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

There are separate worksheets in this file:
- General comments: addresses comments that are generic and not specific for a certain chapter
- General Guidance comments: comments addressing General Guidance chapters. Comments are sorted by
chapter number.
- Sectoral - textual comments: comments addressing the text in one of the technical chapters. Comments are
sorted by NFR code.
- Sectoral - EF comments: comments addressing emission factors in one of the tables in the technical chapters.
Comment
In copying text from the IPCC GLs, frequently inappropriate reference to GHG inventories remains. This must be
checked and corrected everywhere.

The references in Tables don't have correspondence in reference list. It's often impossible to understand where the
original emission factors are retrieved. The reference: Guidebook (2006) or CEPMEIP (2004) are not acceptable,
they work as "Chinese nested boxes": substitute with original references! Also the reference "Visschedijk, 2004" is
not a reference to the work where the user can found EF and detailed explanation of their derivation. The reference
Espreme what means: the reference must be to a document where the methodology to derive EFs is explained.
The table 3.1 of the model chapter (cement as agreed in Dessau) is not implemented in many chapters (e.g
transport), it provides the necessary overview of where emissions are to be expected or not. Please include a
similar table in all chapters.
In the box "major changes since previous versions" please remove the remark on Tiers and the Thessaloniki
meeting. On the other hand the comment in this box should be chapter specific, for example poit out if methods or
emission factoes have been revised (which rarely is included), please add this information. This comment is
generic to the entire guidebook.
Figure and table numbering is not harmonised throughout the revised Guidebook, this must be ensured before
publishing
Everywhere where appropriate the new name of the Guidebook must be used (the name change will almost
certainly be approved)

Comment relates to unc chapter (not in the drop menue): Please make reference to the requirements in the IIR

The formulas do not appear uniform: in some cases the legend is missing.

The new Guidebook must clearly describe where emissions of HM and POPs are expected emitted (ir not
expected) (this is in line with the scope of the project). The version sent out for review has many gaps in this
respect. Furthermore improvements in information on HM and POPs are expected through support by Germany
and the Netherlands, this information must be included in the next version (prior to the TFEIP meeting)
The figures do not appear uniform. The explanation for the blue arrows is missing from time to time (but e.g.
Chapter 2.A.1. Figure 2-1 is OK) and in some cases heat (or fuel) are not denoted. See below
The draft Guidebook use a mixed terminology for substance vs (air) pollutants, please consult the Guidelines and
harmonise text everywhere
The Guidelines use the term "Key category" (agreed by TFEIP), the GB mus be consistent with this decisions (text
and decision trees) (in the current draft both terminologies are used, even within the same chapter, while key
source is most frequently used)
One objective of the project is to facilitate maintenance. Nevertheless, throughout the Guidelines there is a lot of
repetition of information. Examples are definition of TCCCA and reference to the Guidelines. Please ensure that
such repetiton as far as possible is avoided.
The Guidebook is endorsed by the Convention, consequently the term Party is correct (and not MS), and the GB
must be written this way (the current draft not alwyas is). However a statement can be given to explain the role of
the Guidebook under NEC. The term "country" is neutral
The whole draft needs to undergo a proper QA/QC by the consultantst, in the draft many references are missing,
tables refereces are not correct, terminology (outline/numbering) is inappropriate/inconsistent and copy and paste
mistakes makes part of the text meaningless

Scientific improvements: In the agreement betweeen the Commission and EMEP in starting this project some top
priority scientific improvements were setteled. I have looked into a couple of these: i) for solvent use some of the
T2 emission factors given are 18 years old (the rest are more than 10) (e.f domestic solvent use, some solvent
chapters are updated), ii) fugitive emissions from fuel - parts updated - but not the very important chapter on fuel
(gasoline) distribution iii) waste (landfills and waste incineration) - landfill chapter is empty waste incineration
chapters have not been updated. All these are examples of sectors where technology has been changing and it is
likely that the provided information is outdated. Hopefully the consultans can fill these gaps before the next version
is sent for review.
In some cases different technologies/abatment system are defined introducing EFs for each technology (for
example for Volume 2C) in some case new technologies/new products are introduced under abatment (for
example for Volume 3). It's better to produce alwaays EFs tables (non reductions) with technology/products and
put them in section 3.3.2. I think the approach must be unique!
Comment relates to unc chapter (not in the drop menue). Please cite the last draft Guidelines (same comment to
be sec 7 of this chapter)
General guidance: throughout the chapters 'key categories' is interchangabley used with 'key sources'. A variety of
capitalisation is also used: Key Source, key sources etc. Please standardise across all chapters (it should be key
category in the UNECE context)
The number of signicant digits provided throughout the different chapters vary greatly. E.g. 0.1 (Lead - Residential -
Biomass - Fireplaces) and 0.124467 (Lead - Residential - Solid fuels - Stoves)
A contact address would be extermely helpful (in order to refer any questions to / to report additional evidence).
Probably, the Expert Panel chairs are most appropriate to be mentioned.

Numbering of tables and figures in general guidacne chapters needs standardising. Sometimes Fig 1, Fig 2 etc is
used, other times Fig X.1, Fig X.3 is used where X is the section number - Please standardise across all chapters
In far too many instances, material copied and pasted from IPCC Guidelines still contains inappropriate references
to eg other sections or Volumes of the IPPC docs. Please check and correct across all chapters
Terminology. In several general guidance chapters mention is made of reporting obligations for signatories (or
signatory Parties etc) to the various Convention protocols. The obligations are actually only placed on Parties that
have ratified the protocols (i.e. a number of parties have signed but not ratifed protocols). Please correct
terminlogy across all general guidance chapters
General guidance chapters: references to a Party to the Convention should have a capital P. Member States
should also be capitalised. Please standardise across all chapters
In many places the 2006 draft GB cites the previous GB for emission factors. It was agreed at the AEG meeting in
Dublin that this only would be a last resort (jfr page 3 of the minutes). This must be updated where the original
references are available in the current version of the GB (in most cases it is). Furthermore, the referencing to the
current version of the GB is different in different chapters.
Pollutant subscripts eg NH3, SOx NOx etc. Please standardise across all chapters
When all tables are equipped with a column providing the unit it is incomprehensible why this has not been utilised
to ensure more meaningful emission factors, e.g. 4 mg/GJ instead of 0.004 g/GJ.
General guidance: several times CAFÉ is used with accent on the E, please correct to CAFE. Please standardise
across all chapters
Some general guidance chapters use footnotes to provide reference details, while other references are included in
the reference list. If a reference list is included ina chapter avoid use of footnotes.
Styles - not consistent across general guidance chapters i.e. sometimes Level one headings are ALL CAPS,
sometimes Sentence case, sometimes Title Case. Needs to be standardised.

References- for three authors or more in the text use Surname et al (year). Please standardise across all chapters
Reference list provided in each chapter - should be alphabetical, in ascending date of publication and following
consistent format i.e. authors (year) Title etc. Please standardise across all chapters
The references need checking in all general guidance chapters (& sector chapters). In a number of cases
references appear in the text but not in the reference list and vice versa
Abbrevaiations are not always explained. I recommend an explanation in the general volume or separately in the
volume on each sector.
Need a consistent use of CLRTAP, LRTAP or LRTAP Convention - all three are used interchangably. Please
standardise across all chapters (to LRTAP Convention?)
Proposed
decision   Action taken                       Comments
                                              Try to avoid this as much as possible. Check mainly
Accepted                                      the GG chapters for these errors!


                                              As agreed, we will take EFs from (peer-reviewed)
                                              literature or at least publicly available references as
                                              much as we can. However, in quite a number of
Noted      Done for as far as possible        cases we don't have anything better!

                                              I assume it is meant to fill the "Not Applicable" and
Accepted   Done for most chapters             "Not Estimated" boxes with all relevant pollutants.


           Revised in many cases.
Accepted   Comment about Tiers removed.

Accepted   Done
                                              What is the exact new name? I'm not sure. Remains
Accepted                                      to be done.

Accepted                                      Remains to be done. What is exactly meant?
                                              Legends to be completed with every formula where
Accepted   Done                               appropriate
                                              The EF tables will clearly display if emissions of each
                                              pollutant are expected for this source category
                                              (according to reporting template). All contributions
                                              from Germany & Netherlands will be included in final
Accepted   Done                               draft.
           More explanations added to the
Accepted   figures where necessary

Accepted                                      Try to do this as much as possible


Accepted   Done

                                              We'll try to avoid unneccessary repetition, but must
Accepted                                      keep in mind that the Guidebook is over 1700 pages


Accepted   Done                               Use country as much as possible to avoid this issue


Accepted   Done, at least to a large extent

                                              Solvent use - All chapters except domestic use (for
                                              this one no new information available) have been
                                              significanly updated with input from the industry, I
                                              therefore do not agree with this comment.
                                              Fugitives chapter has been updated in consultation
                                              with CONCAWE.
                                              Waste incineration - no other new emission factors
Noted                                         available.
                                           This approach was presented already in Dessau (May
                                           2007) and approved for as far as I know. No time to
Rejected                                   change it now.

Accepted    Done


Accepted    Done
            Checked, corrected where too   6 digits too much, does not reflect the uncertainty of
Accepted    much digits                    the numbers
                                           Remains to be done, but decision on this is needed
Accepted                                   before.

            Done, X-x used where X is
Accepted    section number

Accepted    Checked



Noted

Accepted    Done


                                           Referencing to old Guidebook harmonised. We'll refer
Accepted    Done                           to original literature as much as possible.
Editorial   Done as much as possible

Noted

Editorial   Done
                                           Footnotes sometimes explain more than just the
Noted                                      reference.

Accepted    Checked

Accepted    Checked

Accepted    Done

Accepted    Done
                                           To be discussed, one glossary might indeed be better
Accepted                                   than separate ones in each chapter
            Harmonized in GG chapters as
Accepted    much as possible
Chapter_I               From ToPa From ToLin
D         Volume        Page ge   Line e

       1 Introduction      1




       1 Introduction      1




       1 Introduction      1


       1 Introduction      2    22    2   25


       1 Introduction      2     8    2   10

       1 Introduction      2     2    2    2


       1 Introduction      2    37    2   38

       1 Introduction      2    35    2   35




       1 Introduction      2    18    2   25



       1 Introduction      2    12    2   13

       1 Introduction      2    37    2   38
       1 Introduction      2    37
       1 Introduction      2    31



       1 Introduction      2    19

       1 Introduction      2    27

       1 Introduction      2    13
       1 Introduction      2     2
1 Introduction   2   5


1 Introduction   2   19
1 Introduction   2    6



1 Introduction   3   18   2   19

1 Introduction   3   8    3   10

1 Introduction   3   38   3   39



1 Introduction   3   26   3   36

1 Introduction   3    2   3   4
1 Introduction   3   12

1 Introduction   3   15

1 Introduction   3   16
1 Introduction   3   27
1 Introduction   3   14


1 Introduction   4   9    5   27


1 Introduction   4   9    6   12

1 Introduction   4        6

1 Introduction   4   27

1 Introduction   4   6        7




1 Introduction   4   5



1 Introduction   5   23   5   27




1 Introduction   5   24   5   27
1 Introduction   5   23   5    27


1 Introduction   5   16   5    22



1 Introduction   5   16


1 Introduction   5   13

1 Introduction   5   22
1 Introduction   5   20
1 Introduction   5   20

1 Introduction   5   32
1 Introduction   5   32

1 Introduction   5   30
1 Introduction   5   24

1 Introduction   5   37



1 Introduction   6   5    6    6

1 Introduction   6   13        16
1 Introduction   6    5




1 Introduction   6   24

1 Introduction   7   18   7    18

1 Introduction   7   4    7     6
1 Introduction   7   4    7    11



1 Introduction   7        19

1 Introduction   7   25
1 Introduction     7   22
1 Introduction     7   11


1 Introduction     8   19   8    21


1 Introduction     8   3    8    9



1   Introduction   8   33   9    10
1   Introduction   8   11
1   Introduction   8   12
1   Introduction   8   36

1 Introduction     8   18

1 Introduction     8   15



1 Introduction     9   2    9    4

1 Introduction     9   39   10   22

1 Introduction     9   17        35

1 Introduction     9   38
1 Introduction     9    16
1 Introduction     9    19



1 Introduction     10   32

1 Introduction     10   32



1   Introduction   10   20
1   Introduction   10   24
1   Introduction   10   20
1   Introduction   10    6
1   Introduction   11   25




1 Introduction     11   35




1 Introduction     11   5




1 Introduction     12   8    12   9


1 Introduction     12   26   12   26
1 Introduction     12   11



1   Introduction   12   12
1   Introduction   12   21
1   Introduction   12   25
1   Introduction   12   26
1   Introduction   12   31
1   Introduction   12   32
1   Introduction   13   28   13   28
1   Introduction   13   27   13   27
1   Introduction   13   19   13   19

1 Introduction     13   4    13   21

1 Introduction     13   28   13   29


1 Introduction     13        29


1 Introduction     13   27
1 Introduction     13   27




1 Introduction     14        16


1 Introduction     14   10
1 Introduction     15   23        33


1 Introduction     16        18

1 Introduction     16        18




1 Introduction     16   27

1 Introduction     17   8    17   9

1 Introduction     18   7    18   8
1 Introduction     18   27   18   28

1 Introduction     18   20
1 Introduction     18   30



1 Introduction     18   38

1 Introduction     19        20

1 Introduction     20   1    20   1



1 Introduction     20   1    20   1

1 Introduction     20        21



1 Introduction     22        33

1 Introduction     22

1 Introduction     22
1 Introduction     26



1 Introduction     33   1    33   1




1 Introduction

1 Introduction

1 Introduction
  Methodological
2 Choice           1    1

  Methodological
2 Choice           1    1
  Methodological
2 Choice           1
  Methodological
2 Choice           2    7
  Methodological
2 Choice           2    8
  Methodological
2 Choice           3   1
  Methodological
2 Choice           3   5    3   6
  Methodological
2 Choice           3   7    3   9
  Methodological
2 Choice           3   7    3   8


  Methodological
2 Choice           3   7    3   9
  Methodological
2 Choice           3   7    3   7

  Methodological
2 Choice           3   7    3   9
  Methodological
2 Choice           3   12


  Methodological
2 Choice           3   28   3   32
  Methodological
2 Choice           3   29
  Methodological
2 Choice           3   29
  Methodological
2 Choice           3   32


  Methodological
2 Choice           4   3
  Methodological
2 Choice           4   3
  Methodological
2 Choice           4   4
  Methodological
2 Choice           4   6
  Methodological
2 Choice           4   8
  Methodological
2 Choice           4   8    4   8
  Methodological
2 Choice           4
  Methodological
2 Choice             4         6
  Methodological
2 Choice             5    5

    Methodological
2   Choice           5    5    5    5
    Methodological
2   Choice           5    7
    Methodological
2   Choice           5    8
    Methodological
2   Choice           5    8
    Methodological
2   Choice           5    16
    Methodological
2   Choice           5    26


  Methodological
2 Choice             5    33   5    34
  Methodological
2 Choice             6    3
  Methodological
2 Choice             6    3    6    3
  Methodological
2 Choice             6    3    11   1

  Methodological
2 Choice             6         10

  Methodological
2 Choice             11   1
  Methodological
2 Choice             11   1

  Methodological
2 Choice             11   20
  Methodological
2 Choice             12   5
  Methodological
2 Choice           12        18
  Methodological
2 Choice           12        12

  Methodological
2 Choice           13   4    14   37

  Methodological
2 Choice           13   4
  Methodological
2 Choice           13   16   13   17
  Methodological
2 Choice           13   16   13   17
  Methodological
2 Choice           13   16   13   17

  Methodological
2 Choice           13   20   13   21
  Methodological
2 Choice           13   22
  Methodological
2 Choice           14   12
  Methodological
2 Choice           14   23
  Methodological
2 Choice           14   38   17   3

  Methodological
2 Choice           15   25   15   26
  Methodological
2 Choice           18   12
  Methodological
2 Choice           19   7    19   8
  Methodological
2 Choice           19   14   19   14
  Methodological
2 Choice           19   38   19   38
  Methodological
2 Choice           20   6


  Methodological
2 Choice           20   7    30
  Methodological
2 Choice           20   7    30
  Methodological
2 Choice           20   7    30



  Methodological
2 Choice           20   7    30
  Methodological
2 Choice           20   12
  Methodological
2 Choice           20   22
  Methodological
2 Choice           20   22

  Methodological
2 Choice           20        36



  Methodological
2 Choice           20        30

  Methodological
2 Choice           20        30
  Methodological
2 Choice           31   1

  Methodological
2 Choice           32   1
  Methodological
2 Choice           32   1


  Methodological
2 Choice           32   1
  Methodological
2 Choice           32   4

  Methodological
2 Choice           32   15   33
  Methodological
2 Choice           32   15


  Methodological
2 Choice           32        36

  Methodological
2 Choice           32        36
  Methodological
2 Choice            32        36

  Methodological
2 Choice            32        36
  Methodological
2 Choice            35   2
  Methodological
2 Choice            35   2
  Methodological
2 Choice            35   5    36   2
  Methodological
2 Choice            35   6

  Methodological
2 Choice            36        42

  Methodological
2 Choice            37
  Methodological
2 Choice            37        37
  Data Collection
3 Issues            1    11
  Data Collection
3 Issues            2    13

  Data Collection
3 Issues            2    2

  Data Collection
3 Issues            3    14   3    29
  Data Collection
3 Issues            4    5
  Data Collection
3 Issues            4    17   4    17
  Data Collection
3 Issues            7


  Data Collection
3 Issues            8    5
  Data Collection
3 Issues            10   14
  Data Collection
3 Issues            14   40   14   41
  Data Collection
3 Issues            14   35

  Data Collection
3 Issues            18   16
  Data Collection
3 Issues            19   1
  Data Collection
3 Issues
  Data Collection
3 Issues

  Time series
4 consistency       1    1
  Time series
4 consistency       2    18
  Time series
4 consistency       2    16
  Time series
4 consistency       2    5

  Time series
4 consistency       2    3
  Time series
4 consistency       2    5
  Time series
4 consistency       3    35
  Time series
4 consistency       3    17
  Time series
4 consistency       3    15
  Time series
4 consistency       4    6
  Time series
4 consistency       5    6

  Time series
4 consistency       6    32
  Time series
4 consistency       7    12
  Time series
4 consistency       7    11
  Time series
4 consistency       7    9
  Time series
4 consistency       7    2
  Time series
4 consistency       7    1
  Time series
4 consistency       8    12
  Time series
4 consistency       9    13
  Time series
4 consistency     9    1
  Time series
4 consistency     10   1
  Time series
4 consistency     10   24
  Time series
4 consistency     10   11
  Time series
4 consistency     11   20
  Time series
4 consistency     11   9
  Time series
4 consistency     11   4
  Time series
4 consistency     12   17
  Time series
4 consistency     12   17
  Time series
4 consistency     12   17
  Time series
4 consistency     13   10
  Time series
4 consistency     13   13
  Time series
4 consistency     13   15

  Time series
4 consistency     14   8
  Time series
4 consistency     14   18
  Time series
4 consistency     14   1
  Time series
4 consistency     16   1


  Time series
4 consistency

  Time series
4 consistency
  Time series
4 consistency
  Time series
4 consistency


5 Uncertainties   1    1


5 Uncertainties   2    2
5 Uncertainties   2    3

5 Uncertainties   11   1


5 Uncertainties   14   10
5 Uncertainties   14   11


5 Uncertainties   17   35

5 Uncertainties   19   2

5 Uncertainties   20   20


5 Uncertainties   21   34   21   35


5 Uncertainties   21   30   21   31


5 Uncertainties   21   22


5 Uncertainties   21   14

5 Uncertainties   21   14


5 Uncertainties   22   31


5 Uncertainties   22   36


5 Uncertainties   23   36
5 Uncertainties   24    1




  Inventory
6 Management      1         27
  Inventory
6 Management      2    2    2    2
  Inventory
6 Management   2   19   2   19
  Inventory
6 Management   2   19

  Inventory
6 Management   3   7
  Inventory
6 Management   3   24   3   24
  Inventory
6 Management   3   27   3   28


  Inventory
6 Management   3   34
  Inventory
6 Management   4   7    4   10

  Inventory
6 Management   4   8    4   8
  Inventory
6 Management   4   11   4   12
  Inventory
6 Management   6   4
  Inventory
6 Management   6   7    6   7
  Inventory
6 Management   6   25
  Inventory
6 Management   6   32   6   32



  Inventory
6 Management   7   25   7   26
  Inventory
6 Management   7    35


  Inventory
6 Management   8    17



  Inventory
6 Management   8    19   8    36
  Inventory
6 Management   8    31
  Inventory
6 Management   9    3
  Inventory
6 Management   10   13   10   13




  Inventory
6 Management   11   6    11   6
  Inventory
6 Management   11
  Inventory
6 Management   11

  Inventory
6 Management   12   9    12   14
  Inventory
6 Management   12
  Inventory
6 Management   13   16

  Inventory
6 Management   15   18
  Inventory
6 Management   16   26
  Inventory
6 Management   16   28
  Inventory
6 Management   18   10
  Inventory
6 Management   19   20   19   21
  Inventory
6 Management   19   20   19   20
  Inventory
6 Management       20   9    20   9
  Inventory
6 Management       21   3

  Inventory
6 Management       21   7
  Inventory
6 Management       21   27   21   27
  Inventory
6 Management       21   27
  Inventory
6 Management       21   31
  Inventory
6 Management       21   38   21   38
  Inventory
6 Management       21   38
  Inventory
6 Management       21
  Inventory
6 Management       22   1
  Inventory
6 Management       22   1

  Inventory
6 Management       22        22
  Inventory
6 Management       22        22
  Inventory
6 Management       23   2
  Inventory
6 Management       23   2
  Inventory
6 Management



  Inventory
6 Management

  Inventory
6 Management



  Spatial
7 disaggregation   1    8
  Spatial
7 disaggregation   1    23
  Spatial
7 disaggregation   1    22
  Spatial
7 disaggregation   1   1

  Spatial
7 disaggregation   1   1
  Spatial
7 disaggregation   1   1




  Spatial
7 disaggregation   1   1
  Spatial
7 disaggregation   2   18   2   18
  Spatial
7 disaggregation   2   33   3   31
  Spatial
7 disaggregation   2   25   2   25
  Spatial
7 disaggregation   2   5    2   2


  Spatial
7 disaggregation   2   33   2   33
  Spatial
7 disaggregation   3   24

  Spatial
7 disaggregation   3   11   3   12


  Spatial
7 disaggregation   3   20
  Spatial
7 disaggregation   3   35   3   35



  Spatial
7 disaggregation   3   30   3   31
  Spatial
7 disaggregation   3   6


  Spatial
7 disaggregation   4   16
  Spatial
7 disaggregation   4    14

  Spatial
7 disaggregation   4    7    4    77
  Spatial
7 disaggregation   5    22




  Spatial
7 disaggregation   5    2    5    2
  Spatial
7 disaggregation   6    15
  Spatial
7 disaggregation   6    19

  Spatial
7 disaggregation   6    30   6    30

  Spatial
7 disaggregation   6    28   6    28
  Spatial
7 disaggregation   8    16
  Spatial
7 disaggregation   10   12   10   12
  Spatial
7 disaggregation   10   3    10   3
  Spatial
7 disaggregation   11   22
  Spatial
7 disaggregation   11   4
  Spatial
7 disaggregation   13   13
  Spatial
7 disaggregation   13   11   13   12
  Spatial
7 disaggregation   14   1    14   4
  Spatial
7 disaggregation   14   12
  Spatial
7 disaggregation   15   17

  Spatial
7 disaggregation   15   17
  Spatial
7 disaggregation   15   13
  Spatial
7 disaggregation   15   17
  Spatial
7 disaggregation   15   17




  Spatial
7 disaggregation   17   1


  Spatial
7 disaggregation   24   16

  Spatial
7 disaggregation   27   1


  Spatial
7 disaggregation   32        36



  Spatial
7 disaggregation   32        36
  Spatial
7 disaggregation   33   1
  Spatial
7 disaggregation   35   11
  Spatial
7 disaggregation   37
  Spatial
7 disaggregation   37   2



8 Projections      1    1
8 Projections   1   1


8 Projections   1    1
8 Projections   2   13

8 Projections   2   15

8 Projections   2   25
8 Projections   2   26



8 Projections   2   7
8 Projections   3   3
8 Projections   3   1

8 Projections   3   18

8 Projections   3   1

8 Projections   3   12

8 Projections   3



8 Projections   3   9    3    17


8 Projections   3   16   10   16




8 Projections   3   15   4    2

8 Projections   4   1

8 Projections   4   2



8 Projections   4    1   4     2
8 Projections   4   10   4    12


8 Projections   4   11
8 Projections     4   23   4   26




8 Projections     4   4    4   15




8   Projections   4    4   4   14
8   Projections   5    2
8   Projections   5   15
8   Projections   5   18



8 Projections     5   9    5   10

8 Projections     5   17   5   22


8 Projections     5   4




8 Projections     5   3    5   10


8 Projections     5   12   5   16
8 Projections     6    1




8 Projections     6
8 Projections     6   7


8 Projections     6   3    6   13
8   Projections   6    1
8   Projections   7   17
8   Projections   7   19
8   Projections   7   22
8   Projections   7    1   7   2
8   Projections   7    4
8   Projections   7   14

8 Projections     7   19
8 Projections     7   23
8 Projections     7   33

8 Projections     7   29
8 Projections     7   17




8 Projections     7   8    8   1




8   Projections   8   29
8   Projections   8   22
8   Projections   8    5
8   Projections   8    4
8   Projections   8    5
8   Projections   8   22
8   Projections   8   21

8 Projections     8   18
8 Projections     9   25   9   25
8 Projections     9   25
8 Projections     10   24

8 Projections     10    4   10   11
8 Projections     10   14
8 Projections     10   20



8 Projections     10   13

8 Projections     10   3


8   Projections   10   14   15
8   Projections   10   17
8   Projections   10   18
8   Projections   10   19

8 Projections     10   20
8 Projections     10   22

8 Projections     10   23

8 Projections     10   24
8 Projections     10   29

8 Projections     10   35

8 Projections     10   39   40
8 Projections     11    1




8 Projections     11   41
8 Projections     11   38



8 Projections     11    1   11   3
8 Projections     11   38
8 Projections     11   1    2


8 Projections     11   35   11   37
8 Projections     12   26
8 Projections     13   17

8 Projections     13   20   13   20


8   Projections   13   20   13   22
8   Projections   13   17
8   Projections   13   18
8   Projections   13   20


8 Projections     13   21
8 Projections     13   20   22

8 Projections     14   16
8 Projections     14   31


8 Projections     14   32

8 Projections     15   8    15   16

8 Projections     15   5




8 Projections     16   7

8 Projections     16   8

8 Projections     16   17
8 Projections     16    6
8 Projections     18   17


8 Projections

8 Projections



8 Projections
                                                               Proposed
Comment                                                        decision    Action taken
Proper references should be given to EC legislation and
Convention etc mentioned in the text                           Noted       Amended
I felt Appendix C fuels should be deleted from this chapter,
as it is technical material being presented in a non-
technical chapter. A table of fuels is repeated in
Methodological choice chapter - just present this Fuels
information once (i.e. in the more technical Methodological
chapter)                                                       Accepted
Appendix A (pollutants) and Appendix B (sectors) should
be deleted. Instead reference should be made to the
Guidelines which is the single source where this
information should be defined. Also helps future-proof the
text and removes potential user confusion - e.g. already
there are inconsistences between the pollutant list with
what is in the latest Guidelines                               Accepted

These sentences should be deleted - not future proof (i.e.
will be out of date in next years version of the GB already)   Accepted    Not sure what this is referring to
Ridiculous statement: there is a relationship between the
resources allocated and the reliability of the emission
inventory                                                      Noted       Text amended
Some 'scene setting' is needed, to explain the importance
of emission inventories                                        Rejected    Self evident
SNAP is developed by TFEIP not ETC, in the past there
was a SNAP/NOSE committe in cooperation between EEA                        The current Guidebook credits the
and Europstat.                                                 Rejected    ETC/AE
NFR was further developed in 2006 and 2007 in revising
the GLs, please correct                                        Accepted    track changed (page 2, lines 34-39)
                                                                           The Task Force relies on, and is
                                                                           grateful for, contribution from a
Please also provide information on the improvements                        number of countries; it would be
made to HM and POPs through the support by Germany                         invidious to acknowledge all
and the Netherlands                                            Rejected    contributions.
Please specify that only Tier 1 and Tier 2 methods have
been updated. Many needs for updating Tier 3 methods                       The previous version referred only to
have been identified, but were outside the scope of this                   Simple and Detailed methods, the
project.                                                       Noted       text has been revised.
SNAP97 was developed by CITEPA or ETC/AE                                   The current Guidebook credits the
respectively ?                                                 Accepted    ETC/AE
EEA's THEN European...                                         Editorial
typo - change to to in.                                        Editorial

Signatories do not have reporting obligations - only parties
that have ratified do (many Parties have signed but not                    Text amended to …countries that
ratified protocols). Needs rewording throughout chapter      Accepted      have ratified Convention Protocols

Guidelines - first time of use properly define and reference Editorial
Change wording of 'updated where necessary' i.e. not all
needed updates have been done by this project                Accepted      Text amended
typo - hereafter CALLED                                      Editorial
Superscript the footnote reference 1                            Editorial
Convention - first time of use please write out formal name
of Convention, define abbreviation (see general comment)
and properly reference                                          Accepted    Text amended
typo - word Guidebook missing                                   Editorial
Appendix A should be dleted. It's already inconsistent with
the latest GL. Use instead text such as 'for those
pollutants for which reporting is required as defined in the
EMEP reporting guidelines                                       Accepted
Correct typos in these bullets - procedures, users to, levels
of                                                              Editorial
Kyoto protocol and IPPC Guidelines should be properly
referneced at their first time of use                           Noted       Text amended.
Please insert compliance checking under the Protocols of                    Compliance checking is already
the Convention and an explicit reference to EMEP                            included. There is reference to
modelling activities (disopersion and integrated                            suitability for monitoring. EMEP is
assessment)                                                     Noted       now referenced directly.
Please delete text "Such a knowledge…" under rest of the
sentence, this does not belong here                             Accepted
Delete 2008 - not future proof                                  Editorial
Emissions data is no longer reported to UNECE
Secretariat (now to CEIP). Reword                               Accepted
NEC - reference this and defien abbreviation which is later
used - NECD etc                                                 Editorial
Delete 'and actors' - its jargon                                Editorial
parties should have capital P throuighout chapter               Editorial
Please use the exact wording of the last version of the
Guidelines (consult the Secretariat). The term "Member
states" must NOT appear, but "Parties"                          Editorial   Replaced All
Please check - Defintions of TCCCA elements here need
to be identical to the defintions used in the latest draft                  Definitions are now based on the
Guidelines                                                      Accepted    IPCC 2006 Guidelines.
Include para on Recalculations - it is very important and                   A Note has been added to the
should be highlited                                             Accepted    Transparency definition
consider to change 'this' to 'relevant' or 'appropriate'
directive                                                       Noted       Text amended
                                                                            Section 3 Concepts are introduced in
Include info what is the purpos of this section                 Accepted    lines 7-9

consider to change 'Concepts' to 'Glossary' or channge the                  Intorduction amended. N.B.Readers
system of paras instead of alphabetic order group                           might rightly expect a glossary to be
sysetmetic ( it takes some time to undersatand whats                        more comprehensive and Definitions
about )                                                     Rejected        is equally confusing in this context.
This paragraph states that the guidebook covers all
pollutants, however there are significant shortcomings with
regard to HCB and PAHs. The PAH's have for stationary                       The comment is not relevant to this
combustion been lumped together.                            Noted           section of the Guidebook.
                                                                            The Task Force relies on, and is
                                                                            grateful for, contribution from a
TNO will as a side project add information on new POPs                      number of countries; it would be
for consideration into future protocols (also resulting from                invidious to acknowledge all
product use). Please update the text accordingly                Rejected    contributions.
Please see general remark to use of the term "substance"
vs "air pollutant"                                                Accepted    Text amended where possible
In accordance with TFEIPs decision, the Guidelines are
using the term "key category", please be consistent with
the Guidelines                                                    Accepted    Replaced All
terminology - do not use key source. The agreed term
under UNECE is key category. Correct here and
throughoput all chapters (also, do not captilisise this term if
used in middle of a sentence)                                     Accepted    Replaced All
delete 'actual nature and' . Reproting formats are the
same for all directives , countries just do not need to
complete columns if not ratified protocols                        Editorial
consider to use 'CLRATP' and 'NECD' inventory instead of                      EMEP prefer LRTAP, NEC Directive
LRTAP and NEC (trough the whole report)                           Noted       used
Parties' should be Party's                                        Editorial
typo - 'in that helps' is missing a word(s)                       Editorial   Added "it"

Please check - use of signatory versus ratified for the EC        Editorial
Party TO the…                                                     Editorial
The EMEP GL should have been properly referneced
before, so don‟t need full refernece and weblink here             Editorial
replace covers with 'designed to'                                 Editorial   changed to 'is designed to cover'
Propose to delet Appendix B in which case reference to
the Appendix here should be removed                               Noted
delete sentence - this is reporting specific and is different
for eg NEC. Instead use text ' A national total is…each                       Added "and category as defined in
pollutnat and categories as defined in the repsective                         the repsective reporting
reporting requirements                                            Editorial   requirements"
consider to add sentence like 'Relevant information shell
be provided in IIR'                                               Accepted
replace gas with pollutant                                        Accepted

delete reference to EPER Guidance - is outdated and
replaced by E-PRTR Guideance. In any case I didnl;t see
any reference/common approaches with to EPER/E-PRTR
Guidance in later chapters so perhaps should be deleted.          Accepted
Please also introduce abatement as it frequently used in
compiling air pollutant inventories                               Accepted    Text amendment made
Text appears partly repetition of a prev paragrap, please
streamline                                                        Accepted    text removed
Text should be under the Scope section                            Noted       Text amended - no longer relevant
Prefrably introductory text should be user manual like and
not a novel. It is not easy to find in the text what the user                 Not practical, would introduce too
you looking after. Consider to highlit the 'key words' and                    great a change to the style of the
other options to structure the text                               Rejected    document.
What kind of key sources are you refering to, avaerage in                     Key Catgories are now a defied
Europe or ? Consider explanation as a foonote?                    Rejected    concept in section 3.
In the Chapter there is a Table 3-3 which provides the
rating definitions and typical error ranges used in the
Guidebook.However, there are commonly used rating
definitions developed by theUS EPA. All of the emission
factors in e.g. AP-42 are given an EPAquality rating. These
have been copied in previous versions ofCorinair where
EPA EF's have been given.Other US institutes, eg API also
use the same quality codes.However, the EPA quality
rating definitions and those in Table 3-3are not the same,
and this could cause confusion if the userof the Guidebook
is not aware of this.It is proposed that a new paragraph is
added after line 22, page 7,just before Table 3-3, as
follows:"It should be noted that the definitions of emission
factor quality ratings given in Table 3-3 are not the same
as the definitionsused by the US EPA. Where emission
factors developed by the US EPA or other American
technical institutes are used, the US ratings A, B and C
can be considered to be equivalent to the ratings A, B and
C in Table 3-3. However, US ratings D and Ecan be
considered to be equivalent to ratings C and D in Table 3-
3.The US EPA has no equivalent to the Corinair rating E      Accepted    Footnote 2 added.
typo - or IS missing                                         Editorial
Please change text to "… report emission data to the
Convention to fulfil their obligations under the Protocols.
These protocols are…                                         Editorial
"Relevance" has not previously been defined (page 4), and
needs some more explanation. The remaining text of the
par appears redundant with previous text                     Accepted    Paragraph deleted.
To support more easy maintenance I propose not
repeating the information from the Guidelines here. The
same applies to following paragraphs (e.g NEC and
UNFCCC), the text should be made more general                Accepted    Text abridged
Parties - capital P                                          Editorial
reword - secreatriate no longer receives data                Editorial
Guidelines need to be properly referneced                    Editorial
The Convention on long-range…and its abbreviation
doesn't need defining in every new subsection.               Editorial
use word pollutnats instead of species (species means
soemthing else)                                              Accepted
Emissions should be reported in the NFR format for year X-
2 by the 15th February each year; that is not a realistic
proposition; between 15 and 30 of March will be more                     No longer relevant - text has been
realistic                                                    Noted       amended
Remove bold formatiing for GHG legislation - this isn‟t
done elsewhere                                               Editorial
                                                                         No longer relevant - text has been
Consider to reference also LPS directive                    Editorial    amended
Don‟t have gapo between UN FCCC - is not commonly
done                                                        Editorial
                                                                          No action taken, wherever possible
                                                                          the mention of time refereced events
There is no mention of the on-going review of the NECD -                  has been avoided for ease of future
the text should be updated to reflect this                   Noted        updating.
NH3 not ammonia for consistency                              Editorial

footnote 2 - has variuos superfluous sub-footnote
numbering included - delete. These documents should
also be fully references in the refernece list of the chaptetr Accepted   Footnote removed.
replace should with may. It isn‟t justified to make such a
conclusion here                                                Accepted
                                                                          No action taken, wherever possible
                                                                          the mention of time relative events
No mention of upcoming review of the EU-MM - text                         has been avoided for ease of future
should be updated to mention this important aspect           Rejected     updating.
legislation, not Law                                         Accepted
typo in title                                                Editorial
the the                                                      Editorial
typo - sources                                               Editorial
                                                                          The Kiev protocol , while adopted in
                                                                          2003, has yet to come intor force. No
                                                                          action taken, wherever possible the
                                                                          mention of time relative events has
Details of the enrty into force of the protocol should be                 been avoided for ease of future
given                                                        Rejected     updating.
The international PRTR started at the conference in Rio de
Janeiro in 1992 where all countries were in the so-called
Agenda 21 advised to establish a Pollutant Release and
Transfer system. OECD took the lead for supporting these
activities in close cooperation with UNITAR and UNEP
chemicals. After a series of regional conferences it was
decided to focus on more technical support using the
experiences from countries having already a more                          Reference to to UNITAR and UNEP
established PRTR.                                            Noted        chemicals introduced.
In 2005 the taskforce was merged with the IOMC PRTR
coordination group and is now called the PRTR
coordination taskforce. Useful products are sofar a
resource centre built by Environment Canada and recently
a PRTR portal (www.PRTR.net) providing links with
international and national PRTR activities and information
sources (also by Environment Canada). In 2008 a the
following documents are expected: An overview of quality
control methods (Australie en USEPA), methods for
estimating emissions from small and medium sized
enterprises (Finland), and emissions from product use
(Nordic Council). Japan is working on a paper called
Sharing and Comparing, making links between emissions
and statistical data like national product or number of
inhabitants                                                  Accepted     Text amended
UNITAR is in 2008 supporting Armenia, ChIle, Ecuador,
Panama and Togo with some plans for further support in                    Information not relevant to
Middle America                                               Noted        theGuidebook.
Not polluting, but pollutant                                   Editorial
                                                                           Added "it goes beyond the
                                                                           requirements of the protocol,
mention that E-PRTR also goes beyond requirements of                       covering more pollutants with stricter
the protocol (more polls, strciter thresholds)                 Accepted    thresholds"
later that year' replace with october 2009                     Accepted
replace 14 with 22                                             Accepted
delete final sentence                                          Accepted
replace signatories with Parties                               Editorial
Membership of the TFEIP and the expert panels…                 Accepted
Please delete "should allow for maintenance and",              Accepted
Delete "expert"                                                Editorial
What is the "verification" panel?                              Noted       Text has been amended
The text deviates slightly from the panel TOR agreed in
Dublin, is any difference justified?                           Accepted    Dublin text inserted
                                                                           Sentence changed due to earlier
delete: and will be subject to… etc                                        comment
Please consider shortening, e.g describing all TFEIP
meetings would require an annual update of the
introduction.                                                  Noted       text removed

reword - maintenance of the technical content of the
Guidebook is the responsibility of the TFEIP expert panels Editorial
Delete 2008 - not future proof                             Editorial

                                                                           Unecessary - this is 'additional
make bold all the CORINAIRXX so the user can see the                       information'. Guidance on using the
development.From the text it is not clear what is the                      Guidebook - and the link between
current system. At the end of this section should be clearly               NFR and SNAP is provided in both
defind how is refered current system and include also info                 the Introduction and the section on
on new extended NFR main sectors.                              Rejected    how to use the Guidebook
text not updated. Delete refernece to ETC/AEM. State
again here that TFEIP is responsible for the technical
content and EEA for hosting                                    Accepted
Use numbering instead of bullets                               Accepted
Consider to Include para explaining the role of the EMEP
Centre on Emission inventories and Projections (CEIP)
http://www.emep-emissions.at/ceip/                             Accepted    Reference to CEIP included
                                                                           Unecessary - this is 'additional
Consider to include headings EMEP , TFEIP (and CEIP) Rejected              information'.

                                                                           The 1984 Protocol on Long-term
                                                                           Financing of the Cooperative
                                                                           Programme for Monitoring and
                                                                           Evaluation of the Long-range
check - EMEP is not formed by a protocol I believe (it                     Transmission of Air Pollutants in
existed before the convention). Replace formed with                        Europe (EMEP); 42 Parties. Entered
'funded via'                                           Noted               into force 28 January 1988.
DELETE - 'develops the EMEP emissions inventory based
on emission data from Parties' - it doesn't.           Accepted
delete UNFCCC and Kyoto and replace with NEC and
LRTAP Convention                                       Accepted            Text made more generic
Group Switzerland with Iceland etc and call EFTA
(European free Trade Area countries)                            Accepted
                                                                            "Member States" already removed in
Capitalise Member States                                        Noted       favour of "Parties"
Add Kosovo to the list                                          Accepted
                                                                            Text amended to make it generic
                                                                            and, as elsewhere in the text,
                                                                            mention of dated information subjet
SOER report needs proper referencing                            Noted       to regular review is avoided.
Appendix 1 A Pollutants, The list of POP does not match
with list of the GL                                             Rejected    Appendicies removed
Include in row Dioxins: "expressed as "International Toxic
Equivalents" I-TEQ"                                             Accepted

Include more clear definition of PM2.5 and PM10 (possibly
EN 12341 standard => "real world" PM2.5 and PM10
measurements always include larger particles).                  Rejected    Appendicies removed
Please add the additional POPs proposed added to the
protocols (consult Hugo at TNO)                                 Rejected    Appendicies removed
consider to incclude column with aggregations used fro
gridding . See http://www.emep-
emissions.at/fileadmin/inhalte/emep/doc/AnnexIII__Aggreg
ation__gridded__data_Jan2008.doc                                Rejected    Appendicies removed
I suggest to include in Appendix B "Sectors by NFR code"
correspon- ding SNAP code                                       Rejected    Appendicies removed
Please use the latest version, consulting Katarina M (UBA-
V) [there are some smaller differences]                         Rejected    Appendicies removed
(b) add... and emissions from Cultivation of Rice               Rejected    Appendicies removed
Table "Fuel": For all pollutants except CO2 it doesn' make
much sense to divide MSW into biomass and fossil
fractions because emission factors will be available only for
total MSW.                                                      Rejected    Appendicies removed
The claim that the guidebook includes default emission
factors for all sources and pollutants where applicable is
simply not correct. The guidebook should contain
guidance, but many pollutants from many sources are
listed as not estimated.                                        Rejected    Appendicies removed
General: please also define natural vs anthropogenic
(included in national totals)                                   Rejected    Appendicies removed
Please append a list of abbreviations (SNAP, LRTAP,
TFEIP...)                                                       Rejected    Appendicies removed

Title of chapter and header is spelt wrong. Methodological! Editorial       Changed title and headers
Chapter contains many cross references to other IPCC
Volumes, IPCCC Guidance sections. All need deleting or
rewording                                                    Accepted       references have been revised
The title of the chapter should be added "and identification                Title is included already in the
of key categories"                                           Rejected       heading box.

typo - uncertainty                                              Editorial

Removals not repoted under LRTAP convention                     Accepted    removals removed.
Change "quick and dirty" to "simple"                              Editorial
Insert text stating the quality criteria of Tier 3 (sent by email
27.11.07)                                                         Accepted    Text added

Give a proper reference for the 'present' Guidebook       Editorial
What is meant by "the present GB"? Please redraft to "the
previous EMEP/Corinair Guidebook…"                        Editorial

Delete these sentences - referencs to the 'present'
(existing now) GB are very confusing for future readers
and will be irrelvant onve the updated version is published     Accepted      Text Deleted
To be more clear "The present Guidebook" should be
replaced with "the 2007 EMEP/CORINAIR Guidebook".               Editorial

If this way of describing methods is kept in the guidebook
the Tier wording has to be changed accordingly                  Accepted      Text Deleted

What does * refer to? Correct                                Accepted         Text Deleted
The analysis is based on single pollutants, so this text
would mean that the inventory compiler would look for
decision trees etc in sector chapters for categories and for
pollutants.                                                  Noted            Text will be clarified
Volume B - incorrect IPPC cross-reference - delete or
correct                                                      Noted            Text will be clarified

Can sinks be deleted in UNECE context
Section B - incorrect IPPC cross-reference - delete or
correct                                                         Noted         Text will be clarified
                                                                              This an improved version of the
                                                                              IPCC QA/QC chapter with more
Inventory Management is not the proper name of the                            detailed guidance on inventory
chapter                                                         Rejected      management.
Volume A incorrect IPPC cross-reference - delete or
correct                                                         Noted         Text will be clarified
Volume B - incorrect IPPC cross-reference - delete or
correct                                                         Noted         Text will be clarified
Figure 1 does not print well and is unreadable - repaste in
at higher quality?                                              Accepted      Figure will be reproduced
GHG inventory compiler reference - incorrect IPPC
wording - delete or correct                                     Accepted      Text changed
Please delete reference to "greenhouse gas inventory"
(comment applies throughout the chapter)                        Accepted      Text changed

Decison tree, please delete reference to sinks                  Accepted      Figure will be reproduced
General: The proposed key-category approach (single
handling of each substance) will lead to the fact that almost
all categories will be identified as key. In practice this
would request whether the use of different (simple and
detailed) approaches for one given source category
depending from the substance or the general treatment of
the entire inventory whit detailed approches. Both ways                    It was agreed in Dublin in October
produce avoidable work.                                                    that a normation approach should
We propose to include a kind of normation of the released                  not be applied and each pollutant
emissons e.g. by using accidification potentials (or other                 evaluated in its own right. Accifiying
"transferring" parameters like for UNFCCC the use of                       potentials would only address a
GWP-values). This would streamline the results analysis                    subset of pollutants and would not
due to the inclusion of more than one substance in one                     resolve the issue for other
approach.                                                     Rejected     pollutants…

Good - captialise                                           Editorial      Text changed
I assume the proper reference here is not the "good
practice guidance", please add the correct reference of the
2006 Guidelines                                             Editorial      Text changed

pollutant - I think key categories is meant                   Editorial

Annex 1 - there is no Annex 1. Appendix A?                    Editorial
Since no "annex 1" is available we guess this refers to
"Appendix A"                                                  Editorial
Approach 2 - add relevant chapter cross reference e.g.
Section 2.X.X                                                 Editorial

typo - particulate                                            Editorial

How to take cross-correlations into account is not (neither
in the IPCC GL2006) described. An inclusion of a text as in
the IPCCC GL 2006 p4.7 note 2 should be considered.           Accepted     Text changed
table 1 - put in an Appendix - too long for the body of the                Do once other changes made so not
text                                                          Accepted     to lose page reference
Large table which does not include very helpful                            Do once other changes made so not
information.                                                  Accepted     to lose page reference
The b footnote should reflect the NFR codes. The c
footnote is irrelevant                                        Accepted
Please compare with latest NFR list and correct as
appropriate. Please check table font (appears mixed, also                  Do once other changes made so not
in the footnote)                                              accepted     to lose page reference

Table footnote C- what does this mean in the GB                            Do once other changes made so not
context??? Assessed jointly is relevant to GHGs only??      accepted       to lose page reference
Footnote to table - b - reference to IPPC needs deleting or                Do once other changes made so not
rewording (NFR?)                                            accepted       to lose page reference
                                                            Consult with
                                                            Expert         don't know what is meant by this
Add Section before 2.4.3                                    Panel          comment..

incorrect GHG inventory reference - delete or correct         accepted     Text ammended
This section must be adopted to air pollutant inventories: i)
reference to sinks must be removed from the text ii) the
equantions should be substantially simplified when sinks
are not considered (see the IPCC GPG 2000) iii) change
reference to GHG inventories to air pollutants                  accepted    Text ammended
Footnote 3, there are no UNECE emission reporting,
please provide the proper reference                             accepted    Text ammended
The chapter talks about Greenhousegas inventories. For
APs we do not expect "removals" so that we can skip
calculation of absolute values.                                 accepted    Text ammended
Is sink/removal anywhere relevant for NFR reporting (It is
not for Danish reporting)? If not, then change the text
accordingly.                                                    accepted    Text ammended
Are removals relevant to UNECE inventory context - if not
delete                                                          accepted    Text ammended

Superscript footnote references 5 and 6                         Editorial   Text ammended

change footnote references to upper case                        Editorial   Text ammended
                                                                            It helps with the optional step 2 to
Since the analysis is to be carried out for each pollutant,                 have the pollutant as a column
the pollutant should be in the heading not as a column.     Rejected        feature.
Footnote 6 - incorrect GHG inventory reference - delete or
correct. Sinks relevant??                                   accepted        text will be ammended

Removals relevant??                                             accepted    text will be ammended

typo - dispersed                                                Editorial   text will be ammended
For APs we do not expect "removals" so that we can skip
calculation of absolute values.                                 accepted    text will be ammended
                                                                            It helps with the optional step 2 to
Since the analysis is to be carried out for each pollutant,                 have the pollutant as a column
the pollutant should be in the heading not as a column.         Rejected    feature.

incorrect IPCC reference? - there is no Table 3.3               accepted    text will be ammended

Skip "or removals have increased".                              accepted    text will be ammended

Skip "or decrease of removals in the future".                   accepted    text will be ammended

Please make a reference to the IIR                              accepted    text will be ammended
Examples on the actual pollutants and NFR categories
should be worked out                                            accepted    Example will be provided
A quarter of this chapter is dedicated to illustrate key
source analysis, too many pages? Why showing
contributions of sources that are not key sources? Is the
chosen example relevant?                                        accepted    Example will be provided
The example relates to GHG when CLRTAP/NECD                                 The examples still illustrate the
reporting does not concerns GHG.                                Rejected    approach adaquately
The key sources are defined per pollutant in the new
Guidebook, when the example illustrates an other
definition (key sources defined for the different GHG as
GWP).                                                        accepted         text will be ammended
It is confusing to display category codes within the example
that are not consistent with the recommended ones (cf.
table 1), as far as they relates to the new IPCC categories,
from IPCC GL 2006 which are not yet applied even for
UNFCCC reporting yet.                                        accepted         text will be ammended

key categories in bold. No they're not?
tables needs to be put in Appendix - is far too long for body
of the chapter                                                accepted        Example will be provided
table 4 - Can we not just have an example relevant for air
pollutants instead of GHGs?                                   accepted        Example will be provided
Please provide an example for an air pollutant inventory
(one substance) rather than this example copied from the
GHG inventory guidance                                        accepted        Example will be provided

Chapter 2.6 Examples of key category analysis should be
deleted, if the reference is given in the spec. chapter in the
IPCCC GL, then it should be refer to that. Otherwise an
examle with the air pollutants should be given!                  accepted     Example will be provided
General: We propose a reference system instead of                Consult with
quotation of all these detailed tables 4, 5, 6, 7, 8 (taken      Expert
from the UNFCCC Guidelines).                                     Panel
References should be in correct order of date ie IPCC
2000 before IPCC 2006                                         Editorial
                                                              Consult with
Is the exercise meaningfull and is the results to be used for Expert
methodology demands?                                          Panel
                                                                              It is now mentioned at the bottom of
Appendix A is not mentioned in the text - it needs to be     Accepted         section 2.2
This is a mathematical exercise weighing all pollutants
identically and weighing categories accordingly. (What is
meant by the text refering to the annex (page 5 line 7) that
it consolidate the pollutant?)                               Noted            Text clarified

its not it's                                                     Editorial
                                                                              issue clarified in text. There are
The example assumes 95% treshold for key categories but                       limited examples for Air Pollutant
the keysource chapter recommends 80%.                   Noted                 Key Cateogrit analysis..

