List 2

This file contains all the comments received during the official review period (February 26 - April 1) for
the draft revised Guideb
There are separate worksheets in this file:

- General comments: addresses comments that are generic and not specific for a certain chapter
- General Guidance comments: comments addressing General Guidance chapters. Comments are sorted by chapter number.
- Sectoral - textual comments: comments addressing the text in one of the technical chapters. Comments are sorted by NFR c
- Sectoral - EF comments: comments addressing emission factors in one of the tables in the technical chapters. Comments ar
Comment
In copying text from the IPCC GLs, frequently inappropriate reference to GHG inventories remains. This must be
checked and corrected everywhere.
The references in Tables don't have correspondence in reference list. It's often impossible to understand where the
original emission factors are retrieved. The reference: Guidebook (2006) or CEPMEIP (2004) are not acceptable,
they work as "Chinese nested boxes": substitute with original references! Also the reference "Visschedijk, 2004" is
not a reference to the work where the user can found EF and detailed explanation of their derivation. The
reference Espreme what means: the reference must be to a document where the methodology to derive EFs is
explained.
The table 3.1 of the model chapter (cement as agreed in Dessau) is not implemented in many chapters (e.g
transport), it provides the necessary overview of where emissions are to be expected or not. Please include a
similar table in all chapters.
In the box "major changes since previous versions" please remove the remark on Tiers and the Thessaloniki
meeting. On the other hand the comment in this box should be chapter specific, for example poit out if methods or
emission factoes have been revised (which rarely is included), please add this information. This comment is
generic to the entire guidebook.
Figure and table numbering is not harmonised throughout the revised Guidebook, this must be ensured before
publishing
Everywhere where appropriate the new name of the Guidebook must be used (the name change will almost
certainly be approved)
Comment relates to unc chapter (not in the drop menue): Please make reference to the requirements in the IIR
The formulas do not appear uniform: in some cases the legend is missing.
The new Guidebook must clearly describe where emissions of HM and POPs are expected emitted (ir not
expected) (this is in line with the scope of the project). The version sent out for review has many gaps in this
respect. Furthermore improvements in information on HM and POPs are expected through support by Germany
and the Netherlands, this information must be included in the next version (prior to the TFEIP meeting)
The figures do not appear uniform. The explanation for the blue arrows is missing from time to time (but e.g.
Chapter 2.A.1. Figure 2-1 is OK) and in some cases heat (or fuel) are not denoted. See below
The draft Guidebook use a mixed terminology for substance vs (air) pollutants, please consult the Guidelines and
harmonise text everywhere
The Guidelines use the term "Key category" (agreed by TFEIP), the GB mus be consistent with this decisions (text
and decision trees) (in the current draft both terminologies are used, even within the same chapter, while key
source is most frequently used)
One objective of the project is to facilitate maintenance. Nevertheless, throughout the Guidelines there is a lot of
repetition of information. Examples are definition of TCCCA and reference to the Guidelines. Please ensure that
such repetiton as far as possible is avoided.
The Guidebook is endorsed by the Convention, consequently the term Party is correct (and not MS), and the GB
must be written this way (the current draft not alwyas is). However a statement can be given to explain the role of
the Guidebook under NEC. The term "country" is neutral
The whole draft needs to undergo a proper QA/QC by the consultantst, in the draft many references are missing,
tables refereces are not correct, terminology (outline/numbering) is inappropriate/inconsistent and copy and paste
mistakes makes part of the text meaningless
Scientific improvements: In the agreement betweeen the Commission and EMEP in starting this project some top
priority scientific improvements were setteled. I have looked into a couple of these: i) for solvent use some of the
T2 emission factors given are 18 years old (the rest are more than 10) (e.f domestic solvent use, some solvent
chapters are updated), ii) fugitive emissions from fuel - parts updated - but not the very important chapter on fuel
(gasoline) distribution iii) waste (landfills and waste incineration) - landfill chapter is empty waste incineration
chapters have not been updated. All these are examples of sectors where technology has been changing and it is
likely that the provided information is outdated. Hopefully the consultans can fill these gaps before the next version
is sent for review.
In some cases different technologies/abatment system are defined introducing EFs for each technology (for
example for Volume 2C) in some case new technologies/new products are introduced under abatment (for
example for Volume 3). It's better to produce alwaays EFs tables (non reductions) with technology/products and
put them in section 3.3.2. I think the approach must be unique!
Comment relates to unc chapter (not in the drop menue). Please cite the last draft Guidelines (same comment to
be sec 7 of this chapter)
General guidance: throughout the chapters 'key categories' is interchangabley used with 'key sources'. A variety of
capitalisation is also used: Key Source, key sources etc. Please standardise across all chapters (it should be key
category in the UNECE context)
The number of signicant digits provided throughout the different chapters vary greatly. E.g. 0.1 (Lead - Residential
- Biomass - Fireplaces) and 0.124467 (Lead - Residential - Solid fuels - Stoves)
A contact address would be extermely helpful (in order to refer any questions to / to report additional evidence).
Probably, the Expert Panel chairs are most appropriate to be mentioned.
Numbering of tables and figures in general guidacne chapters needs standardising. Sometimes Fig 1, Fig 2 etc is
used, other times Fig X.1, Fig X.3 is used where X is the section number - Please standardise across all chapters
In far too many instances, material copied and pasted from IPCC Guidelines still contains inappropriate references
to eg other sections or Volumes of the IPPC docs. Please check and correct across all chapters
Terminology. In several general guidance chapters mention is made of reporting obligations for signatories (or
signatory Parties etc) to the various Convention protocols. The obligations are actually only placed on Parties that
have ratified the protocols (i.e. a number of parties have signed but not ratifed protocols). Please correct
terminlogy across all general guidance chapters
General guidance chapters: references to a Party to the Convention should have a capital P. Member States
should also be capitalised. Please standardise across all chapters
In many places the 2006 draft GB cites the previous GB for emission factors. It was agreed at the AEG meeting in
Dublin that this only would be a last resort (jfr page 3 of the minutes). This must be updated where the original
references are available in the current version of the GB (in most cases it is). Furthermore, the referencing to the
current version of the GB is different in different chapters.
Pollutant subscripts eg NH3, SOx NOx etc. Please standardise across all chapters
When all tables are equipped with a column providing the unit it is incomprehensible why this has not been utilised
to ensure more meaningful emission factors, e.g. 4 mg/GJ instead of 0.004 g/GJ.
General guidance: several times CAF is used with accent on the E, please correct to CAFE. Please standardise
across all chapters
Some general guidance chapters use footnotes to provide reference details, while other references are included in
the reference list. If a reference list is included ina chapter avoid use of footnotes.
Styles - not consistent across general guidance chapters i.e. sometimes Level one headings are ALL CAPS,
sometimes Sentence case, sometimes Title Case. Needs to be standardised.
References- for three authors or more in the text use Surname et al (year). Please standardise across all chapters
Reference list provided in each chapter - should be alphabetical, in ascending date of publication and following
consistent format i.e. authors (year) Title etc. Please standardise across all chapters
The references need checking in all general guidance chapters (& sector chapters). In a number of cases
references appear in the text but not in the reference list and vice versa
Abbrevaiations are not always explained. I recommend an explanation in the general volume or separately in the
volume on each sector.
Need a consistent use of CLRTAP, LRTAP or LRTAP Convention - all three are used interchangably. Please
standardise across all chapters (to LRTAP Convention?)
Proposed
decision
Action taken
Accepted
Comments
Try to avoid this as much as possible. Check mainly
the GG chapters for these errors!
Noted
Done for as far as possible
As agreed, we will take EFs from (peer-reviewed)

literature or at least publicly available references as
much as we can. However, in quite a number of
cases we don't have anything better!
Accepted
Done for most chapters
I assume it is meant to fill the "Not Applicable" and

"Not Estimated" boxes with all relevant pollutants.
Accepted
Revised in many cases.

Comment about Tiers removed.
Accepted
Done
What is the exact new name? I'm not sure. Remains
to be done.
Accepted
Accepted
Accepted
Accepted
Accepted
Done
Done
More explanations added to the
figures where necessary
Accepted
Accepted
Remains to be done. What is exactly meant?

Legends to be completed with every formula where
appropriate
The EF tables will clearly display if emissions of each
pollutant are expected for this source category
(according to reporting template). All contributions
from Germany & Netherlands will be included in final
draft.
Try to do this as much as possible
Done
We'll try to avoid unneccessary repetition, but must
keep in mind that the Guidebook is over 1700 pages
Accepted
Accepted
Done
Accepted
Done, at least to a large extent
Use country as much as possible to avoid this issue
Noted
Solvent use - All chapters except domestic use (for

this one no new information available) have been
significanly updated with input from the industry, I
therefore do not agree with this comment.
Fugitives chapter has been updated in consultation
with CONCAWE.
Waste incineration - no other new emission factors
available.
Rejected
This approach was presented already in Dessau

(May 2007) and approved for as far as I know. No
time to change it now.
Accepted
Done
Accepted
Done
Checked, corrected where too
much digits
Accepted
Accepted
Accepted
Done, X-x used where X is

section number
Accepted
Checked
6 digits too much, does not reflect the uncertainty of

the numbers
Remains to be done, but decision on this is needed
before.
Noted
Accepted
Done
Accepted
Editorial
Done
Done as much as possible
Referencing to old Guidebook harmonised. We'll refer

to original literature as much as possible.
Noted
Editorial
Done
Footnotes sometimes explain more than just the
reference.
Noted
Accepted
Checked
Accepted
Checked
Accepted
Done
Accepted
Done
Accepted
To be discussed, one glossary might indeed be better

than separate ones in each chapter
Accepted
Harmonized in GG chapters as
much as possible
Chapter_I
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37
8 Projections
8 Projections
8 Projections
8 Projections
1
2
1
13
8 Projections
15
8 Projections
8 Projections
2
2
25
26
8 Projections
8 Projections
8 Projections
2
3
3
7
3
1
8 Projections
18
8 Projections
8 Projections
12
8 Projections
8 Projections
17
8 Projections
16
10
16
8 Projections
15
8 Projections
8 Projections
8 Projections
8 Projections
4
4
1
10
4
4
2
12
8 Projections
11
8 Projections
23
26
8 Projections
15
8
8
8
8
Projections
Projections
Projections
Projections
4
5
5
5
4
2
15
18
14
8 Projections
10
8 Projections
17
22
8 Projections
8 Projections
10
8 Projections
8 Projections
5
6
12
1
16
8 Projections
8 Projections
8 Projections
8
8
8
8
8
8
8
Projections
Projections
Projections
Projections
Projections
Projections
Projections
6
7
7
7
7
7
7
1
17
19
22
1
4
14
8 Projections
8 Projections
8 Projections
7
7
7
19
23
33
8 Projections
8 Projections
7
7
29
17
8 Projections
8
8
8
8
8
8
8
Projections
Projections
Projections
Projections
Projections
Projections
Projections
8
8
8
8
8
8
8
29
22
5
4
5
22
21
8 Projections
18
13
8 Projections
8 Projections
9
9
25
25
8 Projections
10
24
8 Projections
8 Projections
8 Projections
10
10
10
4
14
20
8 Projections
10
13
8 Projections
10
8
8
8
8
Projections
Projections
Projections
Projections
10
10
10
10
14
17
18
19
8 Projections
8 Projections
10
10
20
22
8 Projections
10
23
8 Projections
8 Projections
10
10
24
29
8 Projections
10
35
8 Projections
8 Projections
10
11
39
1
8 Projections
8 Projections
11
11
41
38
25
10
11
15
40
8 Projections
8 Projections
11
11
1
38
11
8 Projections
11
8 Projections
8 Projections
8 Projections
11
12
13
35
26
17
11
37
8 Projections
13
20
13
20
8
8
8
8
Projections
Projections
Projections
Projections
13
13
13
13
20
17
18
20
13
22
8 Projections
8 Projections
13
13
21
20
8 Projections
8 Projections
14
14
16
31
8 Projections
14
32
8 Projections
15
8 Projections
15
8 Projections
16
8 Projections
16
8 Projections
8 Projections
8 Projections
16
16
18
17
6
17
8 Projections
22
15
16
8 Projections
8 Projections
Comment
Proper references should be given to EC legislation and
Convention etc mentioned in the text
Proposed
decision
Action taken
Noted
Amended
I felt Appendix C fuels should be deleted from this chapter,

as it is technical material being presented in a nontechnical chapter. A table of fuels is repeated in
Methodological choice chapter - just present this Fuels
information once (i.e. in the more technical Methodological
chapter)
Accepted
Appendix A (pollutants) and Appendix B (sectors) should
be deleted. Instead reference should be made to the
Guidelines which is the single source where this
information should be defined. Also helps future-proof the
text and removes potential user confusion - e.g. already
there are inconsistences between the pollutant list with
what is in the latest Guidelines
Accepted
These sentences should be deleted - not future proof (i.e.

will be out of date in next years version of the GB already) Accepted
Ridiculous statement: there is a relationship between the
resources allocated and the reliability of the emission
inventory
Noted
Some 'scene setting' is needed, to explain the importance
Rejected
of emission inventories
SNAP is developed by TFEIP not ETC, in the past there
was a SNAP/NOSE committe in cooperation between EEA
and Europstat.
Rejected
NFR was further developed in 2006 and 2007 in revising
the GLs, please correct
Accepted
Please also provide information on the improvements

made to HM and POPs through the support by Germany
and the Netherlands
Please specify that only Tier 1 and Tier 2 methods have
been updated. Many needs for updating Tier 3 methods
have been identified, but were outside the scope of this
project.
SNAP97 was developed by CITEPA or ETC/AE
respectively ?
EEA's THEN European...
typo - change to to in.
Rejected
Noted
Accepted
Editorial
Editorial
Signatories do not have reporting obligations - only parties

that have ratified do (many Parties have signed but not
ratified protocols). Needs rewording throughout chapter
Accepted
Guidelines - first time of use properly define and reference Editorial
Not sure what this is referring to
Text amended
Self evident
The current Guidebook credits the
ETC/AE
track changed (page 2, lines 34-39)
The Task Force relies on, and is
grateful for, contribution from a
number of countries; it would be
invidious to acknowledge all
contributions.
The previous version referred only to
Simple and Detailed methods, the
text has been revised.
The current Guidebook credits the
ETC/AE
Text amended to countries that

have ratified Convention Protocols
Change wording of 'updated where necessary' i.e. not all

needed updates have been done by this project
typo - hereafter CALLED
Superscript the footnote reference 1
Accepted
Editorial
Editorial
Convention - first time of use please write out formal name

of Convention, define abbreviation (see general comment)
and properly reference
Accepted
typo - word Guidebook missing
Editorial
Appendix A should be dleted. It's already inconsistent with
the latest GL. Use instead text such as 'for those
pollutants for which reporting is required as defined in the
EMEP reporting guidelines
Accepted
Correct typos in these bullets - procedures, users to, levels
of
Editorial
Kyoto protocol and IPPC Guidelines should be properly
referneced at their first time of use
Noted
Please insert compliance checking under the Protocols of
the Convention and an explicit reference to EMEP
modelling activities (disopersion and integrated
assessment)
Please delete text "Such a knowledge" under rest of the
sentence, this does not belong here
Delete 2008 - not future proof
Emissions data is no longer reported to UNECE
Secretariat (now to CEIP). Reword
NEC - reference this and defien abbreviation which is later
used - NECD etc
Delete 'and actors' - its jargon
parties should have capital P throuighout chapter
Please use the exact wording of the last version of the
Guidelines (consult the Secretariat). The term "Member
states" must NOT appear, but "Parties"
Please check - Defintions of TCCCA elements here need
to be identical to the defintions used in the latest draft
Guidelines
Include para on Recalculations - it is very important and
should be highlited
consider to change 'this' to 'relevant' or 'appropriate'
directive
Include info what is the purpos of this section
Noted
Text amended
Text amended
Text amended.
Compliance checking is already
included. There is reference to
suitability for monitoring. EMEP is
now referenced directly.
Accepted
Editorial
Accepted
Editorial
Editorial
Editorial
Editorial
Accepted
Accepted
Noted
Accepted
Replaced All
Definitions are now based on the
IPCC 2006 Guidelines.
A Note has been added to the
Transparency definition
Text amended
Section 3 Concepts are introduced
in lines 7-9
consider to change 'Concepts' to 'Glossary' or channge the

system of paras instead of alphabetic order group
sysetmetic ( it takes some time to undersatand whats
about )
Rejected
Intorduction amended. N.B.Readers

might rightly expect a glossary to be
more comprehensive and Definitions
is equally confusing in this context.
This paragraph states that the guidebook covers all

pollutants, however there are significant shortcomings with
regard to HCB and PAHs. The PAH's have for stationary
combustion been lumped together.
Noted
The comment is not relevant to this

section of the Guidebook.
TNO will as a side project add information on new POPs

for consideration into future protocols (also resulting from
product use). Please update the text accordingly
Rejected
Please see general remark to use of the term "substance"
vs "air pollutant"
Accepted
In accordance with TFEIPs decision, the Guidelines are
using the term "key category", please be consistent with
the Guidelines
The Task Force relies on, and is

grateful for, contribution from a
number of countries; it would be
invidious to acknowledge all
contributions.
Text amended where possible
Accepted
Replaced All
terminology - do not use key source. The agreed term

under UNECE is key category. Correct here and
throughoput all chapters (also, do not captilisise this term if
used in middle of a sentence)
Accepted
Replaced All
delete 'actual nature and' . Reproting formats are the

same for all directives , countries just do not need to
complete columns if not ratified protocols
consider to use 'CLRATP' and 'NECD' inventory instead of
LRTAP and NEC (trough the whole report)
Parties' should be Party's
typo - 'in that helps' is missing a word(s)
Please check - use of signatory versus ratified for the EC
Party TO the
The EMEP GL should have been properly referneced
before, so dont need full refernece and weblink here
replace covers with 'designed to'
Propose to delet Appendix B in which case reference to
the Appendix here should be removed
delete sentence - this is reporting specific and is different
for eg NEC. Instead use text ' A national total iseach
pollutnat and categories as defined in the repsective
reporting requirements
consider to add sentence like 'Relevant information shell
be provided in IIR'
replace gas with pollutant
delete reference to EPER Guidance - is outdated and
replaced by E-PRTR Guideance. In any case I didnl;t see
any reference/common approaches with to EPER/E-PRTR
Guidance in later chapters so perhaps should be deleted.
Please also introduce abatement as it frequently used in
compiling air pollutant inventories
Text appears partly repetition of a prev paragrap, please
streamline
Text should be under the Scope section
Prefrably introductory text should be user manual like and
not a novel. It is not easy to find in the text what the user
you looking after. Consider to highlit the 'key words' and
other options to structure the text
Editorial
Noted
Editorial
Editorial
EMEP prefer LRTAP, NEC Directive

used
Added "it"
Editorial
Editorial
Editorial
Editorial
changed to 'is designed to cover'
Noted
Editorial
Added "and category as defined in

the repsective reporting
requirements"
Accepted
Accepted
Accepted
Accepted
Text amendment made
Accepted
Noted
text removed
Text amended - no longer relevant
Rejected
Not practical, would introduce too

great a change to the style of the
document.
What kind of key sources are you refering to, avaerage in

Europe or ? Consider explanation as a foonote?
Rejected
In the Chapter there is a Table 3-3 which provides the

rating definitions and typical error ranges used in the
Guidebook.However, there are commonly used rating
definitions developed by theUS EPA. All of the emission
factors in e.g. AP-42 are given an EPAquality rating. These
have been copied in previous versions ofCorinair where
EPA EF's have been given.Other US institutes, eg API also
use the same quality codes.However, the EPA quality
rating definitions and those in Table 3-3are not the same,
and this could cause confusion if the userof the Guidebook
is not aware of this.It is proposed that a new paragraph is
added after line 22, page 7,just before Table 3-3, as
follows:"It should be noted that the definitions of emission
factor quality ratings given in Table 3-3 are not the same
as the definitionsused by the US EPA. Where emission
factors developed by the US EPA or other American
technical institutes are used, the US ratings A, B and C
can be considered to be equivalent to the ratings A, B and
C in Table 3-3. However, US ratings D and Ecan be
considered to be equivalent to ratings C and D in Table 33.The US EPA has no equivalent to the Corinair rating E
as allemission factors developed by the EPA are from
measurement andnot from engineeering calculation."
Accepted
typo - or IS missing
Editorial
Key Catgories are now a defied

concept in section 3.
Footnote 2 added.
Please change text to " report emission data to the

Convention to fulfil their obligations under the Protocols.
These protocols are
Editorial
"Relevance" has not previously been defined (page 4),

and needs some more explanation. The remaining text of
the par appears redundant with previous text
Accepted
Paragraph deleted.
Accepted
Editorial
Editorial
Editorial
Text abridged
To support more easy maintenance I propose not

repeating the information from the Guidelines here. The
same applies to following paragraphs (e.g NEC and
UNFCCC), the text should be made more general
Parties - capital P
reword - secreatriate no longer receives data
Guidelines need to be properly referneced
The Convention on long-rangeand its abbreviation
doesn't need defining in every new subsection.
use word pollutnats instead of species (species means
soemthing else)
Emissions should be reported in the NFR format for year
X-2 by the 15th February each year; that is not a realistic
proposition; between 15 and 30 of March will be more
realistic
Editorial
Accepted
Noted
No longer relevant - text has been

amended
Remove bold formatiing for GHG legislation - this isnt

done elsewhere
Consider to reference also LPS directive
Dont have gapo between UN FCCC - is not commonly
done
There is no mention of the on-going review of the NECD the text should be updated to reflect this
NH3 not ammonia for consistency
Editorial
Editorial
Editorial
Noted
Editorial
footnote 2 - has variuos superfluous sub-footnote

numbering included - delete. These documents should
also be fully references in the refernece list of the chaptetr Accepted
replace should with may. It isnt justified to make such a
conclusion here
Accepted
No mention of upcoming review of the EU-MM - text

should be updated to mention this important aspect
legislation, not Law
typo in title
the the
typo - sources
Details of the enrty into force of the protocol should be

given
No longer relevant - text has been

amended
Rejected
Accepted
Editorial
Editorial
Editorial
Rejected
The international PRTR started at the conference in Rio de

Janeiro in 1992 where all countries were in the so-called
Agenda 21 advised to establish a Pollutant Release and
Transfer system. OECD took the lead for supporting these
activities in close cooperation with UNITAR and UNEP
chemicals. After a series of regional conferences it was
decided to focus on more technical support using the
experiences from countries having already a more
established PRTR.
Noted
No action taken, wherever possible

the mention of time refereced events
has been avoided for ease of future
updating.
Footnote removed.

the mention of time relative events
updating.
The Kiev protocol , while adopted in

2003, has yet to come intor force.
the mention of time relative events
updating.
Reference to to UNITAR and UNEP

chemicals introduced.
In 2005 the taskforce was merged with the IOMC PRTR

coordination group and is now called the PRTR
coordination taskforce. Useful products are sofar a
resource centre built by Environment Canada and recently
a PRTR portal (www.PRTR.net) providing links with
international and national PRTR activities and information
sources (also by Environment Canada). In 2008 a the
following documents are expected: An overview of quality
control methods (Australie en USEPA), methods for
estimating emissions from small and medium sized
enterprises (Finland), and emissions from product use
(Nordic Council). Japan is working on a paper called
Sharing and Comparing, making links between emissions
and statistical data like national product or number of
inhabitants
Accepted
UNITAR is in 2008 supporting Armenia, ChIle, Ecuador,
Panama and Togo with some plans for further support in
Middle America
Not polluting, but pollutant
mention that E-PRTR also goes beyond requirements of

the protocol (more polls, strciter thresholds)
later that year' replace with october 2009
replace 14 with 22
delete final sentence
replace signatories with Parties
Membership of the TFEIP and the expert panels
Please delete "should allow for maintenance and",
Delete "expert"
What is the "verification" panel?
The text deviates slightly from the panel TOR agreed in
Dublin, is any difference justified?
Noted
Editorial
Accepted
Accepted
Accepted
Accepted
Editorial
Accepted
Accepted
Editorial
Noted
Information not relevant to

theGuidebook.
Added "it goes beyond the
requirements of the protocol,
covering more pollutants with stricter
thresholds"
Text has been amended
Accepted
Dublin text inserted

Sentence changed due to earlier
comment
Noted
text removed
delete: and will be subject to etc

Please consider shortening, e.g describing all TFEIP
meetings would require an annual update of the
introduction.
Text amended
reword - maintenance of the technical content of the

Guidebook is the responsibility of the TFEIP expert panels Editorial
Delete 2008 - not future proof
Editorial
make bold all the CORINAIRXX so the user can see the
development.From the text it is not clear what is the
current system. At the end of this section should be clearly
defind how is refered current system and include also info
on new extended NFR main sectors.
Rejected
Unecessary - this is 'additional

information'. Guidance on using the
Guidebook - and the link between
NFR and SNAP is provided in both
the Introduction and the section on
how to use the Guidebook
text not updated. Delete refernece to ETC/AEM. State

again here that TFEIP is responsible for the technical
content and EEA for hosting
Use numbering instead of bullets
Accepted
Accepted
Consider to Include para explaining the role of the EMEP

Centre on Emission inventories and Projections (CEIP)
http://www.emep-emissions.at/ceip/
Accepted
Consider to include headings EMEP , TFEIP (and CEIP) Rejected
check - EMEP is not formed by a protocol I believe (it

existed before the convention). Replace formed with
'funded via'
DELETE - 'develops the EMEP emissions inventory based
on emission data from Parties' - it doesn't.
delete UNFCCC and Kyoto and replace with NEC and
LRTAP Convention
Group Switzerland with Iceland etc and call EFTA
(European free Trade Area countries)
Capitalise Member States
Add Kosovo to the list
SOER report needs proper referencing

Appendix 1 A Pollutants, The list of POP does not match
with list of the GL
Include in row Dioxins: "expressed as "International Toxic
Equivalents" I-TEQ"
Noted
The 1984 Protocol on Long-term

Financing of the Cooperative
Programme for Monitoring and
Evaluation of the Long-range
Transmission of Air Pollutants in
Europe (EMEP); 42 Parties. Entered
into force 28 January 1988.
Accepted
Accepted
Text made more generic
Accepted
Noted
Accepted
"Member States" already removed in

favour of "Parties"
Noted
Text amended to make it generic

and, as elsewhere in the text,
mention of dated information subjet
to regular review is avoided.
Rejected
Appendicies removed
Accepted
Include more clear definition of PM2.5 and PM10 (possibly

EN 12341 standard => "real world" PM2.5 and PM10
measurements always include larger particles).
Rejected
Please add the additional POPs proposed added to the
protocols (consult Hugo at TNO)
Rejected
consider to incclude column with aggregations used fro
gridding . See http://www.emepemissions.at/fileadmin/inhalte/emep/doc/AnnexIII__Aggreg
ation__gridded__data_Jan2008.doc
I suggest to include in Appendix B "Sectors by NFR code"
corresponding SNAP code
Please use the latest version, consulting Katarina M (UBAV) [there are some smaller differences]
(b) add... and emissions from Cultivation of Rice
Reference to CEIP included

Unecessary - this is 'additional
information'.
Appendicies removed
Appendicies removed
Rejected
Appendicies removed
Rejected
Appendicies removed
Rejected
Rejected
Appendicies removed
Appendicies removed
Table "Fuel": For all pollutants except CO2 it doesn' make

much sense to divide MSW into biomass and fossil
fractions because emission factors will be available only
for total MSW.
The claim that the guidebook includes default emission
factors for all sources and pollutants where applicable is
simply not correct. The guidebook should contain
guidance, but many pollutants from many sources are
listed as not estimated.
General: please also define natural vs anthropogenic
(included in national totals)
Please append a list of abbreviations (SNAP, LRTAP,
TFEIP...)
Rejected
Appendicies removed
Rejected
Appendicies removed
Rejected
Appendicies removed
Rejected
Appendicies removed
Title of chapter and header is spelt wrong. Methodological! Editorial
Changed title and headers
Chapter contains many cross references to other IPCC

Volumes, IPCCC Guidance sections. All need deleting or
rewording
Accepted
The title of the chapter should be added "and identification
of key categories"
Rejected
references have been revised

Title is included already in the
heading box.
typo - uncertainty
Editorial
Removals not repoted under LRTAP convention
Accepted
Change "quick and dirty" to "simple"

Insert text stating the quality criteria of Tier 3 (sent by
email 27.11.07)
Editorial
Accepted
removals removed.
Text added
Give a proper reference for the 'present' Guidebook

Editorial
What is meant by "the present GB"? Please redraft to "the
previous EMEP/Corinair Guidebook"
Editorial
Delete these sentences - referencs to the 'present'
(existing now) GB are very confusing for future readers
and will be irrelvant onve the updated version is published Accepted
To be more clear "The present Guidebook" should be
replaced with "the 2007 EMEP/CORINAIR Guidebook".
Editorial
Text Deleted
If this way of describing methods is kept in the guidebook

the Tier wording has to be changed accordingly
Accepted
Text Deleted
What does * refer to? Correct
Accepted
Text Deleted
The analysis is based on single pollutants, so this text

would mean that the inventory compiler would look for
decision trees etc in sector chapters for categories and for
pollutants.
Noted
Volume B - incorrect IPPC cross-reference - delete or
correct
Noted
Text will be clarified

Can sinks be deleted in UNECE context

Section B - incorrect IPPC cross-reference - delete or
correct
Inventory Management is not the proper name of the

chapter
Volume A incorrect IPPC cross-reference - delete or
correct
Volume B - incorrect IPPC cross-reference - delete or
correct
Figure 1 does not print well and is unreadable - repaste in
at higher quality?
GHG inventory compiler reference - incorrect IPPC
wording - delete or correct
Please delete reference to "greenhouse gas inventory"
(comment applies throughout the chapter)
Decison tree, please delete reference to sinks
Noted
Rejected
This an improved version of the

IPCC QA/QC chapter with more
detailed guidance on inventory
management.
Noted
Noted
Accepted
Figure will be reproduced
Accepted
Text changed
Accepted
Text changed
Accepted
Figure will be reproduced
General: The proposed key-category approach (single

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

that a normation approach should
not be applied and each pollutant
evaluated in its own right. Accifiying
potentials would only address a
subset of pollutants and would not
resolve the issue for other
pollutants
Good - captialise
Editorial
Text changed
I assume the proper reference here is not the "good

practice guidance", please add the correct reference of the
2006 Guidelines
Editorial
Text changed
pollutant - I think key categories is meant
Editorial
Annex 1 - there is no Annex 1. Appendix A?

Since no "annex 1" is available we guess this refers to
"Appendix A"
Approach 2 - add relevant chapter cross reference e.g.
Section 2.X.X
Editorial
typo - particulate
Editorial
Editorial
Editorial
How to take cross-correlations into account is not (neither

in the IPCC GL2006) described. An inclusion of a text as in
the IPCCC GL 2006 p4.7 note 2 should be considered.
table 1 - put in an Appendix - too long for the body of the
text
Large table which does not include very helpful
information.
The b footnote should reflect the NFR codes. The c
footnote is irrelevant
Accepted
Accepted
Accepted
Text changed
Do once other changes made so not
to lose page reference
Accepted
Please compare with latest NFR list and correct as

appropriate. Please check table font (appears mixed, also
in the footnote)
accepted

Table footnote C- what does this mean in the GB

context??? Assessed jointly is relevant to GHGs only??
accepted
Footnote to table - b - reference to IPPC needs deleting or
rewording (NFR?)
accepted

Add Section before 2.4.3
Consult with
Expert
don't know what is meant by this
Panel
comment..
incorrect GHG inventory reference - delete or correct
accepted
This section must be adopted to air pollutant inventories: i)

reference to sinks must be removed from the text ii) the
equantions should be substantially simplified when sinks
are not considered (see the IPCC GPG 2000) iii) change
reference to GHG inventories to air pollutants
accepted
Footnote 3, there are no UNECE emission reporting,
please provide the proper reference
accepted
The chapter talks about Greenhousegas inventories. For
APs we do not expect "removals" so that we can skip
calculation of absolute values.
Text ammended
Text ammended
Text ammended
accepted
Text ammended
Is sink/removal anywhere relevant for NFR reporting (It is

not for Danish reporting)? If not, then change the text
accordingly.
Are removals relevant to UNECE inventory context - if not
delete
accepted
Text ammended
accepted
Text ammended
Superscript footnote references 5 and 6
Editorial
Text ammended
change footnote references to upper case
Editorial
Text ammended
Since the analysis is to be carried out for each pollutant,

the pollutant should be in the heading not as a column.
Rejected
Footnote 6 - incorrect GHG inventory reference - delete or
accepted
correct. Sinks relevant??
Removals relevant??
accepted
It helps with the optional step 2 to

have the pollutant as a column
feature.
text will be ammended
typo - dispersed
For APs we do not expect "removals" so that we can skip
calculation of absolute values.
Editorial
accepted
Since the analysis is to be carried out for each pollutant,

the pollutant should be in the heading not as a column.
Rejected
It helps with the optional step 2 to

have the pollutant as a column
feature.
incorrect IPCC reference? - there is no Table 3.3
accepted
Skip "or removals have increased".
accepted
Skip "or decrease of removals in the future".
accepted
Please make a reference to the IIR

Examples on the actual pollutants and NFR categories
should be worked out
accepted
accepted
Example will be provided
accepted
Rejected

The examples still illustrate the
approach adaquately
The key sources are defined per pollutant in the new

Guidebook, when the example illustrates an other
definition (key sources defined for the different GHG as
GWP).
accepted
It is confusing to display category codes within the

example that are not consistent with the recommended
ones (cf. table 1), as far as they relates to the new IPCC
categories, from IPCC GL 2006 which are not yet applied
even for UNFCCC reporting yet.
accepted
accepted
accepted
accepted
Chapter 2.6 Examples of key category analysis should be

deleted, if the reference is given in the spec. chapter in the
IPCCC GL, then it should be refer to that. Otherwise an
examle with the air pollutants should be given!
accepted
A quarter of this chapter is dedicated to illustrate key

source analysis, too many pages? Why showing
contributions of sources that are not key sources? Is the
chosen example relevant?
The example relates to GHG when CLRTAP/NECD
reporting does not concerns GHG.
key categories in bold. No they're not?

tables needs to be put in Appendix - is far too long for
body of the chapter
table 4 - Can we not just have an example relevant for air
pollutants instead of GHGs?
Please provide an example for an air pollutant inventory
(one substance) rather than this example copied from the
GHG inventory guidance
General: We propose a reference system instead of

quotation of all these detailed tables 4, 5, 6, 7, 8 (taken
from the UNFCCC Guidelines).
Consult with
Expert
Panel
References should be in correct order of date ie IPCC

2000 before IPCC 2006
Editorial
Is the exercise meaningfull and is the results to be used

for methodology demands?
Consult with
Expert
Panel
Appendix A is not mentioned in the text - it needs to be
Accepted
This is a mathematical exercise weighing all pollutants

identically and weighing categories accordingly. (What is
meant by the text refering to the annex (page 5 line 7) that
it consolidate the pollutant?)
Noted
its not it's
Text clarified
Editorial
The example assumes 95% treshold for key categories but

the keysource chapter recommends 80%.
Noted
Correct caption numbering
It is now mentioned at the bottom of

section 2.2
issue clarified in text. There are

limited examples for Air Pollutant
Key Cateogrit analysis..
Editorial
If the intention is that countries should perform a combined Consult with

ranking of different pollutants it should be addressed in the Expert
it was agreed to move it ot an annex
main chapter and not only as an appendix.
Panel
by the AEG and discussed in Dublin.
The method for combining the key category analysis
decribed in Appendix A is not mentioned nor referenced in
the main chapter.
Noted
It is now mentioned at the bottom of

section 2.2
What is the result of the proposed combining procedure in

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

number of key categories. It was
agreed to offer it as an option only..
Page 32 line 11 states that this combined ranking

SHOULD be done, however the described approach is
only mentioned as a possible approach.
Noted
The individual ranking and scoring for the rank placng can
bee seen in the right columns.
noted
typo
Editorial
already have a Table 4 in the chapter - renumber
Editorial
NOx
Editorial
will clarify
Consult with
Why the definition of fuels is given in Appendix B, it is also Expert
given in Chapter 1 Introduction Appendic C Fuels???
Panel
will clarify
What is this table doing here? It is misplaced and already
included in the introduction. Please correct
Consult with
Expert
Panel
will clarify
The same fuel table is already included in Part

"Introduction".
"Error! Bookmark not defined"
Editorial
Updated contents table
key sources should be key categories
Editorial
Amended
Mention clearly in introduction that section draws heavily

on IPCC - eg as done for chapter time series consistency
Accepted
P 2, lines 2&3 added
In adopting this to air pollutants, the focus must include

Euroean sources, eg Eurostat and E-PRTRs/PRTRs
Accepted
Test amended to include specific

mention of EUROSTAT and data
reported under the E PRTR
Full stop missing
Editorial
Amended
Please define MS (or better rewrite)
Editorial
Please provide reference to EPER measurement guidance Accepted
MS updated to Microsoft
Note added to Table 2.1 and
reference included.
For some of the points the understanding is not very clear.

I suggest to include some typical examples for each point
to increase the usiblity of this list also for "measurement
dummies"
Accepted
Examples added
Remove bullet point
Editorial
Proper references needed for CEN standards
Rejected
Amended
CEN standards are referred to as
EN
Proper reference needed for EN ISO/IEC
Accepted
Edited where necessary
references should be put in ascending date order. Use

author (date) title format throughout (for books as well as
articles)
Editorial
Amended
Editorial
Amended
Accepted
Text added to P7 2.1.1.
Accepted
Explanatory paragraph added.
Chapter contains many cross references to other IPCC

Volumes, IPCCC Guidance sections. All need deleting or
rewording
Editorial
Will re-assign
No such sections as 1.4 and 1.5. Check and correct
Editorial
reference corrected
1.3 should be 2. Check.
Editorial
reference corrected
typo - component an air pollutant reword
Editorial
delete final colon from the title

General: guidance on use of PRTR data is missing and
must be added
General: reference to guidance for collection of spatial
data is missing
good practice guidance' is IPCC 2000. Clarify wording 'good practice guidance of the IPCC2006 guidelines' if that
is what is meant
Editorial
Revise "is a central component an" e.g. "is a central

component of an"
Editorial
No such section - check and correct
Editorial
typo - insert 'necessary' to prepare...
Editorial
No such section as 5.2.3 - check and correct

Capital R for reporting. Provide proper reference at first
time of use
Editorial
typo - to APPLY different
Editorial
Footnote 2 - Overall rather than overlap? Check equation

numbering - there is no equation 5.1. Correct different font
sizes within footnote
Section numbering - use a 3 digit heading before a 4 digit
heading (there is no 2.1.1)
Figure 5.2 - correct figure numbering (the 5 has no
meaning?)
meaning?)
meaning?)
meaning?)
Editorial
Rejected
corrention made to the font and the

equation number.
Editorial
Editorial
Editorial
Editorial
Editorial
Box numbering - remove 5
Editorial
Equation numbering Remove 5 from 5.2
Editorial
Box numbering - remove 6

meaning?)
Editorial
Box numbering. section not Section
Editorial
Use 3 digit heading numbering

Define AFOLU from figure caption (or delete as not
relevant to UNECE inventories)
Editorial
Box numbering
Editorial
Box numbering
Add horizontal lines to table to improve readibility - 3rd
column not aligned properly
Editorial
Add table numbering
Editorial
table numbering - no 5
Editorial
Editorial
Accepted
Editorial
note added
Volumes - incorrect GHG inventory reference - delete or

correct
Editorial
Editorial
Editorial
Since the FOD has a chapter on QA/QC the refernce in

the parenteses should presumably be changed from the
IPCC GL to the FOD chapter
Editorial
Volumes - incorrect GHG inventory reference - delete or
correct
Editorial
references - arrange in ascending date order
Editorial
General: This chapter has been copied from IPCC Gls,

and need to be properly review with the objective of
changing terminology and references to this manual.
Furthermore, figure numbering needs to be changed
Editorial
If nowhere and for none of the pollutants sink/removal is

actual the text should be looked through and revised
accordingly
Since "base year" might not be precise/unique to the air
pollutants the text should be looked through/revised.
Reference to sections and tables does not match the
sections and table headings.
Uncertainties chapter - There are a number of references
in the text not provided in the references list. Check and
correct
Uncertainties chapter - incorrect reference draft GL
2003?? Update to 2008 draft GL or the existing final 2003
GL
Uncertainties chapter - paragraph not article
Uncertainties chapter - Why table 6.(1)? Correct
numbering - 6 is not relevant
Uncertainties chapter - incorrect reference draft GL
2003?? Update to 2008 draft GL or the existing final 2003
GL
Uncertainties chapter - paragraph not article
Editorial
Accepted
Foot note added to explain Base

Year.
Accepted
Checked
Accepted
Reference sections (main text as

well as appendix) checked and
completed
Accepted
Accepted
Done
Corrected
Rejected
Accepted
Accepted
Uncertainties chapter - Footnote 4. A number of references

are provided with no details given in the reference list. Add
to reference list or delete.
Accepted
Uncertainties chapter - Fig 3.5. correct numbering - there
are no Figures 1-4
Accepted
Uncertainties chapter - AFOLU - define or preferable
delete - not relevant to UNECE inventories
Accepted
Uncertainties chapter - Add references to reference list.
And those in footnote 6
Accepted
Done
Corrected
completed
Corrected
Deleted
completed
Uncertainties chapter - References not in reference list
Uncertainties chapter - Reference not in reference list
Accepted

completed
Accepted

completed
Uncertainties chapter - What are approaches 1 and 2.

these are not defined at all in the chapter? Correct or
delete
Accepted
Uncertainties chapter - Not consistent. Section 3.2.3 does
not give details of Approaches 1 and 2
Accepted
Uncertainties chapter - References not in reference list

Uncertainties chapter - Delete if Appendix is empty
Corrected
Corrected
Accepted

completed
Accepted

completed
Accepted
Accepted

completed
Done
According to me all the chapter is very clear; perhaps for

being more practicable could be appreciated some
operating examples related to the management inventory
report (for ex some sheets related to the main phases
(data request/raw data/compilation/QA_QC)) suggesting a
way to include all info as introduced in paragraph 4.6
Noted
"principles" not principals
Accepted
At this point or/and in the paragraph 2.2 could be better

distinguished the difference between "inventory manager"
and "inventory compiler". As for the first one in page 2 line
19, it'd be specified that also the inventory compiler could
be an individual or staff, one institution or more institutions.
If the inventory manager is external to the inventory
compiler staff, the last one need generally a chief
inventory compiler staff. Probably in the case of small
group they can overlap. Anyway I suggest to point out,
also ahead, that the inventory manager (or chief inventory
compiler staff if different) is responsible for the technical
staff management (how to share resp, if for sectoral or
trasversal topics, how to attribute internal deadline, how to
introduce and guarantee that internal reports in the
differents steps must be filled etc.), as financial budget
management to guarantee hw_sw, data acquisition
availability, inventory related external consultants etc.
Accepted
Corrected
Text added
Footnote 1 - Party not party. Check EC signatory or ratified

protocols
Accepted
Text modified
Add referencing for IPCC documents
Accepted
Reference however should be to the

UNFCCC reporting Guidelines here.
"expamnds" -> "expands"

Please harmonise with latest version of the draft
Guidelines (see also comment to the introduction)
Accepted
Accepted
These TCCCA criteria have different definitions to those in

the GB Introduction! They should be consistent with the
formal definitions in the latest version of the draft
Guidelines
Accepted
Done
Please reference the 2008 Guidelines
Accepted
Copied definitions from the draft

guidelines
Added a reference to the still draft
2007 Guidelines
"Inventory compilers, virtual or real institutions," I suggest

to substitute with "Inventory compilers, one o more
institutions,"
Accepted
Done
One from the data providers would be facility operator
Accepted
Done
EMEP Reporting guidelines - add proper reference
Accepted
Done
"detailed energy statistics" I suggest to remove detailed
Accepted
Done
Delete quite string and replace with fixed
Accepted
Done
"incventory" ->"inventory"
Accepted
Done
delete 2nd part of sentence following Authority
Rejected
We believe that in a text box like this

one the suggestion to harmonize
with the UNFCCC is useful; the
laguage is a bit weekened though.
5 should be 6. Reorder bullets once corrected
Accepted
Done
Styles - not consistent across chapter i.e. sometimes Level

one headings are ALL CAPS, sometimes Sentence case,
sometimes Title Case. Needs to be standardised.
Accepted
Done
A bit confusing the reference to year N and N+1 (line 22)

and to year N and N+1 (line 36). It coul be briefly extended
the first sentence "compiling an inventory is an annual
process" (line 19) by mentionning that activities can
Accepted
Delete should and replace with may. (It's not a requirement
for parties)
Accepted
text updated
Delete bit, replace with rather
Accepted
Done
"sectoral inventory" I'd suggest to remove sectoral
Accepted
Done
It is good practice to
the figure is very interesting, only few comments. Some

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

checks. Made figure a bit larger.
Explain large changes is the first of a
different klind of checks. Therefore
order not changed.
Table 1, please make explicit reference to the IIR
Accepted
Done
Figure 4: please change references to CRF
Accepted
Done
Please update the text for air pollutant inventories

Table 1, there are no good practice guidance for air
pollutant inventories, please change the terminolog
Rejected
The GHG guidance here can provide

support for air pollution inventories
Accepted
Done
No such box. Correct or delete
Accepted
text removed
Delete protocol provisions as this is confusing (not all

protocols reflect this). Instead refer to the applicable text in
the Guidelines
Accepted
Done
typo
Accepted
Done
typo >
Accepted
Done
replace will with may

I'd suggest to move in the previous part ("institutional" or
"contact person")
"institutional" I suggest to change with or to add also
"contact/reference person"
"technical" I'd suggest to change with software or archive
aspects
Accepted
Done
Accepted
Done
Accepted
Done
Rejected
Present text is clear
partial text - delete
Accepted
Done
GAINS should be mentioned as a key source of

verification here (both activity data and emissions)
Rejected
GAINS is to be fed by national

reported data, rather than the other
way around.
Venthoven et al, 2004 is not included in "references"
Rejected
It is included i nthe references
van Velthoven et al for 3 or moe authors
Accepted
Done
NACP missing from reference list - include
Accepted
Couldn't find it, reference removed
In -> An
Accepted
Done
table - data provider: An institution

Please discuss the role of EMEP modellering data for
verification purposes
Accepted
Done
Rejected
Do not understand this
Emissions reporting guidelines should be in reference list

Quality Assurance - Section 6.5 - no such section - delete
or correct
Accepted
Done
Accepted
Done
Rejected
Ijn our view this is exactly what is

meant
I suggest to enlarge the "Inventory system" definition, all

the institution involved in the emission inventory
planning/compilation/dissemination etc..
In Validation . "is" -> "Is"

Accepted
Peter van references should be ordered by surname not
Accepted
first name. Date missing from reference details
Done
IPCC refereences need completeing

Please discuss the role of PRTR data in QA/QC (e.g
verification)
Accepted
Done
Rejected
Is in data collection issues
General: many Parties have integrated UNFCCC and

LRTAP/NEC inventories, but not all. The authors of the
current chapter seems to assume the former. This issue
(institutional set-up) should be better explained, perhaps
even in the introduction (see e.g figure 5)
Accepted
See text box
General: Please define inventory compiler, under the

Convention the responsibility lays with the "designated
emission experts"
Rejected
Do not understand this
Instead of referring to gothenburg, refer instead to the

Reporting Guidelines as the driver for reporting.
(technically various EB decisions also implement spatial
reporting and not just the protocol - its easier just to refer
to the GL)
Editorial
is ALSO required
Editorial
Reporting guidelines- use the reference list for referencing
- not footnotes
Accepted
styles - different chapter sections are in different fonts.
Standardise throughout
Chapter name might be changed to reflect reporting of
gridded data also? - 'Spatially disgagregated emissions
mapping'?
Rejected
Chapter could mention in introduction the basic work of the
chpater was developed by EEA's ETC/ACC.
Accepted
Done
Reference moved to Reference list
Current heading is sufficient to

include gridding.
Some areas of additional guidance are missing from the

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

final version.
Editorial
add para on SNAP

Editorial
I suggest to substitute here and after "50x50 km grid" wirh
Editorial
"50x 50 km2"
I suggest to add after "their dispersion partners" "and
impact area"
Editorial
Among "General Terms" I suggest to keep terms more
related to spatial mapping, (such as NUTS, surroggate
etc., I'd include "GIS" definition) and remove those as
"HDV" and "LDV" for example.
Rejected
typo - gross
Editorial
Delete mention of associated proposed directives - its not

at all clear which proposed directives are being talked
about here
Accepted
Terms left in. GIS added
text deleted
HDV: Heavy Duty Vehicles are vehicles with a gross

vehicle weight of < 3,500 kg ==>>>> Heavy Duty Vehicles
are vehicles with a gross vehicle weight of > 3,500 kg
Editorial
.. by an x and y coordinate"s."
Editorial
I'd try to mention an example for each surrogate resolution

level/type and keeping possibly the same order "as land
use coverage pecentage by grid, vehicle flow by road link,
employers number by industrial point, population by
administrative boundary
Accepted
Say also when the protocol entered into force
Editorial
References for the various legislative acts should put in

the references, not in footnotes. Delete footnote 4 given
earlier comment about the whole table should be deleted
Accepted
text changed
text to be changed
this LPS definition is very messy - mixing up E-PRTR and

Guidelines aspects. Rather directly refer to the Guidelines
as the source where the definitions of LPS for reporting
under the convetion and its protocols can be found.
Mention also that defintions of LPS (sectors, thresholds
etc) can differ between different reporting mechanisms.
Don't provide details of the reporting thresholds and
pollutants here - instead refer just to the Guidelines where
these are defined. This will help avoid inconsistencies.
Mention of the E-PRTR reporting thresholds and faility
defintions should be deleted as they confuses the issue
too much here.
Accepted
text to be changed
Definition of LPS: anything is written about th e stack

height, which is also an important parameter for spatiol
resolution and the EMEP gridding.
Accepted
Note added
Appendix G not Annex 6
Editorial
I suggest to mention that also "trasport emission can be

handled sometimes as area soources, for example arcs
that are too numerous or information are not available to
be individually identified as line sources".
Those cases they can be treated as area source
as polygon or as area source as grid by the use of
different surrogate variable (for example as percentage of
linear emission density or from fuel balance, as difference
between total fuel and linear traffic fuel induced)
Accepted
text changed
typo identify to?
Editorial
typo delete misses
Editorial
I suggest to invite compilers to the use when possibile of

the spatial surrogate used for spatial mapping in previous
years to guarantee consistency
Accepted
text added
As the "example 1" is a bit far from the referring text, I

suggest to include the corresponding page (e.g. Example
1, "pag 9")
Accepted
text added
delete and EU- ETS?

Perhaps the emission total to be distributed is "emission t"
instead of "emission ix"
Accepted
I suggest to include in formula note ..to an "(i)" specific
geographic feature
Accepted
Not 4.2 - should be 4.3 Check.
Editorial
styles - delete full stop from heading and all headings from
here on
Editorial
Check - does the latest CORINE provide 45 or more?
andcovers
Editorial
text changed
text changed
Just provide one generic link to EEA dataservice - specific

links become outdated
EUROSTAT has several useful agricultural datasets, e.g.
From the Farm Structural Survey
Accepted
text added
not Annex II, it's Appendix G

The COPERT refernece can be updated to latest v4
manual available on the COPERT website
text added
Editorial
Accepted
Reference to Guidelines should be updated to latest draft,

not the Thessaliniki one (or final version when agreed)
Accepted
Appendix G not Annex 6
Editorial
Complete reference list for TEMIS
Editorial
Apmosphere reference - Briggs not Brigg
Editorial
There is no mention/consideration given in the chpater to

the gridded NFR GNFR which parties are required to
report spatial data in. This is a major omission from the
chapter and needs to be corrected. At least some short
explanation needs to be given on how NFR emissions may
be aggregated to the GNFR and reference made to the
draft Guidelines where this is defined. Ideally proxy
Consult with Need to ensure we respect the
variables for each of the GNFR sectors should also be
Expert
boundary between reporting and
provided
Panel
methodological guidance.
It should be noted in the text that updated information on
% gas connections etc may be available from Eurostat/IEA
etc. This should be checked before being stated
Accepted
See previous comment - surrogates should also be given
for GNFR sectors, as this is the minium that some Parties
will be able to do
text added
Consult with Need to ensure we respect the

Expert
boundary between reporting and
Panel
methodological guidance.
Hopefully this might enhance the accuracy and

consistency of the reported emission data. It would be nice
also to include a section describing this issue in the
guidebook.
Noted
We recommend, that a common harmonized GIS theme
on coast line and territorial sea should be available for the
member countries reporting gridded emission data. This to
avoid the use of themes with different resolution and level
of generalization.
Noted
Figure numbering inconsistent
Editorial

EMEP is extening area to the east , consider to provide
info and add map with extended EMEP area
Editorial
Editorial
Accepted
will add
I miss any reference to the various guidance material

developed for EU MS compilation and reporting of GHG
projections under the working group of the EC climate
change committee. This at least should be referred to.
Throughout chapter, references need checking (text to
reference list and vice versa)
Throughout chapter mixture of key sources, key categories
and different capitalistaion is used - Key categories, Key
Categories etc. please standardise
change "though" to "through"
"Projections are usually much less certain than the historic
inventory and require... "
"Guidance on tackling common problems associated with
gathering appropriate data on"
delete "data"
Definition of "without measures": what technology has
achieved to date, is confusing. Especially comparing with
terminology on p.3, l.16: without measures scenarios
usually start from a convinient historic year.
delete "to"
change "and" to "or"
Footnote, line1- change "and" to "or". Line3, delete
"resulting"
Footnote 1: Line 1 Delete 2nd 'and'. Line 3 Delete
'resulting' Delete 'resulting'
Delete 'present' and replace by 'represent' or 'derive from'
or 'reflect'
Footnote: Policies and Measures and can be laws - delete
"and"
Accepted
Editorial
Editorial
Included footnote and reference in

the reference section.
Changed all to Key Categories
Editorial
Editorial
Editorial
Accepted
Editorial
Editorial
modified text to remove reference to

technology
Doesn't really make a difference
Editorial
Editorial
Editorial
Editorial
WoM scenario. No actual guidance on how this scenario

should be developed i.e. are emissions to be projected
from a base-year based on GDP for example?
Accepted
Generic text on determining cost-effectiveness is not very

helpful. Some guidance on how an costs can be
determined would be useful.
Consult with
Expert
Some references will be included
Panel
where they are available.
We do not understand this definition. The starting year is

only 1995 or 2000? Or may be the latest year of historic
inventory? We think that this should be topic of discussion
in Tallinn on projection expert panel.
Noted
Change "with" to "where"
Editorial
Change "post the historic year" to "are"
Editorial
Text Unclear, I suggest 'scenarios can include the

estimation of "what would have happened" if the measures
already implemented since the historic year had not been
implemented.'
Editorial
duplication of (b) on line 10 and subsequent lettering
Editorial
Text added to paragraph.
The description has been extended

to include some proposed
methodology for calculation (see
somment in line 16 above.
Texted changed due to another
comment
Texted changed due to another
comment
(c) and (d) are a bit vague- it is not clear how they could
differ from the others. It might be helpfut to give examples
of each?
Accepted
Text updated
It would be also good practice to clearly define the

measures that the WM, WoM and WaM scenarios refer.
Text left unchanged.
Noted
The definitions used for With measures and with additional

measures should be fully in line with what is required for
future reporting under NEC and EU-MM (or in the draft
EMEP Reporting Guidelines or draft decisions if this is
specified there). At present the defintions presented here
differ, and thus need to be harmonsied with those
specified in the formal reporting requirements.
Noted
In the definition for "With Measures" an agreed date,
beyond which policies and measures are not considered,
should be mentioned. For example, legislation, policies
and measures in place by 31st of December of the
previous year will only be considered under the "With
Measures" scenario. Policies implemented in the current
year, when the projection is being prepared should be
included in the "With Additional Measures" scenario.
"targets, which has now been superceded."
change "estimates" to "estimated"
" based on a range of datasets, including"
Consult with
Expert
Panel
Editorial
Editorial
Editorial
It depends how much detail you want to go into here but,

the marginal cost curve in terms of a plot of total quantity
of pollution avoided against the marginal cost of reduction
in euros/tonne, is often used.
Accepted
Future assumptions could also be based on behavioural
changes or structural changes in society.
Accepted
Emission projection scenario should be compiled - either
scenarios should be plural or the sentence should start
"An emission"
Text to be updated.

Editorial
There can also be regional considerations that

necessitates that a measure is carried out despite the fact
that it does not the biggest emission reduction for the
lowest cost. For example health considerations in urban
areas.
Accepted
Generic text on the use of "energy models" to determine

basic growth factors. Guidance on which models are
recommended would be useful.
Figure - can't read the text on some sections of this
Accepted
Accepted
Text added under 3.8

Made more clear
Accepted
Make text in the Tier 2 box read ..

(or adaquate current emission
factors)
Flow Chart: Decision Diamond 2- The last sentence is 'or

are current emission factors adequate' to which I
answered yes and am then told in Tier 2 to use a future
emission factor. I think you have to be clearer on what
question you answer yes or no to
You could give an example eg road traffic model

Not clear what is the difference between Tier 3 and Tier 2.
Tier 2 mentions taking "reasonable account" of future
activity changes. Not very specific.
No caption. Figure poor quality and unreadable when
printed. Paste in higher quality version?
"An emission factor"
Add a comma after "Key Source"
effect
formula is singular; plural is formulae or fomulas
..and involves
Revise sentence beginning at (
Be consistent in the use of 'emission factor' and 'emission
rate'. Insert comma after Source
sector's
=Ads should have upper case D
The emission factor for a source using a specific
technology or control in year n
An emission factor
Accepted
text added
Accepted
text clarified
Accepted
Editorial
Editorial
Editorial
Accepted
Editorial
Accepted
Updated
text changed
Editorial
Editorial
Editorial
Accepted
Editorial
Page 7, formula 2 (row 26): in the denominator is ADn,

where in row 33 is ADn = ADs*GFn. But on page 8, row 1,
the formula for ADn is sum of ADt for t=1 to p. If we set the
formula from page 8 to formula 2, then the formula 2 will
be sum of the emission factors for t=1 to p. We think, that
in formula on page 8 (row 1) should be correct ADt=sum of
ADt for t=1 to p (not ADn).
Rejected
I think that it is worth stating in general terms that in some

complex detailed sectors there can be an interraction
between the emission factors assumed for pollutant
control technologies and the projected activity data. For
example in electricity generation the underlying activity
data maybe future electricity demand. The energy
consumption of the power sector must be consistent with
the electricity demand and the efficiency of the future mix
of power stations. The control measures applied (eg FGD,
SCR, carbon capture and storage) will affect the efficiency
of the power stations and hence fuel consumption. Thus
the assumed mix of emission factors affects the fuel
consumption data. In such cases the assumed mix of
abatement technologies is an input to the model which
predicts energy consumption.
" so that a measure"
" methods, the"
Available - uppercase A
comma after methods
its measures
need to be broken down
Either include a definition of Stratification here, or refer to
it's definition somewhere else
Text changed
Text Changed
Text definition of Adt changed to

clarify that ADt is a sub source of
ADn
Accepted
Editorial
Editorial
Editorial
Editorial
Editorial
Accepted
Text added
Accepted
Definition added
Text added
FGD is Flue Gas Desulphurisation?

FGD: abbreviation is not explained
Editorial
Editorial
Possible addition to list. Compare projected trends in data

(emissions or activity) with historic trends- if there are
significant differences then need to explain why. This is
based on a general observation that national
emissions/activity data tend to change gradually (though
not always eg N2O emissions in chemical industry)
We need some text to explain what this figure means- also
it looks as if the arrows are displaced
portray a picture consistent with
in from Rephrase
Accepted
Text added thank you.
Accepted
Editorial
Editorial
Text added to clarify.

Changed with another comment
There is nothing in this section referring to best practice

used in historic compilation. Either include a reference to
another section of the Guidebook, or add the following
text:
Accepted
Example of simplification - arrows need to be re-aligned in
diagram
Editorial
"It is important to ensure that the resulting emission
projections are consistent with the underlying input data.
The following checks"
"The energy related emissions should be checked"
change "matched" to "match"
" estimates. The overall"
" inventory should be consistent with the energy balance
from"
"The transition"
Editorial
Editorial
Editorial
Editorial
Editorial
Accepted
" projection must be realistic. Check for "

" noted. If there is a large step change, then methods
will need to be modified."
" are correct, and that revisions are transparent."
Rejected
" results and what were the sources of the difference."

More sensible to use domestic as the example for both
e.g.'s
sectors
Editorial
Example: The emission limit value defined by the large

combustion plant directive (Directive 2001/80/EC) for new
coal plant is 200 mg/Nm3 NOx as NO2 (@6%O2).
Applying an appropriate volume factor for coal of 364
m3/GJ (NCV) gives a projected emission factor of 72.8
g/GJ coal consumed. (Reference for the volume factor is
Graham, DP, Salway G, Ray, P. Stack Gas Flow Rate
Calculation for Emissions Reporting - Aguide to Current
Best Practice for the Operators of Coal Fired
Boilers.,PT/07/LC422/R May 2007
based on measured
Text and reference added.
Noted
Editorial
Text modified.
bullet replaced with more
appropriate text.
Text modified.
Rejected
Editorial
text left the same
Accepted
Editorial
Example Added
Needs re-wording eg. ..no surrogates available for source

sectors, it is good practice to assume the projected value
is the same as the latest historic yeear.
" based on measured"
Editorial
Editorial
"to assume that projections are the same as those for"
Editorial
Changed from another comment
Including the impact of non-technical measures is

mentioned. No guidance on how this quite complex task
could be carried out.
Need a heading "Emission factors"
projected
Emission projections are always modelled "and" are based
on.
Accepted
Accepted
Editorial
Some text added.

