than dairy cows andfattening pigs and for the tier 2 Uard emf for dairycows and fattening pigs",t is recommended to ma!e clear what the basis isfor all chosen emf (to provide information on thepublications where these data originate from)"(specifie! place in the te!st# page 12. line I to

page 1@. line 2 and page 23. line 16 to page 81.line 2)

Table 8"1 and all other" JI confidence interval isoften the same and should prefrenctially be givenas V-&&" specially to avoid upper emissionlevels above 1"

'icola. can you please seeto this


* is higher for FU then for li+uid systemsfattening pigs



'oted

'oted

'oted

Accepted

e7ected 'ot for Tier 1$leaning period# the unit (in day) is lac!ing Accepted nit inserted

Accepted 9efinition inserted

n-places# add usually occupied Accepted 9efinition e&panded

Accepted average0 inserted

*1 F values presented seem to be not in linewith values used by the 'etherlands for severalanimal categories" /owever. since the basis for thepm1 emf is rather unclear it is very hard to ma!ea good comparison" %ee below +uestions on

categories included and on the time spend in themeadow# *m1 F values in Tables are not always clearlybased on table A8-I in appendi&# eg eg forfattening pigs. sows and laying hens in Table A8-I2 different values are presented for 2 differenthousing types. while in Table 8-? en 8-J (page 13and 1I) only one (meanG) value is presented forthe different systems"

please lower *2"I because these figures arenow higher then *1

* is higher for FU then for li+uid systems forsows

For *1 (Table 8-12) emf are provided for allmanure management systems" %ince there are bigdifferences in the two manure managementsystems cages and perchery) it is recommended toprovide emf for the two management systems"

The distinction betweencages and perchery is inthe new table

please differentiate within poultry for solid(bedding) and li+uid systems

better to add in the table also a definition of n-round N average number of production cycles peryear

mpty period# , prefer to add 4average4 durationduring the yearL"



Accepted

Accepted

Accepted

ditorial 9one

e7ected

Accepted

e7ected4present on a particular day (will)LLL""4 ditorial 9one

ditorial

The lin! to FA: *roduction Uearboo! is#http#>>faostat"fao"org>nder item atest news FA: %tatisticalUearboo!s 2I>26 (issue 1 and issue 2) are

available",ssue 1#http#>>www"fao"org>statistics>yearboo!>volP1P1>inde&"asp and ,ssue 2#http#>>www"fao"org>statistics>yearboo!>volP1P2>inde&"asp(ivestoc! numbers are available from ,ssue 1.Table AJ)"

*lease note that the yearboo! is updated on anannual basis" *roviding the http#>>faostat"fao"org> is probably the best"(Dust a thought regarding section 8"2"8 Activity9ata (line 3-6)L if a country do not carry out

annual surveys on animal numbers how would%TAT or FA: get these numbersG)

eferences included"Than!s to the reviewer

$hec! definition with earlier e&planations on p 3(line 28-26) and p" 11 (line 26)

Te&t amended to beconsistent

%ometimes the two sources of activity datainformation do not match" :%TAT informationfor european countries is updated every year andhave definitive data available" FA:%TAT importantsource. but nowadays data available only till 23year" *robably the best is to encourage at firstnational statistics and after other sources"

/ave amended wordingslightly to reflect thecomment

%ame comment# define is using Average Annualpopulation or annual average population

Are there no activity data on storage andspreading to be mentioned hereG

'o. statement made thatdefault based on surfaceapplication and openstores

The formula should be elaborated further" For mostanimal types AA* is given in the national statistis"For animals having a life cycleO 1year. the cencusin most countries thus ta!es into account emptyplaces" The formula is therefore more a correction

formula for amimals haveing a life cycle W1year"The same is valid for the subse+uent formulas"

This section has been re-written to ma!e clearer

, prefer to have the methodology to estimateanimal number>acivity data before themethodology for F

The T': chapter structuredoes not allow this

(A)nnual agricultural cenus (data) can supply (thisinformation)

%entence changed withother comments



4seasonal production cycle(s). LL4 e7ected

ditorial 9oneTable 8-1 (to Table 8-1I) ditorial 9oneafter the word 4rounds4 specify per year Accepted 9one

Third method seems second method e7ecteddefault data for ' e&cretion# whereG Accepted eference to table given

e7ected

Accepted

e7ected

'o information on application re+uiredG e7ected

e7ected

e7ected

e7ected

e7ected

e7ected

rammar was alreadycorrect

4is seaonal or because the (housing) is beingcleaned4

'o. there are threemethods

The basis for a Tier 2 approach is mentioned inline 13-16" ,n these calculations itMs not e&actlyclear if a brea!down of the different livestoc!categories (cattle. pigs etc") into sub-categories(e"g" sows. piglets etc") is ta!en into account"/owever from sections 8"8"1 Algorithm V 8"8"2Technology %pecific mission Factors it appearsthat different livestoc! sub-categories are ta!eninto account" *erhaps the introduction of section

8"8 could be a bit clearer on this"

Te&t has been substantiallyrevised so comment nolonger relevant (%tep 1

onward)

For * emission is mentioned that 4For graHinganimalsL the graHing season and the daily graHingtime is needed4 <T at page J.@ is written that *emission from 4cattle. pigs ectL" are considered tobe negligible during graHing4GG

The time spent graHing isneeded in order toaccurately estimate thetime spent in the buildingwhere most emissionsta!e place" This is nowmade clear"

%uggest deleting the heading * and begin theparagraphs as follows# 4 ,n the case of *.information is re+uiredLLLLL"4

The guideboo! templatere+uires clear sub-headings

Te&t amended in responseto previous comment tostate that default based onsurface application andopen stores

activity data listed under the heading * are notonly re+uired for * emission estimates but for theother gases as well

Ues. to confirm specificre+uirements for *

emphasis only on livestoc! numbersK much moreactivity data are needed for an accurate inventoryKgive those more room in the chapter

Ues. but this is for Tier 1.the need for activity dataemphasised in Tiers 2 and8

information on manure treatment is needed.please add this to the list

anure treatment is not ama7or factor in nationalemissions

formulate stronger e"g 4Tier 2 is $:'994instead of 4proposed4

Te&t has changed and thepassage referred toremoved"

Chy is * mentioned separately. this infromationis also needed for other componentsG

Ues. to confirm specificre+uirements for *



section 2"1"1 where is itG ditorial

4*4 - misprint G 'oted

Accepted

Accepted

Accepted

%ee comment to page 1@ line 1J" Accepted

Accepted 9one

Accepted

*/ N p/ Accepted

Acceptedafter ' e&cretion# add # and TA' or A' Accepted done

Accepted 'icola is dealing with this

Accepted $hanged to m' e&cretedafter mil! add 4eggs or offspring4 Accepted 9one

Accepted

e7ected

Accepted

Accepted changed to 0!g a-1 '0

Table 8-1 does not e&ist in that form ditorial

e7ected

Accepted

$hanged with earliercomment

'ot sure about this - Dplease could you ta!e aloo!

,n which way are soil */ includedGG - is this shown

in figure 2-1 (process scheme)G

eference to soil p/

deletedemove this Tier 2 description and replace withthe te&t from the original draft (i"e" Cith moree&planation and without the formating errors)

The original te&t has beenre-inserted. with someimprovements

emove this Tier 2 description and replace withthe te&t from the original draft (i"e" Cith moree&planation and without the formating errors)

9uplicate of row 18aboveG


This chapter heading can be left out" ,nstaeademphasiHe that Tier 2 is 7ust ammonia (althoughalready mentioned in line 82)"

4the types of stores in which (manure) is!eptLLL""4



, do not understand why you mention soil */G ;eyvariables are not shown in Figure 2-1

eference to soil p/deleted

Table 8-1. section 8"8"1 and also many times in thefollowing# the ref is wrong or lac!ing

me&creted is not a self-e&plaining symbol for totalnitrogen e&creted. it seems total matter e&creted. itwould be better to use m'e&creted. by analogy

with mTA'

,t seems to me. references to Tables 8-1 and*aragraph 8"8"1 are wrong

'icola. can you chec!table references once wefinish the te&t

, would prefer to find ,*$$ e+uations1"82.1"88right in the uideboo!.

Ce should avoid simplyrepeating ,*$$ te&t

The source of the stepwise approach should becited"

The derivation of theapproach is given insection 8"2"2"1

Treatment of units# 4!g ' a-14 means !ilogramnewton per year5

'eed to sort out the tablesin these steps

in ,*$$ organic matter is defined as olatile%olids# wy not to use the same hereG

The sentence referred tohas been superceded

it is not clear how do you use &faeces and &urine# ,suppose &urine is not the same as &slurry and &faeces is not the same as &FU" %o it is not clearhow to translate &faeces and &urine in mTA'K




Acceptedmfaeces# definitionG Accepted 9efined

Accepted %ame symbols now used

e7ected

Chere is table 8-8G ditorial

chec! subscripts ditorial

And how should we calculate &('faeces)G Accepted

e7ectedany references for the value of fminG Accepted eference inserted

e7ectedmbedding don0t appear in the formulasL e7ected ,t appears in + 28any references for the value of fimmG Accepted eference inserted

Chere are Tables 8-8 and I"JG ditorial

e7ected

e7ected

Appendi& Table I"JGG e7ected

Appendi& Table I"8GG e7ected9o you have a refence for "6?G Accepted eference inserted9o you have a refence for "1G Accepted eference inserted

mm (storage.org) or mm (storage. ')G Accepted

proportion of total e&creta or proportion of total ' ine&cretaG (is the assumption that 'itrogen split inthe same way as mass into faeces and urineG)


use the same symbols in the te&t and in theformulas# mTA'Pslurry is mbuildPslurry.TA'G tc"

, would prefer to see ,*$$ e+uations1"23 right inthe uideboo!

eference to e+uation nolonger made


D - there is now a missinge+uation - would you li!eme to renumber theseG

This section amended toma!e clearer

, would prefer step @ to be graHing" This manure isnot in storage

To ma!e step @ graHingwould interrupt these+uence from e&cretionthrough housing to storageand then to application"

at this point of the calculation &FU is theproportion (without bedding5) of manure e&creted.handled as FU" , believe it woul be better specifythat the proportion is in mass (!g>!g) and that it

doesn0t ta!e into account the bedding materialL

/ave chec!ed formulaeand they do account for

bedding


Table 8-8 shows Tier 1 emission factor for :ther$attle on slurry which give no relevans in the te&tdescribtion"

'icola. when re-draftingcomplete please chec!accuracy of references toTables

Table 8-8 shows Tier 1 emission factor for :ther$attle on slurry which give no relevans in the te&t

describtion"

'icola. when re-draftingcomplete please chec!accuracy of references to

Tables,ncomprehensiblecomment

,ncomprehensiblecomment

mm storage '. correctionmade



4 it does (however) re+uire much moreLLL"4 ditorial 9one

e7ected

e7ected

the active a&cel file is necessary55 Accepted

9oes Appendi& < e&istG e7ected

9o there e&ist an Appendi& <G e7ected

e7ectedCher is Figure 1-1G ditorial 9one

e7ected

Accepted

Accepted

same remar! regarding the terrible table Accepted

Accepted

e7ected

Accepted

Table 8-8 shows Tier 1 emission factor for :ther$attle on slurry which give no relevans in the te&tdescribtion"

'icola. when re-draftingcomplete please chec!accuracy of references toTables

Could a formula not normally be written as# ;g

'/8-' a-1 GG

'ot according to one of

the other reviewers,t was supplied for thereview5

,t was supplied for thereview5

,t was supplied for thereview5

The ammonia emission report unit in 'F is '/8and not '/8-'

Chich is what we havewritten5G

As the F is a percentage of TA'. there is noreason to differentiate in F yard and for graHing

between dairy cows and other cattle

The evidence we haveindicates that there is a

reason

emove tables to an appendi& and replace the te&tand tables from the original draft. adding moreinformation about Fs


Appendi& as we need toagree this with T':

Tables are confusing and should be presented in acondensed form"


The concise tables havebeen restored and we

propose the templatetables go to the Appendi&

To many tables - all data could relativly simple berepresented in one or two tables without missingimportant information"


Appendi& as we need toagree this with T':

:nly emission factors for dairy cows and othercows are included" mission factors for other cattlesub-categories are re+uired here" %ee comment 13for further issues"

The uideboo! only needsto cover the 'F codes"

%ection 8"3. Tier 8 statesthat 0if data are available.emission calculations maybe made for a greaternumber of livestoc!categories than listedunder Tier 20"

emove tables to an appendi& and replace the te&tand tables from the original draft. adding moreinformation about Fs

/ave re-inserted te&t andconcise tables



Accepted

ditorial

e7ected

e7ected

ditorialFigure 1-1 not presented in the document ditorial 9onesame comment as for dairy cattle e7ected And the same riposte

not 4:ther cows4 but 4other cattle4 ditorial

e7ected %ource of F now given

e7ected %ource of F givenThere is no F for outdoor sowsG Accepted F added using ; data

e7ected

e7ected

Table 8-2J - no data for 4other poultry4GG ditorial

(Table 8-2J :ther poultry) no figures are included" Accepted $orrected

e7ected

The chosen tier 2 default emf '/8 in the Tables 8-16 till 8-8 on pages 23 till 81 seem to be anaverage of the figures presented in the appendicespage 3? till I (Table A8-1 a till d)" /owever thereare some deviations# Uard emf are not available inthe appendi& Tables and a figure of "1I ispresented for broilers (one value only for the'etherlands). while in Table 8-2? a value of 1@ ispresented" Chat0s the basis for this figureG

Further footnotes nowadded to new summarytables

$hec! proper width of cells" Chy are last two rowsrelevantG


'ow it is '/8-' conversion despite the formulaconsists of 4storage. '/84" ,t should be changedin all formuals to 4storage. '/8-'4"

This e+uation no longer inchapter

All tables has the unit as TA'" ,t shouldpreferentially be 4 of TA'4 and no JI upperlimit

above 1

Ce thin! the meaning is

clear

All tables could be written more easily" To muchunnessary data



the F for yard is e&tremely high and note&plainable. so please ad7ust to I8

the F for graHing is too high. so please change

into 1

,s the manure of the laying hens consideredalways as solid manure and not slurryG

Ce do not thin! there isenough evidence todiscriminate

broilers and other poultry are mostly !ept on solidmanure systems. so here no need for F li+uidsystems

, cannot see that we havean F for broiler slurry (G)


(Table 8-2@) emf are provided for all manuremanagement systems" /owever. since thesefigures are based on the Appendi& tables it turnsout that only solid manure is included" %ince li+uidmanure systems (cages) still e&ist and since theiremf are different from solid manure systems. alsoli+uid manure management emf should beprovided"

'ot enough evidence todifferentiate



e7ected

$hec! alues and confidence interval in table Accepted

e7ectedadd a reference to Appendi& A8 Accepted 9one

e7ected

Accepted Te&t now amended

Accepted

e7ected

e7ected

after 4storage4 add 4and after field application4 Accepted

Accepted /ave done

Accepted

e7ected

e7ected

Accepted 9oneeinsert sections for the different polluntants" Accepted /ave done

add abatement measures from the house Accepted

please ma!e a differentiation into solid (bedding)and li+uid"

'ot enough evidence todifferentiate

'icola. can you please seeto this

8"8"8 Abatement# why not $ontrols as in section

2"3G Abatments seems more appropriate to end-of-pipe techni+uesL

This section is specific tothe incorporation of

abatement techni+ues inthe calculation

As it seems to me. table 1"1J of ,*$$ chapter 19efault ' e&cretion data is necessary to beincluded in the uideboo!

All inventory ma!ers surelyhave ,*$$ available aswell (and can loo! thedefault values up)

As it seems to me. paragraphs 8"8"8 and 8"8"3 arenot complited

'o techni+ue to reduce emissions in livestoc!

housesG ,n the ,F <F there is a long list of<ATs for animal houses""

The section now ma!esreference to housing

techni+ues in '$ and<F docs

The F for inside storage and outside storagediffer. mainly due to differences in temperature"oreover by removing the manure +uic!er tooutside. is an abatement techni+ue" As , do nothave the data from eidy et al. , cannot chec! thepresented F" ,f necessary , will be helpful toelaborate this in more detail"

, dont0t understand why this section is here and not

within 8"2"8

The intention was to putinformation on activity dataspecific to the Tier with

that Tier And manure applicationinserted

einsert sections for the different polluntants"emove second paragraph (not valid for allabatement measures (eg optimised feeding)

efer to ,*$$ data on manure managementsystems

Table in Appendi& givescross reference to ,*$$definitions

i!ely the choosen approach is that most of theanimal manure does not stay for a long time insidethe animal house and is stored outside"

Fair commenr. but te&talready covers this

This reviewer has the opinion that a lot ofuropean animal production systems store theirmanure inside the animal house

$ontradicts previouscomment

eferer to Appendi!s A - chapter A"8"1 for furtherinformation

eader referred to Appendi& and otherdocuments



Accepted done

, cannot find these notes in the TablesG Acceptedchec! subscripts ditorial 9one

Abatement deals with ammonia only e7ected

e7ected Formula no longer used


Accepted *aragraph re-worded

Acceptedentioned an e&ample of double counting" Accepted &ample now given

Accepted $hanged as suggested

Accepted &ample now given

Accepted

Accepted

Accepted

also in ol and :gin! 23 (see also remar! 22) e7ected 'o need for action%(T.%) GG e7ected These terms are defined

not only housing activity data are relevante. butstorage and spreading as wellK please add these

The concise tables havethe footnotes

<ecause there is only aTier 2 method forammonia

,s the formula correctG The value calculated is myview an implied emission factor and not an F forabated techonlogy" 'Pabatement is not defined"

see remar! 18 about differentiation of inside andoutside storage

missions are not solely governed by fouled area"$hange formulationG

There is no restriction on the form of Tier 8.

provided it can supply estimates that are moreaccurate than Tie 2"

/ave re-worded to ma!ethis point"

%ame comment# for european countries the bestcross chec! is to be done with :%TATinformation" FA:%TAT statistics at this moment arenot updated"

*robably an e&ample of 4manure managementsub-categories within the livestoc! categories4could be useful" :therwise. define it in Figue 8"1 orat page 1? line 2@ where this term is used"

There is also a figure for overall uncertainty in the'etherlands. using a Tier 8 approach" The 9utchuncertainty is 1@ (T':. 23)

=uoted uncertainty now

included. 'icola. can youplease find the fullreference

T':. 23" ncertainty assessment of ':&. %:2and '/8 emissions in the 'etherlands. T': report 23>1. T':. Apeldoorn

=uoted uncertainty nowincluded

,n the te&t is mentioned 4$onse+uently. there arelarge uncertainties associated with the default Ffor this source4" <t no ':& defalut value isrecommended - not even for Tier1 methodology"

