Introduction - European Commissionec.europa.eu/environment/air/pdf/reduction_reports/2018/... · Web viewwere the base for this assessment. In addition an in-depth review of the national

Final Review Report2018

Second phase of review of national air pollution emission

inventory data pursuant to the Directive on the Reduction of

National Emissions of Certain Atmospheric Pollutants (Directive (EU) 2016/2284 or ‘NECD’)

Luxembourg30 November 2018

Reference: 070203/2017/765105/SER/ENV.C.3

Umweltbundesamt GmbHSpittelauer Lände 5

1090 ViennaAustria

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ContentsI. Introduction......................................................................................................................................5

II. Objectives of the review...................................................................................................................5

III. Review approach, team and scope...............................................................................................6

IV. Findings and Conclusions from the Technical Expert Review Team (TERT) for the follow-up to the 2017 in-depth EU review....................................................................................................................9

V. Findings and Conclusions from the Technical Expert Review Team (TERT) for the first phase of the in-depth review of national emission inventories of POPs and heavy metals........................................36

Cross cutting recommendations on HMs and POPs................................................................................41

VI. Effect of revised estimates, technical corrections and adjustments recommended to be approved on the national total and national total for compliance.........................................................41

VII. Statement from Luxembourg on the conclusions presented by the TERT..................................43

VIII. Findings and Conclusions from the Technical Expert Review Team (TERT) for the Review of adjustment applications.........................................................................................................................43

ANNEX I Technical corrections deemed necessary by the TERT and revised estimates provided by Luxembourg............................................................................................................................................44

ANNEX II Review of the 2018 adjustment applications of Luxembourg: TERT report for the EC............46

References and Supporting Documents.................................................................................................52

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List of tablesTable 1: Scope of the comprehensive technical review NECD 2018 (under (EU) 2016/2284)..................8Table 2: Recommendations from the NECD Review 2017, considering revised estimates (RE), technical corrections (TC) and their status of implementation in the inventory submission 2018........................10Table 3: Additional recommendations made during the NECD Review 2018 for NOX, NMVOC, SOX, NH3, PM2.5 considering revised estimates (RE), technical corrections (TC).....................................................35Table 4: Recommendations from the NECD Review 2018 concerning the first phase of the in-depth review of national emission inventories of POPs and heavy metals.......................................................37Table 5: National totals as reported and national totals including revised estimates (RE), technical corrections (TC) and adjustments for NOX, NMVOC, SOX, NH3, PM2.5 .....................................................41Table 6: Summary tables of Technical Corrections and/ or Revised Estimates.......................................44Table 7: Summary information on the Submitted Adjustment Applications, Luxembourg, 2018...........46Table 8: The 2018 Review team of new and previously accepted adjustment applications...................48Table 9: Conclusions and recommendations from the review team on previously accepted adjustment applications............................................................................................................................................49Table 10: Recommendations following the 2018 review of previously accepted adjustment applications...............................................................................................................................................................51Table 11: Information Provided by Luxembourg....................................................................................51Table 12: Additional Information Provided by Luxembourg...................................................................52

Abbreviations

Adj AdjustmentAD Activity DataEC European CommissionEEA European Environment AgencyEF Emission Factor EMEP European Monitoring and Evaluation ProgrammeEMRT Emission Review ToolEU European UnionGB GuidebookHMs Heavy MetalsIE Included Elsewherekt KilotonnesLR Lead Reviewer MS Member StateN NitrogenNA Not Applicable NE Not EstimatedNECD National Emissions Ceilings DirectiveNFR Nomenclature for Reporting

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NH3 AmmoniaNMVOC Non-methane volatile organic compoundsNO Not Occuring NO2 Nitrogen dioxideNOX Nitrogen oxidesPM2.5 Particulate matter equal to or less than 2.5 micrometres in diameterPOPs Persistent Organic PollutantsPTC Potential Technical Correction RE Revised estimateSO2 Sulphur dioxideSOX Sulphur oxidesTC Technical correctionTERT Technical Expert Review TeamVOC Volatile organic compounds

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I. Introduction1. The review of the air pollution emission data submitted by Member States (MS) under the European Union’s National Emissions Ceilings Directive (Directive (EU) 2016/2284) is defined in Article 10(3):

"The Commission, assisted by the European Environment Agency and in consultation with the Member States concerned, shall review the national emission inventory data in the first year of reporting and regularly thereafter. That review shall involve the following:

(a) checks to verify the transparency, accuracy, consistency, comparability and completeness of information submitted;

(b) checks to identify cases where inventory data is prepared in a manner which is inconsistent with the requirements set out under international law, in particular under the LRTAP Convention;

(c) where appropriate, calculation of the resulting technical corrections necessary, in consultation with the Member State concerned.

Where the Member State concerned and the Commission are unable to reach an agreement on the necessity or on the content of the technical corrections pursuant to point (c), the Commission shall adopt a decision laying down the technical corrections to be applied by the Member State concerned.”

2. The second phase of the technical review of NECD inventories was undertaken in accordance with the EU Air emission inventory review guidelines under Service contract No. 070203/2017/765105/SER/ENV.C.3 (EU 2018).

3. The technical review assessed the implementation of all recommendations, potential technical corrections and revised estimates from the NECD Review 2017. The Review Reports from the year 20171 were the base for this assessment. In addition an in-depth review of the national emission inventories of the POPs and heavy metals was initiated and in accordance with the requirements of the NECD (Article 5(8)), all new adjustment applications submitted in 2018 were reviewed in-depth and all adjustment applications submitted in 2018, that were already submitted, reviewed and accepted in 2017 were reviewed with a focus on reviewing the consistency in the reporting of these adjustment applications: For the review of the adjustment applications the Technical Guidance for Parties Making Adjustment Applications and for the Expert Review of Adjustment Applications (ECE/EB.AIR/130)2 was used.

II. Objectives of the review4. The general objective of the second phase of the technical review of Member States’ NECD inventories as reported in February 2018 (and updated before 15 March 2018) was an improvement of transparency, consistency, comparability, completeness and accuracy of submitted data and as such will contribute to establishing accurate, reliable and verified emission inventories for all Member States.

1 Available at http://ec.europa.eu/environment/air/reduction/implementation.htm

2 http://www.ceip.at/fileadmin/inhalte/emep/Adjustments/ECE_EB_AIR_130_AV_for_the_web.pdf

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http://www.ceip.at/fileadmin/inhalte/emep/Adjustments/ECE_EB_AIR_130_AV_for_the_web.pdf

http://ec.europa.eu/environment/air/reduction/implementation.htm

5. The specific objectives of the second phase of the technical review of Member States’ NECD inventories were:

a. a detailed review to verify that Member States have effectively integrated the revised estimates, technical corrections and other relevant recommendations from the 2017 in-depth EU review in their national emission inventories

i. a full in-depth review of national emission inventories, including the calculation of technical corrections, for Greece and Finland as these Member States were not reviewed in-depth in 2017 due to the lack of reporting of the necessary quantitative and qualitative data in 2017

b. initiation of an in-depth review of the national emission inventories of the POPs and heavy metals for which the new NECD sets out mandatory reporting (see table A of Annex I of Directive (EU) 2016/2284), i.e. polycyclic aromatic hydrocarbons (PAHs), dioxins/furans, polychlorinated biphenyls (PCBs), hexachlorobenzene (HCB), cadmium (Cd), mercury (Hg) and lead (Pb);

c. an expert review of

i. new adjustment applications submitted in 2018, not submitted and reviewed yet in 2017 under the new NECD, including the review of the supporting documentation as requested in part 4 of Annex IV of the new NECD and an assessment of whether the adjustment application is consistent with the circumstances described therein

ii. the adjustment applications submitted in 2018, that were already submitted, reviewed and accepted in 2017 under the new NECD (and/or previously under CLRTAP), with a focus on reviewing the consistency in the reporting of these adjustment applications;

6. The review also sought to harmonise approaches used in monitoring inventories reported under the NECD with reviews undertaken by other organisations that have similar interests such as the reviews under the LRTAP Convention and the EU Greenhouse Gas Monitoring Mechanism (MMR)/United Nations Framework Convention on Climate Change (UNFCCC).

III. Review approach, team and scope7. For the Follow-up to the 2017 in-depth EU review the TERT performed a consistent and detailed review to verify that all Member States have effectively integrated the revised estimates, technical corrections and other relevant recommendations from the 2017 in-depth EU review in their national emission inventories of SO2, NOX, PM2.5, NMVOC and NH3.

For Greece and Finland that were not reviewed in-depth in 2017 due to the lack of reporting of the necessary quantitative and qualitative data in 2017, an in-depth review of their national emission inventories of SO2, NOX, PM2.5, NMVOC and NH3 was performed in accordance with the requirements in the guidelines and guidance that were prepared for the 2017 in-depth EU review.

8. For the first phase of the in-depth review of national emission inventories of POPs and heavy metals the TERT focused on the completeness and consistency in the emission reporting of

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PAHs, dioxins/furans, PCBs, HCB, Cd, Hg and Pb with special emphasis on the review of identified key categories.

9. The results of this first phase of the in-depth review were general and sector specific recommendations for quick and obvious improvements of Member States' POPs and heavy metals inventories and did not include proposals for technical corrections or revised estimates. Focus was on the years 1990 (most common reference year used for compliance with basic reduction obligations under the POPs and heavy metals protocols), on 2005 and 2016. However, the consistency of time series data was also checked for all reported years.

10. Review of adjustment applications: New adjustment applications submitted in 2018 were reviewed in depth. Adjustment applications submitted in 2018, that were already submitted, reviewed and accepted in 2017 under the new NECD (and/or previously under CLRTAP) were reviewed with a focus on consistency in the reporting of these adjustment. The review of adjustment applications followed the Review Guidance. The review was performed by relevant sector experts reviewing particular sectors and coordinated by the adjustment lead reviewer.

11. The review was split in two phases:

a) Initial checks were carried out (by the project team) under service contract No. 70203/2017/765105/SER/ENV.C.3 and by the EU inventory team (ETC/ACM). Significant findings from the initial checks that were relevant for the second phase of the technical review and that were not resolved within the initial check phase were followed up by the TERT in the comprehensive desk and centralised review.

b) A Desk Review and Centralised Review was performed by the TERT under service contract No 70203/2017/765105/SER/ENV.C.3 of the Directorate General Environment of the European Commission. The TERT consisted of the following experts:

Lead Reviewers: Justin Goodwin, Kevin Hausmann, Ole-Kenneth Nielsen and Kristina Saarinen Energy: Rianne Dröge, Stephan Poupa, Glen Thistlethwaite and Katrina Young Transport: Jean Marc André, Giorgos Mellios, Tim Murrells and Giannis Papadimitriou IPPU: Coralie Jeannot, Jeroen Kuenen, Ardi Link and Ils Moorkens Agriculture: Michael Anderl, Bernard Hyde, Mette Mikkelsen and Beatriz Sánchez Waste: Céline Gueguen and Garmt Jans Venhuis.

12. The Desk Review and Centralised Review were coordinated by the project team (Sabine Schindlbacher, Katarina Mareckova, Chris Dore and Emma Salisbury).

13. The EEA Review Secretariat consisting of Federico Antognazza and Anke Lükewille supported the second phase of the technical review of Member States’ NECD inventories.

14. The review was performed on the basis of NECD emission data officially reported by Member States by 15 February 2018 and the Informative Inventory Reports (IIRs) reported by 15 March 2018 under the revised NEC Directive. Resubmissions and other additional information provided by Member States during the review were taken into account until 03 May 2018.

