| Aspect |
Sector |
Finding |
CLRTAP_2010 |
CLRTAP_2014 |
NECD_2017 |
NECD_2018 |
Implemented |
Comment |
| General |
|
Provide a PDF version of the IIR for offline use and to better facilitate the review process |
§ 6, 9, 11, 28 |
§ 17 |
|
|
No |
The current Wiki platform isn't able to export a whole site to PDF. But we can provide an offline HTML version with full navigation. |
| General |
|
Use the results of the KCA to prioritise improvements in the inventory |
|
§ 14 |
|
|
yes |
|
| Aspect |
Sector |
Finding |
CLRTAP_2010 |
CLRTAP_2014 |
NECD_2017 |
NECD_2018 |
Implemented |
Comment |
| Transparency |
1.A.1.b |
Include the country specific EFs for combustion in refineries in the relating chapter of its IIR to improve transparency. |
|
§ 55 |
DE-1A1b-2017-0001 |
DE-1A1b-2018-0001 |
No |
Emission factors are under revision. New emission factors will be included in the IIR following completion of the running refinery project. |
| Transparency |
1.A.2.a\1.A.2.b\2.C |
For iron & steel, there is a mix of reporting under 1.A.2.a (PM & CO), 2.C.1 (NOx, SOx, VOC, NH3) and "NE" (HMs and POPs). For non ferrous metals, similar issues are observed. The recommendation is to explain the rationale for reporting in different source categories, as well the rationale for NEs. NE reporting should be avoided as much as possible, e.g. by applying Guidebook Tier 1 EFs. |
§ 48, 49 |
|
|
|
yes |
The reporting in the different source categories is explained in the IIR. |
| Transparency |
1.A.2.g viii |
The ERT recommends that Germany include details of the units of AD used in its estimations, as this was not always the case. |
§ 51 |
|
|
|
yes |
|
| Transparency |
1.A.3.b |
Explain in more detail the emission calculation for road transport, not only by saying that HBEFA and TREMOD are used but giving more information including an overview of emission factors in the next versions of the IIR. |
§ 65 |
§ 72 |
|
|
yes |
detailed (I)EF tables provided in NFR-specific chapters of the IIR |
| Transparency |
1.A.4 |
Provide more detail on the emission factors used, including their applicability for the different years and sub-categories of the time series. Find EFs to estimate emissions for heavy metals (for example: using tier 1 in the EMEP Guidebook, inventories in other countries). |
§ 52 |
|
|
|
yes |
|
| Transparency |
1.B.2.d |
Report in the IIR on what basis emissions from geothermal energy extraction are considered negligible. |
|
§ 59 |
|
|
yes |
|
| Transparency |
2.D.3 |
The methodology described in the IIR for solvent and other product use is found to be not transparent. Provide detail on all 37 subcategories, including activity data and emission factors. |
|
§ 18, 96, 97, 98 |
|
|
yes |
The transparency for the solvents used and products used sector in the IIR was much improved in the submission 2016. |
| Transparency |
3.B |
Explain the variation in activity data for goats in the IIR. |
|
§ 120 |
|
|
yes |
|
| Transparency |
3.B |
The ERT recommends including in the IIR information on the complete time series of the activity data, description of emission drivers, recalculations and improvements for the agriculture sector. |
§ 86, 94 |
|
|
|
yes |
|
| Transparency |
3.B |
Provide additional information in the IIR, especially related to: TAN contents, distributions of housing and storage facilities (e.g. for the first and last reporting year), slurry storage systems and the spreading systems applied, corresponding EFs. |
|
§ 117 |
|
|
yes |
|
| Transparency |
5.A - C |
Since all incineration is reported under energy, add information about the methodology used for different types of waste incineration under NFR 1. In NFR 6.C, use the notation key “IE” instead of “NO”, and to explain the use of the notation key in the IIR. |
§ 103, 110, 111, 112 |
§ 136 |
|
|
yes |
Information on methods used for estimation of energy-related is reported in NFR 1. Germany considers NO to be correct and explains the situation in its IIR. Cremation estimation is explained now. |
| Transparency |
|
Provide more detailed to explain emission trends, e.g. annual fluctuations and discontinuities of emissions. |
|
§ 21, 78 |
|
|
yes |
|
| Transparency |
|
Provide more detailed information on the rationale for recalculations at a sectoral level, to compliment the information already provided in the recalculation tables per pollutant. |
§ 30, 43, 90, 107 |
|
|
|
yes |
|
| Transparency |
|
Extend the use of a bibliography for some subsectors to all sectors in the IIR. |
