EU Air Emission Inventory Review Guidelines 2018

Author Lead author: Chris Dore Contributions from: Aether, UBA-Vienna, European Commission, EEA

Date 08/3/2018

Version Control V0.1: First draft for comment by contributing authors V0.2: Draft to EC for comment V0.3: EC Comments incorporated

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EU AIR EMISSIONS INVENTORY REVIEW GUIDELINES I. INTRODUCTION ............................................................................................................................... 3

II. REVIEW APPROACH ......................................................................................................................... 4

III. THE REVIEW SCHEDULE .............................................................................................................. 6

IV. RESPONSIBILITIES FOR THE REVIEW PROCESS ............................................................................ 6

V. REVIEW OF ANNUAL SUBMISSIONS ................................................................................................ 8

A. Initial Checks ................................................................................................................................... 8

B. Technical Review............................................................................................................................. 9

i. BACKGROUND ......................................................................................................................... 9

ii. COUNTRIES .............................................................................................................................. 9

iii. POLLUTANTS ........................................................................................................................... 9

iv. SECTORS .................................................................................................................................. 9

v. YEARS .................................................................................................................................... 10

vi. PROCEDURES ......................................................................................................................... 10

vii. REVIEW REPORTS .................................................................................................................. 13

ANNEX 1: TECHNICAL CORRECTIONS AND REVISED ESTIMATES .......................................................... 15

Introduction ...................................................................................................................................... 15

The Concept of Technical Corrections and Revised Estimates ......................................................... 15

Quantification of a Technical Correction .......................................................................................... 16

The Process of Determining and Calculating Technical Corrections ................................................ 16

ANNEX 2: REVIEW OF ADJUSTMENT APPLICATIONS ............................................................................ 18

Introduction ...................................................................................................................................... 18

Process and Guidance for the Review of Adjustment Applications ................................................. 18

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I. INTRODUCTION

1. This guidance document, building on the EU Air Emission Inventory Review Guidelines 2017 and the EMEP emission inventory review guidelines as updated in 2016 1 and with due consideration of the EU Effort Sharing Decision greenhouse gas inventories guidelines, provides an overview of the methods and procedures for the review of the air pollution emission data submitted by Member States (MS) under the European Union’s National Emissions Ceilings Directive (NECD) (Directive (EU) 2016/2284) in line with their emission reporting obligations. It is drafted specifically for the 2018 review and will be amended as appropriate for subsequent reviews. It is primarily intended for representatives from MS. A separate guidance document (“Guidance on Review Procedures for TERTs”) has been prepared for the review teams, and whilst it is broadly similar in content, it focuses on a specific part of the review process and has additional detailed information on the relevant processes, tools, and logistics.

2. The purpose of this document is to document the review process and principles, to

ensure consistency in the review of the MS submissions via a thorough technical assessment of national inventories.

3. The emission inventory review will check and assess 2018 MS data submissions to ensure that the European Commission (EC) has available adequate and reliable information on annual inventories and emissions trends and to enhance the quality of emission data and associated information reported to the European Union (EU). The review also seeks to achieve a common approach to prioritizing and monitoring inventory improvements under the NECD with those of other organizations with similar interests such as the UN/ECE Convention on Long-Range Transboundary Air Pollution (CLRTAP). The review process is intended to be transparent and carried out in close cooperation with the nominated national contact point and national experts from MS.

4. The scope and prioritisation of the 2018 review is given in detail in Section V, but in short it covers all MS2 and can be summarised in three sections:

5. Review of the action taken to address findings of the 2017 NECD review.

No new issues will be created3. The scope will be outputs from the 2017 review, and hence include: NOx, NMVOC, SO2, NH3, and PM2.5, primarily for: 2005, 2010 and 2015.

Checks will be made to ensure that technical corrections/revised estimates identified during the 2017 review are correctly included in the 2018 submission.

Checks will be made to see whether recommendations identified during the 2017 review have been addressed.

1 This is available on the meeting web page of the second joint session of the EMEP SB and WGE as an informal document under item 4 (b)” 2 The geographical coverage of MS will be as specified in the NECD for reporting against 2010 emission ceilings. 3 Two exceptions to this are Greece and Finland. It was not possible to undertake detailed reviews in 2017, so detailed reviews will be conducted in 2018 with the same scope as the 2017 reviews, but using the 2018 submission.