15. To avoid any potential conflicts of interest, the lead reviewers and sector review experts did not review emission inventories of Member States where these individuals have themselves contributed to the compilation of that inventory, or presently are or have been any part of the decision-making process related to the compilation of that inventory. Reviewers who are nationals

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of the Member State whose inventory is concerned, did not take part in the review of that inventory.

16. All review experts signed confidentiality agreements in which they agreed to keep information received by Member State confidential.

Table 1: Scope of the comprehensive technical review NECD 2018 (under (EU) 2016/22843)

Element Scope Further information

Member StatesEU geographical coverage of the MS

This Directive shall apply to emissions of the pollutants referred to in Annex I from all sources occurring in the territory of the MS, their exclusive economic zones and pollution control zones.This Directive does not cover emissions in the Canary Islands, the French overseas departments, Madeira, and the Azores.

Years

Issues raised in 2017 review:2005, 2010, 2015, 2016

HMs and POPs:1990, 2005, 2016

In addition, time series consistency was reviewed across the whole time series.

Pollutants

Issues raised in 2017 review:NOX, NMVOC, SOX, NH3, PM2.5

Review of POPs and Heavy Metals: PAHs, dioxins/furans, PCBs, HCB, Cd, Hg and Pb

According to NECD Article 1(1)

Categories

All NFR categories, including selected memo items

All NFR categories as listed in Annex 1 of reporting guidelinesIncluding the following memo items:1A3ai(ii) International aviation cruise (civil)1A3aii(ii) Domestic aviation cruise (civil)1A3di(i) International maritime navigation 1A3 Transport (fuel used) – where a MS uses fuel used for compliance purposes.

National totals

National total and National total for compliance

Rows 141 and 144 in Annex I to reporting Guidelines

3 DIRECTIVE (EU) 2016/2284 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 14 December 2016 on the reduction of national emissions of certain atmospheric pollutants, amending Directive 2003/35/EC and repealing Directive 2001/81/EC

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IV. Findings and Conclusions from the Technical Expert Review Team (TERT) for the follow-up to the 2017 in-depth EU review

17. The TERT assessed the implementation of all recommendations, technical corrections and revised estimates from the NECD Review 2017. This assessment was based on the inventory data submitted under the NECD in 2018 by Luxembourg pursuant to (Directive (EU) 2016/2284) and the Luxembourg Review Report from the year 2017.

18. Luxembourg provided to the Commission a resubmission on 15 March 2018. The TERT considered this resubmission as the basis for the comprehensive review.

19. Table 2 summarises the conclusions of the TERT for the recommendations and revised estimates from the NECD Review 2017 which were not implemented.

a. Recommendations: The TERT noted that Luxembourg has implemented only a few of the recommendations following the 2017 NECD review. The TERT recommends Luxembourg to implement all remaining recommendations by the next submission and flags that this is the second year in which these recommendations have been made.

b. Revised estimates: Luxembourg did not fully implement any of the revised estimates from the NECD Review 2017. Those technical corrections and revised estimates not implemented have been passed to the Commission which, in accordance with Article 10.3 last subparagraph of Directive 2016/2284, may adopt a decision laying down the technical corrections to be applied. The TERT were not satisfied with the implementation of 8 revised estimates from the 2017 NECD review but notes that they are either below the threshold of significance for a technical correction or related to a transparency issue in the IIR.

20. The TERT noted that the recommendation related to the use of the 2013 EMEP/EEA Guidebook was not implemented. The recommendation was not related to a key category. The TERT flags that this is the second year in which this recommendation has been made.

21. The TERT considers that it received responses from Luxembourg that were sufficient to undertake the follow-up to the 2017 in-depth EU review.

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Table 2: Recommendations from the NECD Review 2017, considering revised estimates (RE), technical corrections (TC) and their status of implementation in the inventory submission 2018

Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC4

GB 2016 Issue5

2017 LU-1A1-2018-0001

Yes 1A1 Energy Production, SO2, NOX, NMVOC, PM2.5, 2000-2015

For NFR categories 1A1 Energy Production, 1A2 Stationary Combustion in Manufacturing Industries and Construction and 1A4 Small Combustion and Non-Road Mobile Machinery the TERT noted that part of the emissions is estimated using emission factors from the 2009 EMEP/EEA Guidebook. In response to a question raised during the review Luxembourg explained that only a small part of the emissions is calculated using emission factors from the 2009 EMEP/EEA Guidebook and the main part of the emissions are based on company data or on emission factors from the 2016 EMEP/EEA Guidebook. Luxembourg did not provide a revised estimate, but they indicated that in the planned improvements of the respective categories, an alignment of the remaining default EFs from the 2009 version of the guidebook to the 2016 version will be undertaken for the next submission, if sufficient resources (financial and human) are available. The TERT noted that the issue is below the threshold of significance for a technical correction. The TERT recommends that Luxembourg recalculates the emissions using the 2016 EMEP/EEA Guidebook emission factors to its next submission.

No The TERT reiterates recommendation [LU-1A1-2017-0001] from the 2017 NECD Review regarding the use of emission factors from older version of the Guidebook. The TERT noted that the issue is below the threshold of significance for a technical correction. In response to a question during the review, Luxembourg explained that it will ensure that all methods and emission factors of categories 1A1, 1A2 and 1A4 will be compliant with the 2016 EMEP/EEA Guidebook in its 2019 submission.

No No No

4 Tier 1 used for a key category5 Issue related to use of GB prior to the 2016 version

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Tier 1 KC

GB 2016 Issue

2017 LU-1A2-2018-0001

No 1A2 Stationary Combustion in Manufacturing Industries and Construction, NH3, 2000-2015

For NFR categories 1A2f Stationary Combustion in Manufacturing Industries and Construction: Non-Metallic Minerals, 1A2gviii Stationary Combustion in Manufacturing Industries and Construction: Other and 1A4ci Agriculture/Forestry/Fishing: Stationary the TERT noted that Luxembourg did not report NH3 emissions from biomass combustion. In response to a question raised by the TERT, Luxembourg explained that under NFR 1A2f the combusted biomass consisted of fluff, sewage sludge and shredded tyres, and under NFR 1A4ci the combusted biomass consisted of biogas only. Luxembourg indicated that the default NH3 emission factor of biomass from Chapters 1A2 and 1A4 of the 2016 EMEP/EEA Guidebook are not valid for these fuels. Luxembourg also explained that under NFR 1A2gviii, wood is combusted and provided a first estimate of 0.0299 kt NH3 from 1A2gviii in 2015, and indicated that this is well below the threshold of significance. The TERT noted that the issue is below the threshold of significance for a technical correction. The TERT recommends that Luxembourg includes NH3 emissions from biomass combustion from NFR 1A2gviii in the next submission.

No The TERT reiterates recommendation [LU-1A1-2017-0001] from the 2017 NECD Review regarding NH3 emissions from biomass combustion. In response to a question raised during the review, Luxembourg explained that inclusion of NH3 estimates from 1A2gviii biomass combustion will be included in the 2019 submission.

No No No

2017 LU-1A2gvii-2018-0001

No 1A2gvii Mobile Combustion in Manufacturing Industries and Construction:

Regarding all relevant pollutants from NFR 1A4a Commercial/institutional the TERT noted that the entire category is reported as ‘NO’. Luxembourg states in its IIR that no diesel oil consumption is reported by the national energy balance for this

No Following a recommendation from the previous 2017 NECD Review, LU-1A2gvii -2017-0001, regarding changing the notation key of all relevant pollutants of sector 1A4aii from ‘NO’ to ‘IE’, the TERT

No No No

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Tier 1 KC

GB 2016 Issue

Other, SO2, NH3, NMVOC, PM2.5, 1990-2015

category and that LPG is supposed to be burnt entirely in stationary combustion units. As response to the question raised during the review, Luxembourg confirmed that emissions from mobile machinery under NFR 1A4aii Commercial/institutional: Mobile do occur but are included in mobile machinery from industry (NFR 1A2gvii Mobile Combustion in Manufacturing Industries and Construction), and agreed to change the notation key from 'NO' to 'IE' in the next submission. Furthermore, Luxembourg explained that the national energy balance assigns LPG for mobile use entirely to road transportation and that allocating a very small part to mobile machinery (NFRs 1A2gvii or 1A4aii) would be a rather complex task resulting in only a minor inventory improvement. The TERT acknowledges the information provided, welcoming Luxembourg’s plan to revise the notation key. Regarding the use of LPG, the TERT agrees in the statement provided, and recommends the Luxembourg to further look into this issue as soon as data and resources allow.

noted that this issue has not been addressed in the 2018 NFR tables. In response to a question raised during the review, Luxembourg answered that the notation key for sector 1A4aii will be changed from ‘NO’ to ‘IE’ for all relevant pollutants in the next submission 2019. The TERT welcomes this plan of Luxembourg and recommends that this issue is addressed in 2019.

2017 LU-1A2gvii-2018-0002

No 1A2gvii Mobile Combustion in Manufacturing Industries and Construction: Other, SO2, NOX, NH3, NMVOC, PM2.5, 1990-

For category 1A2gvii Mobile Combustion in Manufacturing Industries and Construction together with several non-road mobile sources, the TERT noted that activity data for biomass is reported as 'not occurring' ('NO'). In response to a question raised during the review, Luxembourg agreed that the notation key 'NO' needs to be changed to 'NA' for 1990-2003, and to 'IE' for

No Following a recommendation from the previous 2017 NECD Review, LU-1A2gvii-2017-0001, related to changing the notation key of biomass in sector 1A2gvii to 'IE', the TERT noted that this issue has not been addressed in the 2018 NFR tables. In response to a question raised during the review,

No No No

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Tier 1 KC

GB 2016 Issue

2015 2004-2015 as biomass use is included in liquid fuels. The TERT partly agreed with the explanation provided by Luxembourg, welcoming the plan to revise the named notation keys. However, in order to improve inventory’s transparency and comparability, the TERT recommends providing separate values for biomass, stating that these data should be available for GHG reporting. Furthermore, the TERT kindly invites Luxembourg to check the correct use of notation keys for activity data for all reported combustion sources.

Luxembourg answered that the change of the notation key for 1A2gvii biomass to ‘IE’ will be addressed in submission 2019. The TERT welcomes this plan of Luxembourg and recommends that this observation is definitely addressed in the next submission 2019.

2017 LU-1A3aii(i)-2018-0001

No 1A3aii(i) Domestic Aviation LTO (civil), NH3, 1990-2015

For NH3 emissions from categories 1A3ai(i) International Aviation LTO (Civil) and 1A3aii(i) Domestic Aviation LTO (Civil) the TERT noted that the emissions are reported as ‘NO’. To the question on the issue Luxembourg agreed, that the notation key needs to be changed to ‘NE’ as proposed by the 2016 EMEP/EEA Guidebook for emissions from aviation gasoline. The TERT recommends Luxembourg to change the notation key to ‘NE’.

No Following a recommendation from the previous 2017 NECD Review, LU-1A3aii(i)-2017-0001, related to changing the notation key of NH3 emissions from sectors 1A3ai(i) and 1A3aii(i) from 'NO' to 'NE', the TERT noted that this issue has not been addressed in the 2018 NFR tables. In response to a question raised during the review, Luxembourg confirmed this observation and promised to address this issue in the submission 2019. The TERT welcomes this plan and recommends that Luxembourg definitely addresses this observation in the next submission 2019.