Correct caption numbering                                        Editorial

If the intention is that countries should perform a combined     Consult with
ranking of different pollutants it should be addressed in the    Expert       it was agreed to move it ot an annex
main chapter and not only as an appendix.                        Panel        by the AEG and discussed in Dublin.
The method for combining the key category analysis
decribed in Appendix A is not mentioned nor referenced in                     It is now mentioned at the bottom of
the main chapter.                                                Noted        section 2.2
What is the result of the proposed combining procedure in
Annex 2? Could this be used to minimise the overall
number of key-categories in the sence of comment 1?
E.g. by inclusion of all results for the different substances                That was the idea.. To minimise the
in these combination procedure. It would request a                           number of key categories. It was
treshold value to identify the "overall-key-categories".      Noted          agreed to offer it as an option only..
Page 32 line 11 states that this combined ranking
SHOULD be done, however the described approach is only
mentioned as a possible approach.                             Noted          will clarify
The individual ranking and scoring for the rank placng can
bee seen in the right columns.                                noted

typo                                                           Editorial

already have a Table 4 in the chapter - renumber               Editorial

NOx                                                            Editorial
                                                               Consult with
Why the definition of fuels is given in Appendix B, it is also Expert
given in Chapter 1 Introduction Appendic C Fuels???            Panel        will clarify
                                                               Consult with
What is this table doing here? It is misplaced and already Expert
included in the introduction. Please correct                   Panel        will clarify
The same fuel table is already included in Part
"Introduction".

"Error! Bookmark not defined"                                  Editorial     Updated contents table

key sources should be key categories                           Editorial     Amended

Mention clearly in introduction that section draws heavily
on IPCC - eg as done for chapter time series consistency       Accepted      P 2, lines 2&3 added
                                                                             Test amended to include specific
In adopting this to air pollutants, the focus must include                   mention of EUROSTAT and data
Euroean sources, eg Eurostat and E-PRTRs/PRTRs                 Accepted      reported under the E PRTR

Full stop missing                                              Editorial     Amended

Please define MS (or better rewrite)                           Editorial     MS updated to Microsoft
                                                                             Note added to Table 2.1 and
Please provide reference to EPER measurement guidance Accepted               reference included.
For some of the points the understanding is not very clear.
I suggest to include some typical examples for each point
to increase the usiblity of this list also for "measurement
dummies"                                                    Accepted         Examples added

Remove bullet point                                            Editorial     Amended

Proper references needed for CEN standards                     Rejected      CEN standards are referred to as EN
Proper reference needed for EN ISO/IEC…                        Accepted    Edited where necessary
references should be put in ascending date order. Use
author (date) title format throughout (for books as well as
articles)                                                      Editorial   Amended

delete final colon from the title                              Editorial   Amended
General: guidance on use of PRTR data is missing and
must be added                                                  Accepted    Text added to P7 2.1.1.
General: reference to guidance for collection of spatial
data is missing                                                Accepted    Explanatory paragraph added.
Chapter contains many cross references to other IPCC
Volumes, IPCCC Guidance sections. All need deleting or
rewording                                                      Editorial   Will re-assign

No such sections as 1.4 and 1.5. Check and correct             Editorial   reference corrected

1.3 should be 2. Check.                                        Editorial   reference corrected

typo - component an air pollutant… reword                   Editorial
good practice guidance' is IPCC 2000. Clarify wording -
'good practice guidance of the IPCC2006 guidelines' if that
is what is meant                                            Editorial
Revise "is a central component an" e.g. "is a central
component of an"                                            Editorial

No such section - check and correct                            Editorial

typo - insert …'necessary' to prepare...                       Editorial

No such section as 5.2.3 - check and correct                   Editorial
Capital R for reporting. Provide proper reference at first
time of use                                                    Editorial

typo - to APPLY different                                      Editorial
Footnote 2 - Overall rather than overlap? Check equation
numbering - there is no equation 5.1. Correct different font               corrention made to the font and the
sizes within footnote                                          Rejected    equation number.
Section numbering - use a 3 digit heading before a 4 digit
heading (there is no 2.1.1)                                    Editorial
Figure 5.2 - correct figure numbering (the 5 has no
meaning?)                                                      Editorial
Figure 5.1 - correct figure numbering (the 5 has no
meaning?)                                                      Editorial
Figure 5.2 - correct figure numbering (the 5 has no
meaning?)                                                      Editorial
Figure 5.1 - correct figure numbering (the 5 has no
meaning?)                                                      Editorial

Box numbering - remove 5                                       Editorial

Equation numbering Remove 5 from 5.2                           Editorial
Box numbering - remove 6                                     Editorial
Figure 5.3 - correct figure numbering (the 5 has no
meaning?)                                                    Editorial

Box numbering. section not Section                           Editorial

Use 3 digit heading numbering                                Editorial
Define AFOLU from figure caption (or delete as not
relevant to UNECE inventories)                               Accepted    note added

Box numbering                                                Editorial

Box numbering                                                Editorial
Add horizontal lines to table to improve readibility - 3rd
column not aligned properly                                  Editorial

Add table numbering                                          Editorial

table numbering - no 5                                       Editorial
Volumes - incorrect GHG inventory reference - delete or
correct                                                      Editorial

table numbering - no 5                                       Editorial

table numbering - no 5                                   Editorial
Since the FOD has a chapter on QA/QC the refernce in the
parenteses should presumably be changed from the IPCC
GL to the FOD chapter                                    Editorial

table numbering - no 5
Volumes - incorrect GHG inventory reference - delete or
correct                                                      Editorial

references - arrange in ascending date order                 Editorial
General: This chapter has been copied from IPCC Gls,
and need to be properly review with the objective of
changing terminology and references to this manual.
Furthermore, figure numbering needs to be changed            Editorial
If nowhere and for none of the pollutants sink/removal is
actual the text should be looked through and revised
accordingly                                                  Editorial
Since "base year" might not be precise/unique to the air                 Foot note added to explain Base
pollutants the text should be looked through/revised.        Accepted    Year.
Reference to sections and tables does not match the
sections and table headings.                                 Accepted    Checked
Uncertainties chapter - There are a number of references                 Reference sections (main text as
in the text not provided in the references list. Check and               well as appendix) checked and
correct                                                      Accepted    completed
Uncertainties chapter - incorrect reference draft GL
2003?? Update to 2008 draft GL or the existing final 2003
GL                                                           Accepted    Done
Uncertainties chapter - paragraph not article                   Accepted   Corrected
Uncertainties chapter - Why table 6.(1)? Correct
numbering - 6 is not relevant                                   Rejected
Uncertainties chapter - incorrect reference draft GL
2003?? Update to 2008 draft GL or the existing final 2003
GL                                                              Accepted   Done
Uncertainties chapter - paragraph not article                   Accepted   Corrected
Uncertainties chapter - Footnote 4. A number of references                 Reference sections (main text as
are provided with no details given in the reference list. Add              well as appendix) checked and
to reference list or delete.                                    Accepted   completed
Uncertainties chapter - Fig 3.5. correct numbering - there
are no Figures 1-4                                              Accepted   Corrected
Uncertainties chapter - AFOLU - define or preferable
delete - not relevant to UNECE inventories                      Accepted   Deleted
                                                                           Reference sections (main text as
Uncertainties chapter - Add references to reference list.                  well as appendix) checked and
And those in footnote 6                                         Accepted   completed
                                                                           Reference sections (main text as
                                                                           well as appendix) checked and
Uncertainties chapter - References not in reference list        Accepted   completed
                                                                           Reference sections (main text as
                                                                           well as appendix) checked and
Uncertainties chapter - Reference not in reference list         Accepted   completed
Uncertainties chapter - What are approaches 1 and 2.
these are not defined at all in the chapter? Correct or
delete                                                          Accepted   Corrected
Uncertainties chapter - Not consistent. Section 3.2.3 does
not give details of Approaches 1 and 2                          Accepted   Corrected
                                                                           Reference sections (main text as
                                                                           well as appendix) checked and
Uncertainties chapter - Reference not in reference list         Accepted   completed
                                                                           Reference sections (main text as
                                                                           well as appendix) checked and
Uncertainties chapter - Reference not in reference list         Accepted   completed
                                                                           Reference sections (main text as
                                                                           well as appendix) checked and
Uncertainties chapter - References not in reference list        Accepted   completed
Uncertainties chapter - Delete if Appendix is empty             Accepted   Done

According to me all the chapter is very clear; perhaps for
being more practicable could be appreciated some
operating examples related to the management inventory
report (for ex some sheets related to the main phases
(data request/raw data/compilation/QA_QC)) suggesting a
way to include all info as introduced in paragraph 4.6     Noted

"principles" not principals                                     Accepted   Corrected
At this point or/and in the paragraph 2.2 could be better
distinguished the difference between "inventory manager"
and "inventory compiler". As for the first one in page 2 line
19, it'd be specified that also the inventory compiler could
be an individual or staff, one institution or more institutions.
If the inventory manager is external to the inventory
compiler staff, the last one need generally a chief inventory
compiler staff. Probably in the case of small group they can
overlap. Anyway I suggest to point out, also ahead, that the
inventory manager (or chief inventory compiler staff if
different) is responsible for the technical staff management
(how to share resp, if for sectoral or trasversal topics, how
to attribute internal deadline, how to introduce and
guarantee that internal reports in the differents steps must
be filled etc.), as financial budget management to
guarantee hw_sw, data acquisition availability, inventory
related external consultants etc.                                Accepted   Text added
Footnote 1 - Party not party. Check EC signatory or ratified
protocols                                                        Accepted   Text modified

                                                                            Reference however should be to the
Add referencing for IPCC documents                               Accepted   UNFCCC reporting Guidelines here.

"expamnds" -> "expands"                                     Accepted
Please harmonise with latest version of the draft
Guidelines (see also comment to the introduction)           Accepted        Done
These TCCCA criteria have different definitions to those in
the GB Introduction! They should be consistent with the
formal definitions in the latest version of the draft                       Copied definitions from the draft
Guidelines                                                  Accepted        guidelines
                                                                            Added a reference to the still draft
Please reference the 2008 Guidelines                             Accepted   2007 Guidelines
"Inventory compilers, virtual or real institutions," I suggest
to substitute with "Inventory compilers, one o more
institutions,"                                                   Accepted   Done

One from the data providers would be facility operator           Accepted   Done

EMEP Reporting guidelines - add proper reference                 Accepted   Done

"detailed energy statistics" I suggest to remove detailed        Accepted   Done

Delete quite string and replace with fixed                       Accepted   Done

"incventory" ->"inventory"                                       Accepted   Done

                                                                            We believe that in a text box like this
                                                                            one the suggestion to harmonize
                                                                            with the UNFCCC is useful; the
delete 2nd part of sentence following Authority                  Rejected   laguage is a bit weekened though.
5 should be 6. Reorder bullets once corrected                  Accepted     Done

Styles - not consistent across chapter i.e. sometimes Level
one headings are ALL CAPS, sometimes Sentence case,
sometimes Title Case. Needs to be standardised.             Accepted        Done

A bit confusing the reference to year N and N+1 (line 22)
and to year N and N+1 (line 36). It coul be briefly extended
the first sentence "compiling an inventory is an annual
process" (line 19) by mentionning that activities can        Accepted       text updated
Delete should and replace with may. (It's not a requirement
for parties)                                                 Accepted       It is good practice to …

Delete bit, replace with rather                                Accepted     Done

"sectoral inventory" I'd suggest to remove sectoral            Accepted     Done

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

Table 1, please make explicit reference to the IIR             Accepted     Done

Figure 4: please change references to CRF                      Accepted     Done

                                                                            The GHG guidance here can provide
Please update the text for air pollutant inventories           Rejected     support for air pollution inventories
Table 1, there are no good practice guidance for air
pollutant inventories, please change the terminolog            Accepted     Done

No such box. Correct or delete                                   Accepted   text removed
Delete protocol provisions as this is confusing (not all
protocols reflect this). Instead refer to the applicable text in
the Guidelines                                                   Accepted   Done

typo                                                           Accepted     Done

typo >                                                         Accepted     Done

replace will with may                                          Accepted     Done
I'd suggest to move in the previous part ("institutional" or
"contact person")                                              Accepted     Done
"institutional" I suggest to change with or to add also
"contact/reference person"                                     Accepted     Done
"technical" I'd suggest to change with software or archive
aspects                                                          Rejected    Present text is clear

partial text - delete                                            Accepted    Done
                                                                             GAINS is to be fed by national
GAINS should be mentioned as a key source of verification                    reported data, rather than the other
here (both activity data and emissions)                   Rejected           way around.

Venthoven et al, 2004 is not included in "references"            Rejected    It is included i nthe references

van Velthoven et al for 3 or moe authors                         Accepted    Done

NACP missing from reference list - include                       Accepted    Couldn't find it, reference removed

In -> An                                                         Accepted    Done

table - data provider: An institution…                           Accepted    Done
Please discuss the role of EMEP modellering data for
verification purposes                                            Rejected    Do not understand this

Emissions reporting guidelines should be in reference list       Accepted    Done
Quality Assurance - Section 6.5 - no such section - delete
or correct                                                       Accepted    Done
 I suggest to enlarge the "Inventory system" definition, all
the institution involved in the emission inventory                           Ijn our view this is exactly what is
planning/compilation/dissemination etc..                         Rejected    meant

In Validation …. "is" -> "Is"                          Accepted              Done
Peter van… references should be ordered by surname not
first name. Date missing from reference details        Accepted              Done

IPCC refereences need completeing                                Accepted    Done
Please discuss the role of PRTR data in QA/QC (e.g
verification)                                                    Rejected    Is in data collection issues
General: many Parties have integrated UNFCCC and
LRTAP/NEC inventories, but not all. The authors of the
current chapter seems to assume the former. This issue
(institutional set-up) should be better explained, perhaps
even in the introduction (see e.g figure 5)                      Accepted    See text box
General: Please define inventory compiler, under the
Convention the responsibility lays with the "designated
emission experts"                                                Rejected    Do not understand this
Instead of referring to gothenburg, refer instead to the
Reporting Guidelines as the driver for reporting.
(technically various EB decisions also implement spatial
reporting and not just the protocol - its easier just to refer
to the GL)                                                       Editorial

is ALSO required                                             Editorial
Reporting guidelines- use the reference list for referencing
- not footnotes                                              Accepted        Reference moved to Reference list
styles - different chapter sections are in different fonts.
Standardise throughout
Chapter name might be changed to reflect reporting of
gridded data also? - 'Spatially disgagregated emissions                   Current heading is sufficient to
mapping'?                                                   Rejected      include gridding.
Chapter could mention in introduction the basic work of the
chpater was developed by EEA's ETC/ACC.                     Accepted
Some areas of additional guidance are missing from the
chapter (which the Guidebook consultants agreed to
complete after taking over responsibility from ETC/ACC for
completion of the chapter.) Specifically, augmented
information on data sources and methods for mapping
forest fires, biogenic VOC emissions, shipping and aviation
should be provided and included in the final draft of this                This guidance will be included in the
chapter.                                                    Accepted      final version.

Remove after key spatial data sources "."                     Editorial

add para on SNAP                                              Editorial
I suggest to substitute here and after "50x50 km grid" wirh
"50x 50 km2"                                                  Editorial
I suggest to add after "their dispersion partners" "and
impact area"                                                  Editorial
Among "General Terms" I suggest to keep terms more
related to spatial mapping, (such as NUTS, surroggate
etc., I'd include "GIS" definition) and remove those as
"HDV" and "LDV" for example.                                  Rejected    Terms left in. GIS added

typo - gross                                                  Editorial
Delete mention of associated proposed directives - its not
at all clear which proposed directives are being talked
about here                                                    Accepted    text deleted

HDV: Heavy Duty Vehicles are vehicles with a gross
vehicle weight of < 3,500 kg ==>>>> Heavy Duty Vehicles
are vehicles with a gross vehicle weight of > 3,500 kg        Editorial

.. by an x and y coordinate"s."                             Editorial
I'd try to mention an example for each surrogate resolution
level/type and keeping possibly the same order "as land
use coverage pecentage by grid, vehicle flow by road link,
employers number by industrial point, population by
administrative boundary                                     Accepted      text changed

Say also when the protocol entered into force                 Editorial

References for the various legislative acts should put in the
references, not in footnotes. Delete footnote 4 given earlier
comment about the whole table should be deleted               Accepted    text to be changed
this LPS definition is very messy - mixing up E-PRTR and
Guidelines aspects. Rather directly refer to the Guidelines
as the source where the definitions of LPS for reporting
under the convetion and its protocols can be found.
Mention also that defintions of LPS (sectors, thresholds
etc) can differ between different reporting mechanisms.
Don't provide details of the reporting thresholds and
pollutants here - instead refer just to the Guidelines where
these are defined. This will help avoid inconsistencies.
Mention of the E-PRTR reporting thresholds and faility
defintions should be deleted as they confuses the issue too
much here.                                                   Accepted    text to be changed
Definition of LPS: anything is written about th e stack
height, which is also an important parameter for spatiol
resolution and the EMEP gridding.                            Accepted    Note added

Appendix G not Annex 6                                       Editorial

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

typo identify to?                                            Editorial

typo delete misses                                           Editorial
I suggest to invite compilers to the use when possibile of
the spatial surrogate used for spatial mapping in previous
years to guarantee consistency                               Accepted    text added
As the "example 1" is a bit far from the referring text, I
suggest to include the corresponding page (e.g. Example
1, "pag 9")                                                  Accepted    text added

delete and EU- ETS?
Perhaps the emission total to be distributed is "emission t"
instead of "emission ix"                                     Accepted    text changed
I suggest to include in formula note ..to an "(i)" specific
geographic feature                                           Accepted    text changed

Not 4.2 - should be 4.3 Check.                               Editorial
styles - delete full stop from heading and all headings from
here on                                                      Editorial
Check - does the latest CORINE provide 45 or more?
andcovers                                                    Editorial
Just provide one generic link to EEA dataservice - specific
links become outdated
EUROSTAT has several useful agricultural datasets, e.g.
From the Farm Structural Survey                                Accepted       text added

not Annex II, it's Appendix G                                  Editorial
The COPERT refernece can be updated to latest v4
manual available on the COPERT website                         Accepted       text added

Reference to Guidelines should be updated to latest draft,
not the Thessaliniki one (or final version when agreed)    Accepted

Appendix G not Annex 6                                         Editorial

Complete reference list for TEMIS                              Editorial

Apmosphere reference - Briggs not Brigg                        Editorial
There is no mention/consideration given in the chpater to
the gridded NFR GNFR which parties are required to
report spatial data in. This is a major omission from the
chapter and needs to be corrected. At least some short
explanation needs to be given on how NFR emissions may
be aggregated to the GNFR and reference made to the
draft Guidelines where this is defined. Ideally proxy          Consult with Need to ensure we respect the
variables for each of the GNFR sectors should also be          Expert       boundary between reporting and
provided                                                       Panel        methodological guidance.

It should be noted in the text that updated information on %
gas connections etc may be available from Eurostat/IEA
etc. This should be checked before being stated                Accepted       text added
See previous comment - surrogates should also be given         Consult with   Need to ensure we respect the
for GNFR sectors, as this is the minium that some Parties      Expert         boundary between reporting and
will be able to do                                             Panel          methodological guidance.

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

Figure numbering inconsistent                                  Editorial

Figure numbering inconsistent                                  Editorial
EMEP is extening area to the east , consider to provide
info and add map with extended EMEP area                       Accepted       will add

Figure numbering inconsistent                                  Editorial
I miss any reference to the various guidance material
developed for EU MS compilation and reporting of GHG
projections under the working group of the EC climate                         Included footnote and reference in
change committee. This at least should be referred to.         Accepted       the reference section.
Throughout chapter, references need checking (text to
reference list and vice versa)
Throughout chapter mixture of key sources, key categories
and different capitalistaion is used - Key categories, Key
Categories etc. please standardise                             Editorial   Changed all to Key Categories
change "though" to "through"                                   Editorial
"Projections are usually much less certain than the historic
inventory and require... "                                     Editorial
"Guidance on tackling common problems associated with
gathering appropriate data on…"                                Editorial
delete "data"                                                  Editorial
Definition of "without measures": what technology has
achieved to date, is confusing. Especially comparing with
terminology on p.3, l.16: without measures scenarios                       modified text to remove reference to
usually start from a convinient historic year.                 Accepted    technology
delete "to"                                                    Editorial   Doesn't really make a difference
change "and" to "or"                                           Editorial
Footnote, line1- change "and" to "or". Line3, delete
"resulting"                                                    Editorial
Footnote 1: Line 1 Delete 2nd 'and'. Line 3 Delete
'resulting' Delete 'resulting'                                 Editorial
Delete 'present' and replace by 'represent' or 'derive from'
or 'reflect'                                                   Editorial
Footnote: Policies and Measures and can be laws - delete
"and"                                                          Editorial

WoM scenario. No actual guidance on how this scenario
should be developed i.e. are emissions to be projected
from a base-year based on GDP for example?                     Accepted     Text added to paragraph.
Generic text on determining cost-effectiveness is not very     Consult with
helpful. Some guidance on how an costs can be                  Expert       Some references will be included
determined would be useful.                                    Panel        where they are available.
We do not understand this definition. The starting year is
only 1995 or 2000? Or may be the latest year of historic                   The description has been extended
inventory? We think that this should be topic of discussion                to include some proposed
in Tallinn on projection expert panel.                                     methodology for calculation (see
                                                               Noted       somment in line 16 above.
                                                                           Texted changed due to another
Change "with" to "where"                                       Editorial   comment
                                                                           Texted changed due to another
Change "post the historic year" to "are"                       Editorial   comment
Text Unclear, I suggest '…scenarios can include the
estimation of "what would have happened" if the measures
already implemented since the historic year had not been
implemented.'                                                  Editorial
duplication of (b) on line 10 and subsequent lettering         Editorial
(c) and (d) are a bit vague- it is not clear how they could
differ from the others. It might be helpfut to give examples
of each?                                                       Accepted    Text updated
It would be also good practice to clearly define the
measures that the WM, WoM and WaM scenarios refer.             Noted          Text left unchanged.

The definitions used for With measures and with additional
measures should be fully in line with what is required for
future reporting under NEC and EU-MM (or in the draft
EMEP Reporting Guidelines or draft decisions if this is
specified there). At present the defintions presented here
differ, and thus need to be harmonsied with those specified
in the formal reporting requirements.                       Noted             Text to be updated.

In the definition for "With Measures" an agreed date,
beyond which policies and measures are not considered,
should be mentioned. For example, legislation, policies
and measures in place by 31st of December of the
previous year will only be considered under the "With
Measures" scenario. Policies implemented in the current        Consult with
year, when the projection is being prepared should be          Expert
included in the "With Additional Measures" scenario.           Panel
"targets, which has now been superceded."                      Editorial
change "estimates" to "estimated"                              Editorial
"… based on a range of datasets, including…"                   Editorial
It depends how much detail you want to go into here but,
the marginal cost curve in terms of a plot of total quantity
of pollution avoided against the marginal cost of reduction
in euros/tonne, is often used.                                 Accepted       Text added to paragraph.
Future assumptions could also be based on behavioural
changes or structural changes in society.                      Accepted       Text added to paragraph.
Emission projection scenario should be compiled - either
scenarios should be plural or the sentence should start "An
emission…"                                                     Editorial
There can also be regional considerations that
necessitates that a measure is carried out despite the fact
that it does not the biggest emission reduction for the
lowest cost. For example health considerations in urban
areas.                                                         Accepted       Text added to paragraph.
Generic text on the use of "energy models" to determine
basic growth factors. Guidance on which models are
recommended would be useful.                                   Accepted       Text added under 3.8
Figure - can't read the text on some sections of this          Accepted       Made more clear
Flow Chart: Decision Diamond 2- The last sentence is 'or
are current emission factors adequate' to which I answered
yes and am then told in Tier 2 to use a future emission                       Make text in the Tier 2 box read
factor. I think you have to be clearer on what question you                   …..(or adaquate current emission
answer yes or no to                                            Accepted       factors)
You could give an example eg road traffic model                Accepted       text added
Not clear what is the difference between Tier 3 and Tier 2.
Tier 2 mentions taking "reasonable account" of future
activity changes. Not very specific.                           Accepted       text clarified
No caption. Figure poor quality and unreadable when
printed. Paste in higher quality version?                         Accepted    Updated
"An emission factor…"                                             Editorial
Add a comma after "Key Source"                                    Editorial
effect                                                            Editorial
formula is singular; plural is formulae or fomulas                Accepted    Text changed
…..and involves                                                   Editorial
Revise sentence beginning at (                                    Accepted    text changed
Be consistent in the use of 'emission factor' and 'emission
rate'. Insert comma after Source                                  Editorial
sector's                                                          Editorial
=Ads should have upper case D                                     Editorial
The emission factor for a source using a specific
technology or control in year n                                   Accepted    Text Changed
An emission factor                                                Editorial
Page 7, formula 2 (row 26): in the denominator is ADn,
where in row 33 is ADn = ADs*GFn. But on page 8, row 1,
the formula for ADn is sum of ADt for t=1 to p. If we set the
formula from page 8 to formula 2, then the formula 2 will
be sum of the emission factors for t=1 to p. We think, that                   Text definition of Adt changed to
in formula on page 8 (row 1) should be correct ADt=sum of                     clarify that ADt is a sub source of
ADt for t=1 to p (not ADn).                                       Rejected    ADn

I think that it is worth stating in general terms that in some
complex detailed sectors there can be an interraction
between the emission factors assumed for pollutant control
technologies and the projected activity data. For example
in electricity generation the underlying activity data maybe
future electricity demand. The energy consumption of the
power sector must be consistent with the electricity
demand and the efficiency of the future mix of power
stations. The control measures applied (eg FGD, SCR,
carbon capture and storage) will affect the efficiency of the
power stations and hence fuel consumption. Thus the
assumed mix of emission factors affects the fuel
consumption data. In such cases the assumed mix of
abatement technologies is an input to the model which
predicts energy consumption.                                      Accepted    Text added
"… so that a measure…"                                            Editorial
"… methods, the…"                                                 Editorial
Available - uppercase A                                           Editorial
comma after methods                                               Editorial
its measures                                                      Editorial
need to be broken down                                            Accepted    Text added
Either include a definition of Stratification here, or refer to
it's definition somewhere else                                    Accepted    Definition added
FGD is Flue Gas Desulphurisation?                                 Editorial
FGD: abbreviation is not explained                                Editorial
Possible addition to list. Compare projected trends in data
(emissions or activity) with historic trends- if there are
significant differences then need to explain why. This is
based on a general observation that national
emissions/activity data tend to change gradually (though
not always eg N2O emissions in chemical industry)              Accepted    Text added thank you.
We need some text to explain what this figure means- also
it looks as if the arrows are displaced                        Accepted    Text added to clarify.
portray a picture consistent with                              Editorial   Changed with another comment
…in from … Rephrase                                            Editorial

There is nothing in this section referring to best practice
used in historic compilation. Either include a reference to
another section of the Guidebook, or add the following text:   Accepted    Text and reference added.
Example of simplification - arrows need to be re-aligned in
diagram                                                        Editorial
"It is important to ensure that the resulting emission
projections are consistent with the underlying input data.
The following checks…"                                         Editorial
"The energy related emissions should be checked…"              Editorial
change "matched" to "match"                                    Editorial
"… estimates. The overall…"                                    Editorial
"… inventory should be consistent with the energy balance
from…"                                                         Editorial
"The transition…"                                              Accepted    Text modified.
                                                                           bullet replaced with more appropriate
"… projection must be realistic. Check for …"                Rejected      text.
"… noted. If there is a large step change, then methods will
need to be modified."                                        Noted         Text modified.
"… are correct, and that revisions are transparent."         Editorial

"… results and what were the sources of the difference."       Editorial
More sensible to use domestic as the example for both
e.g.'s                                                         Rejected    text left the same
sectors                                                        Editorial
Example: The emission limit value defined by the large
combustion plant directive (Directive 2001/80/EC) for new
coal plant is 200 mg/Nm3 NOx as NO2 (@6%O2).
Applying an appropriate volume factor for coal of 364
m3/GJ (NCV) gives a projected emission factor of 72.8
g/GJ coal consumed. (Reference for the volume factor is
Graham, DP, Salway G, Ray, P. Stack Gas Flow Rate
Calculation for Emissions Reporting - Aguide to Current
Best Practice for the Operators of Coal Fired
Boilers.,PT/07/LC422/R May 2007                                Accepted    Example Added
based on measured                                              Editorial

Needs re-wording eg. ..no surrogates available for source
sectors, it is good practice to assume the projected value
is the same as the latest historic yeear.                      Editorial
"… based on measured…"                                         Editorial
"to assume that projections are the same as those for…"          Editorial   Changed from another comment
Including the impact of non-technical measures is
mentioned. No guidance on how this quite complex task
could be carried out.                                            Accepted    Some text added.
Need a heading "Emission factors"                                Accepted    Some text added.
projected                                                        Editorial
Emission projections are always modelled "and" are based                     Changed by another comment to "or"
on….                                                             Editorial   based
The paragraph is listed under the headline "Uncertainties",
however it seems to be referring to sensitivity, which is
described from line 26.                                          Accepted    Paragraph moved
typo                                                             Editorial
change "improve" to "improving"                                  Editorial
change "are based" to "or based"                                 Editorial
                                                                             Changed sentence to make more
                                                                             sense, not in exactly the way
"… employed to make all…"                                        Editorial   suggested.
This para is about sensitivities, should it be moved ??          Accepted    Paragraph moved

Define CART and provide proper reference in reference list       Accepted    Text ammended
change "latst" to "latest"                                       Editorial
Not a good examples because recent catalytst are not
emitted higher NH3. Choose something simple e.g.
aviation                                                         Accepted    text changed
A WoM scenario should not be listed as a necessary
activity for compiling emissions projections.                    Accepted    text changed
change "be in accordance" to "have a methodology that is
consistent"                                                      Editorial

I think some more detail is required ie some sort of list
refering to elements discussed in previous sections. eg.
values and sources of activity data used, GF factors used,
emission factors, details of tiers, sector definitions, sector
stratification, assumptions made in deriving future EFs.         Accepted    text changed
Again reference to QA/QC activities referred to in text-
checking, energy balances, etc                                   Accepted    text changed
Properly define reference for current guidebook
EMEP/TFEIP (2003) etc                                            Accepted    text changed
This isn't a bullet point                                        Editorial
I note that Sectoral Overview of Methods has been cut            Noted
I expect there are similar interractions in transport eg
projected air km and airccraft mix; vehicle km and vehicle
mix.                                                             Noted
Guidance for projections is very generic. The 2006
Guidance is more comprehensive                                   Noted
"The best practice principles for emission inventory
compilation also apply for projections. Therefore the
resulting projections will need to be transparent, accurate,
consistent, complete, and comparable."                           Accepted    text added
Comments   Additional note(s)
NOTE: not all EMEP members are EU members.




The Guidance for EPRTR is regime specific and not
information of the same generic type as that in the text.
Added "of"




Overlap is meant as this describes the equation.
6 is chapter number, this is the format for table/figure
numbering chosen.
Justin might like to check

Reporting is ALSO required..

Needs new guidelines reference?
Can we change the chapter name?




Aviation and National Navigation methods are already
inccluded




This is supposed to include relevant terms used for the
chapter.
Might want to check this is the best way - one of those links
has already been updated!
Ok but the underlying purpose of the Guidebook is certainly
to assist with reporting (this is why for example it is
structured to NFR which is a reporting requirement, and not
a methodological requirement…). It is indeed strange that
the chapter doesn't mention GNFR at all given this role of
the GB. Some information/consideration of GNFR needs to
be added.                                                   Will propose some text for this…




See above                                                  Will propose some text for this…
1995 and 200 are possible starting years for a WOM
scenario. Other years can be chosen.
Measures will be different for different MS. We can not be
prescriptive about what measures belong where in the WM
WAMs scenarios. The boundary for WM is clearly defined
in the WM text inder items a- f.




Definitions will be brought into line. However, as this is the
latest document in the evolution of our understanding there
may be some enhancements to the definitions in this
document over that of the Reporting Guidance.




Text in diagram will be changed.
Text definition of Adt changed to clarify that ADt is a sub
source of ADn
more appropriate text provided




This example is good because it shows the linkages
between different sectoral data for projections.
Chapter                              From ToPa From ToLin
_ID     Chapter_Name        NFR_Code Page ge   Line e




      1 Energy industries   1.A.1.a      1    1   29    8




      1 Energy industries   1.A.1.a      1   65


      1 Energy industries   1.A.1        2   20    2   21




      1 Energy industries   1.A.1        5    8    5   10

      1 Energy industries   1.A.1        5    4

      1 Energy industries   1.A.1        5    4

      1 Energy industries   1.A.1        6    2    6    5




      1 Energy industries   1.A.1.a      6    9   12    4

      1 Energy industries   1.A.1        6    1
      1 Energy industries   1.A.1        6    2

      1 Energy industries   1.A.1.a      6   24



      1 Energy industries   1.A.1.a      7    8    7   15

      1 Energy industries   1.A.1.a      7   19
1 Energy industries   1.A.1.a   8    20   8    24



1 Energy industries   1.A.1.a   8    25   9     2




1 Energy industries   1.A.1.a   9    32   9    33




1 Energy industries   1.A.1.a    9   32
1 Energy industries   1.A.1.a   10   37   10   37



1 Energy industries   1.A.1.a   10    3   11    8
1 Energy industries   1.A.1.a   10   21




1 Energy industries   1.A.1.a   10




1 Energy industries   1.A.1.a   11   7    11    8




1 Energy industries   1.A.1.a   11   13   11   13



1 Energy industries   1.A.1.a   13   11   13   12
1 Energy industries   1.A.1.a   13   12   13   12

1 Energy industries   1.A.1.a   13   13   13   14




1 Energy industries   1.A.1.a   13   18   13   21

1 Energy industries   1.A.1.a   13   12
1 Energy industries   1.A.1.a   13   13


1 Energy industries   1.A.1.a   13   13




1 Energy industries   1.A.1     14        17

1 Energy industries   1.A.1.a   14        27


1 Energy industries   1.A.1.a   14        27

1 Energy industries   1.A.1     15        15



1 Energy industries   1.A.1     16        17

1 Energy industries   1.A.1.a   18




1 Energy industries   1.A.1     19        24




1 Energy industries   1.A.1     19        24
1 Energy industries   1.A.1.a   19   3   27   3




1 Energy industries   1.A.1.a   19   3   27   3




1 Energy industries   1.A.1.a   19   3   27   3




1 Energy industries   1.A.1.a   19   3   27   3




1 Energy industries   1.A.1.a   19   3   27   3

1 Energy industries   1.A.1.a   19   3   27   3

1 Energy industries   1.A.1.a   19   3   27   3




1 Energy industries   1.A.1.a   19   3   27   3


1 Energy industries   1.A.1.a   19   3   27   3


1 Energy industries   1.A.1     21       21
1 Energy industries   1.A.1     22        22

1 Energy industries   1.A.1     23        23


1 Energy industries   1.A.1     23        23

1 Energy industries   1.A.1     25        25


1 Energy industries   1.A.1.a   25   4    25    5

1 Energy industries   1.A.1.a   25   4

1 Energy industries   1.A.1.a   26   1

1 Energy industries   1.A.1.a   26   3




1 Energy industries   1.A.1.a   28   6    28    6



1 Energy industries   1.A.1.b   29   11   29   13


1 Energy industries   1.A.1.b   29   9    40   20

1 Energy industries   1.A.1.b   29   26

1 Energy industries   1.A.1.b   29   28

1 Energy industries   1.A.1.b   30   18

1 Energy industries   1.A.1.b   30   21

1 Energy industries   1.A.1.b   30   25

1 Energy industries   1.A.1.b   30   30
1 Energy industries   1.A.1.b   31    2
1 Energy industries   1.A.1.b   31    3




1 Energy industries   1.A.1.b   33   11   33   11
1 Energy industries   1.A.1.b   33    7
1 Energy industries   1.A.1.b   34   33




1 Energy industries   1.A.1.b   34   33



1 Energy industries   1.A.1.b   34   34




1 Energy industries   1.A.1.b   35   5    35   5




1 Energy industries   1.A.1.b   35   5    38   3




1 Energy industries   1.A.1.b   35   5    38   3




1 Energy industries   1.A.1.b   35   5    38   3
1 Energy industries   1.A.1.b   35   5   38   1




1 Energy industries   1.A.1.b   35   5   38   1




1 Energy industries   1.A.1.b   35   4




1 Energy industries   1.A.1.b   36   1   36   1




1 Energy industries   1.A.1.b   37   1   37   1




1 Energy industries   1.A.1.b   37   4   37   4
1 Energy industries   1.A.1     38   3   38   4




1 Energy industries   1.A.1     38   3   38   4




1 Energy industries   1.A.1.b   38   1   38   1




1 Energy industries   1.A.1.b   38   3   38   3


1 Energy industries   1.A.1.b   39   1   39   1
1 Energy industries   1.A.1.b   39   1




1 Energy industries   1.A.1.b   39   3


1 Energy industries   1.A.1     40        40




1 Energy industries   1.A.1.b   40   5    40   12


1 Energy industries   1.A.1.c   40   21   40   21


1 Energy industries   1.A.1.c   40   21   46    4




1 Energy industries   1.A.1.c   40   21   46    4
1 Energy industries   1.A.1.b   40   12
1 Energy industries   1.A.1     42        42


1 Energy industries   1.A.1.c   42   15   42   15




1 Energy industries   1.A.1.c   43   23   43   23




1 Energy industries   1.A.1     44   1    44    4




1 Energy industries   1.A.1.c   44   1    44    1




1 Energy industries   1.A.1.c   44   3    44    3



1 Energy industries   1.A.1     46   15   47    1
1 Energy industries   1.A.1.c   48   48   48   36


1 Energy industries   1.A.1     51   2    52    1
1 Energy industries   1.A.1     52   2   53   1

1 Energy industries   1.A.1.a   53




1 Energy industries   1.A.1.b   53



1 Energy industries   1.A.1.a   56




1 Energy industries   1.A.1     59   2   59   9
1 Energy industries   1.A.1     59   2    59   9




1 Energy industries   1.A.1.a   61   23

1 Energy industries   1.A.1.a   63   5




1 Energy industries   1.A


1 Energy industries   1.A
1 Energy industries   1.A




1 Energy industries   1.A



1 Energy industries   1.A



1 Energy industries   1.A




1 Energy industries   1.A


1 Energy industries   1.A.1



1 Energy industries   1.A.1

1 Energy industries   1.A.1.a

1 Energy industries   1.A.1.a

1 Energy industries   1.A.1.a


1 Energy industries   1.A.1.a
  Manufacturing industries and
2 construction (combustion)      1.A.2     1         52

  Manufacturing industries and
2 construction (combustion)      1.A.2     2    13   2    14


  Manufacturing industries and
2 construction (combustion)      1.A.2     3    1    3     2

  Manufacturing industries and
2 construction (combustion)      1.A.2     3    1    3     2



  Manufacturing industries and
2 construction (combustion)      1.A.2.c   5    32   5    34

  Manufacturing industries and
2 construction (combustion)      1.A.2     8    31   8    34

  Manufacturing industries and
2 construction (combustion)      1.A.2     8    27   9    27




  Manufacturing industries and
2 construction (combustion)      1.A.2     12   2    12    2




  Manufacturing industries and
2 construction (combustion)      1.A.2     12   5    12    5


  Manufacturing industries and
2 construction (combustion)      1.A.2     12   4    12    4
  Manufacturing industries and
2 construction (combustion)      1.A.2   12   4   12   4




  Manufacturing industries and
2 construction (combustion)      1.A.2   13   2   13   2




  Manufacturing industries and
2 construction (combustion)      1.A.2   13   5   13   5

  Manufacturing industries and
2 construction (combustion)      1.A.2   13   1   13   1




  Manufacturing industries and
2 construction (combustion)      1.A.2   13   1   13   1

  Manufacturing industries and
2 construction (combustion)      1.A.2   13   4   13   4


  Manufacturing industries and
2 construction (combustion)      1.A.2   13   1   13   2


  Manufacturing industries and
2 construction (combustion)      1.A.2   13       47




  Manufacturing industries and
2 construction (combustion)      1.A.2   14   2   14   2




  Manufacturing industries and
2 construction (combustion)      1.A.2   14   5   14   5


  Manufacturing industries and
2 construction (combustion)      1.A.2   14   1   14   1
  Manufacturing industries and
2 construction (combustion)      1.A.2     14   1    14    1




  Manufacturing industries and
2 construction (combustion)      1.A.2     14   1    14    1

  Manufacturing industries and
2 construction (combustion)      1.A.2     14   4    14    4




  Manufacturing industries and
2 construction (combustion)      1.A.2     14   14   48    4




  Manufacturing industries and
2 construction (combustion)      1.A.2.a   15   13   15   13




  Manufacturing industries and
2 construction (combustion)      1.A.2.a   15   11   20    4




  Manufacturing industries and
2 construction (combustion)      1.A.2     15        49




  Manufacturing industries and
2 construction (combustion)      1.A.2     15   10        11


  Manufacturing industries and
2 construction (combustion)      1.A.2     16        16
  Manufacturing industries and
2 construction (combustion)      1.A.2.a   16   3   16   3

  Manufacturing industries and
2 construction (combustion)      1.A.2.a   16   6   16   6

  Manufacturing industries and
2 construction (combustion)      1.A.2.a   17   7   17   7



  Manufacturing industries and
2 construction (combustion)      1.A.2.a   17   2   17   4


  Manufacturing industries and
2 construction (combustion)      1.A.2.a   17   2   17   4



  Manufacturing industries and
2 construction (combustion)      1.A.2.a   17   5   17   8




  Manufacturing industries and
2 construction (combustion)      1.A.2     18       18




  Manufacturing industries and
2 construction (combustion)      1.A.2.a   18   2   18   2




  Manufacturing industries and
2 construction (combustion)      1.A.2.a   18   1   18   2


  Manufacturing industries and
2 construction (combustion)      1.A.2.a   18   1   18   2


  Manufacturing industries and
2 construction (combustion)      1.A.2     18       19

  Manufacturing industries and
2 construction (combustion)      1.A.2.a   19   3   19   3
  Manufacturing industries and
2 construction (combustion)      1.A.2.a   19   1   19   3

  Manufacturing industries and
2 construction (combustion)      1.A.2.a   19   1   19   3

  Manufacturing industries and
2 construction (combustion)      1.A.2.a   19   1   19   3




  Manufacturing industries and
2 construction (combustion)      1.A.2.b   20   2   20   4


  Manufacturing industries and
2 construction (combustion)      1.A.2.b   20   2   20   4



  Manufacturing industries and
2 construction (combustion)      1.A.2     20       26




  Manufacturing industries and
2 construction (combustion)      1.A.2.b   20   1   27   3




  Manufacturing industries and
2 construction (combustion)      1.A.2.b   21   1   21   3


  Manufacturing industries and
2 construction (combustion)      1.A.2.b   22   1   22   3
  Manufacturing industries and
2 construction (combustion)      1.A.2.b   22   1   22   3

  Manufacturing industries and
2 construction (combustion)      1.A.2.b   22   1   22   3

  Manufacturing industries and
2 construction (combustion)      1.A.2.b   22   1   22   3


  Manufacturing industries and
2 construction (combustion)      1.A.2     22       25
  Manufacturing industries and
2 construction (combustion)      1.A.2.b   23   1   23   3


  Manufacturing industries and
2 construction (combustion)      1.A.2.b   23   1   23   3
  Manufacturing industries and
2 construction (combustion)      1.A.2.b   24   1   24   3


  Manufacturing industries and
2 construction (combustion)      1.A.2.b   24   1   24   3




  Manufacturing industries and
2 construction (combustion)      1.A.2     24       27
  Manufacturing industries and
2 construction (combustion)      1.A.2.b   25   2   25   4

  Manufacturing industries and
2 construction (combustion)      1.A.2.b   25   2   25   4

  Manufacturing industries and
2 construction (combustion)      1.A.2.b   25   2   25   4




  Manufacturing industries and
2 construction (combustion)      1.A.2.b   26   1   26   3
  Manufacturing industries and
2 construction (combustion)      1.A.2.b     27   1   27   3


  Manufacturing industries and
2 construction (combustion)      1.A.2.d     28   2   28   4


  Manufacturing industries and
2 construction (combustion)      1.A.2.d     28   1   29   5




  Manufacturing industries and
2 construction (combustion)      1.A.2.d     29   3   29   5

  Manufacturing industries and
2 construction (combustion)      1.A.2.d     29   1   29   2



  Manufacturing industries and
2 construction (combustion)      1.A.2.d     29   1   29   2




  Manufacturing industries and
2 construction (combustion)      1.A.2.d     29   3   29   5


  Manufacturing industries and
2 construction (combustion)      1.A.2       29   4
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   30   1   30   1


  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   30   3   30   5
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   30   2   31   4




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   30   2   31   4

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   31   2   31   3

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   31   2   31   3




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   32   1   35   4
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   32   3   35   3

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   32   3   35   3




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   32   1   35   4


  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   33   3   33   5
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   33   3   33   5

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   34   1   34   3

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   34   1   34   3


  Manufacturing industries and
2 construction (combustion)      1.A.2       35       35

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   35   1   35   3
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   35   3




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   36   1   39   3




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   36   1   39   3


  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   37   1   37   3



  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   37   1   37   3
  Manufacturing industries and
2 construction (combustion)      1.A.2       37   2

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   38   2   38   2

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   38   2   38   2




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   40   1   40   4




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   40   1   41   2




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   40   1   41   2
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   41   1   41   2


  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   41   1   41   2

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   42   3   42   3

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   42   3   42   3




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   42   1   43   3

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   42   1   43   3


  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   43   1   43   3




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   44   1   46   3
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   44   1    48    3

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   45   2    45    2

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   45   2    45    2
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   46   1    46    3


  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   46   1    46    3

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   47   3    47    3

  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   47   3    47    3




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   47   1    48    3
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   47   1    48    3


  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i   48   1    48    3


  Manufacturing industries and
2 construction (combustion)      1.A.2       51   10   51   10

  Manufacturing industries and
2 construction (combustion)      1.A.2       51   10   52    1
  Manufacturing industries and
2 construction (combustion)      1.A.2       52        52
  Manufacturing industries and
2 construction (combustion)      1.A.2       52   2   52   4




  Manufacturing industries and
2 construction (combustion)      1.A.2

  Manufacturing industries and
2 construction (combustion)      1.A.2.a




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i




  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i
  Manufacturing industries and
2 construction (combustion)      1.A.2.f.i