Te&t reworded to refer toemission estimates. notspecific F



Accepted

Accepted

Accepted

Accepted

'otedno overview for ammoniaG Accepted 'ow added

'oted

, miss some further describtion for '/8 and ':& Accepted 'ow added

e7ected

Accepted

Accepted

e7ected

'oted

Accepted /ave done

it is not clear from the previous methodology thatthe emissions from graHing animals have to bereported under 39" /ow could you do it in the caseof tier1 methodologyG ,f , understood it correctly. itis necessary to highligh somewhere else that you

ma!e the calculation under chapter 3< and toreport the results under chapter 39

This has now been made

clearer at the beginning ofthe chapter

why are these sentences reported under 4e&ternalreviewG

The statement has beendeleted

/as this been copied directly from the ,*$$guidelinesG ,t contradicts the statement p8. l 1 - Jwhere all '/8 emissions are reported undermanure management and not under soils"

The statement has beendeleted

All references should be available on the internetat A homepage

'icola. can you chec! thiswith T':

van Fassen etc should read# an Faassen. /""

and an 9i7!. /" 1J?@" anure etc ,n# /"" an dereer. "D" nwin. T"A" an 9i7! and "$" nni! etc

eference seems to havebeen removed

* definitions are not target orientatet",ts ami&ture of differnt defin" ,st to separate why in thepast other defin" Are used and which will be usedin the future" The relevant difference incomparision with gases should be e&plained",tsnice to see my figure(A1-1)but no +uotingG

Amount of science in the uideboo! is 7ust right.

but it is better to place it in one place. it isunimportant where -in the main body te&t or inappendi&

The revision now gives a

more coherent balancebetween chapter and

Appendi&

the Appendi& is toolong"The author could notdecide wether he gives information(scientific(in thebody or the appendi&"

The Appendi& is nowshorter

eneral# Chy is this information in the appendi&and other information in te&t" Chen is itbac!ground information and when notG $hoice isnot clear and seems arbitrarely" *lease e&plainprotocol or change the way information ispresented without shattering"

Ce have restored much ofthe e&planatory te&t to themain chapter and nowthin! the division betweente&t and Appendi& iscoherent"

The appendices are misplaced and should beincluded at the end of the agriculture chapter (i"e"after 3) in future drafts"

,t ma!es more sense tohave the Appendicescloser to the main te&t

A clear guideboo! definition of 4,nhalable dust4 and4espirable dust4 are needed"

9iscuss with D - put intothe chapters

Appendices will re+uire revision. since somematerial will be moved from the current appendicesbac! into the body of the te&t



Accepted

$aption# 4aerodynamic4 instead of 4airodynamic4 'oted

e7ected

e7ected4measured4 instead of 4made4 ditorial 9one

'oted

Accepted

e7ectedlandspreading instead of spreading Accepted done

Accepted eference now given

Accepted %entence e&panded

Appendices will re+uire revision. when commentsabove have been ta!en into account

Appendices have beenrevised

D - is this correctG ,s thisyour graph to changeG

This paragraph appears to be misplaced" %uggestre-wording

*anel $hairs are happywith te&t

why the information here are related only tograHingG

<ecause this is the Appendi& where weinclude specific additionalinformation

For cattle housing system values on pm1 F arelower for litter (Nsolid manureNFU) compared toslurry" This is in contradiction with the te&t on page33 line 8? (section *). which says that it ise&pected to find higher pm1 emissions from littercompared to slurry" This was also found comparingnglish dairy cows with litter to erman dairy cowsin cubicles (slurry)"9irectly below this alinea (page 3I line ?) this isonce more contradicted by the remar! that cubiclehouses (slurry based) give higher pm1 emissionscompared to litter based systems (depending onseveral factors)" This is in line with the presentedpm1 emf" /owever. no reference is presentedhere" Chere are the default pm1 valuespresented based on thenG,t is recommended to rewrite this te&t to present aclear line of reasoning"

,n a deep litter system * emissions can bereduced by I because the dust is incorporatedinto the bed and held there because of moist"

Activity of animals will not have an effect anymore#$,-wor!ing group 'o 18 4$limatiHationnvironmental $ontrol in Animal /ousing4" 1JJ3"

Aerial environment inanimal housing" $oncentrations in and emissionsfrom farm buildings" $,-rapport eport %eries'o"J3"1. $AF. roupement de ennes.ennes $ede&. France. 116 pp"#

/ave incorporatedcomment" 'icola. couldyou as! T': for the fullreference to $, 18.authors etc. it seems tohave got cut off in cell /3?

Chy this sentence is here and not at page 36under educe emissions during and afterlandspreadingG

<ecause this is where wediscuss management

please give the source of table A2"1. &pert roupon Ammonia Abatement

4missions following (the) spreading (of)manuresL""4



Accepted eference now given Asteri& and 4a>4 not e&plained Accepted 'ow e&plained

Accepted

e7ected

e7ected

Accepted 'ow added

Accepted

Accepted All countries now full te&t

Accepted

'umbers in heading not e&plained e7ected 'umbers now deleted

Accepted ade clear it is TA'

please give the source of table A2"2. &pert roupon Ammonia Abatement

it has to be specified which values are e&pressedas TA' or total '

TA'. Table headingcorrected

Table A8-1 Chere is the note e&plenationG

eferenceG

The notes are redundant

and have been deletedThe notes in the table (1.2.8 in the first row of thetable) are not e&plained

The notes are redundantand have been deleted

Table A8-1 There is no te&t ontroducing the table",n which way can this table be usedG

For '/8 as far as dairy cows and fattening pigsare considered. the figures presented in theappendices should be the same as thosepresented in the publication of eidy et al. 2@" ,n

general this seems to be the case" /owever. thereare some deviations" %ome e&amples#

in Appendi& Table A8-1 b storage a figure of1J"2 is presented for dairy cows in the'etherlands. while in the eidy et al. 2@publication a value of 16"8 is presented (for bothmodels)" ,s the value of 1J"2 wrong or is it basedon another publicationG

in Appendi& Table A8-1 graHing for the'etherlands and the ; a figure of 18"8 and @"@ ispresented for dairy cows respectively. while in theeidy et al. 2@ publication a figure of 18"6 and1" is presented" in Appendi& Table A8-1 housing for the ; afigure of 88"2 is presented for fattening pigs. whilein the eidy et al. 2@ publication a figure of ispresented"Ce recommend to present and provide allreferences used"

eferences for eachnational ,nventory nowgiven in the Appendi&

se full te&t or abbreviations of countries. not both('etherlands N ' and not 'l)

the title of table A8"1 is misleading with repect tothe F. or it is of TA' either of total 'available" aybe an additional column is desirable"*lease give also the corresponding references

/eading clarified.references given

Are the emission factors e&pressed as TA' ortotal ' available"



Accepted

Accepted

Accepted

'oted

'oted

'oted

'oted

'oted

/yphenation 4Fattening pigs4 e7ected

For *1# ,t seems from table A8-I that the F for dairycattle are valid for dairy cattle with a weight of I!g" %o if there is information on the mean weight of

cattle categories a recalculation could be made"/owever. Table A8-8 and A8-I are not in line witheachother# according to Table A8-8 calves have aweight from I-1 !g. while in Table A8-I theyhave a weight of 1I!g" <eef cattle is notmentioned in Table A8-8" %ince young cattle in thisTable has a weight between 3I and 6I theycannot be compared with the beef cattle in Table

A8-I (weight of 8I !g)" ,t is unclear what transfer factor should be used"For young cattle it says in Table A8-8 "6 till 1"2K sofor the lower weight of 3I !g the lower transferfactor of "6 should be used" <ut in Table A8-I forbeef cattle with a weight of 8I !g a conversionfactor of "@ is used5 For cattle it is unclear whether in the F pm1presented the time spend in the meadow is ta!eninto accountG ,f it is. how has this been done" Andif it hasn0t how should this be doneG

The tables are nowconsistent in their use oflivestoc! weights

please change the liveweight for calves into I to8 !g

calf weight now I-1I.transfer factors scaledaccordingly

Transformation factors for poultry don0t ma!e

senseG

These factors aree&plained in the te&tabove" The uncertaintyand need for more wor!

are ac!nowledgedthis reviewer does not agree with the conversionfactor of 1" for poultry" Ta!ay et al. 1JJ? givesinformation over the conversion factors even forpoultry"

4%eedorf and /artung. unpubliched4 - cant findthis reference on the reference list"

the conversion factor for fattening pigs is here "16and in table A8"8 "12" *lease change it into "12

A lot of F values for *2"I are physicallyimpossible" 9 is measured as *I" and shouldtherefore be higher then *2"I" %o. please lowerthe *2"I values for dairy cattle. beef cattle.calves and weaners

as a conse+uence of the remar! on conversionfactor of 1". the *1 and *2"I values forlaying hens and broilers should be lower

'ot hyphenated anywhereelse



e7ected

Accepted 9one

Accepted

e7ected

Accepted

Accepted

e7ected

Accepted

e7ected

Accepted

Chat are information in Table A8-@. Table A8-J.Table A8 and Tbales on page I@ used forGG

To provide supplementaryinformation

*assive composting# for the ,*$$ e+uivalentseems more appropriate 4$omposting - passivewindrow4

Chat is reference for the values in this tableG As aeneral comment , want to add that literaturereferences are sometimes given. but not always"

Table heading now givenand referred to in te&t"

, suggest to consider including all ,*$$ referencesright in the te&t

,t should be considered to move some of the morescientific description in appendi& to the main te&t""g" e&plaining why the ':$ emission is animportant environmental issue"

/ave restored much of thete&t to the main chapter

,t is nessary to e&plain much more in detail the

difference between Tier 1 and Tier 2 in theemission factors because they are sofundamentally different" ,s '/8 in Tier 1 convertedto '/8 from '/8-'G %pend much more space one&plaining the emission factors in Tier 2 and thedifference between slurry and solid" &plain why'/8-' is used in Tier 2 compared to Tier 1"

The restoration of te&t nowgives more e&planation

,t is a big confusion between '/8-' and '/8"%ometimes is '/8 reported and sometimes is'/8-' reported" *lease clarify"

There is no confusion. Tier2 calculations have to beas '. but reporting has tobe '/8-'

The chapter on manure management is not verywell written" There is a strong need for clearreferences. a better e&planation of the comple&system with ' and ammonia" ,t loo!s li!e that thereshould be no dublicate between this guideboo!and the ,*$$ 26/owever. for clarification therecould be some tables on 'e& for typical animaltypes" %tabletype distribution from the A,'%dataset etc" to give more information on the basicsituation in many countries" And reduce thenumber of tables because they are reallyunessesary in many cases"

uch of the original te&thas been restored toimprove clarity

eneral comment" 'ational agriculture inventoryconsistency ($TA*-'F$$$)# ,s this new$:,'A, update methodology (Tier2) for manuremanagement compatible with the ,*$$ 26G

eneral# eference to Appendi& A (see Appendi& A) is not conse+uently done loo!ing atcorresponding chapters in the appendi&. pleasechec!" Also chec! table numbers

These cross referenceshave been corrected"'icola. when finished canyou double-chec!"



nits for * are wrong not !g '/8 ditorial

ditorial

eneral# , miss Table with notations ditorial

e7ected

e7ected

e7ected

e7ected

e7ected

e7ected

e7ected

e7ected


eneral# eferences to tables and figures in thete&t are not correct. please chec!"



Accordning to the reporting purposes Tier 1 andTier 2 methodologies will be used" For comparisionneeds it will be necessary to recalculate theemission values

9on0t understand what ismeant by the comment" ,tis no more than astatement not appearing tore+uire an answer"

Accordning to the reporting purposes Tier 1 andTier 2 methodologies will be used" For comparisionneeds it will be necessary to recalculate the

emission values

9on0t understand what ismeant by the comment" ,tis no more than astatement not appearing to

re+uire an answer"









Accordning to the reporting purposes Tier 1 andTier 2 methodologies will be used" For comparisionneeds it will be necessary to recalculate the

emission values

9on0t understand what is

meant by the comment" Accordning to the reporting purposes Tier 1 andTier 2 methodologies will be used" For comparisionneeds it will be necessary to recalculate theemission values

9on0t understand what ismeant by the comment"



e7ected

e7ected

'F8 3"9"1 is not agricultural soils" ,t should be 3"9 Accepted 9one,nconsistent citation of references" Accepted 9one

e7ected

Accepted

e7ectedditorial comment not removed Accepted 9one

'oted

Accepted

,n the overview harvesting is missing Accepted /arvest mentioned in 2"1"3this appendi& is missing Accepted

missions occur from both soil and crops5 e7ected

Accepted

'oted

Add more detail about processes e7ectedadd also in the heading# for -2@ Accepted 9one





%ame remar!s in generall as given for 3"<" , amnot happy with th *

,n the absence of concretesuggestions forimprovement""

%pecify where have to be reported emissions fromgraHing animals" ,t is not clear if they have to be

calculated and reported under 3< or calculatedunder 3< but reported under 39" The same formanure application

Te&t inserted to e&plainand cross-reference

'F 39 and $F 39 codes do not include thesame source categories# Application of manure tosoil and production of animal manure in themeadow is not included in 'F 39 while it isincluded in $F 39"

$lear e&planation given inte&t

*ersistent :rganic *ollutants - what could this e"g"includeG

,n the overview emission from legumes is

mentioend" ,n the te&t separat '/8 emission fromlegumes are only included in Tier 8 approach - isthat correctG

F for legumes nowrestored

Te&t already includescrops

eference to the chapter where they are dealt withis missing"

the *1 emissions reported in the table N arein contrast with the sentence page 28 line 88"9oes the value N in the table mean that theemissions are not estimatedG

/ave changed data using

updated webdabemissions sent by AnneCagner" ':$emissions are now at 3of total so is in contrast towhat it said in the previousparagraph"

The detail is found in thete&t below



'oted 9one

Accepted

Accepted

Acceptede&plain the variables Accepted 'ow done

A paragraph on ': emissions is missing Accepted 'ow insertedappendi& 3. where is itG 'oted ,ncluded in this version

and soils0 should be added to title Accepted

The appendices have disappeared5 Accepted

'oted ,ncluded in this version

Accepted 'ow deleted

Accepted yes"

Acceptednothing found about *m Accepted Te&t restored$A' not e&plained Accepted ,t is now

9elete process diagram - deal with processess bypollutant not source

ood figure to give an overview. but maybe moreuseful to describe the different emission sourcesbased on each substance"

arlier te&t now restoredas appropriate

The mission section should be e&panded andstructured according to pollutant not source",nclude some of the omitted te&t from earlier drafts


'eeds much more scientific bac!groundinformation on emission of ':. ':$ and *"


'o longer relevant sectionhas changed"

*ossibly no longer

relevantG A paragraph on * emissions from soil cultivationis missing

%uggest removing the sentence 4The effects of fsfrom grasslandLL4

'/8 emission from growing crops are mentionedin section 2"2"8" Are this '/8 emission short afterapllication of fertiliser included in therecommended Tier 2 emission factorsG

This reviewer does not understand why a doubleF for grassland is needed in comparison witharable land" There are also arguments that the Ffor arable land is higher due to for instance theabsence of a canopy" *lease give moree&planation"

ore e&planation nowgiven in te&t



'oted

e7ected

Tier 1 method for unfertilised legumes is missing Accepted

e7ected 'ot Tier 1

Accepted Te&t amendedThe 8 in '/8 should be subscripted Accepted 9one

Accepted

e7ected

'ew Yealand in which losses from urea applied tograssland and arable land were compared" Thepaper of /arrison and Cebb (21) is a reviewpaper" /owever. they only refer to the paper of ander Ceerden and Darvis (1JJ@)" Thus. thedifference in the emission factor betweengrassland and arable land is based on only study"

<y contrast. in a review <ouwman et al" (22) of13? research papers it was concluded that themean '/8 emission from grassland is 2 lowerthan for upland crops (the balanced medianshowed almost no difference)" This paper was notused for the guideboo!"Thus. there is no firm scientific basis to usedifferent emission factors for grasslands andarable land" The grassland area in urope is highand therefore the underpinning of higher emissionfactors for grassland must be scientifically sound"oreover. from a theoretical point of view (i"e" theeffect of crop on wind speed and thereby on '/8emission) it may be e&pected that there are arablecropping systems with lower emissions (i"e" when' fertiliHer is applied to high crops or when 'fertiliHer is incorporated) and higher emissions (i"e"when ' fertiliHer is applied to the bare soil 7ust afterplanting or seeding)"

why the fs of the different fertiliHers which wherereported in the old $:,'A, handboo! are notused hereG The consumption of the differentfertiliHers is normally available at a national level.so a better estimate is possible

Tier 1 agreed with *anel$hairs

The F for legumes now inthe te&t

9eafault values in the body of the te&t and detailedtables according to the needs as an appendi&"

According to FA consumption for 26>. urea isthe third most used. after $A' and A'

se chemical notation not words (e"g" forammonia)

%ection has been re-written but instances ofwords rather than chemicalnotation

The unit for ':$ is defined as !g ':$>!g

crop - is it !g harvest cropGG The e+uation (page 6.line @-?) is mentioned use of crop area (haGG)

eference now made to

the Appendi& where moreinformation is provided"



Accepted

Accepted

Accepted

e7ected

A default emf of 2"I@ !g ': per !g fertiliHer-'applied is presented (reference %teinbrecher et al.2?)" ,t seems the wrong unit is used here" ,f2"I@ is meant (N 2I"@ g>!g fertiliHer ') it is not

clear how this could be in line with the value of "@ ':-' (e+uals "J ':>!g fertiliHer N J g ':>!gfertiliHer) presented by %tehfest and <ouwman(26) and until now also presented in theuideboo!"The value of "@ is the fertiliHer induced emf. but inthe former uideboo! also for cultures withoutdirect fertiliHer (but with crop residues and indirectemissions as a conse+uence of ammonia-'deposition and '-leaching from fertiliHer use) thisvalue is recommended to be used"

Chy is this value presented with 2 decimal placesKthis seems unrealistic concerning the high

uncertainty for ': measurements"

'icola.please change in

template to 2"6eneral remar! on '/8# Appendices A1-A3 arenot included. so information on assumptions is notavailable"

Appendices are now in thechapter

ore specific on '/8 (Table 8-1) Tier 1 values are no longer

presented for other fertiliHer types than urea" Forcountries where urea is not commonly used asfertiliHer and where not enough data are availableto use the tier 2 method also tier 1 emf for the

different types of fertiliHer should be available" ,nthe former guideboo! also tier 1 emf werepresented for other fertiliHer types (pJ table 3"1 ofthe uideboo!)" ,t is recommended present tier 1emf for the different types of fertiliHer" This couldbe the former emission factors or new tier 1 emfderived for different fertiliHer types from the tier 2values"

,n the past the urea emf was "1I '/8-'(e+uals "1? '/8 per !g fertiliHer ' applied)"<ased on the current proposed tier 2 method forurea emf the mean value would be "28 (mean oflowest and highest values for all regions and forgrass and arable land# ("11 V "8I)>2)" For region< it should be " 21 (("13 V "2?)>2)# Chat0s thebasis for "22G



'oted

Accepted

e7ected

'oted'o e+uation for Tier 2 methodologyG Accepted +uation now restored

'oted done

:n basis of table 8-1 in the proposed uidelines itis unclear whether the proposed *1 emissionfactor should only be applied to arable land or alsoto grassland (at the presentation in 9ublin also hayma!ing was mentionedK this seems to refer tograssland) and whether the application of fertiliHer

and pesticide use is included" ,t is recommendedto ma!e this clear"The basis for the presented T%*. pm1 and pm2.Iemf (Table 8-1) should be the reference publicationd /oe! and /inH (2@)" /owever. this basiscannot be found there#