Some text added.
The paragraph is listed under the headline "Uncertainties",

however it seems to be referring to sensitivity, which is
described from line 26.
typo
change "improve" to "improving"
change "are based" to "or based"
" employed to make all"

This para is about sensitivities, should it be moved ??
Define CART and provide proper reference in reference
list
change "latst" to "latest"
Editorial
Accepted
Editorial
Editorial
Editorial
Editorial
Accepted
Accepted
Editorial
Not a good examples because recent catalytst are not

emitted higher NH3. Choose something simple e.g.
aviation
Accepted
A WoM scenario should not be listed as a necessary
activity for compiling emissions projections.
Accepted
change "be in accordance" to "have a methodology that is
consistent"
Editorial
I think some more detail is required ie some sort of list
refering to elements discussed in previous sections. eg.
values and sources of activity data used, GF factors used,
emission factors, details of tiers, sector definitions, sector
stratification, assumptions made in deriving future EFs.
Again reference to QA/QC activities referred to in textchecking, energy balances, etc
Properly define reference for current guidebook
EMEP/TFEIP (2003) etc
This isn't a bullet point
I note that Sectoral Overview of Methods has been cut
I expect there are similar interractions in transport eg
projected air km and airccraft mix; vehicle km and vehicle
mix.
Changed by another comment to

"or" based
Paragraph moved
Changed sentence to make more

sense, not in exactly the way
suggested.
Paragraph moved
Text ammended
text changed
text changed
Accepted
text changed
Accepted
text changed
Accepted
Editorial
Noted
text changed
Noted
Guidance for projections is very generic. The 2006

Guidance is more comprehensive
Noted
"The best practice principles for emission inventory

compilation also apply for projections. Therefore the
resulting projections will need to be transparent, accurate,
consistent, complete, and comparable."
Accepted
text added
Comments
Additional note(s)
NOTE: not all EMEP members are EU members.
The Guidance for EPRTR is regime specific and not

information of the same generic type as that in the text.
Added "of"
Overlap is meant as this describes the equation.
6 is chapter number, this is the format for table/figure

numbering chosen.
Justin might like to check

Reporting is ALSO required..
Needs new guidelines reference?
Can we change the chapter name?
Aviation and National Navigation methods are already

inccluded
This is supposed to include relevant terms used for the

chapter.
Might want to check this is the best way - one of those links
has already been updated!
Ok but the underlying purpose of the Guidebook is certainly

to assist with reporting (this is why for example it is
structured to NFR which is a reporting requirement, and not
a methodological requirement). It is indeed strange that
the chapter doesn't mention GNFR at all given this role of
the GB. Some information/consideration of GNFR needs to
be added.
Will propose some text for this
See above
Will propose some text for this
1995 and 200 are possible starting years for a WOM

scenario. Other years can be chosen.
Measures will be different for different MS. We can not be

prescriptive about what measures belong where in the WM
WAMs scenarios. The boundary for WM is clearly defined
in the WM text inder items a- f.
Definitions will be brought into line. However, as this is the

latest document in the evolution of our understanding there
may be some enhancements to the definitions in this
document over that of the Reporting Guidance.
Text in diagram will be changed.
Text definition of Adt changed to clarify that ADt is a sub

source of ADn
more appropriate text provided
This example is good because it shows the linkages

between different sectoral data for projections.
Chapter
_ID
Chapter_Name
From ToPa From ToLin

NFR_Code Page ge
Line e
1 Energy industries
1.A.1.a
29
1 Energy industries
1.A.1.a
65
1 Energy industries
1.A.1
20
21
1 Energy industries
1.A.1
10
1 Energy industries
1.A.1
1 Energy industries
1.A.1
1 Energy industries
1.A.1
1 Energy industries
1.A.1.a
12
1 Energy industries
1 Energy industries
1.A.1
1.A.1
6
6
1
2
1 Energy industries
1.A.1.a
24
1 Energy industries
1.A.1.a
15
1 Energy industries
1.A.1.a
19
1 Energy industries
1.A.1.a
20
24
1 Energy industries
1.A.1.a
25
1 Energy industries
1.A.1.a
32
33
1 Energy industries
1 Energy industries
1.A.1.a
1.A.1.a
9
10
32
37
10
37
1 Energy industries
1 Energy industries
1.A.1.a
1.A.1.a
10
10
3
21
11
1 Energy industries
1.A.1.a
10
1 Energy industries
1.A.1.a
11
11
1 Energy industries
1.A.1.a
11
13
11
13
1 Energy industries
1.A.1.a
13
11
13
12
1 Energy industries
1.A.1.a
13
12
13
12
1 Energy industries
1.A.1.a
13
13
13
14
1 Energy industries
1.A.1.a
13
18
13
21
1 Energy industries
1 Energy industries
1.A.1.a
1.A.1.a
13
13
12
13
1 Energy industries
1.A.1.a
13
13
1 Energy industries
1.A.1
14
17
1 Energy industries
1.A.1.a
14
27
1 Energy industries
1.A.1.a
14
27
1 Energy industries
1.A.1
15
15
1 Energy industries
1.A.1
16
17
1 Energy industries
1.A.1.a
18
1 Energy industries
1.A.1
19
24
1 Energy industries
1.A.1
19
24
1 Energy industries
1.A.1.a
19
27
1 Energy industries
1.A.1.a
19
27
1 Energy industries
1.A.1.a
19
27
1 Energy industries
1.A.1.a
19
27
1 Energy industries
1.A.1.a
19
27
1 Energy industries
1.A.1.a
19
27
1 Energy industries
1.A.1.a
19
27
1 Energy industries
1.A.1.a
19
27
1 Energy industries
1.A.1.a
19
27
1 Energy industries
1.A.1
21
21
1 Energy industries
1.A.1
22
22
1 Energy industries
1.A.1
23
23
1 Energy industries
1.A.1
23
23
1 Energy industries
1.A.1
25
25
1 Energy industries
1.A.1.a
25
1 Energy industries
1.A.1.a
25
1 Energy industries
1.A.1.a
26
1 Energy industries
1.A.1.a
26
1 Energy industries
1.A.1.a
28
1 Energy industries
1.A.1.b
1 Energy industries
25
28
29
11
29
13
1.A.1.b
29
40
20
1 Energy industries
1.A.1.b
29
26
1 Energy industries
1.A.1.b
29
28
1 Energy industries
1.A.1.b
30
18
1 Energy industries
1.A.1.b
30
21
1 Energy industries
1.A.1.b
30
25
1 Energy industries
1 Energy industries
1.A.1.b
1.A.1.b
30
31
30
2
1 Energy industries
1.A.1.b
31
1 Energy industries
1.A.1.b
33
11
1 Energy industries
1 Energy industries
1.A.1.b
1.A.1.b
33
34
7
33
1 Energy industries
1.A.1.b
34
33
1 Energy industries
1.A.1.b
34
34
1 Energy industries
1.A.1.b
35
1 Energy industries
1.A.1.b
1 Energy industries
1.A.1.b
33
11
35
35
38
35
38
1 Energy industries
1.A.1.b
35
38
1 Energy industries
1.A.1.b
35
38
1 Energy industries
1.A.1.b
35
38
1 Energy industries
1.A.1.b
35
1 Energy industries
1.A.1.b
36
36
1 Energy industries
1.A.1.b
37
37
1 Energy industries
1.A.1.b
37
37
1 Energy industries
1.A.1
38
38
1 Energy industries
1.A.1
38
38
1 Energy industries
1.A.1.b
38
38
1 Energy industries
1.A.1.b
38
38
1 Energy industries
1.A.1.b
39
39
1 Energy industries
1.A.1.b
39
1 Energy industries
1.A.1.b
39
1 Energy industries
1.A.1
40
1 Energy industries
1.A.1.b
40
40
12
1 Energy industries
1.A.1.c
40
21
40
21
40
1 Energy industries
1.A.1.c
40
21
46
1 Energy industries
1.A.1.c
40
21
46
1 Energy industries
1 Energy industries
1.A.1.b
1.A.1
40
42
12
1 Energy industries
1.A.1.c
42
15
42
15
1 Energy industries
1.A.1.c
43
23
43
23
1 Energy industries
1.A.1
44
44
1 Energy industries
1.A.1.c
44
44
42
1 Energy industries
1.A.1.c
44
44
1 Energy industries
1 Energy industries
1.A.1
1.A.1.c
46
48
15
48
47
48
1
36
1 Energy industries
1.A.1
51
52
1 Energy industries
1.A.1
52
53
1 Energy industries
1.A.1.a
53
1 Energy industries
1.A.1.b
53
1 Energy industries
1.A.1.a
56
1 Energy industries
1.A.1
59
59
1 Energy industries
1.A.1
59
1 Energy industries
1.A.1.a
61
23
1 Energy industries
1.A.1.a
63
1 Energy industries
1.A
59
1 Energy industries
1.A
1 Energy industries
1.A
1 Energy industries
1.A
1 Energy industries
1.A
1 Energy industries
1.A
1 Energy industries
1.A
1 Energy industries
1.A.1
1 Energy industries
1.A.1
1 Energy industries
1.A.1.a
1 Energy industries
1.A.1.a
1 Energy industries
1.A.1.a
1 Energy industries
1.A.1.a
Manufacturing industries and

2 construction (combustion)
1.A.2

1.A.2
13
14

1.A.2

1.A.2

1.A.2.c
32
34

1.A.2
31
34

1.A.2
27
27

1.A.2
12
12

1.A.2
12
12
52

1.A.2
12
12

1.A.2
12
12

1.A.2
13
13

1.A.2
13
13

1.A.2
13
13

1.A.2
13
13

1.A.2
13
13

1.A.2
13
13

1.A.2
13

1.A.2
14
47
14

1.A.2
14
14
1.A.2
14
14
1.A.2
14
14

1.A.2
14
14

1.A.2
14
14

1.A.2
14
14
48

1.A.2.a
15
13
15
13

1.A.2.a
15
11
20


1.A.2
15

1.A.2
15

1.A.2
16

1.A.2.a
16
16

1.A.2.a
16
16

1.A.2.a
17
17

1.A.2.a
17
17

1.A.2.a
17
17

1.A.2.a
17
17

1.A.2
18
49
10
11
16
18

1.A.2.a
18
18

1.A.2.a
18
18

1.A.2.a
18
18

1.A.2
18

1.A.2.a
19
19

1.A.2.a
19
19

1.A.2.a
19
19

1.A.2.a
19
19

1.A.2.b
20
20

1.A.2.b
20
20

1.A.2
20
19
26

1.A.2.b
20
27

1.A.2.b
21
21

1.A.2.b
22
22

1.A.2.b
22
22

1.A.2.b
22
22

1.A.2.b
22
22
1.A.2
22
1.A.2.b
23
23
1.A.2.b
23
23
1.A.2.b
24
24


25

1.A.2.b
24
1.A.2
24
1.A.2.b
25
25

1.A.2.b
25
25

1.A.2.b
25
25

1.A.2.b
26
26

1.A.2.b
27
27

1.A.2.d
28
28

1.A.2.d
28
29

1.A.2.d
29
29

1.A.2.d
29
29

24
27

1.A.2.d
29
29

1.A.2.d
29
29
1.A.2
29
1.A.2.f.i
30
30

1.A.2.f.i
30
30

1.A.2.f.i
30
31

1.A.2.f.i
30
31

1.A.2.f.i
31
31

1.A.2.f.i
31
31


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

1.A.2.f.i
32
35

1.A.2.f.i
32
35

1.A.2.f.i
33
33

1.A.2.f.i
33
33

1.A.2.f.i
34
34

1.A.2.f.i
34
34

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

35
35

1.A.2.f.i
36
39

1.A.2.f.i
36
39

1.A.2.f.i
37
37

1.A.2.f.i
37
37

1.A.2
37

1.A.2.f.i
38
38

1.A.2.f.i
38
38

1.A.2.f.i
40
40

1.A.2.f.i
40
41

1.A.2.f.i
40
41

1.A.2.f.i
41
41

1.A.2.f.i
41
41

1.A.2.f.i
42
42

1.A.2.f.i
42
42

1.A.2.f.i
42
43

1.A.2.f.i
42
43

1.A.2.f.i
43
43

1.A.2.f.i
44
46

1.A.2.f.i
44
48

1.A.2.f.i
45
45
1.A.2.f.i
45
45
1.A.2.f.i
46
46
1.A.2.f.i
46
46



1.A.2.f.i
47
47

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

1.A.2.f.i
48
48

1.A.2
51
10
51
10
1.A.2
51
10
52
1.A.2
52
1.A.2
52



52
52

1.A.2

1.A.2.a

1.A.2.f.i

1.A.2.f.i

1.A.2.f.i

1.A.2.f.i

1.A.2.f.i

1.A.2.f.i

1.A.2.f.i

1.A.2.f.i

1.A.2.f.i

1.A.2.f.i

1.A.2.f.i
1.A.2.f.i
3 Civil aviation
3 Civil aviation
1.A.3.a
1.A.3.a
1
2
1
5
3 Civil aviation
1.A.3.a
17
3 Civil aviation
1.A.3.a
17
3 Civil aviation
1.A.3.a
14
3 Civil aviation
1.A.3.a
17
3 Civil aviation
1.A.3.a
18
22
3 Civil aviation
1.A.3.a
19
22
3 Civil aviation
1.A.3.a
34
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
12
13
3 Civil aviation
3 Civil aviation
1.A.3.a
1.A.3.a
7
7
2
9
7
7
3
10
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
13
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
10
3 Civil aviation
1.A.3.a
11
3 Civil aviation
1.A.3.a
12
12
42
41
3 Civil aviation
1.A.3.a
12
41
3 Civil aviation
1.A.3.a
13
13
13
28
3 Civil aviation
3 Civil aviation
1.A.3.a
1.A.3.a
13
14
32
29
14
14
13
32
3 Civil aviation
1.A.3.a
14
18
14
32
3 Civil aviation
1.A.3.a
14
14
17
3 Civil aviation
1.A.3.a
15
15
3 Civil aviation
1.A.3.a
15
15
3 Civil aviation
1.A.3.a
15
3 Civil aviation
1.A.3.a
17
17
3 Civil aviation
1.A.3.a
17
3 Civil aviation
1.A.3.a
18
18
13
3 Civil aviation
1.A.3.a
18
16
18
17
3 Civil aviation
1.A.3.a
18
23
18
24
3 Civil aviation
1.A.3.a
18
15
18
24
3 Civil aviation
1.A.3.a
18
25
20
3 Civil aviation
1.A.3.a
18
3 Civil aviation
1.A.3.a
18
3 Civil aviation
1.A.3.a
18
3 Civil aviation
1.A.3.a
20
3 Civil aviation
1.A.3.a
20
3 Civil aviation
1.A.3.a
20
3 Civil aviation
1.A.3.a
20
3 Civil aviation
1.A.3.a
21
3 Civil aviation
1.A.3.a
22
22
22
3 Civil aviation
3 Civil aviation
1.A.3.a
1.A.3.a
22
23
12
23
3 Civil aviation
1.A.3.a
25
26
3 Civil aviation
1.A.3.a
25
3 Civil aviation
1.A.3.a
25
3 Civil aviation
3 Civil aviation
1.A.3.a
1.A.3.a
25
26
4
5
26
3 Civil aviation
1.A.3.a
26
26
3 Civil aviation
3 Civil aviation
1.A.3.a
1.A.3.a
26
26
9
11
27
3 Civil aviation
1.A.3.a
27
29
3 Civil aviation
1.A.3.a
29
13
32
11
3 Civil aviation
1.A.3.a
31
31
3 Civil aviation
1.A.3.a
34
16
34
17
29
3 Civil aviation
1.A.3.a
34
3 Civil aviation
1.A.3.a
35
3 Civil aviation
1.A.3.a
36
29
3 Civil aviation
1.A.3.a
40
3 Civil aviation
1.A.3.a
42
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
36
43
30
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
3 Civil aviation
1.A.3.a
4 Road transport (exhaust)
1.A.3.b
1.A.3.b

1.A.3.b
1.A.3.b
3
3
3
8
3
3
17
9

1.A.3.b
1.A.3.b
3
3
13
19
3
3
14
28
1.A.3.b
23
25
1.A.3.b
10
11
1.A.3.b
1.A.3.b
1.A.3.b
1.A.3.b
10

1.A.3.b
1.A.3.b
1.A.3.b
3
3
3
19
20
21

1.A.3.b
1.A.3.b
3
3
30
33
1.A.3.b
35

1.A.3.b
1.A.3.b
1.A.3.b
4
4
4

1.A.3.b
1.A.3.b
1.A.3.b
6
6
6
29
7
35
30
1.A.3.b
1.A.3.b
14
1.A.3.b
15

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


1.A.3.b
1.A.3.b
15
15
3
3
15

1.A.3.b
1.A.3.b
16
16
29
31
31
1.A.3.b
16
29
1.A.3.b
17
31
1.A.3.b
24
26
1.A.3.b
31
35

1.A.3.b
1.A.3.b
1.A.3.b
35
35
35
9
16
16
1.A.3.b
35
20
1.A.3.b
35
17
1.A.3.b
37
1.A.3.b
39
35
35
10
16
39
18
1.A.3.b
40
40
13
1.A.3.b
44
44

1.A.3.b.iii
1.A.3.b
1.A.3.b
53
53
53
25
3
8
54
34
1.A.3.b
53
12
1.A.3.b
55
1.A.3.b
58
1.A.3.b.iii
63
65
29
26
1.A.3.b
67
1.A.3.b
74
1.A.3.b
76
1.A.3.b
100
100
1.A.3.b
100
100
1.A.3.b
100
1.A.3.b
107
107
14
1.A.3.b
115
118
1.A.3.b
1.A.3.b
1.A.3.b
1.A.3.b
1.A.3.b
1.A.3.b
1.A.3.b
1.A.3.b
1.A.3.b
1.A.3.b
1.A.3.b
5 Road transport, gasoline evaporation
1.A.3.b.v
31
1.A.3.b.v
12
14
1.A.3.b.v
19
27
1.A.3.b.v
25
27
1.A.3.b.v
1.A.3.b.v
11
1.A.3.b.v
1.A.3.b.v
26
27
1.A.3.b.v
1.A.3.b.v
14
1.A.3.b.v
26
27
1.A.3.b.v
1.A.3.b.v
39
1.A.3.b.v
1.A.3.b.v
16
1.A.3.b.v
28
1.A.3.b.v
29
1.A.3.b.v
30
1.A.3.b.v
32
1.A.3.b.v
35
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
10
11
13
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
10
10
1.A.3.b.v
15
15
1.A.3.b.v
10
10
1.A.3.B.V
20
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
17
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
13
1.A.3.b.v
1.A.3.b.v
13
1.A.3.b.v
13
34
1.A.3.b.v
13
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
12
13
1.A.3.b.v
10
12
1.A.3.b.v
12
1.A.3.b.v
13
1.A.3.b.v
13
1.A.3.b.v
14
1.A.3.b.v
15
1.A.3.b.v
15
1.A.3.b.v
15
20
13
1.A.3.b.v
15
22
1.A.3.b.v
16
13
1.A.3.b.v
16
1.A.3.b.v
16
30
1.A.3.b.v
17
16
14
17
1.A.3.b.v
19
11
1.A.3.b.v
20
1.A.3.b.v
20
1.A.3.b.v
21
1.A.3.b.v
21
1.A.3.b.v
22
1.A.3.b.v
23
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
20
1.A.3.b.v
1.A.3.b.v
1.A.3.b.v
Road transport, automobile tyre and

6 brake wear and road abrasion
1.A.3.b.vi
1.A.3.b.vi
10
15
1.A.3.b.vi
23
25
1.A.3.b.vi
10
1.A.3.b.vi
14

1.A.3.b.vi
17

1.A.3.b.vi
20


1.A.3.b.vi
1.A.3.b.vi
33

1.A.3.b.vi
10

1.A.3.b.vi
10
10

1.A.3.b.vi
11
1.A.3.b.vi

12
12
12
13
27
1.A.3.b.vi
13
34
1.A.3.B.VI
14
28
1.A.3.b.vii
14
1.A.3.b.vii
14
1.A.3.b.vi
14
1.A.3.b.vi
14
13

1.A.3.b.vi
14

1.A.3.b.vii
15

1.A.3.b.vi
15
21
16
1.A.3.b.vi
15
21
16
1.A.3.b.vi
15
12
1.A.3.b.vi
15
15
1.A.3.b.vi
15
19

1.A.3.b.vii
16
18

1.A.3.b.vi
16
1.A.3.b.vi
16
20
1.A.3.b.vi
17
17
1.A.3.b.vii
17
1.A.3.b.vi
17
14
1.A.3.b.vi
17
14


15
16
23

1.A.3.b.vi
17
16
1.A.3.b.vi
17
22
1.A.3.b.vii
24
1.A.3.b.vii
25
1.A.3.b.vii
26
1.A.3.b.vi
26
11

1.A.3.b.vi
26
18

1.A.3.b.vi
27

1.A.3.b.vi
28

1.A.3.b.vii
29
13


29
18


1.A.3.b.vi
29
1.A.3.b.vi
30
30
1.A.3.b.vi
60

1.A.3.b.vii

1.A.3.b.vii

29
21
1.A.3.b.vii
1.A.3.b.vii

1.A.3.b.vii

1.A.3.b.vi

1.A.3.b.vi

7 Railways
1.A.3.b.vi
1.A.3.c
16
7 Railways
1.A.3.c
15
7 Railways
1.A.3.c
13
7 Railways
7 Railways
1.A.3.c
1.A.3.c
6
6
13
7 Railways
1.A.3.c
20
7 Railways
1.A.3.c
18
24
7 Railways
7 Railways
1.A.3.c
1.A.3.c
7
7
29
2
32
7 Railways
1.A.3.c
18
7 Railways
1.A.3.c
7 Railways
1.A.3.c
7 Railways
7 Railways
1.A.3.c
1.A.3.c
9
9
7 Railways
1.A.3.c
10
29
10
29
7 Railways
1.A.3.c
10
29
10
29
7 Railways
1.A.3.c
11
20
11
24
7 Railways
1.A.3.c
11
28
11
28
7 Railways
1.A.3.c
11
20
11
24
7 Railways
1.A.3.c
11
28
11
28
7 Railways
1.A.3.c
11
25
11
28
7 Railways
1.A.3.c
11
7 Railways
1.A.3.c
12
25
12
37
7 Railways
7 Railways
1.A.3.c
1.A.3.c
12
12
2
8
12
12
2
8
7 Railways
1.A.3.c
12
22
12
22
7 Railways
7 Railways
1.A.3.c
1.A.3.c
12
12
2
8
12
12
2
8
7 Railways
1.A.3.c
12
22
12
22
7 Railways
7 Railways
7 Railways
1.A.3.c
1.A.3.c
1.A.3.c
12
14
15
23
7
7
15
13
7 Railways
1.A.3.c
16
16
7 Railways
1.A.3.c
16
16
7 Railways
1.A.3.c
7 Railways
Inter(national) navigation, national
8 fishing
1.A.3.c
1.A.3.d

8 fishing
1.A.3.d
32
42

8 fishing
1.A.3.d
32
42

8 fishing
1.A.3.d
11

8 fishing
1.A.3.d
15
17
1.A.3.d
15
17
1.A.3.d
24

8 fishing
8 fishing

8 fishing
1.A.3.d
27
19

8 fishing
1.A.3.d
20
29

8 fishing
1.A.3.d
10

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

8 fishing
1.A.3.d
11
21

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

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

8 fishing
1.A.3.d
35
10
1.A.3.d
35
10
1.A.3.d
36
1.A.3.d
36
1.A.3.d
36
1.A.3.d
36

8 fishing
8 fishing
8 fishing

8 fishing
8 fishing
8 fishing
8 fishing
8 fishing
11

8 fishing
8 fishing
8 fishing
8 fishing
8 fishing
1.A.3.d
37
1.A.3.d
37
1.A.3.d
38
1.A.3.d
38
1.A.3.d
39
1.A.3.d
39
31
1.A.3.d
39
1.A.3.d
39
31
1.A.3.d
39
1.A.3.d
40
40
1.A.3.d
40
24
40
27
1.A.3.d
40
40

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

8 fishing
1.A.3.d
47
48

8 fishing
1.A.3.d
47
48

8 fishing
8 fishing
8 fishing
8 fishing
8 fishing
8 fishing
8 fishing

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

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

8 fishing
1.A.3.d
48

8 fishing
1.A.3.d
48

8 fishing
1.A.3.d
49

8 fishing
1.A.3.d
50
49
26
34
51
28

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

8 fishing
1.A.3.d
53
53

8 fishing
1.A.3.d
53
53

8 fishing
1.A.3.d
53

8 fishing
1.A.3.d
53

8 fishing
1.A.3.d

8 fishing
1.A.3.d

8 fishing
1.A.3.d

8 fishing
1.A.3.d

8 fishing
1.A.3.d

8 fishing
1.A.3.d

8 fishing
1.A.3.d

8 fishing
8 fishing
8 fishing
8 fishing
8 fishing
8 fishing
8 fishing
9 Pipeline compressors
1.A.3.d
1.A.3.d
1.A.3.d
1.A.3.d
1.A.3.d
1.A.3.d
1.A.3.d
1.A.3.e.i
10 Small combustion
1.A.5
10 Small combustion
1.A.4
10 Small combustion
1.A.4
10 Small combustion
1.A.4
10
12
10 Small combustion
1.A.4
19
19
10 Small combustion
1.A.4
22
13
11
10 Small combustion
1.A.4
23
23
13
10 Small combustion
10 Small combustion
1.A.4
1.A.4
4
5
7
36
36
10 Small combustion
1.A.4
16
40
10 Small combustion
1.A.4
40
40
10 Small combustion
1.A.4
10 Small combustion
1.A.4
18
20
10 Small combustion
1.A.4
33
33
10 Small combustion
1.A.4
10 Small combustion
1.A.4
14
10 Small combustion
1.A.4
16
17
16
33
10 Small combustion
1.A.4
18
18
15
10 Small combustion
1.A.4
18
18
10 Small combustion
1.A.4
18
11
18
14
10 Small combustion
1.A.4
18
10 Small combustion
1.A.4
19
10
19
10
10 Small combustion
1.A.4
19
13
19
13
10 Small combustion
1.A.4.b.i
19
10
19
15
10 Small combustion
1.A.4
19
10 Small combustion
1.A.4
19
10 Small combustion
1.A.4
19
14
10 Small combustion
1.A.4
19
14
10 Small combustion
1.A.4
21
21
10 Small combustion
1.A.4.b.i
21
22
37
10 Small combustion
1.A.4
21
10 Small combustion
1.A.4
22
22
10 Small combustion
1.A.4.b.i
22
22
10 Small combustion
1.A.4
22
10 Small combustion
1.A.4
25
10 Small combustion
1.A.4.b.i
27
10 Small combustion
1.A.4
27
15
37
10 Small combustion
1.A.4
28
24
28
24
10 Small combustion
1.A.4
28
24
28
24
10 Small combustion
1.A.4.b.i
29
29
10 Small combustion
1.A.4.b.i
29
37
10 Small combustion
1.A.4.b.i
29
37
10 Small combustion
1.A.4.b.i
30
23
27
30
10 Small combustion
1.A.4.b.i
30
10 Small combustion
1.A.4
31
33
10 Small combustion
1.A.4
33
33
10 Small combustion
1.A.4.b.i
33
33
10 Small combustion
1.A.4
35
35
10 Small combustion
1.A.4.b.i
35
35
10 Small combustion
1.A.4
37
37
10 Small combustion
1.A.4.a.i
37
10 Small combustion
1.A.4.b.i
37
30
37
37
10 Small combustion
1.A.4
38
17
38
10 Small combustion
1.A.4
39
13
10 Small combustion
1.A.4
45
46
10 Small combustion
1.A.4
46
48
10 Small combustion
1.A.4
49
10 Small combustion
1.A.4
73
10 Small combustion
1.A.4
83
10 Small combustion
1.A.4
84
10 Small combustion
10 Small combustion
1.A.4
1.A.4
89
90
1
1
10 Small combustion
1.A.4
91
18
71
89
95
6
1
95
10 Small combustion
1.A.4.a.i
10 Small combustion
1.A.4
10 Small combustion
1.A.4
10 Small combustion
1.A.4
10 Small combustion
10 Small combustion
1.A.4
1.A.4
10 Small combustion
1.A.4.b.i
10 Small combustion
1.A.5
Non-road mobile sources and

11 machinery
11 machinery
11 machinery
95
95
1.A.2.f.ii
24
26
1.A.2.f.ii
13
10
13
13
1.A.2.f.ii
13
15

11 machinery
1.A.2.f.ii
14
1.A.2.f.ii
15
1.A.2.f.ii
16
1.A.2.f.ii
17
1.A.2.f.ii
22
1.A.2.f.ii
23
11
1.A.2.f.ii
23
13

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

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

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

11 machinery
1.A.2.f.ii
37
1.A.2.f.ii
38
16
1.A.2.f.ii
39
1.A.2.f.ii
40
17

11 machinery
11 machinery
11 machinery
11 machinery
11 machinery
11 machinery

11 machinery
11 machinery
11 machinery
11 machinery
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
1.A.2.f.ii
22

11 machinery
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
11 machinery

11 machinery

11 machinery
11 machinery
11 machinery
11 machinery
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
11 machinery
11 machinery
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii

11 machinery
11 machinery
11 machinery
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
11 machinery
1.A.2.f.ii
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
1.A.2.f.ii

11 machinery
11 machinery

11 machinery
11 machinery

11 machinery
11 machinery
11 machinery

11 machinery
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii
1.A.2.f.ii

11 machinery
1.A.2.f.ii
12 Coal mining and handling
1.B.1.a
1.B.1.a
1.B.1.a
1.B.1.a
17
17
1.B.1.a
11
11
1.B.1.a
1.B.1.a
1.B.1.a
10
10
1.B.1.a
11
11
1.B.1.a
11
11
1.B.1.a
13 Solid fuel transformation
1.B.1.b
14
14
14 Other (please specify)
1.B.1.c
10
10
14 Other (please specify)
1.B.1.c
10
10
13
13
Exploration production, transport of oil

15 and natural gas
1.B.2.a.i

15 and natural gas
1.B.2.a.i
26
25

15 and natural gas
1.B.2.b
15
17

15 and natural gas
1.B.2.b
12
12
12
17

15 and natural gas
1.B.2.b
12
15
12
17

15 and natural gas
1.B.2.a.i
14
14

15 and natural gas
1.B.2.a.i
14
14

15 and natural gas
1.B.2.a.i
15
15

15 and natural gas
1.B.2.b
15
15

15 and natural gas
1.B.2.b
15 and natural gas
1.B.2.a.i

15 and natural gas
1.B.2.b

15 and natural gas
15 and natural gas
15 and natural gas
15 and natural gas
15 and natural gas
15 and natural gas
15 and natural gas
15 and natural gas
16
16
1.B.2.b
17
24
25
14
1.B.2.a.i
18
18
24
1.B.2.a.i
22
10
23
18
1.B.2.a.i
23
19
24
1.B.2.a.i
23
19
24
1.B.2.b
27
28
1.B.2.a.i
1.B.2.b
16 Refining / storage
1.B.2.a.iv
1.B.2.a.iv
20
1.B.2.a.iv
1.B.2.a.iv
13
14
6
2
1.B.2.a.iv
14
1.B.2.a.iv
15
21
1.B.2.a.iv
16
1.B.2.a.iv
17
18
14
15
21
17
18
1.B.2.a.iv
17
1.B.2.a.iv
17
1.B.2.a.iv
17
1.B.2.a.iv
17
1.B.2.a.iv
17
1.B.2.a.iv
17
1.B.2.a.iv
20
18
1.B.2.a.iv
20
24
1.B.2.a.iv
1.B.2.a.iv
1.B.2.a.iv
21
22
22
12
6
7
1.B.2.a.iv
22
17
10
1.B.2.a.iv
1.B.2.a.iv
1.B.2.a.iv
22
22
22
15
18
23
1.B.2.a.iv
1.B.2.a.iv
23
23
2
1
1.B.2.a.iv
24
1.B.2.a.iv
24
1.B.2.a.iv
24
1.B.2.a.iv
24
23
17 Distribution of oil products
1.B.2.a.iv
1.B.2.a.v
24
1
1.B.2.a.v

1.B.2.a.v
1.B.2.a.v
1.B.2.a.v
4
4
4
27
29
33
1.B.2.a.v
20
1.B.2.a.v
10

1.B.2.a.v
1.B.2.a.v
7
7
9
27

1.B.2.a.v
1.B.2.a.v
7
8
33
7
17
17
17
17
17
17
17
17
Distribution of oil products

1.B.2.a.v
1.B.2.a.v
1.B.2.a.v
1.B.2.a.v
1.B.2.a.v
1.B.2.a.v
1.B.2.a.v
1.B.2.a.v
8
8
8
8
8
9
9
9
12
18
21
30
39
2
11
32

1.B.2.a.v
1.B.2.a.v
11
11
8
17
1.B.2.a.v
12
27
10
12
12
1.B.2.a.v
13
21
1.B.2.a.v
14
1.B.2.a.v
14
1.B.2.a.v
15
1.B.2.a.v
15
1.B.2.a.v
15
1.B.2.a.v
16
1.B.2.a.v
16
1.B.2.a.v
16
10
1.B.2.a.v
17
1.B.2.a.v
17
1.B.2.a.v
18
13

1.B.2.a.v
1.B.2.a.v
1.B.2.a.v
18
18
18
5
16
21
18
11
19

1.B.2.a.v
1.B.2.a.v
18
19
2
2
1.B.2.a.v
19
19
1.B.2.a.v
20
20
10
1.B.2.a.v
20
10
20
19
1.B.2.a.v
20

1.B.2.a.v
1.B.2.a.v
1.B.2.a.v
21
21
21
8
19
21
21
1.B.2.a.v
21
30

1.B.2.a.v
1.B.2.a.v
21
22
9
12
22
19
1.B.2.a.v
22
17
1.B.2.a.v
22
25
1.B.2.a.v
23
1.B.2.a.v
23
1.B.2.a.v
23
18 Geothermal energy extraction
1.B.2.a.vi
31
33

1.B.2.a.vi
1.B.2.a.vi
4
4
3
11
4
4
4
11
1.B.2.a.vi
19 Venting and flaring
1.B.2.c
17
26
1.B.2.c
16
17
1.B.2.c
18
20
1.B.2.c
14
14

1.B.2.c
1.B.2.c
8
9
11
1
9
9
7
7
1.B.2.c
10
14
10
15
1.B.2.c
10
19
10
21
1.B.2.c
10
20

1.B.2.c
1.B.2.c
11
12
3
20
12
21
1.B.2.c
1.B.2.c
20 Cement production
2.A.1
2.A.1
18
2.A.1
18
2.A.1
26
27
2.A.1
14
25
2.A.1
25
25
2.A.1
2.A.1
27
2.A.1
10
2.A.1
2.A.1
20
12
2.A.1
12
2.A.1
12
2.A.1
2.A.1
2.A.1
10
33
10
34
2.A.1
10
16
10
16
2.A.1
11
11
2.A.1
11
10
2.A.1
2.A.1
13
16
13
2.A.1
16
15
2.A.1
17
20 Total industrial processes
2.A.1
2.A.1
2.A.1
2.A.1
2.A.1
2.A.1
21 Lime production
2.A.2
11
12
14
17
21 Lime production
2.A.2
21 Lime production
2.A.2
21 Lime production
2.A.2
20
22 Limestone and dolomite use
2.A.3
2.A.3
21
2.A.3
2.A.3
15
2.A.3
19
2.A.3
22
2.A.3
24
23 Soda ash production and use
2.A.4
2.A.4
15
2.A.4
25
2.A.4
2.A.4
13
22
16

2.A.4
2.A.4
4
5
1
2
4
5
2
9
2.A.4
2.A.4
24 Asphalt roofing
2.A.5
24 Asphalt roofing
2.A.5
24 Asphalt roofing
2.A.5
17
24 Asphalt roofing
2.A.5
11
24 Asphalt roofing
2.A.5
24 Asphalt roofing
2.A.5
12
12
24 Asphalt roofing
2.A.5
20
20
24 Asphalt roofing
2.A.5
24 Asphalt roofing
2.A.5
11
11
24 Asphalt roofing
2.A.5
25 Road paving with asphalt
2.A.6
2.A.6
2.A.6
15
2.A.6
13
Quarrying and mining of minerals

26 other than coal
2.A.7.a
27 Construction and demolition
2.A.7.b
11
27 Construction and demolition

Storage, handling and transport of
28 mineral products
28 mineral products
2.A.7.b
2.A.7.c
24
2.A.7.c
15
2.A.7.c
16
Other mineral products (Please

specify the sources included/excluded
29 in the notes column to the right)
2.A.7.d

2.A.7.d

28 mineral products
19
19
37
37

2.A.7.d
32
34

2.A.7.d

2.A.7.d
22
22

2.A.7.d
38
41

2.A.7.d
11

2.A.7.d
12
31
12
34

2.A.7.d
14
21
14
22

2.A.7.d
15
15

2.A.7.d
18
18

2.A.7.d
20
16

2.A.7.d
22
22
19

2.A.7.d
22

2.A.7.d
22

2.A.7.d
24

2.A.7.d
24

2.A.7.d
24

2.A.7.d
25
25

2.A.7.d
27
27

2.A.7.d
27
30
30
30
24
25
30

2.A.7.d
27
30

2.A.7.d
27
30

2.A.7.d
31

2.A.7.d
35

2.A.7.d
36
19
37
30 Chemical industry
2.B
2.B
2.B
2.B
2.B
2.B.1
2.B.2
2.B.5.a
2.B
6
8
9
1
17
33
6
8
9
1
17
34
2.B.1
13
16
13
16
2.B.1
13
16
13
17
2.B.1
13
13
13
15
2.B
13
13
2.B
13
13
2.B
13
13
11
2.B.2
14
14
2.B.3
14
14
2.B.4
15
15
2.B.5
15
14
15
15
2.B.5.a
15
14
15
2.B.1
17
25
17
25
2.B.1
17
23
17
25
2.B.1
17
23
17
25
2.B.1
18
18
2.B.2
18
18
2.B.2
19
19
2.B.2
21
21
2.B.2
22
22
11
2.B.3
22
12
23
2.B.2
24
24
2.B.5.a
24
2.B.5.a
25
25
2.B.5.a
26
26
2.B.5.a
28
17
28
17
2.B.5.a
28
28
2.B.5.a
30
30
2.B.5.a
2.B.5.a
30
31
1
13
31
31
3
13
2.B.5.a
31
31
2.B.5.a
33
33
2.B
35
2.B.5.a
2.B
36
37
35
36
37
2.B
37
13
2.B
38
2.B
39
39
18
2.B.5.a
2.B.5.a
39
42
1
17
43
3
3
2.B.5.a
42
16
17
2.B
43
19
2.B.5.a
43
2.B.5.a
44
14
16
2.B.5.a
45
2.B.5.a
2.B.5.a
46
48
1
3
48
3
9
2.B.5.a
48
48
2.B.5.a
48
2.B.5.a
48
44
15
2.B.5.a
48
2.B.5.a
49
21
2.B.5.a
50
50
2.B.5.a
52
10
52
10
2.B.5.a
52
2.B.5.a
53
53
2.B.5.a
53
2.B.5.a
53
2.B.5.a
2.B.5.a
53
55
2.B.5.a
57
2.B
58
2.B
58
2.B
2.B
59
61
1
23
11
24
55
11
58
59
19
2.B.1
63
63
2.B.1
63
63
2.B.1
63
2.B.5.a
64
19
64
21
2.B.5.a
65
65
2.B.5.a
65
2.B.5.a
65
2.B.5.a
66
22
23
2.B.5.a
66
20
21
2.B.5.a
67
2.B.5.a
67
2.B.5.a
69
2.B
16
2.B.1
31 Iron and steel production
2.C.1
2.C.1
2.C.1
20
2.C.1
21
2.C.1
23
2.C.1
11
2.C.1
11
31

2.C.1
2.C.1
11
12
36
17
2.C.1
13
2.C.1
13
2.C.1
14
11
15
2.C.1
16
40
17
20

2.C.1
2.C.1
18
21
9
6
2.C.1
22
18
22
18
2.C.1
22
2.C.1
22
61
22
2.C.1
25
11
25
11
2.C.1
25
11
25
11
2.C.1
25
2.C.1
25
27
2.C.1
25
27
2.C.1
26
26
2.C.1
26
26
2.C.1
26
26
2.C.1
26
26
2.C.1
26
2.C.1
27
27
2.C.1
27
27
27
27
2.C.1
27
27
2.C.1
27
27
2.C.1
27
30
2.C.1
28
13
28
13
2.C.1
28

2.C.1
2.C.1
28
28
2.C.1
28
30
2.C.1
31
32
2.C.1
33
33
2.C.1
33
33
2.C.1
34
2.C.1
34
28
12
28
28
34
34
13
2.C.1
34
34
2.C.1
35
2.C.1
35
35
2.C.1
36
36
2.C.1
36
36
2.C.1
36
38
2.C.1
37
38
2.C.1
37
38
2.C.1
42
28
55
2.C.1
55
56
16
2.C.1
35
2.C.1
32 Ferroalloys production
2.C.2
2.C.2
23
23
2.C.2
22
23
33 Aluminium production
2.C.3
2.C.3
10
10
2.C.3
10
10
2.C.3
10
13
2.C.3
10
13
2.C.3
10
13
2.C.3
12
12
2.C.3
12
12
2.C.3
12
12
2.C.3
12
2.C.3
13
13
2.C.3
13
13
2.C.3
14
2.C.3
14
2.C.3
20
34 Copper production
2.C.5.a
16
2.C.5.a
2.C.5.a
2.C.5.a
2.C.5.a
14
14
20
2.C.5.a
2.C.5.a
14
15
2.C.5.a
15
2.C.5.a
10
2.C.5.a
2.C.5.a
2.C.5.a
10
2.C.5.a
10
2.C.5.a
2.C.5.a
2.C.5.a
2.C.5.a
2.C.5.a
2.C.5.a
10
10
2.C.5.a
2.C.5.a
2.C.5.a
2.C.5.a
2.C.5.a
2.C.5.a
2.C.5.a
2.C.5.a
35 Lead production
2.C.5.b
21
35 Lead production
2.C.5.b
21
35 Lead production
2.C.5.b
35 Lead production
2.C.5.b
35 Lead production
2.C.5.b
16
8
35 Lead production
2.C.5.b
16
35 Lead production
2.C.5.b
16
35 Lead production
2.C.5.b
35 Lead production
2.C.5.b
11
11
35 Lead production
2.C.5.b
12
12
35 Lead production
2.C.5.b
13
13
35 Lead production
2.C.5.b
14
14
35 Lead production
2.C.5.b
14
16
35 Lead production
2.C.5.b
15
15
36 Nickel production
2.C.5.c
2.C.5.c
2.C.5.c
2.C.5.c
13
13
2.C.5.c
2.C.5.c
2.C.5.c
37 Zinc production
2.C.5.d
20
37 Zinc production
2.C.5.d
37 Zinc production
2.C.5.d
10
11
37 Zinc production
2.C.5.d
12
12
37 Zinc production
2.C.5.d
37 Zinc production
2.C.5.d
37 Zinc production
2.C.5.d
37 Zinc production
2.C.5.d
33
34
37 Zinc production
2.C.5.d
37 Zinc production
2.C.5.d
12
37 Zinc production
2.C.5.d
15
37 Zinc production
2.C.5.d
10
10
37 Zinc production
2.C.5.d
10
37 Zinc production
2.C.5.d
11
10
11
37 Zinc production
2.C.5.d
11
11
37 Zinc production
2.C.5.d
12
37 Zinc production
2.C.5.d
12
37 Zinc production
2.C.5.d
13
37 Zinc production
2.C.5.d
13
13
37 Zinc production
2.C.5.d
14
14
37 Zinc production
2.C.5.d
15
15
37 Zinc production
2.C.5.d
16
37 Zinc production
2.C.5.d
16
16
37 Zinc production
2.C.5.d
18
17
18
18
37 Zinc production
2.C.5.d
37 Zinc production
2.C.5.d
12
12
13
16
37 Zinc production
2.C.5.d
37 Zinc production
2.C.5.d
37 Zinc production
2.C.5.d
Other metal production (Please

2.C.5.e

2.C.5.e

2.C.5.e

metal products (Please specify the
sources included/excluded in the
39 notes column to the right)
2.C.5.f
40 Pulp and paper
2.D.1
15
40 Pulp and paper
2.D.1
40
40
40
40
Pulp and paper

Pulp and paper
Pulp and paper
Pulp and paper
2.D.1
2.D.1
2.D.1
2.D.1
5
7
13
13
16
37
7
7
40 Pulp and paper
2.D.1
16
40 Pulp and paper
2.D.1
16
40 Pulp and paper
2.D.1
17
40 Pulp and paper
2.D.1
17
40 Pulp and paper
2.D.1
18
16
17
18
40 Pulp and paper
2.D.1
41 Food and drink
2.D.2
11
41 Food and drink
2.D.2
11
41 Food and drink
2.D.2
16
16
41 Food and drink
2.D.2
17
17
41 Food and drink

41 Food and drink
2.D.2
2.D.2
17
18
5
4
17
18
7
4
41 Food and drink
2.D.2
22
24
43 Production of POPs
2.E
2.E
2.E
1
3
2.E
2.E
44 Consumption of POPs and HMs
2.F
44 Consumption of POPs and HMs
2.F
12
24
3
3
16
46 Paint application
3.A
14
3.A
14
15
3.A
28
28
3.A
14
3.A
14
14
3.A
10
25
10
26
46
46
46
46
46
46
46
46
46
46
46
46
Paint application
Paint application
Paint application
Paint application
Paint application
Paint application
Paint application
Paint application
Paint application
Paint application
Paint application
Paint application
3.A
3.A
3.A
3.A
3.A
3.A
3.A
3.A
3.A
3.A
3.A
3.A
10
10
11
11
11
11
11
11
11
11
11
11
25
26
1
1
1
1
1
1
1
1
1
1
10
10
11
11
11
11
11
11
11
11
11
11
26
26
2
2
2
2
2
2
2
2
2
2
3.A
11
11
3.A
11
3.A
12
31
12
37
3.A
12
26
12
30
3.A
12
20
12
25
3.A
12
15
12
19
3.A
12
15
12
19
3.A
12
16
3.A
13
12
13
15
3.A
15
16
3.A
16
22
16
23
3.A
16
16
23
3.A
16
22
17
3.A
3.A
16
16
17
22
3.A
17
17
3.A
17
16
18
32
3.A
17
3.A
19
19
15
3.A
19
19
19
19
3.A
20
20
3.A
21
21
3.A
22
22
3.A
24
24
3.A
25
31
3.A
28
28
3.A
31
16
3.A
32
21
32
30
3.A
32
21
32
30
3.A
34
17
34
34
3.A
34
17
34
34
3.A
34
34
3.A
34
34
16
3.A
3.A
3.A
3.A
47 Degreasing
3.B.1
47 Degreasing
3.B
47 Degreasing
3.B.1
47 Degreasing
3.B.1
48 Dry cleaning
3.B.2
48 Dry cleaning
3.B.2
17
209
Chemical products, manufacture and

49 processing
3.C

49 processing
3.C

49 processing
3.C
33
33

49 processing
3.C
21
22
3.C
26
3.C
27
3.C
22
3.C

49 processing
3.C

49 processing
3.C
26

49 processing
49 processing
49 processing
49 processing
37
8
10
33

49 processing
3.C
26
33

49 processing
3.C
22
25

49 processing
3.C
11
11
3.C
12
22
12
25
3.C
13
13
3.C
13
15
3.C
13
3.C
14
10
14
11
3.C
14
11
14
11

49 processing
3.C
14
14

49 processing
3.C
14
13
17

49 processing
3.C
14
11

49 processing
49 processing
49 processing
49 processing
49 processing
49 processing

49 processing
3.C
15
24

49 processing
3.C
17
12

49 processing
3.C
18
18
3.C
18
11
19
3.C
20

49 processing
49 processing
49 processing
49 processing
49 processing
49 processing
49 processing
49 processing

49 processing
49 processing
49 processing
3.C
3.C
3.C
3.C
3.C
3.C
3.C
3.C
3.C

49 processing
3.C
50 Printing
3.D.1
22
50 Printing
3.D.1
10
50 Printing
3.D.1
50 Printing
3.D.1
50 Printing
3.D.1
50 Printing
3.D.1
50 Printing
3.D.1
50 Printing
3.D.1
Domestic solvent use including

51 fungicides
51 fungicides
26
17
14
14
18
23
3.D.2
3.D.2

51 fungicides
3.D.2
3.D.2
3.D.2
12
13

51 fungicides
3.D.2
17
17
17
22

51 fungicides
3.D.2
52 Other product use
3.D.3
22
22
3.D.3
39
41
3.D.3
10
18
3.D.3
11
11
3.D.3
17
17
3.D.3
18
18

53 Manure management
3.D.3
4.B

51 fungicides
51 fungicides
4.B
4.B
42
4.B
59
4.B
4.B
4.B
3
3
6
1
3
3
6
14
4.B
14
4.B
4.B
10
12
4.B
21
29
4.B
28
28
4.B
4.B
13
14
4.B
22
24
4.B
11
11
4.B
17
18
4.B
11
11
4.B
19
20
4.B
30
32
4.B
15
4.B
4.B
3
3
15
18
4.B
29
4.B
4.B
3
3
27
27
4.B
15
15
4.B
4.B
4.B
23
24
4.B
11
4.B
11
4.B
4.B
4.B
20
4.B
24
4.B
4.B
15
4.B
11
4.B
4.B
22
4.B
26
4.B
4.B
4.B
5
6
6
20
4.B
4.B
4.B
6
6
2
13
4.B
13
4.B
4.B
7
7
5
27
7
7
5
28
4.B
32
4.B
32
26
7
13
4.B
26
32
4.B
4.B
7
7
28
2
7
7
30
2
4.B
4.B
4.B
7
7
33
1
4.B
4.B
35
4.B
4.B
4.B
28
4.B
4.B
10
10
4.B
34
34
4.B
14
16
4.B
17
21
4.B
4.B
8
8
22
32
8
8
31
32
4.B
4.B
8
8
2
13
4.B
27
4.B
4.B
53
53
53
53
Manure management
Manure management
Manure management
Manure management
4.B
4.B
4.B
4.B
10
10
10
10
1
3
3
3
10
10
10
10
2
3
3
3
4.B
11
22
11
22
4.B
11
26
11
26
4.B
11
18
11
32
4.B
11
18
11
32
4.B
11
28
11
28
4.B
11
11
4.B
11
26
11
26
4.B
11
19
18
12
4.B
11
32
4.B
11
17
4.B
11
26
4.B
11
15
4.B
12
12
4.B
12
12
4.B
4.B
12
12
4
2
12
12
4
3
4.B
12
15
4.B
12
16
4.B
12
16
4.B
12
16
4.B
12
16
4.B
12
16
4.B
12
16
4.B
12
17
4.B
12
17
4.B
12
17
4.B
12
17
4.B
12
17
4.B
12
17
4.B
12
17
4.B
12
17
4.B
12
17
4.B
12
17
4.B
12
4.B
12
17
4.B
12
17
4.B
12
17
17
53 Poultry
4.B.09
12
31
4.B
12
4.B
4.B
12
13
5
1
13
4.B
14
15
4.B
14
16
4.B
15
15
4.B
15
15
4.B
16
16
4.B
4.B
16
17
1
16
17
16
4.B
4.B
17
17
16
18
17
17
16
18
4.B
17
16
17
16
4.B
17
17
4.B
17
17
10
4.B
17
17
4.B
17
17
16
4.B
17
18
12
4.B
17
19
4.B
4.B
17
17
3
9
4.B
17
4.B
17
11
4.B
4.B
4.B
17
17
18
14
4
1
18
4.B
4.B
18
18
4
27
18
18
4
28
4.B
18
14
18
32
4.B
18
10
18
11
4.B
18
18
11
4.B
18
14
18
17
4.B
18
18
11
4.B
18
18
11
4.B
18
16
18
16
4.B
18
24
18
25
4.B
18
18
11
4.B
18
23
18
23
4.B
18
18
4.B
18
36
19
4.B
18
14
24
11
4.B
18
14
24
11
4.B
18
4.B
18
34
4.B
18
16
4.B
19
19
4.B
4.B
19
19
1
35
4.B
20
20
4.B
4.B
20
20
10
15
20
20
10
15
4.B
20
20
4.B
20
21
20
22
4.B
20
4.B
20
18
4.B
20
4.B
21
21
4.B
21
21
4.B
4.B
21
21
10
9
21
21
10
9
4.B
21
13
21
13
4.B
21
21
4.B
21
11
21
30
4.B
21
21
17
4.B
21
4.B
4.B
21
22
31
16
11
16
23
4.B
4.B
4.B
22
22
22
16
6
9
22
22
22
17
7
9
4.B
22
22
22
22
4.B
22
31
4.B
22
22
4.B
22
22
4.B
4.B
4.B
22
22
22
3
9
16
4.B
4.B
22
23
12
33
23
34
4.B
23
26
4.B
23
17
4.B
24
24
4.B
24
24
4.B
24
24
11
4.B
4.B
24
24
8
7
24
24
9
7
4.B
24
16
25
4.B
24
13
31
10
4.B
24
4.B
24
16
31
4.B
24
16
31
4.B
24
12
31
4.B
24
12
31
10
4.B
24
16
31
4.B
24
16
31
4.B
24
10
31
4.B
24
16
4.B
4.B
4.B
24
24
25
16
7
2
26
4.B
26
26
4.B
27
4.B
4.B
27
29
3
1
29
4.B
30
30
4.B
30
30
4.B
30
30
53 Poultry
4.B.09
30
30
53 Poultry
4.B.09
30
30
4.B
30
4.B
30
4.B
4.B
31
31
11
17
31
31
11
17
4.B
31
31
4.B
31
11
31
23
4.B
31
11
31
11
4.B
31
25
31
27
4.B
31
23
31
23
4.B
31
17
31
17
4.B
31
12
31
22
4.B
31
23
31
28
4.B
31
25
31
27
4.B
31
25
31
27
4.B
4.B
31
31
11
12
31
31
22
22
4.B
31
12
31
22
4.B
31
23
31
28
4.B
4.B
31
31
5
12
31
31
6
18
4.B
31
11
4.B
31
24
18
4.B
31
27
4.B
31
25
4.B
4.B
32
32
2
25
32
32
3
28
4.B
32
19
32
19
4.B
32
26
32
27
4.B
33
29
4.B
33
29
4.B
34
10
34
11
4.B
4.B
34
35
23
14
4.B
36
16
36
18
4.B
36
16
36
21
4.B
36
19
36
21
4.B
36
36
39
4.B
4.B
39
40
40
4.B
40
21
42
10
4.B
40
42
10
4.B
40
45
14
4.B
40
4.B
40
57
4.B
40
59
4.B
41
15
42
10
4.B
41
59
4.B
41
59
4.B
41
28
4.B
42
26
42
28
4.B
4.B
43
43
12
12
44
57
4.B
44
38
45
13
4.B
44
37
45
4.B
4.B
45
46
17
7
45
46
22
7
4.B
46
4.B
46
4.B
4.B
47
47
8
8
4.B
48
48
4.B
48
48
4.B
48
48
4.B
48
50
4.B
48
50
4.B
48
50
4.B
4.B
48
48
2
3
4.B
48
4.B
51
13
4.B
51
13
4.B
52
18
4.B
52
18
4.B
52
4.B
53
4.B
53
4.B
53
4.B
53
53
52
19
4.B
54
57
4.B
55
55
4.B
57
4.B
4.B
4.B
4.B
4.B
4.B
4.B
4.B
4.B
4.B
53 Dairy cattle
4.B.01.a
53 Non-dairy cattle
4.B.01.b
53 Sheep
4.B.03
53 Goats
4.B.04
53 Horses
4.B.06
53 Swine
4.B.08
53 Poultry
4.B.09
53 Laying hens
4.B.09.a
53 Broilers
4.B.09.b
53 Turkeys
4.B.09.c
54 Agricultural soils
4.D
4.D.1
1
1
4.D
4.D
10
13
4.D
4.D
2
2
9
17
2
2
12
19
4.D.1
12
13
4.D.1
17
20
4.D
4.D
2
2
32
4.D.1
4.D.1
35
4.D
4.D
15
15
1
18
23
4.D
4.D
15
4.D.1
15
4.D
16
21
54
54
54
54
4.D.1
4.D
4.D
4.D
3
3
4
4
6
4
14
6
5
6
4
4
12
6
14
6
4.D
4.D
19
19
4.D
14
14
4.D.1
13
14
4.D.1
15
21
4.D
4.D
4.D.1
4
4
4
12
Agricultural soils
Agricultural soils
Agricultural soils
Agricultural soils
34
4.D.1
10
14
4.D
10
10
4.D
4.D
17
4.D
4.D
6
6
10
10
6
6
10
10
4.D
20
20
4.D.1
14
16
4.D.1
14
14
4.D.1
14
14
4.D.1
13
13
4.D.1
14
14
4.D.1
14
14
4.D.1
14
14
4.D.1
14
14
4.D.1
4.D.1
6
6
10
19
7
7
14
8
4.D.1
4.D.1
13
4.D
14
14
4.D
14
4.D
14
4.D
10
13
14
4.D.1
4.D.1
6
6
14
14
4.D
4.D
4.D
7
7
11
8
7
7
11
8
4.D
13
14
4.D.1
13
14
4.D.1
4.D
14
14
15
4.D.1
4.D
14
14
14
14
15
4.D
14
4.D
16
21
16
21
4.D
17
17
23
4.D
4.D
17
17
25
27
17
17
27
27
4.D.1
17
18
17
21
4.D.1
17
36
17
37
4.D
18
28
18
28
4.D.1
18
18
4.D.1
18
31
23
4.D.1
18
23
4.D.1
21
21
4.D
4.D.1
4.D.1
4.D.1
4.D.2
4.D.2
55 Field burning of agricultural wastes
4.D.2
4.F

4.F
4.F
2
3
2
15
4.F
13
15
4.F
4.F
15
4.F
12
12
4.F
4.F
4.F
16
4.F
4.F

4.F
4.F
4.F
5
5
5
4
14
10
4.F
4.F
4.F
4.F
4.F
12
4.F

56 Agriculture other
4.F
4.G
4.G
4.G
4.G
57 Solid waste disposal on land

6.A
6.A
1
1

6.A
6.A
2
2
4
14
2
2
4
14

6.A
6.A
6.A
2
2
2
14
3
4
2
2
2
14
3
4
6.A
30

6.A
6.A
2
2
30
2
6.A
6.A
6.A
6.A
18
18
6.A
6.A
58 Waste-water handling
6.B
6.B
1
1
6.B
6.B
11
19
6.B
15
19
6
6
6.B
6.B
6.B
15
6.B
23
23
6.B
23
23
6.B
16
19
6.B
22
23
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
6.B
59 Clinical waste incineration (d)
6.C.a
11
6.C.a
6.C.a
6.C.a

6.C.a
6.C.a
13
15
6.C.a
17
59 Waste incineration
6.C
60 Industrial waste incineration (d)
6.C.b
19
6.C.b
6.C.b
6.C.b
13
16
13
18
6.C.b
11
6.C.b
11
11
6.C.b
12
12
6.C.b
17
17
61 Municipal waste incineration (d)
6.C.c
6.C.c
10
10

6.C.c
6.C.c
10
11
6.C.c
13
22
6.C.c
24
24
6.C.c

62 Cremation
6.C.c
6.C.d
62 Cremation
6.C.d
11
10
11
63 Small scale waste burning
6.C.e
18
6.C.e
15
6.C.e
64 Other waste
6.D
64 Other waste
6.D
64 Other waste
6.D
64 Other waste
6.D
64 Other waste
6.D
64 Other waste
6.D
64 Other waste
6.D
64 Other waste
6.D
64 Other waste
67 Forest fires
6.D
11.B
18
13
Comment
Proposed
decision
Action taken
The EFs are clearly inadequate and was evidently

been reviewed by people with no or little
experience in emission inventory compilation
Rejected
None
The document is weak in discussing Flue gas

treatment impacts on reducing emissions - it is not
clear whether emission factors refer to abated or
unabated emissions and which abatement
technology is used. Also see Comment 10 on this
sheet (only Sox and NOx abatement are discussed
and no co-benefits)
Noted
Modified text to include

more detail on PM, some
additional detail on
abatement added as an
appendix
Table 1-1 has no mention of HCB despite that

there is a reporting requirement for this substance. Accepted
HCB added to Table 1-1
Emissions from cracking and catalyst regeneration

are includedin Chapter 1.B.2.a.iv. Suggest
combine last 2 sentences to read: "Production
processes such as thermal cracking and catalyst
regeneration as well as fugitive emissions are
covered in Chapter 1.B"
Add NFR code to title to maintain consistency with
title 2.1
Insert "1.A.1.b" into section 2.2 title as per that for
2.1 for 1.A.1.a
This paragraph is unclear. Assumeable there
should be a reference to 1A1c.
I can agree in general about the semplification in
methodologies and in reference to BREEF but the
previous release of the chapter was really
interesting including a very good description of
"combustion mechanism", so "Don't throw out the
baby with the bath water"; I propose to maintain
the old documentation in the new GB for example
as an Appendix!
Insert "1.A.1.c" into section 2.2 title as per that for
2.1 for 1.A.1.a
2nd sentence: "IA1b" should read "1A1c".
write: "has typical combustion temperatures
leading to"
For these paragraphs to be of any use they need

to be expanded.
"..up to about 20 MWth.." should read "..from
about 20 MWth..."
Rejected
Text modified to clarify

scope.
Editorial
Done
Editorial
Done
Editorial
Done
Some additional text

included (on PM control)
Consult with and selected information
Expert Panel included as an appendix
Editorial
Editorial
Done
Done
Editorial
Done
Noted
Some slight modifications

but readers needing detail
should consult BREF
scope.
Noted
Not only solid and liquid fuels contains N, biomass

should be included in the parentheses.
Noted
Text amended
Natural gas fuelled stationary engines should be

mentioned as a potential large emitter.
None
Noted
As usually in the text there are no data about

pollutants concentration I propose to delete the
paragraph "Mercury concentrations are reported to
be in the range of 2 - 5 g/m3 for natural gas [van
der Most & Veldt, 1992, Umweltbundesamt,
Germany, 1980]". Why Hg for natural gas and not
other pollutants for other fuels?
Accepted
Text modified to remove

data.
Hg levels quoted for natural gas are too high; own

data show a mean of about 100 ng/m
The sentence "can achieve" is duplicate
Noted
Editorial
Emission factor removed

from text, no new
referencable data from EP
but previous guidebook
factor adopted
Done
Noted
Editorial
Some additional text

included (on PM control)
and selected information
included as an appendix
Done
The entire chapter on controls in this draft are

excerpts from the existing guidebook, however it
has been scaled back so that the usefulness has
totally vanished.
write: "technology.."
Impacts of control measures on SOx and NOx are

discussed, but there is no discussion of particulate
control and the co-benefit of these technologies on
the reduction of e.g. metals
Accepted
Short text added on PM

abatement
As usually in the text there are no data about

pollutants concentration I propose to delete the
paragraph " The NOx reduction efficiency can be
between 70 and 90 %." Otherwise efficiency must
be reported for all technologies in an appropriate
Table. This last option is most appropriate.
Some efficiency data from

current guidebook chapter
added as an appendix
Noted
The sentence "If detailed information is available,

use it" is generic, I propose "if emissions data
coming from continuous stacks measurement are
available, use it; otherwise if information coming
from periodic measurements are available use it in
combination with other information"
Noted
None
The statement, that the default emission factors

have been derived from all available data and
information, seems rather bold when the vast
majority simply refers to the existing guidebook.
Delete the sentence "have been derived from all
available data and information"
Do the term vegetable waste equals agricultural
waste?
Accepted
Text amended
Accepted
Text amended
Accepted
Text amended
There is no clear definition of the assumption

(power input, technology, abatement) of the Tier 1
methodology. If, as stated, the factors are a simple
mean I think this is not appropriate. We cannot
evaluate the EFs without reference to a concept of
"most used" technology.
Noted
Delete "have been derived from all available data
and information".
Accepted
Correct "sib-bituminous" to "sub-bituminous"
Editorial
We feel Petroleum Coke would be better classified
under "hard coal" rather than heavy fuel oil, as it is
a solid fuel
Noted
Tables 3-3-3-9 are not complete. Emission factors
for PAH are shown without indication of species;
emission factors for PCDD/F are shown with
reference to EPA 1998 but there are a lot
European-based data on dioxins emission; no EF
for PCB and HCB for all fuels.
Accepted
Inconsistencies in the terminology used to describe
fuels in different tables
Editorial
It should be indicated in the tables what TEF
system (I-TEF or WHO-TEF) is used for dioxins &
furans
Table 3-5: no Hg emission factor for natural gas.
Discussed with EP 7/5/08;

some detail added and
expansion of Tier 2 factors
Text amended
Done
None
Discussed with EP 7/5/08,

PAH now speciated,
PCDD/F PCB and HCB
added where available.
table fuels modified
Will change with new
tables
Consult with
Expert Panel Discuss with EP 7/5/08
Table 3-7- 3-9: no PCDD/F emission factors for

heavy fuel oil, other liquid fuels and biomass. PAH
emission factor for biomass should be checked.
Accepted
tier 2 emission factors for stationary engines are
missing
Accepted
Tables 3-11, 3-12, 3-13, 3-14, 3-16, 3-17, 3-19, 320: emission factors are shown with reference to
the Guidebook 2006. But Guidebook 2006 does
not contain exactly the same emission factors;
maybe they were recalculated - this should be
indicated. Combustion emissions significantly
depend on boilers power, but Tier 2 tables do not
account this.
Accepted
Factors reviewed and

modified as appropriate
Factors provided
Tables revised, source of

factors should now be
clearer
Tables 3-11, 3-12, 3-13, 3-16, 3-17, 3-19, 3-20

(Tier 2) and Tables 3-3 -3-4 (Tier 1) include same
emission factor for PCDD/F with reference to EPA
1998 a lot of data available for PCDD/F emission Consult with
from coal combustion in Europe.
Expert Panel Discussed with EP 7/5/08
No subdivision based on MWt of the plant are
reported in Tier 2 methodology (the "old" GB
reported this subdivision!); this subdivision can be
more relevant that the subdivision between dry
bottom and wet bottom reported in the new GB
Accepted
Discussed with EP 7/5/08;

size split retained
No subdivision based on technology of combustion

(low NOx burner - staged air supply o overfire air)
of the plant are reported in Tier 2 methodology (the
"old" GB reported this subdivision!); this
subdivision can be more relevant that the
subdivision between dry bottom and wet bottom
reported in the "new" GB
Noted
Discussed with EP 7/5/08,

some text on abatement
efficiency retained as an
appendix to maintain
information
No complete subdivision based on configuration of

burner (wall or tangential) are reported in Tier 2
methodology (the "old" GB reported this
subdivision!); this subdivision can be more relevant
that the subdivision between dry bottom and wet
bottom reported in the "new" GB
Noted
Discussed with EP 7/5/08
No control system specification in Tier 2

methodology (the "old" GB reported this
information!);
Noted
Unclear NOx emission factors and undefined

references, for example for coal the EF is too low
compared with the methodology of "old" GB see
Table 25 of the B11 chapter. For natural gas the EF
is to high compared with the methodology of "old"
GB see Table 24 of the B11 chapter controls?
Noted
Unclear SOx emission factors (% S in fuel? ash
content in coal?) controls?
Accepted
Unclear CO, COV, HM emission factors, no
reference with "old" GB
Noted
Some factors modified by

extension to Tier 2 tables
Text now includes
calculation from fuel S
Some factors modified by
extension to Tier 2 tables
PM emission factors unacceptable for Tier 2. In

US EPA for example a Dry bottom plant burning
Coal with no control has EF = 398,7 while the
same plant with baghouse has EF = 3,5. "New" GB
(CEPMEIP) report EF = 26. What is the
assumption! What is the control system? How can
be used this emission factor in Sweden and
Albania? How can be used to evaluate future
emissions?
Noted
Tier 2 factors are now as

used in guidebook
supplements from 2005/6
CONCLUSION the tables are unclear and

unusable, the "interpretation" of the "old" GB EF is
an unacceptable simplification
Noted
Discussed with EP 7/5/08.