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If a recommendation associated with not using the 2016 version of the Guidebook has not been addressed, and it relates to a key category, then if it is above the 2% impact threshold it will be processed as a potential technical correction.

Other recommendations that have not been addressed will be processed as recommendations.

6. Review of emissions estimates for heavy metals and POPs

The scope will be: Cd, Hg, Pb, PAHs, dioxins/furans, PCBs and HCB. The years being checked will focus on 1990, 2005 and 2016.

Checks will focus on completeness and consistency, with particular emphasis on key categories, and the use of Tier1 methodologies for estimating emissions from key categories.

The appropriateness of national (country specific) methodologies will be checked.

The correct use of the notation keys (NO/NA/NE/IE/NR) and how these impact on completeness will be checked.

Recommendations will be made. No technical corrections/revised estimates will be calculated in this year’s exercise; the Commission’s intention is that that will be done in the 2019 exercise under a subsequent contract.

7. Review of previously accepted adjustments, and new adjustment applications

submitted under NECD.

New adjustment applications will be reviewed according to the processes established under the NECD (which also refer to CLRTAP documentation).

The quantification of previously accepted adjustments under the NECD will be checked.

8. All NFR source sectors included within national totals will be included in the review4,

and selected memo items will also be reviewed, including in particular the memo-item on fuel used based transport emissions when relevant for compliance assessment. Outputs from the review will be used to demonstrate on-going compliance with NECD emission ceilings from 2010 onwards.5

II. REVIEW APPROACH

9. MS submit air pollution emission data annually to the EC and the EEA. Submissions consist of both quantitative and qualitative information. Quantitative data are reported as explained in part 1 of Annex IV to the NECD6. Qualitative data, including methodologies used in calculating emissions, are to be included in an Informative Inventory Report (IIR) as explained in part 3 of Annex IV to the NECD.

4 Specifically, the national totals used to demonstrate compliance with 2010 emission ceilings. This definition requires the inclusion of NOx and NMVOC emissions from agriculture in the national totals. 5 NECD emission reduction commitments for 2020 and 2030 are not currently relevant, but the 2005 base year on which the emission reduction commitments for 2020 and 2030 are calculated will be a focus of the review. 6 Directive (EU) 2016/2284 of the European Parliament and of the Council of 14 December 2016.

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10. The technical review process will be in two steps, performed sequentially – “initial checks” and the “technical review”.

11. Initial Checks (NECD2017 findings and HMs & POPs): Initial checks will be undertaken in an attempt to quickly identify the issues identified in the 2017 review that have been addressed. Initial checks will also be undertaken on the HMs and POPs, and these semi-automated checking procedures will focus on completeness, consistency and comparability of data. Findings from the initial checks will be provided by the project team to the TERT to inform their work in undertaking the technical review.

12. The Technical Review (NECD2017 findings, HMs & POPs and Adjustments): This is a detailed review of MS national inventories and is undertaken by the TERT in two stages (see below). During the technical review, the nominated national contact point, supported by national experts, will have the opportunity to clarify issues or provide additional information related to their inventory: a. Desk Review: During the desk review, members of the TERT will check submitted

inventories and IIRs and generate and issue questions for the MS, and MS will provide responses.

b. Centralised Review: The centralised review lasts for one week, and is the most intense period of the NECD review process. The TERT raises questions for MS, assesses responses from MS, gives recommendations, considers whether revised estimates or technical corrections are necessary, calculates necessary technical corrections and drafts the review report.

13. Adjustments will also be reviewed during the technical review. This will include

applications made in accordance with Article 21(2) of the NECD, and approved adjustments from previous years that are still in force. The review process is detailed in Annex 2.

14. The review process assesses consistency of the submission with the requirements of the

NECD, the EMEP Reporting Guidelines and the methodologies and data specified in the EMEP/EEA Emission Inventory Guidebook. The main output from the MS’s reviews are recommendations on improvements provided to the EC by the end of November 2018. This output will, where needed, include technical corrections to be applied to national emissions estimates (see Appendix 1). The EC will communicate final review reports to the MS and in accordance with article 10.3 of new NECD take further action on technical corrections that are still disputed by Member States.

15. Following the completion of the technical review, MS will have the opportunity to

provide feedback on the review process at meetings led by the EC. 16. The 2018 technical review will be followed by a review in 2019 that in particular will

verify that Member States have incorporated the revised estimates and technical corrections from the 2018 technical review into their emission inventories (for the entire time-series) reported by the 15 February 2019. Where appropriate, technical corrections and revised estimates will have to be recalculated in subsequent reporting rounds to take account of possible (justified and documented) changes to input data.