3 Civil aviation                 1.A.3.a     1   1
3 Civil aviation                 1.A.3.a     2   5    2    5




3 Civil aviation                 1.A.3.a     2   9    2   17


3 Civil aviation                 1.A.3.a     2   9    2   17


3 Civil aviation                 1.A.3.a     3   14



3 Civil aviation                 1.A.3.a     4   7    4   17


3 Civil aviation                 1.A.3.a     4   18   4   22


3 Civil aviation                 1.A.3.a     4   19   4   22




3 Civil aviation                 1.A.3.a     4   34
3 Civil aviation   1.A.3.a   5

3 Civil aviation   1.A.3.a   6    1    6     1




3 Civil aviation   1.A.3.a   7    12   7    13


3 Civil aviation   1.A.3.a   7    2    7     3
3 Civil aviation   1.A.3.a   7    9    7    10


3 Civil aviation   1.A.3.a   7




3 Civil aviation   1.A.3.a   8    7    8    13


3 Civil aviation   1.A.3.a   9    8    9     9


3 Civil aviation   1.A.3.a   9


3 Civil aviation   1.A.3.a   10   1


3 Civil aviation   1.A.3.a   11

3 Civil aviation   1.A.3.a   12   41   12   42


3 Civil aviation   1.A.3.a   12   41



3 Civil aviation   1.A.3.a   13   13   13   28
3 Civil aviation   1.A.3.a   13   32   14   13
3 Civil aviation   1.A.3.a   14   29   14   32

3 Civil aviation   1.A.3.a   14   18   14   32




3 Civil aviation   1.A.3.a   14   14   17    4




3 Civil aviation   1.A.3.a   15   1    15    2



3 Civil aviation   1.A.3.a   15   1    15    2




3 Civil aviation   1.A.3.a   15


3 Civil aviation   1.A.3.a   17   1    17    4

3 Civil aviation   1.A.3.a   17




3 Civil aviation   1.A.3.a   18   7    18   13




3 Civil aviation   1.A.3.a   18   16   18   17
3 Civil aviation   1.A.3.a   18   23   18   24


3 Civil aviation   1.A.3.a   18   15   18   24



3 Civil aviation   1.A.3.a   18   25   20    1

3 Civil aviation   1.A.3.a   18




3 Civil aviation   1.A.3.a   18   6


3 Civil aviation   1.A.3.a   18   7


3 Civil aviation   1.A.3.a   20


3 Civil aviation   1.A.3.a   20


3 Civil aviation   1.A.3.a   20   1


3 Civil aviation   1.A.3.a   20   1
3 Civil aviation   1.A.3.a   21        22


3 Civil aviation   1.A.3.a   22   3    22    9


3 Civil aviation   1.A.3.a   22   12   23    8
3 Civil aviation   1.A.3.a   23




3 Civil aviation   1.A.3.a   25   6    26    1




3 Civil aviation   1.A.3.a   25        29


3 Civil aviation   1.A.3.a   25



3 Civil aviation   1.A.3.a   25   4
3 Civil aviation   1.A.3.a   26   5    26    6

3 Civil aviation   1.A.3.a   26   7    26    7


3 Civil aviation   1.A.3.a   26    9   27
3 Civil aviation   1.A.3.a   26   11




3 Civil aviation   1.A.3.a   27   7    29    6


3 Civil aviation   1.A.3.a   29   13   32   11




3 Civil aviation   1.A.3.a   31   6    31    9
3 Civil aviation   1.A.3.a   34   16   34   17




3 Civil aviation   1.A.3.a   34


3 Civil aviation   1.A.3.a   35




3 Civil aviation   1.A.3.a   36   29   36   30



3 Civil aviation   1.A.3.a   40   6


3 Civil aviation   1.A.3.a   42        43


3 Civil aviation   1.A.3.a


3 Civil aviation   1.A.3.a



3 Civil aviation   1.A.3.a


3 Civil aviation   1.A.3.a



3 Civil aviation   1.A.3.a


3 Civil aviation   1.A.3.a


3 Civil aviation   1.A.3.a


3 Civil aviation   1.A.3.a


3 Civil aviation   1.A.3.a
3 Civil aviation             1.A.3.a


3 Civil aviation             1.A.3.a



3 Civil aviation             1.A.3.a


3 Civil aviation             1.A.3.a


3 Civil aviation             1.A.3.a


3 Civil aviation             1.A.3.a


3 Civil aviation             1.A.3.a


3 Civil aviation             1.A.3.a


3 Civil aviation             1.A.3.a


4 Road transport (exhaust)   1.A.3.b   1

4 Road transport (exhaust)   1.A.3.b   3   1    3    2

4 Road transport (exhaust)   1.A.3.b   3   3    3   17
4 Road transport (exhaust)   1.A.3.b   3   8    3    9




4 Road transport (exhaust)   1.A.3.b   3   13   3   14
4 Road transport (exhaust)   1.A.3.b   3   19   3   28

4 Road transport (exhaust)   1.A.3.b   3   23   3   25




4 Road transport (exhaust)   1.A.3.b   3   10   3   11
4 Road transport (exhaust)   1.A.3.b   3   3

4 Road transport (exhaust)   1.A.3.b   3   5

4 Road transport (exhaust)   1.A.3.b   3   7




4 Road transport (exhaust)   1.A.3.b   3   10




4 Road transport (exhaust)   1.A.3.b   3   19
4 Road transport (exhaust)   1.A.3.b   3   20
4 Road transport (exhaust)   1.A.3.b   3   21

4 Road transport (exhaust)   1.A.3.b   3   30
4 Road transport (exhaust)   1.A.3.b   3   33


4 Road transport (exhaust)   1.A.3.b   3   35




4 Road transport (exhaust)   1.A.3.b   4   2
4 Road transport (exhaust)   1.A.3.b   4
4 Road transport (exhaust)   1.A.3.b   4   9


4 Road transport (exhaust)   1.A.3.b   6   29   6   30
4 Road transport (exhaust)   1.A.3.b   6    7
4 Road transport (exhaust)   1.A.3.b   6   35




4 Road transport (exhaust)   1.A.3.b   7   1    7    2
4 Road transport (exhaust)   1.A.3.b   7   1    7    14




4 Road transport (exhaust)   1.A.3.b   7   5    15    8

4 Road transport (exhaust)   1.A.3.b   8        1
4 Road transport (exhaust)   1.A.3.b   8   13   8    13




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




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

4 Road transport (exhaust)     1.A.3.b   16   29   31    1
4 Road transport (exhaust)     1.A.3.b   16   31


4 Road transport (exhaust)     1.A.3.b   16   29



4 Road transport (exhaust)     1.A.3.b   17   9    31    2




4 Road transport (exhaust)     1.A.3.b   24        26


4 Road transport (exhaust)     1.A.3.b   31        35




4 Road transport (exhaust)     1.A.3.b   35    9   35   10
4 Road transport (exhaust)     1.A.3.b   35   16   35   16
4 Road transport (exhaust)     1.A.3.b   35   16


4 Road transport (exhaust)     1.A.3.b   35   20




4 Road transport (exhaust)     1.A.3.b   35   17
4 Road transport (exhaust)   1.A.3.b       37   4


4 Road transport (exhaust)   1.A.3.b       39   8    39   18




4 Road transport (exhaust)   1.A.3.b       40   6    40   13




4 Road transport (exhaust)   1.A.3.b       44   1    44    3




4 Road transport (exhaust)   1.A.3.b.iii   53   25   54   34
4 Road transport (exhaust)   1.A.3.b       53    3
4 Road transport (exhaust)   1.A.3.b       53    8




4 Road transport (exhaust)   1.A.3.b       53   12




4 Road transport (exhaust)   1.A.3.b       55




4 Road transport (exhaust)   1.A.3.b       58
4 Road transport (exhaust)   1.A.3.b.iii   63    26   65    29




4 Road transport (exhaust)   1.A.3.b       67

4 Road transport (exhaust)   1.A.3.b       74


4 Road transport (exhaust)   1.A.3.b       76




4 Road transport (exhaust)   1.A.3.b       100   5    100    7




4 Road transport (exhaust)   1.A.3.b       100   7    100    8




4 Road transport (exhaust)   1.A.3.b       100




4 Road transport (exhaust)   1.A.3.b       107   8    107   14




4 Road transport (exhaust)   1.A.3.b       115   1    118    0



4 Road transport (exhaust)   1.A.3.b
4 Road transport (exhaust)   1.A.3.b




4 Road transport (exhaust)   1.A.3.b


4 Road transport (exhaust)   1.A.3.b




4 Road transport (exhaust)   1.A.3.b




4 Road transport (exhaust)   1.A.3.b




4 Road transport (exhaust)   1.A.3.b

4 Road transport (exhaust)   1.A.3.b


4 Road transport (exhaust)   1.A.3.b
4 Road transport (exhaust)               1.A.3.b




4 Road transport (exhaust)               1.A.3.b



5 Road transport, gasoline evaporation   1.A.3.b.v   1   31

5 Road transport, gasoline evaporation   1.A.3.b.v   2   12   2   14




5 Road transport, gasoline evaporation   1.A.3.b.v   2   19   2   27




5 Road transport, gasoline evaporation   1.A.3.b.v   2   25   2   27




5 Road transport, gasoline evaporation   1.A.3.b.v   2   7




5 Road transport, gasoline evaporation   1.A.3.b.v   2   11
5 Road transport, gasoline evaporation   1.A.3.b.v   2




5 Road transport, gasoline evaporation   1.A.3.b.v   3   26   2   27




5 Road transport, gasoline evaporation   1.A.3.b.v   3   2    3    5




5 Road transport, gasoline evaporation   1.A.3.b.v   3   7    3   14




5 Road transport, gasoline evaporation   1.A.3.b.v   3   26   3   27




5 Road transport, gasoline evaporation   1.A.3.b.v   3   4    3    4
5 Road transport, gasoline evaporation   1.A.3.b.v   3   39   4   1




5 Road transport, gasoline evaporation   1.A.3.b.v   3   7




5 Road transport, gasoline evaporation   1.A.3.b.v   3   16




5 Road transport, gasoline evaporation   1.A.3.b.v   3   28




5 Road transport, gasoline evaporation   1.A.3.b.v   3   29




5 Road transport, gasoline evaporation   1.A.3.b.v   3   30




5 Road transport, gasoline evaporation   1.A.3.b.v   3   32
5 Road transport, gasoline evaporation   1.A.3.b.v   3   35




5 Road transport, gasoline evaporation   1.A.3.b.v   4   8    4    10




5 Road transport, gasoline evaporation   1.A.3.b.v   4   7




5 Road transport, gasoline evaporation   1.A.3.b.v   4   8



5 Road transport, gasoline evaporation   1.A.3.b.v   5   5    5    11


5 Road transport, gasoline evaporation   1.A.3.b.v   5   4    5    13


5 Road transport, gasoline evaporation   1.A.3.b.v   5   1    5     2


5 Road transport, gasoline evaporation   1.A.3.b.v   5   5    5     6

5 Road transport, gasoline evaporation   1.A.3.b.v   5   10   5    10


5 Road transport, gasoline evaporation   1.A.3.b.v   5   15   5    15

5 Road transport, gasoline evaporation   1.A.3.b.v   5   10   5    10

5 Road transport, gasoline evaporation   1.A.3.B.V   5   3    20    1
5 Road transport, gasoline evaporation   1.A.3.b.v   5


5 Road transport, gasoline evaporation   1.A.3.b.v   5

5 Road transport, gasoline evaporation   1.A.3.b.v   5

5 Road transport, gasoline evaporation   1.A.3.b.v   5


5 Road transport, gasoline evaporation   1.A.3.b.v   6        8


5 Road transport, gasoline evaporation   1.A.3.b.v   6   7

5 Road transport, gasoline evaporation   1.A.3.b.v   6   17




5 Road transport, gasoline evaporation   1.A.3.b.v   6
5 Road transport, gasoline evaporation   1.A.3.b.v   6



5 Road transport, gasoline evaporation   1.A.3.b.v   7        8




5 Road transport, gasoline evaporation   1.A.3.b.v   8   13   9   34


5 Road transport, gasoline evaporation   1.A.3.b.v   8   9




5 Road transport, gasoline evaporation   1.A.3.b.v   8   13




5 Road transport, gasoline evaporation   1.A.3.b.v   8   13




5 Road transport, gasoline evaporation   1.A.3.b.v   8   13
5 Road transport, gasoline evaporation   1.A.3.b.v   8




5 Road transport, gasoline evaporation   1.A.3.b.v   9    8    9     9




5 Road transport, gasoline evaporation   1.A.3.b.v   9    12   9    13




5 Road transport, gasoline evaporation   1.A.3.b.v   10   12




5 Road transport, gasoline evaporation   1.A.3.b.v   12   9




5 Road transport, gasoline evaporation   1.A.3.b.v   13   1    13    1
5 Road transport, gasoline evaporation   1.A.3.b.v   13   1




5 Road transport, gasoline evaporation   1.A.3.b.v   14   1




5 Road transport, gasoline evaporation   1.A.3.b.v   15   1




5 Road transport, gasoline evaporation   1.A.3.b.v   15   1




5 Road transport, gasoline evaporation   1.A.3.b.v   15   20




5 Road transport, gasoline evaporation   1.A.3.b.v   15   22
5 Road transport, gasoline evaporation   1.A.3.b.v   16   13   16   14




5 Road transport, gasoline evaporation   1.A.3.b.v   16   7




5 Road transport, gasoline evaporation   1.A.3.b.v   16   30




5 Road transport, gasoline evaporation   1.A.3.b.v   17   1    17    1




5 Road transport, gasoline evaporation   1.A.3.b.v   19   11




5 Road transport, gasoline evaporation   1.A.3.b.v   20   8    20    9
5 Road transport, gasoline evaporation   1.A.3.b.v   20   2




5 Road transport, gasoline evaporation   1.A.3.b.v   21   3


5 Road transport, gasoline evaporation   1.A.3.b.v   21   7




5 Road transport, gasoline evaporation   1.A.3.b.v   22




5 Road transport, gasoline evaporation   1.A.3.b.v   23   4



5 Road transport, gasoline evaporation   1.A.3.b.v

5 Road transport, gasoline evaporation   1.A.3.b.v


5 Road transport, gasoline evaporation   1.A.3.b.v




5 Road transport, gasoline evaporation   1.A.3.b.v


5 Road transport, gasoline evaporation   1.A.3.b.v




5 Road transport, gasoline evaporation   1.A.3.b.v
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   1
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   2    10   2    15




  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   2    23   2    25
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   2    10
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   2    14



  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   2    17




  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   5    20



  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   6    3
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   7    33


  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   10   9    12    1


  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   10   10




  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi   11   1    12    1
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    12   1    13   27
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    13   34
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.B.VI    14   6    28    5
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii   14

  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii   14   13
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    14
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    14




  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    14   15


  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii   15        16

  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    15   21   16    2


  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    15   21   16    2
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    15   12
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    15   15
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    15   19

  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii   16   18
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    16   6




  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    16   20
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    17   6    17   8
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii   17        23
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    17   14

  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    17   14

  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    17   16
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    17   22



  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii   24



  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii   25
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii   26
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    26   11




  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    26   18
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    27   4




  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    28   1



  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii   29   13   29   18
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    29   2    29    3




  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    30   30
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi    60   6


  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii

  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii


  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii


  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vii
  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi




  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi


  Road transport, automobile tyre and
6 brake wear and road abrasion          1.A.3.b.vi
7 Railways                              1.A.3.c      4    16

7 Railways                              1.A.3.c      6    15   6    21


7 Railways                              1.A.3.c      6    13   8     1


7 Railways                              1.A.3.c      6         9
7 Railways                              1.A.3.c      6    13


7 Railways                              1.A.3.c      6    20

7 Railways                              1.A.3.c      7    18   7    24

7 Railways                              1.A.3.c      7    29   7    32
7 Railways                              1.A.3.c      7     2

7 Railways                              1.A.3.c      7    18

7 Railways                              1.A.3.c      8    2    9     2


7 Railways                              1.A.3.c      8         9

7 Railways                              1.A.3.c      9
7 Railways                              1.A.3.c      9


7 Railways                              1.A.3.c      10   29   10   29


7 Railways                              1.A.3.c      10   29   10   29
7 Railways   1.A.3.c   11   20   11   24




7 Railways   1.A.3.c   11   28   11   28




7 Railways   1.A.3.c   11   20   11   24




7 Railways   1.A.3.c   11   28   11   28


7 Railways   1.A.3.c   11   25   11   28

7 Railways   1.A.3.c   11   4




7 Railways   1.A.3.c   12   25   12   37

7 Railways   1.A.3.c   12   2    12    2
7 Railways   1.A.3.c   12   8    12    8
7 Railways                               1.A.3.c   12   22   12   22

7 Railways                               1.A.3.c   12   2    12    2
7 Railways                               1.A.3.c   12   8    12    8




7 Railways                               1.A.3.c   12   22   12   22

7 Railways                               1.A.3.c   12   23   15   13
7 Railways                               1.A.3.c   14    7
7 Railways                               1.A.3.c   15    7




7 Railways                               1.A.3.c   16   1    16    1




7 Railways                               1.A.3.c   16   1    16    1


7 Railways                               1.A.3.c



7 Railways                               1.A.3.c
  Inter(national) navigation, national
8 fishing                                1.A.3.d   3
  Inter(national) navigation, national
8 fishing                                1.A.3.d   4   32   4   42




  Inter(national) navigation, national
8 fishing                                1.A.3.d   4   32   4   42

  Inter(national) navigation, national
8 fishing                                1.A.3.d   5   2    5   11

  Inter(national) navigation, national
8 fishing                                1.A.3.d   5   15   5   17

  Inter(national) navigation, national
8 fishing                                1.A.3.d   5   15   5   17
  Inter(national) navigation, national
8 fishing                                1.A.3.d   5   24
  Inter(national) navigation, national
8 fishing                                1.A.3.d   6   27   6   19
  Inter(national) navigation, national
8 fishing                                1.A.3.d   7    20   7    29

  Inter(national) navigation, national
8 fishing                                1.A.3.d   10        11




  Inter(national) navigation, national
8 fishing                                1.A.3.d   11   16   11   18




  Inter(national) navigation, national
8 fishing                                1.A.3.d   11   16   11   18
  Inter(national) navigation, national
8 fishing                                1.A.3.d   11   18
  Inter(national) navigation, national
8 fishing                                1.A.3.d   11   18

  Inter(national) navigation, national
8 fishing                                1.A.3.d   11   21

  Inter(national) navigation, national
8 fishing                                1.A.3.d   35   6    35   14

  Inter(national) navigation, national
8 fishing                                1.A.3.d   35   6    35   14

  Inter(national) navigation, national
8 fishing                                1.A.3.d   35   10

  Inter(national) navigation, national
8 fishing                                1.A.3.d   35   10
  Inter(national) navigation, national
8 fishing                                1.A.3.d   36
  Inter(national) navigation, national
8 fishing                                1.A.3.d   36
  Inter(national) navigation, national
8 fishing                                1.A.3.d   36
  Inter(national) navigation, national
8 fishing                                1.A.3.d   36
  Inter(national) navigation, national
8 fishing                                1.A.3.d   37
  Inter(national) navigation, national
8 fishing                                1.A.3.d   37
  Inter(national) navigation, national
8 fishing                                1.A.3.d   38
  Inter(national) navigation, national
8 fishing                                1.A.3.d   38
  Inter(national) navigation, national
8 fishing                                1.A.3.d   39   8

  Inter(national) navigation, national
8 fishing                                1.A.3.d   39   31
  Inter(national) navigation, national
8 fishing                                1.A.3.d   39   8

  Inter(national) navigation, national
8 fishing                                1.A.3.d   39   31
  Inter(national) navigation, national
8 fishing                                1.A.3.d   39
  Inter(national) navigation, national
8 fishing                                1.A.3.d   40   1    40    3

  Inter(national) navigation, national
8 fishing                                1.A.3.d   40   24   40   27
  Inter(national) navigation, national
8 fishing                                1.A.3.d   40   1    40    3

  Inter(national) navigation, national
8 fishing                                1.A.3.d   40   24   40   27




  Inter(national) navigation, national
8 fishing                                1.A.3.d   47   4    48    2




  Inter(national) navigation, national
8 fishing                                1.A.3.d   47   4    48    2




  Inter(national) navigation, national
8 fishing                                1.A.3.d   48   6    48   11
  Inter(national) navigation, national
8 fishing                                1.A.3.d   48   6    48   11



  Inter(national) navigation, national
8 fishing                                1.A.3.d   48        49




  Inter(national) navigation, national
8 fishing                                1.A.3.d   48   26


  Inter(national) navigation, national
8 fishing                                1.A.3.d   49




  Inter(national) navigation, national
8 fishing                                1.A.3.d   50   34   51   28




  Inter(national) navigation, national
8 fishing                                1.A.3.d   50   34   51   28
  Inter(national) navigation, national
8 fishing                                1.A.3.d   53   1   53   1




  Inter(national) navigation, national
8 fishing                                1.A.3.d   53   1   53   1




  Inter(national) navigation, national
8 fishing                                1.A.3.d   53   1




  Inter(national) navigation, national
8 fishing                                1.A.3.d   53   1

  Inter(national) navigation, national
8 fishing                                1.A.3.d
  Inter(national) navigation, national
8 fishing                                1.A.3.d




  Inter(national) navigation, national
8 fishing                                1.A.3.d
  Inter(national) navigation, national
8 fishing                                1.A.3.d




  Inter(national) navigation, national
8 fishing                                1.A.3.d


  Inter(national) navigation, national
8 fishing                                1.A.3.d

  Inter(national) navigation, national
8 fishing                                1.A.3.d

  Inter(national) navigation, national
8 fishing                                1.A.3.d
  Inter(national) navigation, national
8 fishing                                1.A.3.d
   Inter(national) navigation, national
 8 fishing                                1.A.3.d
   Inter(national) navigation, national
 8 fishing                                1.A.3.d
   Inter(national) navigation, national
 8 fishing                                1.A.3.d
   Inter(national) navigation, national
 8 fishing                                1.A.3.d
   Inter(national) navigation, national
 8 fishing                                1.A.3.d




 9 Pipeline compressors                   1.A.3.e.i




10 Small combustion                       1.A.5       1




10 Small combustion                       1.A.4       2   23   2   23



10 Small combustion                       1.A.4       2        2




10 Small combustion                       1.A.4       3   10   3   12

10 Small combustion                       1.A.4       3   19   3   19
10 Small combustion   1.A.4   3   22   13   11



10 Small combustion   1.A.4   3        13


10 Small combustion   1.A.4   4    7
10 Small combustion   1.A.4   5   36   5    36




10 Small combustion   1.A.4   6   16   6    40




10 Small combustion   1.A.4   6   40   6    40




10 Small combustion   1.A.4   7   5    7     8


10 Small combustion   1.A.4   7   18   7    20
10 Small combustion   1.A.4       8    33   8    33




10 Small combustion   1.A.4       9    6    9     8



10 Small combustion   1.A.4       14        15


10 Small combustion   1.A.4       16   17   16   33



10 Small combustion   1.A.4       18   1    18    1




10 Small combustion   1.A.4       18   4    18    6


10 Small combustion   1.A.4       18   11   18   14



10 Small combustion   1.A.4       18   7

10 Small combustion   1.A.4       19   10   19   10



10 Small combustion   1.A.4       19   13   19   13



10 Small combustion   1.A.4.b.i   19   10   19   15
10 Small combustion   1.A.4       19        37


10 Small combustion   1.A.4       19




10 Small combustion   1.A.4       19   14



10 Small combustion   1.A.4       19   14


10 Small combustion   1.A.4       21        21


10 Small combustion   1.A.4.b.i   21        22


10 Small combustion   1.A.4       21   2


10 Small combustion   1.A.4       22        22



10 Small combustion   1.A.4.b.i   22        22


10 Small combustion   1.A.4       22   1    23   2



10 Small combustion   1.A.4       25   2


10 Small combustion   1.A.4.b.i   27        27




10 Small combustion   1.A.4       27   15   37   4
10 Small combustion   1.A.4       28   24   28   24



10 Small combustion   1.A.4       28   24   28   24



10 Small combustion   1.A.4.b.i   29   1    29    1




10 Small combustion   1.A.4.b.i   29   1    37    2

10 Small combustion   1.A.4.b.i   29   1    37    2




10 Small combustion   1.A.4.b.i   30        30


10 Small combustion   1.A.4.b.i   30   1    30    2

10 Small combustion   1.A.4       31        33


10 Small combustion   1.A.4       33        33




10 Small combustion   1.A.4.b.i   33        33


10 Small combustion   1.A.4       35        35




10 Small combustion   1.A.4.b.i   35        35


10 Small combustion   1.A.4       37        37
10 Small combustion   1.A.4.a.i   37   1    37    4



10 Small combustion   1.A.4.b.i   37        37




10 Small combustion   1.A.4       38   17   38   18




10 Small combustion   1.A.4       39   13

10 Small combustion   1.A.4       45        46



10 Small combustion   1.A.4       46        48




10 Small combustion   1.A.4       49   1    71    1


10 Small combustion   1.A.4       73   1


10 Small combustion   1.A.4       83   1
10 Small combustion   1.A.4       84   1




10 Small combustion   1.A.4       89   1   89   6
10 Small combustion   1.A.4       90   1   95   1

10 Small combustion   1.A.4       91       95




10 Small combustion   1.A.4.a.i   95   1   95   9




10 Small combustion   1.A.4


10 Small combustion   1.A.4




10 Small combustion   1.A.4




10 Small combustion   1.A.4
10 Small combustion   1.A.4

10 Small combustion   1.A.4.b.i
10 Small combustion              1.A.5

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   9    24   9    26
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   13   10   13   13
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   13   15

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   14

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   15
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   16

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   17

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   22   6    22    8
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   23   11
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   23   13



   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   28        31


   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   28        31

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   37

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   37   5

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   38   16
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   39   1
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii   40   17
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii


   Non-road mobile sources and
11 machinery                     1.A.2.f.ii

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii


   Non-road mobile sources and
11 machinery                     1.A.2.f.ii

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii


   Non-road mobile sources and
11 machinery                     1.A.2.f.ii


   Non-road mobile sources and
11 machinery                     1.A.2.f.ii
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii


   Non-road mobile sources and
11 machinery                     1.A.2.f.ii

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii

   Non-road mobile sources and
11 machinery                     1.A.2.f.ii
   Non-road mobile sources and
11 machinery                       1.A.2.f.ii
   Non-road mobile sources and
11 machinery                       1.A.2.f.ii

     Non-road mobile sources and
11   machinery                     1.A.2.f.ii
     Non-road mobile sources and
11   machinery                     1.A.2.f.ii
     Non-road mobile sources and
11   machinery                     1.A.2.f.ii
     Non-road mobile sources and
11   machinery                     1.A.2.f.ii

   Non-road mobile sources and
11 machinery                       1.A.2.f.ii

   Non-road mobile sources and
11 machinery                       1.A.2.f.ii

   Non-road mobile sources and
11 machinery                       1.A.2.f.ii
   Non-road mobile sources and
11 machinery                       1.A.2.f.ii

   Non-road mobile sources and
11 machinery                       1.A.2.f.ii


   Non-road mobile sources and
11 machinery                       1.A.2.f.ii

   Non-road mobile sources and
11 machinery                       1.A.2.f.ii

   Non-road mobile sources and
11 machinery                       1.A.2.f.ii
   Non-road mobile sources and
11 machinery                       1.A.2.f.ii


   Non-road mobile sources and
11 machinery                       1.A.2.f.ii
   Non-road mobile sources and
11 machinery                       1.A.2.f.ii


   Non-road mobile sources and
11 machinery                       1.A.2.f.ii
   Non-road mobile sources and
11 machinery                       1.A.2.f.ii
   Non-road mobile sources and
11 machinery                     1.A.2.f.ii


   Non-road mobile sources and
11 machinery                     1.A.2.f.ii


   Non-road mobile sources and
11 machinery                     1.A.2.f.ii

12 Coal mining and handling      1.B.1.a      2    6    2     6



12 Coal mining and handling      1.B.1.a      2    6    2     8

12 Coal mining and handling      1.B.1.a      2    6    2     6

12 Coal mining and handling      1.B.1.a      2    17   2    17



12 Coal mining and handling      1.B.1.a      7    11   7    11



12 Coal mining and handling      1.B.1.a      9    4    9     4



12 Coal mining and handling      1.B.1.a      9    8    9     8




12 Coal mining and handling      1.B.1.a      10   3    10    3

12 Coal mining and handling      1.B.1.a      11   3    11    4




12 Coal mining and handling      1.B.1.a      11   4    11    4



12 Coal mining and handling      1.B.1.a

13 Solid fuel transformation     1.B.1.b      9    14   9    14
14 Other (please specify)                   1.B.1.c     2    10   2    10




14 Other (please specify)                   1.B.1.c     2    10   2    10

   Exploration production, transport of oil
15 and natural gas                          1.B.2.b     2    13   2    13
   Exploration production, transport of oil
15 and natural gas                          1.B.2.a.i   5    7    5     7



   Exploration production, transport of oil
15 and natural gas                          1.B.2.a.i   5    9    5     9

   Exploration production, transport of oil
15 and natural gas                          1.B.2.a.i   5    26   6    25

   Exploration production, transport of oil
15 and natural gas                          1.B.2.b     9    15   9    17


   Exploration production, transport of oil
15 and natural gas                          1.B.2.b     12   12   12   17




   Exploration production, transport of oil
15 and natural gas                          1.B.2.b     12   15   12   17

   Exploration production, transport of oil
15 and natural gas                          1.B.2.a.i   14   6    14    6

   Exploration production, transport of oil
15 and natural gas                          1.B.2.a.i   14   4    14    4



   Exploration production, transport of oil
15 and natural gas                          1.B.2.a.i   15   1    15    3
   Exploration production, transport of oil
15 and natural gas                          1.B.2.b        15   8    15    9




   Exploration production, transport of oil
15 and natural gas                          1.B.2.b        16   1    16    2


   Exploration production, transport of oil
15 and natural gas                            1.B.2.b      17   24   25   14
   Exploration production, transport of oil
15 and natural gas                            1.B.2.a.i    18   3    18   24
   Exploration production, transport of oil
15 and natural gas                            1.B.2.a.i    22   10   23   18
   Exploration production, transport of oil
15 and natural gas                            1.B.2.a.i    23   19   24    3

   Exploration production, transport of oil
15 and natural gas                            1.B.2.a.i    23   19   24    3
   Exploration production, transport of oil
15 and natural gas                            1.B.2.b      27        28
   Exploration production, transport of oil
15 and natural gas                            1.B.2.a.i
   Exploration production, transport of oil
15 and natural gas                            1.B.2.b


16 Refining / storage                         1.B.2.a.iv   2    8


16 Refining / storage                         1.B.2.a.iv   3    20




16 Refining / storage                         1.B.2.a.iv   13   6
16 Refining / storage                         1.B.2.a.iv   14   2    14    3


16 Refining / storage                         1.B.2.a.iv   14   2


16 Refining / storage                         1.B.2.a.iv   15   21   15   21
16 Refining / storage   1.B.2.a.iv   16   2

16 Refining / storage   1.B.2.a.iv   17   18   17   18




16 Refining / storage   1.B.2.a.iv   17   8    17   10




16 Refining / storage   1.B.2.a.iv   17   2




16 Refining / storage   1.B.2.a.iv   17   2




16 Refining / storage   1.B.2.a.iv   17   2




16 Refining / storage   1.B.2.a.iv   17   2



16 Refining / storage   1.B.2.a.iv   17   2

16 Refining / storage   1.B.2.a.iv   20   18

16 Refining / storage   1.B.2.a.iv   20   24

16 Refining / storage   1.B.2.a.iv   21   12
16 Refining / storage   1.B.2.a.iv   22    6
16 Refining / storage   1.B.2.a.iv   22    7
16 Refining / storage   1.B.2.a.iv   22   7


16 Refining / storage   1.B.2.a.iv   22   15
16 Refining / storage   1.B.2.a.iv   22   18
16 Refining / storage   1.B.2.a.iv   22   23




16 Refining / storage   1.B.2.a.iv   23   2    23   5
16 Refining / storage   1.B.2.a.iv   23   1




16 Refining / storage   1.B.2.a.iv   24


16 Refining / storage   1.B.2.a.iv   24

16 Refining / storage   1.B.2.a.iv   24




16 Refining / storage   1.B.2.a.iv   24
16 Refining / storage               1.B.2.a.iv   24
17 Distribution of oil products     1.B.2.a.v     1


17 Distribution of oil products     1.B.2.a.v    3    1



17 Distribution of oil products     1.B.2.a.v    4    27   4    27
17 Distribution of oil products     1.B.2.a.v    4    29
17 Distribution of oil products     1.B.2.a.v    4    33




17 Distribution of oil products     1.B.2.a.v    5    20

17 Distribution of oil products     1.B.2.a.v    7    10   7    10

17 Distribution of oil products     1.B.2.a.v    7     9
17 Distribution of oil products     1.B.2.a.v    7    27

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

17   Distribution of oil products   1.B.2.a.v    8    12
17   Distribution of oil products   1.B.2.a.v    8    18
17   Distribution of oil products   1.B.2.a.v    8    21
17   Distribution of oil products   1.B.2.a.v    8    30
17   Distribution of oil products   1.B.2.a.v    8    39
17   Distribution of oil products   1.B.2.a.v    9     2
17   Distribution of oil products   1.B.2.a.v    9    11
17   Distribution of oil products   1.B.2.a.v    9    32


17 Distribution of oil products     1.B.2.a.v    11    8   12   12
17 Distribution of oil products     1.B.2.a.v    11   17


17 Distribution of oil products     1.B.2.a.v    12   8
17 Distribution of oil products   1.B.2.a.v   13   21




17 Distribution of oil products   1.B.2.a.v   14   2




17 Distribution of oil products   1.B.2.a.v   14   5




17 Distribution of oil products   1.B.2.a.v   15   2




17 Distribution of oil products   1.B.2.a.v   15   5

17 Distribution of oil products   1.B.2.a.v   15   6

17 Distribution of oil products   1.B.2.a.v   16   5    18   11




17 Distribution of oil products   1.B.2.a.v   16   2


17 Distribution of oil products   1.B.2.a.v   16   10


17 Distribution of oil products   1.B.2.a.v   17   2


17 Distribution of oil products   1.B.2.a.v   17   4


17 Distribution of oil products   1.B.2.a.v   18   13   19    9

17 Distribution of oil products   1.B.2.a.v   18    5
17 Distribution of oil products   1.B.2.a.v   18   16
17 Distribution of oil products   1.B.2.a.v   18   21
17 Distribution of oil products   1.B.2.a.v   18   2
17 Distribution of oil products   1.B.2.a.v   19   2


17 Distribution of oil products   1.B.2.a.v   19   19


17 Distribution of oil products   1.B.2.a.v   20   6    20   10




17 Distribution of oil products   1.B.2.a.v   20   10   20   19




17 Distribution of oil products   1.B.2.a.v   20   5




17 Distribution of oil products   1.B.2.a.v   21    8   21    9
17 Distribution of oil products   1.B.2.a.v   21   19
17 Distribution of oil products   1.B.2.a.v   21   21

17 Distribution of oil products   1.B.2.a.v   21   30

17 Distribution of oil products   1.B.2.a.v   21    9
17 Distribution of oil products   1.B.2.a.v   22   12   22   19

17 Distribution of oil products   1.B.2.a.v   22   17

17 Distribution of oil products   1.B.2.a.v   22   25
17 Distribution of oil products   1.B.2.a.v    23   3


17 Distribution of oil products   1.B.2.a.v    23   3


17 Distribution of oil products   1.B.2.a.v    23   3




18 Geothermal energy extraction   1.B.2.a.vi   3    31   3   33




18 Geothermal energy extraction   1.B.2.a.vi   4     3   4    4
18 Geothermal energy extraction   1.B.2.a.vi   4    11   4   11


18 Geothermal energy extraction   1.B.2.a.vi   5    1    5    1




19 Venting and flaring            1.B.2.c      4    17   4   26



19 Venting and flaring            1.B.2.c      6    16   6   17



19 Venting and flaring            1.B.2.c      6    18   6   20
19 Venting and flaring   1.B.2.c   8    14   8    14




19 Venting and flaring   1.B.2.c   8    11   9     7
19 Venting and flaring   1.B.2.c   9     1   9     7



19 Venting and flaring   1.B.2.c   10   14   10   15

19 Venting and flaring   1.B.2.c   10   19   10   21



19 Venting and flaring   1.B.2.c   10   20



19 Venting and flaring   1.B.2.c   11    3
19 Venting and flaring   1.B.2.c   12   20   12   21



19 Venting and flaring   1.B.2.c
19 Venting and flaring   1.B.2.c

20 Cement production     2.A.1     1   1    1     1




20 Cement production     2.A.1     1        18



20 Cement production     2.A.1     1        18




20 Cement production     2.A.1     5   26   5    27



20 Cement production     2.A.1     5   14   5    25




20 Cement production     2.A.1     5   25   5    25




20 Cement production     2.A.1     5        6


20 Cement production     2.A.1     5   27   6     5




20 Cement production     2.A.1     9   5    9    10
20 Cement production   2.A.1   9    2    9     2

20 Cement production   2.A.1   9    20   12    3




20 Cement production   2.A.1   9         12




20 Cement production   2.A.1   9         12

20 Cement production   2.A.1   9    1

20 Cement production   2.A.1   9    1



20 Cement production   2.A.1   10   33   10   34

20 Cement production   2.A.1   10   16   10   16


20 Cement production   2.A.1   11   8    11    9




20 Cement production   2.A.1   11   10   11   12


20 Cement production   2.A.1   13        14
20 Cement production   2.A.1   16   13




20 Cement production   2.A.1   16   15

20 Cement production   2.A.1   17        17
20 Total industrial processes   2

20 Cement production            2.A.1




20 Cement production            2.A.1



20 Cement production            2.A.1


20 Cement production            2.A.1




20 Cement production            2.A.1




20 Cement production            2.A.1


21 Lime production              2.A.2   8   2    8    2




21 Lime production              2.A.2   8        8

21 Lime production              2.A.2   8   1


21 Lime production              2.A.2   9   20   13   3


22 Limestone and dolomite use   2.A.3   1        4
22 Limestone and dolomite use    2.A.3   2   21   2   22

22 Limestone and dolomite use    2.A.3   2   9

22 Limestone and dolomite use    2.A.3   3   15

22 Limestone and dolomite use    2.A.3   3   19

22 Limestone and dolomite use    2.A.3   3   22

22 Limestone and dolomite use    2.A.3   3   24



23 Soda ash production and use   2.A.4   1        6



23 Soda ash production and use   2.A.4   2   15   2   16

23 Soda ash production and use   2.A.4   2   25

23 Soda ash production and use   2.A.4   4   2    4    2

23 Soda ash production and use   2.A.4   4        4

23 Soda ash production and use   2.A.4   4   1    4    2
23 Soda ash production and use   2.A.4   5   2    5    9




23 Soda ash production and use   2.A.4   5   4    5    5


23 Soda ash production and use   2.A.4   5   7    5    7

24 Asphalt roofing               2.A.5   1   1    1    1


24 Asphalt roofing               2.A.5   2   5    2    6
24 Asphalt roofing            2.A.5   2    17


24 Asphalt roofing            2.A.5   3    11




24 Asphalt roofing            2.A.5   5    1


24 Asphalt roofing            2.A.5   6    12   6    12


24 Asphalt roofing            2.A.5   7    20   7    20


24 Asphalt roofing            2.A.5   8    4    8     4




24 Asphalt roofing            2.A.5   11   2    11    2

24 Asphalt roofing            2.A.5




25 Road paving with asphalt   2.A.6   1    1    19   19

25 Road paving with asphalt   2.A.6   4    2

25 Road paving with asphalt   2.A.6   7    15   8     3


25 Road paving with asphalt   2.A.6   13   3
   Quarrying and mining of minerals
26 other than coal                       2.A.7.a   1         5


27 Construction and demolition           2.A.7.b   3    11   4     4

27 Construction and demolition           2.A.7.b
   Storage, handling and transport of
28 mineral products                      2.A.7.c   3    24
   Storage, handling and transport of
28 mineral products                      2.A.7.c   4    15

   Storage, handling and transport of
28 mineral products                      2.A.7.c   6    16




   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   1         37

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   1    1    37    1

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   3    32   3    34

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   4    5    4     7


   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   5    22   5    22

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   7    38   7    41


   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   11        19
   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   12   31   12   34

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   14   21   14   22



   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   15   6    15    8

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   18   4    18    8

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   20   16

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   22   2    22    2




   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   22   2    30


   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   22        30




   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   24   2    24    2
   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   24        25



   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   24   2    30   2




   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   25        25

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   27        27

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   27        30



   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   27        30

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   27        30

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   31

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   35   19

   Other mineral products (Please
   specify the sources included/excluded
29 in the notes column to the right)     2.A.7.d   36        37
30 Chemical industry   2.B       2    9




30 Chemical industry   2.B       2    9




30 Chemical industry   2.B       2    9



30 Chemical industry   2.B       3

30 Chemical industry   2.B       3

30 Chemical industry   2.B.1     5    9    5     9

30 Chemical industry   2.B.2     6     1   6     1
30 Chemical industry   2.B.5.a   8    17   8    17
30 Chemical industry   2.B       9    33   9    34

30 Chemical industry   2.B.1     13   16   13   16




30 Chemical industry   2.B.1     13   16   13   17


30 Chemical industry   2.B.1     13   13   13   15

30 Chemical industry   2.B       13   5    13    5

30 Chemical industry   2.B       13   9    13    5


30 Chemical industry   2.B       13   7    13   11
30 Chemical industry   2.B.2     14   2    14    2



30 Chemical industry   2.B.3     14   9    14    9




30 Chemical industry   2.B.4     15   1    15    2




30 Chemical industry   2.B.5     15   14   15   15




30 Chemical industry   2.B.5.a   15   14        15


30 Chemical industry   2.B.1     17   25   17   25




30 Chemical industry   2.B.1     17   23   17   25



30 Chemical industry   2.B.1     17   23   17   25

30 Chemical industry   2.B.1     18   3    18    3

30 Chemical industry   2.B.2     18   7    18    9


30 Chemical industry   2.B.2     19   4    19    6
30 Chemical industry   2.B.2     21   1    21    3




30 Chemical industry   2.B.2     22   9    22   11

30 Chemical industry   2.B.3     22   12   23    2

30 Chemical industry   2.B.2     24   1    24    3




30 Chemical industry   2.B.5.a   24   7


30 Chemical industry   2.B.5.a   25   1    25    3



30 Chemical industry   2.B.5.a   26   4    26    6


30 Chemical industry   2.B.5.a   28   17   28   17




30 Chemical industry   2.B.5.a   28   3    28    3




30 Chemical industry   2.B.5.a   30   3    30    3

30 Chemical industry   2.B.5.a   30    1   31    3
30 Chemical industry   2.B.5.a   31   13   31   13
30 Chemical industry   2.B.5.a   31   6    31   9



30 Chemical industry   2.B.5.a   33   1    33   3




30 Chemical industry   2.B       35        35




30 Chemical industry   2.B.5.a   36   4    36   4
30 Chemical industry   2.B       37        37




30 Chemical industry   2.B       37   13


30 Chemical industry   2.B       38   9
30 Chemical industry   2.B       39   1    39   18

30 Chemical industry   2.B.5.a   39    1         3
30 Chemical industry   2.B.5.a   42   17   43    3




30 Chemical industry   2.B.5.a   42   16        17




30 Chemical industry   2.B       43   19   44   15




30 Chemical industry   2.B.5.a   43   2          3



30 Chemical industry   2.B.5.a   44   14        16
30 Chemical industry   2.B.5.a   45   1          3


30 Chemical industry   2.B.5.a   46   1          3
30 Chemical industry   2.B.5.a   48   3    48    9

30 Chemical industry   2.B.5.a   48   9    48    9




30 Chemical industry   2.B.5.a   48   4          6

30 Chemical industry   2.B.5.a   48   7          9




30 Chemical industry   2.B.5.a   48   1

30 Chemical industry   2.B.5.a   49   21        24

30 Chemical industry   2.B.5.a   50   6    50    6

30 Chemical industry   2.B.5.a   52   10   52   10


30 Chemical industry   2.B.5.a   52   7

30 Chemical industry   2.B.5.a   53   2    53    9


30 Chemical industry   2.B.5.a   53   1          3

30 Chemical industry   2.B.5.a   53

30 Chemical industry   2.B.5.a   53
30 Chemical industry   2.B.5.a   55   11   55   11



30 Chemical industry   2.B.5.a   57
30 Chemical industry   2.B       58        58




30 Chemical industry   2.B       58   6




30 Chemical industry   2.B       59    1   59   19
30 Chemical industry   2.B       61   23



30 Chemical industry   2.B.1     63   2    63    4


30 Chemical industry   2.B.1     63   6    63    8




30 Chemical industry   2.B.1     63   2

30 Chemical industry   2.B.5.a   64   19   64   21


30 Chemical industry   2.B.5.a   65   6    65    6



30 Chemical industry   2.B.5.a   65   4



30 Chemical industry   2.B.5.a   65   8

30 Chemical industry   2.B.5.a   66   22        23
30 Chemical industry           2.B.5.a   66   20        21




30 Chemical industry           2.B.5.a   67   3          4


30 Chemical industry           2.B.5.a   67   5          7


30 Chemical industry           2.B.5.a   69   1          2


30 Chemical industry           2.B                 16    7


30 Chemical industry           2.B.1


31 Iron and steel production   2.C.1     1         61


31 Iron and steel production   2.C.1     3    2

31 Iron and steel production   2.C.1     4    20

31 Iron and steel production   2.C.1     5    21

31 Iron and steel production   2.C.1     6    23

31 Iron and steel production   2.C.1     11   9

31 Iron and steel production   2.C.1     11   31

31 Iron and steel production   2.C.1     11   36
31 Iron and steel production   2.C.1     12   17


31 Iron and steel production   2.C.1     13   4
31 Iron and steel production   2.C.1   13   1

31 Iron and steel production   2.C.1   14   11   15    9

31 Iron and steel production   2.C.1   16   40   17   20

31 Iron and steel production   2.C.1   18   9
31 Iron and steel production   2.C.1   21   6




31 Iron and steel production   2.C.1   22   18   22   18

31 Iron and steel production   2.C.1   22        22

31 Iron and steel production   2.C.1   22


31 Iron and steel production   2.C.1   25   11   25   11


31 Iron and steel production   2.C.1   25   11   25   11




31 Iron and steel production   2.C.1   25        27

31 Iron and steel production   2.C.1   25   9    27    6



31 Iron and steel production   2.C.1   25   9    27    6


31 Iron and steel production   2.C.1   26   3    26    3


31 Iron and steel production   2.C.1   26   3    26    3


31 Iron and steel production   2.C.1   26   7    26    7


31 Iron and steel production   2.C.1   26   7    26    7
31 Iron and steel production   2.C.1   26        27


31 Iron and steel production   2.C.1   27   3    27    3


31 Iron and steel production   2.C.1   27   6    27    6


31 Iron and steel production   2.C.1   27   6    27    6


31 Iron and steel production   2.C.1   27   3    27    3

31 Iron and steel production   2.C.1   27   8    30    3


31 Iron and steel production   2.C.1   28   13   28   13



31 Iron and steel production   2.C.1   28        28

31 Iron and steel production   2.C.1   28        28
31 Iron and steel production   2.C.1   28   12   28   13




31 Iron and steel production   2.C.1   28        30




31 Iron and steel production   2.C.1   31        32
31 Iron and steel production   2.C.1   33       33


31 Iron and steel production   2.C.1   33       33




31 Iron and steel production   2.C.1   34   5   34   5

31 Iron and steel production   2.C.1   34       34




31 Iron and steel production   2.C.1   34       34




31 Iron and steel production   2.C.1   35   3   35   3

31 Iron and steel production   2.C.1   35       35



31 Iron and steel production   2.C.1   36       36



31 Iron and steel production   2.C.1   36       36

31 Iron and steel production   2.C.1   36       38




31 Iron and steel production   2.C.1   37       38
31 Iron and steel production   2.C.1   37        38

31 Iron and steel production   2.C.1   42   28   55    4

31 Iron and steel production   2.C.1   55   5    56   16




31 Iron and steel production   2.C.1



31 Iron and steel production   2.C.1



32 Ferroalloys production      2.C.2   1         6




32 Ferroalloys production      2.C.2   4    23   4    23



32 Ferroalloys production      2.C.2   4    22   4    23

33 Aluminium production        2.C.3   2         2


33 Aluminium production        2.C.3   10        10



33 Aluminium production        2.C.3   10   1    10    2



33 Aluminium production        2.C.3   10   2    13    5
33 Aluminium production   2.C.3     10       13


33 Aluminium production   2.C.3     10       13


33 Aluminium production   2.C.3     12   3   12   4




33 Aluminium production   2.C.3     12   3   12   4



33 Aluminium production   2.C.3     12   3   12   4



33 Aluminium production   2.C.3     12       14



33 Aluminium production   2.C.3     13   3   13   4




33 Aluminium production   2.C.3     13   3   13   4


33 Aluminium production   2.C.3     14       14

33 Aluminium production   2.C.3     14



33 Aluminium production   2.C.3     20   1   20   3




34 Copper production      2.C.5.a   1        16




34 Copper production      2.C.5.a   2        2
34 Copper production   2.C.5.a   2    3    2     4




34 Copper production   2.C.5.a   4         5



34 Copper production   2.C.5.a   7         7




34 Copper production   2.C.5.a   7         7



34 Copper production   2.C.5.a   7    14   7    15



34 Copper production   2.C.5.a   7    15   9     2




34 Copper production   2.C.5.a   8         10



34 Copper production   2.C.5.a   9         9

34 Copper production   2.C.5.a   9    1    9     2


34 Copper production   2.C.5.a   10        10


34 Copper production   2.C.5.a   10   1    10    2


34 Copper production   2.C.5.a

34 Copper production   2.C.5.a
34 Copper production   2.C.5.a
34 Copper production   2.C.5.a


34 Copper production   2.C.5.a


34 Copper production   2.C.5.a


34 Copper production   2.C.5.a


34 Copper production   2.C.5.a


34 Copper production   2.C.5.a




34 Copper production   2.C.5.a



34 Copper production   2.C.5.a

34 Copper production   2.C.5.a



34 Copper production   2.C.5.a

34 Copper production   2.C.5.a



35 Lead production     2.C.5.b   1   21




35 Lead production     2.C.5.b   1   21


35 Lead production     2.C.5.b   6   6
35 Lead production   2.C.5.b   6    3   16   4

35 Lead production   2.C.5.b   8        8




35 Lead production   2.C.5.b   8        16




35 Lead production   2.C.5.b   8        16



35 Lead production   2.C.5.b   9        9




35 Lead production   2.C.5.b   11       11




35 Lead production   2.C.5.b   12       12




35 Lead production   2.C.5.b   13       13




35 Lead production   2.C.5.b   14       14




35 Lead production   2.C.5.b   14       16
35 Lead production     2.C.5.b   15        15



36 Nickel production   2.C.5.c   1         8


36 Nickel production   2.C.5.c   2         2




36 Nickel production   2.C.5.c   2    6    2     8



36 Nickel production   2.C.5.c   4    13   4    13




36 Nickel production   2.C.5.c   4         4




36 Nickel production   2.C.5.c   4    8    4     9

36 Nickel production   2.C.5.c   8         8




37 Zinc production     2.C.5.d   1         20



37 Zinc production     2.C.5.d   2         2
37 Zinc production   2.C.5.d   2    10   2    11


37 Zinc production   2.C.5.d   2    12   2    12

37 Zinc production   2.C.5.d   5         5




37 Zinc production   2.C.5.d   7         7

37 Zinc production   2.C.5.d   7    7    7     8




37 Zinc production   2.C.5.d   8    33   8    34



37 Zinc production   2.C.5.d   9    2    9     2



37 Zinc production   2.C.5.d   9         12




37 Zinc production   2.C.5.d   9         15



37 Zinc production   2.C.5.d   10        10



37 Zinc production   2.C.5.d   10   3    10    4



37 Zinc production   2.C.5.d   11        11



37 Zinc production   2.C.5.d   11   3    11    4
37 Zinc production   2.C.5.d   12        12



37 Zinc production   2.C.5.d   12   3    12    4



37 Zinc production   2.C.5.d   13        13



37 Zinc production   2.C.5.d   13   3    13    4



37 Zinc production   2.C.5.d   14   3    14    4



37 Zinc production   2.C.5.d   15   3    15    4



37 Zinc production   2.C.5.d   16        16

37 Zinc production   2.C.5.d   16   1    16    2




37 Zinc production   2.C.5.d   18   17   18   18




37 Zinc production   2.C.5.d


37 Zinc production   2.C.5.d



37 Zinc production   2.C.5.d
37 Zinc production                       2.C.5.d


37 Zinc production                       2.C.5.d



   Other metal production (Please
   specify the sources included/excluded
38 in the notes column to the right)     2.C.5.e   1         8