|
§ 77 |
|
|
partly |
The amount of recurring references is very small within most source categories. And the total number of references per page is usually quite low. So directly linking to the documents seems like a good way to make sources available to the readers. |
| Aspect |
Sector |
Finding |
CLRTAP_2010 |
CLRTAP_2014 |
NECD_2017 |
NECD_2018 |
Implemented |
Comment |
| Consistency |
2 |
Ensure time series consistency of TSP emissions between 1990 and later years, and clearly explain in the IIR where and why consistent reporting is not possible. |
|
§ 80 |
|
|
yes |
|
| Consistency |
1.A.1\1.A.2 |
In the IIR in the "Short description" for 1.A.1 and 1.A.2, Germany presents a tier 2 or 3 approach. However, during the review Germany indicated that only the tier 2 approach was used. This needs correction in the IIR (was agreed by Germany to do this) |
§ 47 |
§ 54 |
|
|
yes |
|
| Consistency |
1.A.5 |
The IIR says Tier 1 method is used for 1A5, but it is actually Tier 2/3. This should be corrected in the IIR. |
§ 53 |
|
|
|
yes |
|
| Consistency |
2.A.1\2.A.2 |
A time series inconsistency is found which relates to a different reporting structure before 2000. It is recommended to explore the feasibility of harmonizing the methodology. |
|
§ 93 |
|
|
yes |
|
| Consistency |
2.D.3 |
Provide emissions for 1990-2005 at a disaggregated level similar to later years, if possible. If not, explain why for the earlier period emissions have been estimated at a more aggregated level. Also clearly document in the case of IE where emissions have been allocated. |
|
§ 100, 101 |
|
|
yes |
The manufacturing industry was the most important branch of the GDR economy. The transformation of the markets and the disappearance of large state-owned enterprises in the course of the German unity led to a dramatic change in the eastern part of Germany |
| Consistency |
3.B |
The ERT encourages Germany to further improve the consistency of the time series of NH3 for manure management. In chapter 4 of the EMEP/EEA Guidebook 2013 specific methods are provided. |
|
§ 110 |
|
|
yes |
|
| Consistency |
3.B |
Sheep animal numbers show a step change due to a different reporting time. This should be corrected for and described in the IIR as appropriate. |
|
§ 119 |
|
|
yes |
|
| Consistency |
3.B |
Check and explain the variation in activity data for horses in the IIR. |
|
§ 121 |
|
|
yes |
|
| Consistency |
3.B |
The activity data (animal numbers) is coming from various sources and some corrections are being done. It is recommended that Germany includes a table in the IIR showing the livestock numbers from different sources and the type of elaboration/correction that has been done. |
§ 94 |
|
|
|
yes |
|
| Consistency |
3.B |
Explain how the change in farm practices or the implementation of mitigation measures has affected the time series in the IIR in order to facilitate the assessment of emission trends. |
|
§ 111 |
|
|
yes |
|
| Consistency |
3.B |
Explain in the IIR why the NH3 EF for dairy cattle decreased from 2011 to 2012. |
|
§ 122 |
|
|
yes |
|
| Consistency |
3.B |
Explain in the IIR why the NH3 EF for swine decreased from 1993 to 1994. |
|
§ 123 |
|
|
yes |
|
| Consistency |
3.B |
Explain in the IIR why the NH3 EF significant changes for different poultry subsectors in the 2000s. |
|
§ 124 |
|
|
yes |
|
| Aspect |
Sector |
Finding |
CLRTAP_2010 |
CLRTAP_2014 |
NECD_2017 |
NECD_2018 |
Implemented |
Comment |
| Comparability |
1.A.2\2 |
Germany reports emissions from sugar production in source category 2.D.2. It is recommended to report these emissions under 1A2e and include a more detailed description of the sub-categories, the methodology used, the source of activity data, the source of EFs and consistency across the time series (1990-2008). |
§ 50 |
|
|
|
yes |
Reporting of NMVOC and PM emissions from sugar production in 2.H.2 (used to be 2.D.2) is correct according to the Inventory Guidebook 2016. |
| Comparability |
1.A.2.a\1.A.4.a i\1.A.4.c i\1.A.5.a |
Notation key NE is used for (many) heavy metals despite the availability of EFs in the EMEP/EEA Guidebook. If all HM emissions from iron & steel are reported in 2.C.1, the notation key should be IE. |
|
§ 56 |
|
|
partly |
Implemented for 1A4ai and 1A4ci |
| Comparability |
1.A.3.d i(ii)\1.A.4.c iii |