No No No

2017 LU-1A3b-2018-0002

No 1A3b Road Transport, SO2, NOX, NH3,

For 1A3b Road Transport, all pollutants and years, the TERT noted that there was no evidence that the consumption of lubricants was accounted for

No Following a recommendation from the previous 2017 NECD Review, LU-1A3b-2017-0004, regarding the provision of

No No No

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Tier 1 KC

GB 2016 Issue

NMVOC, PM2.5, 1990-2015

in the energy balance for road transport used in the inventory. In response to a question raised during the review, Luxembourg explained that emissions from lubricant consumption in vehicles with 2-stroke and 4-stroke engines are included in the exhaust emissions from the different vehicle classes (1A3bi-1A3biv). The emission factors from HBEFA used in the NEMO model are based on real-world emission measurements and thus include emissions from lubricants. The TERT acknowledges that lubricant consumption represents a very small contribution to energy consumption by the sector and therefore makes a very small contribution to the emissions. The TERT notes that this issue does not relate to an under- or over-estimate but recommends that for completion the contribution of lubricants to the energy consumption assigned to 1A3b is taken into account in the future submissions and that correct assignment is applied to 2-stroke engines in 1A3b and 4-stroke engines in the IPPU sectors NFR 2D3 Solvent Use/2G Other Product Use, also avoiding a double-count for the IPPU sector.

clarifications on lubricant consumption, the TERT noted that no relevant information can be found in Luxembourg's IIR. In response to a question raised during the review, the Member State answered that relevant explanations will be provided in the next IIR 2019. The TERT welcomes this plan and recommends that for completeness the contribution of lubricants to the energy consumption assigned to 1A3b is taken into account and that correct assignment is applied to 2-stroke engines in 1A3b and 4-stroke engines in the IPPU sectors NFR 2D3/2G, also avoiding double-counting for the IPPU sector.

2017 LU-1A3biv-2018-0001

No 1A3biv Road Transport: Mopeds & motorcycles, PM2.5, 1990-2015

For 1A3biv Road Transport: Mopeds & Motorcycles and PM2.5 emissions in the years 2005, 2010 and 2015 the TERT noted that emissions in the NFR tables were reported as â€˜NOâ€™. In response to the question on the issue Luxembourg explained that this is because the HBEFA does not provide emission factors for PM2.5 emissions from mopeds

RE Following a previous recommendation from the 2017 NECD Review, LU-1A3biv-2017-0001, related to implementing a revised estimate for PM emissions from sector 1A3biv (reported as 'NO' until 2017), the TERT noted that there is an inconsistency between NFR and IIR,

No No No

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Tier 1 KC

GB 2016 Issue

and motorcycles. The TERT notes that Tier 3 emission factors and methodologies for estimating PM emissions from 1A3biv are provided in the 2013 EMEP/EEA Guidebook and in the 2016 EMEP/EEA Guidebook. Luxembourg provided revised estimates for the years 2005, 2010 and 2015 using a Tier 1 method and stated that it will consider to implement the Tier 2 default PM2.5 emission factors for mopeds and motorcycles in the emission model NEMO for its the next submission. The TERT agreed with the revised estimates provided by Luxembourg. The TERT recommends that Luxembourg includes the revised estimates in its next submission.

since these emissions are included in the 2018 NFR tables, but not reflected in IIR. In response to a question raised during the review, Luxembourg agreed with this observation and confirmed that the corresponding sections in the IIR will be updated to reflect this change. The TERT welcomes the plan of Luxembourg to align NFR and IIR regarding PM emissions from 1A3biv and recommends that this issue is addressed in the next submission 2019.

2017 LU-1A3bv-2018-0001

No 1A3bv Road Transport: Gasoline evaporation, NMVOC, 2005-2015

For NFR 1A3bv Road Transport: Gasoline Evaporation NMVOC emissions from evaporation, the TERT noted that emissions were proportionately low compared to other countries and low relative to Luxembourg's exhaust emissions of NMVOCs from passenger cars in NFR 1A3bi Road Transport: Passenger Cars. In response to a question raised during the review, Luxembourg explained that emissions were calculated using the NEMO model which is using a methodology older than in the 2013 EMEP/EEA Guidebook. The TERT estimated that using Luxembourg activity data in the more recent COPERT 5 model, which is consistent with the 2016 EMEP/EEA Guidebook, leads to NMVOC emission estimates 3-3.5 times higher than the reported

No Following a recommendation from the previous 2017 NECD Review, LU-1A3bv-2017-0001, related to low NMVOC evaporative emissions from sector 1A3bv, the TERT noted that these emissions have been recalculated in the 2018 submission (compared to 2017). However, information on how this recalculation was made could not be found in the IIR. In response to a question raised during the review, Luxembourg answered that, since submission 2018, NMVOC emissions from sector 1A3bv include parking, running losses, and hot soak, following a Tier 3 methodology based on the NEMO

No No Yes

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Tier 1 KC

GB 2016 Issue

emissions and would bring it more in line with other countries. The TERT notes that this issue does not relate to an under-estimate greater than the threshold of significance, but the level of under-estimates is considered very close to this threshold. The TERT therefore recommends that Luxembourg uses a methodology for 1A3bv emissions consistent with the 2016 EMEP/EEA Guidebook for the next submission.

model and compatible with the 2016 EMEP/EEA Guidebook. Luxembourg confirmed that these changes are not reflected in the IIR and that the corresponding sections need to be updated. The TERT welcomes the plan of Luxembourg to align NFR and IIR regarding NMVOC emissions from 1A3bv and recommends that this issue is addressed in the next submission 2019.

2017 LU-1A3bvi-2018-0001

No 1A3bvi Road Transport: Automobile tyre and brake wear, PM2.5, 1990-2015

For NFR 1A3bvi Road Transport: Automobile Tyre and Brake Wear and NFR 1A3bvii Road Transport: Automobile Road Abrasion PM2.5 emissions and the years 2005, 2010 and 2015 the TERT noted that emissions and IEFs were relatively high compared with other countries. In response to the question on the issue Luxembourg explained that there was an error in the non-exhaust emissions provided in the NFR tables under NFR 1A3bvi, and provided revised estimates for the years 2005, 2010 and 2015 (as well as the complete time series 1990-2015) covering NFRs 1A3bvi and 1A3bvii combined and stated that these will be included in the next submission. Luxembourg also agreed to explore the possibility of providing separate emissions for NFRs 1A3bvi and 1A3bvii rather than the combined emissions currently reported under NFR 1A3bvi. The TERT agreed with the revised estimates provided by Luxembourg. The TERT recommends that Luxembourg includes the revised estimates in

RE Following a previous recommendation from the 2017 NECD Review, LU-1A3bvi-2017-0001, related to implementing a revised estimate for PM emissions from sectors 1A3bvi - 1A3bvii (for which there was an error in 2017 submission), the TERT noted that there is an inconsistency between NFR and IIR, since these emissions have been correctly recalculated in the 2018 NFR tables, but not reflected in IIR. In response to a question raised during the review, Luxembourg agreed with this observation and confirmed that the corresponding sections in the IIR will be updated to reflect this recalculation. The TERT welcomes the plan of Luxembourg to align NFR and IIR regarding PM emissions from 1A3bvi - 1A3bvii and recommends that this issue is addressed

No No No

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Tier 1 KC

GB 2016 Issue

the next submission and provides separate estimates of PM2.5 emissions for NFRs 1A3bvi and 1A3bvii.

in the next submission 2019.

2017 LU-1A3c-2018-0001

No 1A3c Railways, SO2, NOX, NH3, NMVOC, PM2.5, 1990-2015

For category 1A3c Railways, together with 1A3di(ii) International Inland Waterways and 1A3dii National Navigation (Shipping), the TERT noted that activity data for biomass is reported as 'not applicable' ('NA'). In response to a question raised during the review, Luxembourg agreed that these notation keys need to be changed to 'NO' for 1990-2003, and to 'IE' for 2004-2015 as biomass use is included in liquid fuels. The TERT partly agreed with the explanation provided by Luxembourg, welcoming the plan to revise the named notation keys. However, in order to improve the transparency and comparability of the inventory, the TERT recommends providing separate values for biomass, stating that these data should be available for GHG reporting.

No Following a recommendation from the previous 2017 NECD Review, LU-1A3c-2017-0001, related to the usage of 'NA' for biomass of sectors 1A3c, 1A3di(ii), and 1A3dii, the TERT noted that biomass is still reported as 'NA' in the 2018 NFR tables. In response to a question raised during the review, Luxembourg answered that emissions reported for "liquid fuels" from sectors 1A3c and 1A3d are calculated on the basis of blended fuel consumption, thus emissions from biomass are included; and that the activity data reported for "liquid fuels" in the NFR tables also include biomass activity data. To improve transparency, Luxembourg confirmed that the notation key for biomass activity data for 1A3c, 1A3d, and all other mobile combustion categories will be changed from 'NA' to 'IE' (included in "liquid fuels") in the next submission 2019. The TERT welcomes this plan of Luxembourg and further recommends that, in order to improve inventory’s transparency and comparability, separate values for

No No No

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biomass should be provided, since these are already available (Luxembourg response). This recommendation had already been made during the NECD Review in 2017.

2017 LU-1B-2018-0001

No 1B Fugitive Emission from Fuels, SO2, NOX, NH3, PM2.5, 1990-2015

For subcategories of NFR 1B Fugitive Emission from Fuels, the TERT noted that some uses of the notation keys did not meet the definitions included in Section II.C of Annex I to the Reporting Guidelines and explained by Luxembourg in the IIR. This issue would have affected some NECD pollutants from NFR 1B1b (SOX), 1B1c (SOX), 1B2ai (all except NMVOC), 1B2aiv (all except NMVOC), 1B2c (SOX) and 1B2d (SOX). In response to the question on the issue Luxembourg confirmed to make changes in the notation keys used for the next submission to make them comply with the Reporting Guidelines. The TERT notes that this issue does not relate to an under- or over-estimate. The TERT recommends to use the notation key ‘NO’ for all pollutants when all the processes or activities covered within a category are not occurring in the country (e.g. solid fuel transformation -NFR 1B1b-, other fugitive emissions from solid fuels -NFR 1B1c- or other fugitive emissions for energy production -NFR 1B2c), the ‘NA’ notation key when there is no evidence (Guidebook) that the pollutant be emitted from any activity covered under the category NFR (e.g. NH3, NOX and SOX for NFR 1B1a)

No The TERT reiterates recommendation [LU-1B-2017-0001] from the 2017 NECD Review regarding the use of notation keys. In response to a question raised during the review, Luxembourg explained that it is planning to revise the notation keys in sector 1B for its submission 2019.

No No No

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and ‘NE’ when emissions occur from the category but no estimation or reporting has been implemented.

2017 LU-1B1a-2018-0001

No 1B1a Fugitive Emission from Solid Fuels: Coal mining and handling, PM2.5, 1990-2015

For category 1B1a Fugitive Emission from Solid fuels: Coal Mining and Handling and pollutant PM2.5 the TERT noted that the notation key ‘NO’ had been reported even though coal consumption was occurring. In response to a question raised during the review, Luxembourg provided a revised estimate for all the years. Luxembourg stated that the storage area, existing at four installations, had been calculated based on a rough estimation of coal capacity per ha and that the emissions had been over-estimated as no adjustment due to the actual storage time (estimated lower than two or three months) had been applied. The TERT disagreed with the revised estimate provided as it is very likely an over-estimation. The TERT noted that the issue is below the threshold of significance for a technical correction. The TERT recommends that Luxembourg includes a revised estimate based on the methodology and emission factors proposed in the 2016 EMEP/EEA Guidebook in the next submission.

No The TERT reiterates recommendation [LU-1B1a-2017-0001] from the 2017 NECD Review: “For category 1B1a and pollutant PM2.5 the TERT noted that ‘NO’ notation key had been reported even though coal consumption was occurring. In response to a question raised during the review, Luxembourg provided a revised estimate for all the years. Luxembourg stated that the storage area, existing at four installations, had been calculated based on a rough estimation of coal capacity per ha and that the emissions had been over-estimated as no adjustment due to the actual storage time (estimated lower than two or three months) had been applied. The TERT disagreed with the revised estimate provided as it is very likely an over-estimation. The TERT noted that the issue is below the threshold of significance for a technical correction. The TERT recommends that Luxembourg includes a revised estimate based on the methodology and emission factors proposed in the 2016 EMEP/EEA Guidebook in the next submission.” In

No No No

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response to a question raised during the review, Luxembourg explained that it will implement this review recommendation in its submission 2019, based on the calculation method proposed in the file LU-1B1a-2017-0001.xlsx provided during the review 2017.