More of old guidebook
retained.
Table 3-13 (Tier 2): PM and HM emission factors

are the same as in the Table 3-4 (Tier 1).
Noted
Tables revised.
Noted
Tables revised
Accepted
Tables revised
Table 3-15 (Tier 2): emission factors are the same

as in the Table 3-5 (Tier 1); no Hg emission factor.
Table 3-18: no PCDD/F emission factors for wood
and similar wood wastes.
Table 3-17 (Wet Bottom Boilers) and the Table 312 (Dry bottom Boilers): the same emission factors
for all technologies - this is not correct.
Noted
Table 3-21: no PCDD/F emission factors for wood
and similar wood wastes.
Noted
This table 3-22 is an exact duplicate of table 3-24
in chapter 1A4, including the mistake of having a
negative TSP emission factor.
In the "Not estimated" list of Table 3-22, PAH's
should be deleted
In the "Not estimated" list of Table 3-23, SOx
should be deleted
In the "Not estimated" list of Table 3-24, PM should
be deleted
Even though this report is a draft version there
should not be incomplete references to other
chapters, unless the intent is to purposely annoy
the reader. This is a recurring problem several
times in this draft version.
Tables revised
Editorial

tables
tables
tables
tables
Accepted
Reference included
Editorial
Editorial
Editorial
The industry emission reporting guidance does not

provide anydetails of the technologies. Delete "and
the industry emissionreporting guidance [Concawe,
2007]".
Accepted
unusable, the only complete work by Concawe was
not used
For guidance add "-see Chapter 1B2c" after
"....activities"
For guidance add "-see Chapter 1B2a.iv" after
"....units"
"....releases"
"....emissions"
Change "reduced" to "eliminated" as NH3 is fully
converted
"....units"
Delete ")" after "V"
Tables revised
Text amended
Noted
Discuss with EP 7/5/08
Accepted
Done
Accepted
Done
Accepted
Done
Accepted
Done
Accepted
Done
Accepted
Editorial
Done
Done
Add "[Concawe, 2007]" after "Concawe"

There is a specific paper by Concawe (Report no.
9/05R "Air pollutant emission estimation methods
for EPER and PRTR reporting by refineries
(revised)") that the consultant don't take into
consideration and use an undefined reference US
EPA (2000)
Delete "grouped by major fuel types" as only
refinery gas EF's given.
Add "in Appendix B" after "...comparison"
Add new paragraph: "Concawe has published a
compilation ofrecommended emission factors for
reporting by refineries under the E-PRTR
requirements [Concawe, 2007]. For combustion
the majority of these factors are equivalent to a
Tier 2 approach."
Accepted
Done
Noted
Table has been revisited

and incorporates Concawe
and other sources
Accepted
Accepted
Done
Done
Rejected
Application of these
factors by refinery
operators is on a facility
basis - inclusion of this
statement may preclude
acceptability of this data at
Tier 3
Following on from comment above, it is proposed

that the followingis added after "combustion" at the
end of line 34: "units e.g. boilers and process
heaters and 'furnaces';"
Accepted
Done

EPA (2000)
Text revised
Noted
Tables: - EF for SOx: Providing a fixed EF for SOx

does not permitthe benefits of the reduction in fuel
sulphur content by refineriesto be captured in
inventories. Member State authorities can obtain
the mass and average sulphur content of fuels
used in refineries, soa simple algorithm should be
provided in Tier 2 instead of fixed EF.
Accepted
Text modified, where

member States have
facility specifc data they
should incorporate in their
inventories. Tier 2 could
be refinery-specific but this
is still an aggregated
activity level.
Tables: - there should be consistency in the

number of significantfigures used for emission
factors. Two significant figures should beused for
Tier 2. In Table 4-3 some EF's are given with very
high accuracy (e.g. SOx = 349.9) whereas others
e.g. heavy metals arerounded to only one
significant figure.

tables
Tables: - calculation of upper and lower 95%

confidence limits. The calculation of limits in these
Tables do not appear to follow the guidance in the
cross-cutting Chapter on uncertainities. For
example, an EF with Corinair code C would have
95% limits of100% of the EF value (range 50% to
200% - 100% taken as default). Where Concawe
has made comments on EF's the upper and lower
limit values have been calculated according to
these guidelines.
Noted
limits revised in updated

tables
Table: EF references - there are a number of

references to "Guidebook (2006)" and "Guidebook
(2006), US EPA (2000)". Concawe strongly
considers that an EF derived in some manner
(e.g.by taking geometric mean) of upper and lower
limit values of a range,as quoted in the Guidebook,
should NOT be used where a publishedEF is
available from a well established source (e.g. AP42) whichhas been computed from a large number
of measurements. Such a mean value has more
scientific basis than one derived from valuesat
either end of spread for which the distribution is
unknown. That technique is accepted as being
valid only where an EF derivedfrom a number of
measurements made in the same way is
notavailable.
Noted
None, but revision of

emission factor tables has
been done
Table Titles: Tables 4-3 through 4-7 all refer solely

to "heaters". Thereare other combustion units in
refineries e.g. CO boilers, fired waste heat boilers,
etc. and heaters are often called 'process
furnaces'(see, e.g, text in section 4.1.2) although
there is no contact betweenthe fuel and process
material.It is proposed, therefore, to help clarify
what the EF's are for, the term"Heater" in the titles
of the Tables is changed to "Combustion Unit".
Noted
Text clarified
Add new paragraph for clarity: "All the Tier 2

emission factorsprovided in Tables 4-3 to 4-8 are
for unabated emissions. To estimate emissions
where abatement systems are installed,
informationon abatement system efficiencies is
available in the Refinery BREF[EIPPCB, 2003]".
(However, see comment on p 39, line 3)
Noted
None

EPA (2000)
Noted
See earlier note on

Concawe report

EPA (2000)
Noted
See earlier note on

Concawe report

EPA (2000)
Noted
See earlier note on

Concawe report
Comment on table 4-8:

- the emission of NMVOC is dependent on the fuel
gas composition
- in the USA VOCs (that means non methane / non
ethane hydrocarbons) are regulated and NOT
NMHC (non methane Hydro carbons)
- the LCP BREF document 2006 mentions only
formaldehyde as hydrocarbon
- RECOMMENDATION: the figues on NMVOC in
table 4-8 should be taken out and a general
comment on the fuel dependancy relating to this
emmitent has to be put in the table. Otherwise the
figures will lead to big misunderstandings.
Rejected
We accept that the

emission is dependent on
fuel composition but
combustion and lubricants
are also relevant. We also
accept that USEPA VOC
figure also excludes
ethane however, in the
absence of other data, it
provides a reasonable
value for nmVOC. An
alternative would be to
apply the the USEPA TOC
figure. At least one
member state applies an
emission limit for
formaldehyde but
inventory is about total
nmVOC not individual
components.
The value for NOX in the table 4-8 (100 g/GJ) is

about 120 mg/Nm3 (at 15% O2). This is about 320
mg/Nm3 at 5% O2. This is far away from the
industry recommendation that has been given in
the LCP BREF. There it was recommended to
introduce 190 mg/Nm3 at 15% O2 for lean burn
SG gas engines. This is about 160 g/GJ.
RECOMMENDATION:
- correct the value according to industry
recommendation.
- Furthermore introduce a span for the NOx value.
- A value for gas engine that are operated in the
gas-diesel-mode is missing. This value has also to
be integrated.
Noted
The guidebook is not

reflecting BAT.

EPA (2000)
Noted
See earlier note on

Concawe report

EPA (2000)
Noted
See earlier note on

Concawe report
Wrong NFR, it's no clear what table refer! It's crude

oil combustion? Where? In a process furnace?
Noted
Table 4-9 appears to belong to NFR 1A1c (as
shown in table "code"box.

tables
All the Tier 2 emission factors are for unabated

emissions. It wouldbe useful to provide a table of
abatement system efficiencies (c.f.tables in
1.B.2.a.v and 1.B.2.a.iv) after the Tier 2 EF tables. Noted
Done where possible
Subchapter 5 1A1c Manufacture of solid fuels: the

title and content are not harmonized; only coke
manufacture is described.
Noted
This section may be misleading. If a refinery has

used the Concaweguidance [Concawe, 2007], then
the data do not require a QA/QC check as the EF's
used would be from well recognised and accepted
sources such as EPA AP-42. If facility PRTR data
are extrapolated to derive national inventories,
there is the danger of serious errors as both the
EPER and E-PRTR reporting schemesinclude
thresholds. It is proposed that the second and third
sentences are switched, text extended and the rest
deleted:Thus: "Refinery installations are major
facilities and emission data forindividual plants
may be available, but possibly for only a
limitednumber of pollutants, through a PRTR or
another national emission reporting scheme.
When the quality of such data is assured by a well
developed QA/QC system, it is good practice to
use such data.Guidance on estimating refinery
emissions has been publishedby the industry
sector [Concawe, 2007]"
Noted
Tect amended to partly

reflect comment.
The heading for this chapter misses the second

part "Other energy industries"
Have put in those from old

guidebook POPs chapter
Editorial

unusable
Noted
Have put in those from old

guidebook POPs chapter
This chapter is very thin. Under "Techniques" only

coke manufacture is mentioned. The existing
guidebook does not have a separate chapter on
neither 1A1b nor 1A1c, this would have been an
excellent time to improve that aspect, alas nothing Consult with
has been done.
Expert Panel Done where possible
It is proposed that there is an additional paragraph

on NOx estimation using facility data. "NOx
formation is very complex, anddepends on a
number of parameters e.g. hydrogen and moisture
contents, pre-heat temperature, burner intensity,
etc. Amethodology to calculate NOx emissions has
been published (in theOil and Gas Journal) and
provided in Concawe, 2007 as the recommended
method for refineries to use for emission reporting.
Where facility data are available, this detailed
methodology should beused to obtain more
accurate NOx estimates than the fixed value
emission factor provided in the Tier 2 approach."
Rejected
Figure 5-1: error in the title.
Editorial
The chapter already refers

the reader to Concawe
guidance for Tier 3.
Additional reference or
highlighting of specific
pollutants is not necessary.
Done
The decision tree is obviously similar to the one for

petroleum refining, however the figure text should
reflect the correct chapter.
Editorial
Figure title amended

methodology. If as stated the factors are a simple
evaluate the EFs without reference to a concept of
"most used" technology.
Noted
In the tables 5-3, 5-4 not estimate selenium and

Heavy metals. It is not correct, because HM
includes Se.The same problem for PAH as for
other combustion (only summary EF, not by
pollutants)
Noted
Tables revised

evaluated the EFs without reference to a concept
of "most used" technology. Only very poor list of
pollutants take into account. ? Other liquid fuel?
Consult with
Expert Panel Done

evaluated the EFs without reference to a concept
of "most used" technology. Only very poor list of
pollutants take into account. ?
Noted
Very useful table, however there is no need to

separate emissions from GT and gas engines last.
The order of the pollutants is also strange, SO2,
NOx TSP would be the logical order.
Noted
Appendix B not Appendix 2
Editorial
GT and engines moved,

no other comments on
pollutant order so not
changed
Done
This glossary should either be expanded or

removed. Some listings in the glossary do not
appear previously in the text.
Revised
Accepted
Considering the number of times "Guidebook

(2006)" is referenced in the text it is quite an
accomplishment to have it excluded from the list of
references.
Accepted
References amended Guidebook 2006 generally

replaced by original ref.
Update the reference to the EURELECTRIC guide Editorial
Revised
Reference list: There are references given in the

EF tables of "USEPA (1998)", "US EPA (2000)"
and "US EPA (2003)". There areonly two US EPA
references in the Reference List, and one of these
is for 1987. The other is undated. The Reference
List needs toreflect the references in the text and
tables.
Editorial
References will be
rationalised
Need to define the calculations & assumptions

used to convert emission concentrations into EF
and make sure that they are consistent with
Appendix C
Accepted
note added to tables
Noted
None
The NOx values from the Gothenburg Protocol are

listed in table B4.
These values should be taken out as there os a
political decision to review the Gothenburg
Protocol. Furthermore these values (for diesel
engines) are far beyond BAT.
See also:
http://www.euromot.org/download/news/positions/s
tationary_engines/UNECE_CLRTAP_ABC_Analysi
s_080403.pdf
tationary_engines/EIPPCB_BREF_euromot_comm
ent_may_02.pdf
In these position papers emission limit values are
recommended. We propose to overtake those
emission limit values in table B4.
The given BREF NOX value for new and existing

stationary gas engines in the table B4 is too low.
Correct span should be 20-190 mg/Nm3. Please
compare the emission table of the General
Environmental Health and Safety (EHS) Guidelines
of the World Bank. World Bank has implemented
emission limit values that are depending on the
engine type, the used fuel, the positioon of the
engine etc. We support this strategy as it refers on
different emission limit values that are depending
of different surrounding operation factors. These
factors are also depending on the infrastructure
around the engine (water, reagents, fuel quality,
etc.).
Please compare page 7 of the document under the
following link:
http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTi
tle/gui_EHSGuidelines2007_GeneralEHS/
$FILE/Final+-+General+EHS+Guidelines.pdf
We recommend to distinguish the emission limit
values for different engine types.
Noted
The range indicated in the

comment reflects industry
view of BAT; the table is
intended to summarise the
main BREF AELs and
cannot reflect all
comments/notes to the
Table.
An O2 concentration of 21% instead of 20,9%

seems more common; e.g. 21% is used in the
informative appendix E of EN 14181
Noted
convert US EPA method 19 in SI units or replace it
by the IEA correlations
Rejected
Some sources use 21 (for

example standardisation of
emission concentrations in
the Waste Incineration
Directive which, as with
the LCPD, includes
requirements on CEMS
uncertainty and hence was
a driver for EN14181),
USEPA Method 19 and
others use 20.9 for
corrections and some
others apply values
between these figures (for
example 20.95 or 20.96).
Difference is minor.
units are dscm/J or, dry
m3/J
I could not find any HCB emission factors for coal

and wood combustion or other relevant sources.
See
http://reports.eea.europa.eu/EMEPCORINAIR5/en/
Sources_of_HCB_emissions.pdf.
Accepted
Tables revised
Many EF-references are of kind "(Guidebook

2006)". I suggest to refer to original references
from the Guidebook 2006.
Noted
References revised
The units in the emission factor tables should be

changed depending on pollutant. Main pollutants
and particles could be kept in g/GJ, while metals
could be listed in mg/GJ, PAH in mikrogram/GJ or
mg/GJ and dioxin and other POP's in ng/GJ.
Noted
Noted and some factors

have been modified
In the chapters concerning stationary combustion

there are only given a default emission factor for
PAH. But for reporting purposes individual
emission factors are needed for the 4 different
PAH's.
Accepted
Tables revised
In the existing guidebook information on the 4

different PAH's is available. A combined PAH
emission factor is somewhat useless considering
the reporting requirements.
Accepted
Tables revised
There are a general lack of HCB emission factors

in this chapter. It seems that only under waste
incineration is an emission factor for HCB
provided.
Noted
Tables revised
The existing guidebook has a specific chapter on

HCB, (and PCB), it would be appropiate if the data
in these existing chapters were included and
expanded in this revised guidebook.
Noted
Tables revised
A lot of the emission factors references to

Guidebook 2006 does not seem to correspond
correctly.
Tables revised
Noted
E.g. NOx emission factor for DBB residual oil listed

in table 3-14 as 300 g/GJ. In the existing
guidebook the NOx emission factor for residual oil
varies between 150 and 296 g/GJ
make clear that Emission factors refer to net
calorific values
Accepted
The emission factors for the stationary gasengines
totaly missing.
Noted
No mention of stationary engines in the Methods
Noted
chapter!
If the authors could not be bothered to write
something new, they could at least have copied all
the text from the existing guidebook.
Noted
Additional text added

Table included
General comments: chapter includes large number

of very different processes so will be difficult for
usage; there is no indication where to get
information for estimation of emission from
combustion using proposed methodology (i.e. what
fuel and how much it was used for production of a
certain ferrous or non-ferrous metal). In this case
applicability of it will be low. There are a lot of
tables in the chapter which are not applicable, for
example, emissions from natural gas combustion
in lead or copper production. Assumption that all
NOx, SO2, CO, NMVOC emissions are from fuel
combustion will lead to significant difficulties in
emission inventory and to miss of sources.
Accepted
Tier 1 factors will remain

heat input but Tier 2 will be
revised to be based on
production which should
make chapter more useful
For fuel use in conventional boilers, furnace,

engine or other device emission information is
referred to Chapters 1A1 and 1A4.
Some modification to text
Noted
In table 1-1 under iron and steel one is refered to

chapter 1A1 with regard to stationary engines this
must be a mistake since no guidance on stationary
engines is provided in this chapter.
Accepted
None - combustion
chapters now include a
stationary engine table
I assume the correct chapter for guidance on

mobile sources in industry would be chapter 1A4
Other Mobile and not 1A2.
Amended reference to
1A2fii
Accepted
Where, if any, should be accounted NOx emissions

from catalytic oxidation of ammonia in nitric acid
production? Are you provided for this source of
NOx emissions in Chapters 1A2 or 2B?
Noted
Although NOx arises form

oxidation of ammonia
emissions are assigned to
the process
SOx emissions in this NFR category are calculated

only from SOx emissions from the fuel combusted? Noted
None
Again there are no mention of HCB despite the

reporting requirement for this substance.
Text now includes HCB
Noted
It's not clear where the EFs come from! Particularly

when Guidebook (2006) is quoted it's not true that
EFs are present in this form in original reference! If
elaboration was performed on original data these
must be explained, otherwise the table is
unacceptable
Noted
Discussed with EP, tables

have been amended to
clarify

unacceptable
Noted

clarify
There is any reference about what specific fuels

are covered under fuel type named "Derived
Fuels" in this Chapter. Are these specific fuels
those mentioned in Chapter 1A1, Table 3-2?
Accepted
Yes, table included from

1A1
The 95% confidence interval for TSP in Table 3-2

is 0-10, while for PM10 and PM2,5 the interval is
0.1-10. Is lower value for TSP correct?

tables

unacceptable
Noted

clarify

unacceptable
Noted

clarify
The 95% confidence interval for PM10 in Table 3-2

is 0-2, while for TSP and PM2,5 the interval is
0.02-2. Is lower value for PM10 correct?

tables
Table 3-3: Why Dioxins and Furans emission

factors for natural gas have not been estimated?
When using Tier 2 method there is an emission
factor of 2 I-TEQ ng/GJ for all activities in this NFR
category 1A2 with the exception of cement and
lime production activities (SNAP codes 030311 and
030312)
Noted
Factors now in at Tier 1 refer to process emissions
In Table 3-4 (Tier 1 approach), there is no emission

factor estimated for dioxins and furans when using
heavy fuel oil.
Noted
Now referenced to
combustion chapters
In Chapter 1A1, page 9, lines 31 to 33, it is said

that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
Consult with
are indicated in Table 3-13
Expert Panel Included
Tables 3-13, 3-16, 3-19, 3-26, 3-30, 3-34, 3-36, 338, 3-41, 3-43: EF for Hg and Pb in column Value
are shown as 0, but in column Lower not 0.

tables

unacceptable
Noted

clarify

unacceptable
Noted
There is any reference about what specific fuels
are covered under fuel type named "Other Liquid
Fuels" in this Chapter. Are these specific fuels
those mentioned in Chapter 1A1, Table 3-2?

clarify
There is no mention to heavy metals in Table 3-5.
Yes, table included from

1A1
tables
In Table 3-5, Dioxins and Furans emission factors

have not been estimated for Other Liquid Fuels.
However, when using Tier 2 approach there is an
emission factor of 5 I-TEQ ng/GJ independently of
what is the SNAP activity considered.

tables
Which fuels are considered under the fuel type

"Biomass"?
Noted
For combustion these are

as listed in 1A1 - table now
included in text
In general terms it is have not been clarified

whether the proposed emission factors correspond
to the emissions originated from only the fuels
combusted or they also correspond to total
emissions originated from the fuels combusted
plus those originated from the materials in the
contact furnaces. Carificatin of this pont is
particularly relevant for the activities in the 1A2
NFR category, as many of its installations are
contact furnaces.
Noted
Following discussion with

EP, Tier 1 is default
combustion only, Tier 2 is
generally only
NOx/SOX/CO with balance
of emissions assigned to
the process chapters
Only a unknown elaboration on very old GB

values. NEW INFORMATION FROM IPPC BREF
DON'T TAKEN INTO ACCOUNT. Why only Coke
Oven Gas when old GB contains EFs also for blast
furnace gas and natural gas? Specific fuel
consumptions in GJ/Mg of product MUST BE
REPORTED!
Noted

clarify
Blast furnace cowpers (SNAP 030203): Emission

factors proposed only covers coke oven gas
combustion (table 3-7), but there are no
information available related to other fuels
(specially blast furnace gas, but also GLP or
natural gas).

clarify
Noted
Noted
EF in tables (Tier 2) for TSP, HM and PCDD/F are

the similar for same fuel and different processes,
for instance, EF in Tables 3-8, 3-15, 3-27, 3-28, 332, 3-40 (fuel is coke or hard coal). The same
situation for Gas, Liquid fuels. How this wss
proved? Is it necessary to duplicate tables?
Noted
Tables revised following

discussion with EP
The production processes described in the

guidebook are generic, focussed on applicability
for various individual processes. This approach
does not take into account the more complex
reality of intertwined processes such as Iron and
Steel Manufacture. This is especially true for the
use of mixed process gases.
Noted
Yes but the level of activity

detail defines the basis of
factors suitable for use at
Tier 1 and 2
Table 3-8 Tier 2: it is shown that HM emission

factors are from the Guidebook (2006). But in the
Table 8.2c of the Guidebook (2006) there are no
such emission factors.
Noted
Tables have been revised
Noted

clarify
Noted

clarify
EFs old and not validated. PM EFs for 1.A.2 and

2.C.1: as you subdivide combustion and not
combustion PM emissions! Use BREF EFs!

clarify
The SNAP code in table 3-10 (030302), and the

literal for Technologies/Practices item (Reheating
Furnaces) does not match with the heading of the
table. Which activity is referred to in this table?

tables

Noted
Revised EF tables should

be clearer
For Reheating Furnaces (SNAP 030302) there are

only emission factors for coke oven gas. What's
the matter with the other fuels used in this activity?
In Guidebook 2006 there is a wide list of fuels used
in this furnaces.
Noted

clarify
Table 3-12 (Tier 2): error in the title of the table; not
coincide with the content (Reheating furnaces); EF
for PCDD/F are shown with reference to the
Guidebook 2006, but in the Guidebook 2006 there
are no such emission factors.
Editorial
Done
The title refers to "Gray Iron Foundries" but the

technology in the table refers to "Reheating
Furnaces". However existing GB EFs old and not
validated. PM EFs for 1.A.2 and 2.C.1: as you
subdivide combustion and not combustion PM
emissions! Use BREF EFs!
Noted

clarify
The SNAP code in table 3-12 (030302), and the

literal for Technologies/Practices item (Reheating
Furnaces) does not match with the heading of the
table. Which activity is referred to in this table?
Emission factors in this table are the same as
those proposed in Table 3-10.

tables

Noted
See earlier comment
Tables 3-12 - 3-13 Tier 2: it is known that gray iron

in foundries is produced using coke so how EF for
natural gas and other liquid fuels were obtained
and where they can be applied?
Noted
Table headings modified
Why "Other Liquid Fuels"? Why these EFs ? USE

BREF EFs!

clarify
Noted
In the existing guidebook default values are

provided in g/tonne liquid steel, which perhaps is a
better unit for these type of default emission
factors.
Accepted
Tables have been modified

to allow use of production
activity data at Tier 2
The Hg emission factor proposed in Table 3-13 is 0

g/GJ, while the 95% confidence interval for this
pollutant is 0.00001-0.0001

tables
The Pb emission factor proposed in Table 3-13 is 0


tables
Table 3-14: For Primary and Secondary Pb/Zn/Cu

production using Natural Gas, it is very surprising
that there are no heavy metals emissions
(indicated as not applicable), taking into acccount
that these are processes with contact and the raw
materials obviously content the corresponding
Heavy Metals.
Heavy metals now

assigned to process
emission
Noted

Noted
See earlier comment
The same EF for PM, HM, PCDD/F and PAH are

shown in the Tables 3-14 (Pb/Cu/Zn Production),
3-17 (Secondary Aluminium Production) and 3-20
(Alumina/Mg/Ni Production); though technologies
are different.

tables
All the chapter "3.3.2.2 Combustion in 1A2b 1

Non-ferrous metal" it's unclear because I don't
understand if take into account the different
condition of combustion in roasting and as it's
possible to subdivide emissions from fuel and from
materials in such a case (see GENERAL
PRELIMINARY COMMENT). If it's possible it's
necessary to develop specific emission factors not
to copy "old" EF that derive from another
approach.
Noted

clarify
In Table 3-15, emission factors for Heavy Metals,

Dioxins and Furans and PAH for Primary Pb, Zn
and Cu Production using coke are the same as in
any other activity in this 1A2 NFR category. In the
particular case of Heavy Metals, it seems that
emission factors only refers to emissions
originated from the fuel combusted and there is no
relation to the raw materials used.
Noted

generally only
Table 3-16 also contains mysterious "0" values.

Likewise with table 3-19, table 3-26, table 3-30,
table 3-34, table 3-36, table 3-38, table 3-41 and
table 3-43.
Noted
Rounding issue corrected
Noted

generally only
Table 3-16: same comment as for Table 3-15.


tables


tables
The same EF for PM, HM, PCDD/F and PAH are

shown in the Tables 3-16 (Pb/Cu/Zn Production)
and 3-19 (Secondary Aluminium Production);
though technologies are different.
SNAP code in table 3-17 should be 030310 (not
0303)

tables
tables

Noted
0303)

tables
In Table 3-18, PM10 and PM2.5 emission factors

for heavy fuel oil seem to be interchanged (PM2.5
values are higher than PM10)

tables
The same EF for PM, HM and PAH are shown in

the Tables 3-18 (Secondary Aluminium Production)
and 3-21 (Alumina/Mg/Ni Production); though
technologies are different. There are errors of EF
for PM10 and PM2.5 in both tables.
0303)

tables
tables


tables


tables

Noted

generally only
In Table 3-21, PM10 and PM2.5 emission factors

for heavy fuel oil seem to be interchanged (PM2.5
values are higher than PM10)

be clearer
Accepted

Noted
See earlier comment
All the chapter Combustion in 1A2d Pulp and 1

paper production is not necessary (emissions are
counted in 1.A.1 as boilers)
Noted
Boiler plant emissions can

use factors from !A1 (or
1A4) butthey are not a 1A1
activity
Particles and metals in table 3-24 are indicated as

included elsewhere. Where would that be?
Noted

generally only
In Table 3-23 the 95% confidence interval for Ni is

0.002-0.0. What is the upper bound of this
interval?

tables
Emission factors for dioxins and furans and PAH

for wood are the same as for hard coal (or coke) in
other activities. Are this emission factors correct?
We could not find in Guidebook 2006 this
reference for SNAP activity 030321.

tables
In Table 3-24, particulates and heavy metals

emission factors for black liquor combustion have
the label "IE". Where have these emission factors
been included?

generally only
Noted
What does "IE" for emission factors mean ? Where

included ?
Noted
Erroneous paragraph numeration 3.3.4 and not
3.3.3.1
Editorial
Included elsewhere but

these references have
been removed (not
estimated)
Done

Noted
See earlier comment
Plaster: all the text it's unclear because I don't

condition of combustion in kiln and as it's possible
to subdivide emissions from fuel and from
to copy "old" EF that derive from another approach
(combustion + process).
Noted

generally only
For Plaster Furnaces there are only emission

factors proposed for natural gas and other liquid
fuels. Which emission factors should be used for
other fuels like hard coal, heavy fuel oil, petroleum
coke, wood, ...?
Noted

generally only


tables


tables
Cement: all the text it's unclear because I don't

Noted
Give precise reference to EF rather than
Guidebook (2006)

generally only
tables
The table design with one fuel per table do not give
a general view of EF - all fuels per process in one
table
Editorial
None
For Cement Production, there are no emission

factors proposed for petroleum coke, heavy fuel
oil, wood and wood wastes. Petroleum coke is the
main fuel used in this activity.
Rejected

generally only

Noted
See earlier comment

has not been estimated for Nataural Gas.
However, whe using Tier 2 approach there is an
the SNAP activity considered.

tables


tables


tables
Table 3-31 Tier 2: no emission factors for PCDD/F

which are high for waste combustion.
Waste combustion factors

now removed as
inappropriate in this
chapter
The fuel indicated in Table 3-31 (Hard coal) is

wrong. In accordance with the heading it should be
"Industrial waste"
Table 3-31: Fuel: Replace "Hard coal" with
"Industrial waste"
Noted

tables
tables
Lime: all the text it's unclear because I don't

Noted

generally only
Not all fuels used in lime production are covered in

the Draft. There are no emission factors for coke,
petroleum coke, heavy fuel oil or biomass fuels.
Noted

generally only

Noted
See earlier comment

has not been estimated for Nataural Gas.
However, whe using Tier 2 approach there is an
the SNAP activity considered.
Noted
UNEP factor adopted at

Tier 1, Tier 2 factors will be
in process chapters
NOX-EF for Lime kilns seems to be very high since

the needed temperatures are much lower than for
cement kilns. The different kiln types have very
different levels on NOX emissions. (see
http://www.umweltbundesamt.at/fileadmin/site/publi
kationen/REP0128.pdf, page 11)
Noted
Thamkyou for providing

data, this is good detail on
state of the art/BAT but is
on a restricted pool of
plant. Data from the draft
revised CLP BREF doesn't
provide fuel-based EFs but
indicates a very wide
range of emissions and
the factors provided in the
guidebook are within the
range of 'inferred' factors
from the BREF data.


tables


tables
In Table 3-36, the fuel is described as "Other Liquid

Fuels", but probably it is about gas oil. Is this
assumption correct?
Noted

generally only
Asphalt: all the text it's unclear because I don't

(combustion + process). PM from process where is
inserted?
Noted

generally only
In accordance with Guidebook 2006, chapter

B3313, "During the production of asphalt concrete
considerable amounts of fine particles can be
generated".
Noted

generally only
In Table 3-37 (gas natural combustion in asphalt

plants), the emission factor for NMVOC is
indicated as estimated elsewhere (IE).
Nevertheless, in Table 3-36 (combustion of other
liquid fuels) an emission factor of 11.8 g/GJ is
mentioned.

generally only
Accepted

Noted
See earlier comment


tables


tables
Glass: all the text it's unclear because I don't

inserted? Metals emissions very important for the
sector where are inserted?
Noted

generally only
For Glass Production, the SNAP code indicated is

0303. It is suposed that SNAP codes involved are
030314, 030315, 030316 and 030317.

tables

Noted
See earlier comment
The fuels considered are Hard Coal, Other Liquid

Fuels and Natural Gas. No reference is made to
other fuels like heavy fuel oil, petroleum coke or
biomass (wood and wood wastes).
Noted

generally only
Bricks and Tiles: all the text it's unclear because I

don't understand if take into account the different
inserted?
Noted

generally only


tables

There is no emission factor for NMVOC in Table 342

tables
tables

Noted
See earlier comment


tables


tables
The fuels considered are Other Liquid Fuels and

Natural Gas. No reference is made to other fuels
like Heavy Fuel Oil.
Which SNAP codes are referred to in Tables 3-42
and 3-43?

generally only
tables
Noted

Noted
See earlier comment
In "Glossary" section the LPG are included into

"Gaseous fuels", while in Chapter 1A1, Table 3-2,
the LPG are considered as "Other liquid fuels"
Accepted
Changed changed to liquid

fuels

removed. Some listings in the glossary do not
appear previously in the text.
Accepted
Done
References include only 2 sources.
Noted
Revised
A lot of references in the text do not appear in the

list of references, e.g. CEPMEIP 2004, CITEPA
2007, Guidebook 2006, CITEPA &ENEA 2007, US
EPA 1998, US EPA 2000, US EPA 2003 etc.
Noted
Revised
drying processes in which water vapour is used;

this vapour come from a boiler, so the emission
from this boiler is very similar to emissions in 1.A.1.
Where these emissions are allocated? The only
"additional" non boilers emissions from 1.A.2 can
be emissions from evaporation of organic
substances used in paper manufacturing that can
evaporate in the drying process. The "new"
Guidebook don't take into account these last and
report EFs for combustion that can be different
from EF in 1.A.1. Then we have a lot of similar
cases for example Combustion in Food Industry,
Mechanic Industry, ecc. What emissions factors?
We need a specific subsection.
Next we have old SNAP 0302 and 0303 group and
related new chapters. I think in these chapters
must be inserted only emissions come from
processes in which special condition or the contact
between fuel and materials produces different
combustion characteristics and different EFs:
essentially process furnaces. For these
applications, all the existing documentation (and
for example BREF of the IPPC directive) reports
EFs in g pollutants/kg product. Also statistical data
are available for production and not for energy
consumption of single product (for example are
available sinter production and fuel consumption in
iron & steel industry but not fuel consumption in
sinter plant). If the fuel approach is mandatory
then: 1. It's necessary to develop specific emission
factors, only from fuel, not to copy "old" EF that
derive from another approach (example US EPA
approach, that take into account the overall
process 2. Specific fuel consumptions in GJ/Mg of
product MUST BE REPORTED. INFORMATION
EXISTS AND CAN BE RETRIEVED IN IPPC
BREF DOCUMENT.
Accepted

clarify
The table contains some odd 0 values, I assume

this is due to the haste with which this document
appears to have been drafted.

tables
CONCLUSION: The chapter is unacceptable! All

the documentation from BREF ignored also data
sent to consultant from EP leader! All the
recommendation in EP and from industry about no
separation between combustion and processes
ignored. All the recommendation of use of product
approach ignored.
Noted

generally only
In addition to this, industrial waste fuels cover a

wide variety of materials, as specified in page 6,
lines 35 and 36, with different characteristics and
composition, so it is not clear if the emission
factors proposed should be applied to all industrial
waste fuels.
Noted
Waste factors now

removed
Moreover, there are no emission factors proposed

for heavy metals, dioxins and furans and PAH, and
emissions for these pollutants are relevant when
Consult with Waste factors now
using industrial waste fuels.
Expert Panel removed
Additionally, emission factors for SOx, NOx,

NMVOC and CO are the same as for hard coal.
Are these emission factors correct?

generally only
Consult with of emissions assigned to
Expert Panel the process chapters
Noted

generally only
However, emission factors for particles in Tables 336 and 3-37 seems to concern only fuel
consumption.
Noted

generally only
Taking into account that this is a process with

contact, these particles emission factors are
probably underestimated.
Noted

generally only
Noted

generally only
In addition, the reference for emission factors is

Guidebook (2006), but the corresponding chapter
for SNAP 030313 only provides emission factors
for particles. This comment is also valid for
emission factors related to gas natural
consumption in Table 3-37.
What is the difference between both tables?

Where is the NMVOC emission factor for natural
gas combustion indicated?
There are only two kind of fuels considered: Other

Liquid Fuels and Natural Gas. No reference is
made to other fuels like heavy fuel oil.
Noted

generally only
In addition, emission factors for Other Liquid Fuels

should be splitted for each fuel considered in this
category (gas oil, LPG, ...)
Noted

generally only
Which emissions (combustion and/or process) are

considered in the emission factors proposed? In
chapter 2.A.7.d, emission factors for heavy metals
and particulates are propposed (in terms of mass
of pollutant per unit of production),
and it is not clear if there is a risk of double
counting when applying both emission factors.
What are the major changes since earlier
versions?
Meaning of LTO-cycles 1?
Noted
Noted
Noted
Noted

generally only
Text amended to clarify
Will outline the main
changes
Needs correcting
Default methodology has been developped by

ICAO concerning APU cf. "Airport Air Quality
Guidance Manual" ICAO, April 2007. That could be
added within the GB, as far as the fuel used is the
aircraft kerozene.
Noted
Has been considered and

words added under
"Auxillary power
operations" on p4 of SOD
Within the 2007 EMEP/CORINAIR Guidebook,

general information on APU and fuel dumping are
provided that may be interesting to keep.
Noted
Has been incorporated

where appropriate
It must be emphasized, that military aviation is

classified as NFR code 1A5 (other) according to
agreed EMEP nomenclature.
Noted
has been emphasised
Please distinguish between sources of emissions

belong under this NFR and other (e.g painting
belongs to another NFR and should not be
ignored)
Noted
has been emphasised
This should be explained in much more details,

and a table should be provided giving a thorough
overview of today's situation
Accepted
Will expand explanation
Some elaboration on the grouping of NFR

categories for each reporting requirement would be
useful here.
Accepted
There is a lot of emission data for turboprops also.

Data for the most commonly engine fitted to
specific aircraft
Accepted
Table 2.1, this table needs update as it is ten years

old, and new aircraft must be included
Accepted
Military is reporting under a different NFR, while it's
Accepted
methodology is described here
This paragraph was not included in the outline
agreed in Dessau. Furthermore if it is to be
included it must be updated with new numbers
from more recent references. Same with table 2.3
and 2.4. (the same comment applies to other
chapters including a similar paragraph)
updated aviation emission

factors have been
discussed with MW
(Expert Panel member)
and incorporated as
appropriate
updated aviation emission
factors have been
discussed with MW
(Expert Panel member)
and incorporated as
appropriate
has been emphasised
J Goodwin consulted with

Consult with expert panel member
Expert Panel (MW)
Table 2.2: There is more recent legislation for NOx.

Please refer to the
Accepted
What Directive do you refer to?
Accepted
updated the aviation

emission regulations have
been included.
Table 2.2. Isn't there more up to date information

available?
updated the aviation

emission regulations have
been included.
Accepted
These tables 2-3 and 2-4, sould be completed with

tables relating to internationals emissions. Note :
international LTO emissions are part of national
NECD emissions, and important issues of
emission trends for aviation concern international
J Goodwin consulted with
aviation. For international aviation emissions, e.g. Consult with expert panel member
international/domestic ratios could be displayed.
Expert Panel (MW)
The Decision tree needs improving. Surely the first
2 diamond shaped white boxes are needed to use Consult with
a tier 3 method.
Expert Panel
The decision tree is more less impossible to
understand. Please use the old decision tree as a
basis for the Tier explanations.
Consult with
Expert Panel
Table 3-1 is a complete mess, and is basically

wrong!
Consult with
Expert Panel has been modified
Footnoe 5, must be changed, it is copied from

IPCC (2006) and does not make sense in this
context
Please state where military aviation emissions
should be reported.
Accepted
will reword
Noted
will reword
What do you mean by "not reported here". Military

aviation is a part of NFR 1A5b along with other
military mobile activities.
Noted
will reword
This text is incomprehensible. Further, it is not in

line with the emission reporting Guidelines (for
example multilateral operations are NOT excluded
from emission totals under LRTAP)
Noted
Text taken verbatim from

IPCC 2006, need to
consult with expert panel
This methodological description is not improving

the old "simple method" described in section 4-2 of
B851-13. It is assuming that inventory compiliers
know how to estimate emissions wothout
describing the process.
Noted
This is not possible to understand!
Noted
Some duplication of information with section 3.2.3
Activity data.
Noted
has been modified

has been modified
has been modified
Can the default emission factors (table3-3 for

domestic LTO) also be used non-IFR fligths
domestic LTO? It is not specified whether the
defaults are for IFR/VFR. We have an amount of
LTO for VFR flights (small aircrafts like PA28,C152,
) and not the amount of flight hours for VFR, and Consult with
wonder if we can use table 3-3, 3-8 and 3-9 for it. Expert Panel
In table 3-3 (Tier 1 Default Fuel use in LTO),
second NFR source (domestic LTO) has as fuel :
jet kerosine. Is the value also valid for jet gasoline
& aviation gasoline fuel use? Or must there a value
be added for further use with tables 3-8 and 3-9? Noted
has been modified
Is there no reference to these fuel consumption

EFs in Table 3-3. Also what is meant by kg/tonne
fuel in NFR 1.a.3.a.i(ii). Should it not be kg/LTO?
has been modified
Noted
Information on HM/POPs are missing. Please cite

the origin (source) of emission factors from the
EMEP-C, emission factors must be tracable
(comment applies to many chapters). Furthermore
Tier 1 emission factors must be updated, a lot has
been changed since these Tier 1 emission factors
were derived
Noted
EFs have been included

where available
I'm not sure that a reference to an EF should be

"Calc from Tier 2" in Tables 3-8 and 3-9. This could
be described better.
Noted
Aviation gasoline is added substantial amounts of
lead, please provide information
Noted
has been modified

EFs have been included
where available
Data available and necessary to apply Tier 2

method sould be specified. 'The algorithms
paragraph 3.3.1 is not detailed enough. Some
components of such step by step algorithms is
has been modified in
given but in EF paragraph 3.3.2. A global overview Consult with consultation with expert
of the algoritms is missing.
Expert Panel panel member MW
The Tier 2 method should promote using fuel sold
statistics : separately domestic and international
fuel sold when available. If these separate fuel sold
statistics are not available, then estimation method
could be used to split domestic and international
Consult with consultation with expert
fuel consumption, as presented in step 1.
It is strange to recommand to use Tier 3 EF within
a Tier 2 method. Furthermore, in case of using Tier
2 method, data on cruise distances per aircrafft
type are generally not available for using Tier 3 EF Consult with consultation with expert
(distance dependant).
consultation with expert
panel member MW
The link of theses lines with paragraph 3.3.3

Activity data is not clear.
Noted
Can emissions factors for airplane types that are

disappeared referred to older versions of the
guidebook still be used from older versions (for
example Concorde in 1996 guidelines)?
EFs used have been

Consult with discussed with expert
Expert Panel panel member, MW
Where does the data in this table originate from?
Noted
has been modified
The Tier 2 method is completely wrong! This

method cannot use mission distance based factors Consult with consultation with expert
for cruise - this relates to Tier 3!
Please provide some method description for Tier 2. Noted

panel member MW
In the last part of the box, reference to the EFDB is

made, however there is no EFDB for air pollutants! Noted

panel member MW
Footnote 8, this assumption should be reviewed

due to more recent knowledge

panel member MW
Noted
Table 3-11: It is not acceptable to use the emission

factors for LTO provided by the IPCC 2006
guidelines
table 3-11: Footnote (3) does not appear below;
there (2) apperas twice. - Please change the 2nd
(2) into (3).
Please check if this table has been updated with
more recent aircraft and make corrections as
appropriate
Editorial

panel member MW
Accepted

panel member MW
This paragraph should be more detailed, especially

the link with the steps displayed in 3.3.2.
Noted

panel member MW
Why is military described here in section 3.3.5? In

with the Tier 2 method? There is no mention of
military under the Tier 3 method.
Table 3.14. Source?
Noted
Noted
will clarify
will reference
What is the minimum flown distance for an

airplane to reach cruise level? Table 3-15 starts at
125 nm. It means dat below 125 nm, an airplane is
not cruising yet (in normal average conditions)?
Noted
These data are taken

verbatim from earlier
versions of the guidebook
- refer to expert panel
In general the method choice and description

should preceed the EF tables. Section 3.4.2 on
Tier 3 EFs is on page 25 whilst section 3.4.3.1 on
Tier 3A method is on page 29. This makes the
chapter very difficult to read.
Have re-organised EF
tables
Noted
Please explain where the remainer Tier 3 emission

factors can be found (currently they are available
as a spreadhseet download)
Noted
There are no cruise emission factors published on

the ICAO website.
Noted
The sentence is diffucult to understand.
Noted
Where is the table 3.10 ?
Noted
This is not possible to follow, what has it to do with

engine independent emission factors? And where
is Appendix 1?
Noted
It is both turbo fan and turbo prop engines.
Noted
will continue to be
These data are taken
verbatim from earlier
versions of the guidebook
- refer to expert panel
will clarify
Have asked author of
previous guidebook
should be aircraft type Appendix 1 is unaltered
should be altered
For non-IFR flights, we still use emission factors

from EPA, AP-42 volume II (1985). Can they still be
used? Why are they not included as reference
default emission factors (instead of calculating
nothing) ?
These method descriptions in sections 3.4.3.1 to
3.4.3.3 should be on page 24 before the EF tables. Noted

panel member MW
The note provides considerations on energy

balance for domestic aviation. Similar
considerations on energy balance for international
aviation sould be also included (taking into account
that in case of international aviation, half of
international fuel consumption should be
compared to fuel sold in the country for
international flights).
Accepted

panel member MW
These are very old data, please update

panel member MW
Accepted
This section 4.4 has nothing to do with consistent

time series and recalculation! It is simply copy and
paste from the old chapter section 3.6
"Projections": Even the title has been changed to
fit the misplaced content.
Accepted

panel member MW
This information (including the tables) appears

outdatet. What is for example "current level" in
Table 4-1? Please update or rewrite
has been discussed with

expert panel member MW
Accepted
It is indeed suprising that there is no specific issue

here given the complexity of reporting this category
(e.g. differences betwee UNFCCC, LRTAP and
NEC reporting), memo items etc. (same remark to
navigation/shipping chapter)
Accepted
Will include Description
What other sources? It is essential to explain

where the data comes from
Not changed - taken

verbatim from previous
version of the guidbook.
Refer to expert panel
Noted
What is the difference between Annex B and Table

3-11? Are both needed?
Noted
has been discussed with

expert panel member MW
A large number of references in this chapter are

not found in the reference list. (including IPCC
(2006) which the method is based on!)
Noted
will clarify
Accepted

panel member MW
Accepted

panel member MW
Even more important, a lot of references and

explanations how data are obtained, are missing.
Accepted

panel member MW
All military mobile activities (aviation, land based

and sailing activities) are classified as 1A5b
(equivalent to SNAP code 0801) according to
EMEP.

Please also include Tier 2 cruise emission factors

(else the method will not work)
Please refer also to general comments
summarised in the separate word file "DK Review
of guidebook chapters for mobile sources.doc"

data are available from the current guidebook, both Consult with consultation with expert
for LTO and cruise distance classes
ICAO website.

in the Tables 3-4 and 3-5 is preferable.

Please use the simple method description directly

from the old guidebook.

These LTO factors are not supported by new

cruise emf related to distances, as in the current
guidebook version.

Moreover, looking into the IPCC guidelines the

LTO factors are very poorly documented.

If we use the IPCC data, we loose the consistency

with cruise factors per distance class, and for
species like NOx, NMVOC and CO
cruise factors heavily depend on the actual
aircraft/engine combination. In some countries,
detailed city-pair inventories

are made each year using distances between

airports, and for these countries such new data
gives less meaning.

So, the strong recommendation is to maintain the

"old" LTO (and cruise) emf in order not to introduce Consult with consultation with expert
errors into the inventories.
The data come from specific simulations made by
aircraft emission experts.

and the approach used to obtain the data that is

presented in the guidebook.

The schematic diagram (Figure 4.1) in the chapter

B851 in the Guidebook should be retained in the
new chapter.
Title of chapter should include a reference to
buses, ie HDVs and buses instead of "heavy-duty
trucks".
What is the difference between 'Overview' and
'General description'?
These paragraphs are rather badly written, and
could be improved.
Badly written.
Poorly phrased.
Badly written, and difficult to follow.
Accepted
Noted
Corrected
General Description is part
of the Overview.
Noted
Noted
Corrected
Corrected
Noted
Noted
Rejected because this

phrase was taken verbatim
from existing guidebook,
see B710-1 in pdf version
Changed
What is section 4? The sentence gives no meaning Noted
Sorted
CO is not an Ozone Precursor
The EEA include CO in

their definition of Ozone
Precursor
http://glossary.eea.europa.
eu/EEAGlossary/O/ozone_
precursor
Rejected
Delete 'mobile'. Change 'transportation' to

'transport' (throughout).Change 'vehicles' to
'vehicle'.
Why 'on-road'? The whole chapter refers to road
vehicles.
Emissions from exhaust aftertreatment? This is
nonsense.
Change to 'The most important pollutants from

road vehicles are covered'.
Accepted
Corrected
Noted
Corrected
Noted
Corrected

Consult with from existing guidebook,
Expert Panel see B710-1 in pdf version
The section 2.1 title is not helpful.

What is meant by 'positively ignite'?
Noted
Noted
The existing guidebook

says it is the 5th update,
see B710-2 in pdf version.
These lines merely reflect
these words - no change
made.
Corrected
Corrected
Will clarify & align with
transport terminology
Corrected
Which process? One of the combustion

processes? Figure 2-1 does not show combustion
processes.
Noted
Corrected
Figure 2-1 is poor. What purpose does it serve?

Figure 2-1 gives no information.
This reference is wrong.
Rejected
Noted
Editorial
used to conceptualise the

boundaries of road
transport emissions, and is
an approach adopted
throughout the Guidebook.
Corrected
Sorted
It is written that for Tier 1 uses fuel as activity

indicator with average fuel specific emission
factors. But then in the table 3-2-3.9Ef are g/GJ
Where is Table 2-1?
Where is the Tables 4-7 to 4-29?
Accepted
Editorial
Editorial
Sorted
Sorted
Sorted
What is the relationship to COPERT? If it has been

updated five times why are we now at COPERT 4? Noted
Where is this reference?
Noted
Should read 'three-tier'.
Noted
Figure 3-1 should read "Decision tree for road

transport" not "aviation". I also wonder about the
diamond "Is this a key source?". Road transport is
always a key-source. There should be added the
following statement in p.6 where the figure is
introduced: "Road transport is a key-source in all
countries. Therefore, the Tier 1 method should only
be used in the absence of any more detailed
information than fuel statistics. In parallel, in such a
case, the country needs to make every effort to
collect the detailed statistics required to use a
higher Tier method, preferrably Tier 3."
Editorial
Corrected
Eq. 1 needs to change to read Ei,j,k where k will

refer to fuel (gas, diesel, LPG, NG). Therefore, FCj
should change to FCj,k and Efi,j should change to
Efi,j,k.
Editorial
Corrected
the formula (1) multiply EF [g/kgfuel] for FC (fuel

consumption [kg fuel but in the table the emission
factor for Tier 1 approach are expressed in terms
of g/GJ. There should be one common standard
and I suggest that kg of fuel makes more sense
The emission factors are wrong, due to errors in
the calculations.
units for Cd and Pb in table 3-2 are missing.
Accepted
Sorted
Accepted
Accepted
Sorted
Corrected
Tables 3.2 to 3.9 present emission factors in g/GJ.

First, the methodology in p.7 is in g/kg. Second,
the values are wrong (they should be ~5 times
higher). I understand the editors try to be
consistent with IPCC. On the other hand, Eurostat
data report all values in tonnes that can be readily
converted to kg, without knowing the energy
content of fuel. In addition, methodologies Tier 2
and Tier 3 calculate total fuel consumption in kg so
why having Tier 1 in GJ? Third, emission values in
g/kg fuel are widespread and are published in
scientific literature so the reader can compare
them to the Guidebook values. All models (Copert,
Artemis, even Verit+ in the Netherlands) use fuel
mass values. Heavy metals and sulfur are all
reported per mass of fuel. The user of any
methodology needs now to convert them to GJ! I
know of no source that reports emission in g/GJ
except for GHGs. But even in the 2006 IPCC
Guidelines, N2O and CH4 emission factors for US
and Europe are in mg/km. In summary, I find the
expression g/GJ awkward and not practical and I
strongly reccomend this to be changed back to
Consult with
g/kg fuel.
Expert Panel
Sorted - after discussions

with Expert Panel we have
reverted back to
expressing emission
factors in units of g/tonne
fuel
Tables 3.2 to 3.9 also include emissions of SOx

and heavy metals and make reference to Tables 4XXX. First, as the draft chapter stands now, these
tables are A.XXX and not 4.XXX, but please also
check my comment below related to the structure
of the chapter. Second, why should we provide a
default SOx emission factor (equivalent to 40 ppm
S in fuel) when S content of fuel is known in each
country? None of the countries (except Bulgaria)
that are going to use a Tier 1 methodology have
average sulfur of 40 ppm!!!! I reccomend we
introduce the very simple methodology (two rows)
given in section A.6.9 as part of Tier 1 as well. This
is all it takes to have the correct estimation of SOx. Accepted
Referencing to tables will

be corrected. Also
comment will be
addressed to include a
flexible S content variable
with a default if none is
known.
Tables 3-2 to 3-9 include Default EFs Tier1. The

unit used is g/GJ, instead og g/kg of fuel used. It
may be worth including both EFs by GY and kg in
the final guidebook and a description of the
calculation from one to the other.. Also I think the
reference AUT 2008 needs to be clarified (exactly
a reference to which report?)
unit for Cd in table 3-6 are missing.
unit for Cd in table 3-7 are missing.
Sorted - after discussions

with Expert Panel we have
reverted back to
expressing emission
Consult with factors in units of g/tonne
Expert Panel fuel
Accepted
Sorted
Accepted
Sorted
Accepted
Sorted

table 3-9: unit for Cd and Pb missing
All these Tables 3-11 to 3-38 contain EFs for Tier 2.
What is the reference for these EFs?
Where is Table 4-6?
Accepted
Accepted
Sorted
Sorted
Editorial
Editorial
Corrected
Sorted
Tier 2 method gives EFs by technology, however

these technologies are not provided until the
Appendix to this FOD.
Accepted
Sorted
Tables 3-11 to 3.38 contain the statement "grams

of international toxic equivalent" for DIOX and no
values. There are such values in Table A.101.
Accepted
Corrected
For heavy duty trucks, so many size classe and

technology combinations are missing in terms of
Tier 2 emission factors.
Changed - comment
added regarding what to
Consult with use for "missing" size/
Expert Panel technology combinations.
Table 3-39 is a good summary. I do not understand

why this is only specific to FC and what are the
uses it intents to cover.
Noted
Corrected It's use has

been clarified in the text.
"By applying a trial-and-error-approach..." This

sentence is meaningless!
where is section 4.3.3?
There is no discussion in section 4.3.3!
Accepted
Editorial
Editorial

Sorted
Sorted
It is a very wrong decision to let Tier 3 be

described in an Annex. Tier 3 is what many
countries use now.
Accepted
Sorted
It is very important that this Tier 3 method has a

proper description and overview in the actual
chapter as does the Tier 1 & 2 methods. This
method is the most used method by inventory
compiliers and should not be discussed in an
Appendix.
Accepted
Sorted
The text in Section 4.4 has nothing to do with

consistent time series and recalculation! It is just
copy and paste of Section 13 "Temporal
disaggregation criteria" from the old chapter.
Accepted
Heading changed to reflect

text provided - now no
section on "developing a
consistent time series" Need to decide on the
extent of text neded on
this
The problem of "tank tourism" it is not mentioned.

If it is relevant, fuel balance, as explained here,
could not be applied.
Accepted
Will be refered to..
Accepted

Accepted
Where available data will

be included. These data
were taken verbatim from
Table 10-3 of previous
guidebook. Analogous
data for other pollutants
was not provided.
Accepted
Editorial
Editorial
COPERT 4 is a software
tool outside the scope of
this Guidebook revision.
This question will be
forwarded to the team at
Artistotle University.
Sorted
Sorted
CO is not an Ozone Precursor
Rejected
The EEA include CO in

their definition of Ozone
Precursor
http://glossary.eea.europa.
eu/EEAGlossary/O/ozone_
precursor
Section A.2 is not part of the Tier 3 methodology

and it is ok to remain as an Annex. However, in
other chapters (e.g. non-exhaust PM emissions,
evaporation) the sections referring to the
contribution of the sector to total emissions are
provided as introductory sections before
presenting the Tier 1 methodology. So, please be
consistent between chapters, where you want this
section to be presented (annex or introduction).
Accepted
Sorted
Section A.3 should be part of Tier 1 methodology

because it just provides definitions of the vehicle
classes considered. Section A.4 should be part of
Tier 2 methodology because Tier 2 already uses
the emission standards classification.
Accepted
Sorted
Accepted
Rejected for this version

because this phrase was
taken verbatim from
existing guidebook comment will be passed to
AUT.
References are not old?
This kind of table could be very useful. Why don't

put information on the other pollutants?
Will be the emission factors for buses CNG

included into the COPERT IV?
Reference to Table 4-1 is wrong.
There is no Table 2-1 in the chapter
Metodology does not estimate in which category

should be included tracotrs with registration
number (vehicles). These can not drive on
motorway.
Table A.7 now offers no new information and

needs to be erased.
Accepted
Indeed the current section A.6 should follow as the
next section, after A.1
Accepted
Check format of Figure A.2. The text on the leftmost boxes should be vertical and not horizontal.
Editorial
Rejected because the

guidance we have
received is that the
existing detailed
methodology text should
not be changed much at
all.
See above
Sorted
The sentence is not coherent with the table A.53.