'o basis at all presented for T%* and pm2.Iemf

For pm1 emf the basis is unclear" From Table8 in the eference publication it seems that forpm1 the highest value (eg 3"I6 !g pm1>ha foroat with no reduction applied of for redeposition ofpm1 on the field) is pic!ed to be used as a defaultfor pm1 (3"I in Table 8-1)" /owever. this is not

clearly e&plained and some +uestions rise if this isthe case#-Chy is the average value of "2I (for soilcultivation) in eference Table 8 (and discussed inthe te&t on page 1?) not in line with the figures onsoil cultivation presented in Table 2G /ere evenwith wet soil conditions the total pm1 emf for soilcultivation is I.2 !g>ha" That0s a factor 2 higher5-Chy is no correction term applied for rapid nearsource depositionG-Chy are the harvesting emf in Table 8 lower(between 2" and 8"3 !g pm1>ha) compared tothe values presented in the te&t on p 1? (lowestvalue 8"8K highest 6"J)"

-Chat0s the basis for the values for cleaning anddrying in Table 8

The reference publication (vd /oe! /inH. 2@)mentioned is not easily attainableK , had toapproach one of the authors to get it" :n basis ofthe reference it seems hay ma!ing is not included"FertiliHer use seems to be included. but it is notclear" *esticide use is not included" ,t isrecommended to ma!e the references available"

A revision of the guideboo! should include thenewest !nowledge and lead to more accurateinventory" , was surprised that the '/8 Tier1methodology is simpler than given in the oldguideboo! and the emission factor is only basedon use of urea"

+uations and legends# inconsistent notation. notin line with ,*A$



e7ected

'oted

Accepted

'oted

limiting fertiliHer to urea only is a step bac!wards Accepted 'ew Tier 1 F developed

Acceptednit for particulates should be !g ha-1 a-1" Accepted 9one

Accepted

e7ectedTier 2 e+uation is missing Accepted 9one

,n tables 8-1 to 8-13 emission factors for '/8 arepresented for the different fertiliHer types" ,tsuggested that these emission factors are allderived from /arrison Cebb (21) and an derCeerden and Darvis (1JJ@)" /owever. the+uantification of the effects of temperature and p/on the emission factors is not found in thesepapers",n the review paper of <ouwman et al" (22)effects of crop type. fertiliHer type. applicationmode. ' application rate. temperature. p/. andother soil properties on '/8 emission arestatistically assessed" This paper maybe avaluable source for the guideboo!"eference# <ouwman et al" (22) stimation ofglobal '/8 volatiliHation loss from syntheticfertiliHers and animal manure applied to arablelands and grasslands" lobal <iogeochemical

$ycles 16"*lease indicate clearly in the te&t that the '/8emission N 1@>13 S F"

The ': emission is 2"I@ !g ': per !g fertiliHer 'applied" This means that more ' is lost than the 'input by the fertiliHer" This is +uite impossiblebecause about I of the ' fertiliHer is ta!en upby the crop

The F should be g>!g -'icola. can you pleaseamend in the templatetable"

,t is necessary to e&plain in the te&t how the F forT%*. *1 and *2"I are derived" ,f necessarythe reviewer will assist"

, do not agree with the use of the urea F as thedefault F" The previous approach in the simpemethodology in the old uideboo! should bemaintained" ven though the use of urea accordingto world fertiliser consumption statistics is currentlyappro& I of total ' consumed. it does notwarrant its use as the default" any counties useurea only in the spring when weather conditionsare wet and cold and therefore emissions are low"sing urea as a default in such circumstances

would lead to a gross over estimation of emissionlevels"

at which depth the soil temperature has to bemeasuredG

Te&t amended to ma!eclear it is air temperature

ore e&planation on how to use and apply newproposed F is needed as done also in tier2 3<"



Accepted

Accepted

Accepted

e7ected

Acceptedabatement without note with * concern Accepted Te&t restored

Activity without concern of *. area treated. yields e7ected

section 2"1"1 where is itG Accepted

e7ected

e7ectedsoil ' content# where is it usedG Accepted 'ow deleted

e7ected

Accepted

Accepted

Accepted

Tier 2 emissions should be calculated using theactual spring temperature" eplace e+uatoin andthe original compact version of e+uationparameters" &ample emission factor tables couldbe put into an appendi&

:riginal compact tablenow restored

,t is a bit confusing with so many tables showingthe emission factor for Tier 2 - mineral fertiliser" ,s itpossible to reduce the number of tablesG ,nsteadof a table for each fertiliser type. it could be chosento show a table from each temperature region A. <or $ (t O18 $. TN6-18 $ or t W 6 $)"

Tables are confusing and should be presented in acondensed form"

$oncise tables have beenrestored"

$ontrolling emissions has already been covered onp 3 and I

Ues. but this e&plains howaccount may be ta!en incalculating emissions

sing A' instead of urea may reduce The ':emission" 9efinition of A'GG

Abbreviation now definedat first point of mention

Te&t changed. no longerrelevant

This section has beenadded

The sentence on e&pert 7udgement is not related toconsisten time series. maybe more to ncertainty

,n this specific case e&pert 7udgement may be neededfor a consistent time series

,t is not necessary a specific chapter 3"I"1. put thesentence under line 21

This is the agreed format

for each uideboo!chapter

,s the mentioned uncertainty range (V-I) for allsubstances e&ept from ':$G The uncertaintyrange for ': and * emission is properly muchhigherG

To e&plain the differences between the defaultvalue and tha national value. a robust bacgroundinformation and documentation for the defaultvalue is needed" :therwise you do not support and

promote the meber states to use national values"

9on0t understand the point

that is being madeis the temperature. which is necessary for tier 2.the air or the soil temperatureG

Air temperature nowspecified in the te&t

,FA - please write the name of the organisation(maybe in chapter I 4lossary4)" Are data from thisorganisation available for all member states forfreeGG

'ow given in full in thereference list



Accepted

$itation inconsistent (e"g" 4and4) Accepted

Accepted

Accepted

Accepted 'ot Tier 1

Accepted

'oted

'oted 'ot Tier 1'o guidelines availableG e7ected 'o page reference given

e7ected 'o page reference given

,nconsistent citation of references" Accepted

The reference list include a lot of references whichis not mentioned in the main te&t" , prosume thislist include the references from the appendices5

The references have nowbeen sorted following thevarious revisions of thete&t"

$itations were consistentin that two authors used

4and4 and more than oneauthor was bloggs et al

For ': the reference %tehfest and <ouwman(26) is included in the references (howevermisspelled as %tefest and <owman). but notmentioned in the te&t"

%pelling in reference listcorrected and relevant te&trestored

issing Appendi& A5 There are lin!s to this acouple of places" ,tMs hard to 7udge references toactivity data when the appendi& is missing"


<y reading of the draft , really missed theappendices - especially because the main te&tdoes not content many references or scientifice&planations" At my point of view more specificscientific description and e&planation is needed inthe main chapter" ,t is very important to !now thescientific documentation for the default value"Theguideboo! should not only be useful to calculatethe emission inventory.but also a guideline to findmore scientific information to chec! the conditionsare comparable with the conditions in the member

states and to encourage member states tocontinue the wor! to develop more accurateinventory with national data"

That each answer ma& can be 2II characters isvery frustrating


,t is rather strange to find an 'F 392 here(animal production) since this source is notincluded in 'F39 but in 'F3<



'oted A is not defined Accepted 9one

Accepted

F for '/8 missing from table Accepted

A source published in 1JJ1 is inade+uate" Accepted

'oted

'oted

'oted

'oted

Accepted

Accepted

To my !nowledge is there no -regulation on agr"waste burning. only national legislation" Thisshould be verfied" The te&t indicate that it is veryeasy to burn agr" crop residues and waste in9enmar!" This is not the case" <urning of plant

residue has been prohibited i 9enmar! since 1JJand may only ta!es place in connection withcontinuos cultivation of seed grass"

Ce !now. the ob7ect was

to point out that undersome circumstancesburning may ta!e place

$ouldnMt the lin! to FA: *roduction Uearboo!(FA:. 1JJ1) be updatedG

Ues. up-to-date referencegiven

D - should there be any fsfor '/8 in this chapterG

Ues. up-to-date referencegiven

Table 8-1" There should not be different units in atable. ie"!g> !g dry matter and !g> tonne" ,t will giveerrors in the reporting

The comment specificallyrefers to agriculturalactivity data. so referenceto forest fires is irrelevant

Table 8-1" There are errors in the data" enerallycontains crop residues (straw) .8 ' or e+v" to1"2 ':& after burning if all ' is emitted as ':&"Tier 1 indicates that 23 is ':& or that at lot ofinert '2 is conveted to ':&"

<ecause they are notneeded for the calculation

,f default '>$ ratios are given in the ,*$$guidelines why aren0t they included in table 8"2

which have the same originGTier 2 does not appear to provide the basis ofbetter estimates than Tier 1" emove Tier 2

9efault data is not ta!en from ,*$$ 26 but from,*$$ * 2

D - have changed this intrac! changes. is this thecorrect referenceG

The source data is ta!en from ,*$$ guideboo!.* 2 and not from ,*$$ 26" $rop>cropresidues has been changed very much from *2 to ,*$$ 26" %ee Table 11"2 i the new

guidelines for data" * 2 is not appropriatefor uropean conditions"The authors of these'$$-guidelines should read %trehler and%ttHle" The paper is about utilisable biomass andnot field burning and based primarily on conditionsin the praerie in the %"The figure should be usedvith caution especially under uropean conditionswhere there is other crop>crop residue ratios due tohigh fertilisation rates"



'otedChere is nitrogen mentionedG 'oted

%ouce in not in the table Accepted

'oted

ditorial

ditorial

Table 8"2 is dublicated e7ected

'oted

'oted

Accepted,ncorrect %'A* Accepted

'oted

'oted

Three years average should not be used if wewant to model the emissions in short time spans"%hould then forest fires be averaged over threeyears tooG Averaging is not in line with the new,*$$ guidelines

Tables should be combined" :mit superfluousinformation"

The value is app" the same as for Tier 1. but now itis in g>D not in !g>!g dry matter" %ee my commentpage 3 line 1"

$hanged bac! to !g>!g drymatter

Three different nits are used for the same source(wheat straw)" This is also true for the other tables

$hanged bac! to !g>!g drymatter

, can0t see what thisperson is tal!ing about

Chy should Tier 8 be aggregated at a sub-nationalscale to fine grid scale if the data>model issuperior" ,t is a direct copy from ,*$$$ 26 andmaybe not valid for '$ conditions"

The chapter was based onthe information available

eneral# The chapter gives an impression of lac!of agricultural !nowledge and is more or less acopy and paste of the ,*$$ guidelines

'o. , sourced the datafrom 26

The mentioned cases in the te&t are seldom. and itis very difficult to burn rotten straw. so theimportance is very limited"

y mista!e. in convertingfrom . these F are all&1 too big" $an youplease reduce

This statement is indeed very surpising given thatmany pesticices are considered as *:*s (whereagriculture use is the only source)" *lease properlye&plain *:*s in the conte&t of this chapter

'F category include %'A* 16 4se ofpesticides and limestone4 - but in the te&t4overview4 is mentioned that this sector ia a 4catchall4 for the agricultural sector" %o this 'F categorycovers more than %'A* 16" ,n the 9anishinventory this sector covers sewage sludge. whichare used as fertiliser and applied on agricultural

soils"



'oted

'otedThe chapter is incomplete" 'oted

Accepted 9oneadd 4. '/84 after 4$:4 Accepted 9one

Accepted 9onesubstitute 4very minor4 with 4minor4 Accepted 9oneadd 4. '/84 after 4$:4 Accepted 9one

Accepted $orrected

Accepted $orrectedtoo less e&planation. only reference to / 'oted

For use of pesticides no method is provided" 'ewmethods are available in the 'etherlands and the which could be refered to# 'ie (22). indenet all (26). and inden et all (2?K in

preperation)

'ie 9% de (eds). 22missie-evaluatie D*- 2K Achtergronden enbere!eningen van emissies vangewasbeschermingsmiddelenQ missions of plant protection products to theenvironment" valuation of the policy goals of theong-term $rop *rotection *lan R, apport @16613

inden AA van der. <eelen * van. <erg A vanden. <oer de. aag 9D van der. roenwold D.

/ui7smans DF. ;alf 9F. ;ool %A de. ;rui7ne .er!elbach $. %noo de. i7ftigschild A'.i7ver . Cal AD van dervaluatie duurHame gewasbescherming 26#milieuQidterm evaluation of the plant protection policy ofthe 'etherlandsK environment R, rapport 6@161

,n preperatationinden AA van der. roenwold D. ;rui7ne .utti! . er!elbach $9utch nvironmental ,ndicator for plant protectionproducts. version 2

,nput. calculation and aggregation procedures, eport 6@62>2?

$hapter should be supplemented# now in containsheadings. one table without F. one literaturesource"

Add# 4Also * emissions from waste handling aregenerated but no estimate of emission factors isavailable"4

Add# 4Also * emissions from waste handling aregenerated but no estimate of emission factors is

available"4

An incomplete and une&plained algorithm is givenfor emissions from pulp and paper onlyG

why process emissions from pulp and paper in thisconnection G



Accepted 9one

Accepted 9one

'oted

Accepted Added to references

Accepted

'oted

The chapter is incomplete" %ee e&amples below 'oted

Accepted

Accepted

'oted

substitute 4missions are considered to benegligible in most cases"4 Cith 4%mall +uantity of':$ and nitrate compounds are emitted" For':$ % *A evaluate that J?.@ of landfillgas is methane and 1.8 other :$s such asperchloroethylene. pentane buthane. etc" (*A.

1JJ)" Also * emissions from waste handling aregenerated but no estimate of emission factors isavailable"4

change position of '/8. T%*. *1 and *2.I in4not estimated4 section

no emission factors estimated or applicable" 'oteven for ':$ and $: """, miss some support"

':$ estimated nowfrom ; inventory

% *A (1JJ). Air missions %pecies anual.olume ,K olatile :rganic $ompounds %peciesprofiles. %econd dition. *A-3I2-J-1a.nited %tates nvironmental *rotection Agency.

:ffice of Air =uality *lanning and %tandards.Danuary 1JJ

An estimate of ':$ emissions from landfillswas made using an emission factor of "1 t':$> t methane produced which is e+uivalentto I"6Ig ':$> m8 landfill gas (; inventory.23)"

F used as Tier 1 defaultF

F should be defined depending on the !ind ofwaste deposited

$hapter should be supplemented# now it contains2 tables. including one table with one emissionfactor (for '/8) and list of eferences with 2sources"


$hapter discussed inmeeting with $, &pert*anel eader" atrinesmoved to Tier 2" Tier 1 Ffor ':$ estimatedfrom one of the suggestedpapers"

An aspect of importance not described in thischapter is the importance of industrial effluents tothe sewer system and i"e"contribution to thecentralised CCT*s and i"e" ':$ emissions"

':$ from CCT*mentioned

':$ emissions may occur during sewagecollection and are very dependent upon treatment

processes at different stages at the CCT*s (seerefs row28-8I))

%ome te&t about this issuehas been added

The chapter states that it focusses on biologicaltreatment plants. however. the te&t deals in nodetail with biological processes anddephosphoriHation is a chemical process

Te&t ta!en from former<K adapted to fit better inrevised chapter



'oted

'oted

'oted

Accepted

Accepted

Accepted

'oted

Accepted

'oted

The chapter states that 0':$ and '/8 is ofminor and only of local importance0 as compared tolandfills where these emission are referred to as0emitted in smal +uantities0"

From the ,nventory of "%" reenhouse asmissions. however. it may be observed that theemission of ':$ from wastwater treatmentprocesses are a factor two of the estimatedemisions from landfillsK ranging from I@ to 6? g>yrin 1JJ and 21"

,nformation on ':$addedK see othercomments

The te&t on latrines(http#>>reports"eea"europa"eu>*$:,'A,3>en><J1@vs2"1"pdf) are overpresented compared tosection 2"1 considering the relevance of the twoactivities

change position of '/8. and ':$ in 4notestimated4 section

rase '/8 F and related information and changeposition of '/8 and ':$ in 4not estimated4section

9one following discussions

with $, *" A Tier 1 for':$ has also beenderived

, don0t thin! the similarity of latrines with animalswas correct and then latrines are not e+ual to4waste water treatment plants4" %ubstitute 4Thedefault emission factor for ammonia from wastewater handling is provided in Table 8-1" ,t is e+ualto the estimated emission factor for ammonia fromlatrines. which has been determined from thesimilarity between latrines and open storage ofanimal manure in lagoons or ponds (uideboo!.26)"4 with 4Also '/8 and ':$ emissionsfrom waste water handling are generated but noestimate of emission factors is available"4

9one following discussionswith $, *" A Tier 1 for':$ has also beenderived

Air emissions of *:*s as well as ':$s. $:and ammonia are occurring eventhough maybe atinsignificant levels. still not very well investigated"/owever some scientific studies do adress suchemissions"

%ome info added tochapterK see earliercomments

&amples from the scientific literature documentingsuch emissions of aromatic and halogenatedcompounds from urban CCT*s are %ree et al.

2

%ome info added tochapterK see earlier

comments

:s!ouie.A";". ordi. 9"T". ranato. T"$" and;ollia. " (2?)" *lant-specific correlations topredict the total :$ emissions from wastewatertreatment plants"Atmospheric nvironment. ,n*ress. $orrected *roof. Available online 18February 2?"




'oted

'oted

'oted

'oted

'oted

'oted

'oted

'oted

'oted

'oted

<aillod. $". $rittenden. D"$". ihelic. ". ogers.T"'". rady. $"*"". 1JJ" $ritical evaluation of thestate of technologies for predicting the transportand fate of to&ic compounds in wastewaterfacilities" C*$F research Foundation *ro7ect J-1"

$AAA" "%" *A. 1JJ"


comments$orsi. "". $ard. T"". 1JJ1" stimation of :$emissions using the <aste model" nvironmental*rogress 1 (3). 2J"


9obbs. "A". Cang. ". ovind. ". 1J?J" %orptionof to&ic organic compounds on wastewater solids#correlation with fundamental properties"nvironmental %cience and Technology 28 (J).1J2"


aster et al"" :dor and air emissions control usingbiotechnology for both collection and wastewatertreatment systems" $hemical ngineering Dournal.

olume 118. ,ssues 2-8. 2 :ctober 2I. *agesJ8-13

%ome info added to

chapterK see earliercomments

scalasa et al" Time and space patterns of volatileorganic compounds in a sewage treatmentplant"Cater esearch 8@ (28) 8J18-8J2


,n urban areas. :$ emissions from CCT*s maybe a significant fraction of the total hydrocarbonemissions


whereas the corresponding ':$ emissionsfrom whole Austria were reported as I (2I t

yr) of the total anthropogenic ':$ emissions"


comments

more focus should be given to rban wastewatertreatment plants and separate industrialwastewater treatment plants"(see references ascommnt to list of reference below. page 6 line ?)