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The review in 2019 will also investigate whether recommendations have been addressed.

III. THE REVIEW SCHEDULE

17. The following timetable has been set for the review: MS activities are shown in grey. Activities of other stakeholders are.

Activity Deadline

Preparatory phase January –April

MS submit inventories and notification forms (including for planned adjustment applications)

15 February

MS submit IIRs and adjusted national inventories (incl. supporting information for the adjustment applications)

15 March

Initial checks of submitted inventories for expert review teams 23 April to 11 May

NEC expert group meeting with MS (organised by EC) to discuss draft EU air emission inventory review guidelines and other review tools

9 April

MS nominate contact points for the review 10 April latest

Training for reviewers April – May

Training for MS users on EMRT-NECD performed by EEA April – May

Desk review1/initial questions to MS (LRs) 14 May - 8 June

MS respond to initial questions of expert review teams ASAP but 22 June latest

Centralised review meeting2/additional questions to MS 26 – 29 June

Technical corrections fixed by TERTs and documented 29 June latest

MS respond to additional questions from expert review teams By close of 28th June

Adjustment recommendations agreed within TERT and documented 5 July

Technical corrections to the MS (EC) 5 July

MS feedback to technical corrections (max 4 weeks) latest by 2 August

EEA (supported by the QA team) extracts input for draft review reports for MS from EMRT-NECD

9 July

ALR provides Adjustment Annexes to The Project Management team 17 July

QCA provides Excel File with changes to Emission estimates after review to LRs for check

Before 24 July

Initial Outcomes Reports and Adjustment Annexes sent to MS 31 July

Draft review reports3 to MS (EC) 19 October

MS comment to review reports 3 weeks after received

Final reports submitted to EC (posted at Share point) End Nov 2016 1 Review refers to review of inventories and review of submitted adjustment applications 2 Meeting will cover inventories and review of adjustment applications 3 Country review reports will in addition to review findings contain annexes with technical corrections and details of the review of adjustment applications where applicable

IV. RESPONSIBILITIES FOR THE REVIEW PROCESS

18. Those responsible for the review process are: (a) MS, who shall nominate a national contact point (and substitute) for communication with the TERT, as well as designated emission sector experts.

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(b) MS designated emission sector experts, who (co-ordinated by the national contact point) provide draft responses to review questions and comments received by the national contact point as well as make available any additional information required for the review process; MS national contact points and designated emission sector experts also provide comments to the technical corrections and review reports.

(c) The EC, which shall

(i) agree a schedule for Parties’ reviews, (ii) approve the selection of the TERTs, (iii) act as contact point for MS’ national contact points and designated emission experts; communicate with MS’ throughout the technical review; (iv) with the assistance of the European Environment Agency, overview the review contract to ensure the quality of deliverables and take responsibility of the final review reports provided to the EC (v) taking into account the final review reports, take further appropriate action on technical corrections that have not been implemented from the previous year or are still disputed from the current year (adopting a decision on technical corrections as appropriate) and (vi) publish all findings in the public domain.

(d) The European Environment Agency, who supports the review process with the provision of technical tools for communications between the review project team and the MS and ensures that data for review is provided to the review project team.

(e) The review project team, contracted by the EC, which shall plan and undertake the reviews. The Technical Expert Review Teams (TERTs), see below, will be part of this project team. This work will include:

(i) development of the review guidelines and the review report template– including information tailored to the needs of MS, and separately for the members of the TERT. (ii) participation in preparatory meetings with MS, to support information dissemination about the reviews. (iii) organization of the training of the expert reviewers, regarding the focus and scope of the review, and the review processes and tools and platforms available to support the expert reviewers. (iv) performance of the initial checks by making a check of each data submission, drawing attention to missing data and the results, and providing information as input into the technical review. (v) proposing review teams of technical experts (TERTs), for approval by the EC. (vi) preparing and make available to the TERT data to be reviewed in the technical desk and centralized review in an appropriate format, including: background material, results from the initial checks, informative inventory reports (IIRs), previous review findings, and other ad hoc review findings; (vii) organizing and managing the technical reviews (together with the EEA) venues and timing for the meetings); (viii) editing and publish the technical review reports based upon input provided by the TERT, and communicate the results to the EC;