The sentence must be "However, some additional
reductions need to be applied for vehicle
technologies post-Euro 4 (RFij), which are given in
Table A. 53"
Editorial

taken verbatim from
AUT.
In the equation (27) replace eHOT;i,Euro1 by

eHOT;i,Euro4 to be coherent with table A.53 and
Rfij factors
Editorial

taken verbatim from
AUT.
The "ehot;i,Euro 1" value in eq. 27 should be

replaced with "ehot;i,Euro 4". the "ecold/ehot|i,Euro
1" value should remain intact.
Editorial

taken verbatim from
AUT.
It is not possible to distinguish between mopeds 2

and 4 strokes?

taken verbatim from
existing guidebook Consult with comment will be passed to
Expert Panel AUT.

taken verbatim from
table A.77, A.78, A.79, A.80 e A.81 it is not possible
existing guidebook to define the emission factors in term of emission Consult with comment will be passed to
legislation?
Expert Panel AUT.
Noted
Comments have been

considered.
Up to Euro IV: The vehicle categories 7,5-12 & 1420 & 26-32 tons are missing.
Noted
See also comment 284 Changed - comment

use for "missing" size/
technology combinations.
For newer technologies: The vehicle categories

7,5-20 & 26-32 tons are missing.
See also comment 284 Changed - comment

use for "missing" size/
technology combinations.
Noted
In general the Annex, who is supposed to treat Tier

3, also repeats the data used for the old simple
method.
Noted
The old chapter discusses how to treat emission

inventories in relation to dispersion models.
Heading changed to reflect

text provided - now no
section on "developing a
consistent time series" Need to decide on the
Consult with extent of text neded on
Expert Panel this
THE TIER 3 METHODOLOGY MUST NOT BE

INTRODUCED AS AN ANNEX BUT AS SECTION
3.4, AS ORIGINALLY FORESEEN. NOW THE
WHOLE CHAPTER IS A MESS! ALL SECTIONS
IN CHAPTER 4 DISCUSS ISSUES OF TIER 3
METHODOLOGY (THEY ARE A COPY OF THE
PREVIOUS VERSION OF THE GUIDEBOOK)
AND TIER 3 IS ONLY INTRODUCED IN THE
ANNEX. MOST REFERENCES REFER TO THE
TIER 3 METHOD AND THE TIER 3 IS
INTRODUCED AFTER THE REFERENCES AS AN
ANNEX! IT IS POINTLESS TO MAKE A DETAILED
REVIEW AS THE CHAPTER IS SO BADLY
WRITTEN AND STRUCTURED THAT IS MAKES
NO SENSE.
Accepted
The chapter makes a lot of references to sections
and tables 4.x. These do not exist because Tier 3
has been annexed. These need not be changed
when the editors correct the chapter per my
reccomendation above. However, there are many
erronous references to tables and figures as the
draft version stands now.
In all Tier tables for the road transport not
applicable would be POPsAnnex I
Sorted
Sorted
Accepted
Sorted
Consult with
Expert Panel
The general description and overview could

perhaps include tables 1.1 and 1.2 from the
Guidebook B710-3.
Accepted
Sorted
There is no reference to classification of vehicles

such as in the Guidebook table 3.1 B710-7 and
Table 3.6 B710-16. All of this information is
relevant regardless of which Tier approach is used
by inventory compiliers and should be included in
the chapter overview or description.
Accepted
Accepted - cross reference

included
General comment. This chapter needs major

restructuring. All vehicle classifications, legislation
(as described in B710-13 to B710-16) should be
included in the text of the chapter before
discussion of the different Tier method (1,2 and 3).
Improvements are also needed in referencing EF
tables and if changes are made to EF units these
should be explained clearly. Also there is no bulk
CS EFs based on the 2002 work which could be
useful for a Tier 1 method. There is no discussion
of the contribution road transport makes to total
national emissions.
Accepted
Sorted
Subsections 6.1 and 6.2 should occur in the same

order as the title of Section 6. In addition, the level
3 sections in the report are missing from the table
of contents.
Editorial
Sorted
This paragraph could read a little better.
Revised
noted
This paragraph is poorly constructed and not well

phrased. How do breathing losses relate to diurnal
emissions, hot soak losses and running losses?
Do we need to use both 'losses' and 'emissions'?
Just use 'emissions'.
Accepted
Not changed because this

was taken verbatim from
previous Guidebook
version B760(2007)
Section 3.1. Will pass
comment on to Expert
Panel
The last sentence of the para ought to be the first.

Again. How do 'breathing losses' relate to the
sources mentioned. My understanding is that this
is a part of the process which leads to diurnal
emissions.
Accepted

previous Guidebook
version B760(2007)
Panel
Explain what carbon canisters are.

previous Guidebook
version B760(2007) page
1. Will pass comment on
to Expert Panel
Accepted
Process description' is not a good title in my view.

It is too vague. I also think that it more or less
repeats title 2, and would therefore delete it.
Could be made more

transport specific.
However, might detract
Consult with from a common guidebook
Expert Panel style.
Figure 2-1 is poor. It could show the different

evaporative sources much more clearly (i.e. picture
of vehicle, with diurnal losses, hot soak losses and
running losses explained).
Accepted
Revised
Maybe worth adding that some studies have

identified 'resting emissions' as a separate
evaporative source. These result from diffusion,
permeation, seepage and minor liquid leaks, and
do not need an increase in fuel temperature to
occur. Here, I assume that these are already
included in the hot-soak and diurnal calculations?
Accepted

previous Guidebook
version B760(2007)
Section 3.1.3. Will pass
Panel
Poorly written. Should begin 'Diurnal losses are'.

Can I offer something like this >> The increase in
ambient temperature which occurs during the
daylight hours results in the thermal expansion of
the fuel and vapour in the petrol tank. Without an
evaporation control system, some of the increased
volume of fuel vapour is vented to the atmosphere.
At night, when the temperature drops, the vapour
contracts and fresh air is drawn into the petrol tank
through the vent. This lowers the concentration of
hydrocarbons in the vapour space above the liquid
petrol, which subsequently leads to additional
evaporation. The overall mechanism is also known
as tank breathing.
Accepted

previous Guidebook
version B760(2007)
Panel
Again, the wording could be better. Aren't running

losses are defined as something like 'the
evaporative emissions which occur whilst a vehicle
is being driven'? There is always vapour in the fuel
tank. Are we talking about additional vapour?
Surely there is an increase in the fuel temperature
for all vehicle types (e.g. heat from engine and
exhaust)?
Editorial

previous Guidebook
version B760(2007)
Panel
Does this para refer to vehicle refuelling, fuel

delivery, or both. It shoul dbe clearer. Here, it says
'petrol stations'. I'm not sure whether 'gasoline
stations' even exists in US English.
Accepted

previous Guidebook
version B760(2007)
Panel
Editorial

previous Guidebook
version B760(2007) text in
section 2.2.1. Will pass
Panel
Editorial

previous Guidebook
section 3.3. Will pass
Panel
In general, would prefer the UK English 'petrol' to

the US English 'gasoline'. Please use the term 'fuel
tank' instead of 'gasoline tank'.
Editorial

previous Guidebook
version B760(2007). Will
pass comment on to
Expert Panel
Change to 'Hot-soak emissions occur when '.

'Hot-soak' should be hyphenated when used
immediately before 'emissions'.
Editorial

previous Guidebook
version B760(2007)
Panel
What is the meaning of the Section 2.3 title. It is

very vague.

was the heading used in
the Guidebook version
B760(2007) Heading 3.2.
Consult with Will pass comment on to
Expert Panel Expert Panel
In the line 4 we can read: "Without an emission

control system, some of the increasing volume of
fuel vapor is vented to atmosphere"
Change to 'at the same level. However, the test

procedure for evaporative emissions increased in
severity'.
The first sentence is unclear. What does it mean?

The distinction between VOCs and NMVOCs also
needs to be better explained.
CH2.1 is not a unit. Tank breathing again.
Accepted

previous Guidebook
Panel
Editorial

previous Guidebook
Panel

was the heading used in
the Guidebook version
B760(2007) Heading 3.3.
Again, the Section heading (2.4) needs to be more Consult with Will pass comment on to
informative.
Accepted

previous Guidebook
Panel
Table 2-1: In Spain, the percentage contribution of

the evaporative emissions to the total emissions
from road transport in year 2006 was not 9%, it
was 32.7%
Accepted

previous Guidebook
version B760(2007) Table
2-1. Will pass comment
on to Expert Panel
Explain what TREMOVE is.
Accepted

previous Guidebook
version B760(2007) text
iimmediately above Table
2-1. Will pass comment
on to Expert Panel
Some explanation of this Table would be useful.

For example, why are evaporative emissions
proportionally higher in colder countries than in
hotter countries?
Accepted

previous Guidebook
version B760(2007) page
1. Will pass comment on
to Expert Panel
This is very poor. It does not even relate to road

transport. The terms below the equation do not
match those in the equation, and no units are
given.
Accepted
Sorted
What a mess!: This is not the Tier 1 approach for

evaporation. You use words like "small combustion
installations" and "lime production".
Accepted
Sorted
In the decision tree from figure 3.1 the text in the

first and second rhomboidal boxes is the same
Accepted
Corrected
Accepted
Sorted
Accepted
Sorted
Explain 'SHED'.
What is the sense in this chapter of "The Tier 1

approach for process emissions from small
combustion installations ...!
We can read: ARproduction = the activity rate for
the lime production!
We think it should say "fuel consumption" not "fuel

sales"; "fuel sales" could be a good proxy for "fuel
consumption" but It is not the same
Accepted
The activity rate for lime production
Accepted
Tiers classification. Comments are summarized in
separate Word document
Noted
Decision tree. This is rather poor. The first two
'decisions' contain the same question. In the third
'decision', how is a 'key source' defined? If evap. Is
identified as a key source then data collection is
recommended. However, the user is then directed
to Tier 2. Why not Tier 3, as the requirements for
Tier 3 appear to be fulfilled?. The Figure title
appears twice.
Accepted
The decision tree is wrong: If the answer is "No"
right after start, then you are lead to the same
question one more time.
Section 3.2.1 is copied from lime production and
does not refer to evaporation
Figure 3-1 has two identical diamonds for Tier 3
and Tier 2
Sorted
Sorted
Sorted
Decision tree revised

markedly to reflect the
different tiers, and activity
data, required for each
Accepted
Sorted
Accepted
Sorted
Accepted
Corrected
Noted
Sorted
I would imagine that data on fuel sales and data on

vehicle licensing statistics are kept by different
organisations.
Noted
Whay 'default'. Can these be changed by the
user?
Noted
Sorted
It is questionable if the data in Tables 3-1 to 3-5

are sound. It is recommended to let the original
data suppliers make such aggregated figures.
Sorted
The Tier 1 method proposes evaporation factors in

the form g/kg fuel consumed. This was never
agreed in the Transport Panel so it has to be
discussed. The Tier 1 method proposed by the
transport panel only required the total number of
cars and trucks operating on gasoline, a
temperature range relevant for the country
concerned and the DVPE value of the fuel. All this
is information that exists in each country. The
problem now with Tier 1 is that there is no
temperature effect and, therefore, evaporation
emissions in Ukraine will be equal to emissions in
Algeria! Whatever the method we agree, a
temperature correction needs to be introduced for
the emission factor. Ambient temperature is not
Consult with
difficult to find in any country!
Expert Panel Sorted
The Tier 2 method proposes evaporation factors in

the form g/kg fuel consumed. This was never
discussed in the Transport Panel. The editors
should have at least consulted with the transport
panel if they wanted to change something from
what was agreed. In fact the Tier 2 method
proposed is totally anachronistic and is clearly a
scientific degradation of the Guidebook. The
simple methodology that was proposed in the
previous Guidebook is still the original method
developed by the CORINAIR 1985 working group
and most member states work with it. I strongly
reccomend that the simple method of the previous Consult with
guidebook is used as a Tier 2.
Expert Panel Sorted
Tables 3-2 to 3-5. Explain 'DVPE'. The names of
chemicals do not take capital letters. Should be
'polycyclic aromatic hydrocarbons'. Some of cell
contents are cut off
Accepted
Amended
The use of the words 'hot', 'warm' and ;cold' in the

terms of the equations is confusing. These need to
be explained.
Accepted

previous Guidebook
version B760(2007)
Simpler methodology. Will
pass comment on to
Expert Panel
I would imagine that data on fuel sales and data on

vehicle licensing statistics are kept by different
organisations.
Accepted
Sorted
I assume that what we want to calculate is the total

national emission. For this, you need to sum over
all vehicle categories (Nj). This needs to be
incorporated into the equation.
Accepted

previous Guidebook
version B760(2007)
Equation 1. Will pass
Panel
For consistency with HS and R, why are diurnal

emissions not referred to as 'D'?

previous Guidebook
version B760(2007)
Panel
Rejected
It is not entirely clear what a vehicle catgory ('j')

actually is. Is it a Euro standard? My first thought
was that it related to the descriptions in Tables 3-6
and 3-7, but the problem would then be not having
the activity data for these categories. Maybe this is
why you include Table 3-11, but I don't think that it
is stated explicity. The links between Tables 3-6/3-7
and 3-11 should be stated explicitly.
Accepted

previous Guidebook
version B760(2007)
pass comment on to
Expert Panel
The Tier 3 method proposed is a collation of the

simple and detailed methodology of the 'old'
Guidebook with a mix-up of the emission factors.
As it stands now, the whole chapter is a mess and
it is impossible to review point by point. Simply put,
the Tier 3 text provided makes no sense.
Accepted
Sorted
Cold and warm soak/running emissions. According

to Equations (2) and (3), these only appear to
apply to vehicles with a carburettor. These are
likely to be pre-Euro 1 and uncontrolled (i.e. no
canister). So why are there lots of emission factors
for controlled vehicles in Table 3-6? This shoul dbe Consult with
explained.
Expert Panel

previous Guidebook
version B760(2007)
pass comment on to
Expert Panel
Petrol cars are separated according to whether

they have fuel injection or a carburettor, and hence
the parameter 'c' (the fraction of vehicles eqipped
with a carburettor) needs to be defined. I assume
that this is just for pre-Euro 1 vehicles (and
possibly Euro 1). Bearing in mind the requirement
to combine Tables 3-6 and 3-11, statistics on the
fractions by Euro standard should be given to
users.
Accepted

previous Guidebook
version B760(2007)
pass comment on to
Expert Panel
Is the vaopur pressure required? It appears that it

isnt used.

previous Guidebook
version B760(2007)
Consult with pass comment on to
The reference to the Table which contains parking

duration distributions (and the Table itself) appears
too early in the Chapter. At this point it is not clear
to the reader what this means and why it is
required.
Accepted
Reordered and clarified
We don't understand the matrix presented in the

table 3-10. From this data, if we compute, for
example, the probabilty of the event of not to be
parked some time between 1am and 2am hours
we obtain 0.9072, this means that the 90% of
vehicles are on road at 2am! Without doubt, this is
not representative of the Spanish pattern. So,
either the numbers from the matrix are wrong, or
there is another type of error about the meaning of
the matrix as it is explained in the guidebook text. Accepted
Comment noted - the data

and explanations provided
are taken verbatim from
Table 6-3 of the previous
Guidebook version
B760(2007). Will pass
Panel
Are these values for a particular country?
Not know - the data are

taken verbatim from Table
6-3 of the previous
Guidebook version
Panel
Noted
Explain 'cats'. Again, at this point it is not clear why

fuel tank volume would be required.
Accepted
Comment noted - the data

and explanations provided
are taken verbatim from
Table 6-3 of the previous
Guidebook version
Panel
At this point I am completely lost. This looks like

the start of a more complex 'Tier 4' approach. An
explanation of this structure is required. Are
sections 3.4.5 to 3.4.12 adjustments to the
emissions which have already been calculated to
this point? Furthermore, much of the text in these
sections repeats the earlier text.
Accepted
Sorted
Accepted
Rearranged, but not

changed because this was
taken verbatim from
previous Guidebook
version B760(2007)
Detailed methodology.
Will pass comment on to
Expert Panel
Accepted

previous Guidebook
version B760(2007)
Expert Panel
How are the temperatures calculated in Section

3.4.5 used?
Table 3-12. Surely the values in the first column

should start at 01:00 and end at 24:00 (or 00:00)?
Need to explain that there are 24 intervals in each
row because 0.5 hour steps are used over a 12hour period.
How is Section 3.4.6 used? Explain.

From personal communication from Giorgos
Mellios (COPERT team) it appears that the
numbers in formulae for parameters a and b are
incorrect and they should be replaced by the
following figures: a = -11 -0.015*vp +0.065*T;
b=0.115-0.00015*vp +0.0001*T; please check it
with Giorgos Mellios
How is Section 3.4.7 used? Explain.
How is Section 3.4.8 used? What is 'permeation

and leakage'? Is this a new source? Explain.
Accepted
Rearranged, but not

taken verbatim from
previous Guidebook
version B760(2007)
Expert Panel
Accepted
NOTED - not changed in

this revision because this
previous Guidebook
version B760(2007)
Expert Panel
Accepted
Rearranged, but not

taken verbatim from
previous Guidebook
version B760(2007)
Expert Panel
Accepted
Rearranged, but not

taken verbatim from
previous Guidebook
version B760(2007)
Expert Panel
The formula in this line has not mathematical

meaning, it is not a mathematical formula. The
sum over the continuous variable T has not
meaning. What is that you want to say?: sum of
the formula over the different hours (H1 to H2)
considering constant the temperature of each hour,
or integral of the formula from T1 to T2? The two
things are the same only if the temperature data
are discrete (temperature averaged for each hour),
but if we apply a continuous function to the
maximum and minimum daily temperatures to
approximate the hourly variation, the two things are
distinct
Accepted

previous Guidebook
version B760(2007)
Expert Panel
Delete this Section.
Accepted
Not deleted, because this

previous Guidebook
version B760(2007)
Detailed methodology,
Panel
Change to 'Light fuel components tend to be more

volatile than heavy ones'.
Editorial

previous Guidebook
version B760(2007)
Section 9, pB760-15. Will
pass comment on to
Expert Panel
There is no section 3.3.3.
Accepted
Sorted
Accepted
No change made - these

were the headings
provided in the template
from TNO. Consult with
TNO/Expert panel
regarding their retention
Some of the topics in Chapter 4 (e.g. gridding,

reporting) do not appear to be data quality issues.
Does this comment apply to all Sections 4.1 to 4.3,

or just 4.3? If not, something should be written for
Sections 4.1 and 4.2
Accepted
I believe it does, hence

phrase added
Section 4.5, which Tier does it refer to?
Noted
Not sure - taken verbatim

from Table 10-1 of
previous Guidebook
version B760(2007). Need
to refer question to
authors/ Expert Panel
The reference for COPERT 4 is incorrect.
Accepted
Taken verbatim from

Section14 of previous
Guidebook version
B760(2007). Need to refer
comment to authors/
Expert Panel

The Tier 3 method is now a mix of the simple and
detailed method from the old chapter?
noted
noted
Sorted
This is a very serious mistake by the consultants to

develop such a new method, without discussing
with the data suppliers.
noted
Sorted
Why do we need to have 3 Tier methodologies? Is

it mandatory to have 3 Tiers in the Guidebook?
Tier 1 now makes no sense! Again this was never
agreed with the Transport panel. Moreover, the
methodlogies are again a mess:Why is Table 3-3
part of the Tier 1 since there is no vehicle
distinction to Tier 1? Tier 2 has a correction for
speed but the emission factors are independent of
speed!
Noted
Sorted
Acording the formulae specified in the document

for vehicles without control systems it seems the
right could be replace "some" by "all"
Noted
Sorted
noted
Sorted
We have computed the probabilty as follows: the

probability of to be parked between H-1 to H hours
is the sum from t2=H to t2=H+11 of sum of
f(t2,tpark) from tpark=2(t2-H)+1 to t2=24 , being
understood that: H+x = (H+x) mod 24 and f(t2,
tpark) is the element of matrix at row t2, column
tpark.
There appears to be a problem with the NFR code
for these sources. Part A of Sector 1 is
'Combustion'. Tyre wear, brake wear and road
surface wear are not combustion processes.
Noted
This is an inherent
problem with the
nomenclature for this subsector.
Some references are needed in this paragraph.
References included
Accepted
Figure 2-1 is poor and is not helpful. Could be

much more graphic. Why 'flow diagram'?
Rejected
'This sector'. Which sector? The three sources, the
two NFR codes? Abrasion?
Noted
used to conceptualise the

boundaries of road
transport emissions, and is
an approach adopted
throughout the Guidebook.
Altered
Change 'proportion' to 'contribution'.
Editorial
Process description' is not a good title in my view.

It is too vague. I also think that it repeats title 2,
and would therefore delete it.
Could be made more

transport specific.
Expert Panel style.
Disc brakes are increasingly used in heavy-duty

vehicles.
Noted
Altered

previous Guidebook
version B770(2003)
Panel
Section 2.2 title could be more helpful. What

exactly does it refer to?
What is the meaning of the Section 2.3 title. It is
very vague.
Could be made more

transport specific.
Expert Panel style.
A discussion on emission
Rejected
sources.
It is not possible making an update of the emission

estimate?
Noted
Not with the same level of

completeness. When
reporting improves there
will be.
Are there any more recent data?
Noted
Not with the same level of

completeness. When
reporting improves there
will be.
Accepted

previous Guidebook
version B770(2003)
Panel
Rejected
Numbers are suitable for

indicative purposes. Also
not changed in this
revision because this was
taken verbatim from
previous Guidebook
version B770(2003)
Section 2. Will pass
Panel
A discussion of the Tables would be useful.
Some of these data should be updated.
Surely Tier 2 or Tier 3?

Accepted
Tiers classification. Comments are summarized in
separate Word document
Noted
The decision tree only explains PM10. But
convention needs are TSP and PM2.5 also.
Accepted
The Tier 1 algorithm resolution is per vehicle
classe. But the Tier 1 factors are averaged for all
vehicles.
Figure 3-1. PM10 is not a 'species' it is a prticle
size metric.
Figure 3-1. Where does Tier 3 fit in?
Altered
Sorted
Altered
Consult with
Expert Panel Sorted
Accepted
Altered
Accepted
Sorted
The sum over all vehicle categories should be

formally introduced into the equation.
Accepted

previous Guidebook
version B770(2003)
Panel
Tables 3-1 to 3-3, is averages only. It is considered

a wrong decision not to give data per vehicle
classe. Also, TSP and PM2.5 emission factors are Consult with
needed.
Expert Panel Sorted
Tables 3-1 and 3-2. The units are clearer as g km1 vehicle-1. Subscripts required for PM10 and
PM2.5.
Accepted
Altered
Tables 3-1 and 3-2. The names of chemicals do

not take capital letters. Should be 'polycyclic
aromatic hydrocarbons'. Some of cell contents are
cut off
Accepted
Altered
Reference codes to be updated.
Accepted
will be updated
Metrics other than PM10 are included.

This method seems unnecessarily crude. Where
do these percentages come from?
Accepted
Altered
Accepted
Altered
The Tier 2 algorithm claims speed dependency.

However, no speed dependency is given in the
Table 3-4 to 3-15 emission factors.
Table 3-3. Font too large in Table. What are the
units?
Again, summation over all vehicle categories

required.
Consult with
Expert Panel Sorted
Noted
Table superceded by
changed Tables 3-1 and 32
previous Guidebook
version B770(2003)
Panel
Where are the values for fs,i and Ss(V)?

Where is the speed dependency? Emission factor
tables for TSP and PM2.5 are missing.
Is the detailed methodology Tier 2? This is not
clear.
Accepted
Consult with
Expert Panel Sorted
Consult with
Expert Panel Sorted
Consult with
Expert Panel Altered
This is all badly explained. What is this section

(3.3.2) about? Where is the speed dependence?
Check that the Table titles match the contents.
Consult with
Expert Panel Sorted
Metrics other than TSP are included. This is all

badly explained. What is this section (3.3.2)
about?
Accepted
Sorted
Metrics other than TSP are included.
Accepted
Sorted
In Tier 3 (Table 3-16), the particulate fractions for

other sizes than PM10 are listed for tyre wear. But
these fractions should be available from the
beginning to support also Tier 1 and 2 calculations. Accepted
Sorted
In Tier 3 (Table 3-17), the particulate fractions for

other sizes than PM10 are listed for brake wear.
But these fractions should be available from the
beginning to support also Tier 1 and 2 calculations. Accepted
Sorted
The Tier 3 methodology for road surface wear is
Consult with
missing.
Expert Panel Sorted
This could be more helpful. Why is this the case?
Explain choice of PAHs. Which protocol?
Noted
Sorted
Accepted

previous Guidebook
version B770(2003)
Panel
Should be Table 3-19. Not all the substances listed

are elements - some of them are ions.
Accepted
Sorted regarding table

referenced - Phrase
"Different elements" not
taken verbatim from
previous Guidebook
version B770(2003)
Panel
Table 3-19 needs to be improved. As stated above,

some of the 'elements' are actually ions. The
nomenclature is not consistent (eg. Mg2+ but
SO4--. Subscripts and superscripts are required for
the ions. The term 'elemental speciation' is used
incorrectly. The word 'brake' is spelt incorrectly.
What is the meaning of blank cells?
Accepted

table is taken verbatim
from Table 13 of the
previous Guidebook
pass comment on to
Expert Panel
The text in Section 4.4 has nothing to do with

consistent time series and recalculation! It is more
or less the same text as Section 13 "Temporal
disaggregation criteria" from the old chapter.
Accepted
Title changed
Why is there no text under 4.1 and 4.2?
Accepted
Headings deleted
Are the EFs really for asphalt? This is rather

specific.
noted

is taken verbatim from
Section 11 of the previous
Guidebook version
Panel
What is 'method 3'?
Editorial
Sorted
See
http://www.ssb.no/emner/01/04/10/rapp_emissions
/rapp_200738_en/rapp_200738_en.pdf, page 4144
Noted
Expert panel to be made

aware of these data.
It is a mistake to make such averages, since the

number of vehicles per classe is known from the
road transport exhaust inventory.
Consult with
Expert Panel Sorted
In Tier 3, the expressions for heavy duty load and

axles (tyre wear), heavy duty load (brake wear),
and speed (all vehicle classes) are present.
However, the speed corrections was to be used in
Tier 2.
Consult with
Expert Panel Sorted
Consult with
Expert Panel Sorted
The old chapter briefly discusses how to treat

emission inventories in relation to dispersion
models.
Information from old

Consult with chapter is included, hence
Expert Panel nothing has been lost.
Why have HM and POPs not been included?

is taken verbatim from the
previous Guidebook
pass comment on to
Expert Panel
noted
Emissions other then PM See

http://www.ssb.no/emner/01/04/10/rapp_emissions
/rapp_200738_en/rapp_200738_en.pdf, page 3941
Accepted
What Directive do you refer to?
This is just messy key words, not fit for a
documentation report

is taken verbatim from the
previous Guidebook
pass comment on to
Expert Panel
Accepted
Accepted
relevant information will be

included where
appropriate and time
permits.
Done
Accepted
Done
What is the source of the EFs in tables 3-1, 3-2

and 3-3 in this FOD? Also, how is Tier 1 EFs
approx 20 times greater than Tier 2 EFs?
Accepted
Done
There must be errors somewhere in the emission

factor tables; It is not possible with such
differences between Tier 1 and Tier 2!
What is the reference for SO2?
Accepted
Accepted
Done
Done
Refers reader to RT chapter, but then on following

page, refers reader to the off-road section - which
is correct or are both relevant?
Noted
Done
What is "H"?
Table shows Efs in g/GJ of fuel - where do hours
come into this??
PM0.95??
Noted
Done
Noted
Editorial
Done
Done
factor 'H' in equation is not specified

same data in tables 3-2 and 3-3 whereas table for
line haul locomotives is missing
Noted
Done
Accepted
Done
Table 3-2 and Table 3-3 are the same except for
the technology name! They are titled Tier 2 and the
next line says Tier 1!
Accepted
General comment - where are the Efs for line haul
locomotives?
Accepted
A table for line haul locomotives is missing
Accepted
Done
Done
Done
"(e.g., EX-TREMIS (Chiffi, Fiorello, Schrooten, De

Vlieger (2008); RAILI"
Noted
Done
"(e.g., EX-TREMIS (Chiffi, Fiorello, Schrooten, De

Vlieger (2008); RAILI"
Noted
Done
The EX-TREMIS railways inventory contains time

series 1980-2005 and projections (up to 2030) for
locomotives and railcars specific activity data
(passenger/freight train km and gross hauled tonne
km) as well as for energy consumption and
emission factors. Please, send us a request to
have a view on the preliminary data (a password is
needed) - the project will be concluded by the 30 of
April 2008
Noted
Done
Please quote the EX-TREMIS project, founded by

the JRJ-IPTS of Seville and carried aout by TRT
and VITO, and provide the weblink to users in the
same page http://www.ex-tremis.eu/ - EX-TREMIS
combines statistics from different sources and
calculate emission factors for specific engine types
for each of the 27 EU countries (excluding Malta
and Cyprus that have no railways)
Noted
Done
The EX-TREMIS railways inventory contains time

series 1980-2005 and projections (up to 2030) for
locomotives and railcars specific activity data
(passenger/freight train km and gross hauled tonne
km) as well as for energy consumption and
emission factors.
Noted
Done
Please quote the EX-TREMIS project, founded by

the JRJ-IPTS of Seville and carried aout by TRT
and VITO, and provide the weblink to users in tha
same page http://www.ex-tremis.eu/ - EX-TREMIS
combines statistics from different sources and
calculate emission factors for specific engine types
for each of the 27 EU countries (excluding Malta
and Cyprus that have no railways)
Noted
Done
The emission factors are still missing.

What units are the emissions shown in, in the
USEPA table?
Noted
Done
Noted
Done
Paragraph not clear. For example, "bio-diesel can

be used in all diesel engines with slight or no
modification" - is this true for 100% biodiesel? Are
trains currently running on B2 - B5?
Accepted
please refer to "gross hauled tonne kilometre
(GhTK)"
Accepted
please add "EX-TREMIS 2008"
Accepted
according to Regulation 91/2003, from the
beginning of 2003 all railway undertakings (not
only the "principal") shall report their traffic data to
Eurostat. Moreover, train movements (national,
international and transit train km) are reported
considering only the distance covered on the
national territory of the reporting country. By using
operating data, double counting problem may be
avoided. In EX-TREMIS some technical notes to
data sources will be made available to
compilers/users.
please refer to "gross hauled tonne kilometre
(GhTK)"
please add "EX-TREMIS 2008"
Done
Done
Done
Noted
Done
Accepted
Accepted
Done
Done
according to Regulation 91/2003, from the

beginning of 2003 all railway undertakings (not
only the "principal") shall report their traffic data to
Eurostat. Moreover, train movements (national,
international and transit train km) are reported
considering only the distance covered on the
national territory of the reporting country. By using
operating data, double counting problem may be
avoided.
This is just copy and paste from the IPCC 2006
guidelines.
emisison factors for additives??
The number of the chapter is missing
Noted
Done
Accepted
Noted
Accepted
Done
Done
Done
Please add the reference "EX-TREMIS project Railways Inventory. For information see the
website http://www.ex-tremis.eu/ and Final Report:
Chiffi, Fiorello, Schrooten, De Vlieger, EX-TREMIS,
Exploring non-road Transport Emissions in Europe,
JRC-IPTS (2008)"
Accepted
Done
Please add the reference "EX-TREMIS project Railways Inventory. For information see the
website http://www.ex-tremis.eu/ and Final Report:
Chiffi, Fiorello, Schrooten, De Vlieger, EX-TREMIS,
Exploring non-road Transport Emissions in Europe,
JRC-IPTS (2008)"
Accepted
Done
General comment - chapter refers to diesel and

sometimes to gas oil - use one or the other
perhaps as otherwise confusing
Accepted
Done
Accepted
Done
Noted
done

Table 2.1, please harmonise with IPCC 2006
Guidelines
the distinction beteween domestic (coastal) and

international shipping in terms of "activity" is not so
difficoult to extrapolate. Activity data in EU are
collected and provided to Eurostat by all member
states according to the Maritime Statistics Directive
(Council Directive 96/64/EC). In the Eurostat
Newcronos Maritime Database it is possible to find
quarterly statistics both for passengers and goods
(collections mar_pa_qm_detl and
mar_go_qm_detl) spiltted by direction (inw, outw),
partner entity and type of cargo. These collecions
refers fo main ports only (but 90% of the total
traffic). It is possible to consider the total traffic
(mar_pa_aa and mag_go_aa) of passenger and
goods of all ports by direction and use it for adding
the missing quota to detailed collections.
References and methodologies for doing it are in
EX-TREMIS (2008).
Noted
Done
the distinction beteween domestic (coastal) and

international shipping in terms of "activity" is not so
difficoult to extrapolate. Activity data in EU are
collected and provided to Eurostat by all member
states according to the Maritime Statistics Directive
(Council Directive 96/64/EC). In the Eurostat
Newcronos maritime database it is possible to find
quarterly statistics both for passengers and goods
(collections mar_pa_qm_detl and
mar_go_qm_detl) spiltted by direction (inw, outw),
partner entity and type of cargo. These collecions
refers fo main ports only (but 80/90% of the total
traffic). It is possible to consider the total traffic
(mar_pa_aa and mag_go_aa) of passenger and
goods of all ports by direction and use it for adding
the missing quota to detailed collections.
References and methodologies for doing it are in
EX-TREMIS (2008).
Noted
Done
Please delete, this is not possible to understand/is Consult with I disagree with the
incorrect/refers to Member States (not Parties)
Expert Panel comment
Also the EX-TREMIS methodology gives an
allocation of emissions according to the type of
traffic
Also the EX-TREMIS methodology gives an
allocation of emissions according to the type of
traffic
Footnote: I can't find the reference for the Entec
reports anywhere in the chapter.
Consult with
Expert Panel Can't access website
Consult with
Noted
Done
Please remove or update (this was not in the

original outline agreed by TFEIP/is outdated)
Consult with
Expert Panel please update
What does the terms in bracket [ ] mean? Has this

text been updated in accordance with latest IMO
regulations?
Noted
Table 3.1 and 3.2, please provide original
references for emission factors (not EMEP-C)
(same with the subsequent tables)
Accepted
Eurostat collection of vessel traffic (quarterly data,

main ports, number and gross tonnage of vessels,
by type and size of vessels and inwards direction mar_tf_qm) provides country statistics for 7 groups
of ship types and 22 GT size classes. References
are in EX-TREMIS (2008). Please, quote the
website. In case, request us a tecnical note on this
issue
Noted
Eurostat collection of vessel traffic (quarterly data,
main ports, number and gross tonnage of vessels,
by type and size of vessels and inwards direction mar_tf_qm) provides country statistics for 7 groups
of ship types and 22 GT size classes. References
are in EX-TREMIS (2008). Please, quote the
website.
Noted
Not only NOx emissions are engine specific, but
also PM emissions (see EMS protocols).
Noted
Not only NOx emissions are engine specific, but
also PM emissions (see EMS protocols).
Noted
Done
Done
done
Done
Done
fuel instead of mass:

The calculation formula gives no meaning. Instead Consult with which unit of measure? Mj
of M(fuel sold, engine type) it should
Expert Panel or tonnes?
EX-TREMIS provides a similar tables or additional
parameters in the website (i.e. differentiated
conversion factors or weighted EF)
Noted
Can't access website
EX-TREMIS provides a similar tables or additional

parameters in the website (i.e. differentiated
conversion factors or weighted EF)
Noted
Can't access website
Activity data has to be segmented per activity type

(different EF for hotelling, manoeuvring and
cruising in TIER2).
Noted
Done
Activity data has to be segmented per activity type

(different EF for hotelling, manoeuvring and
cruising in TIER2).
Noted
Done
What is the origin of this table?
Noted
Guidebook 2006
Table 3-27: Source?
Noted
Guidebook 2006
Table 3-27: Source?
Noted
Guidebook 2006
Where does the data in Table 3-27 come from?
Noted
Guidebook 2006
Entec 2002? I can't find this reference in the

chapter
Noted
Done
All table references are wrong
Noted
Done
Where does the data in Table 3-29 come from?

Noted
Table 3-29: Please include the units in the table
Noted
text
Why is the TIER3 methodology not very well suited
to show annual trends in emissions?
Noted
Done
The EF - only cruise based now - should be a

weighted average EF of cruising, manoeuvring and
hotelling.
Noted
Why is the TIER3 methodology not very well suited
Noted
to show annual trends in emissions?
The EF - only cruise based now - should be a
weighted average EF of cruising, manoeuvring and
hotelling.
Noted
Please check the table references
also on the EX-TREMIS website
Done
Done
Done
Done
Done
Noted
Done
Consult with
we may add such tables on EX-TREMIS. Do you

think this may solve problems to compilers or help Consult with
them?
Consult with
also on the EX-TREMIS website
we may add such tables on EX-TREMIS. Do you
think this may solve many problems to compilers?
Consult with
I think we should have to quote the relevant

facilities provided by the Eurostat Newcronos
database. See the comment 11. We have
assembled some technical notes for working with
Eurostat data and produce/derive ship movements.
Please, request us these notes if you think that a
paragraph should be added here.
Noted
Done
I think we should have to quote the relevant

facilities provided by the Eurostat Newcronos
database. See the comment 11. We have
assembled some technical notes for working with
Eurostat data and produce/derive ship movements.
Plese, request us these notes if you think that a
paragraph should be added here.
Noted
Done
The most comprehensive and detailed source of

information for Ferry, Ro-Ro, HS craft and cruise
ships is the ShipPax database (please visit
www.shippax.se for more infos and in particular the
webpage http://www.shippax.se/page/page.asp?
id=14). I think that the "Thomas Cook" source is
not a good reference.
Accepted
done
The most comprehensive and detailed source of

information for Ferry, Ro-Ro, HS craft and cruise
ships is the ShipPax database (please visit
www.shippax.se for more infos and in particular
http://www.shippax.se/page/page.asp?id=14). I
think that the "Thomas Cook" source is not a
good reference.
Accepted
done
This par seems to have been copied from the 2006

GLs; it mentioned the 2006 GLs and makes
reference to multilateral operations, this is not in
line with the LRTAP reporting Guidelines. Please
revise
Accepted
Done
We have built a distance table (mainly for

international traffic) from/to each maritime coastal
areas (MCAs) of EU countries to/from EU MCAs,
all Mediterranean and Baltic third countries and to
13 overseas areas, namely Black Sea, Arabian
Gulf, Red Sea, Indian Sub Continent, Australasia,
Far East - China & Japan, South & East Africa,
West Africa, US Atlantic & Canada - Great Lakes,
Central America Caribbean, South America
Atlantic, US & Canada Pacific, South America Pacific. Do you think this table proveded on the
webste could help compilers? The table refers to
one sole reference port per country
Consult with
Expert Panel
This section 4.4 has nothing to do with consistent

time series and recalculation! It is simply copy and
paste from the old chapter section 3.5
"Projections".
Accepted
done
EX-TREMIS performed an analysis on historical

data (1980-2005) and gives on a country basis
activity data (tonne-miles and ship-miles
movements by type of ship/engine and by OD),
emission factors and total emissions. The EF are
differentiated according to the characteristics of the
visiting fleet calling at seaports of each country.
Please, inform us and request our interim report or Consult with
the outline of the final report of EX-TREMIS.
Expert Panel Consider for Tier 3
EX-TREMIS performed an analysis on historical

data (1980-2005) and gives on a country basis
activity data (tonne-miles and ship-miles
movements by type of ship/engine and by OD),
emission factors and total emissions. The EF are
differentiated according to the characteristics of the
visiting fleet calling at seaports of each country.
Please, inform us and request our interim report or Consult with
the outline of the final report of EX-TREMIS.
Replace the column Consumption at full power

(tonne/day) as a function of gross tonnage (GT)
with the following values: C = 12,0724+0,0012*
GT -1,1501E-8*GT2+4,6484E-14*GT3
C = 7,2194+0,0015*GT-9,1885E-9*GT2+2,6803E14*GT3
C = -2,2602+0,0049*GT-1,6401E-7*GT2+1,7394E12*GT3
C = 0,0919+0,0038*GT-6,1565E-8*GT2+6,7917E13*GT3
C = 6,3501+0,0013*GT+1,6852E-7*GT2-6,2691E12*GT3+ 5,699E-17*GT4
C = 5,2159+0,0034*GT-3,373E-8*GT2+2,062E13*GT3
C = -9,735+0,0486*GT-4,6603E-6*GT2+1,3911E10*GT3
C = -2,2602+0,0049*GT-1,6401E-7*GT2+1,7394E12*GT3
C = .42682 + .00100*GT
C = 1,0857+0,0259*GT-1,0279E-5*GT2+1,6828E9*GT3
C = 1,2744+0,0062*GT-6,4603E-7*GT2+5,5193E11*GT3
C = 1,2744+0,0062*GT-6,4603E-7*GT2+5,5193E11*GT3
C = 8,2909+0,0018*GT-4,4908E-8*GT2+4,8931E14*GT3
Consult with
SEE ANNEX PAPER FOR DETAILS
Add the reference: "Trozzi C., Vaccaro R. (2006),
Methodologies for estimating air pollutant
emissions from ships: a 2006 update, Environment
& Transport, 2th International Scientific
Symposium
(including 15th conference Transport and Air
Pollution), Reims, France : 12-14 June 2006
Accepted
Done
Please insert the EX-TREMIS reference or

website: EX-TREMIS project - Maritme Inventory for information see the website http://www.extremis.eu/ and Final Report: Chiffi, Fiorello,
Schrooten, De Vlieger, EX-TREMIS, Exploring
non-road Transport Emissions in Europe, JRCIPTS (2008).
Accepted
Done
Please insert the EX-TREMIS reference or

website: EX-TREMIS project - Maritme Inventory for information see the website http://www.extremis.eu/ and Final Report: Chiffi, Fiorello,
non-road Transport Emissions in Europe, JRCIPTS (2008).
Accepted
Done
It's impossible to verify Efs without clear reference

about source of data. No correspondence between
Table and references!
Accepted
TIER1&2 are bunker fuel based methodologies,

TIER3 is an activity based methodology. For
instance for Belgium, there is a difference of a
factor 35 between a bunker fuel and an activity
based methodology (Inventory and forecasting of
maritime emissions in the Belgian sea territory, an
activity-based emission model, Atmospheric
Environment, Volume 42, Issue 4, February 2008,
Pages 667-676, Liesbeth Schrooten, Ina De
Vlieger, Luc Int Panis, Karel Styns and Rudi Torfs).
It is possible to make a TIER1&2 activity based
methodology (transforming EUROSTAT statistics
into activities) on findings in Ex-TREMIS - EXTREMIS project - Maritme Inventory - for
information see the website http://www.extremis.eu/ and Final Report: Chiffi, Fiorello,
non-road Transport Emissions in Europe, JRCConsult with
IPTS (2008).
The emission factors used are aggregated

emission factors from ENTEC. The TIER3
methodology can be made even more
desaggregated by using even more desaggregated
emission factors from EMS (AVV, TNO-MEP, RIZA,
MARIN, CE-Delft, Haskoning, Emissieregistratie en
Monitoring Scheepvaart, DGG, November 2003).
The ENTEC emission factors are predefined for
MCR 85% and 20%, as for EMS you can use your
country specific MCR and create your own country
specific emission factor. A comparison of both
sources would be usefull. The EMS protocols are
in Dutch, but you can find relevant documentation
in English in the MOPSEA report
(http://www.belspo.be/belspo/home/publ/pub_ostc/
EV/rappEV43_en.pdf) and the Ex-TREMIS project Consult with
(see comment above for link).
TIER1&2 are bunker fuel based methodologies,

TIER3 is an activity based methodology. For
instance for Belgium, there is a difference of a
factor 35 between a bunker fuel and an activity
based methodology (Inventory and forecasting of
maritime emissions in the Belgian sea territory, an
activity-based emission model, Atmospheric
Environment, Volume 42, Issue 4, February 2008,
Pages 667-676, Liesbeth Schrooten, Ina De
Vlieger, Luc Int Panis, Karel Styns and Rudi Torfs).
It is possible to make a TIER1&2 activity based
methodology (transforming EUROSTAT statistics
into activities) on findings in Ex-TREMIS - EXTREMIS project - Maritme Inventory - for
information see the website http://www.extremis.eu/ and Final Report: Chiffi, Fiorello,
non-road Transport Emissions in Europe, JRCConsult with
IPTS (2008).
The emission factors used are aggregated

emission factors from ENTEC. The TIER3
methodology can be made even more
desaggregated by using even more desaggregated
emission factors from EMS (AVV, TNO-MEP, RIZA,
MARIN, CE-Delft, Haskoning, Emissieregistratie en
Monitoring Scheepvaart, DGG, November 2003).
The ENTEC emission factors are predefined for
MCR 85% and 20%, as for EMS you can use your
country specific MCR and create your own country
specific emission factor. A comparison of both
sources would be usefull. The EMS protocols are
in Dutch, but you can find relevant documentation
in English in the MOPSEA report
(http://www.belspo.be/belspo/home/publ/pub_ostc/
EV/rappEV43_en.pdf) and the Ex-TREMIS project Consult with
(see comment above for link).
Noted
It is very confusing to read this chapter. Practically

all the references to tables in the text
Accepted
are wrong, and some tables are even missing. Also
references are given to an important sources of
information (Entec study)
Accepted
which we can't find in the list of reference. And
even more important, the chapter
Noted
doesn't print the crusial information from Entec.
Inventory makers are asked to look them up
themselves.
Because so much remains to be done in this
chapter, the reviewers are wasting a lot of time.
be M(fuel sold, fuel type, engine type), in order to
have the same resolution as for EF.
When this basis is correct, you can make
summations afterwards.
Done
Done
Done
Done
Accepted
Done
Noted
Done
Noted
Done
Noted
Done
then we are not able to make the calculations!
Noted
Done
I suggest to include a description of typical

devices, e.g.: modified RollsRoyce airplane
turbines with cap. of about 30 MW , fed by natural
gas. Someone even have low-Nox technologies.
Accepted
There is no reference either in the Tier 1 or 2

tables for the NFR 1A5a.It would be correct, if EF
for this NFR not available (or the same asfor other
NFR in this chapter), it would be specified in the
text.
Will amend tables (
In table 1-1 (and furtheron) the term 'nonresidential heating' is introduced. This term is
highly confusing, and requires change. Please
avoid (throughout the text) as much as possible
this kind of negative definition. Here use
"commercial/institutional heating" instead. Also the
term "other" should be avoided and may only be
used when explicitely defined as NFR term.
Accepted
Text modified
Fishing is not covered in the small combustion

chapter and should therefore be removed from the
list of activities covered. Again there is no mention
of HCB in table 1-1.
Noted
HCB included
Subdividing this sector needs to be done in a

consistent manner, in order not to confuse a
reader. The list as presented now is an ambiguous
mixture of NFR attributions (but note my comment
[1] above) and techniques (CHP)
Accepted
The only pathway of interest (emissions from
combustion) is not described in Fig. 2-1
Noted
Text modified to align

technologies more with
NFR
None
In consequence to comment [2], subsections within

the section 2.2 should be consistent to the subdivision first introduced in Page 3/line 10-12.
Furthermore, levels of sub-types are not clear or
consistent (example below, comment [6]). Finally,
techniques and sub-types need to match emission
factors presented. I.e., differentiating between
'open fireplaces' and 'partly closed fireplaces' is
only useful when also emission factors are being
presented (This example being chosen here for
simplicity, but the point is applicable throughout). A
national expert should be able to find the type of
installation operative in his/her country according
to the description in the list of techniques, and then
look up an appropriate emission factor. Ideally, for
each type of appliance an own set of emission
factors is presented by fuel. Of course this will not
always be possible - but in the current text there is
almost no such connection.
Noted
Text modified to align more

closely with NFR, tier 1
factors are on fuel basis so
no technology relevance;
Tier 2 has more
disaggregation but not a
full split as this would be
unmanageable but there
are more appliancespecific details in Appendix
Strong chapter on techniques (Chapter 2.2). One

would wish that all chapters were on this high level.
However the subchapter on CHP should be
expanded.
Noted
None
figure 2-1: wrong title (contribution from

railways)
explain 'autonomy' - or use different term
Rejected
Accepted
Comment for wrong

chapter - have taken into
account in 1A3
Modified
Stove types can not be differentiated by the

description presented. This is widely the case for
the whole list of stove types. Criteria used to form
subcategories are very ambiguous (from fuel type 'pellet' to appication 'cooking' and further to
abatement 'catalytic')
Accepted
Finish stove' and 'Russian stove' may not be

expressions that are very helpful to describe stove
types outside particular countries which apply
these terms. It is o.k. to use those as a support,
but one should not expect this is sufficient
explanation
Accepted
Text modified to address
Authors may wish to refer to the fact that - while

there exist stoves predominantly constructed for
specific fuels - there are also multi-fuel stoves.
These stoves are popular in some countries as
they are able to burn waste - a considerable
emission problem
Accepted
Text included
A very simple statement would help an expert to

understand which type his installation belongs to:
"Boilers are devices which heat water"
Accepted
Done
Automatic feeder systems are also available for

wood logs. The advantage of automatic systems is
that they minimize handling errors
(primary/secondary air, constant combustion
temeratures, )
Accepted
Text modified
Condensing boilers may achieve efficiencies even

above 100% - this is basically their feat. For an
expert using this guidebook, one could make it
esier to identify such an installation: "condensing
boilers require a chimney resistant to the liquid
condensate".
Accepted but detail not

needed here.
Noted
When the potential for large dioxin emission is

mentioned it would only be natural to also address
the possible formation of other POPs notably HCB. Noted
Text modified
Primary measures can be presented in a more

systematic way: modifed fuels / modified heater /
modified combuation
Text order modified
Accepted
Figure 3-1 does not contain any information

specific for small combustion - why is it here then? Rejected
It is a generic decision tree

but the elements are
relevant to small
combustion plant
I strongly disagree: if we limit a country's

contribution to Tier 1 already at this stage, we
should forget about the whole effort. Applying
default emission factors to IEA (and similar)
statistics can be done much more reliably in a
centralized manner, and in fact has been done
already (see GAINS model)
Accepted
Text modified slightly but

Tier 2/1 may be the most
appropriate with (unlike
some other sectors) Tier 3
only being achievable
using the model or hybrid
approach .
In row 11 - AR fuel consumption, but in the row 14 AR production -activity rate for the lime production Accepted
Done
It would be better if these tables 3-1 to 3-12

refering to Tier 1 were listed in order from 1a4a,
1a4b and 1a4c etc. Also what size boilers to these
EFs relate to 20-50 MW or <20 MW?
Noted
See comment [1] above: avoid 'other', instead use
'medium/light liquid fuels'
Rejected
Based on NAPFUE fuel

classifications
Here and elsewhere: If the range presented for

emission factors extends over two orders of
magnitude, reporting has very little meaning
Noted
The selected fuel groupings for residential and

non-residential combustion seems less than ideal.
Biomass should be divided into wood and straw.
Noted
At Tier 1 we have brought

together by main fuel
classifications
Common comment for Tier 1 and Tier 2 tables:

emission factors are shown with reference to
Guidebook 2006. But most of emission factors do
not coincide with the factors in the Guidebook
2006. Especially large differences are for SOx, CO,
NMVOC, PCDD/F, PAH. No emission factors for
indicator PAH while Guidebook 2006 includes
them.
Accepted

be clearer
It would be possible to include corresponding

SNAP codes in the allTier 1 and 2 tables
Table format is fixed to

reflect NFR but SNAP also
provided
Noted
In table 3-2 (and all other Tier 1-2 tables) the total
PAH emission factor is resulted, but according to
requirements of reporting Guideline it is necessary
to report separately on four substances
Accepted
Tables revised
In the table 3-2 (and all other Tier 1-2 tables) from
row "Not estimate" would be deleted "POPs" and
into row "Not applicable" include Annex I POPs (by
each substance).
Noted
Tables revised
Table 3-5: error in Pb and Hg emission factor (in

column Value are shown as 0, but in column Lower
not 0).
Accepted
Rounding/significant figure
issue
Several values listed as "0" in table 3-5 and 3-6.

Lack of HCB emission factor as well as detailed
PAH emission factors are a problem.

tables
Accepted
In the table 3-5, row fuel name - "Other Liquid

Fuels". It is not clear - other, excepting residual
fuel oil, or "other oil" (according to fuel defini
Accepted
Include summary table of

fuel classes
Table 3-6: error in Pb emission factor (in column

Value are shown as 0, but in column Lower not
0).

tables
The dioxin emission seems to refer to the emission

factor for advanced fireplaces in the existing
guidebook. A general tier 1 emission factor should
probably be somewhat higher.
Noted

tables
In table 3-6, upper estimate for Se is below the

recommended value; in tab. 3-7, several metals
exhibit an upper estimate of '0'

tables
In table 3-5 the fuel name is "Heavy Fuel Oil".

According to fuel definition in the new reporting
guideline it must be "Residual Fuel Oil"In other
combustion chapters the same.
Noted
Text modified
It seems odd that all particles from biomass

combustion in the non-residential sector is
assumed to be PM2.5.
Noted

tables
Again Tier 2, Tanles 3-14 to 3-26 seem to start with

residential (1a4a) and then move onto Other
sectors (1a4a and 1a4c). Also there is no
information about thermal size of combustion plant
here.
Noted
Table 3-13 amended

slightly, note that NFR has
no size distinction
in table 3-13 and subsequent tables: provide

emission factors to instllations as they have been
described in section 2.2 - see comment [4]
Addressed where possible.
Noted
solid' fuel is first mentioned here - put this way it

would comprise also biomass; use 'coal' (as in the
previous part of this chapter) or 'solid fossil fuels'
Accepted
Text amended to include

1A1a fuel types
In the table substitute "Solid fuel" with "Coal fuel"
Noted
See earlier note on fuel

classification - don't want
to preclude coke and other
solid fuels
Accepted

tables
The tables contain a very large number of

emission factors quoted as Guidebook (2006) but
with different values. It's impossible to present
similar tables ! Some examples are reported in
EF_comments.
CONCLUSION: ALL THE TABLES MUST BE
REVISED
Noted
The existing guidebook list a dioxin emission factor

of 800 ng/GJ for standard fireplaces and 300 for
advanced fireplaces. Therefore the emission factor
of 350 ng/GJ with reference to the existing
guidebook seems wrong.
Noted
In table 3-16 the EF for CO is 0.01 g/GJ? Surely

this is a mistake. In the next table 3-17 CO has an
EF of 1000g/GJ, or 100,000 greater.
Accepted
Tables 3-17, 3-18, 3-20: heavy metals emission
factors should be rounded.

tables
tables
Table 3-20: errors in EF for PM2.5 (in column

Value are shown as 0, but in column Lower not
0).

tables
The dual reference system is confusing. Either the

reference is the exisisting guidebook or it is
CITEPA. Several of the listed emission factors
does not correspond to the values in the existing
guidebooks values for stoves liquid fuels.
Noted

tables
Table 3-23: errors in EF for PM10 and PM2.5 (in

column Value are shown as 0, but in column Lower
not 0); EF for TSP should be checked.

tables
Most values in table 3-22 refers to the existing

guidebook, however several of the listed emission
factors do not correspond to the emission factors
provided for wood burning boilers in the existing
guidebook.
Noted
Table 3-26: value EF and 95% confidence interval

are the same for TSP, As, Cd, Cr, Hg, Pb.

tables
tables
CO seems to be to high for a diesel engine (liquid

fired) in table 3-26. In the tables 3-24 and 3-25
turbines running on gas and oil are included. In
these two table als gas engines should be
introduced so that the NOx values are comparable
between different prime mover technologies.
See also:
tationary_engines/Future_stationary_engine_emiss
ion_legislation_Nov04.pdf
tationary_engines/EIPPCB_BREF_euromot_comm
ent_may_02.pdf
Noted
Why is there no default emission factors given for
natural gas fired reciprocating engines. It would
seem that a large part of the fuel use for sttionary
engines would be natural gas.
Accepted
Table included
Suggest to do it the other way round - data

reported to the UNFCCC will have no focus on
wood consumption and thus will likely provide
unreliable numbers. Instead: Results on wood
consumption provided here should be made use of
for the UNFCCC submission also.
Accepted
The Tier 3 method needs more elaboration. Should
inventory compiliers use the technology based EFs
in Appendix A or not? These EFs tables should not
be placed in an Appendix if they are part of the Tier
3 methodology.
Noted
removed.
Accepted
Some sources listed as references in the chapter
are missing from the list of references, e.g.
CITEPA 2007, Gustavsson et al. 1993, CEPMEIP
2004, DTI 2005, Guidebook 2006.
Text deleted
The choice of
methodology is up to the
country, the significance of
the source and the
resources available.
Accepted
I suggest to indicate if emissions factors are based

on field measurements (real conditions) or
stationary conditions which e.g. is the case for
(BLT) 1999 to BLT (2005). Additionally It would be
useful to know how many ovens/boilers have been
measured and if the emission factors are
representative for e.g. a specific technology which
is typical for a country or region.
Noted
We have no additional
data - these are as
provided in B216
BLT (2005/2)Hyperlink does not point to a specific

document:
http://www.blt.bmlf.gv.at/menu/index_e.htm.
Editorial
Ref modified
Please correct reference to "sterreichische

Emissionsinventur fr Stau*b*" and
"Umwe*l*tbundesamt"
Editorial
Ref corrected
Appendix B dos not add much additional

information to appendix C of Chapter 1A1 (they are
widely identically). I suggest to just add a table with
typical reference O2 concentrations and the 2
Diagrams and add a reference to chapter 1A1.
Editorial
Reference O2 concentration of wood is often 13%.

I suggest to add a line for this to the diagrams.
Noted
The title of the tables are not visible.
Editorial
The tables are unreadable as they are partly off
the page.
Editorial
Agree but they are

separate chapters, not
sure we can split out the
appendix.
Not changed, there are
many reference O2 levels
eg 7, 10 or 11 national
preferences apply. EN303
(boilers <300kW) is 10%
Done
Done
Emissions that are related to different engine types

are missing e.g. Spark Ignition engine (gas mode).
We recommend to refer on page 102 of the
following document:
http://www.ymparisto.fi/download.asp?
contentid=3708&lan=fi
Furthemore the French limits for Dual Fuel
stationary engines are missing. These should be
added.
Noted
Other details: I reckon a final proofreading will be

performed to take care of a number of editing
issues (incomplete sentences, abbreviations
presented but not explained in Tab 4-4, citations
(CITEPA 2007), and similar)
Noted
Lack of line numbering of the chapter on small

combustion will result in fewer line number
referrals.
Noted
As reference is made to Chapter 1A4, should we

understand that industrial engines are the same
than engines in Commercial, Institutional and
Residential sectors? Does it matter the power of
the engine?
Noted
Final checking needed
Small CHP for public

power uses the same
technology as nonresidential CHP. Gas
turbines can often be
larger than 50 MWth but
engines are generally
smaller (usually a lot
smaller).
Taking into account that raw materials have also

sulphur content, where are the net SOx emissions
estimated for cement and lime production?: either
in 1.A.2.f or in NFR categories 2.A.1 and 2.A.2?
tion in the new reporting guideline)
For instance the emission factors for CO, SO2,
TSP etc.
Not relevant to 1A4

Comment corrupted ?
Don't see where this is
referred to
What are the total net SOx emissions, taking into

account the three components: gross SOx from
fuel, gross SOx from raw materials and SOx
captured by raw materials?
None
This is wrong and confusing. The SNAP group

080100 contains military activities (and different
fuel types), please refer to error 1d.
You must show tables for each NRMM directive
and explain what they contain.
Noted
Done
Accepted
Done
What is the number of this directive?
Noted
Done
Where is there a precise definition of equipment

level and equipment type? This must be
highlighted.
Rejected
Tables for 1A2fii (industry machinery) and 1A4a ii

(Commercial/Institutional: Mobile) emission factors
are missing.
Noted
It is necessary to explain, that only agriculture and
forestry machinery are behind the figures.
Noted
Table 3-3: The categorisation of recreational craft
is wrong. These types of vessels must be included Noted
This sentence gives no meaning. A lot of diesel
fuel is being used by stationary engine, and to
assume all
Noted
The LPG fuel type is also present. In fact, you may
consider to use the term fuel/engine type.
Noted
Please be aware that recreational craft and military
vehicles must be treated differently
Noted
Done
Done
Done
Done
Done
Done
Done
Table 3-13 to 3-16: The figures in this table relates

only to recreational craft. Tables 3-13 (diesel) and
3-15 (4-stroke gasoline) concerns the emission
level prior to the directive 2003/44 emission
standards.
Noted
Done
You have forgotten two tables for 2-stroke gasoline

boats, relating to emission levels before directive
2003/44, and for directive 2003/44 emission levels. Noted
Done
Still missing is three emission factor tables for

diesel fuelled equipment in the NFR sector 1A4aii
Noted
Done
This section is essential for inventory makers in

order to allocate fuel into emission layers, but it
gives no guidance at all.
Noted
Done
Noted
Done
Noted
Done
Noted
Done
Chapter; Non road mobile sources and machinery
Noted
Done

Noted
Done
There are many serious mistakes in this chapter.

Some of them relates to 1) errors in NFR code
categorisation
Noted
Done
A study from 1993 is not recently made. Nothing

has been done to update this part of the text.
Since there is still no updates in this part, I really
have no opinion.
This table is full of errors. Please use the tables
directly from the old guidebook.
and 2) errors in computed emission factors when

transferring from g/tonnes of fuel to g/GJ.
Noted
Done
Error 1a): The data that is stated for 1A5b (Other)

in the new chapter has nothing to do with military
activities!
Noted
Done
These data, submitted by Morten Winther are valid

for boats, and hence represent recreational craft.
The SNAP code for recreational craft is 0803,
Noted
Done
which is specificly mentioned in the old guidebook.