   Other metal production (Please
   specify the sources included/excluded
38 in the notes column to the right)     2.C.5.e   4         4

   Other metal production (Please
   specify the sources included/excluded
38 in the notes column to the right)     2.C.5.e   7         7
   Storage, handling and transport of
   metal products (Please specify the
   sources included/excluded in the
39 notes column to the right)            2.C.5.f   2    9    2    9

40 Pulp and paper                        2.D.1     2    15

40 Pulp and paper                        2.D.1     2    7


40   Pulp and paper                      2.D.1      5   16
40   Pulp and paper                      2.D.1      7   37
40   Pulp and paper                      2.D.1     13    7
40   Pulp and paper                      2.D.1     13    7

40 Pulp and paper                        2.D.1     16   2    16   2

40 Pulp and paper                        2.D.1     16   2

40 Pulp and paper                        2.D.1     17   3    17   3

40 Pulp and paper                        2.D.1     17   1

40 Pulp and paper                        2.D.1     18   3    18   3




40 Pulp and paper                        2.D.1

41 Food and drink                        2.D.2     11   2    12   2
41 Food and drink                2.D.2   11        24

41 Food and drink                2.D.2   16   7    16    7

41 Food and drink                2.D.2   17   3    17    4

41 Food and drink                2.D.2   17   5    17    7
41 Food and drink                2.D.2   18   4    18    4

41 Food and drink                2.D.2   22        24




43 Production of POPs            2.E     1         3



43 Production of POPs            2.E     1    1    3    16
43 Production of POPs            2.E     3         3


43 Production of POPs            2.E
43 Production of POPs            2.E




44 Consumption of POPs and HMs   2.F     1         1



44 Consumption of POPs and HMs   2.F     6         6




46 Paint application             3.A     3    9    3    14

46 Paint application             3.A     3    14   3    15

46 Paint application             3.A     3    28   3    28
46 Paint application     3.A   8    7    9    14


46 Paint application     3.A   9    14   9    14




46 Paint application     3.A   10   25   10   26


46   Paint application   3.A   10   25   10   26
46   Paint application   3.A   10   26   10   26
46   Paint application   3.A   11    1   11    2
46   Paint application   3.A   11    1   11    2
46   Paint application   3.A   11    1   11    2
46   Paint application   3.A   11    1   11    2
46   Paint application   3.A   11    1   11    2
46   Paint application   3.A   11    1   11    2
46   Paint application   3.A   11    1   11    2
46   Paint application   3.A   11    1   11    2
46   Paint application   3.A   11    1   11    2
46   Paint application   3.A   11    1   11    2


46 Paint application     3.A   11   1    11    2


46 Paint application     3.A   11   1

46 Paint application     3.A   12   31   12   37




46 Paint application     3.A   12   26   12   30
46 Paint application   3.A   12   20   12   25


46 Paint application   3.A   12   15   12   19


46 Paint application   3.A   12   15   12   19




46 Paint application   3.A   12   16

46 Paint application   3.A   13   12   13   15




46 Paint application   3.A   15   5    16    5




46 Paint application   3.A   16   22   16   23
46 Paint application   3.A   16   6    16   23


46 Paint application   3.A   16   22   17    4

46 Paint application   3.A   16   17
46 Paint application   3.A   16   22


46 Paint application   3.A   17   3    17    7



46 Paint application   3.A   17   16   18   32

46 Paint application   3.A   17   1




46 Paint application   3.A   19   6    19   15



46 Paint application   3.A   19   19   19   19



46 Paint application   3.A   20   3    20    3
46 Paint application   3.A   21   6    21    6




46 Paint application   3.A   22   3    22    3


46 Paint application   3.A   24   6    24    6




46 Paint application   3.A   25   7    31    7


46 Paint application   3.A   28   3    28    3

46 Paint application   3.A   31   16




46 Paint application   3.A   32   21   32   30



46 Paint application   3.A   32   21   32   30



46 Paint application   3.A   34   17   34   34
46 Paint application   3.A   34   17   34   34


46 Paint application   3.A   34   1    34    7


46 Paint application   3.A   34   8    34   16




46 Paint application   3

46 Paint application   3




46 Paint application   3



46 Paint application   3




46 Paint application   3.A


46 Paint application   3.A
46 Paint application                    3.A




46 Paint application                    3.A



47 Degreasing                           3.B.1   7   8




47 Degreasing                           3.B

47 Degreasing                           3.B.1


47 Degreasing                           3.B.1



48 Dry cleaning                         3.B.2   8   17   8   209



48 Dry cleaning                         3.B.2
   Chemical products, manufacture and
49 processing                           3.C     1        1
   Chemical products, manufacture and
49 processing                           3.C   3   2    3    5




   Chemical products, manufacture and
49 processing                           3.C   3   33   3   33

   Chemical products, manufacture and
49 processing                           3.C   4   21   4   22




   Chemical products, manufacture and
49 processing                           3.C   5   26
   Chemical products, manufacture and
49 processing                           3.C   5   27       37
   Chemical products, manufacture and
49 processing                           3.C   7   22   8   10
   Chemical products, manufacture and
49 processing                           3.C   7   3

   Chemical products, manufacture and
49 processing                           3.C   7   3




   Chemical products, manufacture and
49 processing                           3.C   8   26   8   33



   Chemical products, manufacture and
49 processing                           3.C   8   26   8   33
   Chemical products, manufacture and
49 processing                           3.C   8    22   8    25

   Chemical products, manufacture and
49 processing                           3.C   11   11




   Chemical products, manufacture and
49 processing                           3.C   12   22   12   25
   Chemical products, manufacture and
49 processing                           3.C   13   13
   Chemical products, manufacture and
49 processing                           3.C   13   15
   Chemical products, manufacture and
49 processing                           3.C   13   2          9
   Chemical products, manufacture and
49 processing                           3.C   14   10   14   11
   Chemical products, manufacture and
49 processing                           3.C   14   11   14   11




   Chemical products, manufacture and
49 processing                           3.C   14   2    14    4




   Chemical products, manufacture and
49 processing                           3.C   14   13   17    4




   Chemical products, manufacture and
49 processing                           3.C   14   11


   Chemical products, manufacture and
49 processing                           3.C   15   24
   Chemical products, manufacture and
49 processing                           3.C   17   12


   Chemical products, manufacture and
49 processing                           3.C   18   1    18   3




   Chemical products, manufacture and
49 processing                           3.C   18   11   19   6
   Chemical products, manufacture and
49 processing                           3.C   20   5
   Chemical products, manufacture and
49 processing                           3.C
   Chemical products, manufacture and
49 processing                           3.C
   Chemical products, manufacture and
49 processing                           3.C

   Chemical products, manufacture and
49 processing                           3.C

   Chemical products, manufacture and
49 processing                           3.C
   Chemical products, manufacture and
49 processing                           3.C




   Chemical products, manufacture and
49 processing                           3.C
   Chemical products, manufacture and
49 processing                           3.C
   Chemical products, manufacture and
49 processing                           3.C

   Chemical products, manufacture and
49 processing                           3.C
50 Printing                         3.D.1   5    22   6    26

50 Printing                         3.D.1   7    10




50 Printing                         3.D.1   9    7    9    17


50 Printing                         3.D.1   14   6    14    7

50 Printing                         3.D.1   18   23




50 Printing                         3.D.1




50 Printing                         3.D.1


50 Printing                         3.D.1


   Domestic solvent use including
51 fungicides                       3.D.2   5    1    5     2

   Domestic solvent use including
51 fungicides                       3.D.2   5


   Domestic solvent use including
51 fungicides                       3.D.2   6    3    6     3
   Domestic solvent use including
51 fungicides                       3.D.2   6    6    7     6
   Domestic solvent use including
51 fungicides                       3.D.2   7    12   7    13



   Domestic solvent use including
51 fungicides                       3.D.2   17   17   17   22




   Domestic solvent use including
51 fungicides                       3.D.2

52 Other product use                3.D.3   4    22   4    22


52 Other product use                3.D.3   5    39   5    41

52 Other product use                3.D.3   10   18




52 Other product use                3.D.3   11   1    11    9



52 Other product use                3.D.3   17   1    17    3

52 Other product use                3.D.3   18   1    18    2

52 Other product use                3.D.3
53 Manure management                4.B     1    1    2     2



53 Manure management                4.B     1    1    2     2


53 Manure management                4.B     1         42
53 Manure management   4.B   1        59



53 Manure management   4.B   3   4    3     4




53 Manure management   4.B   3   6    3     6
53 Manure management   4.B   3   1    3    14

53 Manure management   4.B   3   1    3    14


53 Manure management   4.B   3   4    3     5




53 Manure management   4.B   3   10   3    12




53 Manure management   4.B   3   21   3    29

53 Manure management   4.B   3   28   3    28


53 Manure management   4.B   3   2    3     9

53 Manure management   4.B   3   13   3    14


53 Manure management   4.B   3   22   3    24
53 Manure management   4.B   3   11   3    11

53 Manure management   4.B   3   17   3    18


53 Manure management   4.B   3   11   3    11

53 Manure management   4.B   3   19   3    20
53 Manure management   4.B   3   30   3   32

53 Manure management   4.B   3   15   4    9




53 Manure management   4.B   3   15   4    9
53 Manure management   4.B   3   18




53 Manure management   4.B   3   29

53 Manure management   4.B   3   27
53 Manure management   4.B   3   27

53 Manure management   4.B   4   15   4   15

53 Manure management   4.B   4   1    4    6




53 Manure management   4.B   4   1    4    5

53 Manure management   4.B   4   23   4   24

53 Manure management   4.B   4   11   7    2

53 Manure management   4.B   4   11   7    2

53 Manure management   4.B   4   9


53 Manure management   4.B   4   7

53 Manure management   4.B   4   20

53 Manure management   4.B   4   24

53 Manure management   4.B   4   1
53 Manure management   4.B   4   15

53 Manure management   4.B   5   11   5   26

53 Manure management   4.B   5   1


53 Manure management   4.B   5   22



53 Manure management   4.B   5   26

53 Manure management   4.B   5   20
53 Manure management   4.B   6        7
53 Manure management   4.B   6   13




53 Manure management   4.B   6   2


53 Manure management   4.B   6    2
53 Manure management   4.B   6   13

53 Manure management   4.B   6   13



53 Manure management   4.B   7    5   7    5
53 Manure management   4.B   7   27   7   28

53 Manure management   4.B   7   4    7   32

53 Manure management   4.B   7   4    7   32

53 Manure management   4.B   7   26   7   32




53 Manure management   4.B   7   28   7   30
53 Manure management   4.B   7    2   7    2

53 Manure management   4.B   7   1    7    1


53 Manure management   4.B   7   33   8    2
53 Manure management   4.B   7   1


53 Manure management   4.B   7   1




53 Manure management   4.B   7   35

53 Manure management   4.B   7   1


53 Manure management   4.B   7   6

53 Manure management   4.B   7   28

53 Manure management   4.B   7   4


53 Manure management   4.B   8   10   8   10

53 Manure management   4.B   8   34   8   34



53 Manure management   4.B   8   14   8   16

53 Manure management   4.B   8   17   8   21




53 Manure management   4.B   8   22   8   31
53 Manure management   4.B   8   32   8   32

53 Manure management   4.B   8    2
53 Manure management   4.B   8   13

53 Manure management   4.B   8   27
53 Manure management     4.B   9    3    9     4

53 Manure management     4.B   9    1          4


53   Manure management   4.B   10   1    10    2
53   Manure management   4.B   10   3    10    3
53   Manure management   4.B   10   3    10    3
53   Manure management   4.B   10   3    10    3


53 Manure management     4.B   11   22   11   22




53 Manure management     4.B   11   26   11   26

53 Manure management     4.B   11   18   11   32

53 Manure management     4.B   11   18   11   32



53 Manure management     4.B   11   28   11   28




53 Manure management     4.B   11   3    11    5

53 Manure management     4.B   11   26   11   26




53 Manure management     4.B   11   19   18   12

53 Manure management     4.B   11   32
53 Manure management   4.B   11   17




53 Manure management   4.B   11   26

53 Manure management   4.B   11   15


53 Manure management   4.B   12   5    12   7

53 Manure management   4.B   12   4    12   4



53 Manure management   4.B   12   4    12   4
53 Manure management   4.B   12   2    12   3




53 Manure management   4.B   12   5    15   5


53 Manure management   4.B   12   5    16   5


53 Manure management   4.B   12   5    16   6


53 Manure management   4.B   12   5    16   6
53 Manure management   4.B   12   5   16   6


53 Manure management   4.B   12   6   16   6


53 Manure management   4.B   12   5   16   6

53 Manure management   4.B   12   5   17   2




53 Manure management   4.B   12   2   17   2

53 Manure management   4.B   12       17




53 Manure management   4.B   12   5   17   1

53 Manure management   4.B   12   5   17   1

53 Manure management   4.B   12   5   17   1

53 Manure management   4.B   12   5   17   2




53 Manure management   4.B   12   5   17   1



53 Manure management   4.B   12   2   17   2



53 Manure management   4.B   12   5   17   2
53 Manure management   4.B      12       17


53 Manure management   4.B      12   5   17   1


53 Manure management   4.B      12   2   17   2

53 Manure management   4.B      12   5   17   2




53 Poultry             4.B.09   12   5   31   2



53 Manure management   4.B      12   5


53 Manure management   4.B      12   5
53 Manure management   4.B      13   1   13   3

53 Manure management   4.B      14   7   15   1
53 Manure management   4.B   14   7    16    1

53 Manure management   4.B   15   3    15    5

53 Manure management   4.B   15   3    15    5




53 Manure management   4.B   16   1    16    1

53 Manure management   4.B   16    1
53 Manure management   4.B   17   16   17   16


53 Manure management   4.B   17   16   17   16
53 Manure management   4.B   17   18   17   18

53 Manure management   4.B   17   16   17   16
53 Manure management   4.B   17   6    17    6

53 Manure management   4.B   17   7    17   10




53 Manure management   4.B   17   6    17    6

53 Manure management   4.B   17   7    17   16



53 Manure management   4.B   17   3    18   12




53 Manure management   4.B   17   19


53 Manure management   4.B   17   3
53 Manure management   4.B   17   9

53 Manure management   4.B   17   5

53 Manure management   4.B   17   11
53 Manure management   4.B   17   14
53 Manure management   4.B   17    4
53 Manure management   4.B   18    1   18    1

53 Manure management   4.B   18    4   18    4
53 Manure management   4.B   18   27   18   28




53 Manure management   4.B   18   14   18   32




53 Manure management   4.B   18   10   18   11


53 Manure management   4.B   18   8    18   11




53 Manure management   4.B   18   14   18   17


53 Manure management   4.B   18   8    18   11



53 Manure management   4.B   18   3    18   11


53 Manure management   4.B   18   16   18   16


53 Manure management   4.B   18   24   18   25


53 Manure management   4.B   18   8    18   11

53 Manure management   4.B   18   23   18   23
53 Manure management   4.B   18   8    18    8

53 Manure management   4.B   18   36   19    2


53 Manure management   4.B   18   14   24   11


53 Manure management   4.B   18   14   24   11

53 Manure management   4.B   18   3


53 Manure management   4.B   18   34

53 Manure management   4.B   18   16

53 Manure management   4.B   19   1    19    1

53 Manure management   4.B   19    1
53 Manure management   4.B   19   35

53 Manure management   4.B   20   8    20    9



53 Manure management   4.B   20   10   20   10
53 Manure management   4.B   20   15   20   15


53 Manure management   4.B   20   8    20    9

53 Manure management   4.B   20   21   20   22


53 Manure management   4.B   20        23

53 Manure management   4.B   20   18

53 Manure management   4.B   20   8

53 Manure management   4.B   21   7    21    7




53 Manure management   4.B   21   4    21    4
53 Manure management   4.B   21   10   21   10
53 Manure management   4.B   21    9   21    9


53 Manure management   4.B   21   13   21   13

53 Manure management   4.B   21   7    21    7

53 Manure management   4.B   21   11   21   30



53 Manure management   4.B   21   5    21   17

53 Manure management   4.B   21   5




53 Manure management   4.B   21   31
53 Manure management   4.B   22   16   11   16




53 Manure management   4.B   22   16   22   17
53 Manure management   4.B   22    6   22    7
53 Manure management   4.B   22    9   22    9

53 Manure management   4.B   22   22   22   22



53 Manure management   4.B   22   31



53 Manure management   4.B   22   22

53 Manure management   4.B   22   22

53 Manure management   4.B   22    3
53 Manure management   4.B   22    9
53 Manure management   4.B   22   16

53 Manure management   4.B   22   12
53 Manure management   4.B   23   33   23   34
53 Manure management   4.B   23   26

53 Manure management   4.B   23   17

53 Manure management   4.B   24   4    24    5

53 Manure management   4.B   24   4    24    4

53 Manure management   4.B   24   4    24   11

53 Manure management   4.B   24   8    24    9
53 Manure management   4.B   24   7    24    7


53 Manure management   4.B   24   16   25    4




53 Manure management   4.B   24   13   31   10

53 Manure management   4.B   24        31




53 Manure management   4.B   24   16   31    2




53 Manure management   4.B   24   16   31    2




53 Manure management   4.B   24   12   31    2


53 Manure management   4.B   24   12   31   10
53 Manure management   4.B      24   16   31   2


53 Manure management   4.B      24   16   31   2


53 Manure management   4.B      24   10


53 Manure management   4.B      24   16


53 Manure management   4.B      24   16
53 Manure management   4.B      24    7
53 Manure management   4.B      25    2   26   2


53 Manure management   4.B      26   3    26   3

53 Manure management   4.B      27   1

53 Manure management   4.B      27   3
53 Manure management   4.B      29   1    29   5


53 Manure management   4.B      30   2    30   2


53 Manure management   4.B      30   3    30   5


53 Manure management   4.B      30   5    30   6

53 Poultry             4.B.09   30   5    30   5




53 Poultry             4.B.09   30   1    30   1
53 Manure management   4.B   30   1

53 Manure management   4.B   30   5



53 Manure management   4.B   31   11   31   11
53 Manure management   4.B   31   17   31   17




53 Manure management   4.B   31   3    31    3

53 Manure management   4.B   31   11   31   23



53 Manure management   4.B   31   11   31   11




53 Manure management   4.B   31   25   31   27



53 Manure management   4.B   31   23   31   23

53 Manure management   4.B   31   17   31   17


53 Manure management   4.B   31   12   31   22


53 Manure management   4.B   31   23   31   28


53 Manure management   4.B   31   25   31   27


53 Manure management   4.B   31   25   31   27

53 Manure management   4.B   31   11   31   22
53 Manure management   4.B   31   12   31   22


53 Manure management   4.B   31   12   31   22
53 Manure management   4.B   31   23   31   28

53 Manure management   4.B   31    5   31    6
53 Manure management   4.B   31   12   31   18


53 Manure management   4.B   31   11        18



53 Manure management   4.B   31   24

53 Manure management   4.B   31   27

53 Manure management   4.B   31   25


53 Manure management   4.B   32    2   32    3
53 Manure management   4.B   32   25   32   28



53 Manure management   4.B   32   19   32   19



53 Manure management   4.B   32   26   32   27



53 Manure management   4.B   33   29


53 Manure management   4.B   33   29




53 Manure management   4.B   34   10   34   11

53 Manure management   4.B   34   23
53 Manure management   4.B   35   14




53 Manure management   4.B   36   16   36   18
53 Manure management   4.B   36   16   36   21



53 Manure management   4.B   36   19   36   21

53 Manure management   4.B   36   36   39



53 Manure management   4.B   39
53 Manure management   4.B   40   2    40    2




53 Manure management   4.B   40   21   42   10

53 Manure management   4.B   40   1    42   10



53 Manure management   4.B   40   2    45   14


53 Manure management   4.B   40        57




53 Manure management   4.B   40   1    57    1


53 Manure management   4.B   40   1    59    1

53 Manure management   4.B   41   15   42   10


53 Manure management   4.B   41   9    59    1

53 Manure management   4.B   41   9    59    1

53 Manure management   4.B   41   28

53 Manure management   4.B   42   26   42   28



53 Manure management   4.B   43   12   44    6
53 Manure management   4.B   43   12




53 Manure management   4.B   44   38   45   13




53 Manure management   4.B   44   37   45    2


53 Manure management   4.B   45   17   45   22
53 Manure management   4.B   46    7   46    7

53 Manure management   4.B   46   3

53 Manure management   4.B   46   9

53 Manure management   4.B   47   8
53 Manure management   4.B   47   8

53 Manure management   4.B   48   2    48    2

53 Manure management   4.B   48   2    48    4

53 Manure management   4.B   48   3    48    4

53 Manure management   4.B   48   2    50    2
53 Manure management   4.B   48   2   50   2

53 Manure management   4.B   48   3   50   2




53 Manure management   4.B   48   2
53 Manure management   4.B   48   3

53 Manure management   4.B   48   2
53 Manure management   4.B   51   13   53    2


53 Manure management   4.B   51   13




53 Manure management   4.B   52   18   52   19



53 Manure management   4.B   52   18

53 Manure management   4.B   52   8


53 Manure management   4.B   53   1




53 Manure management   4.B   53   1


53 Manure management   4.B   53   1

53 Manure management   4.B   53

53 Manure management   4.B   54   7    57    1
53 Manure management   4.B   55   1   55   1



53 Manure management   4.B   57   1

53 Manure management   4.B



53 Manure management   4.B




53 Manure management   4.B



53 Manure management   4.B




53 Manure management   4.B




53 Manure management   4.B



53 Manure management   4.B


53 Manure management   4.B
53 Manure management   4.B


53 Manure management   4.B




53 Dairy cattle        4.B.01.a




53 Non-dairy cattle    4.B.01.b




53 Sheep               4.B.03




53 Goats               4.B.04




53 Horses              4.B.06




53 Swine               4.B.08



53 Poultry             4.B.09



53 Laying hens         4.B.09.a




53 Broilers            4.B.09.b
53 Turkeys              4.B.09.c

54 Agricultural soils   4.D        1   1     1    1
54 Agricultural soils   4.D.1      1        18


54 Agricultural soils   4.D        1        23




54 Agricultural soils   4.D        2   10   2    13




54 Agricultural soils   4.D        2    9   2    12
54 Agricultural soils   4.D        2   17   2    19

54 Agricultural soils   4.D.1      2   12   2    13



54 Agricultural soils   4.D.1      2   17   2    20

54 Agricultural soils   4.D        2
54 Agricultural soils   4.D        2   32

54 Agricultural soils   4.D.1      2   4

54 Agricultural soils   4.D.1      2   35




54 Agricultural soils   4.D        3   2    3     2

54 Agricultural soils   4.D        3   15   3    15
54 Agricultural soils   4.D        3    1   3     1

54 Agricultural soils   4.D        3   8    3    15


54 Agricultural soils   4.D.1      3   7    3    15
54 Agricultural soils     4.D     3   16   4   21


54   Agricultural soils   4.D.1   3    6   5   12
54   Agricultural soils   4.D     3    4   6    6
54   Agricultural soils   4.D     4   14   4   14
54   Agricultural soils   4.D     4    6   4    6

54 Agricultural soils     4.D     4   1    4    1

54 Agricultural soils     4.D     4   19   4   19

54 Agricultural soils     4.D     4   14   4   14

54 Agricultural soils     4.D.1   4   13   4   14




54 Agricultural soils     4.D.1   4   15   4   21




54 Agricultural soils     4.D     4   12
54 Agricultural soils     4.D     4
54 Agricultural soils     4.D.1   4   34
54 Agricultural soils   4.D.1   4   10       14




54 Agricultural soils   4.D     6   10   6   10

54 Agricultural soils   4.D     6   8    6    8


54 Agricultural soils   4.D     6   9    6   17

54 Agricultural soils   4.D     6   10   6   10
54 Agricultural soils   4.D     6   10   6   10



54 Agricultural soils   4.D     6   20   6   20



54 Agricultural soils   4.D.1   6   14   6   16
54 Agricultural soils   4.D.1   6   14   6   14


54 Agricultural soils   4.D.1   6   14   6   14


54 Agricultural soils   4.D.1   6   13   6   13




54 Agricultural soils   4.D.1   6   14   6   14
54 Agricultural soils   4.D.1   6   14   6   14




54 Agricultural soils   4.D.1   6   14   6   14




54 Agricultural soils   4.D.1   6   14   6   14




54 Agricultural soils   4.D.1   6   10   7   14
54 Agricultural soils   4.D.1   6   19   7    8
54 Agricultural soils   4.D.1   6        13




54 Agricultural soils   4.D.1   6   9    13    8

54 Agricultural soils   4.D     6   14   14    6




54 Agricultural soils   4.D     6   14


54 Agricultural soils   4.D     6   14

54 Agricultural soils   4.D     6   10        14




54 Agricultural soils   4.D.1   6   14
54 Agricultural soils   4.D.1   6   14

54 Agricultural soils   4.D     7   2    7     2


54 Agricultural soils   4.D     7   11   7    11
54 Agricultural soils   4.D     7    8    7     8




54 Agricultural soils   4.D     7    13   14    7




54 Agricultural soils   4.D.1   7    13   14    7

54 Agricultural soils   4.D.1   7         23



54 Agricultural soils   4.D     14   9    14   15

54 Agricultural soils   4.D.1   14   14   14   15
54 Agricultural soils   4.D     14

54 Agricultural soils   4.D     14

54 Agricultural soils   4.D     16   21   16   21



54 Agricultural soils   4.D     17   5    17    6


54 Agricultural soils   4.D     17   25   17   27
54 Agricultural soils   4.D     17   27   17   27



54 Agricultural soils   4.D.1   17   18   17   21




54 Agricultural soils   4.D.1   17   36   17   37

54 Agricultural soils   4.D     18   28   18   28



54 Agricultural soils   4.D.1   18   9    18    9
54 Agricultural soils                     4.D.1   18   31   23



54 Agricultural soils                     4.D.1   18        23



54 Agricultural soils                     4.D.1   21        21


54 Agricultural soils                     4.D


54 Agricultural soils                     4.D.1




54 Agricultural soils                     4.D.1

54 Agricultural soils                     4.D.1


54 Agricultural soils                     4.D.2
54 Agricultural soils                     4.D.2


54 Agricultural soils                     4.D.2
55 Field burning of agricultural wastes   4.F     2         12




55 Field burning of agricultural wastes   4.F     2    2         12
55 Field burning of agricultural wastes   4.F   3   15

55 Field burning of agricultural wastes   4.F   4   13   4   15


55 Field burning of agricultural wastes   4.F   4   1    4    1

55 Field burning of agricultural wastes   4.F   4   15




55 Field burning of agricultural wastes   4.F   4   1




55 Field burning of agricultural wastes   4.F   4   1


55 Field burning of agricultural wastes   4.F   4   7

55 Field burning of agricultural wastes   4.F   5   16   8    4


55 Field burning of agricultural wastes   4.F   5   6




55 Field burning of agricultural wastes   4.F   5   8




55 Field burning of agricultural wastes   4.F   5    4
55 Field burning of agricultural wastes   4.F   5   14
55 Field burning of agricultural wastes   4.F   5   10

55 Field burning of agricultural wastes   4.F   6        8
55 Field burning of agricultural wastes   4.F   6   1


55 Field burning of agricultural wastes   4.F   6   1

55 Field burning of agricultural wastes   4.F   6   1




55 Field burning of agricultural wastes   4.F   9   12


55 Field burning of agricultural wastes   4.F



55 Field burning of agricultural wastes   4.F
56 Agriculture other                      4.G   1   1    1   1




56 Agriculture other                      4.G   2   6    2   7




56 Agriculture other                      4.G
56 Agriculture other              4.G


57 Solid waste disposal on land   6.A   1        4
57 Solid waste disposal on land   6.A   1


57 Solid waste disposal on land   6.A   2    4   2    4
57 Solid waste disposal on land   6.A   2   14   2   14


57 Solid waste disposal on land   6.A   2   14   2   14
57 Solid waste disposal on land   6.A   2    3   2    3
57 Solid waste disposal on land   6.A   2    4   2    4

57 Solid waste disposal on land   6.A   2   30

57 Solid waste disposal on land   6.A   2   30
57 Solid waste disposal on land   6.A   2    2        4
57 Solid waste disposal on land   6.A   3   4    3    5

57 Solid waste disposal on land   6.A   3   7    3    7


57 Solid waste disposal on land   6.A   3




57 Solid waste disposal on land   6.A   4   18   4   18




57 Solid waste disposal on land   6.A

57 Solid waste disposal on land   6.A




58 Waste-water handling           6.B   1        6
58 Waste-water handling           6.B   1        6




58 Waste-water handling           6.B   2   7    2    8



58 Waste-water handling           6.B   2   11   2   19



58 Waste-water handling           6.B   2   15   2   19



58 Waste-water handling           6.B   2   7    2    8
58 Waste-water handling   6.B   2   7    2    8




58 Waste-water handling   6.B   2   15   3    6

58 Waste-water handling   6.B   4   23   4   23



58 Waste-water handling   6.B   4   23   4   23




58 Waste-water handling   6.B   4   16   4   19




58 Waste-water handling   6.B   4   22   4   23



58 Waste-water handling   6.B   6   8




58 Waste-water handling   6.B




58 Waste-water handling   6.B
58 Waste-water handling   6.B




58 Waste-water handling   6.B




58 Waste-water handling   6.B



58 Waste-water handling   6.B


58 Waste-water handling   6.B



58 Waste-water handling   6.B




58 Waste-water handling   6.B



58 Waste-water handling   6.B




58 Waste-water handling   6.B




58 Waste-water handling   6.B




58 Waste-water handling   6.B
58 Waste-water handling              6.B




58 Waste-water handling              6.B

58 Waste-water handling              6.B


58 Waste-water handling              6.B




58 Waste-water handling              6.B




58 Waste-water handling              6.B




58 Waste-water handling              6.B



58 Waste-water handling              6.B

59 Clinical waste incineration (d)   6.C.a   6   11




59 Clinical waste incineration (d)   6.C.a   7        13



59 Clinical waste incineration (d)   6.C.a   7
59 Clinical waste incineration (d)     6.C.a   9




59 Clinical waste incineration (d)     6.C.a   13   4    13    4
59 Clinical waste incineration (d)     6.C.a   15

59 Clinical waste incineration (d)     6.C.a   17


59 Waste incineration                  6.C




60 Industrial waste incineration (d)   6.C.b   1         19

60 Industrial waste incineration (d)   6.C.b   3         3




60 Industrial waste incineration (d)   6.C.b   8    16   8    18



60 Industrial waste incineration (d)   6.C.b   9         9




60 Industrial waste incineration (d)   6.C.b   11   3    11    3




60 Industrial waste incineration (d)   6.C.b   11        11

60 Industrial waste incineration (d)   6.C.b   12        12
60 Industrial waste incineration (d)   6.C.b   17       17

61 Municipal waste incineration (d)    6.C.c   3        3


61 Municipal waste incineration (d)    6.C.c   10       10




61 Municipal waste incineration (d)    6.C.c   10       10
61 Municipal waste incineration (d)    6.C.c   11   3   11   3




61 Municipal waste incineration (d)    6.C.c   13       22

61 Municipal waste incineration (d)    6.C.c   24       24


61 Municipal waste incineration (d)    6.C.c



61 Municipal waste incineration (d)    6.C.c
62 Cremation                           6.C.d   7        7


62 Cremation                           6.C.d



63 Small scale waste burning           6.C.e   1        18


63 Small scale waste burning           6.C.e   5        15


63 Small scale waste burning           6.C.e   9        9

64 Other waste €                       6.D     1        9


64 Other waste €                       6.D     2        2

64 Other waste €                       6.D     5        6
64 Other waste €   6.D    5        7

64 Other waste €   6.D    5        7

64 Other waste €   6.D    5



64 Other waste €   6.D    6   18   7    3

64 Other waste €   6.D

64 Other waste €   6.D
67 Forest fires    11.B   1        13
                                                          Proposed
Comment                                                   decision     Action taken


The EFs are clearly inadequate and was evidently
been reviewed by people with no or little
experience in emission inventory compilation              Rejected     None


The document is weak in discussing Flue gas
treatment impacts on reducing emissions - it is not
clear whether emission factors refer to abated or                      Modified text to include
unabated emissions and which abatement                                 more detail on PM, some
technology is used. Also see Comment 10 on this                        additional detail on
sheet (only Sox and NOx abatement are discussed                        abatement added as an
and no co-benefits)                                 Noted              appendix

Table 1-1 has no mention of HCB despite that
there is a reporting requirement for this substance.      Accepted     HCB added to Table 1-1
Emissions from cracking and catalyst regeneration
are includedin Chapter 1.B.2.a.iv. Suggest combine
last 2 sentences to read: "Production processes
such as thermal cracking and catalyst regeneration
as well as fugitive emissions are covered in                           Text modified to clarify
Chapter 1.B"                                              Rejected     scope.
Add NFR code to title to maintain consistency with
title 2.1                                                 Editorial    Done
Insert "1.A.1.b" into section 2.2 title as per that for
2.1 for 1.A.1.a                                           Editorial    Done
This paragraph is unclear. Assumeable there
should be a reference to 1A1c.                            Editorial    Done
I can agree in general about the semplification in
methodologies and in reference to BREEF but the
previous release of the chapter was really
interesting including a very good description of
"combustion mechanism", so "Don't throw out the                        Some additional text
baby with the bath water"; I propose to maintain the                   included (on PM control)
old documentation in the new GB for example as            Consult with and selected information
an Appendix!                                              Expert Panel included as an appendix
Insert "1.A.1.c" into section 2.2 title as per that for
2.1 for 1.A.1.a                                           Editorial    Done
2nd sentence: "IA1b" should read "1A1c".                  Editorial    Done
write: "…has typical combustion
temperatures…leading to…"                                 Editorial    Done

                                                                       Some slight modifications
For these paragraphs to be of any use they need to                     but readers needing detail
be expanded.                                        Noted              should consult BREF
"..up to about 20 MWth.." should read "..from about                    Text modified to clarify
20 MWth..."                                         Noted              scope.
Not only solid and liquid fuels contains N, biomass
should be included in the parentheses.              Noted        Text amended


Natural gas fuelled stationary engines should be
mentioned as a potential large emitter.              Noted       None

As usually in the text there are no data about
pollutants concentration I propose to delete the
paragraph "Mercury concentrations are reported to
be in the range of 2 - 5 μg/m3 for natural gas [van
der Most & Veldt, 1992, Umweltbundesamt,
Germany, 1980]". Why Hg for natural gas and not                  Text modified to remove
other pollutants for other fuels?                   Accepted     data.
                                                                 Emission factor removed
                                                                 from text, no new
                                                                 referencable data from EP
Hg levels quoted for natural gas are too high; own               but previous guidebook
data show a mean of about 100 ng/m³                  Noted       factor adopted
The sentence "can achieve" is duplicate              Editorial   Done
The entire chapter on controls in this draft are                 Some additional text
excerpts from the existing guidebook, however it                 included (on PM control)
has been scaled back so that the usefulness has                  and selected information
totally vanished.                                    Noted       included as an appendix
write: "…technology.."                               Editorial   Done

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

As usually in the text there are no data about
pollutants concentration I propose to delete the
paragraph " The NOx reduction efficiency can be
between 70 and 90 %." Otherwise efficiency must                  Some efficiency data from
be reported for all technologies in an appropriate               current guidebook chapter
Table. This last option is most appropriate.         Noted       added as an appendix

The sentence "If detailed information is available,
use it" is generic, I propose "if emissions data
coming from continuous stacks measurement are
available, use it; otherwise if information coming
from periodic measurements are available use it in
combination with other information"                 Noted        None
The statement, that the default emission factors
have been derived from all available data and
information, seems rather bold when the vast
majority simply refers to the existing guidebook.   Accepted     Text amended
Delete the sentence "have been derived from all
available data and information"                          Accepted     Text amended
Do the term vegetable waste equals agricultural
waste?                                                   Accepted     Text amended
There is no clear definition of the assumption
(power input, technology, abatement) of the Tier 1
methodology. If, as stated, the factors are a simple
mean I think this is not appropriate. We cannot                       Discussed with EP 7/5/08;
evaluate the EFs without reference to a concept of                    some detail added and
"most used" technology.                                  Noted        expansion of Tier 2 factors
Delete "have been derived from all available data
and information".                                        Accepted     Text amended
Correct "sib-bituminous" to "sub-bituminous"             Editorial    Done
We feel Petroleum Coke would be better classified
under "hard coal" rather than heavy fuel oil, as it is
a solid fuel                                             Noted        None
Tables 3-3-3-9 are not complete. Emission factors
for PAH are shown without indication of species;
emission factors for PCDD/F are shown with                            Discussed with EP 7/5/08,
reference to EPA 1998 but there are a lot                             PAH now speciated,
European-based data on dioxins emission; no EF                        PCDD/F PCB and HCB
for PCB and HCB for all fuels.                           Accepted     added where available.
Inconsistencies in the terminology used to describe
fuels in different tables                                Editorial    table fuels modified
It should be indicated in the tables what TEF
system (I-TEF or WHO-TEF) is used for dioxins &                       Will change with new
furans                                                                tables
                                                         Consult with
Table 3-5: no Hg emission factor for natural gas.        Expert Panel Discuss with EP 7/5/08

Table 3-7- 3-9: no PCDD/F emission factors for
heavy fuel oil, other liquid fuels and biomass. PAH                   Factors reviewed and
emission factor for biomass should be checked.      Accepted          modified as appropriate
tier 2 emission factors for stationary engines are
missing                                             Accepted          Factors provided
Tables 3-11, 3-12, 3-13, 3-14, 3-16, 3-17, 3-19, 3-
20: emission factors are shown with reference to
the Guidebook 2006. But Guidebook 2006 does
not contain exactly the same emission factors;
maybe they were recalculated - this should be
indicated. Combustion emissions significantly                         Tables revised, source of
depend on boilers power, but Tier 2 tables do not                     factors should now be
account this.                                       Accepted          clearer

Tables 3-11, 3-12, 3-13, 3-16, 3-17, 3-19, 3-20
(Tier 2) and Tables 3-3 -3-4 (Tier 1) include same
emission factor for PCDD/F with reference to EPA
1998 – a lot of data available for PCDD/F emission Consult with
from coal combustion in Europe.                    Expert Panel Discussed with EP 7/5/08
No subdivision based on MWt of the plant are
reported in Tier 2 methodology (the "old" GB
reported this subdivision!); this subdivision can be
more relevant that the subdivision between dry                    Discussed with EP 7/5/08;
bottom and wet bottom reported in the new GB           Accepted   size split retained
No subdivision based on technology of combustion
(low NOx burner - staged air supply o overfire air)
of the plant are reported in Tier 2 methodology (the              Discussed with EP 7/5/08,
"old" GB reported this subdivision!); this subdivision            some text on abatement
can be more relevant that the subdivision between                 efficiency retained as an
dry bottom and wet bottom reported in the "new"                   appendix to maintain
GB                                                     Noted      information
No complete subdivision based on configuration of
burner (wall or tangential) are reported in Tier 2
methodology (the "old" GB reported this
subdivision!); this subdivision can be more relevant
that the subdivision between dry bottom and wet
bottom reported in the "new" GB                        Noted      Discussed with EP 7/5/08


No control system specification in Tier 2
methodology (the "old" GB reported this
information!);                                         Noted      Discussed with EP 7/5/08

Unclear NOx emission factors and undefined
references, for example for coal the EF is too low
compared with the methodology of "old" GB see
Table 25 of the B11 chapter. For natural gas the
EF is to high compared with the methodology of                    Some factors modified by
"old" GB see Table 24 of the B11 chapter controls?     Noted      extension to Tier 2 tables
Unclear SOx emission factors (% S in fuel? ash                    Text now includes
content in coal?) controls?                            Accepted   calculation from fuel S
Unclear CO, COV, HM emission factors, no                          Some factors modified by
reference with "old" GB                                Noted      extension to Tier 2 tables
PM emission factors unacceptable for Tier 2. In
US EPA for example a Dry bottom plant burning
Coal with no control has EF = 398,7 while the same
plant with baghouse has EF = 3,5. "New" GB
(CEPMEIP) report EF = 26. What is the
assumption! What is the control system? How can
be used this emission factor in Sweden and                        Tier 2 factors are now as
Albania? How can be used to evaluate future                       used in guidebook
emissions?                                             Noted      supplements from 2005/6
CONCLUSION the tables are unclear and                             Discussed with EP 7/5/08.
unusable, the "interpretation" of the "old" GB EF is              More of old guidebook
an unacceptable simplification                         Noted      retained.

Table 3-13 (Tier 2): PM and HM emission factors
are the same as in the Table 3-4 (Tier 1).             Noted      Tables revised.
Table 3-15 (Tier 2): emission factors are the same
as in the Table 3-5 (Tier 1); no Hg emission factor.   Noted       Tables revised
Table 3-18: no PCDD/F emission factors for wood
and similar wood wastes.                               Accepted    Tables revised
Table 3-17 (Wet Bottom Boilers) and the Table 3-
12 (Dry bottom Boilers): the same emission factors
for all technologies - this is not correct.            Noted       Tables revised
Table 3-21: no PCDD/F emission factors for wood
and similar wood wastes.                               Noted       Tables revised
This table 3-22 is an exact duplicate of table 3-24
in chapter 1A4, including the mistake of having a                  Will change with new
negative TSP emission factor.                          Editorial   tables
In the "Not estimated" list of Table 3-22, PAH's                   Will change with new
should be deleted                                      Editorial   tables
In the "Not estimated" list of Table 3-23, SOx                     Will change with new
should be deleted                                      Editorial   tables
In the "Not estimated" list of Table 3-24, PM should               Will change with new
be deleted                                             Editorial   tables
Even though this report is a draft version there
should not be incomplete references to other
chapters, unless the intent is to purposely annoy
the reader. This is a recurring problem several
times in this draft version.                           Accepted    Reference included
The industry emission reporting guidance does not
provide anydetails of the technologies. Delete "and
the industry emissionreporting guidance [Concawe,
2007]".                                                Accepted    Text amended
CONCLUSION the tables are unclear and
unusable, the only complete work by Concawe was
not used                                               Noted       Discuss with EP 7/5/08
For guidance add "-see Chapter 1B2c" after
"....activities"                                       Accepted    Done
For guidance add "-see Chapter 1B2a.iv" after
"....units"                                            Accepted    Done
For guidance add "-see Chapter 1B2a.iv" after
"....releases"                                         Accepted    Done
For guidance add "-see Chapter 1B2a.iv" after
"....emissions"                                        Accepted    Done
Change "reduced" to "eliminated" as NH3 is fully
converted                                              Accepted    Done
For guidance add "-see Chapter 1B2a.iv" after
"....units"                                            Accepted    Done
Delete ")" after "V"                                   Editorial   Done
Add "[Concawe, 2007]" after "Concawe"                  Accepted    Done
There is a specific paper by Concawe (Report no.
9/05R "Air pollutant emission estimation methods
for EPER and PRTR reporting by refineries
(revised)") that the consultant don't take into                    Table has been revisited
consideration and use an undefined reference US                    and incorporates Concawe
EPA (2000)                                             Noted       and other sources
Delete "grouped by major fuel types" as only
refinery gas EF's given.                            Accepted     Done
Add "in Appendix B" after "...comparison"           Accepted     Done

Add new paragraph: "Concawe has published a                      Application of these factors
compilation ofrecommended emission factors for                   by refinery operators is on
reporting by refineries under the E-PRTR                         a facility basis - inclusion
requirements [Concawe, 2007]. For combustion the                 of this statement may
majority of these factors are equivalent to a Tier 2             preclude acceptability of
approach."                                           Rejected    this data at Tier 3
Following on from comment above, it is proposed
that the followingis added after "combustion" at the
end of line 34: "units e.g. boilers and process
heaters and 'furnaces';"                             Accepted    Done
There is a specific paper by Concawe (Report no.
9/05R "Air pollutant emission estimation methods
for EPER and PRTR reporting by refineries
(revised)") that the consultant don't take into
consideration and use an undefined reference US
EPA (2000)                                           Noted       Text revised
                                                                 Text modified, where
Tables: - EF for SOx: Providing a fixed EF for SOx               member States have
does not permitthe benefits of the reduction in fuel             facility specifc data they
sulphur content by refineriesto be captured in                   should incorporate in their
inventories. Member State authorities can obtain                 inventories. Tier 2 could
the mass and average sulphur content of fuels                    be refinery-specific but this
used in refineries, soa simple algorithm should be               is still an aggregated
provided in Tier 2 instead of fixed EF.               Accepted   activity level.
Tables: - there should be consistency in the
number of significantfigures used for emission
factors. Two significant figures should beused for
Tier 2. In Table 4-3 some EF's are given with very
high accuracy (e.g. SOx = 349.9) whereas others
e.g. heavy metals arerounded to only one                         Will change with new
significant figure.                                              tables
Tables: - calculation of upper and lower 95%
confidence limits. The calculation of limits in these
Tables do not appear to follow the guidance in the
cross-cutting Chapter on uncertainities. For
example, an EF with Corinair code C would have
95% limits of100% of the EF value (range 50% to
200% - 100% taken as default). Where Concawe
has made comments on EF's the upper and lower
limit values have been calculated according to                   limits revised in updated
these guidelines.                                     Noted      tables
Table: EF references - there are a number of
references to "Guidebook (2006)" and "Guidebook
(2006), US EPA (2000)". Concawe strongly
considers that an EF derived in some manner
(e.g.by taking geometric mean) of upper and lower
limit values of a range,as quoted in the Guidebook,
should NOT be used where a publishedEF is
available from a well established source (e.g. AP-
42) whichhas been computed from a large number
of measurements. Such a mean value has more
scientific basis than one derived from valuesat
either end of spread for which the distribution is
unknown. That technique is accepted as being
valid only where an EF derivedfrom a number of                None, but revision of
measurements made in the same way is                          emission factor tables has
notavailable.                                       Noted     been done

Table Titles: Tables 4-3 through 4-7 all refer solely
to "heaters". Thereare other combustion units in
refineries e.g. CO boilers, fired waste heat boilers,
etc. and heaters are often called 'process
furnaces'(see, e.g, text in section 4.1.2) although
there is no contact betweenthe fuel and process
material.It is proposed, therefore, to help clarify
what the EF's are for, the term"Heater" in the titles
of the Tables is changed to "Combustion Unit".        Noted   Text clarified

Add new paragraph for clarity: "All the Tier 2
emission factorsprovided in Tables 4-3 to 4-8 are
for unabated emissions. To estimate emissions
where abatement systems are installed,
informationon abatement system efficiencies is
available in the Refinery BREF[EIPPCB, 2003]".
(However, see comment on p 39, line 3)              Noted     None
There is a specific paper by Concawe (Report no.
9/05R "Air pollutant emission estimation methods
for EPER and PRTR reporting by refineries
(revised)") that the consultant don't take into
consideration and use an undefined reference US               See earlier note on
EPA (2000)                                          Noted     Concawe report
There is a specific paper by Concawe (Report no.
9/05R "Air pollutant emission estimation methods
for EPER and PRTR reporting by refineries
(revised)") that the consultant don't take into
consideration and use an undefined reference US               See earlier note on
EPA (2000)                                          Noted     Concawe report
There is a specific paper by Concawe (Report no.
9/05R "Air pollutant emission estimation methods
for EPER and PRTR reporting by refineries
(revised)") that the consultant don't take into
consideration and use an undefined reference US               See earlier note on
EPA (2000)                                          Noted     Concawe report
                                                              We accept that the
                                                              emission is dependent on
                                                              fuel composition but
                                                              combustion and lubricants
                                                              are also relevant. We also
                                                              accept that USEPA VOC
Comment on table 4-8:                                         figure also excludes
- the emission of NMVOC is dependent on the fuel              ethane however, in the
gas composition                                               absence of other data, it
- in the USA VOCs (that means non methane / non               provides a reasonable
ethane hydrocarbons) are regulated and NOT                    value for nmVOC. An
NMHC (non methane Hydro carbons)                              alternative would be to
- the LCP BREF document 2006 mentions only                    apply the the USEPA TOC
formaldehyde as hydrocarbon                                   figure. At least one
- RECOMMENDATION: the figues on NMVOC in                      member state applies an
table 4-8 should be taken out and a general                   emission limit for
comment on the fuel dependancy relating to this               formaldehyde but inventory
emmitent has to be put in the table. Otherwise the            is about total nmVOC not
figures will lead to big misunderstandings.        Rejected   individual components.