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(f) The Technical Expert Review Team (TERT): The expert reviewers are organised into technical expert review teams (TERTs). The members of the TERT are decided by the EC, after being proposed by the project co-ordinator contracted to manage the reviews. TERTs are responsible for undertaking the technical review and generating corresponding outputs. They shall:

(i) carry out the technical reviews in order to assess whether the submissions reported by MS are consistent with the requirements of the NECD and the EMEP Reporting Guidelines. (ii) where reported data is found to be inconsistent with the recommended methodologies of the EMEP/EEA Guidebook 2016 or where emission estimates are not provided for an NFR source category, the TERT will follow guidance that may result in the determination and implementation of technical corrections to MS emissions inventories (see Annex 1); (iii) prepare a draft review report for each MS reviewed using an agreed template, describing the findings of the technical review including recommendations for improvements, and clearly describing the justification for and methodological details of any technical correction(s) performed; (iv) taking into account comments from the EC and MS, finalise the review report findings.

V. REVIEW OF ANNUAL SUBMISSIONS

A. Initial Checks 19. The review project team shall conduct the basic initial checks of the submission noting

the timeliness, completeness, adherence to the correct format. They will also be required to work closely with the EEA’s European Topic Centre team, who will be undertaking emissions data checks, and providing outputs for use in the NECD review project. Examples of checks that may be carried out include:

(a) an overview of the key category analysis (KCA) per MS; (c) assessment of consistency of the time series by identifying dips and jumps. (d) checks against previously reported inventories for recalculations and changed estimates to determine whether methods and data have been applied consistently across the latest time series (for the pollutants considered in the 2017 review, and not HMs or POPs). (e) review of comparability across MS by calculation of indicators (e.g. emissions per GDP and per capita). (f) checks of accuracy (g) assessment of completeness of submitted inventories by highlighting notation keys indicating missing estimates. (h) comparison with alternative inventories for the HMs and POPs

20. The initial checks will review whether recommendations made during the NECD Review in 2017 have been addressed by the MS in the submission provided.

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Findings will be provided to the TERT for the technical review. In exceptional circumstances, the project team may request re-submissions in specific cases that impact on the ability of the project team to undertake the review.

B. Technical Review

i. BACKGROUND

21. Following completion of the Initial Checks, a Technical review will be performed by the TERT.

22. The purpose of the technical review is to examine in detail, and in a transparent

manner, the reported inventory information for consistency with the reporting requirements of the NECD, providing recommendations for improvement and where appropriate calculation of technical corrections. This will: (a) ensure that the EU has adequate, reliable and verified information on annual NECD inventories and emission trends of anthropogenic emissions by sources; (b) advise users of the data gaps and revisions needed in country data; (c) inform the work of the EC by providing an objective, consistent and transparent technical assessment of the annual quantitative and qualitative inventory information submitted by MS. (a) assist MS to improve the quality of their emission inventories.

23. The technical review will be a desk review followed by a centralized review i.e. the TERT

members will assess the available information and prepare questions to MS at their desks, prior to meeting for the “review week”.

ii. COUNTRIES

24. Technical reviews will be conducted for all MS, but the extent to which this is possible will depend on the information submitted, and will be reviewed on the 15th of April at the latest. The geographical coverage of MS will be as specified in the NECD for reporting against 2010 emission ceilings.

iii. POLLUTANTS

25. The technical review will include a review to assess whether findings from the 2017 review have been addressed (hence potentially referring to NOx, NMVOC, SO2, NH3, and PM2.5). The review will also include an assessment of emissions of HMs and POPs, and more specifically: Cadmium (Cd), Mercury (Hg), Lead (Pb) and polycyclic aromatic hydrocarbons (PAHs), dioxins/furans, polychlorinated biphenyls (PCBs), and hexachlorobenzene (HCB)

26. Reported activity data relevant to the pollutant emissions may be assessed in addition

to the emission estimates.

iv. SECTORS

27. The review will cover all the NFR emission source categories within the national total, relevant for each of the pollutants under review. Specifically, the national totals for demonstrating compliance with the 2010 emission ceilings (which require NOx and

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NMVOC from agriculture to be included). It shall focus on, but not be limited to, the review of key categories. Selected Memo items will also be included in the review; in particular the memo-item on fuel used based transport emissions when relevant for compliance assessment.