Following the CLRTAP transfer procedure between
SNAP and NFR codes,
Noted
recreational craft are further classified as part of
Noted
Navigation 1A3d (agreed by all member states).
If we want recreational craft to be included in this
chapter, it is necessary to include the code 1A3d ii
(National Navigation) in the table on Page 1.
Noted
Done
Done
Done
Error 1b) In the EMEP Draft 2007 guidelines for

estimating and reporting guidelines the NFR
category 1A4a ii (Commercial/Institutional: Mobile)
now appears.
Noted
This category must be included in the table on
Page 1.
Noted
Done
Error 1c): The category 1A4c iii

(Agriculture/Forestry/Fishing: National Fishing is
treated in the Navigation chapter.
Hence this code should be deleted from the table
on Page 1.
Noted
Done
Noted
Done
Noted
Done
If you want to present emf for military in this

chapter you must produce completely new figures,
or perhaps repeat the data from the old guidebook. Noted
Done
Error 2): A calculation error has been made in all

the emission factor tables, when transferring from
g/tonnes to g/GJ.
Noted
Done
In the spreadsheets provided by Morten Winther,

g/GJ related emf are calculated. Please use these
factors instead.
Noted
Done
Error 1d): Military mobile activities are NFR

grouped as 1A5b (other), and contains aviation,
land based and sailing activities.
Serious omission: the information on test

procedures from the old chapter must be included
(and updated) in the new chapter
It is no help for inventory makers to have such
vague description
The Tier 1 figures in the Tables 3-2 to 3-8 are all
wrong. Please use the factors from Morten
Winther, directly.
Done
Noted
Done
Noted
Done
Noted
Done
Fishing vessels are treated in the Navigation

chapter.
in the sector 1A3d (Navigation). This follows the
correct transfer between SNAP (0803)
and the NFR (1A3d) category. In the current
version of the guidebook, SNAP 0803
Noted
Done
Noted
Done
Noted
Done
Noted
Done
It is a very big mistake not to follow the

nomenclature agreed by the inventory community. Noted
Done
is clearly described as inland waterways,

containing also the activities by recreational craft.
If you want to present emf for military you must

produce completely new figures, or perhaps repeat
the data from the old guidebook.
Noted
fuel being used in NRMM would introduce a
serious error in the inventories.
Noted
Tables: Inventory makers must have the
information of which sales year relates to which
emission layers.
Done
Done
Noted
Done
Tables: Tier 2 emission factors prior to stage I must

be split into three technology levels (<1981, 19811990, 1991-stage I) instead of applying one
average.
Noted
Done
The differences between layers are too big to

ignore. You must use the data provided by Morten
Winther.
Noted
Done
Tables 3-14 (diesel) and 3-16 (4-stroke gasoline)

concerns the emission level corresponding with the
directive 2003/44 emission standards.
Noted
It has nothing to do with military equipment! You
are mixing up all definitions.
Noted
Done
In addition, the Table 3-14 to 3-16 captions include

the NFR category 1A4c: Please stress that it is the
recreational craft part of Navigation we are dealing
with here.
Noted
These data I calculated for you also, as a part of
our agreement.
Noted
Done
1) You must provide some kind of information, for

instance %-values, which distributes fuel
consumption as a function of engine age for each
NFR code.
Noted
Such distribution functions can be derived from the
Winther & Nielsen database.
Noted
2) You must also provide information of which
sales year relates to which emission layers.
Noted
You can find these data in the relevant directives,
or alternatively derive aggregated sales year
information from the Winther & Nielsen database.
Noted
Done
Done
Done
Done
Done
Done
3) Finally, you must provide information of average

engine life times for the different NFR codes. This
can be derived from the Winther & Nielsen
database.
Noted
Change as "The extraction and treatment of coal
result mainly in emissions of methane."
Editorial
Delete the sentence "This sector was estimated to
account for 22% of the total national CH4
emissions in the UK in 1991 (Gilham, 1994)." It's
an old data not relevant for the GB.
Accepted
Change as However, also NMVOC, PM and CO2
are emitted
Accepted
Change "methane emission" with "firedamp
Editorial
release"
Delete from not applicable: "TSP, PM10; PM2.5;
Pb; Cd; Hg; As; Cr; Cu; Ni; Se; Zn;" Put in Not
estimated:: "TSP, PM10; PM2.5; Pb; Cd; Hg; As;
Cr; Cu; Ni; Se; Zn;"
Accepted

Accepted

Accepted
Done
Done
Done
Done
Done
Insert after the title: "A Tier 3 methodology for

emission factors estimate for open dust sources at
coal mines can be found in US EPA AP42 in
Chapter 11.9 Western Surface Coal Mining (US
EPA, 1998)"
Accepted
Done
In the text the reference is Tsibulski not Tisbulski.
Done
Editorial
Insert the reference: US EPA, 1998 AP 42,

Compilation of Air Pollutant Emission Factors,
Volume 1: Stationary Point and Area Sources, Fifth
Edition, Volume I, Chapter 11.9 Western Surface
Coal Mining, 1998
Accepted
There are no guidance of storage of solid fuel.
Should particle emission from coal storage be
estimated and if so there should be a default
emission factor made available.
Noted
Are you sure PCB = 2 g (it's not mg?)
Accepted
Add the sentence "In this category can be included

Coal Handling And Storage. For this A Tier 3
methodology for emission factors estimate can be
found in US EPA AP42 in Chapter 13.2.4
Aggregate Handling And Storage Piles (US EPA,
2006)"
Accepted
Added to references
EF removed, not
applicable here
Done
Insert the reference: US EPA, 2006 AP 42,

Compilation of Air Pollutant Emission Factors,
Volume 1: Stationary Point and Area Sources, Fifth
Edition, Volume I, Chapter 13.2.4 Aggregate
Handling And Storage Piles, 2006
Accepted
Why is venting included in this chapter? It should
be placed in the chapter 1B2c VENTING and
flaring.
delete "or liquefied gas": it's included in
subsequent 2.1.8 paragraph
Done
Accepted
Done
Accepted
Done
Accepted
Sentence added
insert a paragraph about "gas compressor station"

and indicate where Emission from these are
computed
Accepted
Sentence added
insert a comment about "oil pumps" and indicate

where Emission from these are computed,
particularly when pumps are fuelled by oil (as in
the case of ships pumping of oil at maritime
terminal"
The references are very old. The newest one is

more than 20 years old. It should be discussed
whether the data are still valid.
Noted
I can only agree with the inserted comment, that

better data should be available. This issue should
however had been solved prior to releasing a first
order draft.
Noted
I am unable to reproduce the resulting emission

factor in table 3-2 based on the current values in
the existing guidebook. The comment states that
the geometric mean from distribution has been
added based on table 8.17 in the existing
guidebook.
Noted
Very strange sentence since the inserted comment

contradicts the meaning of the sentence.
Accepted
insert a Tier 2 evaluation for 050601Pipelines and
050603 Distribution networks; I think it's a priority
Noted
The values in the existing guidebook varies greatly

from 0.091 to 3.2, therefore just taking a geometric
mean of all values listed without an accompanying
explanation does not seem appropriate.
Noted
explanation does not seem appropriate.
Noted
Comment removed; is
wrong

explanation does not seem appropriate. The value
of 3.1 stems from Romania and seems like an
outlier
Noted
As mentioned this chapter is directly copy/paste
from the existing guidebook. A lot of data concerns
venting, this information should be moved to the
correct chapter.
Accepted
I would suggested to move factors for venting to
1.B.2.c.
Accepted
delete all the point 3.4.2.5 Oil loading and transport
Accepted
must be included in 1.B.2.a.v
Erase Table 3-23 as must be included in 1.B.2.a.v
Rejected
Clarify Table 3-24 (in the text erroneous indicated

as Table 8.18): must be included in 1.B.2.a.v and
review the text consequently
Accepted
A couple of the references are not used in the text. Accepted

Volume title correctly: 1.B.2.a.i, 1.B.2.b.
Considering the values in that table covers only
distribution the emission factor seems low.
Done
Done
Done
Checked; some references
removed
Noted
Noted
Delete "Passant, 1993" This reference is no longer

given and theEPA reference is wholly adequate.
Accepted
Done
Figure 2-1: The notation of Heat and its emission is

missing from the chart. See 2nd comment above. Accepted
Figure updated
In Table 3-2, Section "Abatement Technologies"

the use of thephrase "Primary cyclone......." may
be misleading. To avoid confusion, it is
recommended that the abatement technology
isdescribed as "Cyclone systems installed
internally within the regenerator".
replace "unit units" with "unit"
Accepted
Editorial
Done
Done
Title of Table 3-3 requires amendment as it

currently reads ".......reforming unit units". Delete
the word "unit".
Editorial
Done
change "3.3.2.7 Diffuse emissions" with "3.3.2.7

Gasoline storage. For depots of gasoline in
refinery refer to Tier3"
Accepted
Done
Accepted
Updated to 0.4
In Table 3-6, the Upper Confidence Limit looks

incorrect. The samepollutant and EF are given in
the Tier 1 Table 3-1, with an upperlimit of 0.4
instead of 0.6 given in this Table.
replace "This section provides Tier 3 information
for refineries.
Rejected
Proposed changed text to clarify where the

cyclones are installed:"The basic catalytic cracking
regenerator design normally incorporates, inside
the regenerator vessel, cyclone systems to
separate the catalyst particles from the
hydrocarbon vapours.Additional cyclones systems
and/or electrostatic precipitators maybe installed
external to the regenerator to abate further the
particulate emissions".
Accepted
Done
In Table 3-7, the reference for "partial burn with CO

boiler" is wrong. This is not given in CONCAWE
3/07. The oxidation value of 99.5%is given in the
Commission Decision of 29-01-04 on GHG's- see
OJ No. L59, 26.02.2004 (comment later re p24)
Accepted
Done
In Table 3-7, the reference for "full burn

regeneration" is wrong. This is not given in
CONCAWE 3/07. The oxidation value of 99.5%is
given in the Commission Decision of 29-01-04 on
GHG's- see OJ No. L59, 26.02.2004 (comment
later re p24)
Accepted
Done
In Table 3-7, the reference for "additional cyclone

stages" is wrong. This is not given in CONCAWE
3/07. A reference to the RefineryBREF should be
given i.e. "European Commission (2003)"
Accepted
Done
In Table 3-7, the reference for "electrostatic

precipitators" is wrong. This is not given in
CONCAWE 3/07. A reference to the RefineryBREF
should be given i.e. "European Commission
(2003)"
Accepted
Done
In Table 3-7, to clarify where the "Additional

cyclone stages" arelocated, it is recommended to
change this to "Additional cyclonestages installed
external to the regenerator"
Accepted
Should this equation be numbered i.e. be equation
"(9)"?
Editorial
Should this equation be numbered i.e. be equation
Editorial
"(10)"?
Done
Done
Done
References should be (US EPA, 1995, CEN, 2008) Accepted

Reference should be "US EPA (1995)"
Accepted
Reference should be "CEN (2008)"
Accepted
Done
Done
Done
Add new paragraph: "A recent development is the

use of hand-held optical imaging devices to detect
leaking components permitting surveys to be
undertaken more quickly (Epperson et al., 2007)." Accepted
Done
There are issues on double counting which are

highlighted on page 1,lines 9 to 17. Suggest repeat
here.
Accepted
Accepted
Accepted
Done
Done
Done
Current text in this paragraph should be deleted

and replaced: Reason: optical remote sensing
techniques can only measure emissions over a
very short time period e.g. a few hours. Emissions
from refinery sources generally vary widely with
time, e.g. floating roof tank emissions are highly
dependent on wind speed. It is not valid, therefore,
to extrapolate these short term measurements to
calculate refinery annual emission inventories
asthis would result in significant errors. It is
proposed that the It is proposed that the following
text is inserted in its place:"Remote sensing using
optical gas imaging may be used to identify,for
example, if any external floating roof storage tanks
are operating outside of the performance bounds
for which emission factors are valid, permitting
focussed maintenanceto ensure that factors can
then be used for these sources forinventory
purposes."
Accepted
Accepted
Done
Done
Reference EPA 1993 is incorrect. It should be:

"United StatesEnvironmental Protection Agency
(US EPA) 1995. Protocol forEquipment Leak
Emission Estimates. EPA-453/R-95-017. Officeof
Air Quality Planning and Standards, Research
Triangle Park,North Carolina"
Accepted
Done
Accepted
Done
Accepted
Done
If the proposed text addition above (p 22, line 7) is

accepted, thenthere is the need for a new
reference: "Epperson, D et al. "Derivationof new
emission factors for quantification of mass
emissions whenusing optical gas imaging for
detecting leaks". Journal of the Air andWaste
Management Association (JAWMA), Vol. 57, Issue
No. 9,September 2007".
Accepted
Done
Reference CEN (2005) should be updated as this

Standard is now published as EN 15446, 2008.
The reference US EPA 1994 is not referred to in
the chapter. It should be removed from the list.
A new reference is required for Table 3-7 (see

comments above). This is: "European
Commission (2004), "Commission decisionof 29
January 2004 establishing guidelines for the
monitoring andreporting of greenhouse gas
emissions pursuant to Directive2003/87/EC of the
European Parliament and of the Council
(2004/156/EC). Official Journal of the European
Communities No. L59, 26.02.2004"
No EF for SNAP 050402
Accepted
Noted
Done
The figure is nice. A similar one should be provided

for marine terminals or include marine terminals in
the present figure 2.1
Noted
Add the reference: ARPAT (2007) Agenzia
Regionale per la Protezione Ambientale della
Toscana, Monitoraggio delle aree geotermiche.
Rapporto Finale, Anno 2006, Novembre 2007
Directive number is 94/63/EC, not 63/94/EC
Propose change "There are two major sources ..."
to "There are three sources ....". Reasons:
following the statement are listed three sources, of
which only one (standing storage emissions)
issignificant.
Replace "into a cargo tank truck" with "into a cargo
tank truck or ship"
Add "occur when" at start of this line to follow on
from line 8.
Reference should be "European Commission,
2006" not "EIPPCB, 2005"
Should be "European Commission, 2006" not
"EIPPCB, 2005"
Change "reportedly" to "reported".
Rejected
Editorial
Editorial
Done
Done
Accepted
Done
Editorial
Done
Editorial
Editorial
Done
Done
Editorial
Editorial
Done
Done
Editorial
Editorial
Editorial
Editorial
Editorial
Editorial
Editorial
Editorial
Done
Done
Done
Done
Done
Done
Done
Done
AR - gasoline production statistic (p. 11, row 8). On

the p.12, row 12 - amount of gasoline sold should
be used as activity statistics
Accepted
Editorial
Descriptions harmonized;
gasoline sold is relevant
activity here
Done
Give a definition of oil product. What products

have to be included? gasoline, gas oil, fuel oil,
aviation gasoline, distillate oil .?
Description made more

clear
Accepted
What is throughput : crude oil ? Something else?

Define please. Provide also some default values
for average vapour pressures for the different
products from crude oil to naphtha, gasoline, gas
oil
Consult with Gasoline considered here,

Expert Panel has been added to text

oil


oil


oil


oil
In the table 3-6 SNAP 050501 or 050401 (marine
terminals?)
references should not be guide book 2006 but
CONCAWE 2007

Accepted
Correct here
Accepted
Done

oil

What is throughput in service station stations,

gasoline and gas oil? Provide default vapour
pressures or explain how to get them
Accepted
Reference made to US
EPA description

Accepted
EPA description

Accepted
EPA description
Replace "previously contained gasoline" with

"previously contained crude oil, gasoline or other
highly volatile products"
Editorial
Done
Add "is" between ".....pressure" and "the vapour ..." Editorial

Table title should be 3-12
Editorial
Editorial
Done
Done
Done

Why it is not throughput but gasoline?
Accepted
Noted
the efficiency of 98 % is too optimistic in real life

the efficiency is lower. 90 to 95 would be more
reasonable.
Noted
Concawe considered the methodology as

obsolete! Replace all with the sentence "For
depots of gasoline in refinery refer to Tier3"
Rejected
Done
This explanation comes too late. However not only

gasoline is volatile. Aviation gasoline, Naphtha,
crude oil are stored and displaced. They have to
be considered. Gas oil could be considered if
necessary in countries with high temperature.
Accepted
The efficiency of 90 % is too optimistic. From

studies carried out in France the efficiency for a
station with an active system working correctly is
80 %. You have also to consider that due to poor
maintenance, most active systems become less
efficient and some of them are out of service. If
you do not have statistics on the % of active
systems working correctly, an average efficiency
taking into account the systems out of service can
be 60%. The EGTEI document (see the EGTEI
web site) describes this situation. This situation is
common in Europe. Germany and Switzerland
have recently implemented the use of self
controlled active systems (the equipment of
existing stations should be finalised in Germany
this year and 10 % of service stations are already
equipped in Switzerland.). Only with such systems,
the efficiency can rise up to 90 %.
Accepted
Delete "For example, it will use a knowledge of
equipment components fitted in the refinery to
provide estimates of process fugitive emissions."
as this example is not relevant to this NFR.
Should be Table 3-13
The text currently in 4.5 seems more appropriate
here than in 4.5
Change "For storage ..." to "For example, for
storage ..."
Propose move to Section 4.2
Add "refinery" before "storage" to clarify what is in
040104.
Comment taken into

account; some text on this
added and reference to
EGTEI made
Accepted
Editorial
Editorial
Done
Done
Done
Accepted
Done
Editorial
Accepted
Done
Done
Accepted
Done
Add "terminals and " between "marketing" and

"depots" to ensureall facilities are captured.
Editorial
Done
Glossary: Stage I Controls - "terminals (dispatch

stations)" should be replaced by "refinery dispatch
stations".
Editorial
Done
Glossary: True Vapour Pressure - suggest add

"See section 3.3.2.1"at the end of the definition as
the formula to calculate TVP is giventhere.
Accepted
Done
Glossary: Vapour Destruction Unit (VDU). Delete

this definition, asVDUs are not described in the
text as not permitted in EU.
Done
Accepted
" with : "For storage tank emissions Concawe

report suggests the use of the latest edition of API
documents for Floating Roof Tanks (API,2003),
and Vertical Fixed Roof Tanks (API, 2002). For
Aboveground Horizontal Tanks, Concawe report
suggests to use the latest edition of U.S. EPA
methodology (U.S.EPA, 1995). Note that this
reference normally contains the latest version of
previously quoted API methodologies. An emission
calculation software is available from the US EPA
via their website, http://www.epa.gov, or on a CDROM(U.S.EPA, 2005). This CD also contains the
EPA publication (U.S.EPA, 1995) and API
documents (API 2002; 2003)."
Rejected
replace "Most emission factors are taken from the
Guide to Geothermal Energy and the Environment
(Geothermal Energy Association, 2007), available
via http://www.geoenergy.org/publications/reports/Environmental
%20Guide.pdf." with "Emission factors results from
measurement performed by the environmental
protection agency of Toscana region, Italy (ARPAT,
2006). The region is the main Europe producer of
this kind of energy.
Accepted
Delete!
Rejected
Due to differences in chemical composition of
geothermal fluid, site dependent emission factors
obtained by sampling is suggested.
Rejected
Done
Added to text as a
preferable option
Since the authors, judging by the inserted

comment, do not know, what is meant, I will take a
crack at solving the mystery. My best bet is that
line 19-20 and line 21-22 should also be part of the
bulletpoints, then it all makes sense!!
Accepted
Thanks! Now it makes

more sense.
Is there a particular resaon why the emission factor

are expreesed in g/Sm3, or is it just because that
is the units used in the existing guidebook? g/Nm3
og g/GJ could be used.
Accepted
All updated to g/Nm3 for

harmonization.
Despite all the mentions of venting, this table is

about flaring not venting. Data stems from the
existing guidebook, where the quality is C and not
D as mentioned in the inserted comment.
Table heading updated.

Quality rating updated,
Consult with therefore uncertainty
Expert Panel range updated as well.
If the factors only are applicable for Norway, the

relevance of having them in the guidebook would
seem miniscule.
Noted
replace "For the types of storage tanks used to

store volatile liquids at refineries, emission
estimation methodologies are provided by the US
EPA (EPA, 2006). These methodologies require
information on the tank contents, size, shell colour,
floating roof fitting types and number, etc., on a
tank-by-tank basis. Emission calculation software
utilizing the algorithms in the US EPA publication is
available on the EPA website http://www.epa.gov,
or on a CD-ROM (EPA, 2005). " with "For storage
tank emissions Concawe report suggests the use
of the latest edition of API documents for Floating
Roof Tanks (API,2003), and Vertical Fixed Roof
Tanks (API, 2002). For Aboveground Horizontal
Tanks, Concawe report suggests to use the latest
edition of U.S. EPA methodology (U.S.EPA, 1995).
Note that this reference normally contains the
latest version of previously quoted API
methodologies. An emission calculation software is
available from the US EPA via their website,
http://www.epa.gov, or on a CD-ROM(U.S.EPA,
2005). This CD also contains the EPA publication
(U.S.EPA, 1995) and API documents (API 2002;
2003)."
Rejected
No need to repeat a completely identical table.
Rejected
The sentence about uncertainty makes no sense.
No quality codes are provided in this chapter, so
comparison with the uncertainties chapter is rather
difficult.
Accepted
PM10 should be removed from the table and
placed under NA or NE.
Accepted
In the "Not Applicable" list for Table 3-5, PM10 is
given. However,this is also shown in the Table as
"NE". Should it be listed,therefore, in the "Not
Estimated" list?
Sentence removed
Fixed
Accepted
Fixed
In Table 3-5, the following pollutants should be

deleted from the"Not Applicable" list as EF's are
provided: PM10, Pb, Cd, Hg, As, Cr. Cu, Ni and Zn. Accepted
Why no glossary for this chapter?
Noted
Fixed
An emission factor of 0 is clearly not acceptable,

either there is an emission factor or the pollutant
should be listed as not applicable.
Accepted
The CO and NMVOC emission factors are a factor

10 lower from the reference chosen compared to
the other references in the existing guidebook. At
least a note explaining the comparatively low
values should be offered.
Noted
Erase 30311 Cement (is included in B1 Energy)
and erase (decarbonising) from 40612
Accepted
All EFs that are equal to

zero removed, moved to
NA or NE according to
reporting template
Done
Chapter contains scarce information necessary for

emission inventory from cement production. There
are 5 short tables with only PM emission factors.
Chapter should be supplemented and updated.
Noted
Proposals: two Tier 2 tables applicable for EECCA
countries were suggested for the Guidebook: for
wet and dry cement production with averaged
levels of abatement.
Accepted
Two new tables introduced
"This chapter only considers emission of

particulate matter from cement plants, which is
mainly the PM from pre- and aftertreatment". If this
is the case, where can we find the emission factors
of the pre- and aftertreatment processes?
Noted
For many of the pollutants listed in the mentioned
lines the BREF states that a significant contribution
comes from the materials processed.
Noted
In this statement, the ammonia appears as an
important pollutant to be considered in the cement
production but, in the rest of the document, the
ammonia does not appear and in the tables is
treated like " not applicable ".
Accepted
Subchapter 2.3 Emissions contains long list of
pollutants emitted during cement productions and
processes are described but Tier 1 and Tier 2
Tables 3-1-3-3 gives only particulate emission
factors.
Noted
The text concerning emissions of SOX originating

from fuels or raw material can be misunderstood.
Noted
Statement corrected
Erase "For Tier 1 the emissions of NOx, CO,

NMVOC, SOx, heavy metals and POPs can be
assumed to be mainly due to the combustion of
the solid and waste fuels and will be included in
the emission factors used for chapter 1.A.2.f.i. To
avoid double counting estimates should be made
in the chapter 1.A.2.f.i. In the Tier 1 approach they
will, as far as they originate from the chemical
composition of the raw meal, be reported as Not
Estimated."
Rejected
Move B(a)P, B(b)F, B(k)F, CO, DIOX, HCB, Indeno,

NMVOC, NOX, SOx, from Not estimated to Not
applicable
Rejected
Erase Tier 2 (is a copy of Tier 1) because it
generates confusion
Rejected
Tables 3-1-3-3: these tables include only 3
emission factors each which are the same. Tier 2
tables for wet and dry processes include the same
factors for different cement production processes
and same with Tier 1 this is not true and
contradicts to Tier 2 approach determination.
Reworking of EF tables is necessary.
Rejected
Tables 3-1-3-3: there are no emission factors for
heavy metals; it is shown that they are accounted
in 1.A.2. But it is known that heavy metals are
emitted with particles. So it assumed that cement
particulate do not contains heavy metals? And it is
assumed that only particulate is abated while
heavy metals are emitted unabated?
Rejected
Table 3.1: EF seem to be too high, if quarry is
Noted
excluded as presented in Figure 2-1
No need to present the same default EF in three
tables: 3-1, 3-2 and 3-3
Rejected
"The Tier 1 emission factors have been used in the
Tier 2 approach as well". This sentences amounts
to say that there is no Tier 2 approach for the wet
kiln process!
Noted
"and the algorithm in equation (3) reduces to:"
Editorial
"The feeding of dry material into the kiln will

however typically result in higher emissions of dust
as compared to the wet kiln process".
Noted
Equation numbering
corrected
" ..the Tier 2 emission factors for the dry kiln

process in Table 3-3 are the same as the Tier 1
default emission factors presented in Table 3-1".
This sentences amounts to say that there is no Tier
2 approach for the dry kiln process!
Noted
Descriptions of algorithms occupy 2 pages while
only 3 factors available; what is the usefulness of
these algorithms?
Delete "from"
Table 4-1: How does this table correspond to

tables 3-27 - 3-31 (1A2)? Present the
correspondance between the different units
References contain only 4 sources including 2
BREFs: it is too short.
Noted
Editorial
Accepted
Simplest correspondance
included plus a reference
to the BREF if more
detailed information is
requested
Noted
The indication I.E. for the pollutants present also in

Combustion activities is ambiguous; it's not clear if
there are part of process emissions evaluated in
combustion or if there are combustion emissions
Accepted
Where is the equation (3) in the document?
Accepted
We consider that this is a very serious drawback

for process emission estimation in this sector (key
source for many pollutants as heavy metals from
the very kilned raw materials (whose emission
factors do not appear at all))
Noted
Indication removed from

all chapters; now in NE
Equation numbering
corrected
for many of the pollutants listed in the mentioned

lines the BREF states that a significant contribution
comes from the materials processed.
Noted
It is considered that the ammonia in not an
important pollutant to be considered in the cement
production?
Accepted
We consider that this is a very serious drawback
for process emission estimation in this sector (key
source for many pollutants as heavy metals from
the very kilned raw materials (whose emission
factors do not appear at all))
NH3 in NE instead of NA
Noted
So the question arises: where are you allocating

these emissions and what are the corresponding
emission factors, if their emissions have not been
computed in the combustion activity (1.A.2.f.i), and
there is not information on them in this process
actvity?
Noted
The proposed EF are very high compared with
BREF use TSP from BREF and estimate fraction
of PM10 and PM2,5
Accepted
Replaced with BREF

factors
It is assumed that heavy metals are mainly due to

fuel combustion so they are accounted in 1.A.2.f.i.
So it supposed that lime particulate do not contains
heavy metals? And abatement affects particulate Consult with
and not affects heavy metals?
Expert Panel
Table 3.1: EF seem to be too high, if quarry is
excluded as presented in Figure 2-1
Noted
Delete: EFs very old; substitute with controlled / no
controlled TSP from BREF and estimate fraction of
PM10 and PM2,5
Accepted
Done
Chapter contains mainly headings, algorithms and

table without emission factors. It should be
supplemented.
Rejected
Some headings removed

to make more readable
Nevertheless a decision tree is possible: For

Germany we have the question clarified whether
information from sectors limestone used are
available. With "Yes" like in Germany all
calculations are made in sectorspecific chapters,
so 2.A.3 shows only "IE". With "No" an estimation
under 2.A.3 is necessary. In Germany we have
made for verification a limestone balance with the
full set of production and use and so identified
gaps, which were closed in different sectors.
It is not mentioned that heating emission is taken
into consideration in 1.A.2.c.
See comments to german limestone balance
before.
before.
before.
before.
11 subchapters of the chapter consist only of
heading and comment: No specific issues. Maybe
it will be better not to show this chapter at this
stage at all?
Correct the mentioned BREF and write " is
available in the BREF "Large volume inorganic
chemicals - solids and others (European
Commission, 2007)
Correct the word "Boudart reaction" into
"Boudouard reaction"
Round the EFs value. Ammonia lower value = 0,6
Table 3-1: emission factors are with 6 digits after
point it is too much.
Accepted
Decision tree and some

text on this issue added to
chapter
Accepted
Added to chapter
Noted
Noted
Noted
Noted
Noted
Some of the multiple

headings removed
Editorial
Done
Editorial
Done
Accepted
Done
Accepted
Corrected
table 3-1: the emission for NH3 given in the BREF

is 0.6-1.5 (LVIC-SAO, chapter 2.3.3.5)
Accepted
Delete: no clear, no necessary
Rejected
The BREF documents don't present emission limit
values, but BAT-associated emission levels (BATAELs) - delete the sentence "This section provides
emission limit values (ELVs) as defined in the
BREF document"
Accepted
Can't find the cieted value for NH3 in the BREF cite correct or delete value.
Interpretation is correct as Asphalt Roofing
Materials
Accepted
Corrected
Done
Error - value should not
have appeared here.
Removed.
Noted
"...with the exception of asphalt blowing, which is

inventoried separately under NFR source category
1.A.2.f.i".
Accepted
Figure 2-1: The notation for Heat or Fuel and its
emission are missing.
Accepted
Corrected to 3.C
Table 1-3: Mostly the production data are included

in quadrat m. I would recommend the inclusion of
factor-information from this, as well.
Accepted
Decision tree is proper for production only,
emissions of application seem to be relevant are in
Germany calculated too. The decision tree has to
refer to the complete number of application of
roofing materials.
Accepted
The proposed EFs from old GB are obsolete: there
are a new US EPA chapter in AP42
Accepted
Done

Accepted
Done

Accepted
Done
The reference is obsolete new one is U.S.

Environmental Protection Agency (U.S. EPA),
1995. 11.2 Asphalt Roofing Compilation of Air
Pollutant Emission Factors: Stationary Point and
Area Sources. AP-42, Fifth Edition. Office of Air
Quality Planning and Standards, Research
Triangle Park, North Carolina.
This statement is not correct because asphalt
blowing should be in NFR source category 3.C.
Accepted
Old reference replaced by

new one
Accepted
Corrected
Some information from

030313 used as well.
There appears to be
overlap between the two
chapters in the previous
Guidebook and also the
EPA reference given in this
comment.
The chapter is wrong! The content can be
My best guess is that both
appropriate for activity 030313 Asphalt Concrete
the Mix Asphalt plants and
Plants (that was expired from new GB), but EF and
the asphalt application on
reference are old, a new AP42 chapter was
road should be taken into
produced. The chapter following my interpretation
account. Chapter has
refers to asphalt application on road! and concern Consult with therefore not been
VOC emissions (see US EPA AP42 chapter 4.5).
Expert Panel subsequently updated.
Figure 2-2: Heat and its emission are missing from
the chart.
Accepted
Added to figure.
Here seems a mix-up to be: reference to cement
and lime are not useful.
Editorial
Corrected
The emissions factor indicates a mass rate of
about 20%, what is not usually, please see under
EF_comments.
Accepted
Done
Chapter consists of mainly headings. It includes

one table with 3 PM emission factors (for all mining
processes) which seem underestimated. List of
References includes one source.
Noted
AR - not lime production (page 3, row 11), but floor
area of the building construsted (page 4, row 3 or
p.3 row 21)
Editorial
Table 3-1 and 3-2 are exchanged
Rejected
AR production -activity rate for the lime production Editorial

AR - the activity rate for the storage, handling and
transport
Editorial
In Glossary table - AR production -activity rate for
the lime productionThe right definition as on the
page 4, row 15
Editorial
This chapter includes 6 sources, 5 connected with

glass production: Flat Glass, Container Glass,
Glass Wool, Other Glass, Glass (decarbonizing).
Why they were not included in a separate chapter
Glass production like Limestone and Dolomite
taking into account contribution into heavy metals
emission?
Noted
Please, make sure to use the most up-to-date
sources for technical information and emission
factors
Corrected
Noted
Corrected
Corrected
Corrected
According to a not yet published research project

on emission factors of the german glass and
mineral wool industry, 35% cullet is used in the flat
glass production
Noted
Please, provide updated information on preheating
or remove the word currently in line 7 since the
source is 11 years old!
Accepted
Done
please, provide the source to table 2-2.

Furthermore, VDI 2578 on the emission control in
glass works provides more detailed information on
the energy demand of carious glass types and
furnaces
Accepted
Done
Please, provide updated information on soda lime

glass manufacturing via electric heating or remove
the word currently in line 39 since the source is 11
years old!
Accepted
Text updated for as far as

new information available;
old information removed
About 8 pages of the chapter are devoted to

reduction measures for NOx and SO2; this is not
balanced with other chapters especially taking into
consideration that gases are not accounted in
2.A.7.d chapter.
Noted
Accepted
Obvious outdated
information removed, no
updated information
available
Noted
Obvious outdated
updated information
available
Please, update the information on Oxyfuel-using

furnaces. In western Europe TV-glass is not
produced anymore and could therefore be deleted
from the listing expect for the case that the
producing plants in eastern Europe are using
Oxyfuel.
Noted
Obvious outdated
updated information
available
Please, update the information on SCR. There is

no TV-glass production Germany anymore.
Therefore, remove the listing in line 5
Obvious outdated
updated information
available
Please, update the information on fuel staging in

Germany
Please, update the information on Low-NOx in

Germany
Noted
AR production -activity rate for the lime production,

not correctedwould be glass production (page 22,
row 2 or 5)
Editorial
VOC emissions see EPA AP42
Noted
Corrected
In all tables PAH by substance included into row

"not estimate"and to row "not applicable" as PAHIt
would be more correct if Tier tables in all chapters
have been madein identical format (sequence of
rows):NFRSNAP (if
applicable)FuelPollutantsTechnologies (for Tier 23)Region (for Tier 2-3)Abatement technologies (for
Tier 2-3)NENA
Accepted
All corrected
The heavy metal EF refer to the Guidebook (2006)

- some in general and some to Jockel (2001).
However, for lead crystal glass the general EF is
used instead of EF for special glass (e.g. lead
crystal)?
Noted
HM EFs removed where

not applicable
Tables 3-2 to 3-10 contain emission factors which

seem to be too high (by approximately factor 10
and more) according to the preliminary final report
of a research project on emission factors of the
German glass und mineral fibre industry. The
report is expected to be published in May 2008.
Some examples are listed in the EF-comments
spread sheet. They refer to the year 2005 and sum
up energy- and production-related emissions.
Noted
Tables 3-2, 3-3 (Tier 2): PM and HM EF for Flat
glass and Container glass are the same: this is not
true because technologies are different.
Noted
Tables 3-2 to 3-10 contain emission factors for
which the reference year is not mentioned. Please,
add this information. Furthermore, to our
knowledge it is very common to use the metal
classes I to III. Therefore, they should be used in
the handbook as well.
Rejected
It is stated that Heavy metal emission factors from
the Tier 1 table for this source category are added
to the table in order to fill the gap
methodologically this is not good because as
declared Tier 2 is more sophisticated approach
which provide more accurate estimates; generally
Tier 1 tables should originate from Tier 2.
Noted
Table 3-5: heavy metals emission factors are the
same as in Tier 1 Table 3-1 while TSP EF is
different.
Noted
Tables 3-11-3-12: errors (not lime production).
Editorial
Corrected
Subchapter 3.3.2.5 includes 5 tables (3-6 3-10)

with the same HM EF for different types of glass.
This is not true: every type of glass has different
content of HM thus emissions will be different;
differentiation is especially important for lead
crystal glass.
Noted
Tables 3-6 3-10: Guidebook 2006 as referenced

in these tables does not contain such emission
factors.
Accepted
All checked. EFs removed

where not applicable.
In the tables 3-11, 12 (glass production) the NFR

code is 2.A.2 - lime production, would be 2.A.7.d
Editorial
Corrected
Glossary, AR production - the AR for the lime

production??
Editorial
Corrected
Visschedijk (2004) is missing in the References
Editorial
Added
The SNAP for the organic chemical industry is

absolutely not adapted and not representative of
all productions of chemicals substances. The list of
products from SNAP 040501 to 040526 is not
sufficient. The problem is also liked to the fact that
products accounted under different SNAP code,
are produced by the same process (ethylene and
propylene are the best example)
Noted
The problem of carrying our emission inventories
for the organic chemical industry is related to the
decrease in the availability in statistics. Most of the
production of products considered in the SNAP are
not available in current national statistics.
Noted
the first SNAP 040501 and 040502 represent the

same process, the steam cracker. See the
description in the EGTEI document as example.
Consult with
Expert Panel
SNAP 0405025 and SNAP 040526 should not

exist. There are redundant with SNAP 060306 if
this one becomes speciality organic chemical
industry
Noted
SNAP 040622 should also related to the speciality
organic chemistry
Noted
spelling mistake: correct "gassified" into "gasified"
Editorial
processed
Figure 2-4: Please correct "Adsorption" into

"Absorption"
footnote 5 is not existing below
correct reference to the BREF is missing
Ammonia Tier1: I don't found correspondence with
quoted BREF values
Accepted
Editorial
Accepted
Rejected
table 3-1, column "reference": what does LVC ACF

mean: define reference (Probably you mean the
BERF "Large Volume Inorganic Chemicals Ammonia, Acids and Fertilisers" (LVIC - AAF)
December 2006?)
Editorial
the paragraph mentions only two primary sources
of pollutants, but in the table 3-1 below you find
three pollutants
spelling mistake: correct "Tier 2 ort Tier 3" into
"Tier 2 or Tier 3"
put in a space between "tier 1" and " emission
factors"
processed
not found
processed
processed LVIC AAF
Editorial
processed
Editorial
processed
Editorial
not found
write "Tier" always in the same spelling: either with

a capital (see line 1 to 5 on the same page) or in
lower cases.
Editorial
processed
Nitric Acid Tier1: It's better to use BREF average

value: 10.000
Accepted
Processed
Adipic Acid Tier 1:Why no values when can be

found in US EPA AP45?
Rejected
table 3-4: the upper and lower value can not be

found in the refered BREF. Table 7.10 of LVIC SAO
shows the emission factors for different abatement
technology you refer to as tier 2 (s. table 3-16)
Rejected
table 3-5: delete table 3-5, because of to many

very different production processes in 2 B 5
Rejected
Table 3-5; delete this table; it is impossible to

create a emission factor for the whole chemical
industry
Rejected
procesed
Ammonia Tier2: Use IPPC BREF value and

introduce also Tables for controlled process from
IPPC BREF
Rejected
table 3-6: the conventional as well as advanced

processes are not abatement technologies, but
process technologies - expand the text in line 2,
column 6 with the text from line 8, column 2 and
delete the text in ine 8, column 2
Accepted
table 3-6: the reference of the values given here is

the guidebook 2006 - but there are no datas! The
reference for NOx (CO?) seems to be LVIC AAF,
table 2.7? Define the reference of the data
Accepted
Ammonia Tier2: Introduce also Tables for
Rejected
controlled process from IPPC BREF
Nitric Acid: erase table 3-8, for unspecified process
use Tier 1
Accepted
table 3-10: please define why the value is below
the range
processed
processed
Processed
Accepted
processed
table 3-13: only the value of 5000 refers to French

and German plants, the range of 100-1000 refers
to US plants - define how to use value and range
(why is the range lower than the value?)
Accepted
processed
table 3-15: referring to the guidebook 2006 the

data for the extended absorption does also apply
for medium and high pressure processes - add in
line 6/column 2 medium and high pressure
processes
Adipic Acid Tier 2:Why no emission when values
can be found in US EPA AP45?
table 3-18: line 6, column 2: change "withuUsage"
into "with usage "
the SNAP classification 040303 belongs to the
group of metallproduction and not to the chemical
processes - 2B5a doesn't include either the
silicium production nor synthetic amorphes silica
and silicates - please check this issue.
Accepted
processed
Rejected
Editorial
processed
Accepted
prcocessed
In the last line you write, that TSP has not been
estimated - but in line 11 you have a value for TSP
- please check
Noted
table 3-21: line 9 says that decomposition plants
are included - but table 3-22 is covering the
decomposition plants. Change "Including" into e.g.
"without Decomposition plants"
Accepted
processed
Ammonium Nitrate EFs from US EPA AP45
processed
Accepted
Ammonium Sulphate: NH3 value from old Corinair

references, COV from Economopoulos, 93, PM
from EPA
Accepted
NPK fertiliser: NH3 old Corinair EF

There are not emission factors for NPK fertilisers
production.
Urea: PM, PM10, PM2,5 from US EPA AP45
Processed
Rejected
Processed
Noted
Accepted
processed
In this lines the dimension unites for TSP and NH3

are in the range of kg/t, but while using the same
numerical value you have in table 3-28 the
dimension unit g/t. Please check the
dimensions/values.
Noted
table 3-29: The BREF LVIC-SAO is cited incorrect
(s. also Excel sheet "EF_Comments". I also
couldn't find in the BREF emission values for
PM10 and PM2,5. Please cite accurately.
Accepted
processed
Chlorine production. Table 3-33 Tier 2: Hg

emission is shown as NE it need to be estimated
taking into account contribution of Chlorine
production by this method into mercury emissions. Accepted
processed
Chlorine production: Use BREF values

Table 3-36: emission factor for Cd is missed.
Accepted
Noted
processed
Naphtha is not the unique feedstock in Europe for

steam cracking.
Accepted
The list of products provided is not complete.

Please provide all possible products to avoid
double counting by not specialists.
Noted
In France in 2005 the emission is different as the

volumes produced are different. The emission
factors provided for ethylene and propylene are the
correct one to represent the emissions of the
steam crackers if we are able to allocate the
emissions of the steam cracker in all the different
types of products manufactured by this process. In
the Netherlands ethylene and propylene represent
only 49 % of the total products coming from the
steam crackers. What are the other products? Add
an explanation to consider them in SNAP 040527 if
the product is not considered in an other item of
the SNAP. If you do not recommend to proceed as
above, the emissions of the steam crackers are not
correctly estimated
Accepted
Table 3-37; BREF LVOC: range from 0,03 to 6 kg/t
ethen and not 0,4 to 10 in table 3-37.
Accepted
Polyethylene: use BREF values
Noted
Added note on other

feedstocks
processed
accepted
Table 3-41; BREF Polymers: range (LDPE) 0,7 to

1,1 kg/t for new plants and 1,1 to 2,1 kg/t for
existing plants and not 2 to 3 kg/t
Rejected
The EGTEI document on chemical industry

presents emissions from the suspension PVC
process developed with the industry organisation.
The emission factors could be used.
Accepted
Table 3-42; BREF Polymers: range (HDPE) 0,3 to

0,5 kg/t for new plants and 0,5 to 1,8 kg/t for
existing plants and not 1 to 3 kg/t.
Rejected
Table 3-43; BREF Polymers: range 18 to 45 g/t SPVC and not 18 to 100
Rejected
processed, accepted for

NMVOC, TSP EF's
unmodified
Table 3-44; BREF Polymers: range 100 to 500 g/ t

E-PVC and not 18 to 1000
Rejected
Table 3-45; in BREF Polymers the emission factor
for PP is in the range of HDPE (see above)
Polystyrene, Wrong reference: data from BREF
Polystyrene, Wrong VOC EF: correct BREF value
3200
Table 3-48; BAT for HIPS is about 85 g/t (BREF

Polymers)
Table 3-49: BREF Polymers: range (EPS) 0,45 to
0,7 kg/t
Noted
Noted
Noted
Rejected
Accepted
processed
Table 3-47; BAT for GPPS is about 85 g/t (BREF

Polymers)
Table 3-50: BREF Polymers: range (E-SBR) 0,17
to 0,37 kg /t
Styrene Butadiene Rubber very lower VOC from
BREF (170-540)
Ethylene oxide: wrong reference and incomplete
data
Rejected
Accepted
processed
Noted
Noted
BREF LVOC: in the case of tratment by oxidation

the emissions are considered to be zero
Accepted
Formaldehyde: the reference was wrong BREF but
not polymers
Accepted
processed
Processed
Table 3-55:BREF LVOC reportet emissions of

about 0,11 or 3 to 5 kg/t. The reference BREF
Polymers is wrong.
Accepted
processed
Table 3-56: The reference is wrong (BREF LVOC)
Accepted
processed
Table 3-57: the reference is wrong (BREF LVOC)

Ethylbenzene: EF from BREF ?
Accepted
Accepted
processed
Processed
Table 3-61; Please add LVOC as reference
Rejected
made a reference to the

BREF instead
Table 3-63: EF for POPs pesticides production is

shown zero. It is written that emissions of all the
different pesticides are assumed to be neglible
compared to product. But Chapter 2. E
Production of POPs contain EFs for all POPs
pesticides (10 kg/Mg product).
Consult with
Expert Panel
As said before the SNAP 040527 has to be

completed to give examples. In France as
example, all chemical production which can not be
classified in the previous SNAP are put under this
SNAP "other" and their emissions represent a
large amount of total emissions of the organic
chemical industry (30 % at least)
Noted
Is this chapter useful? Nothing is given to try to
estimate the amount of organic chemical products
stored per t of production. There are no statistics
on the quantity of organic chemicals stored. A way
to estimate them should be useful.
Noted
Not clear
Noted
table 4-1: the BAT-associated emission value

referred to the BREF LVIC-AAF is not for NH3 but
for NOx - write "NOx" instead of NH3; please
define also the reference (LVIC-AAF)
Accepted
processed
table 4-2: the BAT-associated emission value

referred to the BREF LVIC-AAF is not for NH3 but
for NOx - write "NOx" instead of NH3
Accepted
processed
Accepted
processed
Accepted
processed
Accepted
processed
The given BAT value for SO2 is not only for drying
but for the total emission level to air (s. LVIC-SAO,
Chapter 3.5.1, No. 14). Therefore add the data to
table 4-5
Accepted
processed
title of the table: the EF given apply not only for

conventional reforming processes, but also for
reduced primary reforming - add reduced primary
reforming processes (LVIC-AAF, table 2.13)
table 4-4: instead of "SO2" write "SOx as SO2" (s.
reference and text above)
tab. 4-6 (Heading): table 4-6 refers to the sulfate
process and not the chloride process - correct
heading into "sulfate process"
The given BAT value for SO2 is not only for drying
but for the total emission level to air (s. LVIC-SAO,
Chapter 3.5.2, No. 18). Therefore add the data to
table 4-6
Accepted
BAT emission factor for S-PVC: 18 to 45 g/t and EPVC: 100 to 500 g/t
Noted
BAT emission factor for LDPE: 0,7 to 1,1 kg/t for

new plants and 1,1 to 2,1 kg/t for existing plants ;
BAT emission factor for HDPE: 0,3 to 0,5 kg/t for
new plants and 0,5 to 1,8 kg/t for existing plants
processed
Rejected
BAT emission factor for GPPS: 85 g/t; HIPS: 85 g/t

and EPS: 0,45 to 0,7 kg/t
Rejected
BAT emission factor for E-SBR: 0,17 to 0,37 kg/t
Accepted
processed
References: Please add: IPPC BREF Polymers IPPC Reference Document on Best Available
Techniques - Polymers, October 2006
Accepted
processed
Except in some country where the industry is not

present, the chemical industry is often a large
emitter of pollutants
Noted
all tables: use units consistently (Mg, t, ton: e.g. in

table 3-1 you use kg/t, in table 3-2 you use g/Mg, in Consult with
table 3-5 you use kg/ton
Expert Panel
Chapter describes all processes in ferrous metals
industry thus very complicated and difficult for
usage.
Noted
Figure 2-1: Notatin for blast furnace gas missing.

Instead of coal injection I recommend coke or
natural gas injection.
Figure 2-2: The "metallurgical coke"in the top left
arrow is incorrect. Correctly: "Coking coal."
Accepted
Done
Accepted
Figure 2-3: Explanation for the blue arrow missing
Accepted
Figure 2-4: Explanation missing for the blue arrow

"...auxiliary reducing agent" should be amended
with "and as a fuel"
"It leaves" should be replaced with: "It and other
fuels leaves"
Letter missing at the beginning of the line.
Correctly: Top of the
Typo in the middle of the line. Correctly: agents.
Accepted
Done
More info provided in
caption
More info provided in
caption
Accepted
Corrected
Accepted
Corrected
Editorial
Editorial
Corrected
Corrected
Accepted
Checked and corrected
Editorial
Corrected
Accepted
Corrected
Accepted
Corrected
Editorial
Accepted
Corrected
Legend added
Contradictions: Here 1.9% is mentioned, but on

page 7/18 it says: " be reduced less than 1%"
In section 2.2.4. the order: BOF, OHF, EAF, while in
the others it is: OHF, BHF, EAF. The letter is
preferred.
The agent for reheating is not mentioned in the
description, e.g. coke oven gas.
The heavy metal content of furnace gas is not
mentioned. Table 3-14 (3/13) does include it.
" sulfurdioxide" should be written as sulfur
dioxid.
No legend provided for formuila. See row 1.
As there are iron & steel installations that have

only some plant (for example no coke production
or no sinter and so on) it's not possible to have a
set of overall emission factors; please use also for
Tier 1 the subdivision used for Tier 2.
Rejected
Table 3-1: emission factor for chromium is
overestimated.
Noted
tab 3-1 NFR Source cat. Should be 2.C.1 not 2.A.1 Editorial
Corrected
Corrected
Subdivide Sinter from pellets as in IPPC BREF
Accepted
Convert the data in g/kg sinter using appropriate

change factor to compare with "state of the art"
EFs
Rejected
Pellets added as separate

Tier 2 using EFs from
BREF
Subchapter 3.3.2.1: for sinter production it appears

that effect of different systems of control onto
heavy metals is different depending on metal and
for some of them more advanced system leads to
increase of emissions.
Accepted
Why are the EFs of TSP, PM10 and PM2.5 not
estimated in the tables 3.3, 3.4, 3.5 and 3.6 ?
Accepted
Espreme factors checked.

Some inconsistencies
remain however.
In table 3.2 the EF of Pb is 0,5 g/Mg sinter product,

while the EFs in the tables 3.3,3.4 and 3.5 are
higher. Is that correct ?
Accepted

remain however.
Accepted

BREF

EFs
Rejected
Accepted

EFs
Rejected
Tables 3-3-3-6: because Table 3-2 is also named

Tier 2 these tables might be considered as Tier 3.
But they includes only heavy metals and POPs
no PM; error in units (should be sinter instead of
pig iron; should be g TEQ/Mg instead of g
/Mg); SNAP code is shown as 030301 while in
Table 3-1 as 040209, except 030301. Tables are
not harmonized with Tables 3-1 and 3-2: thus in
the Table 3-3 (Controlled by wFGD) emission
factors for Cr, Ni, Pb and PCDD/F more high than
in the Table 3-2 while for PCB lower 2000 times;
dioxins are the same in all tables.
Accepted
EFs
Rejected

EFs
Rejected
EFs added

BREF
Corrections in units made
Accepted

Accepted
Erase Table 3-8 and Table 3-9: are in contrast with
Table 3-7
Accepted

BREF
BREF
Tables removed
PM emission factors are very high if compared with

BREF data (a factor 10)! BREF EF must be taken
into account.
Accepted
Factors replaced with

BREF values.
Heavy metals emission factors in the Table 3-7 are

generally underestimated especially for Cd, Pb,
Zn, but for Cr they are overestimated (taking into
account properties of metals).
Noted
Table 3-7: there are errors in unit for PM10 and
PM2.5.
Accepted
Unit PM10 and PM2.5 not correct
Accepted
Corrected
Corrected
Table 3-7 provides EF for pig iron production, for

the whole process starting from the charging of the
blast furnace to the tapping of pig iron. Table 3-8
and Table 3-9 provide EF for the charging and
tapping individually. But emission factors in these
tables are not harmonized.
Accepted
Tables 3-8 and 3-9

removed because they
generate confusion and
are not complete and
rather old anyway
Error in units in Tables 3-10-3-13 for PCDD/F

should be g TEQ/Mg; tables do not contain PM
emission factors; emission factors were taken from
ESPREME without analysis of applicability; they
look very low and probably contain systematic
error in units.
Noted
PM EFs added.
ESPREME data checked
for errors.
Table 3-14: table should be revised: it is shown

that the table is for Uncontrolled conditions but PM
emission factors are too low and lower than HM
emission factors; HM emission factors are partially
from Guidebook 2006, and partially from
CEPMEIP so overall table is heterogeneous and
not reliable; error in units should be steel.
Accepted
Table corrected
Proposals:Tier 2 emission factors table is

suggested applicable for EECCA countries for
typical levels of dust abatement (95-96%).
Accepted
Tables included
Accepted
NOx and CO EFs added to

table
Basic Oxygen Furnace: NOx and CO occurs from

oxidation process (see BREF for description of
process and EFs): THESE EMISSION MUST BE
INCLUDED AS THEY ARE NOT "COMBUSTION"
EMISSIONS (NO FUEL ONLY OXYGEN)
Table 3-15: HM emission factors look
underestimated.
Noted
It is shown that Most emission factors are taken

from the BREF document for Best Available
Technologies in the Iron and Steel Industry
(European Commission, 2001) but this reduce
applicability of emission factors.
Noted
Electric Furnace Steel Plant: NOx and CO occurs

only in small portion due to adding of coal in scrab
as input to electric furnace (see BREF for
description of process and EFs): I THINK ALSO
THESE EMISSION MUST BE INCLUDED, THEY
ARE ONLY IN LIMITED QUANTITY
"COMBUSTION" EMISSIONS
Rejected
Table 3-16: error in units for benzo(a)pyrene. TSP
Accepted
emission factor is underestimated.
Unit corrected.
Table 3-18: emission factor for lead is higher than

in the Table 3-15 (typical conditions).
Accepted

remain however.
Accepted
Tables included
Proposals: tier 2 emission factors table are

typical levels of dust abatement (97.5%).
Tables 3-1 3-21: error in units should be steel. Accepted
Corrected
Tables 3-19-3-21: error in unit should be steel;

units for PCDD/F should be checked. Heavy
metals emission factors among tables were not
harmonized: thus EF for Electric Arc Furnaces with
bag filter (Table 3-20) are higher than with ESP
(Table 3-19).
Accepted
PCDD/F emission factor

corrected. Espreme
factors checked, but some
inconsistencies remain.
Proposals: tier 2 emission factors table is

typical levels of dust abatement (bag filter, about
99%)
Accepted
I propose to erase all this old materials: it's not
TIER3
3.4.2.5 Rolling mills. This activity must be in Tier 2
with BREF EFs
Its not clear why some pollutants are in "1.B.2.
Industrial Processes" section and not in "1.B.1.
Energy" section while are combustion related. For
example in sinter plant the EF for sinter plant in
Table 3.2 is fuel related as explained in quoted
reference ("The combustion process is not
homogenous and is incomplete, resulting in
significant quantities of polycyclic aromatic
hydrocarbons (PAHs) being produced.").
Accepted
Tables included
All this old information
removed
Accepted
Inserted as separate Tier 2
Noted
In the Tables erase the row relative to NOx, CO,

NMVOC and SOx and put these pollutants in the
box "Not applicable" in conformity with other
chapters
Accepted
Harmonized with
Reporting Template
Chapter consists mainly of headings. It includes

one table with one emission factor: this is not
enough for inventory of emissions from this sector. Noted
Ferroalloys production: use PM EFs from BREF
Accepted
The notation keys given in Table 3-1 for Total PAH

(NE) do not correspond to the notation keys given
for the PAHs included in PAH-4 (NA).
Accepted
In the list of main pollutants PAH are not included.
Accepted
Harmonized with
Reporting Template
Harmonized with
Reporting Template
Table 3-1: no EF for dioxins/furans; no EF for PAH

except benso(a)pyrene.
Noted
Accepted
SOx, NOx and VOC comes from process and are

not evaluated elsewhere. Insert EF here from IPPC
BREF. See BREF for details of the process
emissions description.
Accepted
Harmonized with
Reporting Template
Added to tables
Tables 3-1, 3-2, 3-3: benzo(a)pyrene EF are the

same for Tier 1 and Tier 2 for both technologies of
primary aluminium production: this is not so.
Noted
Tables 3-1, 3-2 and 3-3 include CO emission factor
while other gases are estimated in the chapter
1.A.2
Noted
The EF given for benzo(a)pyrene is not valid for
the PreBake-process.
Accepted
EF removed, other EFs

(Netherlands contribution
for POPs) used instead
In the BREF-document SO2 and NOx

emissionfactors (from sulfur and nitrogen in the
anodes) are given. These emission factors might
be useful for estimating emissions using higher
Tier than Tier 1.
Accepted
Added

Accepted
Harmonized with
Reporting Template
Tables 3-2, 3-3 and 3-4: PM emission factors

shown the same for primary (both technologies)
and secondary aluminium production. This is not
so.
Noted
Corrected

Accepted
Harmonized with
Reporting Template
In the BREF-document SO2 and NOx

emissionfactors (from sulfur and nitrogen in the
anodes) are given. These emission factors might
be useful for estimating emissions using higher
Tier than Tier 1.
Accepted
Added
Table 3-4: no EF for dioxins/furans (important for

secondary aluminium); no EF for PAH.
Noted
tab 3-4 NFR Source cat. Should be 2.C.3 not 2.C.1
also in tab 3-3
Accepted
Corrected
The legend for Table 4-3 refers to emission factors

for primary aluminium production. In row four in the
table it says "Secondary aluminium....."
Accepted
Corrected
Proposals: tier 2 emission factor tables are

suggested for primary (limited control and
advanced control) and secondary copper
production in EECCA based upon average values
of unabated dust emissions, emission control
levels and content of metals in dust.
Tables included
Accepted
It is shown that emissions from secondary copper

production are considered in the Chapter 1.A.2.b.
But Table 3-3 proposes EF for secondary copper
production, Tier 1 (Table 3-1) emission factors are
for all copper.
Accepted
Sentence removed, not

applicable here!
"The emissions from the production of secondary

copper are due to energy use only and therefore
treated in the combustion chapter 1.A.2.b".

applicable here!
Accepted
In the sector 2.3 Emissions SO2 emission are

mainly considered in spite of the fact that gaseous
emissions are not estimated in this chapter;
scarce information about PM emission.
Noted
Subchapter 3.2.2: methods of estimation of Tier 1
emission factors are not described and in general
common table for primary and secondary copper
looks artificial.
Noted
Table 3-1: error in unit (aluminium is shown);

emission factors for heavy metals seem
underestimated especially for Pb; no emission
factor for Zn; no emission factor for copper while
copper production is the main source of copper
emission; emission factor for PCDD/F looks
overestimated.
Accepted
The emission factors are expressed in terms of

mass of pollutant per mass of aluminium
produced. Please take into account that the activity
considered is copper production.
Accepted
Unit corrected. Cu EF
added.
Corrected
SOx, NOx and VOC comes from process and are

not evaluated elsewhere. Insert EF here from IPPC
Rejected
Chapter not contains technologically specific
emission factors as necessary: only tables for
primary and secondary copper with the same
errors (see comment to the table 3-1).
Noted
Table 3-2: error in title: not Tier 1, but it is Tier 2;
Error in unit (aluminium is shown); no EF for Zn
and Cu.
The title of the table 3-2 refers to Tier 1 when it
should be Tier 2.
Accepted
Corrected
Accepted
Corrected
Accepted
Unit corrected. EF for Cu

added, for Zn no
information available.
Accepted
Corrected
Accepted
Corrected
Accepted
Noted
Corrected
Table 3-3: error in unit (not aluminium); no EF for

Zn and Cu.
Warning: the emission factor value considered for
Pb matches with one of the 95% confidence
interval value, is this correct?
The 95% confidence interval for Cr in Table 3-1 is
0-0, but the emission factor proposed is 16 g/Mg
aluminium.
The title of the table 3.3 refers to Tier 1 when it
should be Tier 2.
Same comment for tables 3-2 and 3-3.
In Table 3-1, emission factors for As, Cd, Cr, Hg, Ni

and Pb do not coincide with the values that
appears in the indicated reference (ESPREME).
Accepted
The PST, PM10 and PM2.5 emissions factors that
appears in Table 3-2 for Tier 2 are the same that
appears in Table 3-1 for Tier 1.
Noted
The 95% confidence interval for Cr in Table 3-2 is

0-0, but the emission factor proposed is 21 g/Mg
aluminium.
Accepted
Harmonized
Corrected
In Table 3-3, emission factors for As, Cd, Ni and Pb

do not match with the values that appears in the
indicated reference (ESPREME).
Accepted
Harmonized
In Table 3-2, emission factors for As, Cd, Cr, Ni

and Pb do not match with the values that appears
in the indicated reference (ESPREME).
Accepted
Harmonized
Dioxins and furans are indicated as not estimated

but there is an emission factor proposed in Table
3-1.
Accepted
Corrected
In Table 3-1, for SOx, NOx, NMVOC and CO,

emissions are indicated as estimated elsewhere.
Where are these emissions estimated? In the case
of SOx, are not process emissions (other than
those related to the fuel consumption) that should
be computed in this Chapter 2C5a?
Noted
This statement does not match with the presence
of the table 3-3, which presents emissions factors
for secondary copper production.
Same comment for subsequent tables in this
Chapter.
Accepted
Corrected
Noted
In addition, as a big surprise, there is no Cu

emission factor for the very copper production,
although there are emission factors for other heavy
metals.
Accepted
PCB is indicated as not applicable but there is an
emission factor proposed in the Table 3-1.
Accepted
Cu EF added
Corrected
General comment: chapter should be substantially

reworked. Necessity and methods of aggregation
of primary and secondary lead production should
be discussed.
Noted
Chapter should be edited: 'Lime production' (P.5),
'Cement production' (P.5), "Cement industry" (P.4),
'Production of cement' (P.6), 'Zinc production' (P.2),
'Copper plants" (P.18) et. al. are not considered
here.
Accepted
Table 3-1: HM emission factors are
underestimated; no EF for zinc; principals of Tier 1
EF calculation should be discussed.
Noted
SOx and NOx comes from process and are not
evaluated elsewhere. Insert EF here from IPPC
Rejected
Table 3-2: there are no differences with Tier 1 table
for PM, but large differences for HM.
Noted
Corrected
Tier 2 Tables 3-2 3-10: emission factors in the

tables were not harmonized, i.e relations between
dust and HM were not accounted (HM emission
factors cant be higher than PM; abatement affects
PM similar way as most HM. Applicability of
proposed emission factors is limited because no
geographical indications are given for technologies
distribution.
Rejected
Text in section added to

make it more clear that PM
factors are generic, not
specific for the technology
Proposals: two Tier 2 emission factors for primary

lead tables were prepared applicable for EECCA:
first for low level of abatement (about 98%) and
second for high level (>99%).One emission
factors table was prepared for secondary lead
production (abatement <99%).
Accepted
Tables included
Table 3-3: not understandable: if it is a BAT table

why EF for HM are higher than in the Table 3-2
(Typical abatement); lead emission factor is higher
than for TSP.
Accepted
All ESPREME factors

checked again for errors
Table 3-5: EF for TSP is the same as in the Table

3-3 (BAT), but for HM emission factors are
significantly lower than in Table 3-3. Lead emission
factor is underestimated.
Noted

Table 3-6: the same comment as for Table 3-5.
Noted

Table 3-7 (secondary lead): PM EF is the same as

in the Table 3-2 (primary lead) and in the Table 3-1
(Tier 1). PM emission factors are underestimated.
PCB and PCDD/F emission factors errors in
units.
Noted

Table 3-8: HM emission factors are higher for BAT

than for typical abatement (Table 3-7).
Noted

Tables 3-8 - 3-10: PM emission factors are the

same for different technologies but HM emission
factors are different. Dependence of HM emission
factors from abatement is not understandable.
Noted

Table 3-9: HM emission factors are higher for ESP

than for typical abatement (Table 3-7).
Noted

Proposals: chapter should be significantly

supplemented and reworked. Tier 2 region-specific
and technology-specific tables are necessary.
Noted
It is shown that only primary zinc emissions are
considered but emission factors also for secondary
are included in the tables 3-5-3-8.
Accepted
It is written, that Emissions from nickel production
are not significant, since the contribution to the
total national emissions is thought to be
insignificant, i.e. less than 1 % of the national
emissions of any pollutant. It is not right: in
Russian Federation according to rough estimates
about 1 mln. tons of SO2 are emitted annually
from nickel production about 20% of national
total.
Accepted
Sentence removed
SOx, CO, VOC and NOx comes from process and

are not evaluated elsewhere. Insert SOx and CO
EF here from IPPC BREF. See BREF for details of
the process emissions description.
Rejected
SOx included in this

chapter
Table 3-1 (Tier 1) should be updated: it includes

only 2 emission factors: for TSP and Ni. These
factors if considered EMEP-wide are
underestimated. During nickel production other
heavy metals are emitted.
Noted
It is written, that 'Emissions of SOx, NOx, NMVOC

and CO are due to the combustion activities and
subsequently treated in source category 1.A.2.b' .
This is not so: in nickel production from sulphidic
ore SO2 emission is not due to combustion
activities so should be treated in 2.C.5.c chapter.
Accepted
References include only one source (IPPC BREF)
- it is not enough.
Noted
SOx included in this

chapter
Proposals: chapter need to be substantionally

reworked. Two Tier 2 emission factors Tables for
primary zinc production by electrochemical
technology were prepared applicable for EECCA:
first for low level of abatement (about 90%) and
second for high level (>99%). Electrochemical
technology is dominant in the EECCA countries
zinc industry (more than 90% of total primary zinc). Accepted
EECCA tables included.
It is shown, that the most important pollutants

emitted from these processes are heavy metals
(particularly zinc) but there are no emission
factors for zinc in the Tables 3-1 3-8.
Zn EFs added to each

table
Accepted
"This chapter only discusses primary zinc

production. Secondary zinc production causes only
emissions from combustion activities and is
therefore treated in chapter 1.A.2.b".
Accepted
"The most important pollutants emitted from these
processes are heavy metals (particularly zinc)".
Accepted
Subchapter 2.4 Controls: no description of
abatement systems.
Noted
Table 3-1 (Tier 1): heavy metals emission factors
are significantly underestimated; no EF for Cu; no
EF for Zn which is the main pollutant from zinc
production; EF for PCB and PCDD/F are dubious.
Error in unit for PCDD/F.
PCB is indicated as not applicable but there is an
emission factor proposed in the Table 3-1.

applicable here!
table
Noted
Unit errors corrected
Accepted
Corrected
It is written that This section provides technology

specific emission factors for the two techniques
the electrochemical process and the thermal
smelting process but below there are no
descriptions of these technologies and no emission
factors.
Accepted
Sentence removed, no
specific EFs for these
processes available!
In Table 3-2, why are used the emission factors for

Tier 1 from ESPREME like emission factors for Tier
2?
Noted

remain however.
Tables 3-2, 3-5: PM emission factors for primary

(Table 3-2) and secondary (Table 3-5) zinc are the
same while technologies are different.
Noted
Tables 3-2-3-8 Tier 2: tables were not harmonized

with Tier 1 table and with each other; PM emission
levels do not correspond HM emissions and
sometimes lower than HM emission factors; no
zinc emission factors.
Accepted

table
Table 3-3 (BAT technologies table): emission

factors for Cd and Pb are higher than for typical
abatement; emission factor for Cr appeared not
included in Table 3-2.
Accepted

remain however.
Accepted

remain however.
In Table 3-3, 95% confidence interval values for

Cd, Cr, Hg and Pb do not match with the values
that appears in the indicated reference
(ESPREME).
Table 3-4: PM emission factors are the same as in

the Table 3-3 but HM emission factors are lower 4
orders of magnitude.
Noted

Cd, Cr, Hg and Pb do not match with the values
(ESPREME).
Accepted

remain however.
Table 3-5: PM emission factors are the same as for

primary zinc which is not true; HM emission factors
are underestimated; no Zn emission factor.
Accepted

table

As, Cd, Hg and Pb do not match with the values
(ESPREME).
Accepted

remain however.
Accepted

remain however.
Accepted

remain however.
Accepted

remain however.
Accepted

remain however.
Table 3-6: BAT technology, but HM emission

factors compared with typical abatement (Table 35) are 2-3 order of magnitude higher, PM the
same, PCB and PCDD/F lower.
In Table 3-6, emission factors for As, Cd, Hg and
Pb do not match with the values that appears in
the indicated reference (ESPREME).
As, Cd, Cr, Hg and Pb do not match with the
values that appears in the indicated reference
(ESPREME).
As, Cd, Cr, Hg and Pb do not match with the
values that appears in the indicated reference
(ESPREME).
Table 3-9: abatement efficiencies for modern plant

is shown lower than for conventional installations.
Error: not Lead production but Zinc production.
Accepted
The information that is showed in Table 3-9 is for
lead production, not for zinc production.
Accepted
It is written that Tier 2 tables were compiled using
country data from Table 3-10. But data in Tier 2
tables do not correspond to the data in the Table 310. It is not clear enough how Tier 2 tables were
obtained and for what countries data was used.
Region-specific emission factors are necessary.
Accepted
In Table 3-1, for SOx, NOx, NMVOC and CO,
emissions are indicated as estimated elsewhere.
Where are these emissions estimated? Same
comment for subsequent tables in this Chapter.
Accepted
Dioxins and furans are indicated as not estimated

but there is an emission factor proposed in Table
3-1.
Accepted
Corrected
Corrected
New EFs inserted from

ESPREME, they are now
used in all Tier 2.
Corrected
In Table 3-1, emission factors for As, Hg and Pb do

not match with the values that appears in the
indicated reference (ESPREME).
Accepted

remain however.
This statement does not match with the presence

of the Tables 3-5, 3-6, 3-7 and 3-8, which presents
emissions factors for secondary zinc production.
Noted
This statement does not match with the rest of the
capitule because there is no Zn emission factor.
Noted
Chapter consists of 8 pages and one table Tier 1
emission factors for source category 2.C.5.c Nickel
production (probably error) with one emission
factor (for TSP). This is not enough for emission
estimation from Other metals production. Chapter
should be supplemented.
Noted
Error corrected
Table 3-1: the title and content of the table are not
harmonized.
Accepted
Corrected
References include only one source.
Noted
transport of "cement" is not correct

Instead of "hardwood" I recommend wood or
cellulose-bearing materials
Instead of "wood" I would recommend "wood
or other cellulose-bearing materials"
Accepted
Corrected
Accepted
Done
Accepted
Done
Noted
Accepted
Editorial
Editorial
Corrected
Corrected
Corrected
Accepted
Corrected
Accepted
Corrected
Accepted
Corrected
Accepted
Done
Accepted
Corrected
It is not described where ensillary fuel used in

recovery furnace (e.g. oil) should be taken into
consideration. See also page 7, lines 5-6.
THE should be written as the.
using annual national total cement production?
AR - national total cement production???
Kraft process: the values for NMVOC and SOX are
wrongly copied from BREF
Table 3-2, for TSP, PM10, PM2,5 unit is kg/Mg coal
produced?
Acid sulphite process : the values for PM are
wrongly copied from BREF
Table 3-1: I would recommend "air dried pulp"
instead of "dried pulp".
Neutral sulphite semi-chemical process: wrong
reference (see the text)
Several polutants are given in the EF-tables to be

NA. From Swedish experiences there are
emissions of metals, NH3 and also some PAH-4
and dioxins from the process (Kraft and acid
sulphite) why the notation should be NE.
Tables 3-7, 3-8, 3-9: kg/MG alcohol: what
concentration of alcohol?
It is unclear when Table 7-9 and when Table 28-32
should be used.
Cakes, biscuits and breakfast cereals: wrong copy
EF from old GB: verify
In table 3-19 instead of SNAP 040605 must be
SNAP 040627 (meat..)
In table 3-20 instead of SNAP 040605 must be
SNAP 040625 (sugar)
replace kg/Mg meat etc with kg/Mg product
Tables 3-28 to 3-22: kg/hl alcohol: what
concentration of alcohol?
Noted
Noted
Accepted
Some descriptive text

added in beginning of Tier
2 section
Accepted
Corrected
Accepted
Corrected
Accepted
Accepted
Corrected
Done
Noted
Chapter should be significantly supplemented

taking into consideration importance of POPs
production for total POPs emission. Now it consists
of 3 pages and one table with similar emission
factors for all POPs which are not grounded.
Chapter should also include production of POPscontaining products like PCB transformers,
capacitors, dyers etc. which is important for
retrospective emission assessment.
Noted
What confidence can we give to this chapter? Very
poor at first view. This chapter has to be worked
more deeply. What is the definition of products
used in the table 3.1.
Noted
There are no any references.
Noted
Due to increase pressure on Member states for
providing emission inventories for POP, the quality
of this chapter is too low.
Noted
Who is the expert for expert judgement
Noted
Chapter is based upon chapter Electrical
equipment with PCB from the Guidebook 2006
which was reduced. Chapter need to be
significantly supplemented and reworked (maybe
with division into a few chapters) to show overall
picture of consumption of POPs and heavy metals. Noted
Table 3-1: table should be revised - it is not
reliable, for instance it shows emission factors 1
kg/ton from consumption of heavy metals like Cr
or Ni which is not understandable.
Reporting template now

used to automatically fill
NA and NE boxes.
Noted
This section is not very clear. What do you to say ?