According to the ,**$ guidelines such releasesinto the domestic sewer system should be includedin the 0Caste water treatment inresidential>commercial sectors0"


Air emissions of ':$ prevails in pre-treatmentand primary clarifiers. whereas biodegradation andsorption compete in aerobic biological reactors"""

Air emission prevails in secondary clarifiers (e"g"scalas et al" 28. Cater esearch 8@. 8J18]8J2)"




'oted

'oted

'oted

'oted

'oted

'oted

'oted

'oted

'oted

'oted

Accepted $orrected

ost plants have highly techological developedprimary. secodary and tertiary treatment processesincluding mechanical. chemical. biologicalanaerocic and aerobic processes and emissionmay occur at several stages of treatment"


eference for inspiration# *" Tata. D" Citherspoonand $" ue-/ing. ditors. :$ missions fromCastewater Treatment *lants# $haracteriHation.$ontrol and $ompliance. ewis *ublishers. <ocaaton. %A (28) ,%<' 1-I66@6-?2-J. p" 31I


<:9 characterisation . which is the main sourcefor ':$ emission. is totally missing in analogyto the missing precess descriptions which arepotential for ':$ emissions as well as *:*s"


eference for statements in row 26 to 2?# Atasoyet al" (23)"The estimation of ':$ emissionsfrom an urban-scale wastewater treatment plant"Cater esearch.olume 8?. 826I-82@3


latrines are not relevant at all for many uropeancountries

'/$ or non-methane :$ may occur forcontrolled as well as uncontrolled aerationprocesses"

%ree. ". <auer. /". Fuerhac!er. ". llinger. ".%chmidt. /" and *u&baum. /" (2)"

/ydrocarbons missions From Aunicipalwastewater Treatment *ilot *lant ,nienna" Cater. Air. %oil *olution. 123. 1@@-1?6


%chmid. /". <auer. /". llinger. ". Fuerhac!er.". %ree. " and *u&baum. /" (21)" missionsof ':. T:$. $:2. and aerosols from a pilot-scale wastewater treatment plant with intermittentaeration Atmospheric nvironment. 8I. 16J@-1@2"


Cua. <"-Y". Fenga. T"-Y". %reea.". $hiuc. ;"-/"and oa. D"-" (26)" %ampling and analysis ofvolatile organics emitted from wastewater

treatment plant and drain system of an industrialscience par!" Analytica $himica Acta . I@6. 1-111


For e&ample. ':$ contribution from CCT*s inienna. as an urban area. was estimated to bearound @"I of the total anthropogenic ':$emissions L


lossary. A production - the A for the limeproductionG



Acceptedrror of table 8-J Accepted $orrected

Accepted $orrected

Figure 2-1# scheme is too simplified" e7ected

Accepted 9one

Tables 8-1] 8-6# /$< and *$< emission factorsare the same (in spite of the abatement)K ':&. $:and %:& F are not harmoniHed. as well as T%*"For e&ample# T%* F in the Table 8-1 (Tier 1) isthe same with F in the tables 8-3. 8-I and 8-6

(Tier 2. different abatement. including <AT)"

$onsult with

&pert *anel

9ifferences in abatementKliterature references arenot complete" This causesdifferences" /ow else to

deal with thisGGG

Table 8-1" According to the '* Tool!it *$99>FF value of .I2I mg for the high controle+uipment efficiency


Table 8-2" *$$9>F F is 3 mg ,-T=>g waste"There is no contrudictions in values of these twotablesG


Abetment factors are derived from *A notcontrolled>controlled Fs" These abetments cannotbe used for Table 8-6 Fs. related to <ATtechnologies " Also dio&ins abatement table is notpresent in the te&t and is related to unabated Fdifferent from Table 8-6 one" *lease introduceunabated Fs or all the pollutants or erase theentire chapter5

$orrectedK abatementfactors only applicable to*A factors in Tables 8-2and 8-85

Table 3-1" ,t is correct *$99>F emission factor unit- mg>'m8G

Are emissions from flared landfil gas (the part ofthe gas not used for energy purposes) missingG'orway reports these emissions under 6$


,ndustrial waste is e&tremely heterogenous groupwith very different levels of emissions from theircombustion" <ut in the chapter industrial wasteconsidered without differentiation even at Tier 2level" $hapter should be supplemented"


'o new info available.therefore addition of moreTier 2 methods could notbe done" ,ssue has beendiscussed with $, *"

$hange 4uch of the information on pollutantemissions has been reported as emissionconcentrations rather than emission factors" Thesehave been converted using a specific flue gasvolume of I m8 at 11 :2 per tonne of waste"4 with 4mission factors for heavy metals are

assumed to be the same as for clinical wasteincineration"4

Table 8-1# F for T%* and * seem very lowK Ffor *b. /g and Yn are higher than F for T%*"




'oted

Table 3-1# *$99>F emission factor ] error in units" Accepted $orrected

Figure 2-1# scheme is too simplified" e7ected

e7ected

': TA< G e7ected

Table 3-1# *$99>F emission factor ] error in units" Accepted $orrected

'oted

Table 8-1# emission factors need to be updated 'oted

Accepted

9ata are from Table ?"2"2 of old < and areassumed to be the same as for clinical wasteincineration se the same Fs of Tier 1 in Table8"1 eplace the chapter with 4Technology specificemission factors are not available for this sourcecategory" 4


Table 8-2 (ncontrolled)# *$99>F. /$<. *$< and*A/ emission factors are the same as in the Table8-1 (Tier 1 ] typical situation) but T%* and /emission factors are more high" F for *$99>F ]need to be updated ('* $hemicals%tandartiHed Tool!it. 2I might be for instanceused)"


Table 8-8# T%* and * emission factors seem tobe overestimated"

Tables 8-1. 8-2 should be updated. for instanceF for *$99>F from the '* $hemicals%tandartiHed Tool!it (2I)"

Tables 8-1 (Tier 1) and 8-2 (Tier 2) were notharmoniHed# F for *$99>F. /$<. *$< and *A/compounds are the same while F for T%* and/ are more high in Tier 2" ,f Tier 2 factors are thesame as Tier 1 what are the reasons to include inthe chapter choice of methods procedureG


Tables 8-3 ] 8-16 which are shown as Tier 8 tablescan be hardly considered as Tier 8# they are out-ofdate (main reference - *A 1JJI) and do notprovide emission factors for complete list ofinstallations and types of wastes"


There are still only default emission factors forpriority metals" 'o emission factors for othermetals are included"

Caste incineration could potentionally be a largeemission source of the other metals thereforeguidance on these metals should be included"


,t should be possible to provide some roughguidance on the particle siHe distribution. so that*1 and *2"I can be estimated"



'oted

Accepted $orrected

Accepted $orrected

'oted

'oted

'oted

'oted

e7ected

Accepted 9one

'oted

'oted'o emission factors for *. / and *:*s" 'oted

$hapter should be supplemented# it include only:pen burning of agricultural wastes. while othertypes of open burning are also important source ofemission especially *:*s"

in! to more detailedmethods of A*32 inserted

Tables 8-1] 8-1# error in unit for *1" mission

factors for *$99>F need to be updated"Table 8-3# title of the table do not coincide with thecontent (:rchard crops ] in the titleK eaf <urning

] in the table)"

$hapter should be supplemented# now there are 3tables with one F for '/8" 'o references"

Figure 2-1# *rocess scheme consists of one bo&and three arrows and do not provide anyinformation about the processes"


Table 8-1 (Tier 1) and Table 8-8 include the same'/8 F for compost production"

Table 8-2 (Tier 1) and Table 8-3 (Tier 2) include the

same '/8 F for sludge spreading"lots of F seem to be missing. for e&" ':$ ortotal *A/

original references should be named (notuideboo! 26)

9ata are the same as Tier 1" eplace the chapterwith 4Technology specific emission factors are notavailable for this source category" 4

Are emissions from car and house fires missingG%ee FP$omments

Are emissions from tobacco missingG %ee

FP$omments



Comments

,nlude /$< and other *:*s

$overed by ne&t comment

The contractors and indeed many of the individuals inthe pro7ect team have many years e&perience insupport of inventories and combustion emissions" ,fthis 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 ofabatement and in some instances the factors couldrepresent unabated emission" ,n terms of an emissioninventory the !ey issue is whether they can representa national emission" At Tier 1 and Tier 2 inclusion offactors for specific abatement technologies isachievable but would re+uire many tables and isconsidered inappropriate"

'ote that 1<2a"iv covers fugitive releases fromrefining. venting and flaring from oil-refining are 1<2c d respectively"

Te&t and indeed emission factors from the previouschapter could be included as an appendi& butincluding the whole chapter is not appropriate" Cherethe e&pert panel feels that more te&t would be helpfulthen , propose to as! them to determine what shouldbe included (as an appendi&)"

, accept that more detail can be provided but it isintended as general information only - we can go intodetail but there is information elsewhere such as the$* <F"

Firetube boilers more typically at siHes lower than 2Cth"



te&t in prentheses modified to state 0mainly relevant tosolid and li+uid fuels0" aseous fuels can containnitrogen compounds but natural gas contains nitrogenas '2 other nitrogen compounds are only present attrace levels (compared to biomass. coal and fuel oil)"

%ome emission factors are high but whether they are alarge emitter depends on overall technology mi&" Thissection is about formation of 'o& in general ratherthan for different technologies)"

As ta!en from the previous guideboo!" *lease notecommentary elsewhere on mercury in gas"

The te&t was in the original guideboo! but may havebeen contrary to the guideboo! F which was omittedin compilation" uideboo! factor has been restored"

uch of the detail in the current chapter is not relevantto someone preparing a national inventory" The <Fprovides relevant data"

As stated in the introduction to 8"8 details are in the<F" ,nclusion of %:2. ':B but not * is notconsistent but it reflects the original guideboo! where* controls were considered. as commented. withheavy metals controls"

Abatement efficiencies are indicative only - efficienciesare dependent on a range of factors and emissionreductions. particulary for retrofit applications. are veryvariable"

eneric te&t. note that it is not 7ust about emissiondataK more detailed approaches may also need toaddress fuel use"



uropean *$99>F data G

uideboo! factor missed. also data in Ap-32"

Ues. 0all0 is unli!ely and there will always be new datato consider"


The technology used will differ for each country andwill change over time" A representative factor for allusers is not achievable. these factors provide a first orsecond level estimating tool for the sector"


'ote this also applies to 0other li+uid fuels0 which

includes refinery gas - these are 'A*Fclassifications"

An oversight. technology identified but failed to includetable

Ce accept that combustion emissions can depend oncombustion unit siHe but. there has to be a degree ofsimplification otherwise the number of tables becomesunmanageable"



As!ed for uropean-based data"

9ry and wet bottom boiler classifications are as usedin current guideboo! but it is recognised that these arenot the only technology distinctions

Abatement efficiencies are dependent on a range offactors and reductions. particulary for retrofit

applications are very variable"

These dsitinctions are not in current guideboo! but arein A*-32 and are reasonable distinctions for unabatedplant (with downfiring as a potential additionaltechnology)" /owever. these technologies are lessrelevant for new and abated plant"

The factors do not represent a specific level ofemission control. where countries have !nowledge ofabatement levels then this !nowledge should be usedto develop appropriate country-specific emissionfactors"

%ome inconsistencies - incorrect mapping of somefactors in database G

%ome inconsistencies - incorrect mapping of somefactors in database G



%ee previous comment

,t was not the intent

/ave ta!en out this table

,s this correctG

Chere Tier 2 and Tier 1 defaults are the same then wedon0t have data to provide a Tier 2 factor and haveincluded Tier 1

Chere there no data to provide a Tier 2 factor. wehave included Tier 1 data

The wor! by $oncawe is referenced and tables havebeen revisited to incorporate relevant data



see other comments on $oncawe data

,s this right - perhaps one for Dustin>Tinus

'ote that $oncawe references are generally to%*A



see other related comments


The terminology used is not ideal but combustion unitwould not be appropriate either (it could be used todescribe engines. gas turbines. conceivably flares)"%uggest process furnace may be more appropriate"

,n general this is correct but there are significantranges which indicate that some abatement measuresare present"





Ce accept that the emission is dependent on fuelcomposition but combustion and lubricants are alsorelevant" Ce also accept that %*A :$ figure alsoe&cludes ethane however. in the absence of otherdata. it provides a reasonable value for nm:$" Analternative would be to apply the the %*A T:$figure" At least one member state applies an emissionlimit for formaldehyde but inventory is about totalnm:$ not individual components"




'ot sure what table this refers to but tables revised

Title modified but. we have no data for other activities

The completeness or othewise of facility emissionreporting is a !ey issue but is not uni+ue to refineries"Further guidance is provided in cross-cutting chapters"



%ee row I@

see above

$an the e&pert panel provide any further input on co!emanufacture outside iron steel plant or othermanufactured solid fuel processes



$alculated with reference to %*A ethod 1J

Add a footnote G

, thin! this may be a timing issue. F:9 may have beencompleted shortly before document finalised

Chere the references are for A*32. the dates refer tothe chapter dates rather than the current edition"



9one



%ee earlier notes re engines

'ot at Tier 1 but is needed at Tier 2



'ot clear what this comment is about

2<

Ues (for combustion)

%ee 188

'ote that emission is not generally associated withcombustion processes in 1A2 and may be assigned tothe process emission





Chere we have broadly similar fuels we have providedthe same emission factors rather than provide nofactors



see above

see above

Actually table revised

%ee 16J

Ues. this is correct but the Tier 1 and Tier 2 defaultfactors are for application to a wide range oftechnologies with aggregated activity data" Thecompe&ity of individual furnace fuel mi& is more

consistent with a Tier 8 approach"



These are assigned through 'F 2 emission guidance

%ee earlier

The table titles were incorrect. these factors are forheating>reheating





Ues. this would be impossible"

missions should not be included in 1A1



se tier 1



/owever note that for cement the Tier 2 tables willinclude all emissions e&cept *

'ot possible according to editorial re+uirements"/owever such data can be found in <F documents

*etco!e is a fuel but by no means the ma7or fuel in allcountries

,n general *$99>F emissions are not increased byuse of waste in cement !ilns (if applying <AT)



,n the absence of facility-specific data or specific fuelsthen use Tier 1



Ues. other li+uid fuel includes gas oil



metals should be assigned to process"

At Tier 1 we have brought together by main fuelclassifications





Te&t and tables now modified to reflect discussion with* leader

%uggest applying same factors as for coal in cement!ilns



see above





update

include especially the last suggestion

re7ected

could be improved

There are some errors# e"g" we should divideemissions by T: and $ruise not by ta!e off andlandingK it could be improved



,n my view default F should refer only to ,F flight

see the comment above (row 8?)





, agree with the comment" ,n Tier 2 it is not sufficientclear how to estimate cruise emissions (domestic andinternational)# the suggested methodology could bereported with a complete e&ample (ta!ing in accountan average domestic and international distance for

the country)",n my view data needed for the Tier 2 aren of flight by type of aircraft and bydomestic>internationalK total fuel consumption (ifpossible domestic and international separately)Kaverage national distances for domestic andinternational flights" %o the first step should be toestimate T: fuel consumption for domestic andinternational. and cruise fc for domestic on the basis oftables 8"11. 8"12 and 8"1I" ,nternational cruise fuelconsumption should be calculated anyway bydifference with the total F$ in the energy balance"%tep 8 probably is the first step. step 3 the second oneand step 1 and step 2 are a results of the method" ,n

my !nowledge no countries have information n fuelconsumption distinguished by domestic andinternationalK also Tier 8 methodologies. as *agodamodel by :$:'T:. estimated the fuelconsumption on the basis of the distance of the flightsbecause F$ on single trip are not collected because ofconfidentiality"

, disagree with the comment in generalK if the ,*$$26 guidelines report new emission factors beforenot available in my view they should be used





,t is correct. emission from military mobile. includingaviation. are reported in 1AI< with e&ception for thosereferring to multilateral operation that shoul bereported in memo items



,t could be useful to describe the Tier 2





































9one



+uation is correct as it is







will clarify

will clarify

will chec! and clarify units need correcting

will chec! and clarify units need correctingwill clarify

Cill be clarified

will correct

will correct

will correct

'eed to add Fs where appropriate'eed to add Fs where appropriate

will chec! and clarify units need correcting and lin!ing

to F tables"will chec! and clarify units need correcting and lin!ingto F tables"

will chec! and clarify units need correcting and lin!ingto F tables"

Cill incorporate where appropriate to the tiermethodology or reference given to detailed datasets"





nits will be added"

Cill clarify

Cill clarifyCill add

Cill clarifyCill clarify








Cill clarifyCill add

Cill add

Cill add

Cill clarify

Cill review

Cill update


Cill be redrafted to fit with uideboo! and referencemade to ,*$$ 26



Cill update

Cill update

Cill update

Cill update

Cill incorporate where appropriate

$an0t find any later data on ship fleet ma!e up"



clarified

Cill include originals

Cill update

Cill update

Cill update

Cill update

'eed clarifying





Cill clarify reference




Cill include reference






Cill clarify

Cill clarify

Cill clarify

Cill clarify










Cill revise

Cill revise

Cill revise


will be deleted






Cill incorporate



Cill incorporate

Cill incorporate










Tables will be revised and clarified

eferences will be added

will incorporate

Cill be clarified

Cill be clarified

Cill be clarified

Cill be clarified




As applied to 1A3a>c

9iagram is generic

%ome removal of detail. no additional $/* detail

Agreed at :verview and Table 1-1. subse+uent usemodified to align with 'F terminology

Accepted but. tried to retain much of the original te&t(<216) as it has only recently been revised" Thetechnologies are not all 'F sector specific"

'ot sure these comments are being held together that, can follow the references made"



/$< emissions very uncertain

These technology descriptions are largely ta!en fromthe e&isting chapter

accepted however waterheaters are also deviceswhich heat water 5 u* ecodesign ots 1 and 2 aredistinguishable on this basis"



Tier 1 is based on fuel not technology

several coments here. tables reviewed

The factors for some of these activities are highlyuncertain. this is partly due to the movement away

from technology to fuel categories but also reflectsvariability in source data"



%ome more obvious splitting included"

Additional data in appendi&

many tables have been revisedj





To be improved

To be revised

Ciniwarter reference

$an we do as a &-reference

The factors were in the appendi& of <216 of the26>@ guideboo!" ,f they can help a countryelaborate the emissions better and the country hasresources to do this. then why not use them G

The <T test reports are type-approval tests for use in Austria and other countries"



<AT figures G

GG

1A2 G

will clarify

Cill include summary table of limits

will clarify

These are described in 2"2"

This is a fair point but we have tried to avoid applyingdifferent siHes as the number of tables will becomeunmanageable for the guidance"



Table labelling is miss leading and will be corrected"

Cill be clarified in a footnote

will clarify

will clarify

Cill add

Cill update

Cill update

Cill update

Cill elaborate

Cill update

Table will be revised

Cill update

Cill update

Cill update

Cill update

Cill update



Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update



Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update

Cill update



Ce0ll follow the reporting template on this issue"



elates to Tier 8 methodology comment



Ce don0t have any information for thisL consult with*



'ot true" as distribution must be in this chapter"

'ot sure what is meant here"

'ot sure what is meant here"



For full reference see later comment





%till to do if there is time

, suppose this comment is applicable to chapter1"<"2"a"vi" eference added thereinK not here since itis not referred to



These values could indeed be useful for theuideboo!. but we don0t have them and cannot findeasily"



These values could indeed be useful for the

uideboo!. but we don0t have them and cannot findeasily"


'ot sure" Cere listed under II1 in formeruideboo!