2017 LU-2D-2018-0001

Yes 2D Non-energy Products from Fuels and Solvent Uses, NMVOC, 2015

For category 2D Non-Energy Products from Fuels and Solvent Uses the TERT noted that in the 2016 CLRTAP Stage 3 Review report the TERT encouraged Luxembourg to set a new pillar year for 2015 to verify and adjust the solvent sector data to keep the used methodology in the inventory as up-to-date as possible. In response to the question on the issue Luxembourg explained that due to time constrains, the evaluation has been postponed to the 2018 submission. The TERT recommends that Luxembourg updates and adjusts the methodology to the next submission.

No For category 2D and pollutant NMVOC, the TERT noted that Luxembourg did not implement a recommendation provided during the 2017 review (LU-2D-2017-0001). The recommendation concerned the introduction of a new pillar year (2015) in the methodology that Luxembourg uses to estimate NMVOC emissions from solvent use. In response to a question raised during the review, Luxembourg explained that the new pillar year had been introduced, but the text in the IIR had not been updated reflecting this change. Luxembourg agreed to update the IIR with this methodological update for the next submission. The TERT agreed and recommends that Luxembourg updates the IIR to be consistent with the latest emission estimates and the introduction of the new pillar year.

No No No

2017 LU-2D3c- No 2D3c Asphalt For category 2D3c Asphalt Roofing the TERT noted No For category 2D3c, the TERT noted that No No No

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2018-0001 Roofing, NMVOC, PM2.5, 2005, 2010, 2015

that the wrong notation keys have been used for NMVOC and PM2.5 emissions. In response to the question on the issue Luxembourg explained that the notation keys were changed to ‘NO’ in the IIR 2017, however this was not reflected for the other pollutants, nor in the NFR tables but that this will be corrected in the next submission. The TERT recommends that Luxembourg corrects the notation keys in the NFR table in its next submission.

Luxembourg has only partially implemented a recommendation from the 2017 review (LU-2D3c-2017-0001) in the 2018 submission. The recommendation was to review the use of notation keys, since the activity was not occurring. In the 2018 submission, only NMVOC emissions are indicated as NO while other pollutants were reported as ‘NA’ or ‘NE’. In response to a question raised during the review, Luxembourg acknowledged this was not correct and it would be corrected for the next submission. The TERT recommends changing the notation key to ‘NO’ for all pollutants for the next submission, as long as the activity is not occurring. In addition, the TERT recommends that Luxembourg explains that this activity is not occurring in Luxembourg in the IIR.

2017 LU-2G-2018-0001

No 2G Other Product Use, SO2, NOX, NH3, NMVOC, PM2.5, 2005, 2010, 2015

For category 2G Other Product Use the TERT noted that in the IIR Luxembourg has presented emissions from the use of tobacco and fireworks, but has not reported those emissions in the NFR table. The TERT also noted that the emissions from the use of shoes have not been estimated. In response to the question on the issue Luxembourg explained that the emissions from tobacco use and fireworks are mistakenly reported under NFR 2L Other Production, Consumption, Storage,

No For category 2G, the TERT noted that Luxembourg has only partially implemented recommendation LU-2G-2017-0001 in its 2018 submission. During the 2017 review, Luxembourg agreed to include an explanation for not reporting emissions from the use of shoes, but the 2018 IIR does not include this. In response to a question raised during the review, Luxembourg

No No No

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Transportation or Handling of Bulk Products instead of NFR 2G. Luxembourg also explained that regarding the use of shoes it is not clear from the 2016 EMEP/EEA Guidebook, whether these emissions occur during the production of shoes (use of adhesives/glues) or only from the use of shoes. Luxembourg stated that the estimation of emissions from the use of shoes is not justified and they will provide a short explanation in the IIR why they don't estimate emissions from the use of shoes. The TERT recommends that Luxembourg reallocates emissions from tobacco use and fireworks from NFR 2L to NFR 2G in the next submission.

acknowledged this was missing and it would be included in an updated version of the IIR. The TERT agreed and recommends that Luxembourg includes this explanation in the IIR for the next submission.

2017 LU-2H2-2018-0001

No 2H2 Food and Beverages Industry, NMVOC, 2005, 2010, 2015

For category 2H2 Food and Beverages Industry and pollutant NMVOC the TERT noted that that there may be an under-estimate as no emissions were reported from the category. In response to a question raised during the review, Luxembourg provided a revised estimate for the years 1990-2015 and stated that it is not always clearly described in the 2016 EMEP/EEA Guidebook which activities are covered by the EFs. The TERT agreed with the revised estimate provided by Luxembourg. The TERT noted that the issue is below the threshold of significance for a technical correction. The TERT recommends that Luxembourg includes the revised estimate in its next submission and recommends Luxembourg to try to cover all activities for which EFs exist in the

RE For category 2H2 and pollutant NMVOC, the TERT noted that the revised estimate provided by Luxembourg during the 2017 review (LU-2H2-2017-0001) is different from the reported NMVOC emissions in the 2018 submission. The TERT also notes that the IIR does not contain any information on the methodology used for estimating these emissions. In response to a question raised during the review, Luxembourg explained that an update of the IIR was being prepared and provided the section on 2H2. The TERT recommends that Luxembourg includes this text in the IIR for the next

No No No

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Guidebook. The TERT notes that the EFs provided in the 2016 EMEP/EEA Guidebook are related to the industry of food and beverage production.

submission as planned and also corrects the other parts of the IIR reflecting these emissions.

2017 LU-3B-2018-0001

No 3B Manure Management, NMVOC, 1990-2015

The TERT notes with reference to NMVOC emissions from category 3B Manure Management that NMVOC emissions have been recalculated using a Tier 2 method. However, according to Table 1-13 of the IIR a Tier 1 method was used to calculate NMVOC emissions from NFR 3B sub-categories. The TERT asked if Luxembourg would confirm whether Table 1-13 needs to be updated following the recalculations reported in section 5.2.5. Luxembourg replied that section 5.2.3.1 on p. 318 (last paragraph string with NMVOC) gives the correct description of the methods used, i.e. Tier 2 for cattle and Tier 1 for all other animal categories. In that respect, Table 1-13 is correct, but the recalculation description on p. 327 (section 5.2.5) is wrong. The sentence "For all animal categories, the methodology was changed from Tier 1 to Tier 2" should be deleted and replaced by "For dairy and non-dairy cattle, the methodology was changed from Tier 1 to Tier 2". The TERT recommends that this error will be corrected to the IIR of the next submission.

No For category 3B Manure management and NMVOC the TERT noted that there is a lack of transparency, since the Tier level applied is unclear. In response to a question raised during the review, Luxembourg indicated that there is an error in table 1-13 of its IIR and that Tier 2 method is used (except for cervidae, where T1 is used) and that the IIR will be corrected in its final 2018 version. The TERT recommends that Luxembourg updates its IIR.

No No No

2017 LU-3B4f-2018-0001

No 3B4f Manure Management - Mules and asses, NOX, 2005, 2010,

The TERT notes with reference to emissions of NOX from category 3B4f Manure Management - Mules and Asses that these are reported as 'NO' (Table 5-3). However, emissions of NH3 and NMVOC from this sub-category are reported as 'IE'. Table 5.3 in

No For category 3B4f Manure management - Mules and asses NOX emissions the TERT noted that there is a lack of transparency in the IIR. In response to a question raised during the review,

No No No

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2015 the IIR explains that emissions from mules and asses are included with those from horses, which indicates that emissions of NOX from NFR 3B4f should also be reported as 'IE'. In addition, the footnote to Table 5.3 lists the subcategory for horses as NFR 3B6 which should be corrected to 3B4e Manure Management - Horses. To the question on why different notation keys are used for different emissions from this source Luxembourg replied that a wrong notation key is used and should be corrected to ‘IE’ in category 3B4f for NOX emissions. The TERT recommends to correct the notation key and the footnote to the next submission.

Luxembourg indicated the notation key ‘NO’ will be changed to ‘IE’ in its next submission as originally recommended during the 2017 review. The TERT recommends that Luxembourg ensures consistency regarding information in IIR and NFR in its 2019 submission.

2017 LU-3D-2018-0004

No 3D Crop Production and Agricultural Soils, NMVOC, 2005, 2010, 2015

The TERT noted with reference to NMVOC emissions from 3Da1 (Inorganic N-fertilizers), 3Da2a (Animal manure applied to soils), 3Da2b (Sewage sludge applied to soils), 3Da2c (Other organic fertilisers applied to soils), 3Da4 (Crop residues applied to soils), 3Db (Indirect emissions from managed soils), 3Dc (Farm-level agricultural operations including storage, handling and transport of agricultural products) and 3Dd (Off-farm storage, handling and transport of bulk agricultural products) the use of the notation key 'NO' (not occurring) to be inappropriate as those activities are likely to occur in Luxembourg. The TERT recommends to use the notation key 'NA' as this indicates that emissions from the source are negligible or that there is no method available to

No For 3D Crop production and agricultural soils and NMVOC emissions the TERT noted that Luxembourg reports ‘NO’ for subcategories for which 2016 EMEP/EEA Guidebook does not present a methodology. In response to a question raised during the review, Luxembourg indicated that the notation key will be changed in the 2019 submission. The TERT recommends that Luxembourg reports ‘NA’ for NMVOC emissions of categories for which 2016 EMEP/EEA Guidebook does not present a methodology.

No No No

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calculate them, to what Luxembourg agreed

2017 LU-3D-2018-0002

No 3D Crop Production and Agricultural soils, NH3, 1990-2015

The TERT notes with reference to NH3 emissions reported under category 3D Crop Production and Agricultural Soils that section 5.1.1 of the IIR states that these emissions decreased sharply between 1990 and 2015. To the question on the issue Luxembourg responded that the reason for this decrease is mainly the decreased use of inorganic fertiliser (3Da1) and to a lesser extent the urine and dung deposited by grazing animals (3Da3) and that an explanation will be added in the next submission. The TERT recommends Luxembourg to include the explanation.

No For category 3D Crop production and agricultural soils and NH3 emissions the TERT notes that there is a lack of transparency in the trend explanation. In response to a question raised during the review, Luxembourg indicated that final version of 2018 IIR will include some updates and that the original recommendation of including further explanations will be implemented as part of the 2019 submission. The TERT recommends that Luxembourg additionally provides further explanation on trends in its next IIR.

No No No

2017 LU-3D-2018-0005

No 3D Crop Production and Agricultural Soils, PM2.5, 2005, 2010, 2015

The TERT notes with reference to categories 3Da1 (Inorganic N-fertilizers), 3Da2b (Sewage sludge applied to soils), 3Da2c (Other organic fertilisers applied to soils), 3Da4 (Crop residues applied to soils), 3Db (Indirect emissions from managed soils), 3Dc (Farm-level agricultural operations including storage, handling and transport of agricultural products) and 3Dd (Off-farm storage, handling and transport of bulk agricultural products) that the use of the notation key 'NO' (not occurring) for PM emissions is inappropriate as those activities are likely to occur in Luxembourg. The TERT recommends to use the notation key 'NA' instead to indicate that emissions from the source are negligible or that there is no method available to

No For 3D Crop production and agricultural soils and PM2.5 emissions the TERT noted that Luxembourg reports ‘NO’ for categories for which 2016 EMEP/EEA Guidebook does not present methodology. In response to a question raised during the review, Luxembourg indicated that the notation key will be changed in the 2019 submission. The TERT recommends that Luxembourg reports ‘NA’ for PM emissions of categories for which the 2016 EMEP/EEA Guidebook does not present methodology and checks the allocation of its estimates to be in line with the

No No No

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calculate them. Luxembourg replied that the notation keys will be changed to ‘NA’ for TSP, PM10 and PM2.5. The TERT recommends Luxembourg to correct the notation keys to the next submission.

latest Guidebook version.