'"Pharmaceutical products manufacturing (SNAP
060306)" does not correspond to "application of
Pharmaceutical products
coatings during the manufacture of a number of
manufacturing removed
other industrial products"
Accepted
from this list
Consult with
It's not clear where leather finishing is included
Expert Panel
substitute "for architectural or furniture
applications"
Accepted
In the discussion of emissions there is no

indication what happens with VOC's emitted from
cleaning equipemtn, brushes, guns, rollers, etc.
Dilution is also mentioned marginally but it might
be quite important. It certainly should be clear if
this is included or not. In case of emission factors
later shown from the model the model developers
should be asked if the factors include these
components or refer only to solvent in paint.
Noted
I would suggest to apply an uniform emission

factor of 95 % for open applications instead of
100%
Accepted
These products are covered by the Product

Directive 2004/42/EC on the limitation of emissions
of volatile organic compounds due to the use of
organic solvents in certain paints and varnishes
When EGTEI document was done, the directive
was not yet implemented.
Accepted
Updated
The results of this are the Solvent Emissions

Directive (1999/13/EC) and the Product Directive
(2004/42/EC). This latter regulation will be.
EU directive 2004/42/EC ((Decopaint directive")
third column 10th row: 150
third column second row: 75
third column third row: 400
third column fifth row: 400
third column sixth row: 75
third column seventh row: 450
fourth column 10th row: 130
fourth column 9th row: 300
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Some of the values table 2-2 are not correct. The

right ones are in Annex II B of the Decopaint
directive (2004/42/EC)
Accepted
Values corrected
Accepted
Values corrected
Accepted
Directive mentioned
VOC content limit values in table 2.2 have to be

modified according to the Product Directive
mentioned above
Mention the EU Solvents Emissions Directive
1999/13/EC for this sector
Updated. Decopaint
directive added to text.
Directive added
Solvent Directive 1999/13/EC mentions that:

"coating activities which cannot be applied under
contained conditions (as shipbuilding, aircraft
painting) may be exempted from emission limit
values : the reduction scheme is then to be used,
unless it is demonstrated that this option is not
technically and economically feasible. In this case,
the operator must demonstrate to the satisfaction
of the competent authority that the BAT is being
used.
Accepted
Accepted
Text added
Directive mentioned
Car repairing is regulated under the Product

Directive 2004/42/EC and was removed from the
Solvent emissions Directive 1999/13/EC
Accepted
Text updated accordingly
Please quote the regulations of the Decopaint

directive for Car repairing (2004/42/EC, Annex II
B).
Accepted
Directive mentioned
Accepted
Accepted
Directive mentioned
VOC contents in paints used for car repairing are

regulated by the Product Directive 2004/42/EC :
only 1 phase which came into force in 2007 (see
table of VOC content in the Directive)
In the equation the activity rate refers to the

application of paint while later in line 13 on page
15 it says that national production data are used. I
think this is wrong, in time of multinational
consortia producing vertain paints in few locations
and distributing them to many countries we cannot
rely on production figures, not too mention stocks
changins from year to year and exports outside
Europe or imports. I think one needs to refer her to
the paint use and industrial associations need to
be consulted for this data. They do exist and are
available for most countries, for the others one
wouldhave to make assessment based on per
capita use of paint or something like that which I
think would still give better result than production
figures.
Accepted
Should emission factor be distinguished according
to the year : 1990, 2000 and 2010 (after
implementation of the Directive) : if yes, data are
available from CEPE. CITEPA has this type of
information.
Noted
Text adapted, discussion

should be about paint
used
I would go for even more caution when suggesting

as a default value a 2000 average Europen
number. I think it could be better to refer to
developed and developing coutnries and try to
develop two factors at least. We need to
remember that there are very often historical or
cultural differences, say how and from what
materials the houses are built, e.g. if one
compares Scandinavia and Mediterranean
countries, the construction materials are so
different that the standard typical paint applications
must be different. I feel these things should be
mentioned. This type of information will be useful
also for the Tier 1 approach. All that in spite of that
fact that I do agree that the 95% conf.int does
cover that largely.
Noted
In the tables 3-1 to 3-3 the development of the Tier
1 emission factors must be further explained.
Accepted
. Member States to bring decorative or vehicle
refinishing paint products ..
Accepted
Decorative paints (060103 + 060104)
Rejected
Description on how Tier 1

has been derived has
been updated
Corrected
Specific EF for 1990, 2000 and 2010 are available

from CEPE and have been used in RAINS
Noted
Again the issue of production versus use. Please
make sure this is consitent, while for cars, coated
area, etc, it is ok for decorative paint is not the right
appraoch.
Accepted
The sector "industrial coating applications" is very
wide : SNAP codes should be precised
Noted
Dont refer to abatement documents that preceed
the Product Directive 2004/42/EC from April 2004.
The actual abatement regulations in EU-27 should
be from that publication onwards. The EGTEI and
RAINS/GAINS nomenclature used here is not
applicable for DECO.
Noted
The sentence "products containing 50 wt-%
solvent" is not compatible with EF replace with
"products containing 25 wt-% solvent" or correct
EF
Rejected
The sentence "products containing 50 wt-%

solvent" is not compatible with EF replace with
"products containing 25 wt-% solvent" or correct
EF
Rejected
The EF in not applicable; where we can found the

data m2 coated. The EF in this form can be useful
to estimate the new paint technology penetration
but non the emissions. EF MUST be expressed as
g/t of paint or g/t product. Consideration about
transfer efficiency of paint on object can be useful
to estimate future paint consumption but not for
emission inventory. Eventually maintain g/m2 for
emissions but define default value for m2/t as
surface painted for tonnes of products. This default
values can be extracted from original EF source.
Accepted
Version calculated in terms

of g/kg paint applied.
Conversion factor
mentioned in text.
The EF is wrong!! The value is referred to g/m2!

And for this is valid the previous comment: where
we can found the data m2 coated. The EF in this
form can be useful to estimate the new paint
technology penetration but non the emissions. EF
must be expressed as g/t of paint. Consideration
about transfer efficiency of paint on object can be
useful to estimate future paint consumption but not Consult with Error corrected. EF should
for emission inventory.
Expert Panel be g/m2 indeed
There is an emission factor of 200 kg/Mg for
Leather Finishing from BREF that must be taken
into account!
Consult with
Expert Panel
I don't think these are always "abatement", new

technology/new products are often considered. It's
better produce EFs tables (non reductions) with
technology/products and put them in section 3.3.2
as in others chapters of GB. I think the approach
must be unique!
Rejected
The table is not applicable. At statistical level is not
known the m2 of wood painted. We need EFs for
tonne of paint.
Rejected
For wire, area is not the relevant activity which is
the mass of wire coated
Accepted
Corrected
The BAT reference is only applicable to the deco

products applied in a factory (installation). The
majority of the volume in DECO, however, is going
into profeesional use (painters) and do-it-yourself.
For that majority (~75%) there is no accepted BAT. Accepted
Added to the BAT section
Coating of agricultural and construction equipment:

this falls in the industrial coating application (not
the decorative coating application)
Accepted
Moved to Industrial coating

application
I think in this chapter should be described

methodologies to ensure time consistency and
recalcualtion and not methodologies to generate
temporally resolved emission data sets
Text removed; does

indeed not belong here
Noted
What is the meaning of time series? I believed that

it is about emission s changing from year to year
and so here the issues of changing emissions
factors owing to technological change and
legislation might be touched upon. As is it is a very
difernt story. Verify.
Accepted
Text removed; does

It probably does not belong here as I think wood

preservation is a separate chapter and is not part
of coating. Suggest ot simply delete.
Removed; belongs in
wood preservation chapter
Noted
Coating of plastic parts is defined separately in the

BREF: it should be added somewhere and the
place is in the industrial coating.
Rejected
For all source categories: National import, export
and production statictics for single chemicals can
be used as activity data. Used amounts can be
differentiated into activities and facilities.
Emission factors can be applied for use of single
chemicals in products and/or activities.
With respect to harmonization to Directive
1999/13/EC, which is e.g. employed in performing
emission projections: In many technologies a
solvent consumption is warranted at facility level.
cont. below
Noted
Noted
Noted
continued from above, This requires knowledge on

Tier 3 level, which may not be avaliable. The
guideline could suggest how to differentiate a total
use amount of solvent on a facility level.
Noted
FYI: Norway is adopting a different approach to

estimating emissions from the use of solvent
containing products than the ones described in the
Guidebook. Like in the Swedish inventory, volume
data from the national Product Register on the
solvents themselves is used. Emission factors are
specific for combinations of product types and
industrial sectors. The 2008 Guidebook does not
provide us with information that can be used in the
emission model directly. However, the information
provided may help to correctly allocate emission
figures (pertaining to the combinations of product
type and industrial sectors) into the different
source categories and help us to improve our
emission factors. More information on the new
Norwegian model on NMVOC emissions from the
use of solvent containing products can be provided
on demand.
Noted
NO EFs for paint application: boat building (SNAP
06 01 06) - Important in some countries, there is
an EF from BREF!
Accepted
EF added
More information is required in relation to the

emission factors from EGTEI. A specific reference
is required to the background documentation in the
GAINS model so that emission factor values can
be examined for applicability to national
circumstance. The emission factors are not clear in
terms of their derivation. The units differ between
sources. A common emission factor unit would be
helpful.
Accepted
Description on how Tier 1

has been derived has
been updated, reference
to GAINS for
documentation
A very important refernce is missing I think. It is

"DECOPAINT - Study on the Potential for
Reducing Emissions of Volatile Organic
Compounds (VOC) Due To The Use Of Decorative
Paints and Varnishes for Professional and Nonprofessional Use", EC DG Environment Tender
E1/ETU/980084, June 2000. I believe it is available
from the Commission web site. This wouldbe very
valuable for the section on decorative paints, even
if it was certainly used by EGTEI group.
Noted
Mentioned in the text as

an interesting background
document
Cleaning products to be considered are only

organic solvents. This has to be precised. Many
products used for degreasing do not produce
NMVOC
Accepted

circumstance. The referecence to EGTEI for this
sector is to a document published in 2005 and not
2003 as indicated. In respect of dry cleaning i
suggest reverting to the old simple methodology
approach rather than an emission factor based on
kg of garment cleaned.
Accepted
Reference corrected; old

methodology put back but
only as a "reference"
methdology, industry has
insisted on removing
information because it was
outdated!
NO EFs for Electronic components manufacturing
Noted
The old GB emission factors for units in operation

can be useful as Tier 1 meth and must be
maintained in the new GB
Rejected
I think in this chapter should be described

methodologies to ensure time consistency and
recalcualtion and not methodologies to generate
temporally resolved emission data sets
Accepted
Text removed; does

In the "old" Guidebook is present an EF in

kg/inhabitant year that can be useful for countries
with no other information. Transfer the EF in new
GB please.
Accepted
Number placed in text
In this Chapter 60301 (Polyester processing)

should be also considered
Noted
It is not correct to say that all these activities are

insignificant. According to characteristic of the
industry and member states, several of these
activities are significant.
Accepted
In the expanded polystyrene, pentane is the most

often blowing agent used. In extruded polystyrene
other types of chemicals are used. In polyurethane
CFC were used but presently other types of
blowing agents are used. In polyurethane, the
types of blowing agents used depend on the final
use of the foam. Butane, pentane can be used as
many substitutes of CFC such as HFC and HCFC.
Some polyurethane foams can be expanded
directly with CO2 resulting from a reaction between
polyols and water.
Accepted
The description is a little bit too old . A description
of the present situation would be necessary.
F11, F12 are forbidden today and cannot be used

anymore. Give the names of the present blowing
agents.
Information added to
chapter
Noted
The title of the paragraph does not correspond to

the SNAP 060306 definition (manufacturing of
pharmaceutical product) We agree and support the
extension of the scope of SNAP 060306. The
speciality organic chemical industry aims at
producing different types of chemical products
including pharmaceutical products but not only.
Noted
the description comes from the EGTEI document
which is not quoted.
Accepted
Explanations coming from EGTEI to be cited
For expanded polystyrene, pentane is exclusively
used.
Quote fixed
Accepted
Quote fixed
Accepted
Accepted
The reduction techniques available for polystyrene

and polyurethane are different. It would be useful
to distinguish the two applications. For polystyrene,
low pentane content expandable polystyrene can
be used (4.5 to 5 %) but just for some specific
application. Emissions can be captured and
treated by oxidation.
Accepted
chapter
Add on techniques can be used. Applications

exists in several countries. Oxidation techniques
are the most often used techniques but waste
gases containing pentane can be also destroyed in
a boiler.
Accepted
chapter
The EC Directive has been implemented but many

member states have their own regulation going
further the EC directive. Polyurethane foam
processing, Polystyrene foam processing, asphalt
blowing, the non pharmaceutical part of the
speciality chemical industry are not covered by this
directive.
Accepted
Give the list of products to be considered.
Small list of products

added, but is not complete
Accepted
Here is a strong mistake. The suspension process

is a process to produce the PVC from VC
monomers. In this chapter only PVC processing
has to be considered. All the paragraph has to be
removed if no data are available for PVC
Consult with
processing.
Expert Panel
the title is not the correct one
The confidence interval should correspond to
something like 55 to 65 g / kg.
Editorial
This chapter is outdated

In Table 3-6 is meant pharmaceutical products
manufacturing
An emission factors of 50 kg/ton of product (from
two factory in Italy) can also be proposed
Noted
the title of the table if not the correct one. For

rubber it is possible to distinguish tyre production
and other rubber processing. For tyre the EGTEI
default emission factor is 10g/ kg rubber
processed. This emission factor is larger for other
application. The 8 proposed if perhaps
underestimated.
Corrected
Rejected
Editorial
Corrected
Noted
Accepted
Title updated; rubber

production now also
includes tyre production
In the SNAP Code should be only considered

"Asphalt blowing " a special asphalt production
process and not the application of asphalt. The
emissionsfactors are very outdated and very
large!!! The asphalt application is considered under Consult with
40610 and SNAP 40611
Expert Panel
The definition of solvent used is the same as the
definition used by the EC directive 99/13. It
corresponds to new solvents or bought solvents +
solvents recycled. It has to be reminded that in the
EC directive fugitive emissions are expressed in %
compared to solvent used. .
Noted
chapter
The definition of asphalt should be provided. Does

it included only the hydrocarbons or hydrocarbons
+ all additives and ingredient used (stones)?
Noted
Give the list of products to be considered. In fact
they are at east paints, varnishes, glues, inks. In
fact this emission factor comes from EGTEI which
provides the emission factors for solvent borne
products, water based products which can be used
by experts if they have the knowledge on the
share of each type of products.
Accepted
Under 60314 should not be considered Tyre

manufacturing. This is considered under rubber
processing. Under 60314 is considered the
manufacturing of solvent containing products
Accepted
Corrected
This description is the same for all the speciality

fine chemical industry. Lower rates of emissions
can be achieved in the newest plants. In existing
ones also. Check if we stay with a definition of
pharmaceutical products or use the speciality
chemical industry?
Noted
the title is the correct one

NO EF (and NO TABLE!!) for 060313 Leather
Tanning
An emission factor for 060311 Adhesive Tape
Manufacturing is present in BREF
NO EF (and NO TABLE!!) for 060312 Textile
Finishing
Editorial
Corrected
Noted
Accepted
EF added
Noted
US EPA insert a lot of other fiber manufacturing

activities that must be evaluated: ryanoin, acetate,
acrylic, nylon, etc.
Noted
NO EF (and NO TABLE!!) for 060301 Polyester
Processing there are data from EPA AP 42.MUST
BE INSERTED!!
Most of this information can be founded by direct
uses of plant data.
Consult with
Expert Panel
Noted

circumstance. Emission factors for each sub sector
could be presented in one table.
Accepted
But this process has to be considered in chapter
2B
Noted
There is a good description of the suspension
process in EGTEI
Noted
Link to GAINS website

provided where
background info can be
found
In polyurethane foam manufacturing a large part of

VOC emissions is due to the use of solvents for
cleaning moulds and blowing instruments.
Noted
This section only concerns heatset web offset,
being only one of the three groups of printing
porcesses addressed in the previous section. This
should be clearly mentioned. The other two
processes should also be adressed.
Accepted
newspapers are not printed in rotogravure. Mention
magazines, brochures, and catalogues
Accepted
Other processes added

Corrected
This section is dangerous and absolutely useless.

The two halves of the industry (i.e. a) everything to
do with publications and b) everything to do with
packaging) are completely independent of each
other; different techniques, different markets,
different import and export positions, different
solvents etc etc. It is wrong to put them in the
same boat. This section must be deleted. It is as of
vehicle refinishing (i.e. painting) and solvent
consumption in shipbuilding (i.e. also painting) are
taken together.
Rejected
I table 3.8 the line 'technoclogy/process'reads
'heatset offset'. This should be publication gravure. Editorial
"audits" could be replaced by "solvent
management plan"
Editorial
I don't think these are always "abatement", often
new technology/new products are considered. It's
better produce EFs tables (non reductions) with
technology/products and put them in section 3.3.2
as in others chapters of GB. I think the approach
must be unique!
Rejected
In general, 2 other processes could be added:

sheet fed and coldset offset. EF and abetment
efficiencies have been defined by P. Verspoor for
the revision of RAINS. CITEPA has also data on
these emissions.
Noted
Suggest using the previous simple methodlogy

approach and presenting emission factors in one
table.
Rejected
Figure 3-1 seems to be copied into several

documents but it is not always appropriate. This is
such case where including TIER 3 on chart is not
of relevance.
Accepted
Decision tree and

corresponding text
updated
Figure 3.1, decision tree is not correct: the facility

level for domesticsector not available and no Tier 3
for this NFR.
Accepted
Decision tree and

corresponding text
updated
Tier 1 default emission factors is incoherent with

Tier 2 as EF (Tier 1) < SUM (EFs(Tier2)) and
different from old one. Change Tier1 or remove
Tier 2
Consult with
Expert Panel
Althogh the two approaches presented in the

algorithm are principally applicable here, the
formulation (obioviously copied in several
chapters) is not appropriatre, specifically talking
here about industry is not what this sector is
exactly about, it is use of products and their
characteristics (formulation=solvent content) and
then shares in total use are of interest. Please
adapt accordingly.
Accepted
cooling liquid (ethylene glycol) may also contribute
to emissions
Accepted
This must be a missunderstanding. What are these
'add on ' measures that couldbe applied here, a
little incinerator in the bathroom to burn the VOCs
from the hairspray used? Apologies for trying to be
funny :-)
Accepted
An important and very useful reference is missing
and certainbly it could be used for improvement of
the chapter - BIPRO, 2002. "Screening study to
identify reductions in VOC emissions due to the
restrictions in the VOC content of products" -Final
report for the European Commission.
Accepted
should read "2.1.2.3 Organic solvent borne
preservatives"
Editorial
Why is "adhesive tape" the unique sector
described in Industrial application of adhesives.
Many other type of application are existing.
Could it be possible to define which sectors are
considered in IND_OS
When it is said that 3 sectors have the same
activity units (Mg product used), it is not totally
exact as we have Mg of glue, Mg of seed and Mg
of others how do you deal with these
differences? Give examples.
Why is "use of shoes" a source of NMVOC? The
manufacture of shoes is a source of NMVOC, but
the "use of shoes" is a source of PM!!!
The title should be Wood preservation and not Fat,
edible and non edible oil extraction
In this Chapter is not considered (forgotten) glass
and mineral wool enduction
add all subsections to the table of contents
Accepted
Accepted
Description updated
according to comments
Added
Corrected; abatement
indeed not applicable as
such
Added
Section headings renamed

Reference to GAINS
added for documentation
Rejected
Accepted
Update: must be
manufacturing of shoes,
not use of shoes. Moved
to chapter 3.C as well
Editorial
Noted
Editorial
Done
sometimes (e.g. p 18, l 33) there is only one

subsection 3.3.1, but no 3.3.2; subsections need at
least two chapters
Editorial
Not sure about this, I don't

see the need, but can
Nicola discuss with Tinus
Equations and legends: inconsistent notation, not

in line with IUPAC
Nicola, this was mentioned

earlier so probably done
by now
Accepted
The chapter is difficult to read. It is not a really

whole ist a summary previous chapters.Title should
be expanded to livestock husbandry and manure.
Nobody would search for PM emissions in manure
management. The structure is not suitable for
agriculture. PM is not really integrated and is
added only.
Accepted
The structure has been

revised and hopefully is
now much more
accessible
maybe it would be useful to say that N2O

emissions, even if part of the N mass-flow
emission cycle, are not considered here because
GHG
Done
Accepted
it must be specified that the emissions from

grazing animals have to be calculated but not (??)
reported under chapter 4B. In the general scheme
of the chapters it appear they are under 4D
Accepted
Overview too short, gives too little information
Accepted
Expand overview to give more background
information
Accepted
Done
Overview expanded
Overview expanded
To avoid misunderstanding it should be pointed

out, that the emission from grassing animals has to
be reported in NFR category 4D2c
Accepted
Done
Table 1-1 shows that NOx emission from the

agricultural sector contribute by 1.8% of total NOx.
This indicate the important of develop a Tier 1
methodology. Is is possible to recommend a Tier 1
approach based on the reference of the data given
in table 1-1?
Accepted
Simple Tier 1 approach

now included
There is no mention of NH3 being produced from

urine except for the comment in brackets on line
23. It woul read better for the non-ag expert if a
sentince on NH3 from urine and faeces began the
paragraph
Rejected
"a small percentage of this N (is in the form of)
urea or NH4+"
Accepted
No longer relevant as we
have revised these
sections
Done
Suggest re-wording the overview. Appears as if

some text was deleted and as a consequence its
structure does not read well
Accepted
Suggest moving this comment to the bottom of the
page as a footnote
Rejected
Overview revised and

expanded
Footnotes are irritating to
the reader
The reference Jarvis etal doesn't cover pigs. For

pigs 70% of N is in urine and 90% of urine-N =
urea-N.
Reference for pigs now

included
Accepted
add: for EU-27

add N2O and CH4 to the emissions created from
manure
There is no abbreviation expansion for TSP. This
concerns the whole text. I suggest to add the
glossary of all abbreviations in chapter 4B
"in particular (the) handling of manures
as"
Accepted
Rejected
Accepted
Rejected
Done
No longer relevant due to
re-structure of chapter
Done
Groenestein, C.M. and H.G. van Faassen, 1996.

Volatilization of ammonia, nitrous oxide and nitric
oxide in deep-litter systems for fattening pigs.
Journal of Agricultural Engineering Research 65:
269-274
Accepted
Process description is too short
Accepted
Done
Process descriptions now
expanded
Accepted
Accepted
More information provided

on processes and clearly
linked with supplementary
data in Appendix
That text now deleted
Provide more information about processes (put

extended description in an appendix)
An example of "movements activities"?
It is correct that only a small percent of faeces is

NH4+, but the sentence needs further
development, because most manure is managed
in a combination of urine and faces (both slurry
and solid waste). The sentence need to clarify that
the TAN content i in solid based stable systems
contains large amounts of TAN (30-50%). So the
NH3 emission is not "sufficient small".
Rejected
please change Van Fassen and Van Dyke into Van
Faassen and Van Dijk
Accepted
The reference = Van Faassen and Van Dijk
Accepted
Sentence incorrect
ist obvious that PM belonges not to manure
mangement
Dust mainly origins from poultry and pig farms.
Dust from poultry houses is mainly caused by
feathers and manure, dust in pig houses mainly
comes from feed, skin particles, faeces and
bedding (Aarnink & Ellen, 2007, see
www.dustconf.com)
" e.g. at pasture or on yards, and (in) animal
(housing)"
Replace with text from original final draft, which
was structured according to pollutant
This section is dealing with

'fresh' N excreta, so
comment not releveant,
but revision of chapter now
gives more explanatory
text.
Accepted
Done
Done
This entire section has
been revised
There is now a separate
section for PM
Accepted
Nicola, can you please

locate the reference and
insert
Accepted
Done
Accepted
Have done
Accepted
Have done
Accepted
Appendix A2.2.3 ??
Rejected
Repace "NIMVOC inventory is further

complicated." with "Estimates of NMVOC
emissions are further complicated."
Rejected
Delete activity
Rejected
on animal?
Delete "The" from "The significant emissions of
PM.."
"The types of feed consumed will have a major
affect (on) emissions"
Order of items does not seem logical, better follow
order of figure 2-1
TAN needs proper explanation first, unless TAN is
introduced earlier? Also mention UAN
Rejected
Add after building: and the storage system. I think

it shoud be included here instead of in line 26
Delete -the storage system- and add -ventilation
system-. The latter is very important in determining
air velocity and thus emission of ammonia
"the height and density of (the) canopy of the crop
or grassland"
Figure 2-1 appears twice
Authors not cited in chapter 5
Accepted
That sentence has been

deleted
Section has been rewritten
Section has been rewritten
Explanation now give,
including UAN
Rejected
This section re-written to

include original text
Rejected
Rejected
Rejected
Accepted
Rejected
Accepted
Accepted
General: Distuinguish between indoor and outdoor

storage like you did on the previous page in
summing up important elements. Distuinguishing is
very important because reduction strategies for
indoor storage are totally different from outdoor
storage. Indoor storage is a component of the
housing system.
Rejected
General: I assume the symbols for variables are
scientifically correct, but it is also very confusing, I
got lost. Please find better solution
Dammgen and Hutchings is not in References
Can't find "Dmmgen and Hutchings, 2007) at the
reference-list
the treatment of manure (i.e.: aeration, separation,
composting) is not cited here neither considered in
the following
reference?
Incomprehensible
comment
Change made
Done
Reference now given
The figure is to illustrate

the principals.
Rejected
Accepted
The figure has not

confused other reviewers
Reference now included
Accepted
Reference now included
Rejected
Accepted
These are not major

sources and not explicitly
accounted for in the
methodology
Reference added
Accepted
Have done
Accepted
Have done
A good idea to clarified that the NMVOC is related

to the methane in manure.
Noted
Odour (of pigs) can be characterised by 20 main

components (putting those compounds together
creates artificial odour). The formulation used in
these lines suggest something else. Please check. Rejected
the number of Figure 2-1 is double
Accepted
There are two figure 2.1. Some explanation is
needed for this figure in page 7.
Accepted
Do not agree with the

comment, we already state
that most of the emission
is from 20 compounds
Done
Same comment as 16 and
19 above
This chapter only covers NH3. Please expand on

other compounds or incorporate in 2.4.1 (which
then should become 2.3.1)
Figure should be shown in 2.1 before
Accepted
Accepted
We have revised this

section
If the figure remains
Figure 2-1; should consider to show a figure based

on different compounds instead of production
states.
Rejected
May delete the figure
It is not possible "reducing the rate of

transformation of TAN to NH4". This is incorrect.
NH4 is part of TAN. It is possible to change the
distribution between NH3 and NH4 by altering pH.
If animal feed is silage, NH3 can emit. If not taken
into account as losses, please note so
Rejected
replace -mainly from feed- with not only from

excreta, but also from feed, animal skin, flees or
plumage and bedding
between brackets: two third of the total. Of what?
Total NMVOC?
Accepted
Text now amended
Accepted
Replace "Excreta" with "excreta"
Rejected
Sentence clarified
Rejected
better to say also that the measures to reduce

emissions are listed and explained in Appendix A3 Accepted
why manure drying via conveyor belts would
reduce PM emissions?
Accepted
list measures to reduce NH3 emissions (e.g.
reduction of air contact, lowering of the pH value)
instead of manure management stages where NH3
emissions can be reduced
Rejected
See remark 5
NH4 is part of TAN, but not

all of it
Accepted
Done
Comment deleted
Not the purpose of the
Guidebook to give detailed
appraisal of abatement
techniques
We have revised this
section
Not all NH3-emission-reducing techniques in

housing systems reduce odour emission (Mol, G.
and N.W.M. Ogink (2004). The effect of two
ammonia emission reducing pig housing systems
on odour emission. 2nd IWA Conference on Odour
& VOCs: Measurement, Regulation and Control
Techniques, Singapore. Published in: Water
Science and Technology, 2004, issue 4, p.335-340)
2.4.4 written 2 times
Cleaning the air with air scrubbers is also an
abatement option (optional as BAT)
add after N: and/or TAN
Delete "way" from "The latter is the most effective
way"
Rejected
Accepted
We do not state that all

techniques to reduce NH3
emissions reduce odour.
We state that techniques
with reduce either or odour
can reduce NMVOC.
Have changed 'can' to
'may'
Done
Scubbers are now
mentioned elsewhere
TAN inserted
Editorial
Done
Rejected
Editorial
In the expert Group of Ammonia Abatement

(UNECE) air scrubbers are considered to be
category 1 abatement options. Some information
on effectivity in: Melse, R.W. and N. W. M. Ogink
(2005). Air Scrubbing Techniques for Ammonia and
Odor Reduction at Livestock Operations: Review of
On-Farm Research in the Netherlands.
Transactions of the ASAE. Vol. 48(6): 2303-2313.
the abatement means are theoretical but not
applicable or state of art
Rejected
Text amended to report air

scrubbers as category 1
We do not suggest
otherwise
Decision tree: ask first if it is a key source and then

the other questions (tier 3 available, MMS
distribution available, etc.)
before this line insert a heading: Ammonia
Section title 'Ammonia' is missing
Section title 'Ammonia' is missing
Accepted
Editorial
Editorial
Editorial

amend
Done
Done
Done
Accepted
We now state the EF

includes grazing for
ruminants
Accepted
The dafault emission factors include emissions

from grazing animals? (better to specify)
I think it will be easier for the user to work with one

document instead of looking for
information/explanation in IPCC (2006)
Rejected
Restore text from original draft but removing the
discussion of emission factors
Accepted
Restore text from original draft but removing the
discussion of emission factors
Accepted
It could be useful to add the exact reference to
IPCC 2006. Example. I suppose it is refered to
Chapter 10 section 10.2
Accepted
We provide all the

information needed, the
reference to IPCC is to
enable access to more
detail.
Text restored
Text restored
The chapter is already in
the reference list, and we
have added the section to
the reference
General remark: NO emissions from manure

mangement are not presented (only an estimate is
said to be presented in the section on ammonia
emissions for losses during storage (step 10 page
22 with reference to an Appendix Table 5.9 which
cannot be found; it seems to be the Table on p 57).
However, no NO emf is presented for manure
application to soil??
Accepted
Average Annual Population or as IPCC2006
Annual Average Population?
Editorial
Is it required to distinguish between time in stable
and time on grass in Tier 1? I assume that the Tier
1 EF for NH3 given in Table 3-1 to 3-15 only
includes the emission in stable? EF for NMVOC
and PM - is it for 365 days in stable?
Rejected
Could supply with a sentence like "No Tier 1
approach is available for emission of NOx"
Accepted
Appendix A3.1.4??
Rejected
A lot of misunderstanding and miscommunication

can be caused by the definition of the activity data.
Definition of AAP is not in agreement with p. 4 lines
23-26. I do not think it is appropriate to deal with
this matter only with referring to IPCC 2006 for
fuller explanation.
Accepted
Delete "in tables" from "Netherlands, Denmark and
Germany in tables."
Editorial
Tier 1 approach added

Has already been taken
out - discuss with J
It is stated in the text the
EF includes grazing
emissions based on
average grazing periods
Sentence added
Incomprehensible
comment
AAP now defined

consistently
Done
PM10 and PM2.5 are higher for FYM (straw based)

than for liquid systems. Please make a
differentiation
Noted
Specify in the text which regions is applicable the
EF
Noted
This is 4D
References used to proposing new EFs are not

published and not available yet. The National
Inventory Report of a single country can be
considered a scientific reference?
Inconsistent citation of references.
Published references now

provided for the EFs from
each national inventory
Has already changed
Accepted
Editorial
PM10 EF values presented seem to be not in line

with values used by the Netherlands for several
animal categories. However, since the basis for the
pm10 emf is rather unclear it is very hard to make
a good comparison. See below questions on
categories included and on the time spend in the
meadow:
It is unclear where the calves and piglets are
included. Eg for cattle it is unclear whether dairy
cattle only includes female adult dairy cows or also
young (dairy) cattle? And what animal numbers
should be used if dairy cattle is a mixed category?
Since calves have a much lower emission factor
their emission will be overestimated if the
presented emf for other cattle should be used. The
same remark can be made for swine: in what
category should the piglets (weaners) be included?
(specifiek place in the tekst: page 12, line 5 to
page 13, line 3 and page 14, line 7 to page 15, line
5)
Noted
Accepted
The text will be corrected

to Dammgen 2007 - Nicola
In table 3-1 to 3-14 concerning the PM2.5 emission

referees to "Dmmgen et al., 2008" - this reference
is not on the reference list.
Accepted
The text will be corrected

to Dammgen 2007 - Nicola
In table 3-1 to 3-15 Propose one table for each

compounds - then it is more easy to compare the
emission levels for all livestock categories.
Accepted
We have restored such

tables to the text
Accepted

make these corrections in
the tables
Editorial

tables (what are we doing
about tables?!
Dammgen et al 2008 is not in References
The emission factors for NMVOC and PM are

given in incorrect units (kg NH3!). This is valid for
all tables. Both "a-1" and "per AAP" is used. The
same nomenclation should be used all over, eg.
either "a-1" or "per annum"
the unit has to be differentiated by pollutants (not
always kgNH3 a-1 per AAP)
General remark: Incorrect units used in Tables for
most pollutants except NH3 (all units are
expressed as kg NH3)
Editorial
I would prefer fewer tables in the text
Accepted
Remove tables to an appendix (correcting the EFs

for PM where appropriate) and replace the text and
tables from the original draft, adding more
information about EFs
Accepted
Tables are confusing and should be presented in a
Accepted
condensed form.

about tables?!
Concise summary tables
now provided
Have replaced text and
tables from original draft.
Have not yet placed
template tables into
Appendix as we need to
agree this with TNO
now provided
the Reidy et al, 2007 reference is insufficient, it

does not contain the specified NH3 emission
factors. Please give more references
Please indicate in the text that all animal manure is
surface applied
Please indicate in the text that all manure storages
are open
the tables are not the best, previous solution had
been better
Accepted
It is not appropriate to
insert large numbers of
references in the text, the
full list is now given in the
Appendix.
Accepted
Text changed
Accepted
Text changed
Agree, but we need to
agree with TNO
Accepted
The detailed tables provided even though

numerous are user friendly and allow the user to
be able to calculate upper and lower estimates of
emissions for each gas. It may be possible to
included all the info in one large table however, it
may become too cluttered and diificult to use.
There appears to be some discrepancies with the
livestock categories used in 4B and 4D. Suggest a
closer look at the discriptions in the emission factor
database especially for cattle sub-categories.
Rejected
This is not the view of the

great majority of
respondents, and for the
final version we propose
having the detailed tables
in the Appendix
Remove tables to an appendix (correcting the EFs

for PM where appropriate) and replace the text and
tables from the original draft, adding more
Accepted
Have done this. Nicola,

can you please see to EF
corrections
I am afraid the units for NMVOC, PM10,PM2,5 are

not quite clear for me - for all these parameters is
"kg NH3 per AAP"correct? This concerns tables
3.1 to 3.15
Editorial

about tables?!
Tables: References inconsistent with Chapter 5
Editorial

about tables?!
change units for NMVOC, PM10, PM2.5 from NH3

into appropiate units
Editorial

about tables?!
Explain abbreviation "AAP" (explanation comes in

the next section, but should be given when AAP is
used for the first time)
Why are the last two rows relevant? The same
remarks goes for every table 3-.
Done
Can't change the table
template
Accepted
Rejected
The reference publication Reidy et al, 2007 is

mentioned as basis for the values presented in the
Guidelines 2008 draft for tier 1 NH3 emf (on pages
12 till 17 in Tables 3-1 till 3-15) and for tier 2 NH3
(on pages 24 till 31 in Tables 3-16 till 3-30).
However, it only provides some (not all, yard
values are not included) tier 2 data for dairy cows
and fattening pigs. It is unclear what is the basis
for the tier 1 emf for all animal categories (not even
for dairy cattle and fattening pigs the chosen
defaults are presented in Reidy et al, 2007). Also is
it unclear what is the basis for the tier 2 emf for
other animal categories than dairy cows and
fattening pigs and for the tier 2 Yard emf for dairy
cows and fattening pigs.
It is recommended to make clear what the basis is
for all chosen emf (to provide information on the
publications where these data originate from).
(specifiek place in the tekst: page 12, line 5 to
page 17, line 2 and page 24, line 16 to page 31,
line 2)
Accepted
More references given
Table 3.1 and all other. 95% confidence interval is

often the same and should prefrenctially be given
as +-xx%. Especially to avoid upper emission
levels above 100.
Nicola, can you please see

to this
Check units of Table 3-1

same comment as for dairy cattle
PM is higher for FYM then for liquid systems
fattening pigs
Accepted
Editorial
Noted
Noted
PM10 EF values presented seem to be not in line

with values used by the Netherlands for several
animal categories. However, since the basis for the
pm10 emf is rather unclear it is very hard to make
a good comparison. See below questions on
categories included and on the time spend in the
meadow:
Pm10 EF values in Tables are not always clearly
based on table A3-5 in appendix: eg eg for
fattening pigs, sows and laying hens in Table A3-5
2 different values are presented for 2 different
housing types, while in Table 3-8 en 3-9 (page 14
and 15) only one (mean?) value is presented for
the different systems.
Noted
please lower PM2.5 because these figures are
now higher then PM10
Noted
PM is higher for FYM then for liquid systems for
Noted
sows

about tables?!
For PM10 (Table 3-12) emf are provided for all

manure management systems. Since there are big
differences in the two manure management
systems cages and perchery) it is recommended to
provide emf for the two management systems.
Accepted
please differentiate within poultry for solid
(bedding) and liquid systems
Rejected
Cleaning period: the unit (in day) is lacking
Accepted
better to add in the table also a definition of nround = average number of production cycles per
year
n-places: add usually occupied
Empty period: I prefer to add "average" duration
during the year.
The distinction between

cages and perchery is in
the new table
Not for Tier 1
Unit inserted
Accepted
Accepted
Definition inserted
Definition expanded
Accepted
average' inserted
The link to FAO Production Yearbook is:

http://faostat.fao.org/
Under item Latest news FAO Statistical
Yearbooks 2005/2006 (issue 1 and issue 2) are
available.
Issue 1:
http://www.fao.org/statistics/yearbook/vol_1_1/inde
x.asp and Issue 2:
http://www.fao.org/statistics/yearbook/vol_1_2/inde
x.asp
(Livestock numbers are available from Issue 1,
Table A9).
Please note that the yearbook is updated on an
annual basis. Providing the URL
http://faostat.fao.org/ is probably the best.
(Just a thought regarding section 3.2.3 Activity
Data (line 4-6) if a country do not carry out
annual surveys on animal numbers how would
ESTAT or FAO get these numbers?)
Check definition with earlier explanations on p 4
(line 23-26) and p. 11 (line 26)
Accepted
Accepted
Sometimes the two sources of activity data

information do not match. EUROSTAT information
for european countries is updated every year and
have definitive data available. FAOSTAT important
source, but nowadays data available only till 2004
year. Probably the best is to encourage at first
national statistics and after other sources.
Accepted
Same comment: define is using Average Annual
population or annual average population
Editorial
References included.
Thanks to the reviewer
Text amended to be
consistent
Have amended wording

slightly to reflect the
comment
Done
Rejected
No, statement made that

default based on surface
application and open
stores
The formula should be elaborated further. For most

animal types AAP is given in the national statistis.
For animals having a life cycle> 1year, the cencus
in most countries thus takes into account empty
places. The formula is therefore more a correction
formula for amimals haveing a life cycle <1year.
The same is valid for the subsequent formulas.
Accepted
This section has been rewritten to make clearer
Are there no activity data on storage and

spreading to be mentioned here?
I prefer to have the methodology to estimate

animal number/acivity data before the
methodology for EF
"present on a particular day (will).."
(A)nnual agricultural cenus (data) can supply (this
information)
Rejected
Editorial
Editorial
"seasonal production cycle(s), "

"is seaonal or because the (housing) is being
cleaned"
Table 3-1 (to Table 3-15)
after the word "rounds" specify per year
Rejected
Third method seems second method

default data for N excretion: where?
Rejected
Accepted
Editorial
Editorial
Accepted
The TNO chapter structure

does not allow this
Done
Sentence changed with
other comments
Grammar was already
correct
Done
Done
Done
No, there are three
methods
Reference to table given
The basis for a Tier 2 approach is mentioned in

line 14-16. In these calculations its not exactly
clear if a breakdown of the different livestock
categories (cattle, pigs etc.) into sub-categories
(e.g. sows, piglets etc.) is taken into account.
However from sections 3.3.1 Algorithm + 3.3.2
Technology Specific Emission Factors it appears
that different livestock sub-categories are taken
into account. Perhaps the introduction of section
3.3 could be a bit clearer on this.
Rejected
Text has been substantially

revised so comment no
longer relevant (Step 1
onward)
For PM emission is mentioned that "For grazing

animals the grazing season and the daily grazing
time is needed" BUT at page 9,7 is written that PM
emission from "cattle, pigs ect. are considered to
be negligible during grazing"??
Accepted
The time spent grazing is

needed in order to
accurately estimate the
time spent in the building
where most emissions
take place. This is now
made clear.
Suggest deleting the heading PM and begin the

paragraphs as follows: " In the case of PM,
information is required."
The guidebook template

requires clear subheadings
Rejected
No information on application required?
Rejected
Text amended in response

to previous comment to
state that default based on
surface application and
open stores
activity data listed under the heading PM are not

only required for PM emission estimates but for the
other gases as well
Rejected
Yes, to confirm specific

requirements for PM
emphasis only on livestock numbers; much more

activity data are needed for an accurate inventory;
give those more room in the chapter
Rejected
Yes, but this is for Tier 1,

the need for activity data
emphasised in Tiers 2 and
3
information on manure treatment is needed,

please add this to the list
Rejected
Manure treatment is not a

major factor in national
emissions
formulate stronger e.g "Tier 2 is RECOMMENDED"

instead of "proposed"
Rejected
Text has changed and the

passage referred to
removed.
Why is PM mentioned separately, this infromation

is also needed for other components?
Rejected
section 2.1.1 where is it?
Editorial
Yes, to confirm specific

requirements for PM
Changed with earlier
comment
"PM" - misprint ?
Noted
In which way are soil PH included?? - is this shown
Accepted
in figure 2-1 (process scheme)?
Not sure about this - J

please could you take a
look
Reference to soil pH
deleted
Remove this Tier 2 description and replace with

the text from the original draft (i.e. With more
explanation and without the formating errors)
Accepted
The original text has been

re-inserted, with some
improvements
Remove this Tier 2 description and replace with

the text from the original draft (i.e. With more
explanation and without the formating errors)
Accepted
See comment to page 17 line 19.
Accepted
This chapter heading can be left out. Instaead

emphasize that Tier 2 is just ammonia (although
already mentioned in line 32).
"the types of stores in which (manure) is
kept.."
Accepted
PH = pH
I do not understand why you mention soil PH? Key
variables are not shown in Figure 2-1
after N excretion: add : and TAN or UAN
Table 3-1, section 3.3.1 and also many times in the
following: the ref is wrong or lacking
Duplicate of row 103

above?
Accepted
Accepted
Done
comment
comment
Reference to soil pH
deleted
done
Accepted
Nicola is dealing with this
Accepted
Accepted
mexcreted is not a self-explaining symbol for total

nitrogen excreted, it seems total matter excreted, it
would be better to use mNexcreted, by analogy
with mTAN
Accepted
after milk add "eggs or offspring"
Accepted
Changed to mN excreted
Done
It seems to me, references to Tables 3-1 and

Paragraph 3.3.1 are wrong
I would prefer to find IPCC equations10.32,10.33
right in the Guidebook,
Rejected
Nicola, can you check

table references once we
finish the text
We should avoid simply
repeating IPCC text
Accepted
The derivation of the

approach is given in
section 3.2.2.1
The source of the stepwise approach should be

cited.
Treatment of units: "kg N a-1" means kilogram
newton per year!
Table 3-1 does not exist in that form
in IPCC organic matter is defined as Volatile
Solids: wy not to use the same here?
Accepted
Accepted
Editorial
Rejected
changed to 'kg a-1 N'

Need to sort out the tables
in these steps
The sentence referred to
has been superceded
it is not clear how do you use xfaeces and xurine: I

suppose xurine is not the same as xslurry and x
faeces is not the same as xFYM. So it is not clear
how to translate xfaeces and xurine in mTAN;
Accepted
proportion of total excreta or proportion of total N in

excreta? (is the assumption that Nitrogen split in
the same way as mass into faeces and urine?)
Accepted
mfaeces: definition?
Accepted

Defined
use the same symbols in the text and in the

formulas: mTAN_slurry is mbuild_slurry,TAN? Etc. Accepted
I would prefer to see IPCC equations10.24 right in
the Guidebook
Rejected
Where is table 3-3?
Editorial
check subscripts
Editorial
And how should we calculate x(Nfaeces)?
Accepted
I would prefer step 7 to be grazing. This manure is

not in storage
Rejected
any references for the value of fmin?
Accepted
Same symbols now used

Reference to equation no
longer made
in these steps
J - there is now a missing
equation - would you like
me to renumber these?
This section amended to
make clearer
To make step 7 grazing
would interrupt the
sequence from excretion
through housing to storage
and then to application.
Reference inserted
at this point of the calculation xFYM is the

proportion (without bedding!) of manure excreted,
handled as FYM. I believe it woul be better specify
that the proportion is in mass (kg/kg) and that it
doesn't take into account the bedding material
Rejected
mbedding don't appear in the formulas
Rejected
any references for the value of fimm?
Accepted
Where are Tables 3-3 and 5.9?
Table 3-3 shows Tier 1 emission factor for Other
Cattle on slurry which give no relevans in the text
describtion.
Editorial
Have checked formulae

and they do account for
bedding
It appears in Eq 23
Reference inserted
in these steps
Rejected
Nicola, when re-drafting

complete please check
accuracy of references to
Tables

describtion.
Rejected
Appendix Table 5.9??
Rejected
Appendix Table 5.3??

Do you have a refence for 0.68?
Do you have a refence for 0.1?
Rejected
Accepted
Accepted
mm (storage,org) or mm (storage, N)?

" it does (however) require much more."
Accepted
Editorial
Rejected
Editorial

Tables
Not according to one of
the other reviewers
It was supplied for the
review!
review!
review!
Which is what we have
written!?
Done
Rejected
The evidence we have

indicates that there is a
reason

describtion.
Would a formula not normally be written as: Kg
NH3-N a-1 ??
Rejected
the active axcel file is necessary!!
Accepted
Does Appendix B exist?
Rejected
Do there exist an Appendix B?

The ammonia emission report unit in NFR is NH3
and not NH3-N
Wher is Figure 1-1?
Rejected
As the EF is a percentage of TAN, there is no

reason to differentiate in EF yard and for grazing
between dairy cows and other cattle

Tables
Incomprehensible
comment
Incomprehensible
comment
Reference inserted
Reference inserted
mm storage N, correction
made
Done
Rejected
Remove tables to an appendix and replace the text

and tables from the original draft, adding more
Accepted
condensed form.
Accepted

Have not yet placed
agree this with TNO
now provided
same remark regarding the terrible table
Accepted
The concise tables have

been restored and we
propose the template
tables go to the Appendix
Accepted

Have not yet placed
agree this with TNO
To many tables - all data could relativly simple be

represented in one or two tables without missing
important information.
Only emission factors for dairy cows and other

cows are included. Emission factors for other cattle
sub-categories are required here. See comment 14
for further issues.
Rejected
The Guidebook only needs

to cover the NFR codes.
Section 3.4, Tier 3 states
that 'if data are available,
emission calculations may
be made for a greater
number of livestock
categories than listed
under Tier 2'.
Remove tables to an appendix and replace the text

and tables from the original draft, adding more
Accepted
Have re-inserted text and

concise tables
The chosen tier 2 default emf NH3 in the Tables 316 till 3-30 on pages 24 till 31 seem to be an
average of the figures presented in the appendices
page 48 till 50 (Table A3-1 a till d). However there
are some deviations: Yard emf are not available in
the appendix Tables and a figure of 0.15 is
presented for broilers (one value only for the
Netherlands), while in Table 3-28 a value of 17 is
presented. What's the basis for this figure?
Accepted
Further footnotes now

added to new summary
tables
Check proper width of cells. Why are last two rows

relevant?
Editorial

about tables?!
Now it is NH3-N conversion despite the formula

consists of "Estorage, NH3". It should be changed
in all formuals to "Estorage, NH3-N".
Rejected
This equation no longer in

chapter
All tables has the unit as %TAN. It should

preferentially be "% of TAN" and no 95% upperlimit
above 100%
Rejected
We think the meaning is

clear
All tables could be written more easily. To much

unnessary data
Figure 1-1 not presented in the document
same comment as for dairy cattle
Editorial
Editorial
Rejected

about tables?!
Done
And the same riposte
Editorial

about tables?!
Rejected
Source of EF now given
Rejected
Accepted
Source of EF given
EF added using UK data
Is the manure of the laying hens considered

always as solid manure and not slurry?
Rejected
We do not think there is

enough evidence to
discriminate
broilers and other poultry are mostly kept on solid

manure systems, so here no need for EF liquid
systems
Rejected
I cannot see that we have

an EF for broiler slurry (?)
Table 3-29 - no data for "other poultry"??
Editorial

about tables?!
(Table 3-29 Other poultry) no figures are included.
Accepted
Corrected
not "Other cows" but "other cattle"

the EF for yard is extremely high and not
explainable, so please adjust to 53
the EF for grazing is too high, so please change
into 10
There is no EF for outdoor sows?
(Table 3-27) emf are provided for all manure

management systems. However, since these
figures are based on the Appendix tables it turns
out that only solid manure is included. Since liquid
manure systems (cages) still exist and since their
emf are different from solid manure systems, also
liquid manure management emf should be
provided.
Rejected
please make a differentiation into solid (bedding)
Rejected
and liquid.
Check Values and confidence interval in table
3.3.3 Abatement: why not Controls as in section
2.4? Abatments seems more appropriate to endof-pipe techniques
add a reference to Appendix A3
Accepted
Not enough evidence to

differentiate
Not enough evidence to
differentiate
Nicola, can you please see
to this
Rejected
Accepted
This section is specific to

the incorporation of
abatement techniques in
the calculation
Done
As it seems to me, table 10.19 of IPCC chapter 10

Default N excretion data is necessary to be
included in the Guidebook
Rejected
All inventory makers surely

have IPCC available as
well (and can look the
default values up)
As it seems to me, paragraphs 3.3.3 and 3.3.4 are

not complited
Accepted
Text now amended
No technique to reduce emissions in livestock

houses? In the ILF BREF there is a long list of
BATs for animal houses..
Accepted
The section now makes

reference to housing
techniques in UNECE and
BREF docs
The EF for inside storage and outside storage

differ, mainly due to differences in temperature.
Moreover by removing the manure quicker to
outside, is an abatement technique. As I do not
have the data from Reidy et al, I cannot check the
presented EF. If necessary I will be helpful to
elaborate this in more detail.
Rejected
after "storage" add "and after field application"
Accepted
The intention was to put

information on activity data
specific to the Tier with
that Tier
And manure application
inserted
Reinsert sections for the different polluntants.