Emissions reported as IE. The ERT encourages Germany to make separate emission estimates for these sectors in future IIR reports and, in the meantime, a separate summary table of all categories (fully or partially reported as IE) and where they have been moved would be beneficial. |
§ 69 |
|
|
|
yes |
|
| Comparability |
1.A.4.a ii |
Emissions for main pollutants were reported as IE. The ERT encourages the Party to investigate further statistical resources for missing estimates in this sector and include a progress report within the next IIR. |
§ 67 |
|
|
|
yes |
|
| Comparability |
1.A.4.b ii\1.A.4.c ii |
Implied NOx emission factors are at the high end of the range when compared with a selected group of countries (AT, BE, DK, ES, FI, FR, GB, IE, IT, NL, NO). The ERT recommends that the Party reviews the emission factors for these two sources and includes an explanation for this issue in the IIR. |
|
§ 66 |
|
|
No |
This minor issue has not yet been checked. The inventory compiler will look into this as soon as resources allow. |
| Aspect |
Sector |
Finding |
CLRTAP_2010 |
CLRTAP_2014 |
NECD_2017 |
NECD_2018 |
Implemented |
Comment |
| Completeness |
1.A.2.a\1.A.2.b\1.A.4\1.B.1.a |
Some emissions are not estimated for some pollutants: heavy metals and POPs for 1.A.2.a, particulates, heavy metals and POPs for 1.A.2.b, heavy metals for 1.A.4 and NMVOC for 1.B.1.a. The ERT recommends Germany to use the Guidebook default EFs if no other method is available. |
§ 36 |
|
|
|
partly |
|
| Completeness |
1.A.3.a |
NH3 reported as NE. Recommendation to investigate the emissions or report as NO if emissions do not occur. |
§ 68 |
|
|
|
yes |
The notation key 'NE' is used only for ammonia from aviation gasoline (as recommended in the 2016 EMEP Guidebook). For jet kerosene, emissions are estimated. |
| Completeness |
1.A.3.a i(i)\1.A.3.a ii(i) |
Heavy metal emissions are currently not estimated. The ERT recommends that the Party estimates these emissions, using the methodology in the EMEP/EEA Guidebook. |
|
§ 62 |
|
|
yes |
|
| Completeness |
1.A.3.b iv\1.A.4.b ii |
PM10 and PM2.5 emissions are reported as “NE”. The ERT recommends that Germany completes the inventory by estimating these emissions. |
|
§ 63 |
|
|
yes |
|
| Completeness |
1.A.3.b v |
Evaporative emissions from running losses (i.e. vapour generated in the fuel tank during vehicle operation) were missing because not considered in the TREMOD model. The ERT recommends to include these in the inventory. |
|
§ 73 |
|
|
No |
This issue has not yet been looked into as other model revisions especially regarding a follow-up of 'diesel gate' appear much more relevant, tying up all resources. |
| Completeness |
1.A.3.d ii |
Pb and Hg emissions are currently not estimated. The ERT recommends that the Party considers the emission factors available in the Guidebook. |
|
§ 64 |
|
|
yes |
|
| Completeness |
1.A.4.a i\1.A.4.c i\1.A.5.a |
HM and POP currently not reported since no consistent dataset is available (partly country specific, partly Guidebook). The recommendation is to describe the issue in the IIR and until it is solved use the Guidebook emission factors despite their recognized uncertainty, rather than reporting NE. |
|
§ 57 |
|
|
partly |
Implemented for 1A4ai and 1A4ci |
| Completeness |
1.B.1.a |
In 2010 "NE" is indicated for particulates and “NA” for NMVOC, but the Guidebook has EFs. It is recommended that Germany identifies the type of coal mining, using the EFs from the EMEP Guidebook or other references to estimate emissions for this sector. In 2014 NMVOC was reported as NE, and the ERT recommends Germany to describe why NE is reported (emissions assumed negligible). |
§ 54 |
|
|
|
yes |
|
| Completeness |
2.C.1 |
Include emissions for dioxins and heavy metals based on new research project. |
§ 80, 81 |
|
|
|
yes |
|
| Completeness |
3.D |
The ERT encourages Germany to estimate PM10, and PM2.5 emissions for 3D, in future submissions, following the EMEP/EEA Guidebook recommendations. |
§ 98 |
|
|
|
yes |
|
| Completeness |
5.A\5.B\5.C |
The inventory regarding Waste is currently not complete, with missing estimates for several source categories. |
§ 102 |
§ 134, 135 |
|
|
partly |
Ongoing effort, 5.C completed |
| Completeness |
5.A\5.B\5.D |
Improves the completeness of the inventory by estimating emissions from solid waste disposal and wastewater handling. |
|
§ 127 |
|
|
partly |
Ongoing effort, 5.D. Wastewater completed |
| Completeness |
5.E |