A reference for thisLG

This chapter has been drafted in close cooperationwith $oncawe"

&planation is not too late - this is the section foractivity data"



9on0t !now what this is applicable to

ChyG



Tier 1 Tier 2 must be as complete as possible

$annot find te&t at indicated location" Furthermore.this te&t has been added by $oncawe themselves"



Chat table is this comment aboutG

,n this chapter5 Chat is the +uestion hereG

Ce thin! that this is probably not the ma7ority" Andsince we cannot split we chose to report these in thecombustion chapter

mission e&pected in reporting template from sourcecategory 1"A"2"f"i. therefore emission factor in thatchapter (either factor itself or a 'ot stimated)" Cill becorrected in final draft

* is in process chapter (2"A"1). emission factors ofall other pollutants are in 1"A"2" 9escription describescomplete cement production process. since we wantto be complete in this respect"

9on0t !now what is meant by 4misunderstood4" ,n

which wayG



Tier 2 Fs from $$A now inserted

$$A data now inserted as Tier 2

'o idea why this should be removed" , don0t see anyreason to do so"

'ot stimated > 'ot Applicable are filled using thereporting template" There is ':& and %:& fromprocess. but it has not been estimated here andincluded in the combustion %:& in chapter 1"A"2"f"i"

Ce thin! most /s from cement are from the fuelsrather than the raw meal and therefore they are

accounted for in 1A2" verything is emitted togetherfrom the !iln (process combustion). but we have toma!e a split somewhere"

'eeded for electronic emission factor database. Fsnot the same anymore in Final 9raft



,ndication ,"" will not be presented anymore in thefinal draft

*robably also a significant contribution is from thefuels" The +uestion is which one is the mostsignificant. since a split is not possible" Ce thin! thema7ority is from combustion"

Ammonia emissions treated in combustion chapter1A2fi (according to reporting template)K should not bea 'A

These are accounted for in the combustion chapter. asindicated" %ee chapter 1"A"2"

Ce anticipate that dust is mainly from the processesand /s are mainly from the fuel combustion" $ouldbe updated. but only if /s are in ma7ority from theprocess (which we do not thin! is true)"



$hapter mainly important for /s. as indicated

rror made when copying value - will be correctedChyG



To be added

ust be chapter 8"$. not 1"A"2"f"i (, thin! this is also

the point made in the comment. although ,0m notsureG)

ood suggestion. unfortunately , could not easily finda conversion factor"

9ecision tree updated to include product use besidesproduction" 9on0t !now what else to change"

9ates bac! to 1JJI while old uideboo! uses 1JJ3" All Fs the same. so , thin! this is not newer"





This issue has been identified as a problem from thebeginning of the pro7ect" 'eeds to be discussed. ,thin!5

Table 8-2 does not e&ist" $omment not applicablehere"

Ce have to stic! to the 'F structure. which does notidentify glass as a separate source category"



%ource N &pert 7udgement

Ce don0t have any better information" ,f provided. wewould li!e to include this"




':$ Fs from combustion and treated in chapter1"A"2



All consistent tables will be produced for the final draft

True. but no figures available to +uantify this

Could be a nice report to use in a ne&t version. butsince not published yet it will be difficult to incorporatethis now" any emission factors have been revisedfollowing other comments however"

,0m not sure what is meant# %ince all references havea year. , thin! the person commenting refers to whichyear the Fs are valid for" :ur Tier 2 Fs do in

principle not have a reference year. because they aretechnology-based"Ce don0t use a class ,-,,, for /s in the uideboo!"

True. but if these more accurate Fs are not availablethey cannot be used"

*robably this is indeed not correct. but unfortunatlycomplete information is not available from literature"Ce have to deal with what we have"



no suggestion for

%'A* 3622 is &plosives manufacturing

$omplete information is not available from literature"Ce have to deal with what we have"

%entence needs to be added to the preceding sectionsaying that all tables have been made complete byadding Tier 1 Fs where Tier 2 Fs for that specifictechnology were not available

The 3I1 and 3I2 were separate chapters inold guideboo!. but indeed referring tot the samenaftacrac!ing process - this is mentioned in the te&talso "" =uestion on the e&pert panel to combine theboth %'A*% to one paragraphG

686 is on pharmaceutical products. action as!edfrom tas! force on %'A*



%uggested is <AT associated emission levels"

<F ,$ AAF 2@# The tail gas compositiondepends on the applied process conditions" Table 8"8gives an overview of tail gas properties "" sed 2 -3 'm8 > ton and 2 - 3 mg>'m8 "" esults in62 - 18"2 g > ton - uideboo! values# 1" withlower upper I and 1I

Adipic acid production is relevant for emissions ofgreenhouse gasses ('2:). but not consideredsignificant or a !ey source for other air emissionsincluded in the protocols"

The source is indeed Table @"1 in <F ,$ %A:4mission sources and data on typical dust emissionsfrom the Austrian plant at different process stages 4- because we need a Tier 1 we made a aggregated Ffrom the different pprocess stages

The uideboo! has to give Tier 1 F0s for all 'F0sLincluding this one" This table therefore includes Tier 1emission factors for the 'F :ther chemical industry.generated with urostat and * data ] shoud beused with care. and is a very rough estimate5 ""

The uideboo! has to give Tier 1 F0s for all 'F0sLincluding this one" This table therefore includes Tier 1emission factors for the 'F :ther chemical industry.generated with urostat and * data ] shoud beused with care. and is a very rough estimate5 ""

There is already a separate <AT reference in thechapter on <AT for Ammonia



%'A* paragraph on %ilicium production removed

the both processes. steam reforming and partialo&idation are controlled processes

This seems a left over from the former version of theuideboo! "" Cill be corrected. we now assume alower value of 2

This seems a left over from the former version of theuideboo! "" Cill be correctedit is actually the other way round. I refers to %plantswe will use a value in the range for the uropeanplants - I

see comment on T, 1 F comment "" 'ot a !eysource

T%* and '/8# compiled new F0s from the differentunit operations listed in *A32. considering also newdevelopments in ta!ing upper and lower limits



please provide us with a suitable F

'ote#sed the *A A*32 (1JJ6) reference instead . samevalues old chapter <338 guideboo! states# A specificmethodology for these activities has not beenprepared because the contribution to total nationalemissions is thought to be currently insignificant. i"e"less than 1 of national emissions of any pollutant(26)reference to# $: from conomopoulos -O not clear5

old chapter <338 guideboo! states# A specificmethodology for these activities has not beenprepared because the contribution to total nationalemissions is thought to be currently insignificant. i"e"less than 1 of national emissions of any pollutant(26)

Ce received a T, 1 F from %* - chlorine-Tier 1 (not in F:9) we will use

mercury cell# compiled an F from the currentemission levels cell room ventilation "1@ - 1"J8.proces e&haust "1 - 1" g . $austic soda after thedecomposer# "J - "I and storage# 2"6 -O 8# (1 to6). these correspond with the %* value. whichis included in the revision



Chere to find this listG

<F :$# %uitablefeedstoc!s for olefins production range from lightgases (e"g" ethane and *s) to the refinery

li+uid products (naphtha. gas-oil)" /eavier feedstoc!sgenerally give a higher proportion of coproducts(propylene. butadiene. benHene) and need larger >more comple& plants" A large proportion of uropeMspropylene demand (and all of the butadiene demand)can besatisfied by the steam crac!ing of naphtha and gas-oil"The balance of propylene demand isessentially supplied from e&traction of propylene fromrefinery Fluidised $atalytic $rac!er offgasand imports" There is one *9/ (propanedehydrogenation) plant in urope. but it is onlyeconomic when propane prices are low" A similarprocess for butadiene production (by the

dehydrogenation of n-butane) is also available but isnot used in urope where there is generallya surplus of butadiene from steam crac!ing"

$orrect. use the F0s from the <F. Table @"Isummarises the principle pollutants and their sources.together with the range of emission levels met in mosturopean crac!ers"

liminated the other table for proylene "" Ce do note&pect however that the F of "6 underestimates theemissions "" ost uropean plants are having loweremissions

,nformation from the <F :$ were thylene is an

illustrative process



%uggested is <AT associated emission andconsumption levels" $urrent emissions are#<F *olymers. Table 8"J# mission and consumptiondata of 9* plants#9* uropean Average (benchmar! 1JJJ average)23 g>t:$ to air emissions in grams per tonne of product(g>t)" :$ includes all hydrocarbon and other organiccompounds including fugitive emissions " Ce willinclude this information in the <AT chapter

%uggested is <AT associated emission andconsumption levels" $urrent emissions are#

<F *olymers. Table 8"11# mission andconsumption data of /9* plants/9* uropean Average (benchmar! 1JJJ average)28 g>t:$ to air emissions in grams per tonne of product(g>t)" :$ includes all hydrocarbon and other organiccompounds including fugitive emissions" Ce willinclude this information in the <AT chapter

%uggested is <AT associated emission levels" There isalso an split view on <AT which resuts in higher <ATvalues" Ce will include this information in the <ATchapter

%uggested is <AT associated emission levels" There is

also an split view on <AT which resuts in higher <ATvalues" Ce will include this information in the <ATchapter

<F states that ?Ig>t is only for the topIfacilities ""uropean average is 12 g>t "" F willtherefore not be adapted. reference will be made to

the <F (Table 3"12# mission and consumptiondata per tonne of product of /,*% plants) in stead ofuideboo! 26



what information to use thenG

<F states that ?Ig>t is only for the topIfacilities ""uropean average is 12 g>t "" F willtherefore not be adapted. reference will be made tothe <F (Table 3"1# mission and consumptiondata per tonne of product from **% plants) in steadof uideboo! 26

" For more information see also the <F documenton arge olume :rganic $hemicals where theproduction of acrylonitrile is described as one of theillustrative processes

These should indeed be consistent "" *ropose to adaptthe approach on neglible emissions with productioncomparde to product use



pla!!en in e&cel

%uggested is <AT associated emission andconsumption levels" $urrent emissions are#

<F *olymers. Table 8"J# mission and consumptiondata of 9* plants#9* uropean Average (benchmar! 1JJJ average)23 g>t:$ to air emissions in grams per tonne of product(g>t)" :$ includes all hydrocarbon and other organiccompounds including fugitive emissions " Ce willinclude this information in the <AT chapter

<F states that ?Ig>t is only for the topIfacilities ""uropean average is 12 g>t "" F willtherefore not be adapted. reference will be made tothe <F (Table 3"1# mission and consumptiondata per tonne of product from **% plants) in stead

of uideboo! 26new table in <AT chapter. referring to table Table @"8#mission and consumption data from %< plants(per tonne of product)



what units are most suitableG

%entence on this to be added

%entence on this to be added

A Tier 1 is re+uired for every 'F" ,t may be usefulhowever to stress in the te&t that the Tier 1 can only be

used for an ,ntegrated ,ron and %teel facility with allthe subfacilities on site"



$omment not understoodK suggested to list all Fs ing>!g or in another unitG



Tier system here a bit different# iron>steel industryseperated in 8# sinter>pellets. pig iron and steel for Tier2" 9ifferent technologies identified within each ofthese" *roblem with inconsistent values appearsbecause of different references" Try to avoid this asmuch as possible. but will not be completeunavoidable5





ChyG



%* data to be chec!ed

%* data to be chec!ed

a7ority is still combustion. , suppose" %ince we havealways put ':&>%:&>$:>etc" in combustion whencombustion and process must be separated. , thin! it0s

better to !eep this approach here as well"

%plit has been agreed with &pert *anel" %ome of thepollutants are process- and combustion-related andit0s not possible to split" A choice must be made where

to allocate these emissions. which has been done"



'ot anymore

nfortunately <F does not provide generic factorsfor Tier 1. only for different ferroalloys andsubprocesses within the ferroalloy production"Furthermore. the overview in the <F is notcomplete" Therefore difficult to use in the uideboo!and not included"

Also not included in Tier 2 because of non-completeness. but references made"



'F does not distinguish *rimary>%econdary. so atTier 1 level we cannot separate them



*rimary and secondary copper production are process

with contact. therefore we should treat these similarlyto cement and lime production"



%hould be in combustion cahpter 1"A"2"f"i"

%ame as for copper production# process with contact

$omment is true. but not too much can be done at thisstage" Fs from different references have beencombined and this causes inconsistencies (mostobvious between * and /s)" /owever we cannot

7ust simply scale down the * with /. that is toosimple" , thin! however that this is an issue that needsfurther discussion in the future"



$ombining information from different references andcompleting Tier 2 tables with typical Fs causes thisproblem" There is no simple way to solve this however"




$ombining information from different references andcompleting Tier 2 tables with typical Fs causes this

problem" There is no simple way to solve this however"



$omment refers to wrong chapter" $orrection made inHinc chapter (2"$"I"d)



%ame as for copper production# process with contact

'o more data available5

oo! at this issue (same as in copper>lead)



$/$; %* 9ATA

$hec! for Yn FK other comments noted






%hould be in combustion cahpter 1"A"2"f"i"



'o info on this available"

Fuel combustion in 1A2 as indicated multiple times inchapter

Ce use the reporting template as the master to chec!

whether emission are e&pected or not"



'o info on this available"

$hapter needs to be discussed" Chere to collect allthis informationG,f no information is found. , suggest to move allrelevant pollutants to ' and delete the emissionfactors. since they0re all wrong5

$hapter needs to be discussed" Chere to collect all

this informationG,f no new information is found. , propose to delete allobviously wrong Fs and move to '

, do not !now where this should be allocated. discusswith *



$hec! this and add some te&t to ma!e this clear"



ention this somewhere in the descriptionG These canbe considered technology-specific in a way



:nly 'F is considered here. not %'A*

alues correct according to T,

alues correct according to T,

%hould be paint used. not paint produced" pdatenecessary5

Chat to use if T, and>or A,'% data cannot beusedG



9iscuss with *. conversion factor difficult to find

Cill be added" %hould this be in chapter 8"AG

$hec! if default value is available in T, documentto recalculate in terms of mass of paint

Ce have considered this. but then we get hugenumbers of tables (O1) which will ma!e the

document practically non-readable

Table does not provide Fs. only abatementefficiencies" Tier 2 Fs will be revised (g>!g paint)"



*erhaps we can add some wording on this in Tier 8

*erhaps we can add some wording on this in Tier 8

This is not in &ecutive %ummary of <F document(where the other te&t is ta!en from)" $annot find"



$annot be Tier 1 since the old factors are technologyspecificK these new factors have been derived incontact with industrial representatives





ust be chec!ed. what is meant hereG

%ource needs discussion with *

This is too vague" eference needed for changingnumbers"

/ow to deal with thisG 9iffers significantly from presentvalue and unreferenced. so left out"

%ource needs discussion" Chat is meant hereG Fsindeed seem too high. but no other informationavailable5G



F to be added to chapter

*ublished in 1J?2. outdatedG

$annot find proper Fs in A*32

9on0t !now what te&t this comment is applicable to





*rinting is one 'F. therefore a Tier 1 F is necessary

Table structure cannot be changed at this stage

This has been considered. but would generate manytables with all 7ust one F and therefore e&pand thedocument +uite heavily"

*roblem is that references are different" /ow to solvethisG



*roduct masses can be added to obtain some !ind ofgeneric F







































































missions mentioned in the te&t should be in the tableas well (as ' in this case since no numbers areavailable)

'o idea what the point is hereK we would be happyeven with a Tier 15



This solution loo!s +uite o! to me







ust be ng ,-T=>'m8

/ow to define differentiation and where to find FsG

Chat more can be saidG ,t0s 7ust burning of wasteL

Tier 1 represents averaged factors. Tier 2 tables arebasically uncontrolled factors (reduction efficiency tobe applied when abatement is in place)" 9iscuss ifalso Tier 1 should be unabated"

This is the uncontrolled one" ,n Tier 2. abatementefficiencies should be applied when in operation. whilein Tier 1 there is an 4averaged4 factor (alreadyaccounting for an average abatement)

A sentence will be added to ma!e clear that theabatement efficiencies are to be applied to the %*A factors onlyK the type 1>2>8 factors already havetheir abatement in there

To be discussedK , don0t !now how to ta!e this intoaccount

*roblem# T%* from <F while / Fs from former< (values are much older and therefore higher)":bviously / Fs should be updated. but where tofind FsG



9iscuss with &pert *anel5

ust be ng ,-T=>'m8

Chat more can be saidG ,t0s 7ust burning of wasteL

$omment not understood

$onsult *# should we remove this or leave it inG

ust be ng ,-T=>'m8

9iscuss if factors are availableK where to find

'o indication given on where to find this information"

This again raises the +uestion how to deal with Tier 2in this chapter

F for *$99>F from '* already usedK if moreupdates necessary then please specify which ones toupdate and where to find Fs5

&tra information in Tier 2 available is only theunabated-abated FsK Tier 2 uses unabated factorswhere available (you can use abatement efficiencieswhere applicable) while Tier 1 ma!es a best estimatewhen no better info is available



nit will be corrected"

Table to be corrected

There is no original reference for this factor

,f Fs are provided. we are happy to include them5

emove schemeG ,t does not provide information.because a variety of process may occur within thissource category" eft in for now"



Chapter_Name NF_Code Pollutant

1 nergy industries 1"A"1 8-13 %:& 83J"J 2

1 nergy industries 1"A"1 8-13 ':$ 1 2"8

1 nergy industries 1"A"1 8-13 As "12I "3

1 nergy industries 1"A"1 8-13 $d "2I "121 nergy industries 1"A"1 8-13 $r "62I "1I1 nergy industries 1"A"1 8-13 $u "2I "121 nergy industries 1"A"1 8-13 /g "2I 1 nergy industries 1"A"1 8-13 'i "?@I 1"8

1 nergy industries 1"A"1 8-13 *b "82I "361 nergy industries 1"A"1 8-13 Yn "2I "3J

1 nergy industries 1"A"1 8-13 *1

1 nergy industries 1"A"1 8-1I %:& "2I

1 nergy industries 1"A"1 8-1I $: 1I 8J

1 nergy industries 1"A"1 8-1I ':$ 1 2"6

1 nergy industries 1"A"1 8-1I *1 "2 "?J

1 nergy industries 1"A"1 8-1I T%* "2 "?J

1 nergy industries 1"A"1 8-1I *2"I "2 "?J

1 nergy industries 1"A"1 <3 ':& @I 2

1 nergy industries 1"A"1 <3 ':& 3

Chapter _ID

Ta!leNum!er

PresentValue

ProposedValue



1 nergy industries 1"A"1 <3 ':& 16

1 nergy industries 1"A"1"b 3-8 %:& 83J"J 2

1 nergy industries 1"A"1"b 3-8 $: 8 1I

1 nergy industries 1"A"1"b 3-8 ':$ 1 "?3

1 nergy industries 1"A"1"b 3-8 $d "1 "121 nergy industries 1"A"1"b 3-8 $r "1 "1I1 nergy industries 1"A"1"b 3-8 $u "1 "12

1 nergy industries 1"A"1"b 3-8 *b "I "36

1 nergy industries 1"A"1"b 3-8 Yn "I "3J

1 nergy industries 1"A"1"b 3-8 *1

1 nergy industries 1"A"1"b 3-3 %:& 8 21 nergy industries 1"A"1"b 3-3 ':$ 1"8 "6I

1 nergy industries 1"A"1"b 3-3 As "2 "1?