The value for NOX in the table 4-8 (100 g/GJ) is
about 120 mg/Nm3 (at 15% O2). This is about 320
mg/Nm3 at 5% O2. This is far away from the
industry recommendation that has been given in
the LCP BREF. There it was recommended to
introduce 190 mg/Nm3 at 15% O2 for lean burn SG
gas engines. This is about 160 g/GJ.

RECOMMENDATION:
- correct the value according to industry
recommendation.
- Furthermore introduce a span for the NOx value.
- A value for gas engine that are operated in the
gas-diesel-mode is missing. This value has also to            The guidebook is not
be integrated.                                     Noted      reflecting BAT.
There is a specific paper by Concawe (Report no.
9/05R "Air pollutant emission estimation methods
for EPER and PRTR reporting by refineries
(revised)") that the consultant don't take into
consideration and use an undefined reference US               See earlier note on
EPA (2000)                                         Noted      Concawe report
There is a specific paper by Concawe (Report no.
9/05R "Air pollutant emission estimation methods
for EPER and PRTR reporting by refineries
(revised)") that the consultant don't take into
consideration and use an undefined reference US               See earlier note on
EPA (2000)                                         Noted      Concawe report

Wrong NFR, it's no clear what table refer! It's crude
oil combustion? Where? In a process furnace?          Noted
Table 4-9 appears to belong to NFR 1A1c (as                      Will change with new
shown in table "code"box.                                        tables

All the Tier 2 emission factors are for unabated
emissions. It wouldbe useful to provide a table of
abatement system efficiencies (c.f.tables in
1.B.2.a.v and 1.B.2.a.iv) after the Tier 2 EF tables. Noted      Done where possible
Subchapter 5 1A1c Manufacture of solid fuels: the
title and content are not harmonized; only coke
manufacture is described.                             Noted      Discussed with EP 7/5/08


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

The heading for this chapter misses the second                   Have put in those from old
part "Other energy industries"                      Editorial    guidebook POPs chapter

CONCLUSION the tables are unclear and                            Have put in those from old
unusable                                            Noted        guidebook POPs chapter
This chapter is very thin. Under "Techniques" only
coke manufacture is mentioned. The existing
guidebook does not have a separate chapter on
neither 1A1b nor 1A1c, this would have been an
excellent time to improve that aspect, alas nothing Consult with
has been done.                                      Expert Panel Done where possible
It is proposed that there is an additional paragraph
on NOx estimation using facility data. "NOx
formation is very complex, anddepends on a
number of parameters e.g. hydrogen and moisture
contents, pre-heat temperature, burner intensity,
etc. Amethodology to calculate NOx emissions has
been published (in theOil and Gas Journal) and
provided in Concawe, 2007 as the recommended                        The chapter already refers
method for refineries to use for emission reporting.                the reader to Concawe
Where facility data are available, this detailed                    guidance for Tier 3.
methodology should beused to obtain more                            Additional reference or
accurate NOx estimates than the fixed value                         highlighting of specific
emission factor provided in the Tier 2 approach."       Rejected    pollutants is not necessary.
Figure 5-1: error in the title.                         Editorial   Done
The decision tree is obviously similar to the one for
petroleum refining, however the figure text should
reflect the correct chapter.                            Editorial   Figure title amended
There is no clear definition of the assumption
(power input, technology, abatement) of the Tier 1
methodology. If as stated the factors are a simple
mean I think this is not appropriate. We cannot
evaluate the EFs without reference to a concept of
"most used" technology.                                 Noted       Discussed with EP 7/5/08
In the tables 5-3, 5-4 not estimate selenium and
Heavy metals. It is not correct, because HM
includes Se.The same problem for PAH as for
other combustion (only summary EF, not by
pollutants)                                             Noted       Tables revised

There is no clear definition of the assumption
(power input, technology, abatement) of the Tier 1
methodology. If as stated the factors are a simple
mean I think this is not appropriate. We cannot
evaluated the EFs without reference to a concept
of "most used" technology. Only very poor list of       Consult with
pollutants take into account. ? Other liquid fuel?      Expert Panel Done
There is no clear definition of the assumption
(power input, technology, abatement) of the Tier 1
methodology. If as stated the factors are a simple
mean I think this is not appropriate. We cannot
evaluated the EFs without reference to a concept
of "most used" technology. Only very poor list of
pollutants take into account. ?                         Noted       Discussed with EP 7/5/08
Very useful table, however there is no need to                      GT and engines moved, no
separate emissions from GT and gas engines last.                    other comments on
The order of the pollutants is also strange, SO2,                   pollutant order so not
NOx TSP would be the logical order.                     Noted       changed
Appendix B not Appendix 2                               Editorial   Done
This glossary should either be expanded or
removed. Some listings in the glossary do not
appear previously in the text.                          Accepted    Revised
Considering the number of times "Guidebook
(2006)" is referenced in the text it is quite an                References amended -
accomplishment to have it excluded from the list of             Guidebook 2006 generally
references.                                         Accepted    replaced by original ref.

Update the reference to the EURELECTRIC guide Editorial         Revised
Reference list: There are references given in the
EF tables of "USEPA (1998)", "US EPA (2000)"
and "US EPA (2003)". There areonly two US EPA
references in the Reference List, and one of these
is for 1987. The other is undated. The Reference
List needs toreflect the references in the text and             References will be
tables.                                             Editorial   rationalised
Need to define the calculations & assumptions
used to convert emission concentrations into EF
and make sure that they are consistent with
Appendix C                                          Accepted    note added to tables
The NOx values from the Gothenburg Protocol are
listed in table B4.
These values should be taken out as there os a
political decision to review the Gothenburg
Protocol. Furthermore these values (for diesel
engines) are far beyond BAT.
See also:
http://www.euromot.org/download/news/positions/st
ationary_engines/UNECE_CLRTAP_ABC_Analysis
_080403.pdf

http://www.euromot.org/download/news/positions/st
ationary_engines/EIPPCB_BREF_euromot_comm
ent_may_02.pdf

In these position papers emission limit values are
recommended. We propose to overtake those
emission limit values in table B4.                   Noted      None
The given BREF NOX value for new and existing
stationary gas engines in the table B4 is too low.
Correct span should be 20-190 mg/Nm3. Please
compare the emission table of the General
Environmental Health and Safety (EHS) Guidelines
of the World Bank. World Bank has implemented
emission limit values that are depending on the
engine type, the used fuel, the positioon of the
engine etc. We support this strategy as it refers on
different emission limit values that are depending
of different surrounding operation factors. These
factors are also depending on the infrastructure
around the engine (water, reagents, fuel quality,
etc.).

Please compare page 7 of the document under the
following link:                                                   The range indicated in the
                                                                  comment reflects industry
http://www.ifc.org/ifcext/enviro.nsf/AttachmentsByTi              view of BAT; the table is
tle/gui_EHSGuidelines2007_GeneralEHS/$FILE/Fi                     intended to summarise the
nal+-+General+EHS+Guidelines.pdf                                  main BREF AELs and
                                                                  cannot reflect all
We recommend to distinguish the emission limit                    comments/notes to the
values for different engine types.                     Noted      Table.


                                                                  Some sources use 21 (for
                                                                  example standardisation of
                                                                  emission concentrations in
                                                                  the Waste Incineration
                                                                  Directive which, as with the
                                                                  LCPD, includes
                                                                  requirements on CEMS
                                                                  uncertainty and hence was
                                                                  a driver for EN14181),
                                                                  USEPA Method 19 and
                                                                  others use 20.9 for
                                                                  corrections and some
                                                                  others apply values
An O2 concentration of 21% instead of 20,9%                       between these figures (for
seems more common; e.g. 21% is used in the                        example 20.95 or 20.96).
informative appendix E of EN 14181                     Noted      Difference is minor.
convert US EPA method 19 in SI units or replace it                units are dscm/J or, dry
by the IEA correlations                                Rejected   m3/J
I could not find any HCB emission factors for coal
and wood combustion or other relevant sources.
See
http://reports.eea.europa.eu/EMEPCORINAIR5/en/
Sources_of_HCB_emissions.pdf.                          Accepted   Tables revised
Many EF-references are of kind "(Guidebook
2006)". I suggest to refer to original references
from the Guidebook 2006.                               Noted      References revised
The units in the emission factor tables should be
changed depending on pollutant. Main pollutants
and particles could be kept in g/GJ, while metals
could be listed in mg/GJ, PAH in mikrogram/GJ or                  Noted and some factors
mg/GJ and dioxin and other POP's in ng/GJ.             Noted      have been modified
In the chapters concerning stationary combustion
there are only given a default emission factor for
PAH. But for reporting purposes individual
emission factors are needed for the 4 different
PAH's.                                                 Accepted   Tables revised
In the existing guidebook information on the 4
different PAH's is available. A combined PAH
emission factor is somewhat useless considering
the reporting requirements.                            Accepted   Tables revised

There are a general lack of HCB emission factors
in this chapter. It seems that only under waste
incineration is an emission factor for HCB provided. Noted        Tables revised

The existing guidebook has a specific chapter on
HCB, (and PCB), it would be appropiate if the data
in these existing chapters were included and
expanded in this revised guidebook.                    Noted      Tables revised
A lot of the emission factors references to
Guidebook 2006 does not seem to correspond
correctly.                                             Noted      Tables revised
E.g. NOx emission factor for DBB residual oil listed
in table 3-14 as 300 g/GJ. In the existing guidebook
the NOx emission factor for residual oil varies
between 150 and 296 g/GJ
make clear that Emission factors refer to net
calorific values                                       Accepted   Additional text added
The emission factors for the stationary gasengines
totaly missing.                                        Noted      Table included
No mention of stationary engines in the Methods
chapter!                                               Noted
If the authors could not be bothered to write
something new, they could at least have copied all
the text from the existing guidebook.                  Noted
General comments: chapter includes large number
of very different processes so will be difficult for
usage; there is no indication where to get
information for estimation of emission from
combustion using proposed methodology (i.e. what
fuel and how much it was used for production of a
certain ferrous or non-ferrous metal). In this case
applicability of it will be low. There are a lot of
tables in the chapter which are not applicable, for
example, emissions from natural gas combustion                      Tier 1 factors will remain
in lead or copper production. Assumption that all                   heat input but Tier 2 will be
NOx, SO2, CO, NMVOC emissions are from fuel                         revised to be based on
combustion will lead to significant difficulties in                 production which should
emission inventory and to miss of sources.               Accepted   make chapter more useful
For fuel use in conventional boilers, furnace,
engine or other device emission information is
referred to Chapters 1A1 and 1A4.                        Noted      Some modification to text
In table 1-1 under iron and steel one is refered to
chapter 1A1 with regard to stationary engines this                  None - combustion
must be a mistake since no guidance on stationary                   chapters now include a
engines is provided in this chapter.                     Accepted   stationary engine table
I assume the correct chapter for guidance on
mobile sources in industry would be chapter 1A4                     Amended reference to
Other Mobile and not 1A2.                                Accepted   1A2fii

Where, if any, should be accounted NOx emissions                    Although NOx arises form
from catalytic oxidation of ammonia in nitric acid                  oxidation of ammonia
production? Are you provided for this source of                     emissions are assigned to
NOx emissions in Chapters 1A2 or 2B?               Noted            the process

SOx emissions in this NFR category are calculated
only from SOx emissions from the fuel combusted? Noted              None

Again there are no mention of HCB despite the
reporting requirement for this substance.                Noted      Text now includes HCB
It's not clear where the EFs come from! Particularly
when Guidebook (2006) is quoted it's not true that
EFs are present in this form in original reference! If
elaboration was performed on original data these                    Discussed with EP, tables
must be explained, otherwise the table is                           have been amended to
unacceptable                                             Noted      clarify
It's not clear where the EFs come from! Particularly
when Guidebook (2006) is quoted it's not true that
EFs are present in this form in original reference! If
elaboration was performed on original data these                    Discussed with EP, tables
must be explained, otherwise the table is                           have been amended to
unacceptable                                             Noted      clarify
There is any reference about what specific fuels
are covered under fuel type named "Derived Fuels"
in this Chapter. Are these specific fuels those                     Yes, table included from
mentioned in Chapter 1A1, Table 3-2?                     Accepted   1A1
The 95% confidence interval for TSP in Table 3-2
is 0-10, while for PM10 and PM2,5 the interval is                     Will change with new
0.1-10. Is lower value for TSP correct?                               tables
It's not clear where the EFs come from! Particularly
when Guidebook (2006) is quoted it's not true that
EFs are present in this form in original reference! If
elaboration was performed on original data these                      Discussed with EP, tables
must be explained, otherwise the table is                             have been amended to
unacceptable                                             Noted        clarify
It's not clear where the EFs come from! Particularly
when Guidebook (2006) is quoted it's not true that
EFs are present in this form in original reference! If
elaboration was performed on original data these                      Discussed with EP, tables
must be explained, otherwise the table is                             have been amended to
unacceptable                                             Noted        clarify
The 95% confidence interval for PM10 in Table 3-2
is 0-2, while for TSP and PM2,5 the interval is 0.02-                 Will change with new
2. Is lower value for PM10 correct?                                   tables
Table 3-3: Why Dioxins and Furans emission
factors for natural gas have not been estimated?
When using Tier 2 method there is an emission
factor of 2 I-TEQ ng/GJ for all activities in this NFR
category 1A2 with the exception of cement and
lime production activities (SNAP codes 030311 and                     Factors now in at Tier 1 -
030312)                                                  Noted        refer to process emissions
In Table 3-4 (Tier 1 approach), there is no emission
factor estimated for dioxins and furans when using                    Now referenced to
heavy fuel oil.                                          Noted        combustion chapters
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg        Consult with
are indicated in Table 3-13                              Expert Panel Included

Tables 3-13, 3-16, 3-19, 3-26, 3-30, 3-34, 3-36, 3-
38, 3-41, 3-43: EF for Hg and Pb in column Value                      Will change with new
are shown as 0, but in column Lower – not 0.                          tables
It's not clear where the EFs come from! Particularly
when Guidebook (2006) is quoted it's not true that
EFs are present in this form in original reference! If
elaboration was performed on original data these                      Discussed with EP, tables
must be explained, otherwise the table is                             have been amended to
unacceptable                                           Noted          clarify
It's not clear where the EFs come from! Particularly
when Guidebook (2006) is quoted it's not true that
EFs are present in this form in original reference! If
elaboration was performed on original data these                      Discussed with EP, tables
must be explained, otherwise the table is                             have been amended to
unacceptable                                           Noted          clarify
There is any reference about what specific fuels
are covered under fuel type named "Other Liquid
Fuels" in this Chapter. Are these specific fuels                      Yes, table included from
those mentioned in Chapter 1A1, Table 3-2?             Noted          1A1
                                                              Will change with new
There is no mention to heavy metals in Table 3-5.             tables

In Table 3-5, Dioxins and Furans emission factors
have not been estimated for Other Liquid Fuels.
However, when using Tier 2 approach there is an
emission factor of 5 I-TEQ ng/GJ independently of             Will change with new
what is the SNAP activity considered.                         tables
                                                              For combustion these are
Which fuels are considered under the fuel type                as listed in 1A1 - table now
"Biomass"?                                            Noted   included in text
In general terms it is have not been clarified
whether the proposed emission factors correspond
to the emissions originated from only the fuels
combusted or they also correspond to total                    Following discussion with
emissions originated from the fuels combusted                 EP, Tier 1 is default
plus those originated from the materials in the               combustion only, Tier 2 is
contact furnaces. Carificatin of this pont is                 generally only
particularly relevant for the activities in the 1A2           NOx/SOX/CO with balance
NFR category, as many of its installations are                of emissions assigned to
contact furnaces.                                     Noted   the process chapters
Only a unknown elaboration on very old GB values.
NEW INFORMATION FROM IPPC BREF DON'T
TAKEN INTO ACCOUNT. Why only Coke Oven
Gas when old GB contains EFs also for blast
furnace gas and natural gas? Specific fuel                    Discussed with EP, tables
consumptions in GJ/Mg of product MUST BE                      have been amended to
REPORTED!                                             Noted   clarify
Blast furnace cowpers (SNAP 030203): Emission
factors proposed only covers coke oven gas
combustion (table 3-7), but there are no
information available related to other fuels                  Discussed with EP, tables
(specially blast furnace gas, but also GLP or                 have been amended to
natural gas).                                         Noted   clarify

EF in tables (Tier 2) for TSP, HM and PCDD/F are
the similar for same fuel and different processes,
for instance, EF in Tables 3-8, 3-15, 3-27, 3-28, 3-
32, 3-40 (fuel is coke or hard coal). The same
situation – for Gas, Liquid fuels. How this wss               Tables revised following
proved? Is it necessary to duplicate tables?         Noted    discussion with EP
The production processes described in the
guidebook are generic, focussed on applicability for
various individual processes. This approach does
not take into account the more complex reality of             Yes but the level of activity
intertwined processes such as Iron and Steel                  detail defines the basis of
Manufacture. This is especially true for the use of           factors suitable for use at
mixed process gases.                                 Noted    Tier 1 and 2
Table 3-8 Tier 2: it is shown that HM emission
factors are from the Guidebook (2006). But in the
Table 8.2c of the Guidebook (2006) there are no
such emission factors.                               Noted    Tables have been revised
EFs old and not validated. PM EFs for 1.A.2 and                         Discussed with EP, tables
2.C.1: as you subdivide combustion and not                              have been amended to
combustion PM emissions! Use BREF EFs!                      Noted       clarify
EFs old and not validated. PM EFs for 1.A.2 and                         Discussed with EP, tables
2.C.1: as you subdivide combustion and not                              have been amended to
combustion PM emissions! Use BREF EFs!                      Noted       clarify
EFs old and not validated. PM EFs for 1.A.2 and                         Discussed with EP, tables
2.C.1: as you subdivide combustion and not                              have been amended to
combustion PM emissions! Use BREF EFs!                                  clarify

The SNAP code in table 3-10 (030302), and the
literal for Technologies/Practices item (Reheating
Furnaces) does not match with the heading of the                        Will change with new
table. Which activity is referred to in this table?                     tables
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg                       Revised EF tables should
are indicated in Table 3-10                            Noted            be clearer
For Reheating Furnaces (SNAP 030302) there are
only emission factors for coke oven gas. What's
the matter with the other fuels used in this activity?                  Discussed with EP, tables
In Guidebook 2006 there is a wide list of fuels used                    have been amended to
in this furnaces.                                      Noted            clarify

Table 3-12 (Tier 2): error in the title of the table; not
coincide with the content (Reheating furnaces); EF
for PCDD/F are shown with reference to the
Guidebook 2006, but in the Guidebook 2006 there
are no such emission factors.                               Editorial   Done
The title refers to "Gray Iron Foundries" but the
technology in the table refers to "Reheating
Furnaces". However existing GB EFs old and not
validated. PM EFs for 1.A.2 and 2.C.1: as you                           Discussed with EP, tables
subdivide combustion and not combustion PM                              have been amended to
emissions! Use BREF EFs!                                    Noted       clarify
The SNAP code in table 3-12 (030302), and the
literal for Technologies/Practices item (Reheating
Furnaces) does not match with the heading of the
table. Which activity is referred to in this table?
Emission factors in this table are the same as                          Will change with new
those proposed in Table 3-10.                                           tables
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
are indicated in Table 3-12                                 Noted       See earlier comment
Tables 3-12 - 3-13 Tier 2: it is known that gray iron
in foundries is produced using coke so how EF for
natural gas and other liquid fuels were obtained
and where they can be applied?                              Noted       Table headings modified
                                                                        Discussed with EP, tables
Why "Other Liquid Fuels"? Why these EFs ? USE                           have been amended to
BREF EFs!                                                   Noted       clarify
In the existing guidebook default values are
provided in g/tonne liquid steel, which perhaps is a            Tables have been modified
better unit for these type of default emission                  to allow use of production
factors.                                             Accepted   activity data at Tier 2
The Hg emission factor proposed in Table 3-13 is 0
g/GJ, while the 95% confidence interval for this                Will change with new
pollutant is 0.00001-0.0001                                     tables
The Pb emission factor proposed in Table 3-13 is 0
g/GJ, while the 95% confidence interval for this                Will change with new
pollutant is 0.00003-0.2                                        tables
Table 3-14: For Primary and Secondary Pb/Zn/Cu
production using Natural Gas, it is very surprising
that there are no heavy metals emissions
(indicated as not applicable), taking into acccount
that these are processes with contact and the raw               Heavy metals now
materials obviously content the corresponding                   assigned to process
Heavy Metals.                                        Noted      emission
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
are indicated in Table 3-14                          Noted      See earlier comment
The same EF for PM, HM, PCDD/F and PAH are
shown in the Tables 3-14 (Pb/Cu/Zn Production), 3-
17 (Secondary Aluminium Production) and 3-20
(Alumina/Mg/Ni Production); though technologies                 Will change with new
are different.                                                  tables

All the chapter "3.3.2.2 Combustion in 1A2b – 1
Non-ferrous metal" it's unclear because I don't
understand if take into account the different
condition of combustion in roasting and as it's
possible to subdivide emissions from fuel and from
materials in such a case (see GENERAL
PRELIMINARY COMMENT). If it's possible it's                     Discussed with EP, tables
necessary to develop specific emission factors not              have been amended to
to copy "old" EF that derive from another approach. Noted       clarify

In Table 3-15, emission factors for Heavy Metals,
Dioxins and Furans and PAH for Primary Pb, Zn                   Following discussion with
and Cu Production using coke are the same as in                 EP, Tier 1 is default
any other activity in this 1A2 NFR category. In the             combustion only, Tier 2 is
particular case of Heavy Metals, it seems that                  generally only
emission factors only refers to emissions originated            NOx/SOX/CO with balance
from the fuel combusted and there is no relation to             of emissions assigned to
the raw materials used.                              Noted      the process chapters
Table 3-16 also contains mysterious "0" values.
Likewise with table 3-19, table 3-26, table 3-30,
table 3-34, table 3-36, table 3-38, table 3-41 and
table 3-43.                                          Noted      Rounding issue corrected
                                                            Following discussion with
                                                            EP, Tier 1 is default
                                                            combustion only, Tier 2 is
                                                            generally only
                                                            NOx/SOX/CO with balance
                                                            of emissions assigned to
Table 3-16: same comment as for Table 3-15.         Noted   the process chapters
The Hg emission factor proposed in Table 3-16 is 0
g/GJ, while the 95% confidence interval for this            Will change with new
pollutant is 0.00001-0.0001                                 tables
The Pb emission factor proposed in Table 3-16 is 0
g/GJ, while the 95% confidence interval for this            Will change with new
pollutant is 0.00003-0.2                                    tables
The same EF for PM, HM, PCDD/F and PAH are
shown in the Tables 3-16 (Pb/Cu/Zn Production)
and 3-19 (Secondary Aluminium Production);                  Will change with new
though technologies are different.                          tables
SNAP code in table 3-17 should be 030310 (not               Will change with new
0303)                                                       tables
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
are indicated in Table 3-17                         Noted
SNAP code in table 3-18 should be 030310 (not               Will change with new
0303)                                                       tables

In Table 3-18, PM10 and PM2.5 emission factors
for heavy fuel oil seem to be interchanged (PM2.5           Will change with new
values are higher than PM10)                                tables

The same EF for PM, HM and PAH are shown in
the Tables 3-18 (Secondary Aluminium Production)
and 3-21 (Alumina/Mg/Ni Production); though
technologies are different. There are errors of EF          Will change with new
for PM10 and PM2.5 in both tables.                          tables
SNAP code in table 3-19 should be 030310 (not               Will change with new
0303)                                                       tables
The Hg emission factor proposed in Table 3-19 is 0
g/GJ, while the 95% confidence interval for this            Will change with new
pollutant is 0.00001-0.0001                                 tables
The Pb emission factor proposed in Table 3-19 is 0
g/GJ, while the 95% confidence interval for this            Will change with new
pollutant is 0.00003-0.2                                    tables

                                                            Following discussion with
                                                            EP, Tier 1 is default
                                                            combustion only, Tier 2 is
In Chapter 1A1, page 9, lines 31 to 33, it is said          generally only
that "for natural gas only emissions of mercury are         NOx/SOX/CO with balance
relevant ...". However no emission factors for Hg           of emissions assigned to
are indicated in Table 3-20                         Noted   the process chapters
In Table 3-21, PM10 and PM2.5 emission factors
for heavy fuel oil seem to be interchanged (PM2.5               Revised EF tables should
values are higher than PM10)                        Accepted    be clearer
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
are indicated in Table 3-22                         Noted       See earlier comment
                                                                Boiler plant emissions can
All the chapter Combustion in 1A2d – Pulp and 1                 use factors from !A1 (or
paper production is not necessary (emissions are                1A4) butthey are not a 1A1
counted in 1.A.1 as boilers)                           Noted    activity

                                                                Following discussion with
                                                                EP, Tier 1 is default
                                                                combustion only, Tier 2 is
                                                                generally only
                                                                NOx/SOX/CO with balance
Particles and metals in table 3-24 are indicated as             of emissions assigned to
included elsewhere. Where would that be?               Noted    the process chapters

In Table 3-23 the 95% confidence interval for Ni is             Will change with new
0.002-0.0. What is the upper bound of this interval?            tables
Emission factors for dioxins and furans and PAH
for wood are the same as for hard coal (or coke) in
other activities. Are this emission factors correct?
We could not find in Guidebook 2006 this                        Will change with new
reference for SNAP activity 030321.                             tables

                                                                Following discussion with
                                                                EP, Tier 1 is default
                                                                combustion only, Tier 2 is
In Table 3-24, particulates and heavy metals                    generally only
emission factors for black liquor combustion have               NOx/SOX/CO with balance
the label "IE". Where have these emission factors               of emissions assigned to
been included?                                         Noted    the process chapters
                                                                Included elsewhere but
                                                                these references have
What does "IE" for emission factors mean ? Where                been removed (not
included ?                                          Noted       estimated)
Erroneous paragraph numeration 3.3.4 and not
3.3.3.1                                             Editorial   Done
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
are indicated in Table 3-25                         Noted       See earlier comment
Plaster: all the text it's unclear because I don't
understand if take into account the different
condition of combustion in kiln and as it's possible              Following discussion with
to subdivide emissions from fuel and from                         EP, Tier 1 is default
materials in such a case (see GENERAL                             combustion only, Tier 2 is
PRELIMINARY COMMENT). If it's possible it's                       generally only
necessary to develop specific emission factors not                NOx/SOX/CO with balance
to copy "old" EF that derive from another approach                of emissions assigned to
(combustion + process).                              Noted        the process chapters

                                                                  Following discussion with
                                                                  EP, Tier 1 is default
For Plaster Furnaces there are only emission                      combustion only, Tier 2 is
factors proposed for natural gas and other liquid                 generally only
fuels. Which emission factors should be used for                  NOx/SOX/CO with balance
other fuels like hard coal, heavy fuel oil, petroleum             of emissions assigned to
coke, wood, ...?                                      Noted       the process chapters
The Hg emission factor proposed in Table 3-26 is 0
g/GJ, while the 95% confidence interval for this                  Will change with new
pollutant is 0.00001-0.0001                                       tables
The Pb emission factor proposed in Table 3-26 is 0
g/GJ, while the 95% confidence interval for this                  Will change with new
pollutant is 0.00003-0.2                                          tables
Cement: all the text it's unclear because I don't
understand if take into account the different
condition of combustion in kiln and as it's possible              Following discussion with
to subdivide emissions from fuel and from                         EP, Tier 1 is default
materials in such a case (see GENERAL                             combustion only, Tier 2 is
PRELIMINARY COMMENT). If it's possible it's                       generally only
necessary to develop specific emission factors not                NOx/SOX/CO with balance
to copy "old" EF that derive from another approach                of emissions assigned to
(combustion + process).                               Noted       the process chapters
Give precise reference to EF rather than                          Will change with new
Guidebook (2006)                                                  tables
The table design with one fuel per table do not give
a general view of EF - all fuels per process in one
table                                                 Editorial   None

                                                                  Following discussion with
                                                                  EP, Tier 1 is default
                                                                  combustion only, Tier 2 is
For Cement Production, there are no emission                      generally only
factors proposed for petroleum coke, heavy fuel oil,              NOx/SOX/CO with balance
wood and wood wastes. Petroleum coke is the                       of emissions assigned to
main fuel used in this activity.                     Rejected     the process chapters
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
are indicated in Table 3-29                          Noted        See earlier comment
In Table 3-29, Dioxins and Furans emission factors
has not been estimated for Nataural Gas.
However, whe using Tier 2 approach there is an
emission factor of 2 I-TEQ ng/GJ independently of            Will change with new
the SNAP activity considered.                                tables
The Hg emission factor proposed in Table 3-30 is 0
g/GJ, while the 95% confidence interval for this             Will change with new
pollutant is 0.00001-0.0001                                  tables
The Pb emission factor proposed in Table 3-30 is 0
g/GJ, while the 95% confidence interval for this             Will change with new
pollutant is 0.00003-0.2                                     tables
                                                             Waste combustion factors
                                                             now removed as
Table 3-31 Tier 2: no emission factors for PCDD/F            inappropriate in this
which are high for waste combustion.                 Noted   chapter
The fuel indicated in Table 3-31 (Hard coal) is
wrong. In accordance with the heading it should be           Will change with new
"Industrial waste"                                           tables
Table 3-31: Fuel: Replace "Hard coal" with                   Will change with new
"Industrial waste"                                           tables
Lime: all the text it's unclear because I don't
understand if take into account the different
condition of combustion in kiln and as it's possible         Following discussion with
to subdivide emissions from fuel and from                    EP, Tier 1 is default
materials in such a case (see GENERAL                        combustion only, Tier 2 is
PRELIMINARY COMMENT). If it's possible it's                  generally only
necessary to develop specific emission factors not           NOx/SOX/CO with balance
to copy "old" EF that derive from another approach           of emissions assigned to
(combustion + process).                              Noted   the process chapters

                                                             Following discussion with
                                                             EP, Tier 1 is default
                                                             combustion only, Tier 2 is
                                                             generally only
Not all fuels used in lime production are covered in         NOx/SOX/CO with balance
the Draft. There are no emission factors for coke,           of emissions assigned to
petroleum coke, heavy fuel oil or biomass fuels.     Noted   the process chapters
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
are indicated in Table 3-33                          Noted   See earlier comment
In Table 3-33, Dioxins and Furans emission factors
has not been estimated for Nataural Gas.
However, whe using Tier 2 approach there is an               UNEP factor adopted at
emission factor of 2 I-TEQ ng/GJ independently of            Tier 1, Tier 2 factors will be
the SNAP activity considered.                        Noted   in process chapters
                                                              Thamkyou for providing
                                                              data, this is good detail on
                                                              state of the art/BAT but is
                                                              on a restricted pool of
                                                              plant. Data from the draft
                                                              revised CLP BREF doesn't
                                                              provide fuel-based EFs but
NOX-EF for Lime kilns seems to be very high since             indicates a very wide range
the needed temperatures are much lower than for               of emissions and the
cement kilns. The different kiln types have very              factors provided in the
different levels on NOX emissions. (see                       guidebook are within the
http://www.umweltbundesamt.at/fileadmin/site/publi            range of 'inferred' factors
kationen/REP0128.pdf, page 11)                     Noted      from the BREF data.
The Hg emission factor proposed in Table 3-34 is 0
g/GJ, while the 95% confidence interval for this              Will change with new
pollutant is 0.00001-0.0001                                   tables
The Pb emission factor proposed in Table 3-34 is 0
g/GJ, while the 95% confidence interval for this              Will change with new
pollutant is 0.00003-0.2                                      tables

                                                              Following discussion with
                                                              EP, Tier 1 is default
                                                              combustion only, Tier 2 is
                                                              generally only
In Table 3-36, the fuel is described as "Other Liquid         NOx/SOX/CO with balance
Fuels", but probably it is about gas oil. Is this             of emissions assigned to
assumption correct?                                   Noted   the process chapters
Asphalt: all the text it's unclear because I don't
understand if take into account the different
condition of combustion in kiln and as it's possible
to subdivide emissions from fuel and from                     Following discussion with
materials in such a case (see GENERAL                         EP, Tier 1 is default
PRELIMINARY COMMENT). If it's possible it's                   combustion only, Tier 2 is
necessary to develop specific emission factors not            generally only
to copy "old" EF that derive from another approach            NOx/SOX/CO with balance
(combustion + process). PM from process where is              of emissions assigned to
inserted?                                             Noted   the process chapters

                                                              Following discussion with
                                                              EP, Tier 1 is default
                                                              combustion only, Tier 2 is
In accordance with Guidebook 2006, chapter                    generally only
B3313, "During the production of asphalt concrete             NOx/SOX/CO with balance
considerable amounts of fine particles can be                 of emissions assigned to
generated".                                         Noted     the process chapters
                                                                  Following discussion with
                                                                  EP, Tier 1 is default
In Table 3-37 (gas natural combustion in asphalt                  combustion only, Tier 2 is
plants), the emission factor for NMVOC is indicated               generally only
as estimated elsewhere (IE). Nevertheless, in                     NOx/SOX/CO with balance
Table 3-36 (combustion of other liquid fuels) an                  of emissions assigned to
emission factor of 11.8 g/GJ is mentioned.             Accepted   the process chapters
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
are indicated in Table 3-37                            Noted      See earlier comment
The Hg emission factor proposed in Table 3-38 is 0
g/GJ, while the 95% confidence interval for this                  Will change with new
pollutant is 0.00001-0.0001                                       tables
The Pb emission factor proposed in Table 3-38 is 0
g/GJ, while the 95% confidence interval for this                  Will change with new
pollutant is 0.00003-0.2                                          tables
Glass: all the text it's unclear because I don't
understand if take into account the different
condition of combustion in kiln and as it's possible
to subdivide emissions from fuel and from
materials in such a case (see GENERAL                             Following discussion with
PRELIMINARY COMMENT). If it's possible it's                       EP, Tier 1 is default
necessary to develop specific emission factors not                combustion only, Tier 2 is
to copy "old" EF that derive from another approach                generally only
(combustion + process). PM from process where is                  NOx/SOX/CO with balance
inserted? Metals emissions very important for the                 of emissions assigned to
sector where are inserted?                             Noted      the process chapters
For Glass Production, the SNAP code indicated is
0303. It is suposed that SNAP codes involved are                  Will change with new
030314, 030315, 030316 and 030317.                                tables
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
are indicated in Table 3-39                            Noted      See earlier comment

                                                                  Following discussion with
                                                                  EP, Tier 1 is default
                                                                  combustion only, Tier 2 is
The fuels considered are Hard Coal, Other Liquid                  generally only
Fuels and Natural Gas. No reference is made to                    NOx/SOX/CO with balance
other fuels like heavy fuel oil, petroleum coke or                of emissions assigned to
biomass (wood and wood wastes).                        Noted      the process chapters
Bricks and Tiles: all the text it's unclear because I
don't understand if take into account the different
condition of combustion in kiln and as it's possible
to subdivide emissions from fuel and from                      Following discussion with
materials in such a case (see GENERAL                          EP, Tier 1 is default
PRELIMINARY COMMENT). If it's possible it's                    combustion only, Tier 2 is
necessary to develop specific emission factors not             generally only
to copy "old" EF that derive from another approach             NOx/SOX/CO with balance
(combustion + process). PM from process where is               of emissions assigned to
inserted?                                             Noted    the process chapters
The Hg emission factor proposed in Table 3-41 is 0
g/GJ, while the 95% confidence interval for this               Will change with new
pollutant is 0.00001-0.0001                                    tables
The Pb emission factor proposed in Table 3-41 is 0
g/GJ, while the 95% confidence interval for this               Will change with new
pollutant is 0.00003-0.2                                       tables
There is no emission factor for NMVOC in Table 3-              Will change with new
42                                                             tables
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
are indicated in Table 3-42                           Noted    See earlier comment
The Hg emission factor proposed in Table 3-43 is 0
g/GJ, while the 95% confidence interval for this               Will change with new
pollutant is 0.00001-0.0001                                    tables
The Pb emission factor proposed in Table 3-43 is 0
g/GJ, while the 95% confidence interval for this               Will change with new
pollutant is 0.00003-0.2                                       tables

                                                               Following discussion with
                                                               EP, Tier 1 is default
                                                               combustion only, Tier 2 is
                                                               generally only
The fuels considered are Other Liquid Fuels and                NOx/SOX/CO with balance
Natural Gas. No reference is made to other fuels               of emissions assigned to
like Heavy Fuel Oil.                                Noted      the process chapters
Which SNAP codes are referred to in Tables 3-42                Will change with new
and 3-43?                                                      tables
In Chapter 1A1, page 9, lines 31 to 33, it is said
that "for natural gas only emissions of mercury are
relevant ...". However no emission factors for Hg
are indicated in Table 3-44                         Noted      See earlier comment

In "Glossary" section the LPG are included into
"Gaseous fuels", while in Chapter 1A1, Table 3-2,              Changed changed to liquid
the LPG are considered as "Other liquid fuels"      Accepted   fuels
This glossary should either be expanded or
removed. Some listings in the glossary do not
appear previously in the text.                      Accepted   Done

References include only 2 sources.                  Noted      Revised
A lot of references in the text do not appear in the
list of references, e.g. CEPMEIP 2004, CITEPA
2007, Guidebook 2006, CITEPA &ENEA 2007, US
EPA 1998, US EPA 2000, US EPA 2003 etc.              Noted   Revised

Some general preliminary comment is necessary.
This section of the Guidebook and the related "old"
chapter are the most critical ones. In the past the
structure of the guidebook can give rise to double
count of emissions. The new Guidebook have to
resolve this problems, but this is not the case.
We have two kind of technologies:
- the SNAP Group 0301 Combustion in boilers,
gas turbines and stationary
- the SNAP Groups 0302 Process furnaces without
contact and 0303 Processes with contact
For the first group the conditions are very similar to
1.A.1. An very simple example is the following: in
the paper industry the main emissions arise from
drying processes in which water vapour is used;
this vapour come from a boiler, so the emission
from this boiler is very similar to emissions in 1.A.1.
Where these emissions are allocated? The only
"additional" non boilers emissions from 1.A.2 can
be emissions from evaporation of organic
substances used in paper manufacturing that can
evaporate in the drying process. The "new"
Guidebook don't take into account these last and
report EFs for combustion that can be different
from EF in 1.A.1. Then we have a lot of similar              Discussed with EP, tables
cases for example Combustion in Food Industry,               have been amended to
Mechanic Industry, ecc. What emissions factors? Accepted     clarify
The table contains some odd 0 values, I assume
this is due to the haste with which this document            Will change with new
appears to have been drafted.                                tables

CONCLUSION: The chapter is unacceptable! All                 Following discussion with
the documentation from BREF ignored also data                EP, Tier 1 is default
sent to consultant from EP leader! All the                   combustion only, Tier 2 is
recommendation in EP and from industry about no              generally only
separation between combustion and processes                  NOx/SOX/CO with balance
ignored. All the recommendation of use of product            of emissions assigned to
approach ignored.                                    Noted   the process chapters
In addition to this, industrial waste fuels cover a
wide variety of materials, as specified in page 6,
lines 35 and 36, with different characteristics and
composition, so it is not clear if the emission
factors proposed should be applied to all industrial         Waste factors now
waste fuels.                                         Noted   removed
Moreover, there are no emission factors proposed
for heavy metals, dioxins and furans and PAH, and
emissions for these pollutants are relevant when  Consult with Waste factors now
using industrial waste fuels.                     Expert Panel removed

                                                                  Following discussion with
                                                                  EP, Tier 1 is default
                                                                  combustion only, Tier 2 is
                                                                  generally only
Additionally, emission factors for SOx, NOx,                      NOx/SOX/CO with balance
NMVOC and CO are the same as for hard coal.          Consult with of emissions assigned to
Are these emission factors correct?                  Expert Panel the process chapters

                                                                  Following discussion with
In addition, the reference for emission factors is                EP, Tier 1 is default
Guidebook (2006), but the corresponding chapter                   combustion only, Tier 2 is
for SNAP 030313 only provides emission factors                    generally only
for particles. This comment is also valid for                     NOx/SOX/CO with balance
emission factors related to gas natural                           of emissions assigned to
consumption in Table 3-37.                           Noted        the process chapters

                                                                  Following discussion with
                                                                  EP, Tier 1 is default
                                                                  combustion only, Tier 2 is
                                                                  generally only
However, emission factors for particles in Tables 3-              NOx/SOX/CO with balance
36 and 3-37 seems to concern only fuel                            of emissions assigned to
consumption.                                         Noted        the process chapters

                                                                  Following discussion with
                                                                  EP, Tier 1 is default
                                                                  combustion only, Tier 2 is
                                                                  generally only
Taking into account that this is a process with                   NOx/SOX/CO with balance
contact, these particles emission factors are                     of emissions assigned to
probably underestimated.                             Noted        the process chapters

                                                                  Following discussion with
                                                                  EP, Tier 1 is default
                                                                  combustion only, Tier 2 is
                                                                  generally only
What is the difference between both tables? Where                 NOx/SOX/CO with balance
is the NMVOC emission factor for natural gas                      of emissions assigned to
combustion indicated?                             Noted           the process chapters

                                                                  Following discussion with
                                                                  EP, Tier 1 is default
                                                                  combustion only, Tier 2 is
                                                                  generally only
There are only two kind of fuels considered: Other                NOx/SOX/CO with balance
Liquid Fuels and Natural Gas. No reference is                     of emissions assigned to
made to other fuels like heavy fuel oil.             Noted        the process chapters
                                                                Following discussion with
                                                                EP, Tier 1 is default
                                                                combustion only, Tier 2 is
                                                                generally only
In addition, emission factors for Other Liquid Fuels            NOx/SOX/CO with balance
should be splitted for each fuel considered in this             of emissions assigned to
category (gas oil, LPG, ...)                         Noted      the process chapters

                                                                Following discussion with
                                                                EP, Tier 1 is default
Which emissions (combustion and/or process) are                 combustion only, Tier 2 is
considered in the emission factors proposed? In                 generally only
chapter 2.A.7.d, emission factors for heavy metals              NOx/SOX/CO with balance
and particulates are propposed (in terms of mass                of emissions assigned to
of pollutant per unit of production),                 Noted     the process chapters
and it is not clear if there is a risk of double
counting when applying both emission factors.         Noted     Text amended to clarify
What are the major changes since earlier                        Will outline the main
versions?                                             Noted     changes
Meaning of LTO-cycles 1?                              Noted     Needs correcting
Default methodology has been developped by
ICAO concerning APU cf. "Airport Air Quality                    Has been considered and
Guidance Manual" ICAO, April 2007. That could be                words added under
added within the GB, as far as the fuel used is the             "Auxillary power
aircraft kerozene.                                    Noted     operations" on p4 of SOD
Within the 2007 EMEP/CORINAIR Guidebook,
general information on APU and fuel dumping are                 Has been incorporated
provided that may be interesting to keep.             Noted     where appropriate
It must be emphasized, that military aviation is
classified as NFR code 1A5 (other) according to
agreed EMEP nomenclature.                             Noted     has been emphasised

Please distinguish between sources of emissions
belong under this NFR and other (e.g painting
belongs to another NFR and should not be ignored) Noted         has been emphasised
This should be explained in much more details,
and a table should be provided giving a thorough
overview of today's situation                      Accepted     Will expand explanation
Some elaboration on the grouping of NFR
categories for each reporting requirement would be
useful here.                                       Accepted     Will expand explanation
                                                                updated aviation emission
                                                                factors have been
                                                                discussed with MW
There is a lot of emission data for turboprops also.            (Expert Panel member)
Data for the most commonly engine fitted to                     and incorporated as
specific aircraft                                    Accepted   appropriate
                                                                         updated aviation emission
                                                                         factors have been
                                                                         discussed with MW
                                                                         (Expert Panel member)
Table 2.1, this table needs update as it is ten years                    and incorporated as
old, and new aircraft must be included                    Accepted       appropriate
Military is reporting under a different NFR, while it's
methodology is described here                             Accepted       has been emphasised
This paragraph was not included in the outline
agreed in Dessau. Furthermore if it is to be
included it must be updated with new numbers
from more recent references. Same with table 2.3                  J Goodwin consulted with
and 2.4. (the same comment applies to other          Consult with expert panel member
chapters including a similar paragraph)              Expert Panel (MW)
                                                                  updated the aviation
Table 2.2: There is more recent legislation for NOx.              emission regulations have
Please refer to the                                  Accepted     been included.
What Directive do you refer to?                      Accepted     Will expand explanation
                                                                  updated the aviation
Table 2.2. Isn't there more up to date information                emission regulations have
available?                                           Accepted     been included.