Remove second paragraph (not valid for all
abatement measures (eg optimised feeding)
Accepted
Have done
Accepted
Table in Appendix gives

cross reference to IPCC
definitions
I dont't understand why this section is here and not

within 3.2.3
Rejected
Refer to IPCC data on manure management

systems
Likely the choosen approach is that most of the

animal manure does not stay for a long time inside
the animal house and is stored outside.
Rejected
This reviewer has the opinion that a lot of
European animal production systems store their
manure inside the animal house
Referer to Appendiks A - chapter A.3.1 for further
information
Reinsert sections for the different polluntants.
Fair commenr, but text

already covers this
Rejected
Contradicts previous
comment
Accepted
Accepted
Done
Have done
add abatement measures from the house
Accepted
Reader referred to
Appendix and other
documents
not only housing activity data are relevante, but

storage and spreading as well; please add these
Accepted
I cannot find these notes in the Tables?

check subscripts
Accepted
Editorial
done
The concise tables have
the footnotes
Done
Abatement deals with ammonia only
Rejected
Because there is only a

Tier 2 method for
ammonia
Is the formula correct? The value calculated is my

view an implied emission factor and not an EF for
abated techonlogy. N_abatement is not defined.
Rejected
Formula no longer used
see remark 13 about differentiation of inside and

outside storage
Accepted
Emissions are not solely governed by fouled area.
Change formulation?
Accepted
There is no restriction on the form of Tier 3,
provided it can supply estimates that are more
accurate than Tie 2.
Mentioned an example of double counting.
Accepted
Accepted
Text amended
Paragraph re-worded
Have re-worded to make
this point.
Example now given
Same comment: for european countries the best

cross check is to be done with EUROSTAT
information. FAOSTAT statistics at this moment are
not updated.
Accepted
Changed as suggested
Probably an example of "manure management

sub-categories within the livestock categories"
could be useful. Otherwise, define it in Figue 3.1 or
at page 18 line 27 where this term is used.
Accepted
Example now given
There is also a figure for overall uncertainty in the

Netherlands, using a Tier 3 approach. The Dutch
uncertainty is 17% (TNO, 2004)
Quoted uncertainty now

included, Nicola, can you
please find the full
reference
Accepted
TNO, 2004. Uncertainty assessment of NOx, SO2

and NH3 emissions in the Netherlands, TNO report
R 2004/100, TNO, Apeldoorn
Accepted
Quoted uncertainty now

included
In the text is mentioned "Consequently, there are

large uncertainties associated with the default EF
for this source". BUt no NOx defalut value is
recommended - not even for Tier1 methodology.
Accepted
Text reworded to refer to

emission estimates, not
specific EF
also in Mol and Ogink 2004 (see also remark 22)

MS(T,S) ??
Rejected
Rejected
No need for action

These terms are defined
it is not clear from the previous methodology that

the emissions from grazing animals have to be
reported under 4D. How could you do it in the case
of tier1 methodology? If I understood it correctly, it
is necessary to highligh somewhere else that you
make the calculation under chapter 4B and to
report the results under chapter 4D
Accepted
why are these sentences reported under "external
review?
Accepted
This has now been made

clearer at the beginning of
the chapter
The statement has been
deleted
Has this been copied directly from the IPCC

guidelines? It contradicts the statement p3, l 1 - 9
where all NH3 emissions are reported under
manure management and not under soils.
All references should be available on the internet
at EEA homepage
The statement has been

deleted
Nicola, can you check this
with TNO
Accepted
Accepted
van Fassen etc should read: Van Faassen, H.G.

and Van Dijk, H. 1987. Manure etc In: H.G. Van der
Meer, R.J. Unwin, T.A. Van Dijk and G.C. Ennik etc Noted
no overview for ammonia?
Accepted
Reference seems to have

been removed
Now added
PM definitions are not target orientatet.Its a

mixture of differnt defin. Ist to separate why in the
past other defin. Are used and which will be used
in the future. The relevant difference in
comparision with gases should be explained.Its
nice to see my figure(A1-1)but no quoting?
Noted
I miss some further describtion for NH3 and NOx
Accepted
Now added
Rejected
The revision now gives a

more coherent balance
between chapter and
Appendix
Amount of science in the Guidebook is just right,

but it is better to place it in one place, it is
unimportant where -in the main body text or in
appendix
the Appendix is toolong.The author could not

decide wether he gives information(scientific(in the
body or the appendix.
Accepted
The Appendix is now

shorter
General: Why is this information in the appendix

and other information in text. When is it
background information and when not? Choice is
not clear and seems arbitrarely. Please explain
protocol or change the way information is
presented without shattering.
We have restored much of

the explanatory text to the
main chapter and now
think the division between
text and Appendix is
coherent.
Accepted
The appendices are misplaced and should be

included at the end of the agriculture chapter (i.e.
after 4G) in future drafts.
Rejected
A clear guidebook definition of "Inhalable dust" and
"Respirable dust" are needed.
Noted
Appendices will require revision, since some
material will be moved from the current appendices
back into the body of the text
Accepted
Appendices will require revision, when comments
Accepted
above have been taken into account
It makes more sense to

have the Appendices
closer to the main text
Discuss with JG - put into
the GG chapters
Caption: "aerodynamic" instead of "airodynamic"

Noted
This paragraph appears to be misplaced. Suggest
re-wording
Rejected
Have done
Appendices have been
revised
J - is this correct? Is this
your graph to change?
Panel Chairs are happy
with text
why the information here are related only to

grazing?
"measured" instead of "made"
Because this is the

Appendix where we
include specific additional
information
Done
Rejected
Editorial
For cattle housing system values on pm10 EF are

lower for litter (=solid manure=FYM) compared to
slurry. This is in contradiction with the text on page
44 line 38 (section PM), which says that it is
expected to find higher pm10 emissions from litter
compared to slurry. This was also found comparing
English dairy cows with litter to German dairy cows
in cubicles (slurry).
Directly below this alinea (page 45 line 8) this is
once more contradicted by the remark that cubicle
houses (slurry based) give higher pm10 emissions
compared to litter based systems (depending on
several factors). This is in line with the presented
pm10 emf. However, no reference is presented
here. Where are the default pm10 values
presented based on then?
It is recommended to rewrite this text to present a
clear line of reasoning.
Noted
In a deep litter system PM emissions can be
reduced by 50% because the dust is incorporated
into the bed and held there because of moist.
Activity of animals will not have an effect anymore:
CIGR-working group No 13 "Climatization
Environmental Control in Animal Housing". 1994.
Aerial environment in
animal housing. Concentrations in and emissions
from farm buildings. CIGR-rapport Report Series
No.
94.1, CEMAGREF, Groupement de Rennes,
Rennes Cedex, France, 116 pp.:
Accepted
Why this sentence is here and not at page 46
under Reduce emissions during and after
landspreading?
landspreading instead of spreading
please give the source of table A2.1, Expert Group
on Ammonia Abatement
"Emissions following (the) spreading (of)
manures.."
please give the source of table A2.2, Expert Group
on Ammonia Abatement
Asterix and "a/" not explained
it has to be specified which values are expressed
as %TAN or % total N
Table A3-1 Where is the note explenation?
Reference?
The notes in the table (1,2,3 in the first row of the
table) are not explained
Table A3-1 There is no text ontroducing the table.
In which way can this table be used?
Have incorporated
comment. Nicola, could
you ask TNO for the full
reference to CIGR 13,
authors etc, it seems to
have got cut off in cell H
48
Rejected
Accepted
Because this is where we

discuss management
done
Accepted
Reference now given
Accepted
Sentence expanded
Accepted
Accepted
Rejected
Reference now given

Now explained
TAN, Table heading
corrected
The notes are redundant
and have been deleted
The notes are redundant
and have been deleted
Accepted
Now added
Accepted
Rejected
For NH3 as far as dairy cows and fattening pigs

are considered, the figures presented in the
appendices should be the same as those
presented in the publication of Reidy et al, 2007. In
general this seems to be the case. However, there
are some deviations. Some examples:
in Appendix Table A3-1 b storage a figure of
19.2 is presented for dairy cows in the
Netherlands, while in the Reidy et al, 2007
publication a value of 16.3 is presented (for both
models). Is the value of 19.2 wrong or is it based
on another publication?
in Appendix Table A3-1 grazing for the
Netherlands and the UK a figure of 13.3 and 7.7 is
presented for dairy cows respectively, while in the
Reidy et al, 2007 publication a figure of 13.6 and
10.0 is presented.
in Appendix Table A3-1 housing for the UK a
figure of 33.2 is presented for fattening pigs, while
in the Reidy et al, 2007 publication a figure of is
presented.
We recommend to present and provide all
references used.
Accepted
Use full text or abbreviations of countries, not both
(Netherlands = NL and not Nl)
Accepted
the title of table A3.1 is misleading with repect to
the EF, or it is % of TAN either % of total N
available. Maybe an additional column is desirable.
Please give also the corresponding references
Accepted
Numbers in heading not explained
Rejected
Are the emission factors expressed as %TAN or
total N available.
Accepted
References for each

national Inventory now
given in the Appendix
All countries now full text
Heading clarified,
references given
Numbers now deleted
Made clear it is % TAN
For PM10:
It seems from table A3-5 that the EF for dairy
cattle are valid for dairy cattle with a weight of 500
kg. So if there is information on the mean weight of
cattle categories a recalculation could be made.
However, Table A3-3 and A3-5 are not in line with
eachother: according to Table A3-3 calves have a
weight from 50-100 kg, while in Table A3-5 they
have a weight of 150kg. Beef cattle is not
mentioned in Table A3-3. Since young cattle in this
Table has a weight between 450 and 650 they
cannot be compared with the beef cattle in Table
A3-5 (weight of 350 kg).
It is unclear what transfer factor should be used.
For young cattle it says in Table A3-3 0.6 till 1.2; so
for the lower weight of 450 kg the lower transfer
factor of 0.6 should be used. But in Table A3-5 for
beef cattle with a weight of 350 kg a conversion
factor of 0.7 is used!
For cattle it is unclear whether in the EF pm10
presented the time spend in the meadow is taken
into account? If it is, how has this been done. And
if it hasn't how should this be done?
Accepted
The tables are now

consistent in their use of
livestock weights
please change the liveweight for calves into 50 to

300 kg
Accepted
calf weight now 50-150,

transfer factors scaled
accordingly
Accepted
These factors are

explained in the text
above. The uncertainty
and need for more work
are acknowledged
Transformation factors for poultry don't make

sense?
this reviewer does not agree with the conversion
factor of 1.0 for poultry. Takay et al, 1998 gives
information over the conversion factors even for
poultry.
"Seedorf and Hartung, unpubliched" - cant find
this reference on the reference list.
Noted
Noted
the conversion factor for fattening pigs is here 0.16

and in table A3.3 0.12. Please change it into 0.12 Noted
A lot of EF values for PM2.5 are physically
impossible. RD is measured as PM5.0 and should
therefore be higher then PM2.5. So, please lower
the PM2.5 values for dairy cattle, beef cattle,
calves and weaners
Noted
as a consequence of the remark on conversion
factor of 1.0, the PM10 and PM2.5 values for
laying hens and broilers should be lower
Noted
Hyphenation "Fattening pigs"
Rejected
Not hyphenated anywhere

else
What are information in Table A3-7, Table A3-9,

Table A3 and Tbales on page 57 used for??
Rejected
To provide supplementary
information
Passive composting: for the IPCC equivalent

seems more appropriate "Composting - passive
windrow"
Accepted
Done
What is reference for the values in this table? As a

General comment I want to add that literature
references are sometimes given, but not always.
Accepted
I suggest to consider including all IPCC references
right in the text
Rejected
Table heading now given

and referred to in text.
It should be considered to move some of the more

scientific description in appendix to the main text.
E.g. explaining why the NMVOC emission is an
important environmental issue.
Accepted
Have restored much of the

text to the main chapter
It is nessary to explain much more in detail the

difference between Tier 1 and Tier 2 in the
emission factors because they are so
fundamentally different. Is NH3 in Tier 1 converted
to NH3 from NH3-N? Spend much more space on
explaining the emission factors in Tier 2 and the
difference between slurry and solid. Explain why
NH3-N is used in Tier 2 compared to Tier 1.
Accepted
The restoration of text now

gives more explanation
It is a big confusion between NH3-N and NH3.

Sometimes is NH3 reported and sometimes is
NH3-N reported. Please clarify.
There is no confusion, Tier

2 calculations have to be
as N, but reporting has to
be NH3-N
Rejected
The chapter on manure management is not very

well written. There is a strong need for clear
references, a better explanation of the complex
system with N and ammonia. It looks like that there
should be no dublicate between this guidebook
and the IPCC 2006However, for clarification there
could be some tables on Nex for typical animal
types. Stabletype distribution from the RAINS
dataset etc. to give more information on the basic
situation in many countries. And reduce the
number of tables because they are really
unessesary in many cases.
Accepted
Much of the original text

has been restored to
improve clarity
General comment. National agriculture inventory

consistency (CLRTAP-UNFCCC): Is this new
CORINAIR update methodology (Tier2) for manure
management compatible with the IPCC 2006?
Rejected
General: Reference to Appendix A (see Appendix
A) is not consequently done looking at
corresponding chapters in the appendix, please
check. Also check table numbers
Accepted
These cross references

have been corrected.
Nicola, when finished can
you double-check.
Units for PM are wrong not kg NH3

General: References to tables and figures in the
text are not correct, please check.
General: I miss Table with notations
Editorial

about tables?!
Editorial

about tables?!
Editorial

about tables?!
Accordning to the reporting purposes Tier 1 and

Tier 2 methodologies will be used. For comparision
needs it will be necessary to recalculate the
emission values
Rejected
Don't understand what is

meant by the comment. It
is no more than a
statement not appearing to
require an answer.

emission values
Rejected

is no more than a
require an answer.

emission values
Rejected

is no more than a
require an answer.

emission values
Rejected

is no more than a
require an answer.

emission values
Rejected

is no more than a
require an answer.

emission values
Rejected

is no more than a
require an answer.

emission values
Rejected

meant by the comment.

emission values
Rejected

meant by the comment.

emission values
Rejected

is no more than a
require an answer.

emission values
Rejected

is no more than a
require an answer.
NF3 4.D.1 is not agricultural soils. It should be 4.D Accepted

Accepted
Done
Done
Same remarks in generall as given for 4.B. I am

not happy with th PM
In the absence of concrete

suggestions for
improvement..
Rejected
Specify where have to be reported emissions from

grazing animals. It is not clear if they have to be
calculated and reported under 4B or calculated
under 4B but reported under 4D. The same for
manure application
Accepted
NFR 4D and CRF 4D codes do not include the
same source categories: Application of manure to
soil and production of animal manure in the
meadow is not included in NFR 4D while it is
included in CRF 4D.
Rejected
Editorial comment not removed
Accepted
Persistent Organic Pollutants - what could this e.g.
include?
Noted
In the overview emission from legumes is
mentioend. In the text separat NH3 emission from
legumes are only included in Tier 3 approach - is
that correct?
Accepted
In the overview harvesting is missing

this appendix is missing
Accepted
Accepted
Emissions occur from both soil and crops!

Rejected
Reference to the chapter where they are dealt with
is missing.
Accepted
the PM10 emissions reported in the table = 0 are

in contrast with the sentence page 23 line 33.
Does the value = 0 in the table mean that the
emissions are not estimated?
Noted
Add more detail about processes
Rejected
Text inserted to explain

and cross-reference
Clear explanation given in

text
Done
EF for legumes now

restored
Harvest mentioned in 2.1.4
Text already includes
crops
Have changed data using

updated webdab
emissions sent by Anne
Wagner. NMVOC
emissions are now at 4%
of total so is in contrast to
what it said in the previous
paragraph.
The detail is found in the
text below
add also in the heading: for EU-27

Delete process diagram - deal with processess by
pollutant not source
Accepted
Done
Noted
Done
Accepted
Earlier text now restored

as appropriate
The Emission section should be expanded and

structured according to pollutant not source.
Include some of the omitted text from earlier drafts Accepted

as appropriate
Good figure to give an overview, but maybe more

useful to describe the different emission sources
based on each substance.
Needs much more scientific background

information on emission of NO, NMVOC and PM.
explain the variables
A paragraph on NO emissions is missing
appendix 4, where is it?
Accepted
Accepted
Accepted
Noted
and soils' should be added to title
Accepted
The appendices have disappeared!

Accepted
A paragraph on PM emissions from soil cultivation
is missing
Noted
Suggest removing the sentence "The effects of Efs
from grassland"
Accepted
NH3 emission from growing crops are mentioned
in section 2.2.3. Are this NH3 emission short after
apllication of fertiliser included in the
recommended Tier 2 emission factors?
Accepted
This reviewer does not understand why a double

EF for grassland is needed in comparison with
arable land. There are also arguments that the EF
for arable land is higher due to for instance the
absence of a canopy. Please give more
explanation.
Accepted
nothing found about Pm
Accepted
CAN not explained
Accepted

as appropriate
Now done
Now inserted
Included in this version
No longer relevant section
has changed.
Possibly no longer
relevant?
Included in this version
Now deleted
yes.
More explanation now

given in text
Text restored
It is now
In the suggested protocol, the NH3 emission factor

for N fertilizer application to grassland is a factor 2
greater than for arable land. The higher emission
factor for grassland is based on reviews by Van der
Weerden and Jarvis (1997) and Harrison and
Webb (2001). However, the study of Van der
Weerden and Jarvis (1997) is a paper in which flux
measurements on grasslands were carried out. In
this paper, there is only one reference of a study
on arable land, i.e.. a study of Black et al. (1984) in
New Zealand in which losses from urea applied to
grassland and arable land were compared. The
paper of Harrison and Webb (2001) is a review
paper. However, they only refer to the paper of Van
der Weerden and Jarvis (1997). Thus, the
difference in the emission factor between
grassland and arable land is based on only study.
By contrast, in a review Bouwman et al. (2002) of
148 research papers it was concluded that the
mean NH3 emission from grassland is 20% lower
than for upland crops (the balanced median
showed almost no difference). This paper was not
used for the guidebook.
Thus, there is no firm scientific basis to use
different emission factors for grasslands and
arable land. The grassland area in Europe is high
and therefore the underpinning of higher emission
factors for grassland must be scientifically sound.
Moreover, from a theoretical point of view (i.e. the
effect of crop on wind speed and thereby on NH3
emission) it may be expected that there are arable
cropping systems with lower emissions (i.e. when
N fertilizer is applied to high crops or when N
fertilizer is incorporated) and higher emissions (i.e.
when N fertilizer is applied to the bare soil just after
planting or seeding).
Noted
why the Efs of the different fertilizers which where
reported in the old CORINAIR handbook are not
used here? The consumption of the different
fertilizers is normally available at a national level,
so a better estimate is possible
Rejected
Tier 1 method for unfertilised legumes is missing
Accepted
Deafault values in the body of the text and detailed

tables according to the needs as an appendix.
Rejected
According to EFMA consumption for 2006/, urea is
the third most used, after CAN and AN
Accepted
The 3 in NH3 should be subscripted
Accepted
Use chemical notation not words (e.g. for

ammonia)
Accepted
Tier 1 agreed with Panel

Chairs
The EF for legumes now in
the text
Not Tier 1
Text amended
Done
Section has been rewritten but instances of
words rather than chemical
notation
The unit for NMVOC is defined as kg NMVOC/kg

crop - is it kg harvest crop?? The equation (page 6,
line 7-8) is mentioned use of crop area (ha??)
Rejected
Reference now made to

the Appendix where more
information is provided.
A default emf of 2.57 kg NO per kg fertilizer-N

applied is presented (reference Steinbrecher et al,
2008). It seems the wrong unit is used here. If
2.57% is meant (= 25.7 g/kg fertilizer N) it is not
clear how this could be in line with the value of 0.7
% NO-N (equals 0.9 % NO/kg fertilizer = 9 g NO/kg
fertilizer) presented by Stehfest and Bouwman
(2006) and until now also presented in the
Guidebook.
The value of 0.7 is the fertilizer induced emf, but in
the former Guidebook also for cultures without
direct fertilizer (but with crop residues and indirect
emissions as a consequence of ammonia-N
deposition and N-leaching from fertilizer use) this
value is recommended to be used.
Accepted
Why is this value presented with 2 decimal places;
this seems unrealistic concerning the high
uncertainty for NO measurements.
Accepted
Nicola,please change in
template to 2.6
General remark on NH3: Appendices A1-A4 are

not included, so information on assumptions is not
available.
Accepted
Appendices are now in the

chapter
More specific on NH3

(Table 3-1) Tier 1 values are no longer
presented for other fertilizer types than urea. For
countries where urea is not commonly used as
fertilizer and where not enough data are available
to use the tier 2 method also tier 1 emf for the
different types of fertilizer should be available. In
the former guidebook also tier 1 emf were
presented for other fertilizer types (p90 table 4.1 of
the Guidebook). It is recommended present tier 1
emf for the different types of fertilizer. This could
be the former emission factors or new tier 1 emf
derived for different fertilizer types from the tier 2
values.
In the past the urea emf was 0.15 NH3-N
(equals 0.18 NH3 per kg fertilizer N applied).
Based on the current proposed tier 2 method for
urea emf the mean value would be 0.23 (mean of
lowest and highest values for all regions and for
grass and arable land: (0.11 + 0.35)/2). For region
B it should be 0. 21 ((0.14 + 0.28)/2): What's the
basis for 0.22?
Rejected
On basis of table 3-1 in the proposed Guidelines it

is unclear whether the proposed PM10 emission
factor should only be applied to arable land or also
to grassland (at the presentation in Dublin also hay
making was mentioned; this seems to refer to
grassland) and whether the application of fertilizer
and pesticide use is included. It is recommended
to make this clear.
Noted
The basis for the presented TSP, pm10 and pm2,5

emf (Table 3-1) should be the reference publication
Vd Hoek and Hinz (2007). However, this basis
cannot be found there:
No basis at all presented for TSP and pm2,5
emf
For pm10 emf the basis is unclear. From Table
3 in the Reference publication it seems that for
pm10 the highest value (eg 4.56 kg pm10/ha for
oat with no reduction applied of for redeposition of
pm10 on the field) is picked to be used as a default
for pm10 (4.5 in Table 3-1). However, this is not
clearly explained and some questions rise if this is
the case:
-Why is the average value of 0.25 (for soil
cultivation) in Reference Table 3 (and discussed in
the text on page 18) not in line with the figures on
soil cultivation presented in Table 2? Here even
with wet soil conditions the total pm10 emf for soil
cultivation is 5,2 kg/ha. That's a factor 20 higher!
-Why is no correction term applied for rapid near
source deposition?
-Why are the harvesting emf in Table 3 lower
(between 2.0 and 3.4 kg pm10/ha) compared to
the values presented in the text on p 18 (lowest
value 3.3; highest 6.9).
-What's the basis for the values for cleaning and
drying in Table 3
Accepted
The reference publication (vd Hoek & Hinz, 2007)
mentioned is not easily attainable; I had to
approach one of the authors to get it. On basis of
the reference it seems hay making is not included.
Fertilizer use seems to be included, but it is not
clear. Pesticide use is not included. It is
recommended to make the references available.
Rejected
A revision of the guidebook should include the

newest knowledge and lead to more accurate
inventory. I was surprised that the NH3 Tier1
methodology is simpler than given in the old
guidebook and the emission factor is only based
on use of urea.
No equation for Tier 2 methodology?
Equations and legends: inconsistent notation, not
in line with IUPAC
Noted
Accepted
Equation now restored
Noted
done
In tables 3-1 to 3-14 emission factors for NH3 are

presented for the different fertilizer types. It
suggested that these emission factors are all
derived from Harrison & Webb (2001) and Van der
Weerden and Jarvis (1997). However, the
quantification of the effects of temperature and pH
on the emission factors is not found in these
papers.
In the review paper of Bouwman et al. (2002)
effects of crop type, fertilizer type, application
mode, N application rate, temperature, pH, and
other soil properties on NH3 emission are
statistically assessed. This paper maybe a
valuable source for the guidebook.
Reference: Bouwman et al. (2002) Estimation of
global NH3 volatilization loss from synthetic
fertilizers and animal manure applied to arable
lands and grasslands. Global Biogeochemical
Cycles 16.
Rejected
Please indicate clearly in the text that the NH3
emission = 17/14 * EF.
Noted
The NO emission is 2.57 kg NO per kg fertilizer N
applied. This means that more N is lost than the N
input by the fertilizer. This is quite impossible
because about 50% of the N fertilizer is taken up
by the crop
Accepted
The EF should be g/kg Nicola, can you please

amend in the template
table.
It is necessary to explain in the text how the EF for

TSP, PM10 and PM2.5 are derived. If necessary
the reviewer will assist.
Noted
limiting fertilizer to urea only is a step backwards
Accepted
New Tier 1 EF developed
I do not agree with the use of the urea EF as the

default EF. The previous approach in the simpe
methodology in the old Guidebook should be
maintained. Even though the use of urea according
to world fertiliser consumption statistics is currently
approx 50% of total N consumed, it does not
warrant its use as the default. Many counties use
urea only in the spring when weather conditions
are wet and cold and therefore emissions are low.
Using urea as a default in such circumstances
would lead to a gross over estimation of emission
levels.
Accepted
Unit for particulates should be kg ha-1 a-1.
Accepted
at which depth the soil temperature has to be
measured?
Accepted
Done
Text amended to make
clear it is air temperature
More explanation on how to use and apply new

proposed EF is needed as done also in tier2 4B.
Tier 2 equation is missing
Done
Rejected
Accepted
Tier 2 emissions should be calculated using the

actual spring temperature. Replace equatoin and
the original compact version of equation
parameters. Example emission factor tables could
be put into an appendix
Accepted
Original compact table

now restored
It is a bit confusing with so many tables showing

the emission factor for Tier 2 - mineral fertiliser. Is it
possible to reduce the number of tables? Instead
of a table for each fertiliser type, it could be chosen
to show a table from each temperature region A, B
or C (t >13 C, T=6-13 C or t < 6 C).
Accepted
condensed form.
Accepted
Concise tables have been

restored.
Controlling emissions has already been covered on

p 4 and 5
Rejected
Using AN instead of urea may reduce The NO
Accepted
emission. Definition of AN??
abatement without note with PM concern
Accepted
Activity without concern of PM, area treated, yields Rejected
section 2.1.1 where is it?
Accepted
The sentence on expert judgement is not related to

consisten time series, maybe more to Uncertainty Rejected
Yes, but this explains how

account may be taken in
calculating emissions
Abbreviation now defined
at first point of mention
Text restored
Text changed, no longer
relevant
This section has been
added
In this specific case expert
judgement may be needed
for a consistent time series
It is not necessary a specific chapter 4.5.1, put the

sentence under line 21
Rejected
soil N content: where is it used?
Accepted
Is the mentioned uncertainty range (+-50%) for all
substances exept from NMVOC? The uncertainty
range for NO and PM emission is properly much
higher?
This is the agreed format

for each Guidebook
chapter
Now deleted
Rejected
To explain the differences between the default

value and tha national value, a robust bacground
information and documentation for the default
value is needed. Otherwise you do not support and
promote the meber states to use national values. Accepted
is the temperature, which is necessary for tier 2,
the air or the soil temperature?
Accepted
Don't understand the point

that is being made
Air temperature now
specified in the text
IFA - please write the name of the organisation

(maybe in chapter 5 "Glossary"). Are data from this
organisation available for all member states for
free??
Accepted
Now given in full in the

reference list
The reference list include a lot of references which

is not mentioned in the main text. I prosume this
list include the references from the appendices!
Accepted
The references have now

been sorted following the
various revisions of the
text.
Citation inconsistent (e.g. "and")
Accepted
Citations were consistent

in that two authors used
"and" and more than one
author was bloggs et al
For NO the reference Stehfest and Bouwman

(2006) is included in the references (however
misspelled as Stefest and Bowman), but not
mentioned in the text.
Accepted
Spelling in reference list

corrected and relevant text
restored
Missing Appendix A! There are links to this a

couple of places. Its hard to judge references to
activity data when the appendix is missing.
Accepted

Accepted
Not Tier 1
By reading of the draft I really missed the

appendices - especially because the main text
does not content many references or scientific
explanations. At my point of view more specific
scientific description and explanation is needed in
the main chapter. It is very important to know the
scientific documentation for the default value.The
guidebook should not only be useful to calculate
the emission inventory,but also a guideline to find
more scientific information to check the conditions
are comparable with the conditions in the member
states and to encourage member states to
continue the work to develop more accurate
inventory with national data.
Accepted
That each answer max can be 255 characters is
very frustrating
Noted
Noted
No guidelines available?
Rejected
It is rather strange to find an NFR 4D2 here
(animal production) since this source is not
included in NFR4D but in NFR4B
Rejected
Accepted
To my knowledge is there no EU-regulation on agr.

waste burning, only national legislation. This
should be verfied. The text indicate that it is very
easy to burn agr. crop residues and waste in
Denmark. This is not the case. Burning of plant
residue has been prohibited i Denmark since 1990
and may only takes place in connection with
continuos cultivation of seed grass.
Noted
AR is not defined
Accepted
Couldnt the link to FAO Production Yearbook
(FAO, 1991) be updated?
Accepted
EF for NH3 missing from table
Accepted
A source published in 1991 is inadequate.
Accepted
Table 3-1. There should not be different units in a

table, ie.kg/ kg dry matter and kg/ tonne. It will give
errors in the reporting
Noted
Not Tier 1
No page reference given
No page reference given
We know, the object was

to point out that under
some circumstances
burning may take place
Done
Yes, up-to-date reference
given
J - should there be any Efs
for NH3 in this chapter?
Yes, up-to-date reference
given
The comment specifically
refers to agricultural
activity data, so reference
to forest fires is irrelevant
Table 3-1. There are errors in the data. Generally

contains crop residues (straw) 0,3% N or eqv. to
1.2% NOx after burning if all N is emitted as NOx.
Tier 1 indicates that 24% is NOx or that at lot of
inert N2 is conveted to NOx.
If default N/C ratios are given in the IPCC
guidelines why aren't they included in table 3.2
which have the same origin?
Tier 2 does not appear to provide the basis of
better estimates than Tier 1. Remove Tier 2
Noted
Because they are not

needed for the calculation
Noted
Noted
Default data is not taken from IPCC 2006 but from

IPCC GPG 2000
Accepted
J - have changed this in

track changes, is this the
correct reference?
The source data is taken from IPCC guidebook,

GPG 2000 and not from IPCC 2006. Crop/crop
residues has been changed very much from GPG
2000 to IPCC 2006. See Table 11.2 i the new
guidelines for data. GPG 2000 is not appropriate
for European conditions.The authors of these
UNCEC-guidelines should read Strehler and
Sttzle. The paper is about utilisable biomass and
not field burning and based primarily on conditions
in the praerie in the US.The figure should be used
vith caution especially under European conditions
where there is other crop/crop residue ratios due to
high fertilisation rates.
Accepted
Three years average should not be used if we
want to model the emissions in short time spans.
Should then forest fires be averaged over three
years too? Averaging is not in line with the new
IPCC guidelines
Where is nitrogen mentioned?
Souce in not in the table
Tables should be combined. Omit superfluous
information.
Noted
Noted
Accepted
Noted
The value is app. the same as for Tier 1, but now it

is in g/GJ not in kg/kg dry matter. See my comment
page 4 line 1.
Editorial
Three different Units are used for the same source
(wheat straw). This is also true for the other tables Editorial
Table 3.2 is dublicated
Rejected
Why should Tier 3 be aggregated at a sub-national

scale to fine grid scale if the data/model is
superior. It is a direct copy from IPCCC 2006 and
maybe not valid for UNECE conditions.
Noted
Changed back to kg/kg dry

matter
Changed back to kg/kg dry
matter
I can't see what this
person is talking about
The chapter was based on

the information available
General: The chapter gives an impression of lack

of agricultural knowledge and is more or less a
copy and paste of the IPCC guidelines
Noted
The mentioned cases in the text are seldom, and it

is very difficult to burn rotten straw, so the
importance is very limited.
Accepted
Incorrect SNAP
Accepted
This statement is indeed very surpising given that
many pesticices are considered as POPs (where
agriculture use is the only source). Please properly
explain POPs in the context of this chapter
Noted
NFR category include SNAP 1006 "Use of
pesticides and limestone" - but in the text
"overview" is mentioned that this sector ia a "catch
all" for the agricultural sector. So this NFR category
covers more than SNAP 1006. In the Danish
inventory this sector covers sewage sludge, which
are used as fertiliser and applied on agricultural
soils.
Noted
No, I sourced the data

from 2006
My mistake, in converting
from %, these EF are all
x10 too big. Can you
please reduce
For use of pesticides no method is provided. New

methods are available in the Netherlands and the
EU which could be refered to: Nie (2002), Linden
et all (2006), and Linden et all (2008; in
preperation)
Nie DS de (eds), 2002
Emissie-evaluatie MJP-G 2000; Achtergronden en
berekeningen van emissies van
gewasbeschermingsmiddelen
[ Emissions of plant protection products to the
environment. Evaluation of the policy goals of the
Long-term Crop Protection Plan ]
RIVM Rapport 716601004
Linden AMA van der, Beelen P van, Berg GA van
den, Boer M de, Gaag DJ van der, Groenwold JG,
Huijsmans JFM, Kalf DF, Kool SAM de, Kruijne R,
Merkelbach RCM, Snoo GR de, Vijftigschild RAN,
Vijver MG, Wal AJ van der
Evaluatie duurzame gewasbescherming 2006:
milieu
[Midterm evaluation of the plant protection policy of
the Netherlands; environment ]
RIVM rapport 607016001
In preperatation
Linden AMA van der, Groenwold JG, Kruijne R,
Luttik R, Merkelbach RCM
Dutch Environmental Indicator for plant protection
products, version 2
Input, calculation and aggregation procedures
RIVM Report 607600002/2008
Noted
Chapter should be supplemented: now in contains

headings, one table without EF, one literature
source.
Noted
The chapter is incomplete.
Noted
Add: "Also PM emissions from waste handling are
generated but no estimate of emission factors is
available."
add ", NH3" after "CO"
Add: "Also PM emissions from waste handling are
available."
substitute "very minor" with "minor"
add ", NH3" after "CO"
An incomplete and unexplained algorithm is given
for emissions from pulp and paper only?
why process emissions from pulp and paper in this
connection ?
too less explanation, only reference to GHG
Accepted
Accepted
Done
Done
Accepted
Accepted
Accepted
Done
Done
Done
Accepted
Corrected
Accepted
Noted
Corrected
substitute "Emissions are considered to be

negligible in most cases." With "Small quantity of
NMVOC and nitrate compounds are emitted. For
NMVOC US EPA evaluate that 98,7% of landfill
gas is methane and 1,3% other VOCs such as
perchloroethylene, pentane buthane, etc. (EPA,
1990). Also PM emissions from waste handling are
available."
Accepted
change position of NH3, TSP, PM10 and PM2,5 in
"not estimated" section
Accepted
Done
Done
no emission factors estimated or applicable. Not

even for NMVOC and CO ...I miss some support.
Noted
NMVOC estimated now

from UK inventory
US EPA (1990), Air Emissions Species Manual,

Volume I; Volatile Organic Compounds Species
profiles, Second Edition, EPA-4502-90-001a,
United States Environmental Protection Agency,
Office of Air Quality Planning and Standards,
January 1990
Accepted
Added to references
Accepted
EF used as Tier 1 default

EF
An estimate of NMVOC emissions from landfills

was made using an emission factor of 0.01 t
NMVOC/ t methane produced which is equivalent
to 5.65g NMVOC/ m3 landfill gas (UK inventory,
2004).
EF should be defined depending on the kind of
waste deposited
Noted
Chapter should be supplemented: now it contains

2 tables, including one table with one emission
factor (for NH3) and list of References with 2
sources.
The chapter is incomplete. See examples below
Chapter discussed in
meeting with C&I Expert
Panel Leader. Latrines
moved to Tier 2. Tier 1 EF
for NMVOC estimated
Consult with from one of the suggested
Expert Panel papers.
Noted
An aspect of importance not described in this

chapter is the importance of industrial effluents to
the sewer system and i.e.contribution to the
centralised WWTPs and i.e. NMVOC emissions.
Accepted
NMVOC from WWTP

mentioned
NMVOC emissions may occur during sewage

collection and are very dependent upon treatment
processes at different stages at the WWTPs (see
refs row23-35))
Accepted
Some text about this issue

has been added
The chapter states that it focusses on biological

treatment plants, however, the text deals in no
detail with biological processes and
dephosphorization is a chemical process
Text taken from former

GB; adapted to fit better in
revised chapter
Noted
The chapter states that 'NMVOC and NH3 is of

minor and only of local importance' as compared to
landfills where these emission are referred to as
'emitted in smal quantities'.
Noted
From the Inventory of U.S. Greenhouse Gas
Emissions, however, it may be observed that the
emission of NMVOC from wastwater treatment
processes are a factor two of the estimated
emisions from landfills; ranging from 57 to 68 Gg/yr
in 1990 and 2001.
Noted
Information on NMVOC
added; see other
comments
The text on latrines

(http://reports.eea.europa.eu/EMEPCORINAIR4/en
/B9107vs2.1.pdf) are overpresented compared to
section 2.1 considering the relevance of the two
activities
Noted
change position of NH3, and NMVOC in "not
estimated" section
Accepted
Erase NH3 EF and related information and change
position of NH3 and NMVOC in "not estimated"
section
Accepted
Done following discussions

with C&I EP. A Tier 1 for
NMVOC has also been
derived
I don't think the similarity of latrines with animals

was correct and then latrines are not equal to
"waste water treatment plants". Substitute "The
default emission factor for ammonia from waste
water handling is provided in Table 3-1. It is equal
to the estimated emission factor for ammonia from
latrines, which has been determined from the
similarity between latrines and open storage of
animal manure in lagoons or ponds (Guidebook,
2006)." with "Also NH3 and NMVOC emissions
from waste water handling are generated but no
estimate of emission factors is available."
Accepted
Done following discussions

with C&I EP. A Tier 1 for
NMVOC has also been
derived
Air emissions of POPs as well as NMVOCs, CO

and ammonia are occurring eventhough maybe at
insignificant levels, still not very well investigated.
However some scientific studies do adress such
emissions.
Some info added to

chapter; see earlier
comments
Noted
Examples from the scientific literature documenting

such emissions of aromatic and halogenated
compounds from urban WWTPs are Sree et al,
2000
Accepted
Some info added to

comments
Oskouie,A.K., Lordi, D.T., Granato, T.C. and

Kollia, L. (2008). Plant-specific correlations to
predict the total VOC emissions from wastewater
treatment plants.Atmospheric Environment, In
Press, Corrected Proof, Available online 13
February 2008.
Some info added to

comments
Noted
Baillod, C., Crittenden, J.C., Mihelic, R., Rogers,

T.N., Grady, C.P.L., 1990. Critical evaluation of the
state of technologies for predicting the transport
and fate of toxic compounds in wastewater
facilities. WPCF research Foundation Project 90-1.
CAAA. U.S. EPA, 1990.
Noted
Some info added to

comments
Corsi, R.L., Card, T.R., 1991. Estimation of VOC

emissions using the Baste model. Environmental
Progress 10 (4), 290.
Noted
Some info added to

comments
Dobbs, R.A., Wang, L., Govind, R., 1989. Sorption

of toxic organic compounds on wastewater solids:
correlation with fundamental properties.
Environmental Science and Technology 23 (9),
1092.
Noted
Some info added to

comments
Easter et al.. Odor and air emissions control using

biotechnology for both collection and wastewater
treatment systems. Chemical Engineering Journal,
Volume 113, Issues 2-3, 20 October 2005, Pages
93-104
Noted
Some info added to

comments
Escalasa et al. Time and space patterns of volatile

organic compounds in a sewage treatment
plant.Water Research 37 (2003) 3913-3920
Noted
Some info added to

comments
In urban areas, VOC emissions from WWTPs may

be a significant fraction of the total hydrocarbon
emissions
Noted
Some info added to

comments
whereas the corresponding NMVOC emissions

from whole Austria were reported as 5% (25000 t
yr) of the total anthropogenic NMVOC emissions.
Noted
Some info added to

comments
Noted
Some info added to

comments
According to the IPPC guidelines such releases

into the domestic sewer system should be included
in the 'Waste water treatment in
residential/commercial sectors'.
Noted
Some info added to

comments
Air emissions of NMVOC prevails in pre-treatment

and primary clarifiers, whereas biodegradation and
sorption compete in aerobic biological reactors...
Air emission prevails in secondary clarifiers (e.g.
Escalas et al. 2003, Water Research 37, 3913
3920).
Noted
Some info added to

comments
more focus should be given to Urban wastewater

treatment plants and separate industrial
wastewater treatment plants.(see references as
commnt to list of reference below, page 6 line 8)
Most plants have highly techological developed

primary, secodary and tertiary treatment processes
including mechanical, chemical, biological
anaerocic and aerobic processes and emission
may occur at several stages of treatment.
Noted
Some info added to

comments
Reference for inspiration: P. Tata, J. Witherspoon

and C. Lue-Hing, Editors, VOC Emissions from
Wastewater Treatment Plants: Characterization,
Control and Compliance, Lewis Publishers, Boca
Raton, USA (2003) ISBN 1-56676-820-9, p. 415
Noted
Some info added to

comments
Noted
Some info added to

comments
BOD characterisation , which is the main source

for NMVOC emission, is totally missing in analogy
to the missing precess descriptions which are
potential for NVVOC emissions as well as POPs.
Reference for statements in row 26 to 28: Atasoy

et al. (2004).The estimation of NMVOC emissions
from an urban-scale wastewater treatment plant.
Water Research,Volume 38, 3265-3274
Noted
latrines are not relevant at all for many European
countries
Noted
NMHC or non-methane VOC may occur for
controlled as well as uncontrolled aeration
processes.
Sree, U., Bauer, H., Fuerhacker, M., Ellinger, R.,
Schmidt, H. and Puxbaum, H. (2000).
Hydrocarbons Emissions From A
Municipalwastewater Treatment Pilot Plant In
Vienna. Water, Air, & Soil Polution, 124, 177-186
Some info added to

comments
Noted
Noted
Some info added to

comments
Schmid, H., Bauer, H., Ellinger, R., Fuerhacker,

M., Sree, U. and Puxbaum, H. (2001). Emissions
of NO, TVOC, CO2, and aerosols from a pilotscale wastewater treatment plant with intermittent
aeration Atmospheric Environment, 35, 1697-1702. Noted
Some info added to

comments
Wua, B.-Z., Fenga, T.-Z., Sreea,U., Chiuc, K.-H.

and Loa, J.-G. (2006). Sampling and analysis of
volatile organics emitted from wastewater
treatment plant and drain system of an industrial
science park. Analytica Chimica Acta , 576, 100111
Noted
Some info added to

comments
For example, NMVOC contribution from WWTPs in

Vienna, as an urban area, was estimated to be
around 7.5% of the total anthropogenic NMVOC
emissions
Noted
Some info added to

comments
Glossary, AR production - the AR for the lime

production?
Accepted
Tables 3-1 3-6: HCB and PCB emission factors

are the same (in spite of the abatement); NOx, CO
and SOx EF are not harmonized, as well as TSP.
For example: TSP EF in the Table 3-1 (Tier 1) is
the same with EF in the tables 3-4, 3-5 and 3-6
Consult with
(Tier 2, different abatement, including BAT).
Expert Panel
Table 3-1. According to the UNEP Toolkit PCDD/F
EF value of 0,525 mg for the high control
equipment efficiency
Consult with
Expert Panel
Table 3-2. PCCD/F EF is 40 mg I-TEQ/Mg waste.

There is no contrudictions in values of these two
tables?
Consult with
Expert Panel
Abetment factors are derived from EPA not

controlled/controlled EFs. These abetments cannot
be used for Table 3-6 EFs, related to EU BAT
technologies . Also dioxins abatement table is not
present in the text and is related to unabated EF
different from Table 3-6 one. Please introduce
unabated EFs or all the pollutants or erase the
entire chapter!
Accepted
Error of table 3-9
Accepted
Table 4-1. It is correct PCDD/F emission factor unit
- mg/Nm3?
Accepted
Corrected
Differences in abatement;
literature references are
not complete. This causes
differences. How else to
deal with this???
Corrected; abatement
factors only applicable to
EPA factors in Tables 3-2
and 3-3!
Corrected
Corrected
Are emissions from flared landfil gas (the part of

the gas not used for energy purposes) missing?
Norway reports these emissions under 6C
Consult with
Expert Panel
Industrial waste is extremely heterogenous group

with very different levels of emissions from their
combustion. But in the chapter industrial waste
considered without differentiation even at Tier 2
level. Chapter should be supplemented.
No new info available,

therefore addition of more
Tier 2 methods could not
Consult with be done. Issue has been
Expert Panel discussed with C&I EP.
Figure 2-1: scheme is too simplified.
Rejected
Change "Much of the information on pollutant

emissions has been reported as emission
concentrations rather than emission factors. These
have been converted using a specific flue gas
volume of 5000 m3 at 11% O2 per tonne of waste.
" with "Emission factors for heavy metals are
assumed to be the same as for clinical waste
incineration."
Accepted
Table 3-1: EF for TSP and PM seem very low; EF

for Pb, Hg and Zn are higher than EF for TSP.
Consult with
Expert Panel
Done
Data are from Table 8.2.2 of old GB and are

assumed to be the same as for clinical waste
incineration Use the same EFs of Tier 1 in Table
3.1 Replace the chapter with "Technology specific
emission factors are not available for this source
category. "
Consult with
Expert Panel
Table 3-2 (Uncontrolled): PCDD/F, HCB, PCB and

PAH emission factors are the same as in the Table
3-1 (Tier 1 typical situation) but TSP and HM
emission factors are more high. EF for PCDD/F
need to be updated (UNEP Chemicals
Standartized Toolkit, 2005 might be for instance
Consult with
used).
Expert Panel
Table 3-3: TSP and PM emission factors seem to
be overestimated.
Noted
Table 4-1: PCDD/F emission factor error in units. Accepted
Figure 2-1: scheme is too simplified.
Rejected
Tables 3-1, 3-2 should be updated, for instance

EF for PCDD/F from the UNEP Chemicals
Standartized Toolkit (2005).
Rejected
Corrected
Tables 3-1 (Tier 1) and 3-2 (Tier 2) were not

harmonized: EF for PCDD/F, HCB, PCB and PAH
compounds are the same while EF for TSP and
HM are more high in Tier 2. If Tier 2 factors are the
same as Tier 1 what are the reasons to include in Consult with
the chapter choice of methods procedure?
Expert Panel
NO TABLE ?
Rejected
Tables 3-4 3-16 which are shown as Tier 3 tables
can be hardly considered as Tier 3: they are out-of
date (main reference - EPA 1995) and do not
provide emission factors for complete list of
Consult with
installations and types of wastes.
Expert Panel
Table 4-1: PCDD/F emission factor error in units. Accepted
There are still only default emission factors for
priority metals. No emission factors for other
metals are included.
Noted
Waste incineration could potentionally be a large

emission source of the other metals therefore
guidance on these metals should be included.
Table 3-1: emission factors need to be updated
Consult with
Expert Panel
Noted
It should be possible to provide some rough

guidance on the particle size distribution, so that
PM10 and PM2.5 can be estimated.
Accepted
Corrected
Chapter should be supplemented: it include only

Open burning of agricultural wastes, while other
types of open burning are also important source of
emission especially POPs.
Noted
Link to more detailed

methods of AP42 inserted
Tables 3-1 3-10: error in unit for PM10. Emission

factors for PCDD/F need to be updated.
Accepted
Corrected
Table 3-4: title of the table do not coincide with the

content (Orchard crops in the title; Leaf Burning
in the table).
Accepted
Chapter should be supplemented: now there are 4
tables with one EF for NH3. No references.
Noted
Corrected
Figure 2-1: Process scheme consists of one box

and three arrows and do not provide any
information about the processes.
Table 3-1 (Tier 1) and Table 3-3 include the same
NH3 EF for compost production.
Table 3-2 (Tier 1) and Table 3-4 (Tier 2) include the
same NH3 EF for sludge spreading.
lots of EF seem to be missing, for ex. NMVOC or
total PAH
original references should be named (not
Guidebook 2006)
Data are the same as Tier 1. Replace the chapter
with "Technology specific emission factors are not
available for this source category. "
Are emissions from car and house fires missing?
See EF_Comments
Are emissions from tobacco missing? See
EF_Comments
No emission factors for PM, HM and POPs.
Consult with
Expert Panel
Noted
Noted
Noted
Rejected
Accepted
Noted
Noted
Noted
Done
Comments
The contractors and indeed many of the individuals in
the project team have many years experience in
support of inventories and combustion emissions. If
this is an unsupported comment it is neither
constructive nor factual.
The factors represent a wide range of technologies,
for most pollutants there will be varying degrees of
abatement and in some instances the factors could
represent unabated emission. In terms of an emission
inventory the key issue is whether they can represent
a national emission. At Tier 1 and Tier 2 inclusion of
factors for specific abatement technologies is
achievable but would require many tables and is
considered inappropriate.
Inlude HCB and other POPs
Note that 1B2a.iv covers fugitive releases from

refining, venting and flaring from oil-refining are 1B2c
& d respectively.
Covered by next comment
Text and indeed emission factors from the previous

chapter could be included as an appendix but
including the whole chapter is not appropriate. Where
the expert panel feels that more text would be helpful
then I propose to ask them to determine what should
be included (as an appendix).
I accept that more detail can be provided but it is

intended as general information only - we can go into
detail but there is information elsewhere such as the
LCP BREF.
Firetube boilers more typically at sizes lower than 20
MWth.
text in prentheses modified to state 'mainly relevant to

solid and liquid fuels'. Gaseous fuels can contain
nitrogen compounds but natural gas contains nitrogen
as N2 other nitrogen compounds are only present at
trace levels (compared to biomass, coal and fuel oil).
Some emission factors are high but whether they are a
large emitter depends on overall technology mix. This
section is about formation of Nox in general rather
than for different technologies).
As taken from the previous guidebook. Please note

commentary elsewhere on mercury in gas.
The text was in the original guidebook but may have

been contrary to the guidebook EF which was omitted
in compilation. Guidebook factor has been restored.
Much of the detail in the current chapter is not relevant

to someone preparing a national inventory. The BREF
provides relevant data.
As stated in the introduction to 3.3 details are in the
BREF. Inclusion of SO2, NOX but not PM is not
consistent but it reflects the original guidebook where
PM controls were considered, as commented, with
heavy metals controls.
Abatement efficiencies are indicative only - efficiencies

are dependent on a range of factors and emission
reductions, particulary for retrofit applications, are very
variable.
Generic text, note that it is not just about emission

data; more detailed approaches may also need to
address fuel use.
Yes, 'all' is unlikely and there will always be new data

to consider.
to consider.
The technology used will differ for each country and

will change over time. A representative factor for all
users is not achievable, these factors provide a first or
second level estimating tool for the sector.
to consider.
Note this also applies to 'other liquid fuels' which
includes refinery gas - these are NAPFUE
classifications.
European PCDD/F data ?
Guidebook factor missed, also data in Ap-42.
An oversight, technology identified but failed to include

table
We accept that combustion emissions can depend on

combustion unit size but, there has to be a degree of
simplification otherwise the number of tables becomes
unmanageable.
Asked for European-based data.
Dry and wet bottom boiler classifications are as used

in current guidebook but it is recognised that these are
not the only technology distinctions
Abatement efficiencies are dependent on a range of

factors and reductions, particulary for retrofit
applications are very variable.
These dsitinctions are not in current guidebook but are
in AP-42 and are reasonable distinctions for unabated
plant (with downfiring as a potential additional
technology). However, these technologies are less
relevant for new and abated plant.
The factors do not represent a specific level of
emission control, where countries have knowledge of
abatement levels then this knowledge should be used
to develop appropriate country-specific emission
factors.
Some inconsistencies - incorrect mapping of some

factors in database ?
Some inconsistencies - incorrect mapping of some

factors in database ?
Where Tier 2 and Tier 1 defaults are the same then we

don't have data to provide a Tier 2 factor and have
included Tier 1
See previous comment
Where there no data to provide a Tier 2 factor, we

have included Tier 1 data
It was not the intent
The work by Concawe is referenced and tables have

been revisited to incorporate relevant data
Have taken out this table
Is this correct?
Note that Concawe references are generally to

USEPA
see other comments on Concawe data
Is this right - perhaps one for Justin/Tinus
The terminology used is not ideal but combustion unit

would not be appropriate either (it could be used to
describe engines, gas turbines, conceivably flares).
Suggest process furnace may be more appropriate.
In general this is correct but there are significant

ranges which indicate that some abatement measures
are present.
see other related comments
We accept that the emission is dependent on fuel

composition but combustion and lubricants are also
relevant. We also accept that USEPA VOC figure also
excludes ethane however, in the absence of other
data, it provides a reasonable value for nmVOC. An
alternative would be to apply the the USEPA TOC
figure. At least one member state applies an emission
limit for formaldehyde but inventory is about total
nmVOC not individual components.
Not 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 emission

reporting is a key issue but is not unique to refineries.
Further guidance is provided in cross-cutting chapters.
Can the expert panel provide any further input on coke

manufacture outside iron & steel plant or other
manufactured solid fuel processes
See row 57
see above
I think this may be a timing issue, FOD may have been

completed shortly before document finalised
Where the references are for AP42, the dates refer to

the chapter dates rather than the current edition.
Calculated with reference to USEPA Method 19
Add a footnote ?
Done
See earlier notes re engines

Not at Tier 1 but is needed at Tier 2
Not clear what this comment is about
2B
Yes (for combustion)

Note that emission is not generally associated with
combustion processes in 1A2 and may be assigned to
the process emission
See 133
Where we have broadly similar fuels we have provided

the same emission factors rather than provide no
factors
Yes, this is correct but the Tier 1 and Tier 2 default

factors are for application to a wide range of
technologies with aggregated activity data. The
compexity of individual furnace fuel mix is more
consistent with a Tier 3 approach.
see above
see above
Actually table revised
See 169
The table titles were incorrect, these factors are for

heating/reheating
These are assigned through NFR 2 emission guidance
See earlier
Yes, this would be impossible.
Emissions should not be included in 1A1
Use tier 1
However note that for cement the Tier 2 tables will

include all emissions except PM
Not possible according to editorial requirements.

However such data can be found in BREF documents
Petcoke is a fuel but by no means the major fuel in all

countries
In general PCDD/F emissions are not increased by

use of waste in cement kilns (if applying BAT)
In the absence of facility-specific data or specific fuels

then use Tier 1
Yes, other liquid fuel includes gas oil
metals should be assigned to process.
At Tier 1 we have brought together by main fuel

classifications
Text and tables now modified to reflect discussion with

EP leader
Suggest applying same factors as for coal in cement

kilns
see above
update
include especially the last suggestion
rejected
could be improved
There are some errors: e.g. we should divide
emissions by LTO and Cruise not by take off and
landing; it could be improved
In my view default EF should refer only to IFR flight
see the comment above (row 38)
I agree with the comment. In Tier 2 it is not sufficient

clear how to estimate cruise emissions (domestic and
international): the suggested methodology could be
reported with a complete example (taking in account
an average domestic and international distance for
the country).In my view data needed for the Tier 2 are
n of flight by type of aircraft and by
domestic/international; total fuel consumption (if
possible domestic and international separately);
average national distances for domestic and
international flights. So the first step should be to
estimate LTO fuel consumption for domestic and
international, and cruise fc for domestic on the basis of
tables 3.11, 3.12 and 3.15. International cruise fuel
consumption should be calculated anyway by
difference with the total FC in the energy balance.
Step 3 probably is the first step, step 4 the second one
and step 1 and step 2 are a results of the method. In
my knowledge no countries have information n fuel
consumption distinguished by domestic and
international; also Tier 3 methodologies, as Pagoda
model by EUROCONTROL, estimated the fuel
consumption on the basis of the distance of the flights
because FC on single trip are not collected because of
confidentiality.
I disagree with the comment in general; if the IPCC

2006 guidelines report new emission factors before
not available in my view they should be used
It is correct, emission from military mobile, including

aviation, are reported in 1A5B with exception for those
referring to multilateral operation that shoul be
reported in memo items
It could be useful to describe the Tier 2
Done
Equation is correct as it is
will clarify
will clarify
will check and clarify units need correcting
will check and clarify units need correcting

will clarify
Will be clarified
will check and clarify units need correcting and linking
to EF tables.
to EF tables.
will correct
to EF tables.
will correct
will correct
Need to add EFs where appropriate
Need to add EFs where appropriate
Will incorporate where appropriate to the tier
methodology or reference given to detailed datasets.




Units will be added.
Will clarify
Will clarify
Will add

Will clarify
Will clarify

Will be redrafted to fit with Guidebook and reference
made to IPCC 2006
Will clarify
Will add
Will add
Will add
Will clarify
Will review
Will update
Will update
Will update
Will update
Will update
Will incorporate where appropriate
Can't find any later data on ship fleet make up.
clarified
Will include originals
Will update
Will update
Will update
Will update
Need clarifying

Will clarify reference
Will include reference

Will clarify
Will clarify
Will clarify
Will clarify

Will revise
Will revise
Will revise
will be deleted
Will incorporate
Will incorporate
Will incorporate
Tables will be revised and clarified
References will be added
will incorporate
Will be clarified
Will be clarified
Will be clarified
Will be clarified

As applied to 1A4a/c
Agreed at Overview and Table 1-1, subsequent use

modified to align with NFR terminology
Accepted but, tried to retain much of the original text

(B216) as it has only recently been revised. The
technologies are not all NFR sector specific.
Diagram is generic
Not sure these comments are being held together that

I can follow the references made.
Some removal of detail, no additional CHP detail
These technology descriptions are largely taken from

the existing chapter
accepted however waterheaters are also devices

which heat water ! EuP ecodesign Lots 1 and 2 are
distinguishable on this basis.
HCB emissions very uncertain
Tier 1 is based on fuel not technology
The factors for some of these activities are highly

uncertain, this is partly due to the movement away
from technology to fuel categories but also reflects
variability in source data.
several coments here, tables reviewed
Some more obvious splitting included.
Additional data in appendix
many tables have been revised#
The factors were in the appendix of B216 of the

2006/7 guidebook. If they can help a country
elaborate the emissions better and the country has
resources to do this, then why not use them ?
To be improved
To be revised
The BLT test reports are type-approval tests for use in

Austria and other countries.
Winiwarter reference
Can we do as a x-reference
BAT figures ?
This is a fair point but we have tried to avoid applying

different sizes as the number of tables will become
unmanageable for the guidance.
??
1A2 ?
will clarify
Will include summary table of limits
will clarify
These are described in 2.2.
Table labelling is miss leading and will be corrected.

Will be clarified in a footnote
will clarify
will clarify
Will add
Will update
Will update
Will update
Will elaborate
Will update
Table will be revised

Will update
Will update
Will update
Will update
Will update
Will update
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Will update
We'll follow the reporting template on this issue.
Relates to Tier 3 methodology comment
We don't have any information for this consult with

EP
Not true. Gas distribution must be in this chapter.
Not sure what is meant here.
Not sure what is meant here.
For full reference see later comment
Still to do if there is time

I suppose this comment is applicable to chapter
1.B.2.a.vi. Reference added therein; not here since it
is not referred to
These values could indeed be useful for the

Guidebook, but we don't have them and cannot find
easily.

easily.

easily.

easily.

easily.
Not sure. Were listed under 050501 in former
Guidebook

easily.
A reference for this?

This chapter has been drafted in close cooperation
with Concawe.
Explanation is not too late - this is the section for

activity data.
Don't know what this is applicable to
Why?
Cannot find text at indicated location. Furthermore,

this text has been added by Concawe themselves.
Tier 1 & Tier 2 must be as complete as possible
What table is this comment about?
In this chapter! What is the question here?

We think that this is probably not the majority. And
since we cannot split we chose to report these in the
combustion chapter
Emission expected in reporting template from source
category 1.A.2.f.i, therefore emission factor in that
chapter (either factor itself or a Not Estimated). Will be
corrected in final draft
PM is in process chapter (2.A.1), emission factors of
all other pollutants are in 1.A.2. Description describes
complete cement production process, since we want
to be complete in this respect.
Don't know what is meant by "misunderstood". In
which way?
No idea why this should be removed. I don't see any

reason to do so.
Not Estimated / Not Applicable are filled using the
reporting template. There is NOx and SOx from
process, but it has not been estimated here and
included in the combustion SOx in chapter 1.A.2.f.i.
Tier 2 EFs from EECCA now inserted
EECCA data now inserted as Tier 2
We think most HMs from cement are from the fuels

rather than the raw meal and therefore they are
accounted for in 1A2. Everything is emitted together
from the kiln (process & combustion), but we have to
make a split somewhere.
Needed for electronic emission factor database, EFs

not the same anymore in Final Draft
Indication I.E. will not be presented anymore in the

final draft
Probably also a significant contribution is from the

fuels. The question is which one is the most
significant, since a split is not possible. We think the
majority is from combustion.
Ammonia emissions treated in combustion chapter
1A2fi (according to reporting template); should not be
a NA
These are accounted for in the combustion chapter, as

indicated. See chapter 1.A.2.
We anticipate that dust is mainly from the processes

and HMs are mainly from the fuel combustion. Could
be updated, but only if HMs are in majority from the
process (which we do not think is true).
Chapter mainly important for GHGs, as indicated
Error made when copying value - will be corrected

Why?
Must be chapter 3.C, not 1.A.2.f.i (I think this is also

the point made in the comment, although I'm not
sure?)
To be added
Good suggestion, unfortunately I could not easily find
a conversion factor.
Decision tree updated to include product use besides

production. Don't know what else to change.
Dates back to 1995 while old Guidebook uses 1994.
All EFs the same, so I think this is not newer.
This issue has been identified as a problem from the

beginning of the project. Needs to be discussed, I
think!
Table 3-2 does not exist. Comment not applicable

here.
We have to stick to the NFR structure, which does not

identify glass as a separate source category.
Source = Expert judgement
We don't have any better information. If provided, we

would like to include this.



NMVOC EFs from combustion and treated in chapter

1.A.2
All consistent tables will be produced for the final draft
Would be a nice report to use in a next version, but

since not published yet it will be difficult to incorporate
this now. Many emission factors have been revised
following other comments however.
True, but no figures available to quantify this

I'm not sure what is meant: Since all references have
a year, I think the person commenting refers to which
year the EFs are valid for. Our Tier 2 EFs do in
principle not have a reference year, because they are
technology-based.
We don't use a class I-III for HMs in the Guidebook.
True, but if these more accurate EFs are not available

they cannot be used.
Probably this is indeed not correct, but unfortunatly
complete information is not available from literature.
We have to deal with what we have.
Complete information is not available from literature.