2017 LU-3D-2018-0001

Yes 3D Crop Production and Agricultural Soils, NH3, PM2.5, 1990-2015

The TERT noted that NH3 emissions from all sub-categories of NFR 3B Manure Management have been calculated using a Tier 2 method. However, NH3 emissions reported under NFRs 3Da1 Inorganic N-Fertilisers, 3Da2a Animal Manure Applied to Soils and 3Da3 Urine and Dung Deposited by Grazing Animals have been calculated using a Tier 1 method while NH3 emissions from the earlier stages of manure management have been calculated using a Tier 2 approach. The TERT considers that the Tier 2 approach could have been used for all emissions arising from manure management including those reported under NFR 3D. To the question on the issue the Luxembourg responded that the Tier 1 was used for NFRs 3Da2a and 3Da3 as they are not key categories and because the official version of the 2016 EMEP/EEA Guidebook accessible on the EEA website only provides a Tier 1 method. Luxembourg also responded that the Tier 2 method has been considered, but that the specific data needed to apply the method, may not be available. The TERT recommends that Luxembourg adopts the Tier 2 approach according to the 2016 EMEP/EEA Guidebook to the next inventory submission.

No For the categories 3Da2 Animal manure applied to soils and 3Da3 Urine and dung deposited by grazing animals and NH3 emissions the TERT noted that, according to the IIR, a Tier 1 method is applied. In response to a question raised during the review, Luxembourg clarify that Tier 2 is used for these estimates and that the methodological description in the IIR will be updated in the next submission. The TERT additionally recommends that Luxembourg includes activity data and emissions factor information in its next submission.

No No No

2017 LU-3D-2018- No 3D Crop The TERT notes that in section 5.3.1.2 of the IIR it is No For category 3D Crop Production and No No No

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0003 Production and Agricultural Soils, NOX, 1990-2015

stated that 'Unlike ammonia emissions, NOX emissions are increasing since 1990'. However, the next sentence reports a decrease in NOX emissions of 28.1% over the period while a decrease in NOX emissions is presented in Table 5-17. To the question on the issue Luxembourg confirmed that the sentence quoted is a misprint and confirmed that this will be corrected in the next submission of the IIR. The TERT recommends Luxembourg to carry out this correction.

Agricultural Soils and NOX emissions the TERT notes that there is a lack of transparency in the trend explanation. In response to a question raised during the review, Luxembourg indicated that the "final version of the 2018 IIR" will include some updates and that the original recommendation of including further explanations will be implemented as part of the 2019 submission. The TERT recommends that Luxembourg also updates its explanations on trends in its next IIR.

2017 LU-3Da1-2018-0001

Yes 3Da1 Inorganic N-fertilizers (includes also urea application), NH3, 1990-2015

The TERT noted that in the 2016 Stage 3 Review the TERT encouraged Luxembourg to try to obtain the information needed to adopt a Tier 2 approach to calculate NH3 emissions from the key category NFR 3Da1 Inorganic N-Fertilisers, to which Luxembourg replied that this was a planned improvement (described in section 5.3.7 on p. 321 of the IIR) but that for the Tier 2 method information on the specific fertiliser types used is needed for the entire time series and that recent analysis of the available data has shown that these detailed data are not and will not become available, especially for the historic years, making the use of the Tier 2 method impossible. Also, using splicing techniques to create a time series, seems inappropriate, as this would imply an implicit detailed knowledge on historic fertiliser

No For category 3Da1 Inorganic N-fertilizers and NH3 emissions the TERT noted that Tier 1 is used, although this is a key category. In response to a question raised during the review, Luxembourg indicated that due to lack of resources the recommendation to apply Tier 2 will be implemented as part of the 2019 submission and that the "final version of 2018 IIR" will include some updates. The TERT recommends that Luxembourg applies Tier 2 for NH3 estimates of 3Da1 Inorganic N-fertilizers in its next submission and provides information on activity data and emission factors in its IIR.

No Yes No

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management and other detailed historic data. In addition, data on fertiliser use in Luxembourg is uncertain, and using splicing techniques would only increase this uncertainty. The TERT acknowledges the considered answer and understands that the data for the use of a Tier 2 method are not available. However, the TERT recommends Luxembourg to seek information on the amounts of different N fertilisers used in order to adopt Tier 2 methods in future inventories.

2017 LU-3Da2a-2018-0001

No 3Da2a Animal Manure Applied to Soils, NOX, NH3, PM2.5, 2005, 2010, 2015

The TERT notes with reference to emissions of NH3, NOX and PM from livestock manures applied to land (3Da2a Animal Manure Applied to Soils) that these are reported as 'IE' (included elsewhere). The 2016 EMEP/EEA Guidebook gives a methodology for the calculation of NH3 and NOX emissions from this sub-category and guidance that those emissions should be reported under NFR 3Da2a. To the question on where NH3 and NOX emissions from 3Da2a have been reported and how PM2.5 emissions from this source were calculated and where they were reported the Luxembourg replied that NH3 emissions from livestock manure applied to land are included under manure management (3B) in this submission and that in the next submission they will be reallocated to NFR 3Da2a. For NOX emissions from livestock manure applied to land, as the same emission factor is used as in manure management, these emissions are included under manure management For PM2.5

No For 3Da2a Manure applied to soils emissions and PM2.5 emissions the TERT noted a lack of transparency in the IIR. In response to a question raised during the review, Luxembourg clarified Tier 1 from the 2016 EMEP/EEA Guidebook is used. The TERT recommends that Luxembourg includes information on method used in its next submission and reports the current 3Da2a Manure applied to soils emissions under 3Dc Farm-level agricultural operations including storage, handling and transport of agricultural products in line with 2016 EMEP/EEA Guidebook. For 3Da2a Manure applied to soils emissions and NH3 and NOX emissions, Luxembourg indicated that reasons for recalculations are reported in more detail in its next submission.

No No No

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emissions from livestock manures applied to land, a rough estimation based on manure (kg/animal) and quantity applied to land (kg/ha agricultural area) was used. These emissions are also reported under Manure Management (3B) in the respective animal categories. The TERT recommends Luxembourg to report emissions from livestock manures applied to land under NFR 3Da2a and to calculate the emissions according to the 2016 EMEP/EEA Guidebook.

2017 LU-3Da3-2018-0001

No 3Da3 Urine and Dung Deposited by Grazing Animals, NOX, NMVOC, PM2.5, 2005, 2010, 2015

The TERT notes that NOX, NMVOC and PM emissions from NFR 3Da3 Urine and Dung Deposited by Grazing Animals have been reported as 'IE'. To the question on the issue Luxembourg replied that the notation key ‘IE’ reported for NMVOC, NOX and PM from NFR 3Da3 is incorrect, and should be ‘NE’ and attached a file providing NOX emissions for the entire time series for categories 3Da1, 3Da2a, 3Da2b, 3Da2c, 3Da3, 3Da4. The TERT recommends the Member State to follow the 2016 EMEP/EEA Guidebook method to calculate and report also PM2.5 and NMVOC emissions from livestock manures applied to land and to include the revised estimates for NOX provided during the review in the next submission.

RE For 3Da3 Urine and dung deposited by grazing animals, PM2.5 and years 1990-2016 the TERT noted that in response to a question raised during the review Luxembourg provided a clear response to questions from the TERT. The TERT noted that there might be an over-estimate in 3B Manure management emissions since they include emissions from grazing animals. The TERT noted that this issue is below the threshold of significance for a technical correction. The TERT recommends that Luxembourg estimates and reports PM2.5 emissions in line with 2016 EMEP/EEA Guidebook and consider housed livestock only. For 3Da3 Urine and dung deposited by grazing animals, emissions of NMVOC and years 1990-2016 the TERT noted that in response to a question raised

No No No

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during the review Luxembourg indicated emissions are estimated applying Tier 2 but have been wrongly reported as ‘IE’. The TERT recommends that Luxembourg correctly reports the emissions of 3Da3 in line with 2016 EMEP/EEA Guidebook.

2017 LU-3De-2018-0001

No 3De Cultivated Crops, NOX, NH3, 2005, 2010, 2015

The TERT notes with reference to NH3 and NOX emissions from Cultivated Crops (3De) that these are reported as 'IE' (included elsewhere). The TERT notes that if NH3 emissions have been calculated from cultivated crops they should be reported under NFR 3De. To the question where NH3 and NOX emissions from cultivated crops are reported Luxembourg replied that NH3 emissions are included under Manure Management 3B and that in the next submission they will be reported under NFR 3De and NOX emission as ‘NA’. The TERT recommends Luxembourg to carry out these improvements.

No For 3De Cultivated crops and NH3 emissions the TERT noted that there is a lack of transparency since emissions are reported as ‘IE’. In response to a question raised during the review, Luxembourg indicated these emissions are currently reported under 3B Manure management and they will be re-allocated following Table 3.1 in chapter 3D of the 2016 EMEP/EEA Guidebook. The TERT recommends that Luxembourg reports estimates due to 3D Crop production and agricultural soils in line with the 2016 EMEP/EEA Guidebook.

No No No

2017 LU-5A-2018-0001

No 5A Biological Treatment of Waste - Solid Waste Disposal on Land, NMVOC, PM2.5, 2005, 2010, 2015

The TERT noted that NMVOC and PM2.5 emissions from NFR 5A Biological Treatment of Waste - Solid Waste Disposal on Land for the years 2005, 2010 and 2015 are reported as ‘NA’. In response to the question on the issue Luxembourg provided revised estimates for the years 2005, 2010, 2015 and stated that these will be included in the next submission. The revised estimates for all pollutants are below the threshold of significance. The TERT agreed with the revised estimates provided by

RE The TERT noted that Luxembourg did not fully implement the 2017 TERT recommendation LU-5A-2017-0001. Estimates are reported in the NFR but no AD, and no specifics are included in the IIR apart from planned improvements for NMVOC. In response to a question raised during the review, Luxembourg provided the calculation file LU-5A-2018-0001.xlsx. The TERT

No No No

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Luxembourg. The TERT recommends that Luxembourg includes the revised estimates in the next submission.

agrees with the approach of estimating NMVOC as a fraction of landfill gas. However, the TERT did not fully understand the methodology used and how this compares to that provided in the 2016 EMEP/EEA Guidebook (which uses a "Methane content in landfill gas" parameter of 50% - a fraction in volume, see parameter F in IPCC 2006, Vol5, Chap 3). The TERT notes that this issue may relate to an over- or under-estimate (expected to be below the threshold of significance) and recommends that Luxembourg checks the methodology to derive landfill gas volume on the basis of CH4 amount (starting by the conversion of CH4 mass into volume - using the density of CH4 - and then applying the CH4 content) and that Luxembourg provide a methodological description in the next submission.