28. The key category analyses will include an assessment of the reported and potential

other key categories for each MS. The review will assess whether or not such sources were included and evaluate the methods used for estimating these emissions.

v. YEARS

29. The review to assess whether findings from the 2017 review have been addressed will relate to 2005, 2010 and 2015. The review of HMs and POPs will consider emissions data from 1990, 2005 and 2016. A focus shall be on ensuring that a consistent approach has been taken in estimating emissions for these years and that emission estimates are complete. In addition, time series consistency checks will be carried out.

vi. PROCEDURES

A. Tasks and responsibilities for the TERT

30. The TERT will use the findings from the initial checks as a starting point and only assess other issues in exceptional cases.

31. Each TERT shall follow checklists, which may require some or all of the following to be undertaken: (a) Examine the application of the EMEP Reporting Guidelines and the use of the EMEP/EEA Guidebook 2016 and identify non-compliance with these requirements;

(b) Examine whether the good practice guidance of the EMEP/EEA Guidebook 2016 has been applied and documented in the IIR, in particular in relation to transparency, noting the identification of key categories, selection and use of methodologies and assumptions, development and selection of emission factors, collection and selection of activity data, reporting of recalculations and consistent time-series and quality assurance and quality control procedures, and identify any inconsistencies;

(c) Compare emission estimates, activity data, implied emission factors and any recalculations (for the pollutants reviewed under the 2017 NECD review) with data from previous submissions, to identify any irregularities or inconsistencies;

(d) Identify any missing sources and examine any explanatory information relating to their exclusion from the inventory. It may be necessary to draw on other national datasets to achieve this analysis, such as information submitted to the MMR/UNFCCC;

(e) Identify the reasons for any differences between a MS’s and the project teams key category determination;

(f) Assess the consistency of information in the reporting tables with that in the IIR;

(g) Assess the extent to which issues raised in the initial checks, as well as issues and questions raised in previous reviews conducted under the NECD or the CLRTAP have been addressed and resolved;

(h) examine in particular emission estimates for categories for which adjustment applications have been submitted;

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(i) Identify areas for further improvement of the inventories and note possible ways for improving the estimation and the reporting of inventory information;

(j) Consider the entire inventory process from the collection of data to the reported emission estimates and examine procedures and institutional arrangements for inventory development and management, including quality assurance and quality control, record-keeping and documentation procedures;

(k) Calculate technical corrections for those emissions source categories where the Reporting Guidelines and/or methodologies of the EMEP/EEA Guidebook 2016 have not been followed, and/or where no emission estimate has been provided. The calculation of Technical Corrections will definitely be undertaken for cases where the TERT does not agree with the implementation of revised estimates or technical corrections arising from the NECD Review 2017, and/or where no agreement can be reached during the review and for recommendations relating to the use of Guidebook versions prior to the 2016 EMEP/EEA Guidebook that concern key categories and that are above the threshold of significance (see below).Technical corrections shall be calculated in consultation with the respective MS by using the default methodologies and emission factors (Tier 1 or Tier 2) provided in the EMEP/EEA Guidebook 2016 with activity data from the MS’s submission, IIR, and/or other appropriate sources including national and international statistical organizations. The TERT will use a Tier 2 approach for the calculation of technical corrections for key categories where this is possible. The TERT will document and justify cases where a technical correction cannot be performed, while making every effort to keep those cases to a minimum. More information on technical corrections is included as Annex 1.

(l) The TERT may use other relevant technical information in the review process, such as information from national and international organizations.

B. Methods and procedures for the TERT

32. Inventory submissions from each MS will be assigned to a TERT that will be responsible for conducting the review in accordance with the procedures and time frames established.

33. Each TERT will provide a thorough technical assessment of the inventory information

submitted and will, under its collective responsibility, prepare a review report in accordance with the principles given in this document, and the “Guidance on Review Procedures for TERTs”.

34. TERTs will be coordinated by the project team, which will provide administrative

support, and, as appropriate, technical and methodological assistance, as well as assistance in the use of these Review Guidelines.

35. TERTs will be composed of experts proposed by the project co-ordinator, and agreed by

the EC on the basis of their professional experience in compiling and/or reviewing emission inventories. A member of the TERT shall not review a national inventory of their own country, or one where they contributed to emissions estimates.

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36. Communication between the TERT and the nominated national contact point of the MS under review should be through the lead reviewers or designated contact of the project team. The EMRT-NECD web-based tool will be used as the communication platform within the TERT and with MS. Other communication routes will only be used in exceptional circumstances and if agreed with the respective MS Information provided to a specific member of the TERT may be made available to other members of the team.