These tables 2-3 and 2-4, sould be completed with
tables relating to internationals emissions. Note :
international LTO emissions are part of national
NECD emissions, and important issues of emission
trends for aviation concern international aviation.                    J Goodwin consulted with
For international aviation emissions, e.g.                Consult with expert panel member
international/domestic ratios could be displayed.         Expert Panel (MW)
The Decision tree needs improving. Surely the first
2 diamond shaped white boxes are needed to use            Consult with
a tier 3 method.                                          Expert Panel
The decision tree is more less impossible to
understand. Please use the old decision tree as a         Consult with
basis for the Tier explanations.                          Expert Panel

Table 3-1 is a complete mess, and is basically            Consult with
wrong!                                                    Expert Panel has been modified
Footnoe 5, must be changed, it is copied from
IPCC (2006) and does not make sense in this
context                                                   Accepted       will reword
Please state where military aviation emissions
should be reported.                                       Noted          will reword
What do you mean by "not reported here". Military
aviation is a part of NFR 1A5b along with other
military mobile activities.                               Noted          will reword
This text is incomprehensible. Further, it is not in
line with the emission reporting Guidelines (for                         Text taken verbatim from
example multilateral operations are NOT excluded                         IPCC 2006, need to
from emission totals under LRTAP)                         Noted          consult with expert panel
This methodological description is not improving
the old "simple method" described in section 4-2 of
B851-13. It is assuming that inventory compiliers
know how to estimate emissions wothout
describing the process.                                Noted          has been modified
This is not possible to understand!                    Noted          has been modified
Some duplication of information with section 3.2.3
Activity data.                                         Noted          has been modified
Can the default emission factors (table3-3 for
domestic LTO) also be used non-IFR fligths
domestic LTO? It is not specified whether the
defaults are for IFR/VFR. We have an amount of
LTO for VFR flights (small aircrafts like
PA28,C152,…) and not the amount of flight hours
for VFR, and wonder if we can use table 3-3, 3-8       Consult with
and 3-9 for it.                                        Expert Panel

In table 3-3 (Tier 1 Default Fuel use in LTO),
second NFR source (domestic LTO) has as fuel :
jet kerosine. Is the value also valid for jet gasoline
& aviation gasoline fuel use? Or must there a value
be added for further use with tables 3-8 and 3-9?      Noted          has been modified

Is there no reference to these fuel consumption
EFs in Table 3-3. Also what is meant by kg/tonne
fuel in NFR 1.a.3.a.i(ii). Should it not be kg/LTO?    Noted          has been modified
Information on HM/POPs are missing. Please cite
the origin (source) of emission factors from the
EMEP-C, emission factors must be tracable
(comment applies to many chapters). Furthermore
Tier 1 emission factors must be updated, a lot has
been changed since these Tier 1 emission factors                      EFs have been included
were derived                                           Noted          where available
I'm not sure that a reference to an EF should be
"Calc from Tier 2" in Tables 3-8 and 3-9. This could
be described better.                                   Noted          has been modified
Aviation gasoline is added substantial amounts of                     EFs have been included
lead, please provide information                       Noted          where available
Data available and necessary to apply Tier 2
method sould be specified. 'The algorithms
paragraph 3.3.1 is not detailed enough. Some
components of such step by step algorithms is                       has been modified in
given but in EF paragraph 3.3.2. A global overview     Consult with consultation with expert
of the algoritms is missing.                           Expert Panel panel member MW

The Tier 2 method should promote using fuel sold
statistics : separately domestic and international
fuel sold when available. If these separate fuel sold
statistics are not available, then estimation method               has been modified in
could be used to split domestic and international     Consult with consultation with expert
fuel consumption, as presented in step 1.             Expert Panel panel member MW
It is strange to recommand to use Tier 3 EF within
a Tier 2 method. Furthermore, in case of using Tier
2 method, data on cruise distances per aircrafft                  has been modified in
type are generally not available for using Tier 3 EF Consult with consultation with expert
(distance dependant).                                Expert Panel panel member MW
                                                                  has been modified in
The link of theses lines with paragraph 3.3.3                     consultation with expert
Activity data is not clear.                          Noted        panel member MW
Can emissions factors for airplane types that are
disappeared referred to older versions of the                     EFs used have been
guidebook still be used from older versions (for     Consult with discussed with expert
example Concorde in 1996 guidelines)?                Expert Panel panel member, MW

Where does the data in this table originate from?   Noted          has been modified




The Tier 2 method is completely wrong! This                        has been modified in
method cannot use mission distance based factors Consult with consultation with expert
for cruise - this relates to Tier 3!                  Expert Panel panel member MW
                                                                   has been modified in
                                                                   consultation with expert
Please provide some method description for Tier 2. Noted           panel member MW
                                                                   has been modified in
In the last part of the box, reference to the EFDB is              consultation with expert
made, however there is no EFDB for air pollutants! Noted           panel member MW
                                                                   has been modified in
Footnote 8, this assumption should be reviewed                     consultation with expert
due to more recent knowledge                          Noted        panel member MW
Table 3-11: It is not acceptable to use the emission               has been modified in
factors for LTO provided by the IPCC 2006             Consult with consultation with expert
guidelines                                            Expert Panel panel member MW
table 3-11: Footnote (3) does not appear below;                    has been modified in
there (2) apperas twice. - Please change the 2nd                   consultation with expert
(2) into (3).                                         Editorial    panel member MW
Please check if this table has been updated with                    has been modified in
more recent aircraft and make corrections as                        consultation with expert
appropriate                                              Accepted   panel member MW
                                                                    has been modified in
This paragraph should be more detailed, especially                  consultation with expert
the link with the steps displayed in 3.3.2.         Noted           panel member MW
Why is military described here in section 3.3.5? In
with the Tier 2 method? There is no mention of
military under the Tier 3 method.                   Noted           will clarify
Table 3.14. Source?                                 Noted           will reference

What is the minimum flown distance for an airplane                  These data are taken
to reach cruise level? Table 3-15 starts at 125 nm.                 verbatim from earlier
It means dat below 125 nm, an airplane is not                       versions of the guidebook -
cruising yet (in normal average conditions)?        Noted           refer to expert panel
In general the method choice and description
should preceed the EF tables. Section 3.4.2 on Tier
3 EFs is on page 25 whilst section 3.4.3.1 on Tier
3A method is on page 29. This makes the chapter                     Have re-organised EF
very difficult to read.                             Noted           tables
Please explain where the remainer Tier 3 emission
factors can be found (currently they are available
as a spreadhseet download)                          Noted           will continue to be
                                                                    These data are taken
                                                                    verbatim from earlier
There are no cruise emission factors published on                   versions of the guidebook -
the ICAO website.                                 Noted             refer to expert panel
The sentence is diffucult to understand.          Noted             will clarify
                                                                    Have asked author of
Where is the table 3.10 ?                                Noted      previous guidebook
This is not possible to follow, what has it to do with
engine independent emission factors? And where                      should be aircraft type -
is Appendix 1?                                           Noted      Appendix 1 is unaltered
It is both turbo fan and turbo prop engines.             Noted      should be altered
For non-IFR flights, we still use emission factors
from EPA, AP-42 volume II (1985). Can they still be
used? Why are they not included as reference                    has been modified in
default emission factors (instead of calculating   Consult with consultation with expert
nothing) ?                                         Expert Panel panel member MW
                                                                has been modified in
These method descriptions in sections 3.4.3.1 to                consultation with expert
3.4.3.3 should be on page 24 before the EF tables. Noted        panel member MW

The note provides considerations on energy
balance for domestic aviation. Similar
considerations on energy balance for international
aviation sould be also included (taking into account
that in case of international aviation, half of                     has been modified in
international fuel consumption should be compared                   consultation with expert
to fuel sold in the country for international flights). Accepted    panel member MW
                                                                    has been modified in
                                                                    consultation with expert
These are very old data, please update                   Accepted   panel member MW
This section 4.4 has nothing to do with consistent
time series and recalculation! It is simply copy and
paste from the old chapter section 3.6                              has been modified in
"Projections": Even the title has been changed to fit               consultation with expert
the misplaced content.                                   Accepted   panel member MW
This information (including the tables) appears
outdatet. What is for example "current level" in                    has been discussed with
Table 4-1? Please update or rewrite                      Accepted   expert panel member MW
It is indeed suprising that there is no specific issue
here given the complexity of reporting this category
(e.g. differences betwee UNFCCC, LRTAP and
NEC reporting), memo items etc. (same remark to
navigation/shipping chapter)                             Accepted   Will include Description
                                                                    Not changed - taken
                                                                    verbatim from previous
What other sources? It is essential to explain                      version of the guidbook.
where the data comes from                                Noted      Refer to expert panel

What is the difference between Annex B and Table                    has been discussed with
3-11? Are both needed?                           Noted              expert panel member MW
A large number of references in this chapter are
not found in the reference list. (including IPCC
(2006) which the method is based on!)            Noted              will clarify
                                                                    has been modified in
Please also include Tier 2 cruise emission factors                  consultation with expert
(else the method will not work)                          Accepted   panel member MW

Please refer also to general comments                               has been modified in
summarised in the separate word file "DK Review                     consultation with expert
of guidebook chapters for mobile sources.doc"            Accepted   panel member MW
                                                                    has been modified in
Even more important, a lot of references and                        consultation with expert
explanations how data are obtained, are missing.         Accepted   panel member MW
All military mobile activities (aviation, land based
and sailing activities) are classified as 1A5b                   has been modified in
(equivalent to SNAP code 0801) according to         Consult with consultation with expert
EMEP.                                               Expert Panel panel member MW
                                                                 has been modified in
data are available from the current guidebook, both Consult with consultation with expert
for LTO and cruise distance classes                 Expert Panel panel member MW
                                                                 has been modified in
                                                    Consult with consultation with expert
ICAO website.                                       Expert Panel panel member MW
                                                                 has been modified in
                                                    Consult with consultation with expert
in the Tables 3-4 and 3-5 is preferable.            Expert Panel panel member MW
                                                                 has been modified in
Please use the simple method description directly Consult with consultation with expert
from the old guidebook.                             Expert Panel panel member MW
These LTO factors are not supported by new                          has been modified in
cruise emf related to distances, as in the current     Consult with consultation with expert
guidebook version.                                     Expert Panel panel member MW
                                                                    has been modified in
Moreover, looking into the IPCC guidelines the         Consult with consultation with expert
LTO factors are very poorly documented.                Expert Panel panel member MW

If we use the IPCC data, we loose the consistency              has been modified in
with cruise factors per distance class, and for   Consult with consultation with expert
species like NOx, NMVOC and CO                    Expert Panel panel member MW
cruise factors heavily depend on the actual                    has been modified in
aircraft/engine combination. In some countries,   Consult with consultation with expert
detailed city-pair inventories                    Expert Panel panel member MW
 are made each year using distances between                    has been modified in
airports, and for these countries such new data   Consult with consultation with expert
gives less meaning.                               Expert Panel panel member MW
So, the strong recommendation is to maintain the               has been modified in
                                                  Consult with consultation with expert
"old" LTO (and cruise) emf in order not to introduce
errors into the inventories.                      Expert Panel panel member MW
                                                               has been modified in
The data come from specific simulations made by Consult with consultation with expert
aircraft emission experts.                        Expert Panel panel member MW
                                                               has been modified in
and the approach used to obtain the data that is  Consult with consultation with expert
presented in the guidebook.                       Expert Panel panel member MW
The schematic diagram (Figure 4.1) in the chapter              has been modified in
B851 in the Guidebook should be retained in the   Consult with consultation with expert
new chapter.                                      Expert Panel panel member MW
Title of chapter should include a reference to
buses, ie HDVs and buses instead of "heavy-duty
trucks".                                          Accepted     Corrected
What is the difference between 'Overview' and                  General Description is part
'General description'?                            Noted        of the Overview.
These paragraphs are rather badly written, and
could be improved.                                Noted        Corrected
Badly written.                                    Noted        Corrected

                                                                     Rejected because this
                                                                     phrase was taken verbatim
                                                                     from existing guidebook,
Poorly phrased.                                        Noted         see B710-1 in pdf version
Badly written, and difficult to follow.                Noted         Changed

What is section 4? The sentence gives no meaning Noted               Sorted
                                                                     The EEA include CO in
                                                                     their definition of Ozone
                                                                     Precursor
                                                                     http://glossary.eea.europa.
                                                                     eu/EEAGlossary/O/ozone_
CO is not an Ozone Precursor                           Rejected      precursor
Delete 'mobile'. Change 'transportation' to
'transport' (throughout).Change 'vehicles' to
'vehicle'.                                               Accepted    Corrected
Why 'on-road'? The whole chapter refers to road
vehicles.                                                Noted       Corrected
Emissions from exhaust aftertreatment? This is
nonsense.                                                Noted       Corrected

                                                                Rejected because this
                                                                phrase was taken verbatim
Change to 'The most important pollutants from      Consult with from existing guidebook,
road vehicles are covered…'.                       Expert Panel see B710-1 in pdf version
                                                                The existing guidebook
                                                                says it is the 5th update,
                                                                see B710-2 in pdf version.
                                                                These lines merely reflect
What is the relationship to COPERT? If it has been              these words - no change
updated five times why are we now at COPERT 4? Noted            made.
Where is this reference?                           Noted        Corrected
Should read 'three-tier'.                          Noted        Corrected
                                                                Will clarify & align with
The section 2.1 title is not helpful.              Noted        transport terminology
What is meant by 'positively ignite'?              Noted        Corrected
Which process? One of the combustion
processes? Figure 2-1 does not show combustion
processes.                                         Noted        Corrected

                                                                     used to conceptualise the
                                                                     boundaries of road
                                                                     transport emissions, and is
                                                                     an approach adopted
Figure 2-1 is poor. What purpose does it serve?          Rejected    throughout the Guidebook.
Figure 2-1 gives no information.                         Noted       Corrected
This reference is wrong.                                 Editorial   Sorted
It is written that for Tier 1 uses fuel as activity
indicator with average fuel specific emission
factors. But then in the table 3-2-3.9Ef are g/GJ        Accepted    Sorted
Where is Table 2-1?                                      Editorial   Sorted
Where is the Tables 4-7 to 4-29?                         Editorial   Sorted

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

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

Tables 3.2 to 3.9 present emission factors in g/GJ.
First, the methodology in p.7 is in g/kg. Second, the
values are wrong (they should be ~5 times higher).
I understand the editors try to be consistent with
IPCC. On the other hand, Eurostat data report all
values in tonnes that can be readily converted to
kg, without knowing the energy content of fuel. In
addition, methodologies Tier 2 and Tier 3 calculate
total fuel consumption in kg so why having Tier 1 in
GJ? Third, emission values in g/kg fuel are
widespread and are published in scientific literature
so the reader can compare them to the Guidebook
values. All models (Copert, Artemis, even Verit+ in
the Netherlands) use fuel mass values. Heavy
metals and sulfur are all reported per mass of fuel.
The user of any methodology needs now to convert
them to GJ! I know of no source that reports
emission in g/GJ except for GHGs. But even in the                    Sorted - after discussions
2006 IPCC Guidelines, N2O and CH4 emission                           with Expert Panel we have
factors for US and Europe are in mg/km. In                           reverted back to
summary, I find the expression g/GJ awkward and                      expressing emission
not practical and I strongly reccomend this to be     Consult with   factors in units of g/tonne
changed back to g/kg fuel.                            Expert Panel   fuel

Tables 3.2 to 3.9 also include emissions of SOx
and heavy metals and make reference to Tables 4-
XXX. First, as the draft chapter stands now, these
tables are A.XXX and not 4.XXX, but please also
check my comment below related to the structure
of the chapter. Second, why should we provide a
default SOx emission factor (equivalent to 40 ppm
S in fuel) when S content of fuel is known in each                   Referencing to tables will
country? None of the countries (except Bulgaria)                     be corrected. Also
that are going to use a Tier 1 methodology have                      comment will be
average sulfur of 40 ppm!!!! I reccomend we                          addressed to include a
introduce the very simple methodology (two rows)                     flexible S content variable
given in section A.6.9 as part of Tier 1 as well. This               with a default if none is
is all it takes to have the correct estimation of SOx. Accepted      known.
Tables 3-2 to 3-9 include Default EFs Tier1. The
unit used is g/GJ, instead og g/kg of fuel used. It                   Sorted - after discussions
may be worth including both EFs by GY and kg in                       with Expert Panel we have
the final guidebook and a description of the                          reverted back to
calculation from one to the other.. Also I think the                  expressing emission
reference AUT 2008 needs to be clarified (exactly        Consult with factors in units of g/tonne
a reference to which report?)                            Expert Panel fuel
units for Cd and Pb in table 3-5 are missing.            Accepted     Sorted
unit for Cd in table 3-6 are missing.                    Accepted     Sorted
unit for Cd in table 3-7 are missing.                    Accepted     Sorted
units for Cd and Pb in table 3-9 are missing.            Accepted     Sorted
table 3-9: unit for Cd and Pb missing                    Accepted     Sorted
All these Tables 3-11 to 3-38 contain EFs for Tier
2. What is the reference for these EFs?                  Editorial     Corrected
Where is Table 4-6?                                      Editorial     Sorted
Tier 2 method gives EFs by technology, however
these technologies are not provided until the
Appendix to this FOD.                                    Accepted      Sorted

Tables 3-11 to 3.38 contain the statement "grams
of international toxic equivalent" for DIOX and no
values. There are such values in Table A.101.            Accepted      Corrected

                                                                       Changed - comment
For heavy duty trucks, so many size classe and                         added regarding what to
technology combinations are missing in terms of   Consult with         use for "missing" size/
Tier 2 emission factors.                          Expert Panel         technology combinations.
Table 3-39 is a good summary. I do not understand
why this is only specific to FC and what are the                       Corrected It's use has
uses it intents to cover.                         Noted                been clarified in the text.

                                                                       Rejected because this
                                                                       phrase was taken verbatim
"By applying a trial-and-error-approach..." This                       from existing guidebook,
sentence is meaningless!                                 Accepted      see B710-37 in pdf version
where is section 4.3.3?                                  Editorial     Sorted
There is no discussion in section 4.3.3!                 Editorial     Sorted
It is a very wrong decision to let Tier 3 be described
in an Annex. Tier 3 is what many countries use
now.                                                     Accepted      Sorted
It is very important that this Tier 3 method has a
proper description and overview in the actual
chapter as does the Tier 1 & 2 methods. This
method is the most used method by inventory
compiliers and should not be discussed in an
Appendix.                                                Accepted      Sorted
                                                                  Heading changed to reflect
                                                                  text provided - now no
The text in Section 4.4 has nothing to do with                    section on "developing a
consistent time series and recalculation! It is just              consistent time series" -
copy and paste of Section 13 "Temporal                            Need to decide on the
disaggregation criteria" from the old chapter.         Accepted   extent of text neded on this
The problem of "tank tourism" it is not mentioned. If
it is relevant, fuel balance, as explained here, could
not be applied.                                        Accepted   Will be refered to..

                                                                  Rejected because this
                                                                  phrase was taken verbatim
                                                                  from existing guidebook,
References are not old?                               Accepted    see B710-41 in pdf version
                                                                  Where available data will
                                                                  be included. These data
                                                                  were taken verbatim from
                                                                  Table 10-3 of previous
                                                                  guidebook. Analogous
This kind of table could be very useful. Why don't                data for other pollutants
put information on the other pollutants?              Accepted    was not provided.
                                                                  COPERT 4 is a software
                                                                  tool outside the scope of
                                                                  this Guidebook revision.
                                                                  This question will be
Will be the emission factors for buses CNG                        forwarded to the team at
included into the COPERT IV?                          Accepted    Artistotle University.
Reference to Table 4-1 is wrong.                      Editorial   Sorted
There is no Table 2-1 in the chapter                  Editorial   Sorted
                                                                  The EEA include CO in
                                                                  their definition of Ozone
                                                                  Precursor
                                                                  http://glossary.eea.europa.
                                                                  eu/EEAGlossary/O/ozone_
CO is not an Ozone Precursor                          Rejected    precursor

Section A.2 is not part of the Tier 3 methodology
and it is ok to remain as an Annex. However, in
other chapters (e.g. non-exhaust PM emissions,
evaporation) the sections referring to the
contribution of the sector to total emissions are
provided as introductory sections before presenting
the Tier 1 methodology. So, please be consistent
between chapters, where you want this section to
be presented (annex or introduction).               Accepted      Sorted

Section A.3 should be part of Tier 1 methodology
because it just provides definitions of the vehicle
classes considered. Section A.4 should be part of
Tier 2 methodology because Tier 2 already uses
the emission standards classification.                Accepted    Sorted
                                                                 Rejected for this version
                                                                 because this phrase was
Metodology does not estimate in which category                   taken verbatim from
should be included tracotrs with registration                    existing guidebook -
number (vehicles). These can not drive on                        comment will be passed to
motorway.                                           Accepted     AUT.

                                                                 Rejected because the
                                                                 guidance we have received
                                                                 is that the existing detailed
                                                                 methodology text should
Table A.7 now offers no new information and                      not be changed much at
needs to be erased.                                 Accepted     all.
Indeed the current section A.6 should follow as the
next section, after A.1                             Accepted     See above

Check format of Figure A.2. The text on the left-
most boxes should be vertical and not horizontal.   Editorial      Sorted
                                                                   Rejected for this version
The sentence is not coherent with the table A.53.                  because this phrase was
The sentence must be "However, some additional                     taken verbatim from
reductions need to be applied for vehicle                          existing guidebook -
technologies post-Euro 4 (RFij), which are given in                comment will be passed to
Table A. 53"                                          Editorial    AUT.
                                                                   Rejected for this version
                                                                   because this phrase was
                                                                   taken verbatim from
In the equation (27) replace eHOT;i,Euro1 by                       existing guidebook -
eHOT;i,Euro4 to be coherent with table A.53 and                    comment will be passed to
Rfij factors                                          Editorial    AUT.
                                                                   Rejected for this version
                                                                   because this phrase was
                                                                   taken verbatim from
The "ehot;i,Euro 1" value in eq. 27 should be                      existing guidebook -
replaced with "ehot;i,Euro 4". the "ecold/ehot|i,Euro              comment will be passed to
1" value should remain intact.                        Editorial    AUT.
                                                                   Rejected for this version
                                                                   because this phrase was
                                                                   taken verbatim from
                                                                   existing guidebook -
It is not possible to distinguish between mopeds 2 Consult with comment will be passed to
and 4 strokes?                                        Expert Panel AUT.
                                                                   Rejected for this version
                                                                   because this phrase was
                                                                   taken verbatim from
table A.77, A.78, A.79, A.80 e A.81 it is not                      existing guidebook -
possible to define the emission factors in term of    Consult with comment will be passed to
emission legislation?                                 Expert Panel AUT.

Please refer also to general comments
summarised in the separate word file "DK Review                  Comments have been
of guidebook chapters for mobile sources.doc"       Noted        considered.
                                                                  See also comment 284 -
                                                                  Changed - comment
                                                                  added regarding what to
Up to Euro IV: The vehicle categories 7,5-12 & 14-                use for "missing" size/
20 & 26-32 tons are missing.                       Noted          technology combinations.

                                                                  See also comment 284 -
                                                                  Changed - comment
                                                                  added regarding what to
For newer technologies: The vehicle categories 7,5-               use for "missing" size/
20 & 26-32 tons are missing.                        Noted         technology combinations.
In general the Annex, who is supposed to treat Tier
3, also repeats the data used for the old simple
method.                                             Noted         Sorted

                                                                 Heading changed to reflect
                                                                 text provided - now no
                                                                 section on "developing a
                                                                 consistent time series" -
The old chapter discusses how to treat emission     Consult with Need to decide on the
inventories in relation to dispersion models.       Expert Panel extent of text neded on this

THE TIER 3 METHODOLOGY MUST NOT BE
INTRODUCED AS AN ANNEX BUT AS SECTION
3.4, AS ORIGINALLY FORESEEN. NOW THE
WHOLE CHAPTER IS A MESS! ALL SECTIONS
IN CHAPTER 4 DISCUSS ISSUES OF TIER 3
METHODOLOGY (THEY ARE A COPY OF THE
PREVIOUS VERSION OF THE GUIDEBOOK)
AND TIER 3 IS ONLY INTRODUCED IN THE
ANNEX. MOST REFERENCES REFER TO THE
TIER 3 METHOD AND THE TIER 3 IS
INTRODUCED AFTER THE REFERENCES AS
AN ANNEX! IT IS POINTLESS TO MAKE A
DETAILED REVIEW AS THE CHAPTER IS SO
BADLY WRITTEN AND STRUCTURED THAT IS
MAKES NO SENSE.                       Accepted                    Sorted

The chapter makes a lot of references to sections
and tables 4.x. These do not exist because Tier 3
has been annexed. These need not be changed
when the editors correct the chapter per my
reccomendation above. However, there are many
erronous references to tables and figures as the
draft version stands now.                           Accepted     Sorted
In all Tier tables for the road transport not       Consult with
applicable would be POPsAnnex I                     Expert Panel
The general description and overview could
perhaps include tables 1.1 and 1.2 from the
Guidebook B710-3.                                   Accepted      Sorted
There is no reference to classification of vehicles
such as in the Guidebook table 3.1 B710-7 and
Table 3.6 B710-16. All of this information is
relevant regardless of which Tier approach is used
by inventory compiliers and should be included in                      Accepted - cross reference
the chapter overview or description.                Accepted           included

General comment. This chapter needs major
restructuring. All vehicle classifications, legislation
(as described in B710-13 to B710-16) should be
included in the text of the chapter before
discussion of the different Tier method (1,2 and 3).
Improvements are also needed in referencing EF
tables and if changes are made to EF units these
should be explained clearly. Also there is no bulk
CS EFs based on the 2002 work which could be
useful for a Tier 1 method. There is no discussion
of the contribution road transport makes to total
national emissions.                                     Accepted       Sorted
Subsections 6.1 and 6.2 should occur in the same
order as the title of Section 6. In addition, the level
3 sections in the report are missing from the table
of contents.                                            Editorial      Sorted

This paragraph could read a little better.                noted        Revised
                                                                       Not changed because this
                                                                       was taken verbatim from
This paragraph is poorly constructed and not well                      previous Guidebook
phrased. How do breathing losses relate to diurnal                     version B760(2007)
emissions, hot soak losses and running losses? Do                      Section 3.1. Will pass
we need to use both 'losses' and 'emissions'? Just                     comment on to Expert
use 'emissions'.                                          Accepted     Panel
                                                                       Not changed because this
                                                                       was taken verbatim from
The last sentence of the para ought to be the first.                   previous Guidebook
Again. How do 'breathing losses' relate to the                         version B760(2007)
sources mentioned. My understanding is that this is                    Section 3.1. Will pass
a part of the process which leads to diurnal                           comment on to Expert
emissions.                                                Accepted     Panel
                                                                       Not changed because this
                                                                       was taken verbatim from
                                                                       previous Guidebook
                                                                       version B760(2007) page
                                                                       1. Will pass comment on
Explain what carbon canisters are.                        Accepted     to Expert Panel
                                                                       Could be made more
                                                                       transport specific.
Process description' is not a good title in my view. It                However, might detract
is too vague. I also think that it more or less           Consult with from a common guidebook
repeats title 2, and would therefore delete it.           Expert Panel style.
Figure 2-1 is poor. It could show the different
evaporative sources much more clearly (i.e. picture
of vehicle, with diurnal losses, hot soak losses and
running losses explained).                           Accepted     Revised

Maybe worth adding that some studies have                         Not changed because this
identified 'resting emissions' as a separate                      was taken verbatim from
evaporative source. These result from diffusion,                  previous Guidebook
permeation, seepage and minor liquid leaks, and                   version B760(2007)
do not need an increase in fuel temperature to                    Section 3.1.3. Will pass
occur. Here, I assume that these are already                      comment on to Expert
included in the hot-soak and diurnal calculations?   Accepted     Panel

Poorly written. Should begin 'Diurnal losses are…'.
Can I offer something like this >> The increase in
ambient temperature which occurs during the
daylight hours results in the thermal expansion of
the fuel and vapour in the petrol tank. Without an
evaporation control system, some of the increased
volume of fuel vapour is vented to the atmosphere.
At night, when the temperature drops, the vapour                  Not changed because this
contracts and fresh air is drawn into the petrol tank             was taken verbatim from
through the vent. This lowers the concentration of                previous Guidebook
hydrocarbons in the vapour space above the liquid                 version B760(2007)
petrol, which subsequently leads to additional                    Section 3.1.1. Will pass
evaporation. The overall mechanism is also known                  comment on to Expert
as „tank breathing‟.                                  Accepted    Panel
Again, the wording could be better. Aren't running
losses are defined as something like 'the                         Not changed because this
evaporative emissions which occur whilst a vehicle                was taken verbatim from
is being driven'? There is always vapour in the fuel              previous Guidebook
tank. Are we talking about additional vapour?                     version B760(2007)
Surely there is an increase in the fuel temperature               Section 3.1.2. Will pass
for all vehicle types (e.g. heat from engine and                  comment on to Expert
exhaust)?                                             Editorial   Panel
                                                                  Not changed because this
                                                                  was taken verbatim from
                                                                  previous Guidebook
Does this para refer to vehicle refuelling, fuel                  version B760(2007)
delivery, or both. It shoul dbe clearer. Here, it says            Section 3.1.3. Will pass
'petrol stations'. I'm not sure whether 'gasoline                 comment on to Expert
stations' even exists in US English.                   Accepted   Panel
                                                                  Not changed because this
                                                                  was taken verbatim from
                                                                  previous Guidebook
                                                                  version B760(2007) text in
In the line 4 we can read: "Without an emission                   section 2.2.1. Will pass
control system, some of the increasing volume of                  comment on to Expert
fuel vapor is vented to atmosphere"                  Editorial    Panel
                                                                   Not changed because this
                                                                   was taken verbatim from
                                                                   previous Guidebook
                                                                   version B760(2007) text in
Change to '…at the same level. However, the test                   section 3.3. Will pass
procedure for evaporative emissions increased in                   comment on to Expert
severity'.                                            Editorial    Panel
                                                                   Not changed because this
                                                                   was taken verbatim from
                                                                   previous Guidebook
In general, would prefer the UK English 'petrol' to                version B760(2007). Will
the US English 'gasoline'. Please use the term 'fuel               pass comment on to
tank' instead of 'gasoline tank'.                    Editorial     Expert Panel
                                                                   Not changed because this
                                                                   was taken verbatim from
                                                                   previous Guidebook
                                                                   version B760(2007)
Change to 'Hot-soak emissions occur when …'.                       Section 3.1.3. Will pass
'Hot-soak' should be hyphenated when used                          comment on to Expert
immediately before 'emissions'.                       Editorial    Panel

                                                                   Not changed because this
                                                                   was the heading used in
                                                                   the Guidebook version
                                                                   B760(2007) Heading 3.2.
What is the meaning of the Section 2.3 title. It is   Consult with Will pass comment on to
very vague.                                           Expert Panel Expert Panel
                                                                   Not changed because this
                                                                   was taken verbatim from
                                                                   previous Guidebook
                                                                   version B760(2007) text in
The first sentence is unclear. What does it mean?                  section 3.2. Will pass
The distinction between VOCs and NMVOCs also                       comment on to Expert
needs to be better explained.                         Accepted     Panel
                                                                   Not changed because this
                                                                   was taken verbatim from
                                                                   previous Guidebook
                                                                   version B760(2007) text in
                                                                   section 3.2. Will pass
                                                                   comment on to Expert
CH2.1 is not a unit. Tank breathing again.            Editorial    Panel

                                                               Not changed because this
                                                               was the heading used in
                                                               the Guidebook version
                                                               B760(2007) Heading 3.3.
Again, the Section heading (2.4) needs to be more Consult with Will pass comment on to
informative.                                      Expert Panel Expert Panel
                                                                  Not changed because this
                                                                  was taken verbatim from
                                                                  previous Guidebook
                                                                  version B760(2007) text in
                                                                  section 3.3. Will pass
                                                                  comment on to Expert
Explain 'SHED'.                                        Accepted   Panel
                                                                  Not changed because this
                                                                  was taken verbatim from
Table 2-1: In Spain, the percentage contribution of               previous Guidebook
the evaporative emissions to the total emissions                  version B760(2007) Table
from road transport in year 2006 was not 9%, it                   2-1. Will pass comment
was 32.7%                                           Accepted      on to Expert Panel
                                                                  Not changed because this
                                                                  was taken verbatim from
                                                                  previous Guidebook
                                                                  version B760(2007) text
                                                                  iimmediately above Table
                                                                  2-1. Will pass comment
Explain what TREMOVE is.                               Accepted   on to Expert Panel
                                                                  Not changed because this
                                                                  was taken verbatim from
Some explanation of this Table would be useful.                   previous Guidebook
For example, why are evaporative emissions                        version B760(2007) page
proportionally higher in colder countries than in                 1. Will pass comment on
hotter countries?                                  Accepted       to Expert Panel
This is very poor. It does not even relate to road
transport. The terms below the equation do not
match those in the equation, and no units are
given.                                             Accepted       Sorted
What a mess!: This is not the Tier 1 approach for
evaporation. You use words like "small combustion
installations" and "lime production".              Accepted       Sorted

In the decision tree from figure 3.1 the text in the
first and second rhomboidal boxes is the same          Accepted   Corrected
What is the sense in this chapter of "The Tier 1
approach for process emissions from small
combustion installations ...!                          Accepted   Sorted
We can read: ARproduction = the activity rate for
the lime production!                                   Accepted   Sorted
We think it should say "fuel consumption" not "fuel
sales"; "fuel sales" could be a good proxy for "fuel
consumption" but It is not the same                    Accepted   Sorted

The activity rate for lime production            Accepted         Sorted
Tiers classification. Comments are summarized in
separate Word document                           Noted            Sorted
Decision tree. This is rather poor. The first two
'decisions' contain the same question. In the third
'decision', how is a 'key source' defined? If evap. Is
identified as a key source then data collection is
recommended. However, the user is then directed                      Decision tree revised
to Tier 2. Why not Tier 3, as the requirements for                   markedly to reflect the
Tier 3 appear to be fulfilled?. The Figure title                     different tiers, and activity
appears twice.                                            Accepted   data, required for each
The decision tree is wrong: If the answer is "No"
right after start, then you are lead to the same
question one more time.                                   Accepted   Sorted
Section 3.2.1 is copied from lime production and
does not refer to evaporation                             Accepted   Sorted
Figure 3-1 has two identical diamonds for Tier 3
and Tier 2                                                Accepted   Corrected
It is questionable if the data in Tables 3-1 to 3-5 are
sound. It is recommended to let the original data
suppliers make such aggregated figures.                   Noted      Sorted
I would imagine that data on fuel sales and data on
vehicle licensing statistics are kept by different
organisations.                                            Noted      Sorted

Whay 'default'. Can these be changed by the user? Noted         Sorted
The Tier 1 method proposes evaporation factors in
the form g/kg fuel consumed. This was never
agreed in the Transport Panel so it has to be
discussed. The Tier 1 method proposed by the
transport panel only required the total number of
cars and trucks operating on gasoline, a
temperature range relevant for the country
concerned and the DVPE value of the fuel. All this
is information that exists in each country. The
problem now with Tier 1 is that there is no
temperature effect and, therefore, evaporation
emissions in Ukraine will be equal to emissions in
Algeria! Whatever the method we agree, a
temperature correction needs to be introduced for
the emission factor. Ambient temperature is not    Consult with
difficult to find in any country!                  Expert Panel Sorted
The Tier 2 method proposes evaporation factors in
the form g/kg fuel consumed. This was never
discussed in the Transport Panel. The editors
should have at least consulted with the transport
panel if they wanted to change something from
what was agreed. In fact the Tier 2 method
proposed is totally anachronistic and is clearly a
scientific degradation of the Guidebook. The simple
methodology that was proposed in the previous
Guidebook is still the original method developed by
the CORINAIR 1985 working group and most
member states work with it. I strongly reccomend
that the simple method of the previous guidebook Consult with
is used as a Tier 2.                                 Expert Panel Sorted
Tables 3-2 to 3-5. Explain 'DVPE'. The names of
chemicals do not take capital letters. Should be
'polycyclic aromatic hydrocarbons'. Some of cell
contents are cut off                                 Accepted     Amended
                                                                  Not changed because this
                                                                  was taken verbatim from
                                                                  previous Guidebook
                                                                  version B760(2007)
The use of the words 'hot', 'warm' and ;cold' in the              Simpler methodology. Will
terms of the equations is confusing. These need to                pass comment on to
be explained.                                        Accepted     Expert Panel
I would imagine that data on fuel sales and data on
vehicle licensing statistics are kept by different
organisations.                                       Accepted     Sorted
                                                                  Not changed because this
                                                                  was taken verbatim from
                                                                  previous Guidebook
I assume that what we want to calculate is the total              version B760(2007)
national emission. For this, you need to sum over                 Equation 1. Will pass
all vehicle categories (Nj). This needs to be                     comment on to Expert
incorporated into the equation.                      Accepted     Panel
                                                                  Not changed because this
                                                                  was taken verbatim from
                                                                  previous Guidebook
                                                                  version B760(2007)
                                                                  Equation 1. Will pass
For consistency with HS and R, why are diurnal                    comment on to Expert
emissions not referred to as 'D'?                    Rejected     Panel

It is not entirely clear what a vehicle catgory ('j')
actually is. Is it a Euro standard? My first thought             Not changed because this
was that it related to the descriptions in Tables 3-6            was taken verbatim from
and 3-7, but the problem would then be not having                previous Guidebook
the activity data for these categories. Maybe this is            version B760(2007)
why you include Table 3-11, but I don't think that it            Simpler methodology. Will
is stated explicity. The links between Tables 3-6/3-             pass comment on to
7 and 3-11 should be stated explicitly.               Accepted   Expert Panel
The Tier 3 method proposed is a collation of the
simple and detailed methodology of the 'old'
Guidebook with a mix-up of the emission factors.
As it stands now, the whole chapter is a mess and
it is impossible to review point by point. Simply put,
the Tier 3 text provided makes no sense.               Accepted    Sorted
                                                                   Not changed because this
Cold and warm soak/running emissions. According                    was taken verbatim from
to Equations (2) and (3), these only appear to apply               previous Guidebook
to vehicles with a carburettor. These are likely to be             version B760(2007)
pre-Euro 1 and uncontrolled (i.e. no canister). So                 Simpler methodology. Will
why are there lots of emission factors for controlled Consult with pass comment on to
vehicles in Table 3-6? This shoul dbe explained.      Expert Panel Expert Panel
Petrol cars are separated according to whether
they have fuel injection or a carburettor, and hence
the parameter 'c' (the fraction of vehicles eqipped                Not changed because this
with a carburettor) needs to be defined. I assume                  was taken verbatim from
that this is just for pre-Euro 1 vehicles (and                     previous Guidebook
possibly Euro 1). Bearing in mind the requirement                  version B760(2007)
to combine Tables 3-6 and 3-11, statistics on the                  Simpler methodology. Will
fractions by Euro standard should be given to                      pass comment on to
users.                                                 Accepted    Expert Panel
                                                                   Not changed because this
                                                                   was taken verbatim from
                                                                   previous Guidebook
                                                                   version B760(2007)
                                                                   Simpler methodology. Will
Is the vaopur pressure required? It appears that it   Consult with pass comment on to
isn‟t used.                                           Expert Panel Expert Panel
The reference to the Table which contains parking
duration distributions (and the Table itself) appears
too early in the Chapter. At this point it is not clear
to the reader what this means and why it is
required.                                               Accepted   Reordered and clarified

We don't understand the matrix presented in the
table 3-10. From this data, if we compute, for
example, the probabilty of the event of not to be                  Comment noted - the data
parked some time between 1am and 2am hours                         and explanations provided
we obtain 0.9072, this means that the 90% of                       are taken verbatim from
vehicles are on road at 2am! Without doubt, this is                Table 6-3 of the previous
not representative of the Spanish pattern. So,                     Guidebook version
either the numbers from the matrix are wrong, or                   B760(2007). Will pass
there is another type of error about the meaning of                comment on to Expert
the matrix as it is explained in the guidebook text. Accepted      Panel
                                                                    Not know - the data are
                                                                    taken verbatim from Table
                                                                    6-3 of the previous
                                                                    Guidebook version
                                                                    B760(2007). Will pass
                                                                    comment on to Expert
Are these values for a particular country?             Noted        Panel

                                                                    Comment noted - the data
                                                                    and explanations provided
                                                                    are taken verbatim from
                                                                    Table 6-3 of the previous
                                                                    Guidebook version
                                                                    B760(2007). Will pass
Explain 'cats'. Again, at this point it is not clear why            comment on to Expert
fuel tank volume would be required.                      Accepted   Panel

At this point I am completely lost. This looks like
the start of a more complex 'Tier 4' approach. An
explanation of this structure is required. Are
sections 3.4.5 to 3.4.12 adjustments to the
emissions which have already been calculated to
this point? Furthermore, much of the text in these
sections repeats the earlier text.                     Accepted     Sorted
                                                                    Rearranged, but not
                                                                    changed because this was
                                                                    taken verbatim from
                                                                    previous Guidebook
                                                                    version B760(2007)
                                                                    Detailed methodology.
How are the temperatures calculated in Section                      Will pass comment on to
3.4.5 used?                                            Accepted     Expert Panel
                                                                    Not changed because this
                                                                    was taken verbatim from
Table 3-12. Surely the values in the first column                   previous Guidebook
should start at 01:00 and end at 24:00 (or 00:00)?                  version B760(2007)
Need to explain that there are 24 intervals in each                 Detailed methodology.
row because 0.5 hour steps are used over a 12-                      Will pass comment on to
hour period.                                           Accepted     Expert Panel
                                                                    Rearranged, but not
                                                                    changed because this was
                                                                    taken verbatim from
                                                                    previous Guidebook
                                                                    version B760(2007)
                                                                    Detailed methodology.
                                                                    Will pass comment on to
How is Section 3.4.6 used? Explain.                    Accepted     Expert Panel
                                                              NOTED - not changed in
From personal communication from Giorgos                      this revision because this
Mellios (COPERT team) it appears that the                     was taken verbatim from
numbers in formulae for parameters a and b are                previous Guidebook
incorrect and they should be replaced by the                  version B760(2007)
following figures: a = -11 -0.015*vp +0.065*T;                Detailed methodology.
b=0.115-0.00015*vp +0.0001*T; please check it                 Will pass comment on to
with Giorgos Mellios                              Accepted    Expert Panel
                                                              Rearranged, but not
                                                              changed because this was
                                                              taken verbatim from
                                                              previous Guidebook
                                                              version B760(2007)
                                                              Detailed methodology.
                                                              Will pass comment on to
How is Section 3.4.7 used? Explain.               Accepted    Expert Panel
                                                              Rearranged, but not
                                                              changed because this was
                                                              taken verbatim from
                                                              previous Guidebook
                                                              version B760(2007)
                                                              Detailed methodology.
How is Section 3.4.8 used? What is 'permeation                Will pass comment on to
and leakage'? Is this a new source? Explain.      Accepted    Expert Panel

The formula in this line has not mathematical
meaning, it is not a mathematical formula. The sum
over the continuous variable T has not meaning.
What is that you want to say?: sum of the formula
over the different hours (H1 to H2) considering               NOTED - not changed in
constant the temperature of each hour, or integral            this revision because this
of the formula from T1 to T2? The two things are              was taken verbatim from
the same only if the temperature data are discrete            previous Guidebook
(temperature averaged for each hour), but if we               version B760(2007)
apply a continuous function to the maximum and                Detailed methodology.
minimum daily temperatures to approximate the                 Will pass comment on to
hourly variation, the two things are distinct      Accepted   Expert Panel
                                                              Not deleted, because this
                                                              was taken verbatim from
                                                              previous Guidebook
                                                              version B760(2007)
                                                              Detailed methodology,
                                                              Section 8.12. Will pass
                                                              comment on to Expert
Delete this Section.                              Accepted    Panel
                                                              Not changed because this
                                                              was taken verbatim from
                                                              previous Guidebook
                                                              version B760(2007)
                                                              Section 9, pB760-15. Will
Change to 'Light fuel components tend to be more              pass comment on to
volatile than heavy ones'.                       Editorial    Expert Panel
There is no section 3.3.3.                             Accepted   Sorted
                                                                  No change made - these
                                                                  were the headings
                                                                  provided in the template
                                                                  from TNO. Consult with
Some of the topics in Chapter 4 (e.g. gridding,                   TNO/Expert panel
reporting) do not appear to be data quality issues. Accepted      regarding their retention
Does this comment apply to all Sections 4.1 to 4.3,
or just 4.3? If not, something should be written for              I believe it does, hence
Sections 4.1 and 4.2                                 Accepted     phrase added
                                                                  Not sure - taken verbatim
                                                                  from Table 10-1 of
                                                                  previous Guidebook
                                                                  version B760(2007). Need
                                                                  to refer question to
Section 4.5, which Tier does it refer to?              Noted      authors/ Expert Panel
                                                                  Taken verbatim from
                                                                  Section14 of previous
                                                                  Guidebook version
                                                                  B760(2007). Need to refer
                                                                  comment to authors/
The reference for COPERT 4 is incorrect.               Accepted   Expert Panel

Please refer also to general comments
summarised in the separate word file "DK Review
of guidebook chapters for mobile sources.doc"          noted
The Tier 3 method is now a mix of the simple and
detailed method from the old chapter?                  noted      Sorted
This is a very serious mistake by the consultants to
develop such a new method, without discussing
with the data suppliers.                               noted      Sorted
Why do we need to have 3 Tier methodologies? Is
it mandatory to have 3 Tiers in the Guidebook?
Tier 1 now makes no sense! Again this was never
agreed with the Transport panel. Moreover, the
methodlogies are again a mess:Why is Table 3-3
part of the Tier 1 since there is no vehicle
distinction to Tier 1? Tier 2 has a correction for
speed but the emission factors are independent of
speed!                                                 Noted      Sorted
Acording the formulae specified in the document
for vehicles without control systems it seems the
right could be replace "some" by "all"                 Noted      Sorted
We have computed the probabilty as follows: the
probability of to be parked between H-1 to H hours
is the sum from t2=H to t2=H+11 of sum of
f(t2,tpark) from tpark=2(t2-H)+1 to t2=24 , being
understood that: H+x = (H+x) mod 24 and f(t2,
tpark) is the element of matrix at row t2, column
tpark.
                                                       noted      Sorted
There appears to be a problem with the NFR code
for these sources. Part A of Sector 1 is                           This is an inherent problem
'Combustion'. Tyre wear, brake wear and road                       with the nomenclature for
surface wear are not combustion processes.      Noted              this sub-sector.