2017 LU-5B-2018-0001

No 5B Biological Treatment of Waste, NH3, 2005, 2010, 2015

For category 5B1 Biological Treatment of Waste - Composting and pollutants NH3 for years 2005, 2010, 2015 the TERT noted that Luxembourg reports the notation key ‘NA’. In response to a question raised during the review, Luxembourg explained that an incorrect notation key is used. Luxembourg provided revised estimates for the years 2005, 2010 and 2015 and stated that these

RE The TERT noted that Luxembourg did not fully implement the 2017 TERT recommendation LU-5B-2017-0001. NH3

emissions from 5B1 Composting are reported for the entire time series in the NFR but no information is provided in the IIR on the AD, EFs, or specifics of the methodology (apart from planned

No No No

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will be included in the next submission. The TERT agreed with the explanation and the revised estimate provided by Luxembourg. The TERT noted that the issue is below the threshold of significance for a technical correction and recommends that Luxembourg includes the revised estimate in its next submission.

improvements for NH3). Moreover, there is no explanation for the use of ‘IE’ for NH3 in sector 5B2. In response to a question raised during the review, Luxembourg provided a calculation file concerning the estimate of NH3 emissions from 5B1. No information concerning the ‘IE’ for 5B2 was provided. The TERT recommends that Luxembourg include the methodological description for 5B1 and provide a justification of using ‘IE’ for 5B2 in the next submission.

2017 LU-5D-2018-0001

No 5D Wastewater Handling, NH3, NMVOC, 2005, 2010, 2015

For category 5D Wastewater Handling and pollutants NMVOC, NH3 for years 2005, 2010, 2015 the TERT noted that Luxembourg does not calculate emissions. In response to a question raised during the review, Luxembourg explained that a wrong notation key is used. Luxembourg provided the revised estimates for the years 2005, 2010 and 2015 and stated that it will include them in the next submission. The TERT agreed with the revised estimates provided by Luxembourg. The TERT noted that the issue is below the threshold of significance for a technical correction. The TERT recommends that Luxembourg includes the revised estimate in its next submission.

RE The TERT noted that Luxembourg did not fully implement the 2017 TERT recommendation LU-5D-2017-0001. Estimates are reported in the NFR for the entire time series but no activity data is given. Specifics on the methodology used, EF and AD are not included in the IIR, apart from planned improvements for 5D1. In response to a question raised during the review, Luxembourg provided a calculation file and the TERT noted that Luxembourg uses the 2016 EMEP/EEA Guidebook emission factor for latrines for the estimation of NH3 from 'population not connected'. This approach leads to an over-estimation for NH3. Luxembourg

No No No

32






Tier 1 KC

GB 2016 Issue

explained that using the NH3 EF for latrines for people not connected to sewage plants but using septic tanks instead, was approved by the previous TERT (2017) and is asking to the TERT to advise Luxembourg to revert back to the use of a notation key. However, in the 2017 review, although Luxembourg transmitted a RE for NMVOC and NH3, only the estimate for NMVOC was accepted and included in the RE template. As there are no latrines in Luxembourg, the TERT recommends that Luxembourg report ‘NA’ for NH3 emissions from 5D1 and provide the explanation in the next IIR.

2017 LU-5E-2018-0001

No 5E Other waste, SO2, NOX, NH3, NMVOC, PM2.5, 2005, 2010, 2015

For 5E Other Waste (car and building fires), pollutant PM2.5, and years 2005, 2010, 2015 the TERT noted that Luxembourg reports the notation key ‘NA’. In response to a question raised during the review, Luxembourg provided revised estimates to which the TERT agreed The TERT recommends that Luxembourg includes the revised estimates in its next submission and documents the methodology, activity data and emission factors in the IIR.

RE For sector 5E the TERT noted that Luxembourg did not fully implement the 2017 TERT recommendation LU-5E-2017-0001. Estimates are reported in the NFR for the entire Time series, but no activity data is given. Furthermore, specifics on methodology, estimates, emission factors, activity data and planned improvements are not included in the IIR. In response to a question raised during the 2018 review, Luxembourg submitted a file with detailed information the calculation of the emissions for the main pollutants,

No No No

33






Tier 1 KC

GB 2016 Issue

HM and POPs. Luxembourg also replied that the detailed description of the calculation method and activity data used will be provided in the final version of the IIR 2018, and that HMs and POPs emissions will be reported in the next submission. The TERT thanks Luxembourg for providing the detailed information and recommends that Luxembourg includes the detailed information on activity data, emission estimates and methodology for the entire time series in its 2019 submission.

34

Table 3: Additional recommendations made during the NECD Review 2018 for NOX, NMVOC, SOX, NH3, PM2.5 considering revised estimates (RE), technical corrections (TC)

Observation Key CategoryNFR, Pollutant(s), Year(s)

RecommendationRE or TC in 2018

Tier 1 used for a key category

Issue related to use of GB prior to the 2016 version

LU-1A2gviii-2018-0001

Yes 1A2gviii Stationary Combustion in Manufacturing Industries and Construction: Other, SO2, 1990-2015

For category 1A2gviii Stationary Combustion in Manufacturing Industries and Construction, pollutant SO2 and years 1990 to 2015, the TERT noted that emissions have been recalculated, contributing more than 2% of the national total, without an explanation in the IIR. In response to a question raised during the review, Luxembourg explained that it could not spot the reason until now, but it will investigate it and eventually correct it. The TERT recommends that Luxembourg implements adequate QA/QC procedures to avoid such potential errors in the future and that it explores and explains all recalculations in its IIR.

No No No

LU-3Da1-2018-0002

No 3Da1 Inorganic N-fertilizers (includes also urea application), NOX, 2000-2015

The TERT notes with reference to NOX emissions of 3D1a Inorganic N-fertilizers that there is a lack of transparency in the explanations of the recalculations. The TERT recommends that, in its next submission, Luxembourg includes information on activity data, emission factor or methodology changes that affects emissions estimates.

No No No

35

V. Findings and Conclusions from the Technical Expert Review Team (TERT) for the first phase of the in-depth review of national emission inventories of POPs and heavy metals

22. The TERT checked the national inventory data submitted under NECD submitted in 2018 by Luxembourg pursuant to (Directive (EU) 2016/2284).

23. Luxembourg provided to the Commission a resubmission on 15 March 2018. The TERT considered this resubmission as the basis for the comprehensive review.

24. The TERT carried out checks to verify the transparency, accuracy, consistency, comparability and completeness of the HMs and POPs inventory. The focus was on the years 1990, 2005, and 2016.

25. The TERT considers that it received responses from Luxembourg that were sufficient to undertake the first phase of the in-depth review of national emission inventories of POPs and heavy metals appropriately.

26. Transparency and Consistency: The TERT found the submitted inventory to be sufficiently detailed and documented. The TERT identified inconsistencies across data reported in the Annex I emission reporting template and the IIR.

27. Completeness: The TERT identified several cases where no emission estimates were provided though methods are provided in the 2016 EMEP/EEA Guidebook.

28. The TERT noted that Tier 2 methods are used for key categories.

29. Notation keys: The TERT noted that for the reporting of HMs and POPs the use of the notation keys is generally consistent with the Reporting Guidelines.

30. The TERT noted that the submitted HMs and POPs inventory is only partly in line with Directive (EU) 2016/2284 regarding the emissions in sector transport.

31. The TERT noted that for HMs and POPs reported national total for compliance (row 144) does not differ from national total (row 141) and is reported in line with NECD.

32. The TERT noted that Luxembourg reported transport emissions based on fuel sold and has additionally reported transport emission based on fuel used. This is in line with the reporting guidelines. The reporting of emissions based on fuel sold is mandatory.

33. The TERT identified recommendations in order to improve the national HMs and POPs inventory data of Luxembourg (see Table 4).

36

Table 4: Recommendations from the NECD Review 2018 concerning the first phase of the in-depth review of national emission inventories of POPs and heavy metals6



RecommendationTier 1 used for a key category


LU-2C1-2018-0003

Yes 2C1 Iron and Steel Production, PCBs, 1990-2016

For category 2C1 and pollutant PCB, the TERT noted that in the time series of PCB emissions from iron and steel industry (2C1), an outlier emission is found in 1995 which is more than 10 times higher in the years before and the years after. In response to a question raised during the review, Luxembourg explained that this peak was due to the start-up of an electric arc furnace in that year where emissions were not yet fully in control, while in later years this was resolved. The TERT agrees with the explanation and recommends Luxembourg to include this explanation in the IIR for the next submission.

No No

LU-2D3g-2018-0001

Yes 2D3g Chemical Products, PAHs, 1990, 2005, 2016

For category 2D3g Chemical Products and pollutant PAHs the TERT noted that emissions are not estimated (‘NE’) for all years in the time series, despite the availability of emission factors for asphalt blowing in the 2016 EMEP/EEA Guidebook. In response to a question raised during the review, Luxembourg explained that asphalt blowing does not occur in Luxembourg and indicated they will change the notation key to ‘NO’ for the next submission. The TERT notes that category 2D3g includes multiple activities and that ‘NO’ would not be the appropriate notation key. Therefore, the TERT recommends that Luxembourg includes an explanation stating that asphalt blowing is not occurring in the country in the next IIR.

No No

LU-1A3b-2018-0004

No 1A3b Road Transport, SO2, NOX, NH3, NMVOC, PM2.5, PAHs, PCBs, HCB, Cd, Hg, Pb, PCDD/F,

For all sub-sectors of 1A3b (Road Transport), the TERT noted that biomass activity data is reported as 'NA' in Luxembourg's NFR tables. However, from the IIR it is understood that biomass is included in liquid fuels activity data. In response to a question raised during the review, Luxembourg answered that in submission 2019, biomass activity data for 1A3b will be explicitly reported both in the NFR tables and in the IIR. The TERT welcomes this plan and recommends that, for transparency and comparability purposes, biomass is explicitly provided in the next submission 2019.

No No

6 The recommendations in this table are a result of the review of the POPs and HMs inventories. The TERT have, in some instances, highlighted where these recommendations may also affect other pollutants.

37





1990-2016

LU-1A3b-2018-0001

No 1A3b Road Transport, PAHs, 1990, 2005, 2016

For pollutant PAHs, sector 1A3b (Road Transport), the TERT observed a significant difference of Luxembourg's data to the TNO inventory study. Looking into this issue, the TERT found in the IIR, p. 415, that "POPs emissions from transport were estimated on basis of the national car pool rather than on total fuel sales", which is not in accordance with the Reporting Guidelines. In response to questions raised during the review, the following points were clarified and agreed between TERT and Luxembourg: HMs and POPs should be calculated based on fuel sold, as done for the main pollutants and PM. Then, optionally and additionally, emissions could be also calculated based on fuel used. However, Luxembourg reported HMs and POPs emissions only on the basis of the national car pool (fuel used), rather than on total fuel sales. The TERT recommends that Luxembourg calculates and reports HMs and POPs emissions from 1A3b based on fuel sold in the next submission 2019. HMs and POPs emissions from 1A3b calculated based on fuel used should be reported as a memo item and for compliance, if at all. Luxembourg, however, reported fuel used emissions so as to contribute to the NFR row "NATIONAL TOTAL: National total for the entire territory (based on fuel sold)", which is not correct. Hence, the TERT recommends that Luxembourg reports fuel sold (and not fuel used) emissions to contribute to the "NATIONAL TOTAL: National total for the entire territory (based on fuel sold)". Luxembourg is currently evaluating a new Tier 3 method for PAHs emissions. The TERT welcomes this plan and encourages Luxembourg to switch to this Tier 3 method in the next submission 2019, updating the description in the IIR accordingly.

No No

LU-1B2aiv-2018-0001

No 1B2aiv Fugitive Emissions Oil: Refining / storage, Cd, Hg, PCDD/F, 1990, 2005, 2016

For category 1B2aiv Fugitive Emissions Oil: Refining / Storage and pollutants Cd, Hg, Pb and POPs the TERT noted that Luxembourg uses the notation key ‘NA’ although the emission source is not occurring. In response to a question raised during the review, Luxembourg responded that it plans to revise the notation keys to 'NO' in its submission 2019. The TERT recommends that Luxembourg verifies the correct use of notation keys for HM and POP in general and for category 1B2aiv in particular.