C. TERT composition

37. Each TERT will comprise a lead reviewer (see below), and expert reviewers assigned to

the following sectors: energy – stationary combustion and fugitive; energy - road transport and other mobile sources; industrial processes and product use and solvents and other products use; agriculture; waste. When undertaking the review of the 2017 outputs and the review of HMs and POPs, the sector experts in the different teams will act as counterparts ('peers') and will check each other's results in order to ensure the four-eyes-principle.

38. The composition of the TERT shall be designed to ensure that the collective skills of a

team address the sectors mentioned above and that experts in a team have the necessary experience in the review process. TERT members have also been selected with a view to achieving a balance between experts from MS with different inventories and national circumstances in the overall composition of the expert review teams, without compromising the selection criteria referred to above.

D. Lead reviewers

39. For each of the four TERTs an inventory expert with substantial inventory review experience and management skills will serve as a lead reviewer.

40. Lead reviewers should ensure that the review in which they participate is conducted in

line with the methods and procedures indicated in the present document and that the expert team carries out the reviews consistently across all MS and years under review. Besides ensuring a consistent approach across the four TERTs, they should also ensure the quality and the objectivity of the technical assessments in the reviews.

41. Lead reviewers will compile draft review reports and document technical corrections. 42. Lead reviewers will undertake the following (selected tasks will require support from

other members of the project team): (a) prepare a brief work plan for the review activity;

(b) verify that the experts have all the necessary information provided by the project team prior to the review activity;

(c) ensure that there is good communication within the TERT;

(d) monitor the progress of the review activity;

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(e) coordinate and check queries of the TERT to the MS’s nominated national contact point and coordinate the inclusion of the answers in the review reports;

(f) provide technical advice to the TERT members and ad hoc experts, if needed;

(g) verify that the review team gives priority to individual source categories for review in accordance with these guidelines.

(h) ensure that the review is performed in accordance with these guidelines;

(i) have responsibility for the compilation of the review reports in line with the agreed template and submit the draft reports to the project team manager.

(j) assist the project team manager with the finalisation of the review reports following receipt of comments of any country.

E. Quality Assurance and Quality Control

43. Throughout the report, quality assurance and quality control will be assured by the quality controller. The quality controller will undertake a number of key QA/QC activities at various stages of the review.

44. In the preparatory phase the quality controller will: Quality check the tools and materials that are developed by the project team and

that are provided to the Commission and EEA.

Quality check the training materials.

Contribute to the development of a guidance document for the reviewers including quality guidelines.

45. During the review the quality controller (together with the project manager) will participate in the centralised review in order to ensure consistency across Member States. He will pay particular attention to checking the following:

Identification of potential technical corrections.

Calculation of potential and final technical corrections for Member States

Draft review reports

Final review reports for submission to the EC

46. The quality controller will have an important role in ensuring the high quality of other project deliverables by quality checking:

Workplan and final project report

The reports on potential technical corrections

vii. REVIEW REPORTS

47. To inform MS as early as possible about recommendations from the NECD Review 2018 and with the aim to enable MS to implement these recommendations in the inventory submission in 2019, each MS will receive an “Initial Outcomes Report”. This report will list all recommendations, but will not contain all elements of the Final Review Reports. As this report will be prepared before MS provide feedback on potential technical corrections, the status of technical corrections and revised estimates will not be final.

48. Under its collective responsibility, the TERT will produce for each reviewed country a review report. The review reports should contain an objective assessment of the

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adherence of the inventory information to the Reporting Guidelines and should not contain any political judgement. The reports will be provided to the EC, who will make them available in the public domain.

49. The report should be as concise as possible, focussing on particular strengths and

identified problems, as well as on an overall appraisal of the quality and reliability of the inventory, the implementation of the recommendations from the NECD review 2017, emission trends, actual emission factors and activity data, the degree of adherence to the Reporting Guidelines and the EMEP/EEA Guidebook 2016, improvement recommendations, and providing details of any identified technical corrections.

50. The review report shall also provide an overview of key review findings including:

(a) a summary including assessment of mandatory reporting requirements, timeliness, formats, completed tables;

(b) key issues related to data quality, such as an assessment of transparency, major issues relating to completeness and use of methods, major inconsistencies in time series, issues with recalculations, implementation of the recommendations from the NECD review 2017 and an overview of identified technical corrections;

(c) a summary of identified recommendations and how these relate to the inventory quality criteria defined in the EMEP Reporting Guidelines i.e. transparency, consistency, comparability, completeness or accuracy;

(d) justification and details of any identified technical corrections;

(e) recommendations concerning adjustment applications where appropriate.