Although the Guidebook has methods for car and house fires in Chapter 6, it may be more transparent to include these in Chapter 7 as Chapter 6.D is more focused on compost and sludge. The ERT encourages Germany to consider including some of these emissions in the next submissions. |
§ 116 |
§139 |
DE-5A-2017-0003 |
|
yes |
|
| Completeness |
6 |
Consider currently missing sources: NH3 emissions from Cats and Dogs, from Zoo animals, and human ammonia emissions, etc. |
§ 116 |
|
|
|
No |
|
| Completeness |
|
Emissions prior to 1990 are not reported. |
§ 27 |
§ 24 |
|
|
yes |
|
| Completeness |
|
LPS data were not reported. |
|
§ 10 |
|
|
yes |
|
| Completeness |
|
A key category analysis (KCA) was missing for the base years (1990 or 2000 for PM) of the pollutants. |
|
§ 13 |
|
|
yes |
|
| Aspect |
Sector |
Finding |
CLRTAP_2010 |
CLRTAP_2014 |
NECD_2017 |
NECD_2018 |
Implemented |
Comment |
| Accuracy |
1.A.1.b\1.A.1.c\2 |
Improvement from Tier 2 to Tier 3, using plant-specific data, for some industrial processes including cement production, as well as for large combustion plants (e.g. 1.A.1.b, 1.A.1.c) |
§ 19, 41, 45, 46 |
|
|
|
partly |
Included for large combustion plants, no plant-specific data for cement production |
| Accuracy |
1.A.3. bvi |
This source is a key category for Pb and the ERT has noted that the emission factor for brake wear used by Germany was higher than the maximum range quoted by the 2013 Guidebook. Germany is recommended to review the EF, explain where it is coming from in the IIR, and potentially revise to bring in line with the Guidebook. |
|
§ 74 |
|
|
yes |
|
| Accuracy |
1.A.3.d ii\1.A.5.b |
Review the methodology for national navigation by distinguishing between coastal and inland shipping based on an ongoing research project, as well as explicitly include emissions from military activities. |
|
§ 75, 76 |
|
|
yes |
|
| Accuracy |
2.A.1 |
Cement production is a key source for Hg, HCB and for NOx, PM10 and PAH but Tier 1 is used. The ERT encourages Germany to use plant-specific data collected as part of the LCPD, IPPC and E-PRTR to develop a tier 2 or 3 methodology in the near future and to document these in its IIR. |
§ 79 |
§ 88 |
|
|
No |
No plant-specific data for only two pollutants useful (Hg, PM2.5) |
| Accuracy |
2.D.3 |
Increase the use of information from individual installations that make a high contribution to the key categories, such as car assembly sites and big printing installations. |
|
§ 104 |
|
|
yes |
Emissions caused by the use of solvents and solvent-based products are reported in the relevant source groups. In our methodology we also include the application of solvent-based products in large installations such as those used in automotive series production or large printing systems. The emission data of defined individual plants are thus included in the calculation but cannot be shown and published individually for reasons of confidentiality and data protection. |
| Accuracy |
2.L |
Include results of ongoing research project to improve from Tier 1 to higher Tier methodology. |
§ 82, 83 |
|
|
|
yes |
|
| Accuracy |
3.B |
There were errors in the calculation of N excretion rates, it is recommended that Germany corrects this. |
§ 97 |
|
|
|
yes |
|
| Accuracy |
3.B |
Describe the efforts taken to verify / validate the emission model in the IIR. |
|
§ 118 |
|
|
Yes |
|
| Accuracy |
|
Implement a (qualitative and quantitative) uncertainty analysis and use the results to prioritize improvements to the inventory |
§ 20, 24 |
§ 32, 44e, 85 |
|
|
yes |
|
| Accuracy |
|
Include a chapter in the IIR with for each source category the foreseen improvements for the inventory |
|
§ 34 |
|
|
partly |
Included for most categories |
| Aspect |
Sector |
Finding |
CLRTAP_2010 |
CLRTAP_2014 |
NECD_2017 |
NECD_2018 |
Implemented |
Comment |
| QA/QC |
|
Fully implement the QA/QC system for the air pollutant emission inventory. If possible, implement a unified QA/QC system for reporting to CLRTAP and UNFCCC. |
§ 21, 24, 62, 74, 88, 105 |
§ 37, 44f |
|
|
No |
Ongoing discussion |
| QA/QC |
|
Widen the use of the existing QA/QC system, used for the set of activity data as well as the methods and emission factors for GHGs, for the needs of CLRTAP/NECD inventories and providing further details on its implementation in the IIR (general and sectoral descriptions). |
§ 33, 40 |
§ 16, 69, 84, 87, 103, 105 |
|
|
No |
Ongoing discussion |
| QA/QC |
|
Include information on verification and validation of the inventory in the IIR. |
|
§ 38 |
|
|
No |
Ongoing discussion |