1 nergy industries 1"A"1"b 3-3 $d "1 "13

1 nergy industries 1"A"1"b 3-3 $r "1 "13

1 nergy industries 1"A"1"b 3-3 $u "8 "2@

1 nergy industries 1"A"1"b 3-3 /g "1 "13

1 nergy industries 1"A"1"b 3-3 'i "1 "13

1 nergy industries 1"A"1"b 3-3 *b "3 "31

1 nergy industries 1"A"1"b 3-3 Yn "2 "1?

1 nergy industries 1"A"1"b 3-3 *1 2 8"2



1 nergy industries 1"A"1"b 3-I %:& 2 2

1 nergy industries 1"A"1"b 3-I $: 8I 16

1 nergy industries 1"A"1"b 3-I ':$ 1"? 1"I1 nergy industries 1"A"1"b 3-I As "8 "81 nergy industries 1"A"1"b 3-I $d "1 "11 nergy industries 1"A"1"b 3-I $r "J "J

1 nergy industries 1"A"1"b 3-6 %:& 1 2

1 nergy industries 1"A"1"b 3-6 $: @I 8J

1 nergy industries 1"A"1"b 3-6 ':$ 2 2"6

1 nergy industries 1"A"1"b 3-6 As "8 "83

1 nergy industries 1"A"1"b 3-6 $d "1 "@1

1 nergy industries 1"A"1"b 3-6 $r "8 "2@

1 nergy industries 1"A"1"b 3-6 $u "2 "22

1 nergy industries 1"A"1"b 3-6 /g "1 J-I

1 nergy industries 1"A"1"b 3-6 'i "3 "86

1 nergy industries 1"A"1"b 3-6 *b "2 "1?

1 nergy industries 1"A"1"b 3-6 *1 "?J

1 nergy industries 1"A"1"b 3-@ %:& 1

1 nergy industries 1"A"1"b 3-@ $: 3 8J



1 nergy industries 1"A"1"b 3-@ ':$ 8"1 2"6

1 nergy industries 1"A"1"b 3-@ *1 "J "?J

1 nergy industries 1"A"1"b 3-@ T%* 1"1 "?J

1 nergy industries 1"A"1"b 3-@ *2"I "3 "?J

1 nergy industries 1"A"1"b 3-? ':& 1 3

1 nergy industries 1"A"1"b 3-? %:& 1

1 nergy industries 1"A"1"b 3-? $: 3 2@

1 nergy industries 1"A"1"b 3-? ':$ 8"1 I6

1 nergy industries 1"A"1"b 3-? *1 "J "8@

1 nergy industries 1"A"1"b 3-? T%* 1"1 "8@

1 nergy industries 1"A"1"b 3-? *2"I "3 "8@1 nergy industries 1"A"1"b 3-2 Arsenic "1 "831 nergy industries 1"A"1"b 3-2 $admium "1 "@11 nergy industries 1"A"1"b 3-2 $hromium "2 "2@31 nergy industries 1"A"1"b 3-2 ercury "1 J-I1 nergy industries 1"A"1"b 3-2 'ic!el "86 "86

1 nergy industries 1"A"1"b 3-2 ead "1? "1@J

1 nergy industries 1"A"1"b 3-8 Arsenic "3 8"J?

1 nergy industries 1"A"1"b 3-8 $admium "1 1"2

1 nergy industries 1"A"1"b 3-8 $hromium "1 13"?

1 nergy industries 1"A"1"b 3-8 ercury

1 nergy industries 1"A"1"b 3-8 'ic!el 1 18

1 nergy industries 1"A"1"b 3-8 ead "I 3"I6

1 nergy industries 1"A"1"b 3-3 Arsenic "2 1"?1

1 nergy industries 1"A"1"b 3-3 $admium "1 1"86

1 nergy industries 1"A"1"b 3-3 $hromium "1 1"86

1 nergy industries 1"A"1"b 3-3 ercury "1 1"86



1 nergy industries 1"A"1"b 3-3 'ic!el "1 1"86

1 nergy industries 1"A"1"b 3-3 ead "3 3"@

1 nergy industries 1"A"1"b 3-& Arsenic 8"J?

1 nergy industries 1"A"1"b 3-& $admium 1"2

1 nergy industries 1"A"1"b 3-& $hromium 13"?

1 nergy industries 1"A"1"b 3-& ercury

1 nergy industries 1"A"1"b 3-& 'ic!el 18

1 nergy industries 1"A"1"b 3-& ead 3"I6

1 nergy industries 1"A"1"b 3-& Arsenic

1 nergy industries 1"A"1"b 3-& $admium 2"I2

1 nergy industries 1"A"1"b 3-& $hromium 6"26

1 nergy industries 1"A"1"b 3-& ercury @"81

1 nergy industries 1"A"1"b 3-& 'ic!el @J"8

1 nergy industries 1"A"1"b 3-& ead 18"6

1 nergy industries 1"A"1"b 3-& Arsenic "838

1 nergy industries 1"A"1"b 3-& $admium "@12

1 nergy industries 1"A"1"b 3-& $hromium 2"@3

1 nergy industries 1"A"1"b 3-& ercury "?6

1 nergy industries 1"A"1"b 3-& 'ic!el 8"6



1 nergy industries 1"A"1"b 3-& ead 1"@J

1 nergy industries 1"A"1"a 8"28 $: 1 1"I

1 nergy industries 1"A"1"a 8"28 ':$ "2 "1J

1 nergy industries 1"A"1"a 8"28 *1 1 2

1 nergy industries 1"A"1"a 8"28 $d "2 "22

1 nergy industries 1"A"1"a 8"28 'i "I "I3

1 nergy industries 1"A"1"a 8-8 9io&ins

1 nergy industries 1"A"1"a 8-8

1 nergy industries 1"A"1"a 8-8 T%* 3 2

1 nergy industries 1"A"1"a 8-8 *1 8 1I

1 nergy industries 1"A"1"a 8-8 *2"I 1 I

1 nergy industries 1"A"1"a 8-8 ':$ 8 "3





1 nergy industries 1"A"1"a 8-3 *1 8 1

1 nergy industries 1"A"1"a 8-3 *2"I 2 @


1 nergy industries 1"A"1"a 8-I *1

1 nergy industries 1"A"1"a 8-I ':$ 8 "I

1 nergy industries 1"A"1"a 8-6 T%*

1 nergy industries 1"A"1"a 8-@ %:& 8I 2I

1 nergy industries 1"A"1"a 8-@ Arsenic "1 "2



1 nergy industries 1"A"1"a 8-@ $admium "1 "2

1 nergy industries 1"A"1"a 8-@ $hromium "8 "?

1 nergy industries 1"A"1"a 8-@ ercury "? "8

1 nergy industries 1"A"1"a 8-@ 'ic!el "@ "2

1 nergy industries 1"A"1"a 8-@ ':$ 8 "6

1 nergy industries 1"A"1"a 8-? *1































1 nergy industries 1"A"1"a 8-1@ T%* 6 2

1 nergy industries 1"A"1"a 8-1@ *1 8 1

1 nergy industries 1"A"1"a 8-1@ *2"I 2 @

1 nergy industries 1"A"1"a 8-1@ 9io&ins

1 nergy industries 1"A"1"a 8-1@ ':$ 8 "3

1 nergy industries 1"A"1"a 8-1J T%* 3 2

1 nergy industries 1"A"1"a 8-1J *1 8 1I

1 nergy industries 1"A"1"a 8-1J *2"I 1 I

1 nergy industries 1"A"1"a 8-1J 9io&ins






1 nergy industries 1"A"1"a 8-2 9io&ins1 nergy industries 1"A"1"a 8-22 T%* -"?

1 nergy industries 1"A"1"a 8-22 %:& "2I

1 nergy industries 1"A"1"a 8-22 ':$ 1"6 1

1 nergy industries 1"A"1"a 8-22 *1 "2 "J11 nergy industries 1"A"1"a 8-22 T%* "2 "J11 nergy industries 1"A"1"a 8-22 *2"I "2 "J1

1 nergy industries 1"A"1"a 8-28 %:& 13"2 2

1 nergy industries 1"A"1"a 8-28 *b "6 "68

1 nergy industries 1"A"1"a 8-23 *1

1 nergy industries 1"A"1"a 8-23 %:& "I 2

1 nergy industries 1"A"1"a 8-23 $: 1 8J

1 nergy industries 1"A"1"a 8-23 ':$ 2"I 1

1 nergy industries 1"A"1"a 8-23 *1 2 "J1



1 nergy industries 1"A"1"a 8-23 T%* 8 "J11 nergy industries 1"A"1"a 8-23 *2"I 1 "J1

1 nergy industries 1"A"1"a 8-2I T%*

1 nergy industries 1"A"1"a 8-8 Arsenic "3 "I21 nergy industries 1"A"1"a 8-8 $admium "2 "J81 nergy industries 1"A"1"a 8-8 $hromium "8 "8@11 nergy industries 1"A"1"a 8-8 ercury "2 "82J1 nergy industries 1"A"1"a 8-8 'ic!el "I "J161 nergy industries 1"A"1"a 8-8 ead "? "28881 nergy industries 1"A"1"a 8-3 Arsenic "3 "1@81 nergy industries 1"A"1"a 8-3 $admium "2 "1I8@1 nergy industries 1"A"1"a 8-3 $hromium "2?1 "8@11 nergy industries 1"A"1"a 8-3 ercury "8 "12I1 nergy industries 1"A"1"a 8-3 'ic!el "I "IJJ1 nergy industries 1"A"1"a 8-3 ead "? "I8I@

1 nergy industries 1"A"1"a 8-@ Arsenic "1 1"113@1 nergy industries 1"A"1"a 8-@ $admium "1 1"I?J3I1 nergy industries 1"A"1"a 8-@ $hromium "8 28"11J81 nergy industries 1"A"1"a 8-@ ercury "? "18IJ61 nergy industries 1"A"1"a 8-@ 'ic!el "@ 28"11J81 nergy industries 1"A"1"a 8-@ ead "2I 3"883?@1 nergy industries 1"A"1"a &-& /g() "I1 nergy industries 1"A"1"a &-& /g(,,) "31 nergy industries 1"A"1"a &-& /g(p) "1

6 1"A"8"b"vi 8-1J As "? 8"?

6 1"A"8"b"vi 8-1J $d 2"6 3"@8

6 1"A"8"b"vi 8-1J $r 12"3 28"?2I

6 1"A"8"b"vi 8-1J 'i 88"6 2J"?I

oad transport. automobile tyreand bra!e wear






6 1"A"8"b"vi 8-1J *b 1@ 1@6"26

6 1"A"8"b"vi 8-1J As 1 6@"I

6 1"A"8"b"vi 8-1J $d 18"28? 22"8@@?

6 1"A"8"b"vi 8-1J $r 66J"283 281"JJ

6 1"A"8"b"vi 8-1J 'i 368"133 826"I1I

6 1"A"8"b"vi 8-1J *b 8126"8 6@1"?1

6 1"A"8"b"vi 8-I T%* "J6 "62J

6 1"A"8"b"vi 8-I *1 "63 "J81

6 1"A"8"b"vi 8-I *2.I "8I "I

6 1"A"8"b"vi 8-@ T%* "31 "83J2?

6 1"A"8"b"vi 8-@ *1 "2@ "2@J3














6 1"A"8"b"vi 8-@ *2.I "1I "13

6 1"A"8"b"vi 8-J T%* "11 "J@

6 1"A"8"b"vi 8-J *1 "@8 "@J?

6 1"A"8"b"vi 8-J *2.I "8J "33

6 1"A"8"b"vi 8-11 T%* "3? "32@8

6 1"A"8"b"vi 8-11 *1 "82 "8@62

6 1"A"8"b"vi 8-11 *2.I "1@ "1J81 %mall combustion 1"A"3"b 8-I Arsenic "8 1"??J11 %mall combustion 1"A"3"b 8-I $admium "1 1@"11131 %mall combustion 1"A"3"b 8-I $hromium "2 23?"?J81 %mall combustion 1"A"3"b 8-I ercury 1"2IJ1 %mall combustion 1"A"3"b 8-I 'ic!el "1 23?"?J81 %mall combustion 1"A"3"b 8-I ead 36"66@31 %mall combustion 1"A"3"b 8-6 Arsenic "I "1@1 %mall combustion 1"A"3"b 8-6 $admium "1 "1@

1 %mall combustion 1"A"3"b 8-6 $hromium "2 "18881 %mall combustion 1"A"3"b 8-6 ercury "I "J6@1 %mall combustion 1"A"3"b 8-6 'ic!el "2 "1@1 %mall combustion 1"A"3"b 8-6 ead "J@1 %mall combustion 1"A"3"b"i 8-I ercury "11 %mall combustion 1"A"3"b"i 8-I ead 1 %mall combustion 1"A"3"b"i 8-6 ead 3




oad transport. automobile tyre

and bra!e wear






1 %mall combustion 1"A"3"b"i 8-13 T%* II 8I

1 %mall combustion 1"A"3"b"i 8-13 *1 I8 88

1 %mall combustion 1"A"3"b"i 8-13 *2.I I81 88

1 %mall combustion 1"A"3"b"i 8-13 $opper "1J "2

1 %mall combustion 1"A"3"b"i 8-13 ercury "@ "1

1 %mall combustion 1"A"3"b"i 8-13 $hromium "1 "1

1 %mall combustion 1"A"3"b"i 8-13 ':$ ? 6

1 %mall combustion 1"A"3"b"i 8-1I %:B "@

1 %mall combustion 1"A"3"b"i 8-1I 2 1"I1 %mall combustion 1"A"3"b"i 8-1I T%* "2 "I1 %mall combustion 1"A"3"b"i 8-1I *1 "2 "I1 %mall combustion 1"A"3"b"i 8-1I *2.I "2 "I

1 %mall combustion 1"A"3"b"i 8-16 ':B 12 I

1 %mall combustion 1"A"3"b"i 8-16 $: 82 1

1 %mall combustion 1"A"3"b"i 8-16 %:B "1 6

1 %mall combustion 1"A"3"b"i 8-16 /1 %mall combustion 1"A"3"b"i 8-2 *2"I 11 %mall combustion 1"A"3"b"i 8-23 T%* -"? "?1 %mall combustion 1"A"3"b"i &-& /g() "I1 %mall combustion 1"A"3"b"i &-& /g(,,) "8

1 %mall combustion 1"A"3"b"i &-& /g(p) "2

18 %olid fuel transformation 1"<"1"b 8-1 *1 1

18 %olid fuel transformation 1"<"1"b 8-1 *2.I J

16 efining > storage 1"<"2"a"iv 8-6 ':$ "2 "2

9io&ins andFurans



16 efining > storage 1"<"2"a"iv 8-@ *1 "? "6

1? eothermal energy e&traction 1"<"2"a"vi 8-1 ':B

1? eothermal energy e&traction 1"<"2"a"vi 8-1 %:B 161? eothermal energy e&traction 1"<"2"a"vi 8-1 '/8 8 211? eothermal energy e&traction 1"<"2"a"vi 8-1 *%T 1? eothermal energy e&traction 1"<"2"a"vi 8-1 *1

1? eothermal energy e&traction 1"<"2"a"vi 8-1 *2.I 1? eothermal energy e&traction 1"<"2"a"vi 8-1 /g "2 "331? eothermal energy e&traction 1"<"2"a"vi 8-1 As "2I1J enting and flaring 1"<"2"c 8-8 ':& 3 8"@

2 $ement production 2"A"1 &-& /g() "?

2 $ement production 2"A"1 &-& /g(,,) "1I

2 $ement production 2"A"1 &-& /g(p) "I

28 %oda ash production and use 2"A"3 tab" 8-1 '/8 "8?@8 1

2I oad paving with asphalt 2"A"6 'o" 8-6 ':$ 2 8

2J :ther mineral products 2"A"@"d 8-2 %:& 1J

2J :ther mineral products 2"A"@"d 8-2 Arsenic "12 "?



2J :ther mineral products 2"A"@"d 8-2 $admium "1I "6?

2J :ther mineral products 2"A"@"d 8-2 $hromium 2"3 "?

2J :ther mineral products 2"A"@"d 8-2 $opper "6 "@

2J :ther mineral products 2"A"@"d 8-2 ercury "I "8

2J :ther mineral products 2"A"@"d 8-2 'ic!el 1"J "@3

2J :ther mineral products 2"A"@"d 8-2 ead 12 "3

2J :ther mineral products 2"A"@"d 8-2 %elenium 1? "1I

2J :ther mineral products 2"A"@"d 8-2 Yinc 11 "866

2J :ther mineral products 2"A"@"d Table 8-2 *2"I 82 1"?

2J :ther mineral products 2"A"@"d Table 8-2 *1 86 1J"6

2J :ther mineral products 2"A"@"d Table 8-2 %e 1? 1"86

8 $hemical industry 2"<"I"a 8-& Arsenic

8 $hemical industry 2"<"I"a 8-& $admium

8 $hemical industry 2"<"I"a 8-& $hromium

8 $hemical industry 2"<"I"a 8-& 'ic!el8 $hemical industry 2"<"I"a &-& /g(p)

81 ,ron and steel production 2"$"1 8-2 ead "I 8"I38?



81 ,ron and steel production 2"$"1 8-2 Arsenic "2 "1@?J

81 ,ron and steel production 2"$"1 8-2 $admium "J "8J3

81 ,ron and steel production 2"$"1 8-2 $hromium "2 2"8

81 ,ron and steel production 2"$"1 8-2 'ic!el "J "?J3@

81 ,ron and steel production 2"$"1 8-2 ercury "I "1?8?

81 ,ron and steel production 2"$"1 8-& $admium "21@66

81 ,ron and steel production 2"$"1 8-& $hromium 2"8

81 ,ron and steel production 2"$"1 8-& ercury "IIJ

81 ,ron and steel production 2"$"1 8-& 'ic!el "@2II8

81 ,ron and steel production 2"$"1 8-& ead 2"611J1

81 ,ron and steel production 2"$"1 8-& Arsenic "36J

81 ,ron and steel production 2"$"1 8-& $admium "66@?