Some references are needed in this paragraph.       Accepted       References included

                                                                   used to conceptualise the
                                                                   boundaries of road
                                                                   transport emissions, and is
Figure 2-1 is poor and is not helpful. Could be                    an approach adopted
much more graphic. Why 'flow diagram'?              Rejected       throughout the Guidebook.
'This sector'. Which sector? The three sources, the
two NFR codes? Abrasion?                            Noted          Altered

Change 'proportion' to 'contribution'.              Editorial        Altered
                                                                     Could be made more
                                                                     transport specific.
Process description' is not a good title in my view. It              However, might detract
is too vague. I also think that it repeats title 2, and Consult with from a common guidebook
would therefore delete it.                              Expert Panel style.
                                                                     NOTED - not changed in
                                                                     this revision because this
                                                                     was taken verbatim from
                                                                     previous Guidebook
                                                                     version B770(2003)
                                                                     Section 3.2. Will pass
Disc brakes are increasingly used in heavy-duty                      comment on to Expert
vehicles.                                               Noted        Panel
                                                                     Could be made more
                                                                     transport specific.
                                                                     However, might detract
Section 2.2 title could be more helpful. What           Consult with from a common guidebook
exactly does it refer to?                               Expert Panel style.
What is the meaning of the Section 2.3 title. It is                  A discussion on emission
very vague.                                             Rejected     sources.
                                                                     Not with the same level of
                                                                     completeness. When
It is not possible making an update of the emission                  reporting improves there
estimate?                                               Noted        will be.
                                                                     Not with the same level of
                                                                     completeness. When
                                                                     reporting improves there
Are there any more recent data?                         Noted        will be.
                                                                     NOTED - not changed in
                                                                     this revision because this
                                                                     was taken verbatim from
                                                                     previous Guidebook
                                                                     version B770(2003)
                                                                     Section 3.2. Will pass
                                                                     comment on to Expert
A discussion of the Tables would be useful.             Accepted     Panel
                                                                     Numbers are suitable for
                                                                     indicative purposes. Also
                                                                     not changed in this
                                                                     revision because this was
                                                                     taken verbatim from
                                                                     previous Guidebook
                                                                     version B770(2003)
                                                                     Section 2. Will pass
                                                                     comment on to Expert
Some of these data should be updated.                   Rejected     Panel

Surely Tier 2 or Tier 3?                                Accepted     Altered
Tiers classification. Comments are summarized in
separate Word document                                  Noted        Sorted
The decision tree only explains PM10. But
convention needs are TSP and PM2.5 also.                Accepted     Altered
The Tier 1 algorithm resolution is per vehicle
classe. But the Tier 1 factors are averaged for all     Consult with
vehicles.                                               Expert Panel Sorted
Figure 3-1. PM10 is not a 'species' it is a prticle
size metric.                                            Accepted     Altered

Figure 3-1. Where does Tier 3 fit in?                   Accepted     Sorted
                                                                     NOTED - not changed in
                                                                     this revision because this
                                                                     was taken verbatim from
                                                                     previous Guidebook
                                                                     version B770(2003)
                                                                     Equation 1. Will pass
The sum over all vehicle categories should be                        comment on to Expert
formally introduced into the equation.                  Accepted     Panel
Tables 3-1 to 3-3, is averages only. It is considered
a wrong decision not to give data per vehicle
classe. Also, TSP and PM2.5 emission factors are        Consult with
needed.                                                 Expert Panel Sorted
Tables 3-1 and 3-2. The units are clearer as g km-
1 vehicle-1. Subscripts required for PM10 and
PM2.5.                                                  Accepted     Altered
Tables 3-1 and 3-2. The names of chemicals do
not take capital letters. Should be 'polycyclic
aromatic hydrocarbons'. Some of cell contents are
cut off                                                 Accepted     Altered

Reference codes to be updated.                          Accepted     will be updated

Metrics other than PM10 are included.                   Accepted     Altered
This method seems unnecessarily crude. Where
do these percentages come from?                         Accepted     Altered
The Tier 2 algorithm claims speed dependency.
However, no speed dependency is given in the            Consult with
Table 3-4 to 3-15 emission factors.                     Expert Panel Sorted
                                                                  Table superceded by
Table 3-3. Font too large in Table. What are the                  changed Tables 3-1 and 3-
units?                                              Noted         2
                                                                  NOTED - not changed in
                                                                  this revision because this
                                                                  was taken verbatim from
                                                                  previous Guidebook
                                                                  version B770(2003)
                                                                  Equation 1. Will pass
Again, summation over all vehicle categories                      comment on to Expert
required.                                           Accepted      Panel
                                                    Consult with
Where are the values for fs,i and Ss(V)?            Expert Panel Sorted
Where is the speed dependency? Emission factor      Consult with
tables for TSP and PM2.5 are missing.               Expert Panel Sorted
Is the detailed methodology Tier 2? This is not     Consult with
clear.                                              Expert Panel Altered
This is all badly explained. What is this section
(3.3.2) about? Where is the speed dependence?       Consult with
Check that the Table titles match the contents.     Expert Panel Sorted

Metrics other than TSP are included. This is all
badly explained. What is this section (3.3.2) about? Accepted     Sorted

Metrics other than TSP are included.                Accepted      Sorted

In Tier 3 (Table 3-16), the particulate fractions for
other sizes than PM10 are listed for tyre wear. But
these fractions should be available from the
beginning to support also Tier 1 and 2 calculations. Accepted     Sorted

In Tier 3 (Table 3-17), the particulate fractions for
other sizes than PM10 are listed for brake wear.
But these fractions should be available from the
beginning to support also Tier 1 and 2 calculations. Accepted      Sorted
The Tier 3 methodology for road surface wear is       Consult with
missing.                                              Expert Panel Sorted

This could be more helpful. Why is this the case?   Noted         Sorted
                                                                  NOTED - not changed in
                                                                  this revision because this
                                                                  was taken verbatim from
                                                                  previous Guidebook
                                                                  version B770(2003)
                                                                  Section 9. Will pass
                                                                  comment on to Expert
Explain choice of PAHs. Which protocol?             Accepted      Panel
                                                                   Sorted regarding table
                                                                   referenced - Phrase
                                                                   "Different elements" not
                                                                   changed because this was
                                                                   taken verbatim from
                                                                   previous Guidebook
                                                                   version B770(2003)
                                                                   Section 9. Will pass
Should be Table 3-19. Not all the substances listed                comment on to Expert
are elements - some of them are ions.               Accepted       Panel
                                                                   NOTED - not changed in
Table 3-19 needs to be improved. As stated above,                  this revision because this
some of the 'elements' are actually ions. The                      table is taken verbatim
nomenclature is not consistent (eg. Mg2+ but SO4--                 from Table 13 of the
. Subscripts and superscripts are required for the                 previous Guidebook
ions. The term 'elemental speciation' is used                      version B770(2003). Will
incorrectly. The word 'brake' is spelt incorrectly.                pass comment on to
What is the meaning of blank cells?                 Accepted       Expert Panel

The text in Section 4.4 has nothing to do with
consistent time series and recalculation! It is more
or less the same text as Section 13 "Temporal
disaggregation criteria" from the old chapter.       Accepted      Title changed

Why is there no text under 4.1 and 4.2?              Accepted      Headings deleted
                                                                   NOTED - not changed in
                                                                   this revision because this
                                                                   is taken verbatim from
                                                                   Section 11 of the previous
                                                                   Guidebook version
                                                                   B770(2003). Will pass
Are the EFs really for asphalt? This is rather                     comment on to Expert
specific.                                            noted         Panel

What is 'method 3'?                                  Editorial     Sorted

See
http://www.ssb.no/emner/01/04/10/rapp_emissions/              Expert panel to be made
rapp_200738_en/rapp_200738_en.pdf, page 41-44 Noted           aware of these data.
It is a mistake to make such averages, since the
number of vehicles per classe is known from the  Consult with
road transport exhaust inventory.                Expert Panel Sorted

In Tier 3, the expressions for heavy duty load and
axles (tyre wear), heavy duty load (brake wear),     Consult with
and speed (all vehicle classes) are present.         Expert Panel Sorted
However, the speed corrections was to be used in     Consult with
Tier 2.                                              Expert Panel Sorted

The old chapter briefly discusses how to treat                    Information from old
emission inventories in relation to dispersion       Consult with chapter is included, hence
models.                                              Expert Panel nothing has been lost.
                                                                  NOTED - not changed in
                                                                  this revision because this
                                                                  is taken verbatim from the
                                                                  previous Guidebook
                                                                  version B770(2003). Will
                                                                  pass comment on to
Why have HM and POPs not been included?               noted       Expert Panel
                                                                  NOTED - not changed in
                                                                  this revision because this
                                                                  is taken verbatim from the
                                                                  previous Guidebook
Emissions other then PM See                                       version B770(2003). Will
http://www.ssb.no/emner/01/04/10/rapp_emissions/                  pass comment on to
rapp_200738_en/rapp_200738_en.pdf, page 39-41 Accepted            Expert Panel

Please refer also to general comments                             relevant information will be
summarised in the separate word file "DK Review                   included where appropriate
of guidebook chapters for mobile sources.doc"         Accepted    and time permits.
What Directive do you refer to?                       Accepted    Done
This is just messy key words, not fit for a
documentation report                                  Accepted    Done
What is the source of the EFs in tables 3-1, 3-2
and 3-3 in this FOD? Also, how is Tier 1 EFs
approx 20 times greater than Tier 2 EFs?              Accepted    Done
There must be errors somewhere in the emission
factor tables; It is not possible with such
differences between Tier 1 and Tier 2!                Accepted    Done
What is the reference for SO2?                        Accepted    Done
Refers reader to RT chapter, but then on following
page, refers reader to the off-road section - which
is correct or are both relevant?                      Noted       Done

What is "H"?                                          Noted       Done
Table shows Efs in g/GJ of fuel - where do hours
come into this??                                      Noted       Done
PM0.95??                                              Editorial   Done

factor 'H' in equation is not specified               Noted       Done
same data in tables 3-2 and 3-3 whereas table for
line haul locomotives is missing                      Accepted    Done
Table 3-2 and Table 3-3 are the same except for
the technology name! They are titled Tier 2 and the
next line says Tier 1!                                Accepted    Done
General comment - where are the Efs for line haul
locomotives?                                          Accepted    Done
A table for line haul locomotives is missing          Accepted    Done

"(e.g., EX-TREMIS (Chiffi, Fiorello, Schrooten, De
Vlieger (2008); RAILI…"                               Noted       Done

"(e.g., EX-TREMIS (Chiffi, Fiorello, Schrooten, De
Vlieger (2008); RAILI…"                               Noted       Done
The EX-TREMIS railways inventory contains time
series 1980-2005 and projections (up to 2030) for
locomotives and railcars specific activity data
(passenger/freight train km and gross hauled tonne
km) as well as for energy consumption and
emission factors. Please, send us a request to
have a view on the preliminary data (a password is
needed) - the project will be concluded by the 30 of
April 2008                                           Noted      Done

Please quote the EX-TREMIS project, founded by
the JRJ-IPTS of Seville and carried aout by TRT
and VITO, and provide the weblink to users in the
same page http://www.ex-tremis.eu/ - EX-TREMIS
combines statistics from different sources and
calculate emission factors for specific engine types
for each of the 27 EU countries (excluding Malta
and Cyprus that have no railways)                    Noted      Done
The EX-TREMIS railways inventory contains time
series 1980-2005 and projections (up to 2030) for
locomotives and railcars specific activity data
(passenger/freight train km and gross hauled tonne
km) as well as for energy consumption and
emission factors.                                    Noted      Done

Please quote the EX-TREMIS project, founded by
the JRJ-IPTS of Seville and carried aout by TRT
and VITO, and provide the weblink to users in tha
same page http://www.ex-tremis.eu/ - EX-TREMIS
combines statistics from different sources and
calculate emission factors for specific engine types
for each of the 27 EU countries (excluding Malta
and Cyprus that have no railways)                    Noted      Done


The emission factors are still missing.             Noted       Done
What units are the emissions shown in, in the
USEPA table?                                        Noted       Done

Paragraph not clear. For example, "bio-diesel can
be used in all diesel engines with slight or no
modification" - is this true for 100% biodiesel? Are
trains currently running on B2 - B5?                 Accepted   Done
please refer to "gross hauled tonne kilometre
(GhTK)"                                              Accepted   Done
please add "EX-TREMIS 2008"                          Accepted   Done
according to Regulation 91/2003, from the
beginning of 2003 all railway undertakings (not only
the "principal") shall report their traffic data to
Eurostat. Moreover, train movements (national,
international and transit train km) are reported
considering only the distance covered on the
national territory of the reporting country. By using
operating data, double counting problem may be
avoided. In EX-TREMIS some technical notes to
data sources will be made available to
compilers/users.                                        Noted      Done
please refer to "gross hauled tonne kilometre
(GhTK)"                                                 Accepted   Done
please add "EX-TREMIS 2008"                             Accepted   Done
according to Regulation 91/2003, from the
beginning of 2003 all railway undertakings (not only
the "principal") shall report their traffic data to
Eurostat. Moreover, train movements (national,
international and transit train km) are reported
considering only the distance covered on the
national territory of the reporting country. By using
operating data, double counting problem may be
avoided.                                                Noted      Done
This is just copy and paste from the IPCC 2006
guidelines.                                             Accepted   Done
emisison factors for additives??                        Noted      Done
The number of the chapter is missing                    Accepted   Done
Please add the reference "EX-TREMIS project -
Railways Inventory. For information see the
website http://www.ex-tremis.eu/ and Final Report:
Chiffi, Fiorello, Schrooten, De Vlieger, EX-TREMIS,
Exploring non-road Transport Emissions in Europe,
JRC-IPTS (2008)"                                        Accepted   Done
Please add the reference "EX-TREMIS project -
Railways Inventory. For information see the
website http://www.ex-tremis.eu/ and Final Report:
Chiffi, Fiorello, Schrooten, De Vlieger, EX-TREMIS,
Exploring non-road Transport Emissions in Europe,
JRC-IPTS (2008)"                                        Accepted   Done
General comment - chapter refers to diesel and
sometimes to gas oil - use one or the other
perhaps as otherwise confusing…                         Accepted   Done

Please refer also to general comments
summarised in the separate word file "DK Review
of guidebook chapters for mobile sources.doc"           Accepted   Done
Table 2.1, please harmonise with IPCC 2006
Guidelines                                              Noted      done
the distinction beteween domestic (coastal) and
international shipping in terms of "activity" is not so
difficoult to extrapolate. Activity data in EU are
collected and provided to Eurostat by all member
states according to the Maritime Statistics Directive
(Council Directive 96/64/EC). In the Eurostat
Newcronos Maritime Database it is possible to find
quarterly statistics both for passengers and goods
(collections mar_pa_qm_detl and
mar_go_qm_detl) spiltted by direction (inw, outw),
partner entity and type of cargo. These collecions
refers fo main ports only (but 90% of the total
traffic). It is possible to consider the total traffic
(mar_pa_aa and mag_go_aa) of passenger and
goods of all ports by direction and use it for adding
the missing quota to detailed collections.
References and methodologies for doing it are in
EX-TREMIS (2008).                                       Noted        Done

the distinction beteween domestic (coastal) and
international shipping in terms of "activity" is not so
difficoult to extrapolate. Activity data in EU are
collected and provided to Eurostat by all member
states according to the Maritime Statistics Directive
(Council Directive 96/64/EC). In the Eurostat
Newcronos maritime database it is possible to find
quarterly statistics both for passengers and goods
(collections mar_pa_qm_detl and
mar_go_qm_detl) spiltted by direction (inw, outw),
partner entity and type of cargo. These collecions
refers fo main ports only (but 80/90% of the total
traffic). It is possible to consider the total traffic
(mar_pa_aa and mag_go_aa) of passenger and
goods of all ports by direction and use it for adding
the missing quota to detailed collections.
References and methodologies for doing it are in
EX-TREMIS (2008).                                       Noted        Done

Please delete, this is not possible to understand/is   Consult with I disagree with the
incorrect/refers to Member States (not Parties)        Expert Panel comment
Also the EX-TREMIS methodology gives an
allocation of emissions according to the type of       Consult with
traffic                                                Expert Panel Can't access website
Also the EX-TREMIS methodology gives an
allocation of emissions according to the type of       Consult with
traffic                                                Expert Panel Can't access website
Footnote: I can't find the reference for the Entec
reports anywhere in the chapter.                       Noted        Done
Please remove or update (this was not in the           Consult with
original outline agreed by TFEIP/is outdated)          Expert Panel please update
What does the terms in bracket [ ] mean? Has this
text been updated in accordance with latest IMO
regulations?                                             Noted
Table 3.1 and 3.2, please provide original
references for emission factors (not EMEP-C)
(same with the subsequent tables)                        Accepted   Done
Eurostat collection of vessel traffic (quarterly data,
main ports, number and gross tonnage of vessels,
by type and size of vessels and inwards direction -
mar_tf_qm) provides country statistics for 7 groups
of ship types and 22 GT size classes. References
are in EX-TREMIS (2008). Please, quote the
website. In case, request us a tecnical note on this
issue                                                    Noted      Done
Eurostat collection of vessel traffic (quarterly data,
main ports, number and gross tonnage of vessels,
by type and size of vessels and inwards direction -
mar_tf_qm) provides country statistics for 7 groups
of ship types and 22 GT size classes. References
are in EX-TREMIS (2008). Please, quote the
website.                                                 Noted      done
Not only NOx emissions are engine specific, but
also PM emissions (see EMS protocols).                   Noted      Done
Not only NOx emissions are engine specific, but
also PM emissions (see EMS protocols).                   Noted   Done
                                                                 fuel instead of mass: which
The calculation formula gives no meaning. Instead Consult with unit of measure? Mj or
of M(fuel sold, engine type) it should              Expert Panel tonnes?
EX-TREMIS provides a similar tables or additional
parameters in the website (i.e. differentiated
conversion factors or weighted EF)                  Noted        Can't access website
EX-TREMIS provides a similar tables or additional
parameters in the website (i.e. differentiated
conversion factors or weighted EF)                  Noted        Can't access website
Activity data has to be segmented per activity type
(different EF for hotelling, manoeuvring and
cruising in TIER2).                                 Noted        Done
Activity data has to be segmented per activity type
(different EF for hotelling, manoeuvring and
cruising in TIER2).                                 Noted        Done

What is the origin of this table?                        Noted      Guidebook 2006

Table 3-27: Source?                                      Noted      Guidebook 2006

Table 3-27: Source?                                      Noted      Guidebook 2006

Where does the data in Table 3-27 come from?             Noted      Guidebook 2006
Entec 2002? I can't find this reference in the
chapter                                                  Noted      Done

All table references are wrong                           Noted      Done
Where does the data in Table 3-29 come from?         Noted        Done
Table 3-29: Please include the units in the table
text                                                 Noted        Done
Why is the TIER3 methodology not very well suited
to show annual trends in emissions?                  Noted        Done
The EF - only cruise based now - should be a
weighted average EF of cruising, manoeuvring and
hotelling.                                           Noted        Done
Why is the TIER3 methodology not very well suited
to show annual trends in emissions?                  Noted        Done
The EF - only cruise based now - should be a
weighted average EF of cruising, manoeuvring and
hotelling.                                           Noted        Done

Please check the table references                    Noted        Done
                                                     Consult with
also on the EX-TREMIS website                        Expert Panel Can't access website
we may add such tables on EX-TREMIS. Do you
think this may solve problems to compilers or help   Consult with
them?                                                Expert Panel Can't access website
                                                     Consult with
also on the EX-TREMIS website                        Expert Panel Can't access website

we may add such tables on EX-TREMIS. Do you          Consult with
think this may solve many problems to compilers?     Expert Panel Can't access website

I think we should have to quote the relevant
facilities provided by the Eurostat Newcronos
database. See the comment 11. We have
assembled some technical notes for working with
Eurostat data and produce/derive ship movements.
Please, request us these notes if you think that a
paragraph should be added here.                    Noted          Done

I think we should have to quote the relevant
facilities provided by the Eurostat Newcronos
database. See the comment 11. We have
assembled some technical notes for working with
Eurostat data and produce/derive ship movements.
Plese, request us these notes if you think that a
paragraph should be added here.                     Noted         Done
The most comprehensive and detailed source of
information for Ferry, Ro-Ro, HS craft and cruise
ships is the ShipPax database (please visit
www.shippax.se for more infos and in particular the
webpage
http://www.shippax.se/page/page.asp?id=14). I
think that the "Thomas Cook…" source is not a
good reference.                                     Accepted      done
The most comprehensive and detailed source of
information for Ferry, Ro-Ro, HS craft and cruise
ships is the ShipPax database (please visit
www.shippax.se for more infos and in particular
http://www.shippax.se/page/page.asp?id=14). I
think that the "Thomas Cook…" source is not a
good reference.                                      Accepted      done
This par seems to have been copied from the 2006
GLs; it mentioned the 2006 GLs and makes
reference to multilateral operations, this is not in
line with the LRTAP reporting Guidelines. Please
revise                                               Accepted      Done

We have built a distance table (mainly for
international traffic) from/to each maritime coastal
areas (MCAs) of EU countries to/from EU MCAs,
all Mediterranean and Baltic third countries and to
13 overseas areas, namely Black Sea, Arabian
Gulf, Red Sea, Indian Sub Continent, Australasia,
Far East - China & Japan, South & East Africa,
West Africa, US Atlantic & Canada - Great Lakes,
Central America – Caribbean, South America –
Atlantic, US & Canada – Pacific, South America -
Pacific. Do you think this table proveded on the
webste could help compilers? The table refers to     Consult with
one sole reference port per country                  Expert Panel
This section 4.4 has nothing to do with consistent
time series and recalculation! It is simply copy and
paste from the old chapter section 3.5
"Projections".                                       Accepted     done

EX-TREMIS performed an analysis on historical
data (1980-2005) and gives on a country basis
activity data (tonne-miles and ship-miles
movements by type of ship/engine and by OD),
emission factors and total emissions. The EF are
differentiated according to the characteristics of the
visiting fleet calling at seaports of each country.
Please, inform us and request our interim report or Consult with
the outline of the final report of EX-TREMIS.          Expert Panel Consider for Tier 3

EX-TREMIS performed an analysis on historical
data (1980-2005) and gives on a country basis
activity data (tonne-miles and ship-miles
movements by type of ship/engine and by OD),
emission factors and total emissions. The EF are
differentiated according to the characteristics of the
visiting fleet calling at seaports of each country.
Please, inform us and request our interim report or Consult with
the outline of the final report of EX-TREMIS.          Expert Panel Consider for Tier 3
Replace the column Consumption at full power
(tonne/day) as a function of gross tonnage (GT)
with the following values: C = 12,0724+0,0012*
GT -1,1501E-8*GT2+4,6484E-14*GT3
C = 7,2194+0,0015*GT-9,1885E-9*GT2+2,6803E-
14*GT3
C = -2,2602+0,0049*GT-1,6401E-7*GT2+1,7394E-
12*GT3
C = 0,0919+0,0038*GT-6,1565E-8*GT2+6,7917E-
13*GT3
C = 6,3501+0,0013*GT+1,6852E-7*GT2-6,2691E-
12*GT3+ 5,699E-17*GT4
C = 5,2159+0,0034*GT-3,373E-8*GT2+2,062E-
13*GT3
C = -9,735+0,0486*GT-4,6603E-6*GT2+1,3911E-
10*GT3
C = -2,2602+0,0049*GT-1,6401E-7*GT2+1,7394E-
12*GT3
C = .42682 + .00100*GT
C = 1,0857+0,0259*GT-1,0279E-5*GT2+1,6828E-
9*GT3
C = 1,2744+0,0062*GT-6,4603E-7*GT2+5,5193E-
11*GT3
C = 1,2744+0,0062*GT-6,4603E-7*GT2+5,5193E-
11*GT3
C = 8,2909+0,0018*GT-4,4908E-8*GT2+4,8931E-
14*GT3                                          Consult with
 SEE ANNEX PAPER FOR DETAILS                    Expert Panel Consider for Tier 3

Add the reference: "Trozzi C., Vaccaro R. (2006),
Methodologies for estimating air pollutant
emissions from ships: a 2006 update, Environment
& Transport, 2th International Scientific Symposium
(including 15th conference Transport and Air
Pollution), Reims, France : 12-14 June 2006             Accepted   Done
Please insert the EX-TREMIS reference or
website: EX-TREMIS project - Maritme Inventory -
for information see the website http://www.ex-
tremis.eu/ and Final Report: Chiffi, Fiorello,
Schrooten, De Vlieger, EX-TREMIS, Exploring non-
road Transport Emissions in Europe, JRC-IPTS
(2008).                                                 Accepted   Done
Please insert the EX-TREMIS reference or
website: EX-TREMIS project - Maritme Inventory -
for information see the website http://www.ex-
tremis.eu/ and Final Report: Chiffi, Fiorello,
Schrooten, De Vlieger, EX-TREMIS, Exploring non-
road Transport Emissions in Europe, JRC-IPTS
(2008).                                                 Accepted   Done
It's impossible to verify Efs without clear reference
about source of data. No correspondence between
Table and references!                                   Accepted
TIER1&2 are bunker fuel based methodologies,
TIER3 is an activity based methodology. For
instance for Belgium, there is a difference of a
factor 35 between a bunker fuel and an activity
based methodology (Inventory and forecasting of
maritime emissions in the Belgian sea territory, an
activity-based emission model, Atmospheric
Environment, Volume 42, Issue 4, February 2008,
Pages 667-676, Liesbeth Schrooten, Ina De
Vlieger, Luc Int Panis, Karel Styns and Rudi Torfs).
It is possible to make a TIER1&2 activity based
methodology (transforming EUROSTAT statistics
into activities) on findings in Ex-TREMIS - EX-
TREMIS project - Maritme Inventory - for
information see the website http://www.ex-
tremis.eu/ and Final Report: Chiffi, Fiorello,
Schrooten, De Vlieger, EX-TREMIS, Exploring non-
road Transport Emissions in Europe, JRC-IPTS         Consult with
(2008).                                              Expert Panel Consider for Tier 3

The emission factors used are aggregated
emission factors from ENTEC. The TIER3
methodology can be made even more
desaggregated by using even more desaggregated
emission factors from EMS (AVV, TNO-MEP,
RIZA, MARIN, CE-Delft, Haskoning,
Emissieregistratie en –Monitoring Scheepvaart,
DGG, November 2003). The ENTEC emission
factors are predefined for MCR 85% and 20%, as
for EMS you can use your country specific MCR
and create your own country specific emission
factor. A comparison of both sources would be
usefull. The EMS protocols are in Dutch, but you
can find relevant documentation in English in the
MOPSEA report
(http://www.belspo.be/belspo/home/publ/pub_ostc/
EV/rappEV43_en.pdf) and the Ex-TREMIS project Consult with
(see comment above for link).                     Expert Panel Consider for Tier 3
TIER1&2 are bunker fuel based methodologies,
TIER3 is an activity based methodology. For
instance for Belgium, there is a difference of a
factor 35 between a bunker fuel and an activity
based methodology (Inventory and forecasting of
maritime emissions in the Belgian sea territory, an
activity-based emission model, Atmospheric
Environment, Volume 42, Issue 4, February 2008,
Pages 667-676, Liesbeth Schrooten, Ina De
Vlieger, Luc Int Panis, Karel Styns and Rudi Torfs).
It is possible to make a TIER1&2 activity based
methodology (transforming EUROSTAT statistics
into activities) on findings in Ex-TREMIS - EX-
TREMIS project - Maritme Inventory - for
information see the website http://www.ex-
tremis.eu/ and Final Report: Chiffi, Fiorello,
Schrooten, De Vlieger, EX-TREMIS, Exploring non-
road Transport Emissions in Europe, JRC-IPTS         Consult with
(2008).                                              Expert Panel Consider for Tier 3

The emission factors used are aggregated
emission factors from ENTEC. The TIER3
methodology can be made even more
desaggregated by using even more desaggregated
emission factors from EMS (AVV, TNO-MEP,
RIZA, MARIN, CE-Delft, Haskoning,
Emissieregistratie en –Monitoring Scheepvaart,
DGG, November 2003). The ENTEC emission
factors are predefined for MCR 85% and 20%, as
for EMS you can use your country specific MCR
and create your own country specific emission
factor. A comparison of both sources would be
usefull. The EMS protocols are in Dutch, but you
can find relevant documentation in English in the
MOPSEA report
(http://www.belspo.be/belspo/home/publ/pub_ostc/
EV/rappEV43_en.pdf) and the Ex-TREMIS project Consult with
(see comment above for link).                     Expert Panel Consider for Tier 3

Please refer also to general comments
summarised in the separate word file "DK Review
of guidebook chapters for mobile sources.doc"        Noted        Done

It is very confusing to read this chapter. Practically
all the references to tables in the text               Accepted   Done
are wrong, and some tables are even missing. Also
references are given to an important sources of
information (Entec study)                              Accepted   Done
which we can't find in the list of reference. And
even more important, the chapter                       Noted      Done
doesn't print the crusial information from Entec.
Inventory makers are asked to look them up
themselves.                                             Accepted   Done
Because so much remains to be done in this
chapter, the reviewers are wasting a lot of time.       Noted      Done
be M(fuel sold, fuel type, engine type), in order to
have the same resolution as for EF.                     Noted      Done
When this basis is correct, you can make
summations afterwards.                                  Noted      Done

then we are not able to make the calculations!          Noted      Done

I suggest to include a description of typical devices,
e.g.: modified RollsRoyce airplane turbines with
cap. of about 30 MW , fed by natural gas.
Someone even have low-Nox technologies.                Accepted
There is no reference either in the Tier 1 or 2
tables for the NFR 1A5a.It would be correct, if EF
for this NFR not available (or the same asfor other
NFR in this chapter), it would be specified in the
text.                                                              Will amend tables (

In table 1-1 (and furtheron) the term 'non-
residential heating' is introduced. This term is
highly confusing, and requires change. Please
avoid (throughout the text) as much as possible
this kind of negative definition. Here use
"commercial/institutional heating" instead. Also the
term "other" should be avoided and may only be
used when explicitely defined as NFR term.              Accepted   Text modified
Fishing is not covered in the small combustion
chapter and should therefore be removed from the
list of activities covered. Again there is no mention
of HCB in table 1-1.                                    Noted      HCB included
Subdividing this sector needs to be done in a
consistent manner, in order not to confuse a
reader. The list as presented now is an ambiguous                  Text modified to align
mixture of NFR attributions (but note my comment                   technologies more with
[1] above) and techniques (CHP)                         Accepted   NFR
The only pathway of interest (emissions from
combustion) is not described in Fig. 2-1                Noted      None
In consequence to comment [2], subsections within
the section 2.2 should be consistent to the sub-
division first introduced in Page 3/line 10-12.
Furthermore, levels of sub-types are not clear or
consistent (example below, comment [6]). Finally,
techniques and sub-types need to match emission
factors presented. I.e., differentiating between
'open fireplaces' and 'partly closed fireplaces' is
only useful when also emission factors are being
presented (This example being chosen here for                   Text modified to align
simplicity, but the point is applicable throughout). A          more closely with NFR, tier
national expert should be able to find the type of              1 factors are on fuel basis
installation operative in his/her country according to          so no technology
the description in the list of techniques, and then             relevance; Tier 2 has more
look up an appropriate emission factor. Ideally, for            disaggregation but not a
each type of appliance an own set of emission                   full split as this would be
factors is presented by fuel. Of course this will not           unmanageable but there
always be possible - but in the current text there is           are more appliance-
almost no such connection.                             Noted    specific details in Appendix
Strong chapter on techniques (Chapter 2.2). One
would wish that all chapters were on this high level.
However the subchapter on CHP should be
expanded.                                              Noted    None
                                                                Comment for wrong
figure 2-1: wrong title (…contribution from                     chapter - have taken into
railways…)                                           Rejected   account in 1A3
explain 'autonomy' - or use different term           Accepted   Modified
Stove types can not be differentiated by the
description presented. This is widely the case for
the whole list of stove types. Criteria used to form
subcategories are very ambiguous (from fuel type -
'pellet' to appication 'cooking' and further to
abatement 'catalytic')                               Accepted   Text modified to clarify

Finish stove' and 'Russian stove' may not be
expressions that are very helpful to describe stove
types outside particular countries which apply these
terms. It is o.k. to use those as a support, but one
should not expect this is sufficient explanation     Accepted   Text modified to address
Authors may wish to refer to the fact that - while
there exist stoves predominantly constructed for
specific fuels - there are also multi-fuel stoves.
These stoves are popular in some countries as
they are able to burn waste - a considerable
emission problem                                     Accepted   Text included
A very simple statement would help an expert to
understand which type his installation belongs to:
"Boilers are devices which heat water"               Accepted   Done
Automatic feeder systems are also available for
wood logs. The advantage of automatic systems is
that they minimize handling errors
(primary/secondary air, constant combustion
temeratures, …)                                     Accepted    Text modified
Condensing boilers may achieve efficiencies even
above 100% - this is basically their feat. For an
expert using this guidebook, one could make it
esier to identify such an installation: "condensing
boilers require a chimney resistant to the liquid               Accepted but detail not
condensate".                                        Noted       needed here.

When the potential for large dioxin emission is
mentioned it would only be natural to also address
the possible formation of other POPs notably HCB. Noted         Text modified
Primary measures can be presented in a more
systematic way: modifed fuels / modified heater /
modified combuation                                Accepted     Text order modified
                                                                It is a generic decision tree
                                                                but the elements are
Figure 3-1 does not contain any information                     relevant to small
specific for small combustion - why is it here then? Rejected   combustion plant
I strongly disagree: if we limit a country's                    Text modified slightly but
contribution to Tier 1 already at this stage, we                Tier 2/1 may be the most
should forget about the whole effort. Applying                  appropriate with (unlike
default emission factors to IEA (and similar)                   some other sectors) Tier 3
statistics can be done much more reliably in a                  only being achievable
centralized manner, and in fact has been done                   using the model or hybrid
already (see GAINS model)                            Accepted   approach .

In row 11 - AR fuel consumption, but in the row 14 -
AR production -activity rate for the lime production Accepted   Done
It would be better if these tables 3-1 to 3-12
refering to Tier 1 were listed in order from 1a4a,
1a4b and 1a4c etc. Also what size boilers to these
EFs relate to 20-50 MW or <20 MW?                    Noted
See comment [1] above: avoid 'other', instead use               Based on NAPFUE fuel
'medium/light liquid fuels'                          Rejected   classifications

Here and elsewhere: If the range presented for
emission factors extends over two orders of
magnitude, reporting has very little meaning        Noted

The selected fuel groupings for residential and non-            At Tier 1 we have brought
residential combustion seems less than ideal.                   together by main fuel
Biomass should be divided into wood and straw.       Noted      classifications
Common comment for Tier 1 and Tier 2 tables:
emission factors are shown with reference to
Guidebook 2006. But most of emission factors do
not coincide with the factors in the Guidebook
2006. Especially large differences are for SOx, CO,
NMVOC, PCDD/F, PAH. No emission factors for
indicator PAH while Guidebook 2006 includes                         Revised EF tables should
them.                                               Accepted        be clearer
                                                                    Table format is fixed to
It would be possible to include corresponding                       reflect NFR but SNAP also
SNAP codes in the allTier 1 and 2 tables                 Noted      provided

In table 3-2 (and all other Tier 1-2 tables) the total
PAH emission factor is resulted, but according to
requirements of reporting Guideline it is necessary
to report separately on four substances                  Accepted   Tables revised
In the table 3-2 (and all other Tier 1-2 tables) from
row "Not estimate" would be deleted "POPs" and
into row "Not applicable" include Annex I POPs (by
each substance).                                         Noted      Tables revised
Table 3-5: error in Pb and Hg emission factor (in
column Value are shown as 0, but in column Lower                    Rounding/significant figure
– not 0).                                                Accepted   issue
Several values listed as "0" in table 3-5 and 3-6.
Lack of HCB emission factor as well as detailed                     Will change with new
PAH emission factors are a problem.                      Accepted   tables
In the table 3-5, row fuel name - "Other Liquid
Fuels". It is not clear - other, excepting residual                 Include summary table of
fuel oil, or "other oil" (according to fuel defini       Accepted   fuel classes
Table 3-6: error in Pb emission factor (in column
Value are shown as 0, but in column Lower – not                     Will change with new
0).                                                                 tables
The dioxin emission seems to refer to the emission
factor for advanced fireplaces in the existing
guidebook. A general tier 1 emission factor should                  Will change with new
probably be somewhat higher.                             Noted      tables
In table 3-6, upper estimate for Se is below the
recommended value; in tab. 3-7, several metals                      Will change with new
exhibit an upper estimate of '0'                                    tables
In table 3-5 the fuel name is "Heavy Fuel Oil".
According to fuel definition in the new reporting
guideline it must be "Residual Fuel Oil"In other
combustion chapters the same.                            Noted      Text modified
It seems odd that all particles from biomass
combustion in the non-residential sector is                         Will change with new
assumed to be PM2.5.                                     Noted      tables
Again Tier 2, Tanles 3-14 to 3-26 seem to start with
residential (1a4a) and then move onto Other
sectors (1a4a and 1a4c). Also there is no                           Table 3-13 amended
information about thermal size of combustion plant                  slightly, note that NFR has
here.                                                    Noted      no size distinction
in table 3-13 and subsequent tables: provide
emission factors to instllations as they have been
described in section 2.2 - see comment [4]               Noted      Addressed where possible.

solid' fuel is first mentioned here - put this way it
would comprise also biomass; use 'coal' (as in the                  Text amended to include
previous part of this chapter) or 'solid fossil fuels'   Accepted   1A1a fuel types
                                                                    See earlier note on fuel
                                                                    classification - don't want
                                                                    to preclude coke and other
In the table substitute "Solid fuel" with "Coal fuel"    Noted      solid fuels
The tables contain a very large number of emission
factors quoted as Guidebook (2006) but with
different values. It's impossible to present similar
tables ! Some examples are reported in                              Will change with new
EF_comments.                                             Accepted   tables
CONCLUSION: ALL THE TABLES MUST BE
REVISED                                                  Noted
The existing guidebook list a dioxin emission factor
of 800 ng/GJ for standard fireplaces and 300 for
advanced fireplaces. Therefore the emission factor
of 350 ng/GJ with reference to the existing
guidebook seems wrong.                                   Noted
In table 3-16 the EF for CO is 0.01 g/GJ? Surely
this is a mistake. In the next table 3-17 CO has an                 Will change with new
EF of 1000g/GJ, or 100,000 greater.                      Accepted   tables
Tables 3-17, 3-18, 3-20: heavy metals emission                      Will change with new
factors should be rounded.                                          tables
Table 3-20: errors in EF for PM2.5 (in column
Value are shown as 0, but in column Lower – not                     Will change with new
0).                                                                 tables

The dual reference system is confusing. Either the
reference is the exisisting guidebook or it is
CITEPA. Several of the listed emission factors
does not correspond to the values in the existing                   Will change with new
guidebooks values for stoves liquid fuels.         Noted            tables
Table 3-23: errors in EF for PM10 and PM2.5 (in
column Value are shown as 0, but in column Lower                    Will change with new
– not 0); EF for TSP should be checked.                             tables
Most values in table 3-22 refers to the existing
guidebook, however several of the listed emission
factors do not correspond to the emission factors
provided for wood burning boilers in the existing                   Will change with new
guidebook.                                         Noted            tables

Table 3-26: value EF and 95% confidence interval                    Will change with new
are the same for TSP, As, Cd, Cr, Hg, Pb.                           tables
CO seems to be to high for a diesel engine (liquid
fired) in table 3-26. In the tables 3-24 and 3-25
turbines running on gas and oil are included. In
these two table als gas engines should be
introduced so that the NOx values are comparable
between different prime mover technologies.

See also:
http://www.euromot.org/download/news/positions/st
ationary_engines/Future_stationary_engine_emissi
on_legislation_Nov04.pdf

http://www.euromot.org/download/news/positions/st
ationary_engines/EIPPCB_BREF_euromot_comm
ent_may_02.pdf                                          Noted
Why is there no default emission factors given for
natural gas fired reciprocating engines. It would
seem that a large part of the fuel use for sttionary
engines would be natural gas.                           Accepted   Table included
Suggest to do it the other way round - data
reported to the UNFCCC will have no focus on
wood consumption and thus will likely provide
unreliable numbers. Instead: Results on wood
consumption provided here should be made use of
for the UNFCCC submission also.                         Accepted   Text deleted
The Tier 3 method needs more elaboration. Should                   The choice of methodology
inventory compiliers use the technology based EFs                  is up to the country, the
in Appendix A or not? These EFs tables should not                  significance of the source
be placed in an Appendix if they are part of the Tier              and the resources
3 methodology.                                          Noted      available.
This glossary should either be expanded or
removed.                                                Accepted
Some sources listed as references in the chapter
are missing from the list of references, e.g.
CITEPA 2007, Gustavsson et al. 1993, CEPMEIP
2004, DTI 2005, Guidebook 2006.                         Accepted

I suggest to indicate if emissions factors are based
on field measurements (real conditions) or
stationary conditions which e.g. is the case for
(BLT) 1999 to BLT (2005). Additionally It would be
useful to know how many ovens/boilers have been
measured and if the emission factors are                           We have no additional
representative for e.g. a specific technology which                data - these are as
is typical for a country or region.                  Noted         provided in B216
BLT (2005/2)Hyperlink does not point to a specific
document:
http://www.blt.bmlf.gv.at/menu/index_e.htm.          Editorial     Ref modified
Please correct reference to "Österreichische
Emissionsinventur für Stau*b*" and
"Umwe*l*tbundesamt"                                  Editorial     Ref corrected
Appendix B dos not add much additional
information to appendix C of Chapter 1A1 (they are                  Agree but they are
widely identically). I suggest to just add a table with             separate chapters, not
typical reference O2 concentrations and the 2                       sure we can split out the
Diagrams and add a reference to chapter 1A1.            Editorial   appendix.

                                                                    Not changed, there are
                                                                    many reference O2 levels
                                                                    eg 7, 10 or 11 national
Reference O2 concentration of wood is often 13%.                    preferences apply. EN303
I suggest to add a line for this to the diagrams.    Noted          (boilers <300kW) is 10%
The title of the tables are not visible.             Editorial      Done
The tables are unreadable as they are partly off the
page.                                                Editorial      Done

Emissions that are related to different engine types
are missing e.g. Spark Ignition engine (gas mode).
We recommend to refer on page 102 of the
following document:

http://www.ymparisto.fi/download.asp?contentid=37
08&lan=fi

Furthemore the French limits for Dual Fuel
stationary engines are missing. These should be
added.                                                  Noted
Other details: I reckon a final proofreading will be
performed to take care of a number of editing
issues (incomplete sentences, abbreviations
presented but not explained in Tab 4-4, citations
(CITEPA 2007), and similar)                             Noted       Final checking needed
Lack of line numbering of the chapter on small
combustion will result in fewer line number
referrals.                                              Noted
                                                                    Small CHP for public
                                                                    power uses the same
                                                                    technology as non-
                                                                    residential CHP. Gas
As reference is made to Chapter 1A4, should we                      turbines can often be
understand that industrial engines are the same                     larger than 50 MWth but
than engines in Commercial, Institutional and                       engines are generally
Residential sectors? Does it matter the power of                    smaller (usually a lot
the engine?                                             Noted       smaller).

Taking into account that raw materials have also
sulphur content, where are the net SOx emissions
estimated for cement and lime production?: either
in 1.A.2.f or in NFR categories 2.A.1 and 2.A.2?                    Not relevant to 1A4
tion in the new reporting guideline)                                Comment corrupted ?
For instance the emission factors for CO, SO2,                      Don't see where this is
TSP etc.                                                            referred to
What are the total net SOx emissions, taking into
account the three components: gross SOx from
fuel, gross SOx from raw materials and SOx
captured by raw materials?                                          None
This is wrong and confusing. The SNAP group
080100 contains military activities (and different
fuel types), please refer to error 1d.                   Noted      Done
You must show tables for each NRMM directive
and explain what they contain.                           Accepted   Done

What is the number of this directive?                    Noted      Done
Where is there a precise definition of equipment
level and equipment type? This must be
highlighted.                                             Rejected   Done
Tables for 1A2fii (industry machinery) and 1A4a ii
(Commercial/Institutional: Mobile) emission factors
are missing.                                             Noted      Done
It is necessary to explain, that only agriculture and
forestry machinery are behind the figures.               Noted      Done

Table 3-3: The categorisation of recreational craft
is wrong. These types of vessels must be included        Noted      Done
This sentence gives no meaning. A lot of diesel
fuel is being used by stationary engine, and to
assume all                                               Noted      Done
The LPG fuel type is also present. In fact, you may
consider to use the term fuel/engine type.               Noted      Done
Please be aware that recreational craft and military
vehicles must be treated differently                     Noted      Done
Table 3-13 to 3-16: The figures in this table relates
only to recreational craft. Tables 3-13 (diesel) and
3-15 (4-stroke gasoline) concerns the emission
level prior to the directive 2003/44 emission
standards.                                               Noted      Done

You have forgotten two tables for 2-stroke gasoline
boats, relating to emission levels before directive
2003/44, and for directive 2003/44 emission levels. Noted           Done

Still missing is three emission factor tables for
diesel fuelled equipment in the NFR sector 1A4aii        Noted      Done
This section is essential for inventory makers in
order to allocate fuel into emission layers, but it
gives no guidance at all.                                Noted      Done

A study from 1993 is not recently made. Nothing
has been done to update this part of the text.           Noted      Done
Since there is still no updates in this part, I really
have no opinion.                                         Noted      Done
This table is full of errors. Please use the tables
directly from the old guidebook.                         Noted      Done
Chapter; Non road mobile sources and machinery         Noted   Done

Please refer also to general comments
summarised in the separate word file "DK Review
of guidebook chapters for mobile sources.doc"          Noted   Done
There are many serious mistakes in this chapter.
Some of them relates to 1) errors in NFR code
categorisation                                         Noted   Done
and 2) errors in computed emission factors when
transferring from g/tonnes of fuel to g/GJ.            Noted   Done
Error 1a): The data that is stated for 1A5b (Other)
in the new chapter has nothing to do with military
activities!                                            Noted   Done

These data, submitted by Morten Winther are valid
for boats, and hence represent recreational craft.
The SNAP code for recreational craft is 0803,        Noted     Done
 which is specificly mentioned in the old guidebook.
Following the CLRTAP transfer procedure between
SNAP and NFR codes,                                  Noted     Done
recreational craft are further classified as part of
Navigation 1A3d (agreed by all member states).       Noted     Done

If we want recreational craft to be included in this
chapter, it is necessary to include the code 1A3d ii
(National Navigation) in the table on Page 1.          Noted   Done
Error 1b) In the EMEP Draft 2007 guidelines for
estimating and reporting guidelines the NFR
category 1A4a ii (Commercial/Institutional: Mobile)
now appears.                                           Noted   Done
This category must be included in the table on
Page 1.                                                Noted   Done
Error 1c): The category 1A4c iii
(Agriculture/Forestry/Fishing: National Fishing is
treated in the Navigation chapter.                     Noted   Done
Hence this code should be deleted from the table
on Page 1.                                             Noted   Done
Error 1d): Military mobile activities are NFR
grouped as 1A5b (other), and contains aviation,
land based and sailing activities.                     Noted   Done

If you want to present emf for military in this
chapter you must produce completely new figures,
or perhaps repeat the data from the old guidebook. Noted       Done
Error 2): A calculation error has been made in all
the emission factor tables, when transferring from
g/tonnes to g/GJ.                                  Noted       Done
In the spreadsheets provided by Morten Winther,
g/GJ related emf are calculated. Please use these
factors instead.                                   Noted       Done
Serious omission: the information on test
procedures from the old chapter must be included
(and updated) in the new chapter                        Noted   Done
 It is no help for inventory makers to have such
vague description                                       Noted   Done
The Tier 1 figures in the Tables 3-2 to 3-8 are all
wrong. Please use the factors from Morten
Winther, directly.                                      Noted   Done
 Fishing vessels are treated in the Navigation
chapter.                                                Noted   Done
in the sector 1A3d (Navigation). This follows the
correct transfer between SNAP (0803)                    Noted   Done
and the NFR (1A3d) category. In the current
version of the guidebook, SNAP 0803                     Noted   Done

is clearly described as inland waterways,
containing also the activities by recreational craft.   Noted   Done

 It is a very big mistake not to follow the
nomenclature agreed by the inventory community.         Noted   Done
If you want to present emf for military you must
produce completely new figures, or perhaps repeat
the data from the old guidebook.                        Noted   Done
fuel being used in NRMM would introduce a
serious error in the inventories.                       Noted   Done
Tables: Inventory makers must have the
information of which sales year relates to which
emission layers.                                        Noted   Done
Tables: Tier 2 emission factors prior to stage I
must be split into three technology levels (<1981,
1981-1990, 1991-stage I) instead of applying one
average.                                                Noted   Done
 The differences between layers are too big to
ignore. You must use the data provided by Morten
Winther.                                                Noted   Done
Tables 3-14 (diesel) and 3-16 (4-stroke gasoline)
concerns the emission level corresponding with the
directive 2003/44 emission standards.                   Noted   Done
 It has nothing to do with military equipment! You
are mixing up all definitions.                          Noted   Done
In addition, the Table 3-14 to 3-16 captions include
the NFR category 1A4c: Please stress that it is the
recreational craft part of Navigation we are dealing
with here.                                              Noted   Done
These data I calculated for you also, as a part of
our agreement.                                          Noted   Done
1) You must provide some kind of information, for
instance %-values, which distributes fuel
consumption as a function of engine age for each
NFR code.                                               Noted   Done
Such distribution functions can be derived from the
Winther & Nielsen database.                             Noted   Done
2) You must also provide information of which
sales year relates to which emission layers.          Noted       Done

You can find these data in the relevant directives,
or alternatively derive aggregated sales year
information from the Winther & Nielsen database.      Noted       Done
3) Finally, you must provide information of average
engine life times for the different NFR codes. This
can be derived from the Winther & Nielsen
database.                                             Noted       Done
Change as "The extraction and treatment of coal
result mainly in emissions of methane."               Editorial   Done
Delete the sentence "This sector was estimated to
account for 22% of the total national CH4
emissions in the UK in 1991 (Gilham, 1994)." It's
an old data not relevant for the GB.                  Accepted    Done
Change as However, also NMVOC, PM and CO2
are emitted                                           Accepted    Done
Change "methane emission" with "firedamp
release"                                              Editorial   Done
Delete from not applicable: "TSP, PM10; PM2.5;
Pb; Cd; Hg; As; Cr; Cu; Ni; Se; Zn;" Put in Not
estimated:: "TSP, PM10; PM2.5; Pb; Cd; Hg; As;
Cr; Cu; Ni; Se; Zn;"                                  Accepted
Delete from not applicable: "TSP, PM10; PM2.5;
Pb; Cd; Hg; As; Cr; Cu; Ni; Se; Zn;" Put in Not
estimated:: "TSP, PM10; PM2.5; Pb; Cd; Hg; As;
Cr; Cu; Ni; Se; Zn;"                                  Accepted
Delete from not applicable: "TSP, PM10; PM2.5;
Pb; Cd; Hg; As; Cr; Cu; Ni; Se; Zn;" Put in Not
estimated:: "TSP, PM10; PM2.5; Pb; Cd; Hg; As;
Cr; Cu; Ni; Se; Zn;"                                  Accepted
Insert after the title: "A Tier 3 methodology for
emission factors estimate for open dust sources at
coal mines can be found in US EPA AP42 in
Chapter 11.9 Western Surface Coal Mining (US
EPA, 1998)"                                           Accepted    Done

In the text the reference is Tsibulski not Tisbulski. Editorial   Done
Insert the reference: US EPA, 1998 AP 42,
Compilation of Air Pollutant Emission Factors,
Volume 1: Stationary Point and Area Sources, Fifth
Edition, Volume I, Chapter 11.9 Western Surface
Coal Mining, 1998                                     Accepted    Added to references
There are no guidance of storage of solid fuel.
Should particle emission from coal storage be
estimated and if so there should be a default
emission factor made available.                       Noted
                                                                  EF removed, not
Are you sure PCB = 2 g (it's not mg?)                 Accepted    applicable here
Add the sentence "In this category can be included
Coal Handling And Storage. For this A Tier 3
methodology for emission factors estimate can be
found in US EPA AP42 in Chapter 13.2.4
Aggregate Handling And Storage Piles (US EPA,
2006)"                                                   Accepted   Done
Insert the reference: US EPA, 2006 AP 42,
Compilation of Air Pollutant Emission Factors,
Volume 1: Stationary Point and Area Sources, Fifth
Edition, Volume I, Chapter 13.2.4 Aggregate
Handling And Storage Piles, 2006                         Accepted   Done
Why is venting included in this chapter? It should
be placed in the chapter 1B2c VENTING and
flaring.                                                 Accepted   Done
delete "or liquefied gas": it's included in subsequent
2.1.8 paragraph                                          Accepted   Done

insert a comment about "oil pumps" and indicate
where Emission from these are computed,
particularly when pumps are fuelled by oil (as in the
case of ships pumping of oil at maritime terminal"       Accepted   Sentence added
insert a paragraph about "gas compressor station"
and indicate where Emission from these are
computed                                                 Accepted   Sentence added
The references are very old. The newest one is
more than 20 years old. It should be discussed
whether the data are still valid.                        Noted
I can only agree with the inserted comment, that
better data should be available. This issue should
however had been solved prior to releasing a first
order draft.                                             Noted
I am unable to reproduce the resulting emission
factor in table 3-2 based on the current values in
the existing guidebook. The comment states that
the geometric mean from distribution has been
added based on table 8.17 in the existing
guidebook.                                               Noted

Very strange sentence since the inserted comment                    Comment removed; is
contradicts the meaning of the sentence.         Accepted           wrong

insert a Tier 2 evaluation for 050601Pipelines and
050603 Distribution networks; I think it's a priority    Noted

The values in the existing guidebook varies greatly
from 0.091 to 3.2, therefore just taking a geometric
mean of all values listed without an accompanying
explanation does not seem appropriate.               Noted
The values in the existing guidebook varies greatly
from 0.001 to 3.1, therefore just taking a geometric
mean of all values listed without an accompanying
explanation does not seem appropriate.                   Noted
The values in the existing guidebook varies greatly
from 0.009 to 3.1, therefore just taking a geometric
mean of all values listed without an accompanying
explanation does not seem appropriate. The value
of 3.1 stems from Romania and seems like an
outlier                                                  Noted
As mentioned this chapter is directly copy/paste
from the existing guidebook. A lot of data concerns
venting, this information should be moved to the
correct chapter.                                         Accepted
I would suggested to move factors for venting to
1.B.2.c.                                                 Accepted    Done
delete all the point 3.4.2.5 Oil loading and transport
must be included in 1.B.2.a.v                            Accepted    Done

Erase Table 3-23 as must be included in 1.B.2.a.v        Rejected
Clarify Table 3-24 (in the text erroneous indicated
as Table 8.18): must be included in 1.B.2.a.v and
review the text consequently                             Accepted    Done
                                                                     Checked; some references
A couple of the references are not used in the text. Accepted        removed

Volume title correctly: 1.B.2.a.i, 1.B.2.b.              Noted
Considering the values in that table covers only
distribution the emission factor seems low.              Noted

Delete "Passant, 1993" This reference is no longer
given and theEPA reference is wholly adequate.     Accepted          Done

Figure 2-1: The notation of Heat and its emission is
missing from the chart. See 2nd comment above.           Accepted    Figure updated
In Table 3-2, Section "Abatement Technologies"
the use of thephrase "Primary cyclone......." may be
misleading. To avoid confusion, it is recommended
that the abatement technology isdescribed as
"Cyclone systems installed internally within the
regenerator".                                            Accepted    Done
replace "unit units" with "unit"                         Editorial   Done
Title of Table 3-3 requires amendment as it
currently reads ".......reforming unit units". Delete
the word "unit".                                         Editorial   Done
change "3.3.2.7 Diffuse emissions" with "3.3.2.7
Gasoline storage. For depots of gasoline in
refinery refer to Tier3"                                 Accepted    Done
In Table 3-6, the Upper Confidence Limit looks
incorrect. The samepollutant and EF are given in
the Tier 1 Table 3-1, with an upperlimit of 0.4
instead of 0.6 given in this Table.                   Accepted    Updated to 0.4
replace "This section provides Tier 3 information
for refineries.                                       Rejected

Proposed changed text to clarify where the
cyclones are installed:"The basic catalytic cracking
regenerator design normally incorporates, inside
the regenerator vessel, cyclone systems to
separate the catalyst particles from the
hydrocarbon vapours.Additional cyclones systems
and/or electrostatic precipitators maybe installed
external to the regenerator to abate further the
particulate emissions".                              Accepted     Done