No No

LU-2C1-2018-0002

No 2C1 Iron and Steel

For category 2C1 Iron and Steel Production the TERT noted strong variations in PAH emissions from iron and steel production, in particular a sharp decrease (factor 10,000) during the mid-

No No

38





Production, PAHs, 1990-2016

1990s. In response to a question raised during the review, Luxembourg explained that this was due to the replacement of primary iron and steel production facilities with secondary production. The TERT agrees with the explanation, notes that this issue does not relate to an over- or under-estimate and recommends that Luxembourg includes this explanation in the IIR for the next submission.

LU-2C1-2018-0001

No 2C1 Iron and Steel Production, HCB, 2016

For category 2C1 Iron and Steel Production and pollutant HCB the TERT noted that emissions are not occurring while for other pollutants emissions are estimated. In addition, the TERT notes that the 2016 EMEP/EEA Guidebook has emission factors from this source category. In response to a question raised during the review, Luxembourg explained that the emissions from sintering were reported in 2C1 between 1990 and 1997, and that HCB emissions from electric arc furnaces are estimated but reported in 1A2a. Luxembourg agreed to reallocate these emissions to 2C1 for the next submission. The TERT agreed with the explanations and recommends that Luxembourg reallocates HCB emissions from electric arc furnaces to 2C1 for the next submission and documents the methodology used to estimate these emissions clearly in the IIR.

No No

LU-2D3a-2018-0001

No 2D3a Domestic Solvent Use including fungicides, Hg, 1990, 2005, 2016

For category 2D3a Domestic Solvent Use Including Fungicides and pollutant Hg the TERT noted that emissions are not reported by Luxembourg, despite the availability of a Hg emission factor from fluorescent tubes in the 2016 EMEP/EEA Guidebook. In response to a question raised during the review, Luxembourg explained that the background of the EF is unclear, and it is not sure if this is appropriate to be used. The TERT recommends that Luxembourg investigates Hg emissions from this source category and includes an estimate for this source in the next submission (based on either the Guidebook or an alternative approach), along with an explanation of the methodology in the IIR.

No No

LU-5C2-2018-0001

No 5C2 Open Burning of Waste, Cd, PAHs, 1990, 2005, 2016

The TERT noted that for emissions from 5C2 Open Burning of Waste the notation key ‘NA’ is reported for Cd and PAHs (and for other HM and POPs) although EFs are included in the 2016 EMEP/EEA Guidebook. In the IIR (page 333, table 6-1) Luxembourg states that the main pollutants are ‘NO’ without further clarification. In response to a question raised during the review, Luxembourg explained that, as open burning of waste is banned in Luxembourg by law, ‘NO’ seems justified for the main pollutants and indicated that the same notation key will be applied for HMs and POPs in the next submission. The TERT recommends that Luxembourg

No No

39





increases the transparency of the IIR by providing these explanations in the IIR.

40

VI. Cross cutting recommendations on HMs and POPs

34. The TERT identified the following cross-cutting issues for improvement in the inventory and recommends that Luxembourg:

a. Uses the notation key ‘NE’ where emissions are expected to occur but are not estimated and corrects the use of notation keys according to the definitions in the Reporting Guidelines;

b. Improves the transparency of the inventory by improving the IIR;

c. Makes sure to consistently calculate emissions from transport across all pollutants, in particular HMs and POPs, based on fuels sold.

VII. Effect of revised estimates, technical corrections and adjustments recommended to be approved on the national total and national total for compliance

35. The table below shows differences between submitted inventories in Annex 1 table, rows 141 and 144 and revised national totals after accounting revised estimates, technical corrections and adjustments recommended to be approved. The table shows the direct changes in response to the NECD Review 2018. As no revised estimates and technical corrections were calculated for HMs and POPs the table only shows the main pollutants.

Table 5: National totals as reported and national totals including revised estimates (RE), technical corrections (TC) and adjustments for NOX, NMVOC, SOX, NH3, PM2.5

7

Description ReferencePollutant estimates (kt)

2005 2010 2015 2016

NOX

National total (row 141) Annex1, 15/03/2018 54.546 33.460 22.012 19.849

National total for compliance (row 144) 16.079 11.268 8.897 8.773

National total (row 141) including revised estimates and technical corrections accepted by Luxembourg

Calculated using above data

54.546 33.460 22.012 19.849

National total for compliance (row 144) estimate including revised estimates, technical corrections accepted by Luxembourg and adjustments


16.079 11.268 8.897 8.773

7 The tables presented in this report show numbers rounded to three decimal places, although most numbers are available with greater precision. For all calculations, all available decimal places were used. Therefore, the totals shown may slightly differ from calculation results where only three decimals would be taken into account.

41


2005 2010 2015 2016

recommended (by TERT) to be accepted by EC

NMVOC



Difference between original estimates and revised estimates provided by Luxembourg and accepted by the TERT

3B Manure management LU-3B-2018-0003 0.398 0.449 0.462 0.471



15.695 12.239 13.077 13.387

National total for compliance (row 144) estimate including revised estimates, technical corrections accepted by Luxembourg and adjustments recommended (by TERT) to be accepted by EC


13.342 7.544 8.799 9.121

SOX





2.419 1.704 1.336 0.999



2.381 1.676 1.313 0.977

NH3





6.326 6.335 6.367 6.500



5.954 6.149 6.247 6.387

PM2.5





2.456 1.829 1.360 1.522

National total for compliance (row 144) estimate including revised estimates, technical corrections


1.344 1.266 1.050 1.246

42


2005 2010 2015 2016

accepted by Luxembourg and adjustments recommended (by TERT) to be accepted by EC

VIII. Statement from Luxembourg on the conclusions presented by the TERT

36. Luxembourg did not raise any issues with the calculated estimates in Table 5.

IX. Findings and Conclusions from the Technical Expert Review Team (TERT) for the Review of adjustment applications

37. Luxembourg did submit in 2018, 3 adjustment applications undergoing review under this contract (see Statement from Luxembourg on the conclusions presented by the TERT).

38. The TERT concluded that the applications do meet all of the requirements laid out in Decision 2012/12 of the Executive Body of the CLRTAP, and therefore recommends that the European Commission accept these adjustment applications. Details on the Review of Adjustment Applications are given in Annex II.

43

ANNEX I Technical corrections deemed necessary by the TERT and revised estimates provided by Luxembourg

39. The TERT calculated technical corrections for cases

a. where it did not agree with the way that a revised estimate or technical correction from the NECD review 2017 was implemented and where no revised estimate was provided by Member States during the review

b. and in cases where a recommendation related to the use of Guidebook versions prior to the 2016 version was not implemented and concerned a key category and where no revised estimate was provided by Member States during the review.

40. The methods for calculating the technical corrections are set up in the “Guidance on technical corrections” and are based on the basic adjustment methods referred in the revised UNECE Reporting Guidelines and UNFCCC Adjustment guidance8 and use the 2016 EMEP/EEA Guidebook as a reference for methods and emission factors.

Table 6: Summary tables of Technical Corrections and/ or Revised Estimates

1

EMRT ID: LU-3B-2018-0003

EMRT URL:https://emrt-necd.eionet.europa.eu/2018/LU-3B-2018-0003

Member State: Luxembourg

Sector: 3B Manure management

Gases: NMVOC

Completed by (SE): Beatriz Sánchez

Reviewed by (LR): Chris Dore

Reviewed by QC Controller: Chris Dore

The underlying problem: The TERT notes lack of transparency in the IIR related to 3B NMVOC recalculations.

The rationale for the corrected estimate:

Luxembourg provided revised estimates, taken into account the recommendations from CLRTAP review

Summarise the methodology used:

For NMVOC, the default Tier 2 emission factors for dairy and non-dairy cattle were applied(EMEP/EEA Guidebook 2016, 3.B Manure Management, Table 3.11, p.30); whereas for the remaininganimal categories, the Tier 1 default emission factors from the EMEP/EEA Guidebook 2016

8 Technical guidance on methodologies for adjustments under Article 5, paragraph 2, of the Kyoto Protocol

44

(3.b Manure Management, Table 3.4, p.18) have been used.

2

Details of the corrected estimate

Original estimate (kt)Notes

Year NOX SO2 NMVOC NH3 PM2.5

LU-3B-2018-0003-OE 2005 3.2659

LU-3B-2018-0003-OE 2010 3.5379

LU-3B-2018-0003-OE 2015 3.6177

LU-3B-2018-0003-OE 2016 3.6747

Was a Revised Estimate received from the MS? yes

Revised Estimate received from MS (kt)Notes


LU-3B-2018-0003-RE 2005 3.6638

LU-3B-2018-0003-RE 2010 3.9866

LU-3B-2018-0003-RE 2015 4.0795

LU-3B-2018-0003-RE 2016 4.1461

Was the Revised Estimate accepted by the TERT?

yes

Technical Correction calculated by TERT (kt)Notes


LU-3B-2018-0003-TC 2005

LU-3B-2018-0003-TC 2010

LU-3B-2018-0003-TC 2015

LU-3B-2018-0003-TC 2016

Was the Technical Correction accepted by the MS?

45

ANNEX II Review of the 2018 adjustment applications of Luxembourg: TERT report for the EC

Table 7: Summary information on the Submitted Adjustment Applications, Luxembourg, 2018

Source Sector Years Pollutant Application type 1A3b Road transport 2010-2016 NOX Previously accepted3B Manure management3D Crop production and agricultural soils

2010-2016 NMVOC Previously accepted

3B Manure management3D Crop production and agricultural soils

2010-2016 NOX Previously accepted

1 Introduction 41. Article 5.8 of the NECD (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.” 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 Part 1, 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 in 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 without prejudice to the additional arrangements specified in Part 4 of Annex IV of the new NECD.9 It allows inter alia the submission of additional information during the review, necessary for a proper and full assessment of the adjustment application.

42. Member States may apply to adjust their inventory data or emission reduction commitments if they are in non-compliance with their emission ceilings established in NEC Directive 2001/81/EC (in accordance with article 21(2) of new NECD). If a Member State applies for more than one adjustment and not all these adjustments are required to bring that Member State into compliance, that Member States should be informed that in accordance with the intent of the adjustment procedure, recommendation for approval will be limited to adjustments necessary to bring compliance and be invited to withdraw one or more of its adjustments. In making an adjustment application, Member States must demonstrate that extraordinary circumstances have given rise to revisions to their emissions estimates. These extraordinary circumstances fall into three broad categories:

a) Emission source categories are identified that were not accounted for at the time when the emission reduction commitments were set; or

9 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).

46

b) For a particular source, the emission factors used to estimate emissions for the year in which emissions reduction commitments are to be attained are significantly different to those used when the emission reduction commitments were set; or

c) The methodologies used for determining emissions from specific source categories have undergone significant changes between the time when emission reduction commitments were set and the year they are to be attained.

“Technical corrections” and “revised estimates” arise when the review team identifies substantial quality issues with the emissions inventory. The emissions inventory data is revised during the review to address the issue. Consequently, technical corrections and revised estimates change the national emission totals, which can make 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 that are affected by technical corrections or revised estimates should be reviewed, but the finalised outcome of the work on technical corrections and revised estimates must first be established before the review of the associated adjustment application.

The review of an adjustment application can recommend acceptance or rejection. In the case of a rejection, the recommendation may be accompanied by information explaining that the principle of the adjustment is considered appropriate but that the quantification has not been determined correctly, or it has not been possible to adequately assess the quantification in the time available for the review. Consequently, it may be appropriate for Member States to consider resubmitting selected rejected applications at a future date.