51. The main body of the review report shall detail the review findings and

recommendations to the MS, including: (a) Sector specific recommendations for inventory improvements

(b) the detailed technical basis upon which technical corrections have been estimated.

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ANNEX 1: TECHNICAL CORRECTIONS AND REVISED ESTIMATES

Introduction 52. Under certain circumstances, the TERT is required to estimate “technical corrections” to

be subsequently applied to the inventories of the MS. The principle of establishing technical corrections has existed in the framework of the annual review of greenhouse gas emissions inventories (under the EU MMR and UNFCCC), but was only introduced recently in the field of air pollutant emissions inventory reviews. Consequently, it is appropriate to provide some background to the concept, some definitions, and information on the different steps of the process.

The Concept of Technical Corrections and Revised Estimates

53. The objective of technical corrections process is to establish improvements in completeness, consistency, comparability and accuracy of the reported emissions data from MS.

54. Where reported data is found to be inconsistent with the NECD requirements, and in

particular the recommended methodologies of the EMEP/EEA Guidebook 2016 or where emission estimates are not provided for an NFR source category, the TERT liaise with the MS to understand the issue in detail and quantify the extent to which emissions might be corrected to ensure compliance with best practice.

55. If the TERT considers that emissions are significantly under or overestimated7, then the

MS is invited to make a revised submission with “revised estimates” that address the issue raised. Should the MS decline to do this, then the TERT will calculate a “technical correction”.

56. Where the MS concerned and the Commission are unable to reach an agreement on

the necessity or on the content of a technical correction as calculated and proposed by the TERT, the Commission shall, pursuant to article 10(3) of the NECD, adopt a decision laying down the technical correction to be applied by the MS concerned.

57. Technical corrections and revised estimates shall apply to the full time series of national

emission estimates and shall be incorporated by MS prior to next year’s reporting on the 15 February. Where necessary, technical corrections and revised estimates shall be recalculated to account for improvements made to input data.

58. The review report will include a justification and details of any of any revised estimates

or technical corrections.

7 The term “significantly” is defined by the use of thresholds for the amount by which the emissions estimates would be changed. In addition, the use of Tier 1 methodologies for key categories will be considered as potentially giving rise to a significant overestimate.

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Quantification of a Technical Correction 59. Where the TERT conclude that a correction at NFR sector level, or a cumulative effect

across several NFR sectors, would result in more than a 2% impact on the MS national total in one of the reported years under review (2005,2010, 2015/2016), the MS will be invited to make a revised estimate. Corrections that result in a smaller impact will result in a recommendation and not a requirement for a revised estimate - unless (at the discretion of the Lead Reviewer), it is concluded that there are numerous corrections below the 2% threshold that would sum to an impact substantially above the threshold.

60. Revised estimates and technical corrections are calculated in consultation with the

respective MS by using the default methodologies and emission factors (Tier 1 or Tier 2) provided in the 2016 version of the EMEP/EEA Guidebook with activity data from the MS’ submission, IIR, and/or other appropriate sources including national and international statistical organizations. A Tier 2 approach will be used for the calculation of technical corrections for key categories where this is possible. The TERT will document and justify cases where a technical correction cannot be performed, while making every effort to keep those cases to a minimum.

The Process of Determining and Calculating Technical Corrections 61. Recommendations will be flagged as potential technical corrections where the TERT

does not agree with the implementation of revised estimates or technical corrections arising from the NECD Review 2017, and/or where no agreement can be reached during the review for recommendations relating to the use of Guidebook versions prior to the 2016 EMEP/EEA Guidebook that concern key categories and that are above the threshold of significance. For HMs and POPs no potential technical corrections will be calculated during the NECD Review 2018. The following provides a summary of the process by which revised estimates and technical corrections are determined:

1. The TERT highlight an observation and issues questions to the MS. The TERT

mentions in their question whether this could relate to an over or under estimate and possible technical correction.

2. The MS responds with clarifications and/or answers. The MS can provide a justification for their existing estimate, or propose a revised estimate that addressed the issue raised by the TERT. The revised estimate may span several sources, several pollutants, and be relevant for the entire time series.

3. The TERT respond to the MS to indicate whether they agree with the MS response (justification or revised estimates) or whether they propose a technical correction.