81 ,ron and steel production 2"$"1 8-& ercury "18@

81 ,ron and steel production 2"$"1 8-& 'ic!el "188I6

81 ,ron and steel production 2"$"1 8-& ead 3"6J1

81 ,ron and steel production 2"$"1 8-& 'ic!el 1

81 ,ron and steel production 2"$"1 &-& /g() "@

81 ,ron and steel production 2"$"1 &-& /g(,,) "8

81 ,ron and steel production 2"$"1 8-& ercury "1381 ,ron and steel production 2"$"1 &-& /g(p)

81 ,ron and steel production 2"$"1 8-& Arsenic

81 ,ron and steel production 2"$"1 8-& Arsenic "13I1




81 ,ron and steel production 2"$"1 8-& ead 8

81 ,ron and steel production 2"$"1 8-& 'ic!el

81 ,ron and steel production 2"$"1 8-& ead "6

81 ,ron and steel production 2"$"1 8-& Arsenic

81 ,ron and steel production 2"$"1 8-& $admium "11

81 ,ron and steel production 2"$"1 8-& $hromium

81 ,ron and steel production 2"$"1 8-& ercury

81 ,ron and steel production 2"$"1 8-& 'ic!el "IJJ

81 ,ron and steel production 2"$"1 8-& ead "886

81 ,ron and steel production 2"$"1 8-& Arsenic 8

81 ,ron and steel production 2"$"1 8-& $admium "?


81 ,ron and steel production 2"$"1 8-& ercury

81 ,ron and steel production 2"$"1 8-& $admium

83 $opper production 2"$"I"a 8-1 Arsenic 8J 8?"@682

83 $opper production 2"$"I"a 8-1 $admium 12 11"3?66

83 $opper production 2"$"I"a 8-1 $hromium 16 16"186

83 $opper production 2"$"I"a 8-1 ercury "28 "288I

83 $opper production 2"$"I"a 8-1 'ic!el 13 13"38J

83 $opper production 2"$"I"a 8-2 $admium 1I 13"II81

83 $opper production 2"$"I"a 8-1 ead 16 1IJ"I66



83 $opper production 2"$"I"a 8-2 $hromium 21 21"8I1I

83 $opper production 2"$"I"a 8-2 ercury "81 "8118

83 $opper production 2"$"I"a 8-2 'ic!el 1J 1J"211

83 $opper production 2"$"I"a 8-2 ead 1@ 1@3"68@

83 $opper production 2"$"I"a 8-& Arsenic 1"8@228

83 $opper production 2"$"I"a 8-& $admium 2"2?@I

83 $opper production 2"$"I"a 8-& $hromium

83 $opper production 2"$"I"a 8-& ercury

83 $opper production 2"$"I"a 8-& 'ic!el "12I@J

83 $opper production 2"$"I"a 8-& ead 113"8I2

83 $opper production 2"$"I"a 8-2 Arsenic I1 I1"226?

8I ead production 2"$"I"b 8-& ercury

8I ead production 2"$"I"b 8-& 'ic!el

8I ead production 2"$"I"b 8-& ead 32I"J26

8I ead production 2"$"I"b 8-& $admium 1"11I8

8I ead production 2"$"I"b 8-& Arsenic 8"3I13@

8I ead production 2"$"I"b 8-& $hromium8I ead production 2"$"I"b 8-1 Arsenic "?J "?@31@8I ead production 2"$"I"b 8-1 $admium "88 "82I688I ead production 2"$"I"b 8-1 $hromium 8I ead production 2"$"I"b 8-1 ercury "@ "6J3@8I ead production 2"$"I"b 8-1 'ic!el 8I ead production 2"$"I"b 8-1 ead 12 11I"J8



8I ead production 2"$"I"b 8-2 Arsenic "1I "1I@

8I ead production 2"$"I"b 8-2 $admium "6@ "6@

8I ead production 2"$"I"b 8-2 $hromium

8I ead production 2"$"I"b 8-2 ercury "J8 "J2I32

8I ead production 2"$"I"b 8-2 'ic!el

8I ead production 2"$"I"b 8-2 ead 18 12"I621

8I ead production 2"$"I"b &-& /g() "?3

8I ead production 2"$"I"b &-& /g(,,) "1

8I ead production 2"$"I"b &-& /g(p) "6

8@ Yinc production 2"$"I"d 8-2 'ic!el 8@ Yinc production 2"$"I"d 8-1 Arsenic "12 "11JI68@ Yinc production 2"$"I"d 8-1 $admium 2"I 2"I881J8@ Yinc production 2"$"I"d 8-1 $hromium 8@ Yinc production 2"$"I"d 8-1 ercury 8"? 8"@?I@?

8@ Yinc production 2"$"I"d 8-1 'ic!el 8@ Yinc production 2"$"I"d 8-1 ead 13 13"?36

8@ Yinc production 2"$"I"d 8-2 Arsenic

8@ Yinc production 2"$"I"d 8-2 $admium 2"3 2"381??

8@ Yinc production 2"$"I"d 8-2 ercury I I"3II6

8@ Yinc production 2"$"I"d 8-2 ead 1@ 1@"282

8@ Yinc production 2"$"I"d 8-& Arsenic "3@?26

8@ Yinc production 2"$"I"d 8-& $admium 2"?8@12

8@ Yinc production 2"$"I"d 8-& $hromium

8@ Yinc production 2"$"I"d 8-& ercury "63I

8@ Yinc production 2"$"I"d 8-& 'ic!el



8@ Yinc production 2"$"I"d 8-& ead I"26?JI

8@ Yinc production 2"$"I"d 8-2 $hromium

8@ Yinc production 2"$"I"d &-& /g() "?

8@ Yinc production 2"$"I"d &-& /g(,,) "1I

8@ Yinc production 2"$"I"d &-& /g(p) "I

36 *aint application 8"A"8 8-8 ':$ 2 8?

36 *aint application 8"A"2 8-2 ':$ 3 266

36 *aint application 8"A"1 8-1 ':$ 1I ?

36 *aint application 8"A new $: 12I

3@ 9egreasing 8"<"1 new $: @3



I2 :ther product use 8"9"8 new $: I"I

IJ $linical waste incineration 6"$ ':$

IJ $linical waste incineration 6"$ %:2 "2

IJ $linical waste incineration 6"$ $: "3

IJ $linical waste incineration 6"$ *aricles "13

IJ $linical waste incineration 6"$ &-& /g(p) "2

IJ $linical waste incineration 6"$ $/3 "8@

IJ $linical waste incineration 6"$ '2: "1I

IJ $linical waste incineration 6"$ /

IJ $linical waste incineration 6"$ &-& /g() "2

IJ $linical waste incineration 6"$ &-& /g(,,) "6

IJ $linical waste incineration 6"$ 'o& "1@

6 ,ndustrial waste incineration (d) 6"$"b 8-1 $admium 8 "11I?

6 ,ndustrial waste incineration (d) 6"$"b 8-1 $hromium "8



6 ,ndustrial waste incineration (d) 6"$"b 8-1 ercury 8I "?66I

6 ,ndustrial waste incineration (d) 6"$"b 8-1 'ic!el I6 "18I33

6 ,ndustrial waste incineration (d) 6"$"b 8-1 ead "1 1"2I@66

6 ,ndustrial waste incineration (d) 6"$"b 8-1 Arsenic "I "163I

63 :ther waste 6"9

63 :ther waste 6"9 tobacco

houseand carefires

T%*. / anddio&in

':&. ':$.$:. T%*.*A/./ anddio&in



e"erence

1J"J 2 Accepted

1"? 2"? 'oted

"2 "? 'oted

"6 "23 Accepted"I "3I A*, *ublication 83? (rated 9) e7ected"3 "86 A*, *ublication 83? (rated 9) e7ected

A*, *ublication 83? (not detected) e7ected"88 8"1 A*, *ublication 83? (rated 9) e7ected

"28 "J2 e7ected"16 "1I A*, *ublication 83? (rated 9) e7ected

'oted

Accepted

28 II Accepted

1"8 I"2 Accepted

"I8 1"8 Accepted

"I8 1"8 Accepted

"I8 1"8 Accepted

'oted

'oted

Lo#erLimit

$pperLimit

Proposeddecision

$hemistry. assuming all sulphurconverted (values to be multiplied with

% N wt % in fuel)% *A A*-32 $h 1"8. Table 1"8-8(rated A)

% *A A*-32 $h 1"8. Table 1"8-11(rated $)

% *A A*-32 $h 1"8. Table 1"8-11(rated $)

% *A A*-32 $h 1"8. Table 1"8-11

(rated $)

% *A A*-32 provides algorithmrelating * to sulphur content

*age ?. line 1@ of this chapter statessulphur in natural gas is negligible" ,fthis proposal is not accepted. then thealgorithm 2S% should be used - seeabove"

% *A A*-32 $h 1"3. Table 1"3-1(rated <)

% *A A*-32 $h 1"3. Table 1"3-2

(rated $)% *A A*-32 $h 1"3. Table 1"3-2(rated <)

A*-32 (as above) states that all * W1 micron


%ee#http#>>www"ifc"org>ifce&t>enviro"nsf>Attachments<yTitle>guiP/%uidelines2@Peneral/%>^F,>FinalV-VeneralV/%Vuidelines"pdf

For dual fuel engines operated withgas. overta!e Corld <an! proposal.see eneral /% uidelines#http#>>www"ifc"org>ifce&t>enviro"nsf>Attachments<yTitle>guiP/%uidelines2@Peneral/%>^F,>FinalV-VeneralV/%Vuidelines"pdf



'oted

1J"J 2 'oted

12 1? 'oted

"6@ 1 'oted

"6 "23 'oted"I "3I A*, *ublication 83? (rated 9) 'oted"3 "86 A*, *ublication 83? (rated 9) 'oted

"28 "J2 'oted

"16 "1I A*, *ublication 83? (rated 9) 'oted

'oted

1J"J 2 'oted"I2 "@? -*T 'oted

"6 "I3 Accepted

"@ "32 'oted

"@ "32 Accepted

"J "?1 'oted

"@ "32 'oted

"@ "32 'oted

"13 "12 'oted

"6 "I3 'oted

1 J"6 'oted

For gas diesel engines. see#http#>>www"ifc"org>ifce&t>enviro"nsf>Attachments<yTitle>guiP/%uidelines2@Peneral/%>^F,>FinalV-VeneralV/%Vuidelines"pdf

$hemistry. assuming all sulphur

converted (values to be multiplied with% N wt % in fuel)

% *A A*-32 $h 1"8. Table 1"8-1(rated A)

% *A A*-32 $h 1"8. Table 1"8-8(rated A)

% *A A*-32 $h 1"8. Table 1"8-11(rated $)

% *A A*-32 $h 1"8. Table 1"8-11(rated $)

% *A A*-32 provides algorithmrelating * to sulphur content

$hemistry. assuming all sulphurconverted (values to be multiplied with% N wt % in fuel)

% *A A*-32 $h 1"8. Table 1"8-1(rated 9)K K present value rounded upto one significant figure

% *A A*-32 $h 1"8. Table 1"8-1(rated 9)K present value rounded up to

one significant figure% *A A*-32 $h 1"8. Table 1"8-1(rated 9)K present value rounded up toone significant figure

% *A A*-32 $h 1"8. Table 1"8-1(rated 9)K present value rounded up toone significant figure


% *A A*-32 $h 1"8. Table 1"8-1(rated 9)K present value rounded up to

one significant figure% *A A*-32 $h 1"8. Table 1"8-1(rated 9)K present value rounded up toone significant figure


% *A A*-32 $h 1"8. Table 1"8-1(rated 9)



1J"J 2 'oted

? 82 Accepted

"3J 3"3 'oted2-I "6 uideboo!. 26 gives units as g>TD AcceptedI-6 "2 uideboo!. 26 gives units as g>TD 'otedI-I "1? uideboo!. 26 gives units as g>TD 'oted

1J"J 2 'oted

28 II 'oted

1"8 I"2 'oted

"11 "1 'oted

"23 "21 'oted

"13 "I3 'oted

"11 "33 'oted

3-I "1@ 'oted

"1? "@2 'oted

"J "86 'oted

"I8 1"8 'oted

'oted

28 II 'oted


% *A A*-32 $h 1"I. Table 1"I-1(rated 9)

% *A A*-32 $h 1"I. Table 1"I-1

(rated 9)


% *A A*-32 $h 1"3. Table 1"3-1(rated <)K Assuming refinery gase+uivalent to natural gas

% *A A*-32 $h 1"3. Table 1"3-2(rated $)K Assuming refinery gas

e+uivalent to natural gas A*, *ublication 83? (rated 9)K presentvalue rounded up to one significantfigure

A*, *ublication 83? (rated 9)K presentvalue rounded up to one significantfigure

A*, *ublication 83? (rated $)K presentvalue rounded up to one significantfigure

A*, *ublication 83? (rated c)K presentvalue rounded up to one significant

figure A*, *ublication 83? (rated $)K presentvalue rounded up to one significantfigure



% *A A*-32 $h 1"3. Table 1"3-2(rated <)K assuming refinery gas

e+uivalent to natural gas*age ?. line 1@ of this chapter statessulphur in natural gas is negligible" ,fthis proposal is not accepted. then thealgorithm 2S% should be used - seeabove"

% *A A*-32 $h 1"3. Table 1"3-1(rated <)



1"8 I"2 'oted

"I8 1"8 'oted

"I8 1"8 'oted

"I8 1"8 'oted

23 I6 'oted

'oted

16 8? 'oted

2? 11 'oted

"11 "11 'oted

"11 "11 'oted

"11 "11 'oted"2 "I %*-Table 2I 'oted"I "1 %*-Table 2I 'oted

"1 "3 %*-Table 2I 'oted"I "1I %*-Table 2I 'oted

"2 "6 %*-Table 2I 'oted

"12 "21 %*-Table 2I 'oted

2 6 'oted

"? 1"I 'oted

1 2 'oted

Accepted

I 1I Accepted

8 @ 'oted

1"I 2"I 'oted

1 1"? Accepted

1 1"? Accepted

1 1"? Accepted

% *A A*-32 $h 1"3. Table 1"3-2(rated $)

% *A A*-32 $h 1"3. Table 1"3-2(rated <)



% *A A*-32 $h 8"2. Table 8"2-2(rated <)

*age ?. line 1@ of this chapter statessulphur in natural gas is negligible" ,fthis proposal is not accepted. then thealgorithm 2S% should be used - seeabove"

% *A A*-32 $h 8"2. Table 8"2-2(rated <)

% *A A*-32 $h 8"2. Table 8"2-2

(rated $)% *A A*-32 $h 8"2. Table 8"2-2(rated 9)



%*-Table 23 (called in theF:9 under Tier 2)



%*-Table 23 (called in theF:9 under Tier 2) (not in F:9)


%*-Table 23 (called in the

F:9 under Tier 2)%*-Table 28 (called in theF:9 under Tier 2)






1 1"? 'oted

8 6 'oted

2 6 Accepted

"? 1"I 'oted

1 2 'oted

'oted

I 1I 'oted

8 @ 'oted

'oted

1 I 'oted

8 J 'oted

3 1 'oted

I 1 'oted

1 2 'oted

"2 "I 'oted

"I 1"2 'oted

1"I 3 'oted

"I "1I 'oted

2 I 'oted



%*-gas turbines-destillate oil-table 26 (not in F:9)






%*-gas turbines-natural gasand refinery fuel gas-table 2@ (not in

F:9)%*-gas turbines-natural gasand refinery fuel gas-table 2@ (not inF:9)

%*-gas turbines-natural gasand refinery fuel gas-table 2@ (not inF:9)

%*-gas turbines-natural gasand refinery fuel gas-table 2@ (not inF:9)

%*-gas turbines-natural gasand refinery fuel gas-table 2@ (not in

F:9)%*-gas turbines-natural gasand refinery fuel gas-table 2@ (not inF:9)

%*-gas turbines-natural gasand refinery fuel gas-table 2? (not inF:9)


%*-gas turbines-natural gasand refinery fuel gas-table 2? (not in

F:9)%*-gas turbines-natural gasand refinery fuel gas-table 2? (not inF:9)




1 8 'oted

"@ 8 'oted

"1 "6 'oted

"I 3 'oted

"1 "33 'oted

"2I "11 'oted

'oted

'oted

2 'oted

'oted

'oted

Accepted


% *A A*-32 $h 8"1. Table 8"1-1(rated $)K present value rounded up toone significant figure

*resent value rounded up to onesignificant figure

% *A A*-32 $h 8"1. Table 8"1-2a(rated $)

% *A A*-32 $h 8"1. Table 8"1-I(rated $)K present value rounded up toone significant figure


F are much too high being based on1JJ? dataK according to ownmeasurements on power plants thema7ority of dio&ins>furans are notdetectableK we suggest to use the$T,$ data of 6-1

As the $T,$ data are basedon more actual measurements theranges of the F should be e&tendedto include the $T,$ FK theyshould also include the F calculatedin appendi& <

The proposed F seems too high -under the $*9 plant OIC(thermal) have an of Img>'m8 (1@"I g>D). so the suggestedvalue would seem more appropriate"

According to our data. the lower JIconfidence intervals for T%* are toohigh" Ce recommend

ecalculated from proposed T%* Ffactor


F seems very high - ':$emission generally related tocombustion conditions and is oftenbelow instrument detection limits"%uggest using $T,$ valueof "3



Accepted

2 Accepted

Accepted

Accepted

Accepted

"2 Accepted

Accepted

"1 Accepted

Accepted

"1 Accepted





ecalculated from proposed T%* F

factor


ower JI confidence limit value for*1 is lower than that of *2"I -suggest that they should be the same

F seems very high - ':$emission generally related tocombustion conditions and is oftenbelow instrument detection limits"%uggest using $T,$ valueof "I

ower JI confidence limit value forT%* is lower than that of *1 -suggest that they should be the same

imit for sulphur in fuel oil is 1 - thise+uates to an emission of around 2Ig>D

F given appears to be for a 1"Isulphur fuel - as fuel sulphur hasdecreased so has the heavy metalcontent" %uggest using the$T,$ value of "2 g>D



"1 Accepted

"I Accepted

"2 Accepted

"1 Accepted

Accepted

"1 Accepted

Accepted

Accepted

2 Accepted

Accepted


F given appears to be for a 1"Isulphur fuel - as fuel sulphur hasdecreased so has the heavy metalcontent" %uggest using the$T,$ value of "? g>D


F given appears to be for a 1"Isulphur fuel - as fuel sulphur hasdecreased so has the heavy metal

content" %uggest using the$T,$ value of "2 g>D




,t should be stated which TF factorsare used (,-TF or C/:-TF)G

The proposed F seems too high -

under the $*9 plant OIC(thermal) have an of Img>'m8 (1@"I g>D). so the suggestedvalue would seem more appropriate"





Accepted

Accepted

2 Accepted

Accepted

Accepted

Accepted

Accepted

2 Accepted

Accepted

Accepted


F seems very high - ':$emission generally related tocombustion conditions and is oftenbelow instrument detection limits"

%uggest using $T,$ valueof "3



ecalculated from proposed T%* F

factor ecalculated from proposed T%* Ffactor


F seems very high - ':$emission generally related tocombustion conditions and is often

below instrument detection limits"%uggest using $T,$ valueof "3







2 Accepted

Accepted

Accepted

Accepted

Accepted

2 Accepted

Accepted

Accepted

Accepted

Accepted





F are much too high being based on1JJ? dataK according to ownmeasurements on power plants thema7ority of dio&ins>furans are notdetectableK we suggest to use the