We have to deal with what we have.
Sentence needs to be added to the preceding section
saying that all tables have been made complete by
adding Tier 1 EFs where Tier 2 EFs for that specific
technology were not available
no suggestion for
The 040501 and 040502 were separate chapters in

old guidebook, but indeed referring tot the same
naftacracking process - this is mentioned in the text
also .. Question on the expert panel to combine the
both SNAPS to one paragraph?
060306 is on pharmaceutical products, action asked

from task force on SNAP
SNAP 040622 is Explosives manufacturing
Suggested is BAT associated emission levels.
BREF LVIC AAF 2007: The tail gas composition

depends on the applied process conditions. Table 3.3
gives an overview of tail gas properties .. Used 200 4000 Nm3 / ton and 200 - 4000 mg/Nm3 .. Results in
620 - 13.200 g / ton - Guidebook values: 10.000 with
lower upper 5000 and 15000
Adipic acid production is relevant for emissions of
greenhouse gasses (N2O), but not considered
significant or a key source for other air emissions
included in the protocols.
The source is indeed Table 7.10 in BREF LVIC SAO
"Emission sources and data on typical dust emissions
from the Austrian plant at different process stages "
- because we need a Tier 1 we made a aggregated EF
from the different pprocess stages
The Guidebook has to give Tier 1 EF's for all NFR's
including this one. This table therefore includes Tier 1
emission factors for the NFR Other chemical industry,
generated with Eurostat and EPER data shoud be
used with care, and is a very rough estimate! ..
The Guidebook has to give Tier 1 EF's for all NFR's
including this one. This table therefore includes Tier 1
emission factors for the NFR Other chemical industry,
generated with Eurostat and EPER data shoud be
used with care, and is a very rough estimate! ..
There is already a separate BAT reference in the

chapter on BAT for Ammonia
the both processes, steam reforming and partial

oxidation are controlled processes
This seems a left over from the former version of the

Guidebook .. Will be corrected, we now assume a
lower value of 2000
This seems a left over from the former version of the
Guidebook .. Will be corrected
it is actually the other way round, 5000 refers to US
plants
we will use a value in the range for the European
plants - 500
see comment on TIER 1 EF comment .. Not a key

source
SNAP paragraph on Silicium production removed
TSP and NH3: compiled new EF's from the different

unit operations listed in EPA42, considering also new
developments in taking upper and lower limits
Note:
Used the EPA AP42 (1996) reference instead , same
values
old chapter B443 guidebook states: A specific
methodology for these activities has not been
prepared because the contribution to total national
emissions is thought to be currently insignificant, i.e.
less than 1% of national emissions of any pollutant
(2006)
reference to: COV from Economopoulos -> not clear!
old chapter B443 guidebook states: A specific
methodology for these activities has not been
prepared because the contribution to total national
emissions is thought to be currently insignificant, i.e.
less than 1% of national emissions of any pollutant
(2006)
We received a TIER 1 EF from ESPREME - chlorineTier 1 (not in FOD) we will use

mercury cell: compiled an EF from the current
emission levels cell room ventilation 0.17 - 1.93,
proces exhaust 0.01 - 1.0 g , Caustic soda after the
decomposer: 0.009 - 0.05 and storage: 2.6 -> 3: (1 to
6), these correspond with the ESPREME value, which
is included in the revision
please provide us with a suitable EF
BREF LVOC: Suitable

feedstocks for olefins production range from light
gases (e.g. ethane and LPGs) to the refinery
liquid products (naphtha, gas-oil). Heavier feedstocks
generally give a higher proportion of coproducts
(propylene, butadiene, benzene) and need larger /
more complex plants. A large proportion of Europes
propylene demand (and all of the butadiene demand)
can be
satisfied by the steam cracking of naphtha and gas-oil.
The balance of propylene demand is
essentially supplied from extraction of propylene from
refinery Fluidised Catalytic Cracker offgas
and imports. There is one PDH (propane
dehydrogenation) plant in Europe, but it is only
economic when propane prices are low. A similar
process for butadiene production (by the
dehydrogenation of n-butane) is also available but is
not used in Europe where there is generally
a surplus of butadiene from steam cracking.
Where to find this list?
Correct, use the EF's from the BREF, Table 7.5

summarises the principle pollutants and their sources,
together with the range of emission levels met in most
European crackers.
Eliminated the other table for proylene .. We do not
expect however that the EF of 0.6 underestimates the
emissions .. Most European plants are having lower
emissions
Information from the BREF LVOC were Ethylene is an
illustrative process
Suggested is BAT associated emission and

consumption levels. Current emissions are:
BREF Polymers, Table 3.9: Emission and consumption
data of LDPE plants:
LDPE European Average (benchmark 1999 average)
2400 g/t
VOC to air emissions in grams per tonne of product
(g/t). VOC includes all hydrocarbon and other organic
compounds including fugitive emissions . We will
include this information in the BAT chapter

BREF Polymers, Table 3.11: Emission and
consumption data of HDPE plants
HDPE European Average (benchmark 1999 average)
2300 g/t
compounds including fugitive emissions. We will
Suggested is BAT associated emission levels. There is
also an split view on BAT which resuts in higher BAT
values. We will include this information in the BAT
chapter
Suggested is BAT associated emission levels. There is
also an split view on BAT which resuts in higher BAT
values. We will include this information in the BAT
chapter
BREF states that 85g/t is only for the top50%

facilities ..European average is 120 g/t .. EF will
therefore not be adapted, reference will be made to
the BREF (Table 4.12: Emission and consumption
data per tonne of product of HIPS plants) in stead of
Guidebook 2006

data per tonne of product from GPPS plants) in stead
of Guidebook 2006
. For more information see also the BREF document

on Large Volume Organic Chemicals where the
production of acrylonitrile is described as one of the
illustrative processes
These should indeed be consistent .. Propose to adapt

the approach on neglible emissions with production
comparde to product use
what information to use then?
plakken in excel

BREF Polymers, Table 3.9: Emission and consumption
data of LDPE plants:
LDPE European Average (benchmark 1999 average)
2400 g/t
compounds including fugitive emissions . We will
data per tonne of product from GPPS plants) in stead
of Guidebook 2006
new table in BAT chapter, referring to table Table 7.3:
Emission and consumption data from ESBR plants
(per tonne of product)
what units are most suitable?
Sentence on this to be added

Sentence on this to be added
A Tier 1 is required for every NFR. It may be useful

however to stress in the text that the Tier 1 can only be
used for an Integrated Iron and Steel facility with all
the subfacilities on site.
Comment not understood; suggested to list all EFs in

g/kg or in another unit?


Tier system here a bit different: iron/steel industry

seperated in 3: sinter/pellets, pig iron and steel for Tier
2. Different technologies identified within each of
these. Problem with inconsistent values appears
because of different references. Try to avoid this as
much as possible, but will not be complete
unavoidable!
Why?
Majority is still combustion, I suppose. Since we have

always put NOx/SOx/CO/etc. in combustion when
combustion and process must be separated, I think it's
better to keep this approach here as well.
ESPREME data to be checked
ESPREME data to be checked
Split has been agreed with Expert Panel. Some of the

pollutants are process- and combustion-related and
it's not possible to split. A choice must be made where
to allocate these emissions, which has been done.
Unfortunately BREF does not provide generic factors

for Tier 1, only for different ferroalloys and
subprocesses within the ferroalloy production.
Furthermore, the overview in the BREF is not
complete. Therefore difficult to use in the Guidebook
and not included.
Also not included in Tier 2 because of noncompleteness, but references made.
Not anymore
NFR does not distinguish Primary/Secondary, so at

Tier 1 level we cannot separate them
Primary and secondary copper production are process

with contact, therefore we should treat these similarly
to cement and lime production.
Should be in combustion cahpter 1.A.2.f.i.
Same as for copper production: process with contact
Comment is true, but not too much can be done at this

stage. EFs from different references have been
combined and this causes inconsistencies (most
obvious between PM and HMs). However we cannot
just simply scale down the PM with HM, that is too
simple. I think however that this is an issue that needs
further discussion in the future.
Combining information from different references and

completing Tier 2 tables with typical EFs causes this
problem. There is no simple way to solve this however.






Comment refers to wrong chapter. Correction made in

zinc chapter (2.C.5.d)
Same as for copper production: process with contact
No more data available!
Look at this issue (same as in copper/lead)
CHECK ESPREME DATA



Check for Zn EF; other comments noted
Should be in combustion cahpter 1.A.2.f.i.
Fuel combustion in 1A2 as indicated multiple times in

chapter
We use the reporting template as the master to check

whether emission are expected or not.
No info on this available.
No info on this available.
Chapter needs to be discussed. Where to collect all

this information?
If no information is found, I suggest to move all
relevant pollutants to NE and delete the emission
factors, since they're all wrong!
Chapter needs to be discussed. Where to collect all

this information?
If no new information is found, I propose to delete all
obviously wrong EFs and move to NE
I do not know where this should be allocated, discuss

with EP
Check this and add some text to make this clear.
Mention this somewhere in the description? These can

be considered technology-specific in a way
Only NFR is considered here, not SNAP
Should be paint used, not paint produced. Update

necessary!
What to use if EGTEI and/or GAINS data cannot be

used?
Values correct according to EGTEI
Values correct according to EGTEI
Check if default value is available in EGTEI document

to recalculate in terms of mass of paint
Discuss with EP, conversion factor difficult to find
Will be added. Should this be in chapter 3.A?
We have considered this, but then we get huge

numbers of tables (>100) which will make the
document practically non-readable
Table does not provide EFs, only abatement
efficiencies. Tier 2 EFs will be revised (g/kg paint).
This is not in Executive Summary of BREF document

(where the other text is taken from). Cannot find.
Perhaps we can add some wording on this in Tier 3
Perhaps we can add some wording on this in Tier 3
Cannot be Tier 1 since the old factors are technology

specific; these new factors have been derived in
contact with industrial representatives
Must be checked, what is meant here?
This is too vague. Reference needed for changing

numbers.
How to deal with this? Differs significantly from present

value and unreferenced, so left out.
Source needs discussion. What is meant here? EFs

indeed seem too high, but no other information
available!?
Source needs discussion with EP
EF to be added to chapter
Published in 1982, outdated?
Cannot find proper EFs in AP42

Don't know what text this comment is applicable to

Printing is one NFR, therefore a Tier 1 EF is necessary
This has been considered, but would generate many

tables with all just one EF and therefore expand the
document quite heavily.
Table structure cannot be changed at this stage
Problem is that references are different. How to solve

this?
Product masses can be added to obtain some kind of

generic EF
Emissions mentioned in the text should be in the table

as well (as NE in this case since no numbers are
available)
No idea what the point is here; we would be happy

even with a Tier 1!
This solution looks quite ok to me
Tier 1 represents averaged factors, Tier 2 tables are

basically uncontrolled factors (reduction efficiency to
be applied when abatement is in place). Discuss if
also Tier 1 should be unabated.
This is the uncontrolled one. In Tier 2, abatement
efficiencies should be applied when in operation, while
in Tier 1 there is an "averaged" factor (already
accounting for an average abatement)
A sentence will be added to make clear that the

abatement efficiencies are to be applied to the US
EPA factors only; the type 1/2/3 factors already have
their abatement in there
Must be ng I-TEQ/Nm3
To be discussed; I don't know how to take this into
account
How to define differentiation and where to find EFs?

What more can be said? It's just burning of waste
Problem: TSP from BREF while HM EFs from former

GB (values are much older and therefore higher).
Obviously HM EFs should be updated, but where to
find EFs?
This again raises the question how to deal with Tier 2

in this chapter
Discuss with Expert Panel!
What more can be said? It's just burning of waste
EF for PCDD/F from UNEP already used; if more
updates necessary then please specify which ones to
update and where to find EFs!
Extra information in Tier 2 available is only the

unabated-abated EFs; Tier 2 uses unabated factors
where available (you can use abatement efficiencies
where applicable) while Tier 1 makes a best estimate
when no better info is available
Comment not understood
Consult EP: should we remove this or leave it in?

Discuss if factors are available; where to find
No indication given on where to find this information.
Unit will be corrected.
Table to be corrected
Remove scheme? It does not provide information,

because a variety of process may occur within this
source category. Left in for now.
There is no original reference for this factor
If EFs are provided, we are happy to include them!
Chapter
_ID
Chapter_Name
NFR_Code
TableNu
mber
Pollutant
1 Energy industries
1.A.1
3-14
SOx
1 Energy industries
1.A.1
3-14
NMVOC
1 Energy industries
1.A.1
3-14
1
1
1
1
1
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
1.A.1
1.A.1
1.A.1
1.A.1
1.A.1
1 Energy industries
1 Energy industries
Present Propose
Value
dValue
349.9
20
10
2.3
As
0.0125
0.004
3-14
3-14
3-14
3-14
3-14
Cd
Cr
Cu
Hg
Ni
0.025
0.0625
0.025
0.025
0.875
0.0012
0.015
0.012
0
1.03
1.A.1
1.A.1
3-14
3-14
Pb
Zn
0.0325
0.025
0.0046
0.049
1 Energy industries
1.A.1
3-14
PM10
1 Energy industries
1.A.1
3-15
SOx
1 Energy industries
1.A.1
3-15
CO
15
39
1 Energy industries
1.A.1
3-15
NMVOC
10
2.6
1 Energy industries
1.A.1
3-15
PM10
0.2
0.89
1 Energy industries
1.A.1
3-15
TSP
0.2
0.89
1 Energy industries
1.A.1
3-15
PM2.5
0.2
0.89
1 Energy industries
1.A.1
B4
NOx
75
200
1 Energy industries
1.A.1
B4
NOx
0.25
400
1 Energy industries
1.A.1
B4
NOx
1 Energy industries
1.A.1.b
4-3
SOx
1 Energy industries
1.A.1.b
4-3
1 Energy industries
1.A.1.b
1 Energy industries
1 Energy industries
1 Energy industries
1600
349.9
20
CO
30
15
4-3
NMVOC
10
0.84
1.A.1.b
1.A.1.b
1.A.1.b
4-3
4-3
4-3
Cd
Cr
Cu
0.001
0.01
0.01
0.0012
0.015
0.012
1 Energy industries
1 Energy industries
1.A.1.b
1.A.1.b
4-3
4-3
Pb
Zn
0.005
0.05
0.0046
0.049
1 Energy industries
1.A.1.b
4-3
PM10
1 Energy industries
1 Energy industries
1.A.1.b
1.A.1.b
4-4
4-4
SOx
NMVOC
30
1.3
20
0.65
1 Energy industries
1.A.1.b
4-4
As
0.002
0.0018
1 Energy industries
1.A.1.b
4-4
Cd
0.001
0.0014
1 Energy industries
1.A.1.b
4-4
Cr
0.001
0.0014
1 Energy industries
1.A.1.b
4-4
Cu
0.003
0.0027
1 Energy industries
1.A.1.b
4-4
Hg
0.001
0.0014
1 Energy industries
1.A.1.b
4-4
Ni
0.001
0.0014
1 Energy industries
1.A.1.b
4-4
Pb
0.004
0.0041
1 Energy industries
1.A.1.b
4-4
Zn
0.002
0.0018
1 Energy industries
1.A.1.b
4-4
PM10
3.2
1 Energy industries
1.A.1.b
4-5
SOx
20
1 Energy industries
1.A.1.b
4-5
CO
35
16
1
1
1
1
Energy industries
Energy industries
Energy industries
Energy industries
1.A.1.b
1.A.1.b
1.A.1.b
1.A.1.b
4-5
4-5
4-5
4-5
NMVOC
As
Cd
Cr
1.8
1.5
0.03 0.00003
0.01 0.00001
0.09 0.00009
1 Energy industries
1.A.1.b
4-6
SOx
100
20
1 Energy industries
1.A.1.b
4-6
CO
75
39
1 Energy industries
1.A.1.b
4-6
NMVOC
2.6
1 Energy industries
1.A.1.b
4-6
As
0.0003 0.00034
1 Energy industries
1.A.1.b
4-6
Cd
0.001 0.00071
1 Energy industries
1.A.1.b
4-6
Cr
0.003
0.0027
1 Energy industries
1.A.1.b
4-6
Cu
0.002
0.0022
1 Energy industries
1.A.1.b
4-6
Hg
0.0001
9E-005
1 Energy industries
1.A.1.b
4-6
Ni
0.004
0.0036
1 Energy industries
1.A.1.b
4-6
Pb
0.002
0.0018
1 Energy industries
1.A.1.b
4-6
PM10
1 Energy industries
1.A.1.b
4-7
SOx
0.89
100
1 Energy industries
1.A.1.b
4-7
CO
40
39
1 Energy industries
1.A.1.b
4-7
NMVOC
3.1
2.6
1 Energy industries
1.A.1.b
4-7
PM10
0.9
0.89
1 Energy industries
1.A.1.b
4-7
TSP
1.1
0.89
1 Energy industries
1.A.1.b
4-7
PM2.5
0.4
0.89
1 Energy industries
1.A.1.b
4-8
NOx
100
400
1 Energy industries
1.A.1.b
4-8
SOx
100
1 Energy industries
1.A.1.b
4-8
CO
40
270
1 Energy industries
1.A.1.b
4-8
NMVOC
3.1
56
1 Energy industries
1.A.1.b
4-8
PM10
0.9
0.037
1 Energy industries
1.A.1.b
4-8
TSP
1.1
0.037
1
1
1
1
1
1
1
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
1.A.1.b
1.A.1.b
1.A.1.b
1.A.1.b
1.A.1.b
1.A.1.b
1.A.1.b
4-8
4-2
4-2
4-2
4-2
4-2
4-2
PM2.5
Arsenic
Cadmium
Chromium
Mercury
Nickel
Lead
0.4
0.0001
0.0001
0.0002
0.0001
0.0036
0.0018
0.037
0.00034
0.00071
0.00274
9E-005
0.0036
0.00179
1 Energy industries
1.A.1.b
4-3
Arsenic
0.004
3.98
1 Energy industries
1.A.1.b
4-3
Cadmium
0.001
1.2
1 Energy industries
1.A.1.b
4-3
Chromium
0.01
14.8
1 Energy industries
1.A.1.b
4-3
Mercury
1 Energy industries
1.A.1.b
4-3
Nickel
1030
1 Energy industries
1.A.1.b
4-3
Lead
0.005
4.56
1 Energy industries
1.A.1.b
4-4
Arsenic
0.002
1.81
1 Energy industries
1.A.1.b
4-4
Cadmium
0.001
1.36
1 Energy industries
1.A.1.b
4-4
Chromium
0.001
1.36
1 Energy industries
1.A.1.b
4-4
Mercury
0.001
1.36
1 Energy industries
1.A.1.b
4-4
Nickel
0.001
1.36
1 Energy industries
1.A.1.b
4-4
Lead
0.004
4.07
1 Energy industries
1.A.1.b
4-x
Arsenic
1 Energy industries
1.A.1.b
4-x
Cadmium
1.2
1 Energy industries
1.A.1.b
4-x
Chromium
14.8
1 Energy industries
1.A.1.b
4-x
Mercury
1 Energy industries
1.A.1.b
4-x
Nickel
1030
1 Energy industries
1.A.1.b
4-x
Lead
4.56
1 Energy industries
1.A.1.b
4-x
Arsenic
1 Energy industries
1.A.1.b
4-x
Cadmium
2.52
1 Energy industries
1.A.1.b
4-x
Chromium
6.26
1 Energy industries
1.A.1.b
4-x
Mercury
7.31
1 Energy industries
1.A.1.b
4-x
Nickel
79.3
1 Energy industries
1.A.1.b
4-x
Lead
13.6
1 Energy industries
1.A.1.b
4-x
Arsenic
0.343
1 Energy industries
1.A.1.b
4-x
Cadmium
0.712
1 Energy industries
1.A.1.b
4-x
Chromium
2.74
1 Energy industries
1.A.1.b
4-x
Mercury
3.98
0.086
1 Energy industries
1.A.1.b
4-x
Nickel
3.6
1 Energy industries
1.A.1.b
4-x
Lead
1.79
1 Energy industries
1.A.1.a
3.23
CO
1 Energy industries
1.A.1.a
3.23
1 Energy industries
1.A.1.a
1 Energy industries
1.5
NMVOC
0.2
0.19
3.23
PM10
10
1.A.1.a
3.23
Cd
0.002
0.0022
1 Energy industries
1.A.1.a
3.23
Ni
1 Energy industries
1.A.1.a
3-3
Dioxins
1 Energy industries
1.A.1.a
3-3
1 Energy industries
1.A.1.a
3-3
TSP
40
20
1 Energy industries
1.A.1.a
3-3
PM10
30
15
1 Energy industries
1.A.1.a
3-3
PM2.5
10
0.0005 0.00054
1 Energy industries
1.A.1.a
3-3
NMVOC
30
0.4
1 Energy industries
1.A.1.a
3-4
Dioxins
1 Energy industries
1.A.1.a
3-4
TSP
60
20
1 Energy industries
1.A.1.a
3-4
PM10
30
10
1 Energy industries
1.A.1.a
3-4
PM2.5
20
1 Energy industries
1.A.1.a
3-4
NMVOC
30
0.4
1 Energy industries
1.A.1.a
3-5
PM10
1 Energy industries
1.A.1.a
3-5
NMVOC
30
0.5
1 Energy industries
1.A.1.a
3-6
TSP
1 Energy industries
1.A.1.a
3-7
SOx
350
250
1 Energy industries
1.A.1.a
3-7
Arsenic
0.01
0.002
1 Energy industries
1.A.1.a
3-7
Cadmium
0.01
0.002
1 Energy industries
1.A.1.a
3-7
Chromium
0.03
0.008
1 Energy industries
1.A.1.a
3-7
Mercury
0.008
0.0003
1 Energy industries
1.A.1.a
3-7
Nickel
0.7
0.2
1 Energy industries
1.A.1.a
3-7
NMVOC
30
0.6
1 Energy industries
1.A.1.a
3-8
PM10
1 Energy industries
1.A.1.a
3-11
Dioxins
1 Energy industries
1.A.1.a
3-11
Dioxins
1 Energy industries
1.A.1.a
3-11
TSP
40
20
1 Energy industries
1.A.1.a
3-11
PM10
30
15
1 Energy industries
1.A.1.a
3-11
PM2.5
10
1 Energy industries
1.A.1.a
3-11
NMVOC
30
0.4
1 Energy industries
1.A.1.a
3-12
TSP
60
20
1 Energy industries
1.A.1.a
3-12
PM10
30
10
1 Energy industries
1.A.1.a
3-12
PM2.5
20
1 Energy industries
1.A.1.a
3-12
Dioxins
1 Energy industries
1.A.1.a
3-12
NMVOC
30
0.4
1 Energy industries
1.A.1.a
3-13
TSP
60
20
1 Energy industries
1.A.1.a
3-13
PM10
30
10
1 Energy industries
1.A.1.a
3-13
PM2.5
20
1 Energy industries
1.A.1.a
3-13
TSP
60
20
1 Energy industries
1.A.1.a
3-13
PM10
30
10
1 Energy industries
1.A.1.a
3-13
PM2.5
20
1 Energy industries
1.A.1.a
3-13
Dioxins
1 Energy industries
1.A.1.a
3-13
NMVOC
30
0.4
1 Energy industries
1.A.1.a
3-16
TSP
40
20
1 Energy industries
1.A.1.a
3-16
PM10
30
15
1 Energy industries
1.A.1.a
3-16
PM2.5
10
1 Energy industries
1.A.1.a
3-16
Dioxins
1 Energy industries
1.A.1.a
3-16
NMVOC
30
0.4
1 Energy industries
1.A.1.a
3-17
TSP
60
20
1 Energy industries
1.A.1.a
3-17
PM10
30
10
1 Energy industries
1.A.1.a
3-17
PM2.5
20
1 Energy industries
1.A.1.a
3-17
Dioxins
1 Energy industries
1.A.1.a
3-17
NMVOC
30
0.4
1 Energy industries
1.A.1.a
3-19
TSP
40
20
1 Energy industries
1.A.1.a
3-19
PM10
30
15
1 Energy industries
1.A.1.a
3-19
PM2.5
10
1 Energy industries
1.A.1.a
3-19
Dioxins
1 Energy industries
1.A.1.a
3-20
TSP
60
20
1 Energy industries
1.A.1.a
3-20
PM10
30
10
1 Energy industries
1.A.1.a
3-20
PM2.5
20
1 Energy industries
1 Energy industries
1.A.1.a
1.A.1.a
3-20
3-22
Dioxins
TSP
-0.8
1 Energy industries
1.A.1.a
3-22
SOx
0.25
1 Energy industries
1.A.1.a
3-22
NMVOC
1.6
1 Energy industries
1 Energy industries
1 Energy industries
1.A.1.a
1.A.1.a
1.A.1.a
3-22
3-22
3-22
PM10
TSP
PM2.5
0.2
0.2
0.2
0.91
0.91
0.91
1 Energy industries
1.A.1.a
3-23
SOx
14.2
20
1 Energy industries
1.A.1.a
3-23
Pb
0.006
0.0063
1 Energy industries
1.A.1.a
3-24
PM10
1 Energy industries
1.A.1.a
3-24
SOx
0.5
20
1 Energy industries
1.A.1.a
3-24
CO
10
39
1 Energy industries
1.A.1.a
3-24
NMVOC
2.5
1 Energy industries
1 Energy industries
1 Energy industries
1.A.1.a
1.A.1.a
1.A.1.a
3-24
3-24
3-24
PM10
TSP
PM2.5
2
3
1
0.91
0.91
0.91
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
1.A.1.a
3-25
3-3
3-3
3-3
3-3
3-3
3-3
3-4
3-4
3-4
3-4
3-4
3-4
3-7
3-7
3-7
3-7
3-7
3-7
x-x
x-x
x-x
TSP
Arsenic
Cadmium
Chromium
Mercury
Nickel
Lead
Arsenic
Cadmium
Chromium
Mercury
Nickel
Lead
Arsenic
Cadmium
Chromium
Mercury
Nickel
Lead
Hg(0)
Hg(II)
Hg(p)
0.004
0.0002
0.003
0.002
0.005
0.008
0.004
0.0002
0.00281
0.003
0.005
0.008
0.01
0.01
0.03
0.008
0.7
0.025
0.00502
0.00093
0.03071
0.00329
0.00916
0.02333
0.0173
0.01537
0.03071
0.00125
0.0599
0.05357
1.01147
1.58945
23.1193
0.13596
23.1193
4.33487
0.5
0.4
0.1
Road transport, automobile tyre

6 and brake wear
1.A.3.b.vi
3-19
As
0.8
3.8

6 and brake wear
1.A.3.b.vi
3-19
Cd
2.6
4.73
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries
Energy industries

6 and brake wear
1.A.3.b.vi
3-19
Cr
12.4
23.825

6 and brake wear
1.A.3.b.vi
3-19
Ni
33.6
29.85

6 and brake wear
1.A.3.b.vi
3-19
Pb
107
176.26

6 and brake wear
1.A.3.b.vi
3-19
As
10
67.5

6 and brake wear
1.A.3.b.vi
3-19
Cd
13.2038 22.3778

6 and brake wear
1.A.3.b.vi
3-19
Cr
669.234 2310.99

6 and brake wear
1.A.3.b.vi
3-19
Ni
463.144 326.515

6 and brake wear
1.A.3.b.vi
3-19
Pb
3126.03 6071.81

6 and brake wear
1.A.3.b.vi
3-5
TSP
0.0096 0.06209

6 and brake wear
1.A.3.b.vi
3-5
PM10
0.0064 0.00931

6 and brake wear
1.A.3.b.vi
3-5
PM2,5

6 and brake wear
1.A.3.b.vi
3-7
TSP
0.041 0.34928

6 and brake wear
1.A.3.b.vi
3-7
PM10
0.027 0.02794

6 and brake wear
1.A.3.b.vi
3-7
PM2,5
0.015

6 and brake wear
1.A.3.b.vi
3-9
TSP
0.011 0.00907

6 and brake wear
1.A.3.b.vi
3-9
PM10
0.0073 0.00798

6 and brake wear
1.A.3.b.vi
3-9
PM2,5
0.0039 0.00404

6 and brake wear
1.A.3.b.vi
3-11
TSP
0.048 0.04273

6 and brake wear
1.A.3.b.vi
3-11
PM10
0.032 0.03762
3-11
3-5
3-5
3-5
3-5
PM2,5
Arsenic
Cadmium
Chromium
Mercury
6
10
10
10
10

and brake wear
Small combustion
Small combustion
Small combustion
Small combustion
1.A.3.b.vi
1.A.4.b
1.A.4.b
1.A.4.b
1.A.4.b
0.0035
0.017
0.0003
0.001
0.002
0
0.0005
0.0014
0.01903
10.8891
17.1114
248.893
1.20059
10
10
10
10
10
10
10
10
10
10
10
Small combustion
Small combustion
Small combustion
Small combustion
Small combustion
Small combustion
Small combustion
Small combustion
Small combustion
Small combustion
Small combustion
1.A.4.b
1.A.4.b
1.A.4.b
1.A.4.b
1.A.4.b
1.A.4.b
1.A.4.b
1.A.4.b
1.A.4.b.i
1.A.4.b.i
1.A.4.b.i
3-5
3-5
3-6
3-6
3-6
3-6
3-6
3-6
3-5
3-5
3-6
Nickel
Lead
Arsenic
Cadmium
Chromium
Mercury
Nickel
Lead
Mercury
Lead
Lead
0.01
0
0.0005
0.001
0.002
0.0005
0.002
0
0
0
0
248.893
46.6674
0.00017
0.00017
0.01333
0.00967
0.00017
0.00097
0.1
10 Small combustion
1.A.4.b.i
3-14
TSP
550
350
10 Small combustion
1.A.4.b.i
3-14
PM10
530
330
10 Small combustion
1.A.4.b.i
3-14
PM2,5
531
330
10 Small combustion
1.A.4.b.i
3-14
Copper
0.019
0.02
10 Small combustion
1.A.4.b.i
3-14
Mercury
0.0007
0.001
10 Small combustion
1.A.4.b.i
3-14
Chromium
0.001
0.01
10 Small combustion
1.A.4.b.i
3-14
NMVOC
800
600
10 Small combustion
1.A.4.b.i
3-15
0.7
10
10
10
10
Small combustion
Small combustion
Small combustion
Small combustion
1.A.4.b.i
1.A.4.b.i
1.A.4.b.i
1.A.4.b.i
3-15
3-15
3-15
3-15
SOX
Dioxins and
Furans
TSP
PM10
PM2,5
2
0.2
0.2
0.2
1.5
0.5
0.5
0.5
10 Small combustion
1.A.4.b.i
3-16
NOX
120
50
10 Small combustion
1.A.4.b.i
3-16
CO
320
10
10 Small combustion
1.A.4.b.i
3-16
SOX
0.01
6000
10 Small combustion
10 Small combustion
1.A.4.b.i
1.A.4.b.i
3-16
3-20
HM
PM2.5
10
40
10
10
10
10
Small combustion
Small combustion
Small combustion
Small combustion
1.A.4.b.i
1.A.4.b.i
1.A.4.b.i
1.A.4.b.i
3-24
x-x
x-x
x-x
TSP
Hg(0)
Hg(II)
Hg(p)
1.B.1.b
3-1
PM10
100
1.B.1.b
3-1
PM2,5
90
1.B.2.a.iv
3-6
NMVOC
0.2
0.2
1.B.2.a.iv
1.B.2.a.vi
3-7
3-1
PM10
NOX
0.8
0
0.6
18
18
18
18
18
18
18
19
1.B.2.a.vi
1.B.2.a.vi
1.B.2.a.vi
1.B.2.a.vi
1.B.2.a.vi
1.B.2.a.vi
1.B.2.a.vi
1.B.2.c
3-1
3-1
3-1
3-1
3-1
3-1
3-1
3-3
SOX
NH3
PST
PM10
PM2,5
Hg
As
NOx
16
300
0
0
0
0.2
2.A.1
x-x
Hg(0)
0.8
2.A.1
x-x
Hg(II)
0.15
2.A.1
x-x
Hg(p)
0.05
2.A.4
tab. 3-1
NH3
Geothermal energy extraction

Venting and flaring
-0.8
0.3873
0.8
0.5
0.3
0.2
2100
0.44
0.025
3.7
2.A.6
No. 3-6
NMVOC
200
30
29 Other mineral products
2.A.7.d
3-2
SOx
1900
2.A.7.d
3-2
Arsenic
0.12
0.08
2.A.7.d
3-2
Cadmium
0.15
0.068
2.A.7.d
3-2
Chromium
2.4
0.08
2.A.7.d
3-2
Copper
0.6
0.007
2.A.7.d
3-2
Mercury
0.05
0.003
2.A.7.d
3-2
Nickel
1.9
0.74
2.A.7.d
3-2
Lead
12
0.4
2.A.7.d
3-2
Selenium
18
0.15
2.A.7.d
3-2
Zinc
11
0.366
2.A.7.d
Table 3-2 PM2.5
320
10.8
2.A.7.d
Table 3-2 PM10
360
19.6
2.A.7.d
Table 3-2 Se
18
1.36
2.B.5.a
3-x
Arsenic
2.B.5.a
3-x
Cadmium
2.B.5.a
3-x
Chromium
2.B.5.a
2.B.5.a
3-x
x-x
Nickel
Hg(p)
2.C.1
3-2
Lead
2.C.1
3-2
Arsenic
2.C.1
3-2
Cadmium
2.C.1
3-2
Chromium
2.C.1
3-2
Nickel
2.C.1
3-2
Mercury
2.C.1
3-x
Cadmium
2.C.1
3-x
Chromium
2.C.1
3-x
Mercury
0.05059
2.C.1
3-x
Nickel
0.72553
2.C.1
3-x
Lead
2.61191
2.C.1
3-x
Arsenic
0.40069
2.C.1
3-x
Cadmium
0.06678
2.C.1
3-x
Chromium
2.C.1
3-x
Mercury
0.00137
2.C.1
3-x
Nickel
0.13356
2.C.1
3-x
Lead
4.00691
2.C.1
3-x
Nickel
10
2.C.1
x-x
Hg(0)
0.7
0
0.5 3.54308
0.02 0.01789
0.009 0.00394
0.02
2.3
0.009 0.08947
0.05 0.01838
0.21766
2.3
2.3
2.C.1
x-x
Hg(II)
0.3

2.C.1
2.C.1
3-x
x-x
Mercury
Hg(p)
2.C.1
3-x
Arsenic
2.C.1
3-x
Arsenic
2.C.1
3-x
Chromium
2.3
2.C.1
3-x
Lead
300
2.C.1
3-x
Nickel
2.C.1
3-x
Lead
2.C.1
3-x
Arsenic
2.C.1
3-x
Cadmium
2.C.1
3-x
Chromium
2.C.1
3-x
Mercury
2.C.1
3-x
Nickel
0.00599
2.C.1
3-x
Lead
0.00336
2.C.1
3-x
Arsenic
30
2.C.1
3-x
Cadmium
0.8
2.C.1
3-x
Chromium
2.3
2.C.1
3-x
Mercury
2.C.1
3-x
Cadmium
2.C.5.a
3-1
Arsenic
39 38.7632
2.C.5.a
3-1
Cadmium
12 11.4866
2.C.5.a
3-1
Chromium
16 16.0136
0.00014
0
0.01451
0.0006
0.00011
2.C.5.a
3-1
Mercury
0.023 0.02335
2.C.5.a
3-1
Nickel
14
2.C.5.a
3-2
Cadmium
15 14.5531
2.C.5.a
3-1
Lead
2.C.5.a
3-2
Chromium
2.C.5.a
3-2
Mercury
2.C.5.a
3-2
Nickel
19 19.2101
2.C.5.a
3-2
Lead
170 174.637
2.C.5.a
3-x
Arsenic
1.37223
2.C.5.a
3-x
Cadmium
2.28705
2.C.5.a
3-x
Chromium
2.C.5.a
3-x
Mercury
2.C.5.a
3-x
Nickel
0.12579
2.C.5.a
3-x
Lead
114.352
2.C.5.a
3-2
Arsenic
35 Lead production
2.C.5.b
3-x
Mercury
35 Lead production
2.C.5.b
3-x
Nickel
14.439
160 159.566
21 21.3515
0.031 0.03113
51 51.2268
35 Lead production
2.C.5.b
3-x
Lead
425.926
35 Lead production
2.C.5.b
3-x
Cadmium
1.10153
35 Lead production
2.C.5.b
3-x
Arsenic
3.45147
35
35
35
35
35
35
35
Lead production
Lead production
Lead production
Lead production
Lead production
Lead production
Lead production
2.C.5.b
2.C.5.b
2.C.5.b
2.C.5.b
2.C.5.b
2.C.5.b
2.C.5.b
3-x
3-1
3-1
3-1
3-1
3-1
3-1
Chromium
Arsenic
Cadmium
Chromium
Mercury
Nickel
Lead
35 Lead production
2.C.5.b
3-2
Arsenic
0.015 0.01507
35 Lead production
2.C.5.b
3-2
Cadmium
0.067
35 Lead production
2.C.5.b
3-2
Chromium
35 Lead production
2.C.5.b
3-2
Mercury
35 Lead production
2.C.5.b
3-2
Nickel
35 Lead production
2.C.5.b
3-2
Lead
13 12.5621
35 Lead production
2.C.5.b
x-x
Hg(0)
0.84
35 Lead production
2.C.5.b
x-x
Hg(II)
0.1
35 Lead production
2.C.5.b
x-x
Hg(p)
0.06
37
37
37
37
37
37
37
Zinc production
Zinc production
Zinc production
Zinc production
Zinc production
Zinc production
Zinc production
2.C.5.d
2.C.5.d
2.C.5.d
2.C.5.d
2.C.5.d
2.C.5.d
2.C.5.d
3-2
3-1
3-1
3-1
3-1
3-1
3-1
Nickel
Arsenic
Cadmium
Chromium
Mercury
Nickel
Lead
37 Zinc production
2.C.5.d
3-2
Arsenic
37 Zinc production
2.C.5.d
3-2
Cadmium
0.89
0.33
0
0.7
0
120
0.87417
0.32563
0.69407
115.903
0.067
0
0.93 0.92542
0
0
0.12
2.5
0
3.8
0
14
0.11956
2.53319
3.78578
14.0846
0
2.4 2.43188
37 Zinc production
2.C.5.d
3-2
Mercury
5 5.04556
37 Zinc production
2.C.5.d
3-2
Lead
37 Zinc production
2.C.5.d
3-x
Arsenic
0.47826
37 Zinc production
2.C.5.d
3-x
Cadmium
2.83712
37 Zinc production
2.C.5.d
3-x
Chromium
37 Zinc production
2.C.5.d
3-x
Mercury
37 Zinc production
2.C.5.d
3-x
Nickel
37 Zinc production
2.C.5.d
3-x
Lead
37 Zinc production
2.C.5.d
3-2
Chromium
37 Zinc production
2.C.5.d
x-x
Hg(0)
0.8
37 Zinc production
2.C.5.d
x-x
Hg(II)
0.15
37 Zinc production
2.C.5.d
x-x
Hg(p)
0.05
3.A.3
3-3
NMVOC
200
380
3.A.2
3-2
NMVOC
400
266
17 17.0232
0.00645
5.26895
0
3.A.1
3-1
NMVOC
3.A
new
COV
125
47 Degreasing
3.B.1
new
COV
740
3.D.3
new
COV
5.5
59 Clinical waste incineration
6.C
MNVOC
6.C
SO2
0.02
6.C
CO
0.04
6.C
Paricles
0.14
6.C
x-x
150
80
Hg(p)
0.2
6.C
CH4
0.37
6.C
N2O
0.0015
6.C
6.C
x-x
Hg(0)
0.2
6.C
x-x
Hg(II)
0.6
6.C
6.C.b
3-1
Cadmium
6.C.b
3-1
Chromium
0.3
6.C.b
3-1
Mercury
35 0.08665
6.C.b
3-1
Nickel
56 0.13544
6.C.b
3-1
Lead
0.1 1.25766
6.C.b
3-1
Arsenic
6.D
house
and care TSP, HM and
fires
dioxin
64 Other waste
64 Other waste
6.D
HM
Nox
tobacco
NOx, NMVOC,
CO, TSP,
PAH,HM and
dioxin
0.17
3 0.10158
0.05 0.01645
LowerLi UpperLi
mit
mit
Reference
19.9
20
1.8
2.8
0.002
0.008
0.0006
0.005
0.004
0.0024
0.045
0.036
0.33
3.1
0.0023
0.016
0.0092
0.15
23
55
1.3
5.2
0.53
1.3
0.53
1.3
0.53
1.3
Chemistry, assuming all sulphur

converted (values to be multiplied with
S = wt% S in fuel)
US EPA AP-42 Ch 1.3, Table 1.3-3
(rated A)
(rated C)
(rated C)
API Publication 348 (rated D)
API Publication 348 (not detected)
(rated C)
US EPA AP-42 provides algorithm
relating PM to sulphur content
Page 8, line 17 of this chapter states
sulphur in natural gas is negligible. If
this proposal is not accepted, then the
algorithm 20*S should be used - see
above.
(rated B)
(rated C)
(rated B)
AP-42 (as above) states that all PM <
1 micron
1 micron
Proposed
decision
Accepted
Noted
Noted
Accepted
Rejected
Rejected
Rejected
Rejected
Rejected
Rejected
Noted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
See:
http://www.ifc.org/ifcext/enviro.nsf/Atta
chmentsByTitle/gui_EHSGuidelines20
07_GeneralEHS/$FILE/Final++General+EHS+Guidelines.pdf
Noted
For dual fuel engines operated with
gas, overtake World Bank proposal,
see General EHS Guidelines:
Noted
For gas diesel engines, see:

Noted
19.9
20
12
18
0.67
0.0006
0.005
0.004
0.0024
0.045
0.036
0.0023
0.016
0.0092
0.15
19.9
0.52

S = wt% S in fuel)
(rated A)
(rated A)
(rated C)
(rated C)
US EPA AP-42 provides algorithm
relating PM to sulphur content
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted

20 S = wt% S in fuel)
Noted
0.78 E-PRTR
Noted
0.0006

(rated D); ; present value rounded up
0.0054 to one significant figure
0.0007

(rated D); present value rounded up to
0.0042 one significant figure
Noted
0.0007

Accepted
0.0009

Noted
0.0007

Noted
0.0007

Noted
0.0014

Noted
0.0006

Noted
Accepted

9.6 (rated D)
19.9
20
32
0.49
4.4
2E-005 0.00006
5E-006 0.00002
5E-005 0.00018
19.9

S = wt% S in fuel)
(rated D)
(rated D)
Guidebook, 2006 gives units as g/TJ
Noted
Noted
Accepted
Noted
Accepted
Noted
Noted

Noted
23

(rated B); Assuming refinery gas
55 equivalent to natural gas
Noted
1.3

(rated C); Assuming refinery gas
5.2 equivalent to natural gas
Noted
0.00011
API Publication 348 (rated D); present

value rounded up to one significant
0.001 figure
Noted
0.00024
API Publication 348 (rated D); present

0.0021 figure
Noted
0.0014
API Publication 348 (rated C); present

0.0054 figure
Noted
0.0011
API Publication 348 (rated c); present

0.0044 figure
Noted

4E-005 0.00017 figure
Noted
0.0018

0.0072 figure
Noted
0.0009

0.0036 figure
Noted
0.53

(rated B); assuming refinery gas
1.3 equivalent to natural gas
Noted

above.
Noted
23
1.3
0.53
0.53
0.53
240

55 (rated B)
5.2 (rated C)
1.3 (rated B)
1.3 1 micron
1.3 1 micron
560 (rated B)
160
380
28
110
0.011
0.11
0.011
0.11
0.011
0.11
0.0002 0.0005
0.0005
0.001
0.001
0.004
0.00005 0.00015
0.002
0.006
0.0012 0.0021
2
0.8
1.5
10
20
500
1500
1.5
2.5
1.8

above.
(rated B)
(rated C)
(rated D)
1 micron
1 micron
ESPREME-Table 25
ESPREME-Table 25
ESPREME-Table 25
ESPREME-Table 25
ESPREME-Table 25
ESPREME-Table 25
ESPREME-Table 24 (called in the
FOD under Tier 2)
FOD under Tier 2)
FOD under Tier 2)
FOD under Tier 2) (not in FOD)
FOD under Tier 2)
FOD under Tier 2)
FOD under Tier 2)
FOD under Tier 2)
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Accepted
Accepted
Noted
Noted
Accepted
1
1
1
3
2
0.8
10
500
3

1.8 FOD under Tier 2)
6 FOD under Tier 2)
ESPREME-gas turbines-destillate oil6 table 26 (not in FOD)
ESPREME-gas turbines-destillate oil1.5 table 26 (not in FOD)
ESPREME-gas turbines-destillate oiltable 26 (not in FOD)
Accepted
Accepted
Noted
Noted
Accepted
Noted
Noted
Noted
Noted
Noted
ESPREME-gas turbines-natural gas

and refinery fuel gas-table 27 (not in
FOD)
Noted

5 FOD)
Noted

9 FOD)
Noted

10 FOD)
Noted
50

100 FOD)
Noted
10

20 FOD)
Noted
0.2

0.5 FOD)
Noted
0.5

1.2 FOD)
Noted
1.5

4 FOD)
Noted
0.05

0.15 FOD)
Noted

5 FOD)
Noted

3 FOD)
Noted
0.5

(rated C); present value rounded up to
3 one significant figure
Noted
Present value rounded up to one
0.6 significant figure
Noted
US EPA AP-42 Ch 3.1, Table 3.1-2a
4 (rated C)
Noted
0.001

Noted
0.00025

Noted
0.7
0.1
EF are much too high being based on

1998 data; according to own
measurements on power plants the
majority of dioxins/furans are not
detectable; we suggest to use the
EURELECTRIC data of 6E-10
Noted
As the EURELECTRIC data are based

on more actual measurements the
ranges of the EF should be extended
to include the EURELECTRIC EF; they
should also include the EF calculated
in appendix B
Noted
The proposed EF seems too high under the LCPD plant >500
MW(thermal) have an ELV of 50
mg/Nm3 (17.5 g/GJ), so the suggested
value would seem more appropriate.
According to our data, the lower 95%
confidence intervals for TSP are too
high. We recommend
Noted
Recalculated from proposed TSP EF
factor
Noted
factor
Noted
0.02
0.1
EF seems very high - NMVOC

emission generally related to
combustion conditions and is often
below instrument detection limits.
Suggest using EURELECTRIC value
of 0.4
Accepted

Accepted
high. We recommend
Accepted
factor
Accepted
factor
Accepted
of 0.4
Accepted
Lower 95% confidence limit value for

PM10 is lower than that of PM2.5 suggest that they should be the same
Accepted

of 0.5
Accepted

TSP is lower than that of PM10 suggest that they should be the same
Accepted
Limit for sulphur in fuel oil is 1% - this

equates to an emission of around 250
g/GJ
Accepted
0.001
EF given appears to be for a 1.5%

sulphur fuel - as fuel sulphur has
decreased so has the heavy metal
content. Suggest using the
EURELECTRIC value of 0.002 g/GJ
Accepted
0.001

Accepted
0.005

Accepted
0.0002

Accepted

Accepted

of 0.6
Accepted

Accepted

Accepted
It should be stated which TEF factors

are used (I-TEF or WHO-TEF)?
Accepted
0.1
0.1
high. We recommend
Accepted
factor
Accepted
factor
Accepted
of 0.4
Accepted
high. We recommend
Accepted
factor
Accepted
factor
Accepted
Accepted

of 0.4
Accepted
high. We recommend
Accepted
factor
Accepted
factor
Accepted
high. We recommend
Accepted
Accepted
factor
factor
Accepted
Accepted

Suggest using EURELCETRIC value
of 0.4
Accepted
high. We recommend
Accepted
factor
Accepted

factor
Accepted

Accepted

of 0.4
Accepted
high. We recommend
Accepted
factor
Accepted
factor
Accepted
Accepted

of 0.4
Accepted
high. We recommend
Accepted
Accepted
factor

factor
Accepted
EF are probably too high being based

on 1998 data; we have not measured
these on fluidised bed plants but the
values are likely to be similar to those
from PF plants so we suggest using
the EURELECTRIC data of 6E-10
Accepted
high. We recommend
Noted
factor
Noted
factor
Noted
EF are probably too high being based

on 1998 data; we have not measured
these on fluidised bed plants but the
values are likely to be similar to those
from PF plants so we suggest using
the EURELECTRIC data of 6E-10
negative value?
sulphur in natural gas is negligible.
(rated C)
(rated C)
Assuming all PM < 1 micron
Noted
Noted
Noted
0.5
0.45
0.45
0.45
1.8
1.8
1.8
19.9

Noted
0.003

Noted
0.1

Noted
Noted
Noted
Noted
Noted
19.9
30

Noted
(rated A); assumed refinery gas
47 equivalent to natural gas
0.5
0.45
0.45
0.45
1.8
1.8
1.8
0.1
0.0035
0.00047
0.02142
0.00235
0.00583
0.0175
0.00439
0.00439
0.00779
0.00062
0.02196
0.01757
0.72248
0.72248
16.5138
0.09064
7.22479
2.16744
0.4
0.3
0.05
0.007
0.0014
0.04285
0.0047
0.01458
0.035
0.02196
0.02635
0.03897
0.0025
0.13174
0.10539
1.44496
2.88991
33.0276
0.36257
43.3487
6.50231
0.6
0.5
0.2

(rated C); assuming refinery gas
equivalent to natural gas
(rated C)
TSP is lower than that of PM10 suggest that they should be the same
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
1.6
Hjortenkrans et al. 2007, Uexkll et al.

2005, Warner et al. 2002, Westerlund
2001, Legret & Pagotto 1999,
Stechmann 1993, Hildemann et al.
6 1991, Heinrichs 1993
Noted
1.4

9 1991, Heinrichs 1993
Noted

61 1991, Heinrichs 1993
Noted
2.4

63 1991, Heinrichs 1993
Noted
6.3

670 1991, Heinrichs 1993
Noted
10

130 1991, Heinrichs 1993
Noted
1.5

57 1991, Heinrichs 1993
Noted
114.9375

8050 1991, Heinrichs 1993
Noted
80

660 1991, Heinrichs 1993
Noted
120

20000 1991, Heinrichs 1993
Noted
0.017
TNO 2001, BUWAL 1992, Gebbe et al.

1997, CARB 1993, Garben et al. 1996,
Baumann 1997, Legret and Pagotto
0.12 1999, Lkewille et al. 2001
Noted
0.00255

1997, CARB 1993, Garben et al. 1996,
0.018 1999, Lkewille et al. 2001
Noted

1997, CARB 1993, Garben et al. 1996,
0.00014 0.00096 1999, Lkewille et al. 2001
Noted
0.034

1997, CARB 1993, Garben et al. 1996,
0.768 1999, Lkewille et al. 2001
Noted

1997, CARB 1993, Garben et al. 1996,
0.00272 0.06144 1999, Lkewille et al. 2001
Noted
1997, CARB 1993, Garben et al. 1996,
0.00014 0.00307 1999, Lkewille et al. 2001
Noted
0.00179
Garg et al. 2000, Legret&Pagotto

1999, Warner et al. 2002, RauterbergWulff 1998, Johansson et al. 1998,
Westerlund 2001, Buwal 2001, TNO
0.02 2001
Noted

0.00158 0.01761 2001
Noted
0.0008 0.00891 2001
Noted
0.00347

0.09 2001
Noted

0.00306 0.07924 2001
Noted
0.00155
7.77791
7.77791
177.781
0.8004
0.04009
15.5558
31.1116
355.561
3.20158

2001
ESPREME
ESPREME
ESPREME
ESPREME
Noted
Noted
Noted
Noted
Noted
77.7791
23.3337
0.00011
0.00011
0.00889
0.00556
0.00011
0.00056
0.03
466.674
70.0012
0.00028
0.00028
0.02222
0.01667
0.00028
0.00167
0.1
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
ESPREME
Guidebook 2006. unit mg/GJ
Guidebook 2006, unit mg/GJ
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
ERROR IN COPY FROM "OLD" GB or

wrong reference
Accepted
wrong reference
Accepted
ERROR IN COPY FROM "OLD" GB
*** Proposed value > PM10 one
Accepted
ERROR IN COPY FROM "OLD" GB

or wrong reference
Accepted

wrong reference
Accepted
wrong reference
Accepted
wrong reference
Accepted
I WE SPEAK ABOUT "NATURAL"
GAS EF=0, if we speak of other gases
(i.e. LPG) then mut be declared
wrong reference
EF of old GB has less uncertainty
It's inaudite that consultant it's not able
to copy "old" in "new" Efs
wrong reference
Guidebook 2006, unit g/GJ
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
Noted
0.4
0.2
0.1
45
40
0.1
0.3
800
0.26
0.02
0.6 ESPREME
0.4 ESPREME
0.3 ESPREME
estimated fraction of PM by US EPA
180 data
estimated fraction of PM by US EPA
160 data
Upper limit as per Table 3-1 of this
0.4 NFR
Accepted
Noted
Noted
Noted
Accepted
Accepted
Accepted
Refinery BREF provides a range of

abatementefficiencies for cyclones
between 30% and 90%Propose lower
limit set to BREF value.Propose
0.9 default efficiency is taken at mid range Accepted
0 ARPAT, 2007
Accepted
ARPAT, 2007 Note that the proposed
value is wrong! The reference quoted
say: "While geothermal plants do not
emit sulfur dioxide directly, once
hydrogen sulfide is released as a gas
into the atmosphere, it spreads into
the air and eventually changes into
9000 ARPAT, 2007
ARPAT, 2007
ARPAT, 2007
ARPAT, 2007
1.3 ARPAT, 2007
0.045 ARPAT, 2007
Guidebook 2006
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
0.7
0.9 ESPREME
Rejected
0.1
0.2 ESPREME
Rejected
0.01
0.1 ESPREME
Rejected
0.6
BREF "Large Volume Inorganic

Chemicals - Solids and Other Industry
(LVIC - SAO) October 2006, chapter
1.5 2.3.3.5), unit kg/ton
Accepted
used EF of german NIR, referenced on

VDI 2283 Aufbereitungsanlagen fr
Asphaltmischgut
Accepted
Average of measurements coming
from members of the federation (only
2170 flat glass)
Accepted

flat glass), lower limit = below
0.18 detection limit
Accepted

Accepted

0.13 flat glass)
Accepted

Accepted

Accepted
0.54

0.97 flat glass)
Accepted
0.23

0.68 flat glass)
Accepted
0.02

0.4 flat glass)
Accepted
0.13

0.56 flat glass)
Accepted
1360
0.01
unpublished report on emission factors

of the German glas and mineral fibre
industry for the year 2005
Accepted
Accepted
Accepted
1.78944 5.36831
0.00895 0.02684
0.00179 0.00537
1.15
3.45
0.05368 0.16105
0.01225 0.03676
0.14511 0.29021
1.15
3.45
0.03794 0.05691
0.21766
1.0883
1.0883 4.35318
0.26713 0.53426
0.05343 0.08014
1.53333 3.06667
0.00069 0.00206
0.06678 0.66782
2.67128 6.67819
8
0.6
15
ESPREME - chlorine-Tier 1 (not in

FOD)
FOD)
FOD)
FOD)
ESPREME-Chlor alkali production
ESPREME-(called in the FOD under
Tier 2)
Tier 2)
Tier 2)
Tier 2)
Tier 2)
Tier 2)
ESPREME - Electric arc -Tier 1 (not in
FOD)
FOD)
FOD)
FOD)
FOD)
ESPREME - Basic oxygen-Tier 1 (not
in FOD)
in FOD)
in FOD)
in FOD)
in FOD)
in FOD)
ESPREME - open hearth furnace-Tier
1 (not in FOD)
0.8 ESPREME
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Rejected
0.2
7E-005
0.00726
1.15
200
0.0003
9E-005
0.0048
0.0018
20
0.5
1.53333
0.4 ESPREME
ESPREME -pig iron-Tier 1 (not in
0.00021 FOD)
ESPREME
FOD)
0.02177 FOD)
3.45 FOD)
500 1 (not in FOD)
FOD)
0.00091 FOD)
ESPREME - cast iron-Tier 1 (not in
FOD)
0.00015 FOD)
FOD)
FOD)
0.00719 FOD)
0.0042 FOD)
50 1 (not in FOD)
1.5 1 (not in FOD)
3.83333 1 (not in FOD)
1 (not in FOD)
FOD)
Rejected
Accepted
Rejected
Accepted
Rejected
Accepted
Accepted
Rejected
Accepted
Rejected
Accepted
Rejected
Rejected
Accepted
Accepted
Accepted
Accepted
Accepted
Rejected
Rejected
ESPREME - primary copper-Tier 1

The unit (g/Mg) aluminium should be
26.3385 52.9057 corrected in g/Mg copper
Accepted

Accepted

Accepted

Accepted

Accepted

(called in the FOD under Tier 2) - The
unit (g/Mg aluminium) should be
Accepted

Accepted

Accepted

Accepted

Accepted
116.425 291.062
0.57176 2.05834
1.14352 4.57409
0.05718 0.17153
57.1762 228.705

corrected in g/Mg copper
ESPREME - secondary copper-Tier 1
(not in FOD)
(not in FOD)
(not in FOD)
(not in FOD)
(not in FOD)
(not in FOD)

ESPREME - secondary lead-Tier 1
(not in FOD)
(not in FOD)
Accepted
Accepted
Accepted
Rejected
Rejected
Accepted
Accepted
Accepted
Rejected
Rejected

146.871 587.485 (not in FOD)
0.73436 2.93742 (not in FOD)
2.20307 5.14049 (not in FOD)
(not in FOD)
0.5583 1.3002 ESPREME - primary lead-Tier 1
ESPREME - primary lead-Tier 1
0.01005 0.0201 (called in the FOD under Tier 2)
(called in the FOD under Tier 2)
(called in the FOD under Tier 2)
Accepted
Accepted
Accepted
Rejected
Accepted
Accepted
Rejected
Accepted
Rejected
Accepted
Accepted
Accepted
Rejected
Accepted
Rejected
Accepted
0.7
0.9 ESPREME-primary lead
Rejected
0.05
Rejected
0.01
0.0608
1.13487
1.51447
4.45843
0.97275

ESPREME - primary zinc-Tier 1 (called
in the FOD under Tier 2)
0.18239 ESPREME - primary zinc-Tier 1
ESPREME - primary zinc-Tier 1
ESPREME - primary zinc-Tier 1
3.89101 in the FOD under Tier 2)
Rejected
Rejected
Accepted
Accepted
Rejected
Accepted
Rejected
Accepted
Rejected
Accepted

2.01822 8.07289 in the FOD under Tier 2)
4.86376 34.0463 in the FOD under Tier 2)
ESPREME - secondary zinc-Tier 1 (not
0.24318 0.72955 in FOD)
1.62121 4.05304 in FOD)
in FOD)
0.00323 0.00968 in FOD)
in FOD)
3.24243 8.10607 in FOD)
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
0.7
0.9 ESPREME-zinc
Rejected
0.1
0.2 ESPREME-zinc
Rejected
0.01
0.1 ESPREME-zinc
Rejected
The Emission factor is specific for

Germany; Reference: J. Theloke.
NMVOC-Emissionen aus der
Lsemittelanwendung und
Mglichkeiten zu ihrer Minderung.
Fort-schritt-Berichte VDI Reihe 15 Nr.
252. Dsseldorf: VDI-Verlag,
1900 (Dissertation), 2005
Consult with
Expert Panel
66

Consult with
Expert Panel
60

g/m2 European Commission (2006d),
Integrated Pollution Prevention and
Control (IPPC), Reference Document
on Best Available Techniques (BREF)
for the Surface Treatment of Metals
and Plastics, August 2006
Consult with
Expert Panel
Accepted
electronic components kg/t wafer Carlo

Trozzi (Private Communication, 2008) Accepted
g/m2 060311 Adhesive Tape
Manufacturing (BREF)
Accepted
http://www.ssb.no/emner/01/04/10/rap
p_emissions/rapp_200738_en/rapp_2
00738_en.pdf page 110, tabel 7.2,
unit = kg/ton
Rejected
unit = kg/ton
Accepted
unit = kg/ton
Accepted
unit = kg/ton
Accepted
0.1
0.3 ESPREME
Rejected
unit = kg/ton
Rejected
unit = kg/ton
Rejected
00738_en.pdf page 110, tabel 7.2
Accepted
0.1
0.3 ESPREME
Rejected
0.5
0.7 ESPREME
Rejected
unit = kg/ton
Accepted
0.04837 0.14511 ESPREME
Accepted
ESPREME
Rejected
0.06302 0.11817 ESPREME
Rejected
0.04837 0.19349 ESPREME
Accepted
0.48371 1.93486 ESPREME
Accepted
0.00967 0.01935 ESPREME
Accepted
00738_en.pdf, page 112
Accepted
00738_en.pdf page 112
Accepted
Action taken
Comments
Need to address Sulphur emissions - will
replace with S = wt%S in fuel and default
EF using default sulphur content (made
explicit in text)
Replaced with AP42 Efs

Robert - please can you look into this
Robert - please can you look into this

Done
Done
Done
Done
Done
I-TEF
See first comment
See first comment
See first comment
See first comment
See first comment
Not included at this stage. Could be done at

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.

later stage.
Old' Guidebook references will all be

updated and referenced to original source
Done

Done

Done

Done

Done

Done

Done
Updated
Updated
Updated
Updated
Value = 0, so not taken into account
Updated
Updated
Updated
Updated
Updated
Not included yet. Is not one of the
pollutants in the protocol. Perhaps this can
be included in separate (not Tier 1/2 tables)
somewhere in the text?
95% confidence interval estimated
accepted
ESPREME list only EF's for mercury
accepted
accepted
accepted
accepted


Value = 0
No value
No value
No value
No value
No value
No value
No value
No value
No value
No value
No value
No value
No value
No value
No value
No value

No value
No value
No value
No value
No value
No value

Not included for now. GAINS weighted

average over all countries seems more
appropriate as Tier 1
Should we use this as the Tier 1? Or the

weighted average of GAINS as we have
now?


now?


now?
Added to chapter and database
I suppose NMVOC is meant (COV?)

EF is for boat building
I suppose NMVOC is meant (COV?)
No idea what this means
Inserted
Inserted
Inserted
GHG
GHG
HMs included where EF available

Inserted
Inserted
No new value suggested
BREF value used instead
Inserted
Inserted
Inserted
EFs included
EFs included

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

the draft revised Guideb

There are separate worksheets in this file:

Done for as far as possible

As agreed, we will take EFs from (peer-reviewed)

Done for most chapters

I assume it is meant to fill the "Not Applicable" and

Revised in many cases.

Remains to be done. What is exactly meant?

Try to do this as much as possible

Done, at least to a large extent

Use country as much as possible to avoid this issue

Solvent use - All chapters except domestic use (for

This approach was presented already in Dessau

Done, X-x used where X is

6 digits too much, does not reflect the uncertainty of

Referencing to old Guidebook harmonised. We'll refer

To be discussed, one glossary might indeed be better

From ToPa From ToLin

I felt Appendix C fuels should be deleted from this chapter,

These sentences should be deleted - not future proof (i.e.

Please also provide information on the improvements

Signatories do not have reporting obligations - only parties

Not sure what this is referring to

Text amended to countries that

Change wording of 'updated where necessary' i.e. not all

Convention - first time of use please write out formal name

consider to change 'Concepts' to 'Glossary' or channge the

Intorduction amended. N.B.Readers

This paragraph states that the guidebook covers all

The comment is not relevant to this

TNO will as a side project add information on new POPs

The Task Force relies on, and is

terminology - do not use key source. The agreed term

delete 'actual nature and' . Reproting formats are the

EMEP prefer LRTAP, NEC Directive

changed to 'is designed to cover'

Added "and category as defined in

Text amendment made

Not practical, would introduce too

What kind of key sources are you refering to, avaerage in

In the Chapter there is a Table 3-3 which provides the

Key Catgories are now a defied

Please change text to " report emission data to the

"Relevance" has not previously been defined (page 4),

To support more easy maintenance I propose not

No longer relevant - text has been

Remove bold formatiing for GHG legislation - this isnt

footnote 2 - has variuos superfluous sub-footnote

No mention of upcoming review of the EU-MM - text

Details of the enrty into force of the protocol should be

No longer relevant - text has been

The international PRTR started at the conference in Rio de

No action taken, wherever possible

No action taken, wherever possible

The Kiev protocol , while adopted in

Reference to to UNITAR and UNEP

In 2005 the taskforce was merged with the IOMC PRTR

mention that E-PRTR also goes beyond requirements of

Information not relevant to

Text has been amended

Dublin text inserted

delete: and will be subject to etc