43. Any Member State submitting an application for an adjustment to its inventory is required to notify the European Commission by 15 February at the latest. As explained above the supporting information must be included in the Informative Inventory Report (by 15 March of the same year) 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 specified in Part 4.1 of Annex IV.

44. As mandated by the European Union’s National Emissions Ceilings Directive (Directive (EU) 2016/2284) applications for adjustments that are submitted by Member States are subject to an expert review.

45. In 2018 the reviewers undertook a detailed technical review of newly submitted adjustment applications. Information provided regarding adjustments that were accepted in previous years was also reviewed. Reviews are undertaken in cooperation with the EEA and recommendations from the review on the acceptance or rejection of an adjustment are communicated to the European Commission. The European Commission then takes its decision on any adjustment application based on the outcome of the technical assessment completed by the reviewers considering also the effect of technical corrections and revised estimates.

46. The review of submitted adjustments were performed by an expert review team. The team was formed of the experts identified in Table 8.

Table 8: The 2018 Review team of new and previously accepted adjustment applications

Role Sectors Name

47

Adjustment lead reviewer All Chris Dore Ole- Kenneth Nielsen

Expert reviewer Energy: Stationary and fugitives Rianne DrögeKatrina Young

Expert reviewer Energy: Transport and off-road Jean-Marc AndréGiorgos MelliosTim MurrellsGiannis Papadimitriou

Expert reviewer Industrial processes and product use

Ardi Link

Expert reviewer Agriculture Michael AnderlBernard HydeMette MikkelsenBeatriz Sánchez

Basic checks (Step 1 and 2) All Katarina MareckovaRobert Wankmüller

1 Review of Adjustments approved prior to 201847. Luxembourg had 3 adjustments granted prior to 2018, details of which can be found in Table 9. Luxembourg included information on these adjustments in its submission under the National Emissions Ceilings Directive (Directive (EU) 2016/2284) of 15/03/2018 and thus after the legal deadline of 15 February, reporting sectoral level data in Annex VII to the reporting guidelines and in line 143 of Annex I. Along with Annex VII, Luxembourg submitted the “Declaration on consistency” with a short summary of recalculations of these granted adjustments. Additional documentation was provided during the review in response to requests from the reviewers. Table11 lists the documentation provided by Luxembourg.

48. The review of previously accepted adjustment applications focuses on checking that any recalculations performed have been done so using a methodology that follows best practice, and that transparent supporting information has been provided. A check is made that the adjustment is still “necessary” to ensure compliance, but no check is made on the basis of the application - as this would have been checked in detail during the review when the adjustment application was first made.

49. The reviewers noted that for the applied adjustment in the sector 3B and 3D Agriculture for pollutants NOX and NMVOC and years 2010-2016, recalculations have occurred. The reviewers found it necessary to ask Luxembourg to recalculate the quantification of NMVOC emissions from Agriculture 3B and 3D. The reviewers found it necessary to ask Luxembourg for additional information regarding NOX, and were satisfied with the reply. All supporting information has been provided. The review of the recalculations and the supporting information showed that the method has not been changed and recalculations are due to improvements in emission factors and activity data, and thus the reviewers conclude that the adjustment should continue to be granted.

48

Table 9: Conclusions and recommendations from the review team on previously accepted adjustment applications

Year of first application

Country Sector Inventory year

Poll. Basis of Adjustment

Conclusions text Recommendation & Impact on National Total10

2017 Luxembourg 1A3b Road transport

2010-2016 NOX Significantly different EFs

The TERT reviewed the information submitted by Luxembourg on the previously accepted adjustment for sector 1A3b, pollutant NOX, years 2010-2016. The TERT did not find it necessary to ask Luxembourg for clarifications, since sufficient explanation is provided in the document "ApprovedAdj_Luxembourg_2018v2_180315.pdf" and IIR. Following the review of the information made available prior to the review, the TERT concludes that the adjustment continues to meet the requirements stated in the NECD for an adjustment, and therefore recommends that the European Commission continues to accept the most recent submission as a valid adjustment for this source and pollutant.

-15.6 % in 2016Accept

2017 Luxembourg 3B Manure management3D Crop production and agricultural soils

2010-2016 NMVOC New Source The TERT reviewed the information submitted by Luxembourg on the previously accepted adjustment for NMVOC emissions from 3B Manure management and 3D Crop production and agricultural soils. The TERT found it necessary to ask Luxembourg for clarifications, and Luxembourg did recalculate the quantification of the adjustment to the TERTs satisfaction. Following the review of the information made available prior to and during the review, the TERT concludes that the adjustment, taking into account recalculations to the adjustment quantification made within this review, does continue to meet the requirements stated in the NECD for an adjustment, and therefore recommends that the European Commission does continue to accept the most recent submission as a valid adjustment for this source and pollutant. The TERT noted that the revised estimates for the adjustment values are different to those agreed under the CLRTAP review. The TERT therefore recommends that Luxembourg submits adjustment information in its next submission that is consistent between the NECD and CLRTAP.

-29.3 % in 2016Accept

2017 Luxembourg 3B Manure management3D Crop production

2010-2016 NOX New Source The TERT reviewed the information submitted by Luxembourg on the previously accepted adjustment for NOX emissions from 3B Manure management and 3D Crop production and agricultural soils. The TERT found

-5.0 % in 2016Accept

49

Year of first application

Country Sector Inventory year

Poll. Basis of Adjustment

Conclusions text Recommendation & Impact on National Total

and agricultural soils

it necessary to ask Luxembourg for clarifications, and Luxembourg did answer these questions satisfactorily. The TERT did not find it necessary to ask Luxembourg to recalculate the quantification of the adjustment. Following the review of the information made available prior to and during the review, the TERT concludes that the adjustment does continue to meet the requirements stated in the NECD for an adjustment, and therefore recommends that the European Commission does continue to accept the most recent submission as a valid adjustment for these sources and pollutant.

50

2 Conclusions and Recommendations of TERT concerning adjustment applications

50. The reviewers have undertaken an assessment of the application for a previously approved adjustment of the NOX emissions inventory that was submitted by Luxembourg for Transport 1A3b and Agriculture 3B and 3D and also the NMVOC emissions inventory for Agriculture 3B and 3D.

51. The review of the submitted application followed the guidance provided in the Annex to Decision 2012/12 of the Executive Body of the CLRTAP as amended by Technical Guidance ECE/EB.AIR/130. The findings of the reviewers are described in detail in sections above of this report.

52. Table 10 below provides a summary of the adjustment applications received from Luxembourg, and the subsequent recommendations made by the reviewers to the European Commission.

Source Sector Years Pollutant Application type Recommendation1A3b Road transport 2010-2016 NOX Previously accepted

(first submitted in 2017)Accept


2010-2016 NMVOC Previously accepted(first submitted in 2017)

Accept


2010-2016 NOX Previously accepted(first submitted in 2017)

Accept

Table 10: Recommendations following the 2018 review of previously accepted adjustment applications

3 Information Provided by Luxembourg53. Table 11 lists the information provided by Luxembourg in its adjustment application. The information provided by Luxembourg was stored on the EMRT-NECD review platform.

Table 11: Information Provided by Luxembourg

Filename Short description of content

LU_CLRTAP-NEC_2018v2_Notiication_180315.docx

The notification of 3 previously accepted adjustment applications for 2018

ApprovedAdj_Luxembourg_2018v2_180315.pdf

Declaration on consistent reporting of Approved Adjustments

LU_CLRTAP_ 2018_V2_Anenx_VII_Adjustments_summary_180315.xlsx

The detailed calculations for the quantification of the 2018 adjustments.

51

MS_IIR_2016_draft_160315_v4.pdf The Informative Inventory Report provided by Luxembourg

54. The reviewers found it necessary to ask Luxembourg for further information.

Table 12: Additional Information Provided by Luxembourg

Filename Short description of content

EMRT- NECD QA exchange, 26/06/18

The reviewers asked for clarification of recalculations providing changes on methodology, activity data and emission factors to be given for NOX and NMVOC emissions from Agriculture 3B and 3D.

RE_NECD_Review- outstanding question.msg

Email exchange concerning the recalculations of NMVOC emissions from 3B and 3D.

LU_CLRTAP_2018v3_Annex_VII_Adjustments_summary_180706.xlsx

An updated version of the adjustments summary report.

RE_LU_3B_ADJ-2018_0003_V3.xlsx

Revised estimate file which summaries the recalculation to the adjustment of NMVOC emissions from Agriculture.

52

References and Supporting Documents

Annex I emission reporting template. Available at http://www.ceip.at/ms/ceip_home1/ceip_home/reporting_instructions/

EEA 2018. National Emission Ceilings (NEC) Directive reporting status. Available at:https://www.eea.europa.eu/themes/air/national-emission-ceilings/nec-directive-reporting-status-2018

EU 2018, EU Air Emission inventory review Guidelines. Available at http://ec.europa.eu/environment/air/reduction/implementation.htm

EU 2018, Guidance for TERTs. Available upon request.

Decision 2012/3 (ECE/EB.AIR/111/Add.1): Adjustments under the Gothenburg Protocol to emission reduction commitments or to inventories for the purposes of comparing total national emissions with them

Decision 2012/12 (ECE/EB.AIR/113/Add.1): Guidance for adjustments under the 1999 Protocol to Abate Acidification, Eutrophication and Ground-level Ozone to emission reduction commitments or to inventories for the purposes of comparing total national emissions with them

Decision 2014/1 (ECE/EB.Air/127/Add.1) Improving the guidance for adjustments under the 1999 Protocol to Abate Acidification, Eutrophication and Ground-level Ozone to emission reduction commitments or to inventories for the purposes of comparing total national emissions with them

EMEP/EEA, 2016 EMEP/EEA air pollutant emission inventory guidebook – 2016 EEA technical report No. 21/2016 European Environment Agency, Copenhagen. Available at: http://www.eea.europa.eu//publications/emep-eea-guidebook-2016

EMEP/EEA Air Pollutant Emission Inventory Guidebook 2013http://www.eea.europa.eu/publications/emep-eea-guidebook-2013

2014 Reporting Guidelines (ECE/EB.AIR/125 ) for Estimating and Reporting Emission Data under CLRTAP http://www.ceip.at/ms/ceip_home1/ceip_home/reporting_instructions/

ECE/EB.AIR/130: Technical Guidance for Parties Making Adjustment Applications and for the Expert Review of Adjustment Applications, 14 April 2015 http://www.ceip.at/fileadmin/inhalte/emep/Adjustments/ECE_EB_AIR_130_AV_for_the_web.pdf

NEC Directive 2001, DIRECTIVE 2001/81/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL, of 23 October 2001 on national emission ceilings for certain atmospheric pollutantshttps://eur-lex.europa.eu/eli/dir/2016/2284/oj

NEC Directive 2016, DIRECTIVE (EU) 2016/2284 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 14 December 2016 on the reduction of national emissions of certain atmospheric pollutants, amending Directive 2003/35/EC and repealing Directive 2001/81/EC. http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2016.344.01.0001.01.ENG

53

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2016.344.01.0001.01.ENG

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2016.344.01.0001.01.ENG

http://www.ceip.at/fileadmin/inhalte/emep/Adjustments/ECE_EB_AIR_130_AV_for_the_web.pdf

http://www.ceip.at/ms/ceip_home1/ceip_home/reporting_instructions/

http://www.eea.europa.eu/publications/emep-eea-guidebook-2013

http://www.eea.europa.eu//publications/emep-eea-guidebook-2016

http://www.eea.europa.eu//publications/emep-eea-guidebook-2016

http://ec.europa.eu/environment/air/reduction/implementation.htm

https://www.eea.europa.eu/themes/air/national-emission-ceilings/nec-directive-reporting-status-2018