$T,$ data of 6-11






F are much too high being based on1JJ? dataK according to ownmeasurements on power plants thema7ority of dio&ins>furans are not

detectableK we suggest to use the$T,$ data of 6-1




2 Accepted

Accepted

Accepted

Accepted

Accepted

2 Accepted

Accepted

Accepted

Accepted





F are much too high being based on1JJ? dataK according to ownmeasurements on power plants thema7ority of dio&ins>furans are notdetectableK we suggest to use the

$T,$ data of 6-1






F are probably too high being basedon 1JJ? dataK we have not measuredthese on fluidised bed plants but the

values are li!ely to be similar to thosefrom *F plants so we suggest usingthe $T,$ data of 6-1



2 'oted

'oted

'oted

'otednegative valueG 'oted

'oted

"I 2 'oted

"3I 1"? 'oted"3I 1"? Assuming all * W 1 micron 'oted"3I 1"? Assuming all * W 1 micron 'oted

1J"J 2 'oted

"8 "18 'oted

"1 'oted

1J"J 2 'oted

8 3@ 'oted

"I 2 'oted

"3I 1"? 'oted





F are probably too high being basedon 1JJ? dataK we have not measuredthese on fluidised bed plants but thevalues are li!ely to be similar to those

from *F plants so we suggest usingthe $T,$ data of 6-1

*age ?. line 1@ of this chapter statessulphur in natural gas is negligible"

% *A A*-32 $h 8"1. Table 8"1-2a(rated $)

% *A A*-32 $h 8"1. Table 8"1-2a(rated $)




$hemistry. assuming all sulphurconverted (values to be multiplied with

% N wt % in fuel)% *A A*-32 $h 8"1. Table 8"1-1(rated A)K assumed refinery gase+uivalent to natural gas

% *A A*-32 $h 8"1. Table 8"1-2a(rated $)K assuming refinery gase+uivalent to natural gas

% *A A*-32 $h 8"1. Table 8"1-2a(rated $)



"3I 1"? Assuming all * W 1 micron 'oted"3I 1"? Assuming all * W 1 micron 'oted

"1 'oted

"8I "@ %* 'oted"3@ "13 %* 'oted"2132 "32?I %* 'oted"28I "3@ %* 'oted"I?8 "13I? %* 'oted"1@I "8I %* 'oted

"38J "21J6 %* 'oted"38J "268I %* 'oted"@@J "8?J@ %* 'oted"62 "2I %* 'oted"21J6 "181@3 %* 'oted"1@I@ "1I8J %* 'oted

"@223? 1"333J6 %* 'oted"@223? 2"??JJ1 %* 'oted16"I18? 88"2@6 %* 'oted"J63 "862I@ %* 'oted@"223@J 38"83?@ %* 'oted2"16@33 6"I281 %* 'oted

"3 "6 %* 'oted"8 "I %* 'oted

"I "2 %* 'oted

1"6 6 'oted

1"3 J 'oted

2 61 'oted

2"3 68 'oted

ower JI confidence limit value forT%* is lower than that of *1 -suggest that they should be the same

/7orten!rans et al" 2@. e&!ll et al"2I. Carner et al" 22. Cesterlund21. egret *agotto 1JJJ.

%techmann 1JJ8. /ildemann et al"1JJ1. /einrichs 1JJ8

/7orten!rans et al" 2@. e&!ll et al"2I. Carner et al" 22. Cesterlund21. egret *agotto 1JJJ.%techmann 1JJ8. /ildemann et al"1JJ1. /einrichs 1JJ8





6"8 6@ 'oted

1 18 'oted

1"I I@ 'oted

113"J8@I ?I 'oted

? 66 'oted

12 2 'oted

"1@ "12 'oted

"2II "1? 'oted

"13 "J6 'oted

"83 "@6? 'oted

"2@2 "6133 'oted




/7orten!rans et al" 2@. e&!ll et al"2I. Carner et al" 22. Cesterlund21. egret *agotto 1JJJ.

%techmann 1JJ8. /ildemann et al"1JJ1. /einrichs 1JJ8



T': 21. <CA 1JJ2. ebbe et al"1JJ@. $A< 1JJ8. arben et al" 1JJ6.<aumann 1JJ@. egret and *agotto1JJJ. !ewille et al" 21







"13 "8@ 'oted

"1@J "2 'oted

"1I? "1@61 'oted

"? "?J1 'oted

"83@ "J 'oted

"86 "@J23 'oted

"1II "3J 'oted@"@@@J1 1I"III? %* 'oted@"@@@J1 81"1116 %* 'oted1@@"@?1 8II"I61 %* 'oted"?3 8"21I? %* 'oted

@@"@@J1 366"6@3 %* 'oted28"888@ @"12 %* 'oted"11 "2? %* 'oted"11 "2? %* 'oted

"??J "2222 %* 'oted"II6 "166@ %* 'oted"11 "2? %* 'oted"I6 "16@ %* 'oted

"8 "1 uideboo! 26" unit mg>D 'oted'oted

uideboo! 26. unit mg>D 'oted


arg et al" 2. egret*agotto1JJJ. Carner et al" 22. auterberg-

Culff 1JJ?. Dohansson et al" 1JJ?.Cesterlund 21. <uwal 21. T':21

arg et al" 2. egret*agotto1JJJ. Carner et al" 22. auterberg-Culff 1JJ?. Dohansson et al" 1JJ?.Cesterlund 21. <uwal 21. T':21

arg et al" 2. egret*agotto1JJJ. Carner et al" 22. auterberg-Culff 1JJ?. Dohansson et al" 1JJ?.Cesterlund 21. <uwal 21. T':

21arg et al" 2. egret*agotto1JJJ. Carner et al" 22. auterberg-Culff 1JJ?. Dohansson et al" 1JJ?.Cesterlund 21. <uwal 21. T':21





Accepted

Accepted

Accepted

Accepted

Accepted

Accepted

Accepted

'oted

'otedF of old < has less uncertainty 'otedF of old < has less uncertainty 'otedF of old < has less uncertainty 'oted

'oted

'oted

'oted

'oteduideboo! 26. unit g>D 'oted

Accepted"3 "6 %* 'oted"2 "3 %* 'oted

"1 "8 %* 'oted

3I 1? Accepted

3 16 Accepted

"1 "3 Accepted

: ,' $:*U F: 4:94 < orwrong reference


: ,' $:*U F: 4:94 <SSS *roposed value O *1 one

: ,' $:*U F: 4:94 <or wrong reference




, C %*A; A<:T 4'ATA4A% FN. if we spea! of other gases(i"e" *) then mut be declared


,t0s inaudite that consultant it0s not ableto copy 4old4 in 4new4 fs




estimated fraction of * by % *Adata

estimated fraction of * by % *Adata

pper limit as per Table 8-1 of this'F



"8 "J Accepted

A*AT. 2@ Accepted

Accepted? J A*AT. 2@ Accepted

A*AT. 2@ Accepted A*AT. 2@ Accepted

A*AT. 2@ Accepted"26 1"8 A*AT. 2@ Accepted"2 "3I A*AT. 2@ Accepted

uideboo! 26 Accepted

"@ "J %* e7ected

"1 "2 %* e7ected

"1 "1 %* e7ected

"6 1"I Accepted

Accepted

186 21@ Accepted

"1? Accepted

efinery <F provides a range ofabatementefficiencies for cyclonesbetween 8 and J*ropose lowerlimit set to <F value"*roposedefault efficiency is ta!en at mid range

A*AT. 2@ 'ote that the proposedvalue is wrong5 The reference +uotedsay# 4Chile geothermal plants do notemit sulfur dio&ide directly. oncehydrogen sulfide is released as a gasinto the atmosphere. it spreads intothe air and eventually changes into

<F 4arge olume ,norganic$hemicals - %olids and :ther ,ndustry(,$ - %A:) :ctober 26. chapter2"8"8"I). unit !g>ton

used F of german ',. referenced on9, 22?8 Aufbereitungsanlagen fr

Asphaltmischgut

Average of measurements coming

from members of the federation (onlyflat glass)

Average of measurements comingfrom members of the federation (onlyflat glass). lower limit N belowdetection limit



"2I Accepted

"1 "18 Accepted

"11 Accepted

"8J Accepted

"I3 "J@ Accepted

"28 "6? Accepted

"2 "3 Accepted

"18 "I6 Accepted

Accepted

Accepted

Accepted

Accepted

Accepted

Accepted

Accepted%*-$hlor al!ali production Accepted

1"@?J33 I"86?81 Accepted


Average of measurements comingfrom members of the federation (only

flat glass) Average of measurements comingfrom members of the federation (onlyflat glass). lower limit N belowdetection limit


Average of measurements comingfrom members of the federation (onlyflat glass)




unpublished report on emission factorsof the erman glas and mineral fibre

industry for the year 2I

unpublished report on emission factorsof the erman glas and mineral fibreindustry for the year 2I

unpublished report on emission factorsof the erman glas and mineral fibreindustry for the year 2I

%* - chlorine-Tier 1 (not inF:9)

%* - chlorine-Tier 1 (not in

F:9)%* - chlorine-Tier 1 (not inF:9)

%* - chlorine-Tier 1 (not inF:9)

%*-(called in the F:9 underTier 2)



"?JI "26?3 Accepted

"1@J "I8@ Accepted

1"1I 8"3I Accepted

"I86? "161I Accepted

"122I "86@6 Accepted

"13I11 "2J21 Accepted

1"1I 8"3I Accepted

"8@J3 "I6J1 Accepted

"21@66 1"??8 Accepted

1"??8 3"8I81? Accepted

"26@18 "I8326 Accepted

"I838 "?13 Accepted

1"I8888 8"666@ Accepted

"6J "26 Accepted

"66@? "66@?2 Accepted

2"6@12? 6"6@?1J Accepted

? 1I Accepted

"6 "? %* e7ected

"2 "3 %* e7ected

@-I "21 Accepted%* e7ected

Accepted

"@26 "21@@ e7ected

1"1I 8"3I Accepted






%* - lectric arc -Tier 1 (not inF:9)





%* - <asic o&ygen-Tier 1 (notin F:9)






%* - open hearth furnace-Tier1 (not in F:9)

%* -pig iron-Tier 1 (not inF:9)






2 I Accepted

e7ected

"8 "J1 Accepted

e7ected

J-I "1I Accepted

e7ected

e7ected

"3? "@1J Accepted

"1? "32 Accepted

2 I Accepted

"I 1"I Accepted

1"I8888 8"?8888 Accepted

e7ected

e7ected

26"88?I I2"JI@ Accepted

J"1@@8 1?"6@2 Accepted

1"J1?3 21"?86@ Accepted

"1II@ "8?J1 Accepted

?"@3613 21"?@2I Accepted

11"632I 28"2?3J Accepted

11"618 2@I"3@2 Accepted




%* - cast iron-Tier 1 (not inF:9)











%* - primary copper-Tier 1The unit (g>g) aluminium should be

corrected in g>g copper %* - primary copper-Tier 1The unit (g>g) aluminium should becorrected in g>g copper

%* - primary copper-Tier 1The unit (g>g) aluminium should becorrected in g>g copper


%* - primary copper-Tier 1The unit (g>g) aluminium should be

corrected in g>g copper %* - primary copper-Tier 1(called in the F:9 under Tier 2) - Theunit (g>g aluminium) should becorrected in g>g copper




13"II@? 2J"11I6 Accepted

"2@I "I1?J Accepted

11"632I 2J"162 Accepted

116"32I 2J1"62 Accepted

"I@1@6 2"I?83 Accepted

1"138I2 3"I@3J Accepted

e7ected

e7ected

"I@1? "1@1I8 Accepted

I@"1@62 22?"@I Accepted

83"J2@3 6J"?I3? Accepted

e7ected

e7ected

136"?@1 I?@"3?I Accepted

"@8386 2"J8@32 Accepted

2"28@ I"133J Accepted

e7ected"II?8 1"82 %* - primary lead-Tier 1 Accepted

"2212? "?J@8 %* - primary lead-Tier 1 Accepted%* - primary lead-Tier 1 e7ected

"III2I "?82?? %* - primary lead-Tier 1 Accepted%* - primary lead-Tier 1 e7ected

32"JJ?? 1IJ"388 %* - primary lead-Tier 1 Accepted

%* - primary copper-Tier 1(called in the F:9 under Tier 2) - Theunit (g>g aluminium) should becorrected in g>g copper

%* - primary copper-Tier 1(called in the F:9 under Tier 2) - The

unit (g>g aluminium) should becorrected in g>g copper



%* - secondary copper-Tier 1(not in F:9)






%* - primary copper-Tier 1(called in the F:9 under Tier 2) - The

unit (g>g aluminium) should becorrected in g>g copper

%* - secondary lead-Tier 1(not in F:9)








"1I "21 Accepted

"I2I "1I Accepted

e7ected

"@383 1"11I1 Accepted

e7ected

?"8@3@2 16"@3J3 Accepted

"@ "J %*-primary lead e7ected

"I "1I %*-primary lead e7ected

"1 "1I %*-primary lead e7ected

e7ected"6? "1?28J %* - primary Hinc-Tier 1 Accepted

1"183?@ 8"J81I2 %* - primary Hinc-Tier 1 Accepted%* - primary Hinc-Tier 1 e7ected

1"I133@ 6"I@J %* - primary Hinc-Tier 1 Accepted

%* - primary Hinc-Tier 1 e7ected3"3I?38 2@"I618 %* - primary Hinc-Tier 1 Accepted

e7ected

"J@2@I 8"?J11 Accepted

2"1?22 ?"@2?J Accepted

3"?68@6 83"368 Accepted

"2381? "@2JII Accepted

1"62121 3"I83 Accepted

Accepted

"828 "J6? Accepted

Accepted

%* - primary lead-Tier 1(called in the F:9 under Tier 2)






%* - primary Hinc-Tier 1 (calledin the F:9 under Tier 2)





%* - secondary Hinc-Tier 1 (notin F:9)







8"23238 ?"16@ Accepted

Accepted

"@ "J %*-Hinc e7ected

"1 "2 %*-Hinc e7ected

"1 "1 %*-Hinc e7ected

I 1J

66 I8

6 2

Accepted

Accepted



The mission factor is specific for

ermanyK eference# D" Thelo!e"':$-missionen aus derksemittelanwendung undkglich!eiten Hu ihrer inderung"Fort-schritt-<erichte 9, eihe 1I 'r"2I2" 9sseldorf# 9,-erlag.(9issertation). 2I


The mission factor is specific forermanyK eference# D" Thelo!e"':$-missionen aus derksemittelanwendung undkglich!eiten Hu ihrer inderung"Fort-schritt-<erichte 9, eihe 1I 'r"

2I2" 9sseldorf# 9,-erlag.(9issertation). 2I


The mission factor is specific forermanyK eference# D" Thelo!e"':$-missionen aus derksemittelanwendung undkglich!eiten Hu ihrer inderung"Fort-schritt-<erichte 9, eihe 1I 'r"2I2" 9sseldorf# 9,-erlag.(9issertation). 2I


g>m2 uropean $ommission (26d).,ntegrated *ollution *revention and$ontrol (,**$). eference 9ocumenton <est Available Techni+ues (<F)for the %urface Treatment of etalsand *lastics. August 26

electronic components !g>t wafer $arloTroHHi (*rivate $ommunication. 2?)



Accepted

e7ected

Accepted

Accepted

Accepted

"1 "8 %* e7ected

e7ected

e7ected

Accepted

"1 "8 %* e7ected

"I "@ %* e7ected

Accepted

"3?8@ "13I11 %* Accepted

%* e7ected

g>m2 6811 Adhesive Tapeanufacturing (<F)

http#>>www"ssb"no>emner>1>3>1>rappPemissions>rappP2@8?Pen>rappP2@8?Pen"pdf page 11. tabel @"2.unit N !g>ton






http#>>www"ssb"no>emner>1>3>1>rappPemissions>rappP2@8?Pen>rappP2@8?Pen"pdf page 11. tabel @"2




"682 "11?1@ %* e7ected

"3?8@ "1J83J %* Accepted

"3?8@1 1"J83?6 %* Accepted

"J6@ "1J8I %* Accepted

Accepted

Accepted

http#>>www"ssb"no>emner>1>3>1>rappPemissions>rappP2@8?Pen>rappP2@8?Pen"pdf. page 112

http#>>www"ssb"no>emner>1>3>1>rappPemissions>rappP2@8?Pen>rappP2@8?Pen"pdf page 112



Action taken Comments

eplaced with A*32 fs

eplaced with A*32 fs

eplaced with A*32 fseplaced with A*32 fseplaced with A*32 fseplaced with A*32 fseplaced with A*32 fs

eplaced with A*32 fseplaced with A*32 fs

obert - please can you loo! into this

obert - please can you loo! into this

9one

9one

9one

9one

9one

'eed to address %ulphur emissions - willreplace with % N wt% in fuel and defaultF using default sulphur content (made

e&plicit in te&t)





,-TF



%ee first comment



%ee first comment



%ee first comment





%ee first comment







%ee first comment





'ot included at this stage" $ould be done atlater stage"






















'ot included at this stage" $ould be done at

later stage"






9one

9one

9one

9one

9one

9one

9one

pdated

pdated

pdated

:ld0 uideboo! references will all beupdated and referenced to original source









pdated

alue N . so not ta!en into account

pdatedpdatedalue N . so not ta!en into accountalue N . so not ta!en into account

alue N . so not ta!en into accountpdatedpdatedpdated

JI confidence interval estimated

'ot included yet" ,s not one of thepollutants in the protocol" *erhaps this canbe included in separate (not Tier 1>2 tables)somewhere in the te&tG







accepted %* list only F0s for mercury



accepted %* list only F0s for mercuryaccepted



alue N

'o value





'o value

'o value

'o value

'o value

'o value

'o value



'o value

'o value

'o value

'o value

'o value

'o value

'o value



'o value

'o value

'o value

'o value

'o value

'o value

'o value

'o value


'ot included yet" ,s not one of thepollutants in the protocol" *erhaps this can

be included in separate (not Tier 1>2 tables)somewhere in the te&tG




Added to chapter and database

Added to chapter and database , suppose ':$ is meant ($:G)

'ot included yet" ,s not one of thepollutants in the protocol" *erhaps this can

be included in separate (not Tier 1>2 tables)somewhere in the te&tG



'ot included for now" A,'% weightedaverage over all countries seems moreappropriate as Tier 1

%hould we use this as the Tier 1G :r theweighted average of A,'% as we havenowG

'ot included for now" A,'% weighted

average over all countries seems moreappropriate as Tier 1

%hould we use this as the Tier 1G :r the

weighted average of A,'% as we havenowG

'ot included for now" A,'% weightedaverage over all countries seems moreappropriate as Tier 1

%hould we use this as the Tier 1G :r theweighted average of A,'% as we havenowG

, suppose ':$ is meant ($:G)F is for boat building

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