4. MS can respond to say they agree with the technical correction and convert it into a revised estimate, or MS can respond to say they disagree, and provide a justification for their position.

5. If the TERT do not agree with the information provided by the MS, they inform the MS, and draft a technical correction which is included in the draft review report that is sent to the MS.

6. MS have a further opportunity to respond to the TERT’s conclusions in the draft report, which will be considered by the review team.

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7. The TERT make a final decision whether to uphold the technical correction, and include it in the final version of the review report.

8. The views of the MS will be reflected in the Review report. 9. The EC shall consider the technical corrections proposed by the contractor. Where it

is considered grounds for the technical correction to exist, and where disagreement from a MS on the proposed technical correction remains, the Commission shall in accordance with article 10(3) of the NECD adopt a decision laying down the technical correction. In particular, for those cases where the TERT does not agree with the implementation of revised estimates or technical corrections arising from the NECD Review 2017, and where the Commission agrees with the TERT conclusion, it will also adopt a decision in accordance with article 10(3) laying down the technical correction.

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ANNEX 2: REVIEW OF ADJUSTMENT APPLICATIONS

Introduction 62. Article 5 of the NECD (Directive (EU) 2016/2284) explains that MS may draw on a

number of different flexibilities. This includes the option of applying for an Adjustment to the national total, under selected circumstances. Article 21(2) allows the use of the adjustment flexibility also for the 2010 ceilings that will remain applicable until 31/12/2019.

63. Adjustment applications newly made in 2018 under the NECD will be reviewed.

Furthermore, adjustments accepted under the NECD in previous years will also be reviewed. MS should indicate by 15 February (at the latest) for which pollutants, sectors and years they plan to submit adjustment application.

64. All supporting information for the adjustment application should be included in the IIR

to be submitted by 15 March, including a demonstration that the use of the adjustment procedure fulfils the relevant conditions set out in article 5(1) and part 4 of Annex IV. Information on recalculations relating to adjustments approved prior to 2018 shall be reported on sectoral level (see reporting requirements relating to Annex VII) and in line 143 of Annex I. Along with Annex VII MS should submit the “Declaration on consistency” with a short summary information on potential recalculations of approved adjustments.

Process and Guidance for the Review of Adjustment Applications 65. Article 5.8 of the NECD text (Directive (EU) 2016/2284) explains that “The Commission,

when exercising its powers under paragraphs 6 and 7 (reviewing the use of flexibilities), shall take into account the relevant guidance documents developed under the LRTAP Convention.” As explained above article 8(4) and part 4 of Annex IV of the NECD text further specify that Member States that opt for the adjustment flexibility must include supporting information in the Informative Inventory Report, including a demonstration that the use of the adjustment procedure fulfils the relevant conditions set out in article 5(1) and part 4 of Annex IV. The minimum supporting information required is highlighted in part 4.1 of Annex IV (which is based on paragraph 2 of the Annex to LRTAP Executive Body Decision 2012/12). In the chapeau of Annex IV it is further specified that adjusted emission inventories should be prepared using the EMEP reporting guidelines (which in its turn contains references to the relevant EB decisions 2012/3 and 2012/12, as amended by 2014/1), while also adding that reliance upon these EMEP reporting guidelines is without prejudice to the additional arrangements specified in part 4 of Annex IV. Consequently, the review of Adjustment applications under the NECD will in principle follow the process for reviewing Adjustment applications made under the CLRTAP (as presented in relevant EB decisions), however (formally) without prejudice to the additional arrangements specified in part 4 of Annex

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IV of the new NECD.8 It allows inter alia the submission of additional information during the review, necessary for a proper and full assessment of the adjustment application.

66. Technical corrections and revised estimates may change the national emission totals

making a specific adjustment no longer necessary or make a specific adjustment incompatible/invalid when applied to the same category for which a technical correction or revised estimate was approved. Adjustment applications should also be reviewed in these cases, but any recommendation on the review of concerned adjustment applications should be subject to the outcome of the work on technical corrections and revised estimates. The review of an adjustment application can therefore recommend acceptance or rejection (with the possibility of a resubmission next year if still appropriate/required, for instance where recalculations or a changed methodology are needed and have not been provided by the MS in the year in question).

8 See the following overview and guidance documentation: ECE/EB.AIR/111/Add.1, ECE/EB.AIR/113/Add.1, ECE/AB.AIR/127/Add.1 and ECE/EB.AIR/130).