In Table 3-7, the reference for "partial burn with CO
boiler" is wrong. This is not given in CONCAWE
3/07. The oxidation value of 99.5%is given in the
Commission Decision of 29-01-04 on GHG's- see
OJ No. L59, 26.02.2004 (comment later re p24)         Accepted    Done
In Table 3-7, the reference for "full burn
regeneration" is wrong. This is not given in
CONCAWE 3/07. The oxidation value of 99.5%is
given in the Commission Decision of 29-01-04 on
GHG's- see OJ No. L59, 26.02.2004 (comment
later re p24)                                         Accepted    Done

In Table 3-7, the reference for "additional cyclone
stages" is wrong. This is not given in CONCAWE
3/07. A reference to the RefineryBREF should be
given i.e. "European Commission (2003)"               Accepted    Done
In Table 3-7, the reference for "electrostatic
precipitators" is wrong. This is not given in
CONCAWE 3/07. A reference to the RefineryBREF
should be given i.e. "European Commission
(2003)"                                               Accepted    Done
In Table 3-7, to clarify where the "Additional
cyclone stages" arelocated, it is recommended to
change this to "Additional cyclonestages installed
external to the regenerator"                          Accepted    Done
Should this equation be numbered i.e. be equation
"(9)"?                                                Editorial   Done
Should this equation be numbered i.e. be equation
"(10)"?                                               Editorial   Done

References should be (US EPA, 1995, CEN, 2008) Accepted           Done
Reference should be "US EPA (1995)"            Accepted           Done
Reference should be "CEN (2008)"               Accepted           Done
Add new paragraph: "A recent development is the
use of hand-held optical imaging devices to detect
leaking components permitting surveys to be
undertaken more quickly (Epperson et al., 2007)."     Accepted   Done
There are issues on double counting which are
highlighted on page 1,lines 9 to 17. Suggest repeat
here.                                                 Accepted   Done
Reference should be "US EPA (1995)"                   Accepted   Done
Reference should be "US EPA (1995)"                   Accepted   Done

Current text in this paragraph should be deleted
and replaced: Reason: optical remote sensing
techniques can only measure emissions over a
very short time period e.g. a few hours. Emissions
from refinery sources generally vary widely with
time, e.g. floating roof tank emissions are highly
dependent on wind speed. It is not valid, therefore,
to extrapolate these short term measurements to
calculate refinery annual emission inventories
asthis would result in significant errors. It is
proposed that the It is proposed that the following
text is inserted in its place:"Remote sensing using
optical gas imaging may be used to identify,for
example, if any external floating roof storage tanks
are operating outside of the performance bounds
for which emission factors are valid, permitting
focussed maintenanceto ensure that factors can
then be used for these sources forinventory
purposes."                                           Accepted    Done
Reference should be "US EPA (1995)"                  Accepted    Done
Reference EPA 1993 is incorrect. It should be:
"United StatesEnvironmental Protection Agency
(US EPA) 1995. Protocol forEquipment Leak
Emission Estimates. EPA-453/R-95-017. Officeof
Air Quality Planning and Standards, Research
Triangle Park,North Carolina"                        Accepted    Done

Reference CEN (2005) should be updated as this
Standard is now published as EN 15446, 2008.          Accepted   Done
The reference US EPA 1994 is not referred to in
the chapter. It should be removed from the list.      Accepted   Done
If the proposed text addition above (p 22, line 7) is
accepted, thenthere is the need for a new
reference: "Epperson, D et al. "Derivationof new
emission factors for quantification of mass
emissions whenusing optical gas imaging for
detecting leaks". Journal of the Air andWaste
Management Association (JAWMA), Vol. 57, Issue
No. 9,September 2007".                                Accepted   Done
A new reference is required for Table 3-7 (see
comments above). This is: "European
Commission (2004), "Commission decisionof 29
January 2004 establishing guidelines for the
monitoring andreporting of greenhouse gas
emissions pursuant to Directive2003/87/EC of the
European Parliament and of the Council
(2004/156/EC). Official Journal of the European
Communities No. L59, 26.02.2004"                        Accepted    Done
No EF for SNAP 050402                                   Noted
The figure is nice. A similar one should be provided
for marine terminals or include marine terminals in
the present figure 2.1                                  Noted
Add the reference: ARPAT (2007) Agenzia
Regionale per la Protezione Ambientale della
Toscana, Monitoraggio delle aree geotermiche.
Rapporto Finale, Anno 2006, Novembre 2007               Rejected
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Propose change "There are two major sources ..."
to "There are three sources ....". Reasons:
following the statement are listed three sources, of
which only one (standing storage emissions)
issignificant.                                          Accepted    Done
Replace "into a cargo tank truck" with "into a cargo
tank truck or ship"                                     Editorial   Done
Add "occur when" at start of this line to follow on
from line 8.                                            Editorial   Done
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Reference should be "European Commission,
2006" not "EIPPCB, 2005"                                Editorial   Done
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Should be "European Commission, 2006" not
"EIPPCB, 2005"                                          Editorial   Done
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Change "reportedly" to "reported".                      Editorial   Done
AR - gasoline production statistic (p. 11, row 8). On               Descriptions harmonized;
the p.12, row 12 - amount of gasoline sold should                   gasoline sold is relevant
be used as activity statistics                          Accepted    activity here
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Give a definition of oil product. What products have
to be included? gasoline, gas oil, fuel oil, aviation               Description made more
gasoline, distillate oil ….?                            Accepted    clear
What is throughput : crude oil ? Something else?
Define please. Provide also some default values
for average vapour pressures for the different
products from crude oil to naphtha, gasoline, gas     Consult with Gasoline considered here,
oil…                                                  Expert Panel has been added to text
What is throughput : crude oil ? Something else?
Define please. Provide also some default values
for average vapour pressures for the different
products from crude oil to naphtha, gasoline, gas     Consult with Gasoline considered here,
oil…                                                  Expert Panel has been added to text
What is throughput : crude oil ? Something else?
Define please. Provide also some default values
for average vapour pressures for the different
products from crude oil to naphtha, gasoline, gas     Consult with Gasoline considered here,
oil…                                                  Expert Panel has been added to text
What is throughput : crude oil ? Something else?
Define please. Provide also some default values
for average vapour pressures for the different
products from crude oil to naphtha, gasoline, gas     Consult with Gasoline considered here,
oil…                                                  Expert Panel has been added to text
What is throughput : crude oil ? Something else?
Define please. Provide also some default values
for average vapour pressures for the different
products from crude oil to naphtha, gasoline, gas     Consult with Gasoline considered here,
oil…                                                  Expert Panel has been added to text
In the table 3-6 SNAP 050501 or 050401 (marine
terminals?)                                           Accepted     Correct here
references should not be guide book 2006 but
CONCAWE 2007                                          Accepted     Done
What is throughput : crude oil ? Something else?
Define please. Provide also some default values
for average vapour pressures for the different
products from crude oil to naphtha, gasoline, gas     Consult with Gasoline considered here,
oil…                                                  Expert Panel has been added to text
What is throughput in service station stations,
gasoline and gas oil? Provide default vapour                       Reference made to US
pressures or explain how to get them                  Accepted     EPA description
What is throughput in service station stations,
gasoline and gas oil? Provide default vapour                       Reference made to US
pressures or explain how to get them                  Accepted     EPA description
What is throughput in service station stations,
gasoline and gas oil? Provide default vapour                       Reference made to US
pressures or explain how to get them                  Accepted     EPA description
Replace "previously contained gasoline" with
"previously contained crude oil, gasoline or other
highly volatile products"                             Editorial    Done

Add "is" between ".....pressure" and "the vapour ..." Editorial    Done
Table title should be 3-12                            Editorial    Done
Directive number is 94/63/EC, not 63/94/EC            Editorial    Done
What is throughput in service station stations,
gasoline and gas oil? Provide default vapour
pressures or explain how to get them                    Accepted    Done
Why it is not throughput but gasoline?                  Noted
the efficiency of 98 % is too optimistic in real life
the efficiency is lower. 90 to 95 would be more
reasonable.                                             Noted
Concawe considered the methodology as obsolete!
Replace all with the sentence "For depots of
gasoline in refinery refer to Tier3"                    Rejected

This explanation comes too late. However not only
gasoline is volatile. Aviation gasoline, Naphtha,
crude oil are stored and displaced. They have to be
considered. Gas oil could be considered if
necessary in countries with high temperature.       Accepted

The efficiency of 90 % is too optimistic. From
studies carried out in France the efficiency for a
station with an active system working correctly is
80 %. You have also to consider that due to poor
maintenance, most active systems become less
efficient and some of them are out of service. If you
do not have statistics on the % of active systems
working correctly, an average efficiency taking into
account the systems out of service can be 60%.
The EGTEI document (see the EGTEI web site)
describes this situation. This situation is common in
Europe. Germany and Switzerland have recently
implemented the use of self controlled active
systems (the equipment of existing stations should
be finalised in Germany this year and 10 % of                       Comment taken into
service stations are already equipped in                            account; some text on this
Switzerland.). Only with such systems, the                          added and reference to
efficiency can rise up to 90 %.                       Accepted      EGTEI made

Delete "For example, it will use a knowledge of
equipment components fitted in the refinery to
provide estimates of process fugitive emissions."
as this example is not relevant to this NFR.            Accepted    Done
Directive number is 94/63/EC, not 63/94/EC              Editorial   Done
Should be Table 3-13                                    Editorial   Done
The text currently in 4.5 seems more appropriate
here than in 4.5                                        Accepted    Done
Change "For storage ..." to "For example, for
storage ..."                                            Editorial   Done
Propose move to Section 4.2                             Accepted    Done
Add "refinery" before "storage" to clarify what is in
040104.                                                 Accepted    Done
Add "terminals and " between "marketing" and
"depots" to ensureall facilities are captured.          Editorial   Done
Glossary: Stage I Controls - "terminals (dispatch
stations)" should be replaced by "refinery dispatch
stations".                                            Editorial        Done
Glossary: True Vapour Pressure - suggest add
"See section 3.3.2.1"at the end of the definition as
the formula to calculate TVP is giventhere.           Accepted         Done
Glossary: Vapour Destruction Unit (VDU). Delete
this definition, asVDUs are not described in the text
as not permitted in EU.                               Accepted         Done

" with : "For storage tank emissions Concawe
report suggests the use of the latest edition of API
documents for Floating Roof Tanks (API,2003),
and Vertical Fixed Roof Tanks (API, 2002). For
Aboveground Horizontal Tanks, Concawe report
suggests to use the latest edition of U.S. EPA
methodology (U.S.EPA, 1995). Note that this
reference normally contains the latest version of
previously quoted API methodologies. An emission
calculation software is available from the US EPA
via their website, http://www.epa.gov, or on a CD-
ROM(U.S.EPA, 2005). This CD also contains the
EPA publication (U.S.EPA, 1995) and API
documents (API 2002; 2003)."                             Rejected
replace "Most emission factors are taken from the
Guide to Geothermal Energy and the Environment
(Geothermal Energy Association, 2007), available
via http://www.geo-
energy.org/publications/reports/Environmental%20
Guide.pdf." with "Emission factors results from
measurement performed by the environmental
protection agency of Toscana region, Italy (ARPAT,
2006). The region is the main Europe producer of
this kind of energy.                                     Accepted      Done
Delete!                                                  Rejected
Due to differences in chemical composition of
geothermal fluid, site dependent emission factors                      Added to text as a
obtained by sampling is suggested.                       Rejected      preferable option

Since the authors, judging by the inserted
comment, do not know, what is meant, I will take a
crack at solving the mystery. My best bet is that line
19-20 and line 21-22 should also be part of the                        Thanks! Now it makes
bulletpoints, then it all makes sense!!                  Accepted      more sense.
Is there a particular resaon why the emission factor
are expreesed in g/Sm3, or is it just because that is
the units used in the existing guidebook? g/Nm3 og                    All updated to g/Nm3 for
g/GJ could be used.                                      Accepted     harmonization.
Despite all the mentions of venting, this table is                    Table heading updated.
about flaring not venting. Data stems from the                        Quality rating updated,
existing guidebook, where the quality is C and not       Consult with therefore uncertainty range
D as mentioned in the inserted comment.                  Expert Panel updated as well.
If the factors only are applicable for Norway, the
relevance of having them in the guidebook would
seem miniscule.                                         Noted



replace "For the types of storage tanks used to
store volatile liquids at refineries, emission
estimation methodologies are provided by the US
EPA (EPA, 2006). These methodologies require
information on the tank contents, size, shell colour,
floating roof fitting types and number, etc., on a
tank-by-tank basis. Emission calculation software
utilizing the algorithms in the US EPA publication is
available on the EPA website http://www.epa.gov,
or on a CD-ROM (EPA, 2005). " with "For storage
tank emissions Concawe report suggests the use
of the latest edition of API documents for Floating
Roof Tanks (API,2003), and Vertical Fixed Roof
Tanks (API, 2002). For Aboveground Horizontal
Tanks, Concawe report suggests to use the latest
edition of U.S. EPA methodology (U.S.EPA, 1995).
Note that this reference normally contains the latest
version of previously quoted API methodologies.
An emission calculation software is available from
the US EPA via their website, http://www.epa.gov,
or on a CD-ROM(U.S.EPA, 2005). This CD also
contains the EPA publication (U.S.EPA, 1995) and
API documents (API 2002; 2003)."                        Rejected
No need to repeat a completely identical table.         Rejected
The sentence about uncertainty makes no sense.
No quality codes are provided in this chapter, so
comparison with the uncertainties chapter is rather
difficult.                                              Accepted   Sentence removed
PM10 should be removed from the table and
placed under NA or NE.                                  Accepted   Fixed
In the "Not Applicable" list for Table 3-5, PM10 is
given. However,this is also shown in the Table as
"NE". Should it be listed,therefore, in the "Not
Estimated" list?                                        Accepted   Fixed

In Table 3-5, the following pollutants should be
deleted from the"Not Applicable" list as EF's are
provided: PM10, Pb, Cd, Hg, As, Cr. Cu, Ni and Zn. Accepted        Fixed
Why no glossary for this chapter?                  Noted
                                                                   All EFs that are equal to
An emission factor of 0 is clearly not acceptable,                 zero removed, moved to
either there is an emission factor or the pollutant                NA or NE according to
should be listed as not applicable.                     Accepted   reporting template
The CO and NMVOC emission factors are a factor
10 lower from the reference chosen compared to
the other references in the existing guidebook. At
least a note explaining the comparatively low
values should be offered.                          Noted
Erase 30311 Cement (is included in B1 Energy)
and erase (decarbonising) from 40612               Accepted      Done

Chapter contains scarce information necessary for
emission inventory from cement production. There
are 5 short tables with only PM emission factors.
Chapter should be supplemented and updated.       Noted
Proposals: two Tier 2 tables applicable for EECCA
countries were suggested for the Guidebook: for
wet and dry cement production with averaged
levels of abatement.                              Accepted       Two new tables introduced

"This chapter only considers emission of particulate
matter from cement plants, which is mainly the PM
from pre- and aftertreatment". If this is the case,
where can we find the emission factors of the pre-
and aftertreatment processes?                        Noted

For many of the pollutants listed in the mentioned
lines the BREF states that a significant contribution
comes from the materials processed.                   Noted
In this statement, the ammonia appears as an
important pollutant to be considered in the cement
production but, in the rest of the document, the
ammonia does not appear and in the tables is
treated like " not applicable ".                      Accepted   Statement corrected
Subchapter 2.3 Emissions contains long list of
pollutants emitted during cement productions and
processes are described but Tier 1 and Tier 2
Tables 3-1-3-3 gives only particulate emission
factors.                                              Noted

The text concerning emissions of SOX originating
from fuels or raw material can be misunderstood. Noted
Erase "For Tier 1 the emissions of NOx, CO,
NMVOC, SOx, heavy metals and POPs can be
assumed to be mainly due to the combustion of the
solid and waste fuels and will be included in the
emission factors used for chapter 1.A.2.f.i. To
avoid double counting estimates should be made in
the chapter 1.A.2.f.i. In the Tier 1 approach they
will, as far as they originate from the chemical
composition of the raw meal, be reported as “Not
Estimated”."                                       Rejected
Move B(a)P, B(b)F, B(k)F, CO, DIOX, HCB,
Indeno, NMVOC, NOX, SOx, from Not estimated
to Not applicable                                      Rejected
Erase Tier 2 (is a copy of Tier 1) because it
generates confusion                                    Rejected

Tables 3-1-3-3: these tables include only 3
emission factors each which are the same. Tier 2
tables for wet and dry processes include the same
factors for different cement production processes
and same with Tier 1 – this is not true and
contradicts to Tier 2 approach determination.
Reworking of EF tables is necessary.              Rejected

Tables 3-1-3-3: there are no emission factors for
heavy metals; it is shown that they are accounted
in 1.A.2. But it is known that heavy metals are
emitted with particles. So it assumed that cement
particulate do not contains heavy metals? And it is
assumed that only particulate is abated while heavy
metals are emitted unabated?                           Rejected
Table 3.1: EF seem to be too high, if quarry is
excluded as presented in Figure 2-1                    Noted
No need to present the same default EF in three
tables: 3-1, 3-2 and 3-3                               Rejected
"The Tier 1 emission factors have been used in the
Tier 2 approach as well". This sentences amounts
to say that there is no Tier 2 approach for the wet
kiln process!                                          Noted
                                                                   Equation numbering
"and the algorithm in equation (3) reduces to:"        Editorial   corrected
"The feeding of dry material into the kiln will
however typically result in higher emissions of dust
as compared to the wet kiln process".                  Noted
" ..the Tier 2 emission factors for the dry kiln
process in Table 3-3 are the same as the Tier 1
default emission factors presented in Table 3-1".
This sentences amounts to say that there is no Tier
2 approach for the dry kiln process!                   Noted
Descriptions of algorithms occupy 2 pages while
only 3 factors available; what is the usefulness of
these algorithms?                                      Noted
Delete "from"                                          Editorial
                                                                   Simplest correspondance
                                                                   included plus a reference
Table 4-1: How does this table correspond to                       to the BREF if more
tables 3-27 - 3-31 (1A2)? Present the                              detailed information is
correspondance between the different units             Accepted    requested
References contain only 4 sources including 2
BREFs: it is too short.                                Noted
The indication I.E. for the pollutants present also in
Combustion activities is ambiguous; it's not clear if
there are part of process emissions evaluated in                       Indication removed from all
combustion or if there are combustion emissions        Accepted        chapters; now in NE
                                                                       Equation numbering
Where is the equation (3) in the document?              Accepted       corrected
We consider that this is a very serious drawback
for process emission estimation in this sector (key
source for many pollutants as heavy metals from
the very kilned raw materials (whose emission
factors do not appear at all))                          Noted

for many of the pollutants listed in the mentioned
lines the BREF states that a significant contribution
comes from the materials processed.                     Noted
It is considered that the ammonia in not an
important pollutant to be considered in the cement
production?                                             Accepted       NH3 in NE instead of NA
We consider that this is a very serious drawback
for process emission estimation in this sector (key
source for many pollutants as heavy metals from
the very kilned raw materials (whose emission
factors do not appear at all))                          Noted
So the question arises: where are you allocating
these emissions and what are the corresponding
emission factors, if their emissions have not been
computed in the combustion activity (1.A.2.f.i), and
there is not information on them in this process
actvity?                                                Noted
The proposed EF are very high compared with
BREF use TSP from BREF and estimate fraction of                        Replaced with BREF
PM10 and PM2,5                                          Accepted       factors

It is assumed that heavy metals are mainly due to
fuel combustion so they are accounted in 1.A.2.f.i.
So it supposed that lime particulate do not contains
heavy metals? And abatement affects particulate         Consult with
and not affects heavy metals?                           Expert Panel
Table 3.1: EF seem to be too high, if quarry is
excluded as presented in Figure 2-1                     Noted
Delete: EFs very old; substitute with controlled / no
controlled TSP from BREF and estimate fraction of
PM10 and PM2,5                                          Accepted       Done
Chapter contains mainly headings, algorithms and
table without emission factors. It should be                           Some headings removed
supplemented.                                           Rejected       to make more readable
Nevertheless a decision tree is possible: For
Germany we have the question clarified whether
information from sectors limestone used are
available. With "Yes" like in Germany all
calculations are made in sectorspecific chapters,
so 2.A.3 shows only "IE". With "No" an estimation
under 2.A.3 is necessary. In Germany we have
made for verification a limestone balance with the                Decision tree and some
full set of production and use and so identified                  text on this issue added to
gaps, which were closed in different sectors.         Accepted    chapter
It is not mentioned that heating emission is taken
into consideration in 1.A.2.c.                        Accepted    Added to chapter
See comments to german limestone balance
before.                                               Noted
See comments to german limestone balance
before.                                               Noted
See comments to german limestone balance
before.                                               Noted
See comments to german limestone balance
before.                                               Noted
11 subchapters of the chapter consist only of
heading and comment: No specific issues. Maybe
it will be better not to show this chapter at this                Some of the multiple
stage at all?                                         Noted       headings removed
Correct the mentioned BREF and write "… is
available in the BREF "Large volume inorganic
chemicals - solids and others (European
Commission, 2007)                                     Editorial   Done
Correct the word "Boudart reaction" into
"Boudouard reaction"                                  Editorial   Done

Round the EFs value. Ammonia lower value = 0,6        Accepted    Done
Table 3-1: emission factors are with 6 digits after
point – it is too much.                               Accepted    Corrected
table 3-1: the emission for NH3 given in the BREF
is 0.6-1.5 (LVIC-SAO, chapter 2.3.3.5)                Accepted    Corrected
Delete: no clear, no necessary                        Rejected
The BREF documents don't present emission limit
values, but BAT-associated emission levels (BAT-
AELs) - delete the sentence "This section provides
emission limit values (ELVs) as defined in the
BREF document"                                        Accepted    Done
                                                                  Error - value should not
Can't find the cieted value for NH3 in the BREF -                 have appeared here.
cite correct or delete value.                       Accepted      Removed.
Interpretation is correct as Asphalt Roofing
Materials                                           Noted
"...with the exception of asphalt blowing, which is
inventoried separately under NFR source category
1.A.2.f.i".                                         Accepted      Corrected to 3.C
Figure 2-1: The notation for Heat or Fuel and its
emission are missing.                               Accepted
Table 1-3: Mostly the production data are included
in quadrat m. I would recommend the inclusion of
factor-information from this, as well.              Accepted
Decision tree is proper for production only,
emissions of application seem to be relevant are in
Germany calculated too. The decision tree has to
refer to the complete number of application of
roofing materials.                                  Accepted

The proposed EFs from old GB are obsolete: there
are a new US EPA chapter in AP42                 Accepted       Done

The proposed EFs from old GB are obsolete: there
are a new US EPA chapter in AP42                 Accepted       Done

The proposed EFs from old GB are obsolete: there
are a new US EPA chapter in AP42                  Accepted      Done
The reference is obsolete new one is U.S.
Environmental Protection Agency (U.S. EPA),
1995. “11.2 Asphalt Roofing” Compilation of Air
Pollutant Emission Factors: Stationary Point and
Area Sources. AP-42, Fifth Edition. Office of Air
Quality Planning and Standards, Research Triangle               Old reference replaced by
Park, North Carolina.                             Accepted      new one
This statement is not correct because asphalt
blowing should be in NFR source category 3.C.     Accepted      Corrected

                                                                Some information from
                                                                030313 used as well.
                                                                There appears to be
                                                                overlap between the two
                                                                chapters in the previous
                                                                Guidebook and also the
                                                                EPA reference given in this
                                                                comment.
The chapter is wrong! The content can be                        My best guess is that both
appropriate for activity 030313 Asphalt Concrete                the Mix Asphalt plants and
Plants (that was expired from new GB), but EF and               the asphalt application on
reference are old, a new AP42 chapter was                       road should be taken into
produced. The chapter following my interpretation               account. Chapter has
refers to asphalt application on road! and concern Consult with therefore not been
VOC emissions (see US EPA AP42 chapter 4.5). Expert Panel subsequently updated.
Figure 2-2: Heat and its emission are missing from
the chart.                                         Accepted     Added to figure.
Here seems a mix-up to be: reference to cement
and lime are not useful.                           Editorial    Corrected
The emissions factor indicates a mass rate of
about 20%, what is not usually, please see under
EF_comments.                                       Accepted     Done
Chapter consists of mainly headings. It includes
one table with 3 PM emission factors (for all mining
processes) which seem underestimated. List of
References includes one source.                      Noted
AR - not lime production (page 3, row 11), but floor
area of the building construsted (page 4, row 3 or
p.3 row 21)                                          Editorial     Corrected

Table 3-1 and 3-2 are exchanged                        Rejected

AR production -activity rate for the lime production   Editorial   Corrected
AR - the activity rate for the storage, handling and
transport                                              Editorial   Corrected
In Glossary table - AR production -activity rate for
the lime productionThe right definition as on the
page 4, row 15                                         Editorial   Corrected
This chapter includes 6 sources, 5 connected with
glass production: Flat Glass, Container Glass,
Glass Wool, Other Glass, Glass (decarbonizing).
Why they were not included in a separate chapter
“Glass production” like Limestone and Dolomite
taking into account contribution into heavy metals
emission?                                              Noted

Please, make sure to use the most up-to-date
sources for technical information and emission
factors                                               Noted
According to a not yet published research project
on emission factors of the german glass and
mineral wool industry, 35% cullet is used in the flat
glass production                                      Noted

Please, provide updated information on preheating
or remove the word currently in line 7 since the
source is 11 years old!                                Accepted    Done
please, provide the source to table 2-2.
Furthermore, VDI 2578 on the emission control in
glass works provides more detailed information on
the energy demand of carious glass types and
furnaces                                               Accepted    Done
Please, provide updated information on soda lime
glass manufacturing via electric heating or remove                 Text updated for as far as
the word currently in line 39 since the source is 11               new information available;
years old!                                             Accepted    old information removed
About 8 pages of the chapter are devoted to
reduction measures for NOx and SO2; this is not
balanced with other chapters especially taking into
consideration that gases are not accounted in
2.A.7.d chapter.                                       Noted
                                                                  Obvious outdated
                                                                  information removed, no
Please, update the information on fuel staging in                 updated information
Germany                                               Accepted    available
                                                                  Obvious outdated
                                                                  information removed, no
Please, update the information on Low-NOx in                      updated information
Germany                                         Noted             available
Please, update the information on Oxyfuel-using
furnaces. In western Europe TV-glass is not
produced anymore and could therefore be deleted                   Obvious outdated
from the listing expect for the case that the                     information removed, no
producing plants in eastern Europe are using                      updated information
Oxyfuel.                                        Noted             available
                                                                  Obvious outdated
Please, update the information on SCR. There is                   information removed, no
no TV-glass production Germany anymore.                           updated information
Therefore, remove the listing in line 5               Noted       available

AR production -activity rate for the lime production,
not correctedwould be glass production (page 22,
row 2 or 5)                                           Editorial   Corrected



VOC emissions see EPA AP42                           Noted
In all tables PAH by substance included into row
"not estimate"and to row "not applicable" as PAHIt
would be more correct if Tier tables in all chapters
have been madein identical format (sequence of
rows):NFRSNAP (if
applicable)FuelPollutantsTechnologies (for Tier 2-
3)Region (for Tier 2-3)Abatement technologies (for
Tier 2-3)NENA                                        Accepted     All corrected
The heavy metal EF refer to the Guidebook (2006) -
some in general and some to Jockel (2001).
However, for lead crystal glass the general EF is
used instead of EF for special glass (e.g. lead                   HM EFs removed where
crystal)?                                            Noted        not applicable

Tables 3-2 to 3-10 contain emission factors which
seem to be too high (by approximately factor 10
and more) according to the preliminary final report
of a research project on emission factors of the
German glass und mineral fibre industry. The
report is expected to be published in May 2008.
Some examples are listed in the EF-comments
spread sheet. They refer to the year 2005 and sum
up energy- and production-related emissions.        Noted
Tables 3-2, 3-3 (Tier 2): PM and HM EF for Flat
glass and Container glass are the same: this is not
true because technologies are different.
                                                    Noted
Tables 3-2 to 3-10 contain emission factors for
which the reference year is not mentioned. Please,
add this information. Furthermore, to our
knowledge it is very common to use the metal
classes I to III. Therefore, they should be used in
the handbook as well.                               Rejected

It is stated that “Heavy metal emission factors from
the Tier 1 table for this source category are added
to the table in order to fill the gap” –
methodologically this is not good because as
declared Tier 2 is more sophisticated approach
which provide more accurate estimates; generally
Tier 1 tables should originate from Tier 2.          Noted

Table 3-5: heavy metals emission factors are the
same as in Tier 1 Table 3-1 while TSP EF is
different.                                            Noted



Tables 3-11-3-12: errors (not lime production).       Editorial   Corrected
Subchapter 3.3.2.5 includes 5 tables (3-6 – 3-10)
with the same HM EF for different types of glass.
This is not true: every type of glass has different
content of HM thus emissions will be different;
differentiation is especially important for lead
crystal glass.                                        Noted

Tables 3-6 – 3-10: Guidebook 2006 as referenced
in these tables does not contain such emission                    All checked. EFs removed
factors.                                        Accepted          where not applicable.


In the tables 3-11, 12 (glass production) the NFR
code is 2.A.2 - lime production, would be 2.A.7.d     Editorial   Corrected


Glossary, AR production - the AR for the lime
production??                                          Editorial   Corrected



Visschedijk (2004) is missing in the References       Editorial   Added
The SNAP for the organic chemical industry is
absolutely not adapted and not representative of all
productions of chemicals substances. The list of
products from SNAP 040501 to 040526 is not
sufficient. The problem is also liked to the fact that
products accounted under different SNAP code,
are produced by the same process (ethylene and
propylene are the best example)                        Noted

The problem of carrying our emission inventories
for the organic chemical industry is related to the
decrease in the availability in statistics. Most of the
production of products considered in the SNAP are
not available in current national statistics.           Noted


the first SNAP 040501 and 040502 represent the
same process, the steam cracker. See the                Consult with
description in the EGTEI document as example.           Expert Panel
SNAP 0405025 and SNAP 040526 should not
exist. There are redundant with SNAP 060306 if
this one becomes speciality organic chemical
industry                                                Noted
SNAP 040622 should also related to the speciality
organic chemistry                                       Noted

spelling mistake: correct "gassified" into "gasified"   Editorial      processed
Figure 2-4: Please correct "Adsorption" into
"Absorption"                                            Accepted       processed
footnote 5 is not existing below                        Editorial      not found
correct reference to the BREF is missing                Accepted       processed
Ammonia Tier1: I don't found correspondence with
quoted BREF values                                      Rejected
table 3-1, column "reference": what does LVC ACF
mean: define reference (Probably you mean the
BERF "Large Volume Inorganic Chemicals -
Ammonia, Acids and Fertilisers" (LVIC - AAF)
December 2006?)                                         Editorial      processed LVIC AAF
the paragraph mentions only two primary sources
of pollutants, but in the table 3-1 below you find
three pollutants                                        Editorial      processed
spelling mistake: correct "Tier 2 ort Tier 3" into
"Tier 2 or Tier 3"                                      Editorial      processed
put in a space between "tier 1" and " emission
factors"                                                Editorial      not found
write "Tier" always in the same spelling: either with
a capital (see line 1 to 5 on the same page) or in
lower cases.                                            Editorial      processed
Nitric Acid Tier1: It's better to use BREF average
value: 10.000                                           Accepted   Processed


Adipic Acid Tier 1:Why no values when can be
found in US EPA AP45?                                   Rejected

table 3-4: the upper and lower value can not be
found in the refered BREF. Table 7.10 of LVIC
SAO shows the emission factors for different
abatement technology you refer to as tier 2 (s.
table 3-16)                                             Rejected   procesed




table 3-5: delete table 3-5, because of to many very
different production processes in 2 B 5              Rejected



Table 3-5; delete this table; it is impossible to
create a emission factor for the whole chemical
industry                                                Rejected
Ammonia Tier2: Use IPPC BREF value and
introduce also Tables for controlled process from
IPPC BREF                                               Rejected
table 3-6: the conventional as well as advanced
processes are not abatement technologies, but
process technologies - expand the text in line 2,
column 6 with the text from line 8, column 2 and
delete the text in ine 8, column 2                      Accepted   processed
table 3-6: the reference of the values given here is
the guidebook 2006 - but there are no datas! The
reference for NOx (CO?) seems to be LVIC AAF,
table 2.7? Define the reference of the data             Accepted   processed
Ammonia Tier2: Introduce also Tables for
controlled process from IPPC BREF                       Rejected
Nitric Acid: erase table 3-8, for unspecified process
use Tier 1                                              Accepted   Processed

table 3-10: please define why the value is below
the range                                               Accepted   processed
table 3-13: only the value of 5000 refers to French
and German plants, the range of 100-1000 refers
to US plants - define how to use value and range
(why is the range lower than the value?)              Accepted   processed

table 3-15: referring to the guidebook 2006 the data
for the extended absorption does also apply for
medium and high pressure processes - add in line
6/column 2 medium and high pressure processes Accepted           processed
Adipic Acid Tier 2:Why no emission when values
can be found in US EPA AP45?                         Rejected
table 3-18: line 6, column 2: change "withuUsage"
into "with usage "                                   Editorial   processed

the SNAP classification 040303 belongs to the
group of metallproduction and not to the chemical
processes - 2B5a doesn't include either the silicium
production nor synthetic amorphes silica and
silicates - please check this issue.                  Accepted   prcocessed
In the last line you write, that TSP has not been
estimated - but in line 11 you have a value for TSP -
please check                                          Noted
table 3-21: line 9 says that decomposition plants
are included - but table 3-22 is covering the
decomposition plants. Change "Including" into e.g.
"without Decomposition plants"                        Accepted   processed


Ammonium Nitrate EFs from US EPA AP45                 Accepted   processed




Ammonium Sulphate: NH3 value from old Corinair
references, COV from Economopoulos, 93, PM
from EPA                                       Accepted          Processed




NPK fertiliser: NH3 old Corinair EF                   Rejected   Processed
There are not emission factors for NPK fertilisers
production.                                           Noted
Urea: PM, PM10, PM2,5 from US EPA AP45                Accepted   processed
In this lines the dimension unites for TSP and NH3
are in the range of kg/t, but while using the same
numerical value you have in table 3-28 the
dimension unit g/t. Please check the
dimensions/values.                                 Noted
table 3-29: The BREF LVIC-SAO is cited incorrect
(s. also Excel sheet "EF_Comments". I also
couldn't find in the BREF emission values for PM10
and PM2,5. Please cite accurately.                 Accepted    processed

Chlorine production. Table 3-33 Tier 2: Hg
emission is shown as NE – it need to be estimated
taking into account contribution of Chlorine
production by this method into mercury emissions. Accepted     processed




Chlorine production: Use BREF values                Accepted   processed
Table 3-36: emission factor for Cd is missed.       Noted




Naphtha is not the unique feedstock in Europe for              Added note on other
steam cracking.                                     Accepted   feedstocks
The list of products provided is not complete.
Please provide all possible products to avoid
double counting by not specialists.                 Noted
In France in 2005 the emission is different as the
volumes produced are different. The emission
factors provided for ethylene and propylene are the
correct one to represent the emissions of the
steam crackers if we are able to allocate the
emissions of the steam cracker in all the different
types of products manufactured by this process. In
the Netherlands ethylene and propylene represent
only 49 % of the total products coming from the
steam crackers. What are the other products? Add
an explanation to consider them in SNAP 040527 if
the product is not considered in an other item of
the SNAP. If you do not recommend to proceed as
above, the emissions of the steam crackers are not
correctly estimated                                 Accepted   processed
Table 3-37; BREF LVOC: range from 0,03 to 6 kg/t
ethen and not 0,4 to 10 in table 3-37.              Accepted   accepted
Polyethylene: use BREF values                       Noted




Table 3-41; BREF Polymers: range (LDPE) 0,7 to
1,1 kg/t for new plants and 1,1 to 2,1 kg/t for
existing plants and not 2 to 3 kg/t                 Rejected

The EGTEI document on chemical industry
presents emissions from the suspension PVC                     processed, accepted for
process developed with the industry organisation.              NMVOC, TSP EF's
The emission factors could be used.                 Accepted   unmodified




Table 3-42; BREF Polymers: range (HDPE) 0,3 to
0,5 kg/t for new plants and 0,5 to 1,8 kg/t for
existing plants and not 1 to 3 kg/t.                Rejected


Table 3-43; BREF Polymers: range 18 to 45 g/t S-
PVC and not 18 to 100                               Rejected
Table 3-44; BREF Polymers: range 100 to 500 g/ t
E-PVC and not 18 to 1000                         Rejected

Table 3-45; in BREF Polymers the emission factor
for PP is in the range of HDPE (see above)       Noted
Polystyrene, Wrong reference: data from BREF     Noted
Polystyrene, Wrong VOC EF: correct BREF value
3200                                             Noted




Table 3-48; BAT for HIPS is about 85 g/t (BREF
Polymers)                                        Rejected
Table 3-49: BREF Polymers: range (EPS) 0,45 to
0,7 kg/t                                         Accepted   processed




Table 3-47; BAT for GPPS is about 85 g/t (BREF
Polymers)                                        Rejected
Table 3-50: BREF Polymers: range (E-SBR) 0,17
to 0,37 kg /t                                    Accepted   processed
Styrene Butadiene Rubber very lower VOC from
BREF (170-540)                                   Noted
Ethylene oxide: wrong reference and incomplete
data                                             Noted

BREF LVOC: in the case of tratment by oxidation
the emissions are considered to be zero         Accepted    processed
Formaldehyde: the reference was wrong BREF but
not polymers                                    Accepted    Processed
Table 3-55:BREF LVOC reportet emissions of
about 0,11 or 3 to 5 kg/t. The reference BREF
Polymers is wrong.                              Accepted    processed

Table 3-56: The reference is wrong (BREF LVOC) Accepted     processed

Table 3-57: the reference is wrong (BREF LVOC)   Accepted   processed
Ethylbenzene: EF from BREF ?                     Accepted   Processed


                                                            made a reference to the
Table 3-61; Please add LVOC as reference         Rejected   BREF instead
Table 3-63: EF for POPs pesticides production is
shown zero. It is written that “emissions of all the
different pesticides are assumed to be neglible
compared to product”. But Chapter “2. E
Production of POPs” contain EFs for all POPs         Consult with
pesticides (10 kg/Mg product).                       Expert Panel
As said before the SNAP 040527 has to be
completed to give examples. In France as
example, all chemical production which can not be
classified in the previous SNAP are put under this
SNAP "other" and their emissions represent a large
amount of total emissions of the organic chemical
industry (30 % at least)                             Noted

Is this chapter useful? Nothing is given to try to
estimate the amount of organic chemical products
stored per t of production. There are no statistics
on the quantity of organic chemicals stored. A way
to estimate them should be useful.                      Noted
Not clear                                               Noted
table 4-1: the BAT-associated emission value
referred to the BREF LVIC-AAF is not for NH3 but
for NOx - write "NOx" instead of NH3; please
define also the reference (LVIC-AAF)                    Accepted    processed
table 4-2: the BAT-associated emission value
referred to the BREF LVIC-AAF is not for NH3 but
for NOx - write "NOx" instead of NH3                    Accepted    processed

title of the table: the EF given apply not only for
conventional reforming processes, but also for
reduced primary reforming - add reduced primary
reforming processes (LVIC-AAF, table 2.13)              Accepted    processed
table 4-4: instead of "SO2" write "SOx as SO2" (s.
reference and text above)                               Accepted    processed
tab. 4-6 (Heading): table 4-6 refers to the sulfate
process and not the chloride process - correct
heading into "sulfate process"                          Accepted    processed
The given BAT value for SO2 is not only for drying
but for the total emission level to air (s. LVIC-SAO,
Chapter 3.5.1, No. 14). Therefore add the data to
table 4-5                                               Accepted    processed
The given BAT value for SO2 is not only for drying
but for the total emission level to air (s. LVIC-SAO,
Chapter 3.5.2, No. 18). Therefore add the data to
table 4-6                                               Accepted    processed
BAT emission factor for S-PVC: 18 to 45 g/t and E-
PVC: 100 to 500 g/t                                     Noted
BAT emission factor for LDPE: 0,7 to 1,1 kg/t for
new plants and 1,1 to 2,1 kg/t for existing plants ;
BAT emission factor for HDPE: 0,3 to 0,5 kg/t for
new plants and 0,5 to 1,8 kg/t for existing plants        Rejected




BAT emission factor for GPPS: 85 g/t; HIPS: 85 g/t
and EPS: 0,45 to 0,7 kg/t                          Rejected


BAT emission factor for E-SBR: 0,17 to 0,37 kg/t          Accepted       processed
References: Please add: IPPC BREF Polymers -
IPPC Reference Document on Best Available
Techniques - Polymers, October 2006                       Accepted       processed
Except in some country where the industry is not
present, the chemical industry is often a large
emitter of pollutants                                     Noted
all tables: use units consistently (Mg, t, ton: e.g. in
table 3-1 you use kg/t, in table 3-2 you use g/Mg, in     Consult with
table 3-5 you use kg/ton                                  Expert Panel
Chapter describes all processes in ferrous metals
industry thus very complicated and difficult for
usage.                                                    Noted
Figure 2-1: Notatin for blast furnace gas missing.
Instead of coal injection I recommend coke or
natural gas injection.                                    Accepted       Done
Figure 2-2: The "metallurgical coke"in the top left
arrow is incorrect. Correctly: "Coking coal."             Accepted       Done
                                                                         More info provided in
Figure 2-3: Explanation for the blue arrow missing        Accepted       caption
                                                                         More info provided in
Figure 2-4: Explanation missing for the blue arrow        Accepted       caption
"...auxiliary reducing agent" should be amended
with "and as a fuel…"                                     Accepted       Corrected
"It leaves…" should be replaced with: "It and other
fuels leaves…"                                            Accepted       Corrected
Letter missing at the beginning of the line.
Correctly: Top of the …                                   Editorial      Corrected
Typo in the middle of the line. Correctly: agents.        Editorial      Corrected

Contradictions: Here 1.9% is mentioned, but on
page 7/18 it says: "… be reduced less than 1%"            Accepted       Checked and corrected
In section 2.2.4. the order: BOF, OHF, EAF, while
in the others it is: OHF, BHF, EAF. The letter is
preferred.                                             Editorial   Corrected
The agent for reheating is not mentioned in the
description, e.g. coke oven gas.                       Accepted    Corrected
The heavy metal content of furnace gas is not
mentioned. Table 3-14 (3/13) does include it.          Accepted    Corrected
"… sulfurdioxide…" should be written as sulfur
dioxid.                                                Editorial   Corrected
No legend provided for formuila. See row 1.            Accepted    Legend added

As there are iron & steel installations that have
only some plant (for example no coke production or
no sinter and so on) it's not possible to have a set
of overall emission factors; please use also for Tier
1 the subdivision used for Tier 2.                    Rejected     Corrected
Table 3-1: emission factor for chromium is
overestimated.                                        Noted

tab 3-1 NFR Source cat. Should be 2.C.1 not 2.A.1 Editorial        Corrected
                                                                   Pellets added as separate
                                                                   Tier 2 using EFs from
Subdivide Sinter from pellets as in IPPC BREF          Accepted    BREF
Convert the data in g/kg sinter using appropriate
change factor to compare with "state of the art"
EFs                                                    Rejected
Subchapter 3.3.2.1: for sinter production it appears
that effect of different systems of control onto
heavy metals is different depending on metal and                   Espreme factors checked.
for some of them more advanced system leads to                     Some inconsistencies
increase of emissions.                                 Accepted    remain however.
Why are the EFs of TSP, PM10 and PM2.5 not
estimated in the tables 3.3, 3.4, 3.5 and 3.6 ?        Accepted    EFs added

In table 3.2 the EF of Pb is 0,5 g/Mg sinter product,              Espreme factors checked.
while the EFs in the tables 3.3,3.4 and 3.5 are                    Some inconsistencies
higher. Is that correct ?                             Accepted     remain however.
                                                                   Pellets added as separate
                                                                   Tier 2 using EFs from
Subdivide Sinter from pellets as in IPPC BREF          Accepted    BREF
Convert the data in g/kg sinter using appropriate
change factor to compare with "state of the art"
EFs                                                    Rejected
                                                                   Pellets added as separate
                                                                   Tier 2 using EFs from
Subdivide Sinter from pellets as in IPPC BREF          Accepted    BREF
Convert the data in g/kg sinter using appropriate
change factor to compare with "state of the art"
EFs                                                    Rejected
Tables 3-3-3-6: because Table 3-2 is also named
Tier 2 these tables might be considered as Tier 3.
But they includes only heavy metals and POPs –
no PM; error in units (should be „sinter‟ instead of
„pig iron‟; should be „μg TEQ/Mg‟ instead of „μg
/Mg„); SNAP code is shown as 030301 while in
Table 3-1 as 040209, except 030301. Tables are
not harmonized with Tables 3-1 and 3-2: thus in the
Table 3-3 (Controlled by wFGD) – emission factors
for Cr, Ni, Pb and PCDD/F more high than in the
Table 3-2 while for PCB – lower 2000 times;
dioxins are the same in all tables.                  Accepted    Corrections in units made
Convert the data in g/kg sinter using appropriate
change factor to compare with "state of the art"
EFs                                                  Rejected
Convert the data in g/kg sinter using appropriate
change factor to compare with "state of the art"
EFs                                                  Rejected
                                                                 Pellets added as separate
                                                                 Tier 2 using EFs from
Subdivide Sinter from pellets as in IPPC BREF         Accepted   BREF
                                                                 Pellets added as separate
                                                                 Tier 2 using EFs from
Subdivide Sinter from pellets as in IPPC BREF         Accepted   BREF
Erase Table 3-8 and Table 3-9: are in contrast with
Table 3-7                                             Accepted   Tables removed
PM emission factors are very high if compared with
BREF data (a factor 10)! BREF EF must be taken                   Factors replaced with
into account.                                         Accepted   BREF values.
Heavy metals emission factors in the Table 3-7 are
generally underestimated especially for Cd, Pb, Zn,
but for Cr they are overestimated (taking into
account properties of metals).                        Noted
Table 3-7: there are errors in unit for PM10 and
PM2.5.                                                Accepted   Corrected
Unit PM10 and PM2.5 not correct                       Accepted   Corrected
Table 3-7 provides EF for pig iron production, for
the whole process starting from the charging of the              Tables 3-8 and 3-9
blast furnace to the tapping of pig iron. Table 3-8              removed because they
and Table 3-9 provide EF for the charging and                    generate confusion and
tapping individually. But emission factors in these              are not complete and
tables are not harmonized.                            Accepted   rather old anyway
Error in units in Tables 3-10-3-13 for PCDD/F –
should be μg TEQ/Mg; tables do not contain PM
emission factors; emission factors were taken from
ESPREME without analysis of applicability; they
look very low and probably contain systematic error
in units.                                                        PM EFs added. ESPREME
                                                      Noted      data checked for errors.
Table 3-14: table should be revised: it is shown that
the table is for Uncontrolled conditions but PM
emission factors are too low and lower than HM
emission factors; HM emission factors are partially
from Guidebook 2006, and partially – from
CEPMEIP so overall table is heterogeneous and
not reliable; error in units – should be „steel‟.     Accepted    Table corrected
Proposals:Tier 2 emission factors table is
suggested applicable for EECCA countries for
typical levels of dust abatement (95-96%).            Accepted    Tables included

Basic Oxygen Furnace: NOx and CO occurs from
oxidation process (see BREF for description of
process and EFs): THESE EMISSION MUST BE
INCLUDED AS THEY ARE NOT "COMBUSTION"                             NOx and CO EFs added to
EMISSIONS (NO FUEL ONLY OXYGEN)                        Accepted   table
Table 3-15: HM emission factors look
underestimated.                                        Noted
It is shown that “Most emission factors are taken
from the BREF document for Best Available
Technologies in the Iron and Steel Industry
(European Commission, 2001) but this reduce
applicability of emission factors.                     Noted
Electric Furnace Steel Plant: NOx and CO occurs
only in small portion due to adding of coal in scrab
as input to electric furnace (see BREF for
description of process and EFs): I THINK ALSO
THESE EMISSION MUST BE INCLUDED, THEY
ARE ONLY IN LIMITED QUANTITY
"COMBUSTION" EMISSIONS                                 Rejected
Table 3-16: error in units for benzo(a)pyrene. TSP
emission factor is underestimated.                     Accepted   Unit corrected.

                                                                  Espreme factors checked.
Table 3-18: emission factor for lead is higher than               Some inconsistencies
in the Table 3-15 (typical conditions).                Accepted   remain however.
Proposals: tier 2 emission factors table are
suggested applicable for EECCA countries for
typical levels of dust abatement (97.5%).
                                                       Accepted   Tables included

Tables 3-1– 3-21: error in units – should be „steel‟. Accepted    Corrected
Tables 3-19-3-21: error in unit – should be „steel‟;
units for PCDD/F should be checked. Heavy
metals emission factors among tables were not                     PCDD/F emission factor
harmonized: thus EF for Electric Arc Furnaces with                corrected. Espreme factors
bag filter (Table 3-20) are higher than with ESP                  checked, but some
(Table 3-19).                                         Accepted    inconsistencies remain.
Proposals: tier 2 emission factors table is
suggested applicable for EECCA countries for
typical levels of dust abatement (bag filter, about
99%)
                                                         Accepted   Tables included
I propose to erase all this old materials: it's not                 All this old information
TIER3                                                    Accepted   removed
3.4.2.5 Rolling mills. This activity must be in Tier 2
with BREF EFs                                            Accepted   Inserted as separate Tier 2
It‟s not clear why some pollutants are in "1.B.2.
Industrial Processes" section and not in "1.B.1.
Energy" section while are combustion related. For
example in sinter plant the EF for sinter plant in
Table 3.2 is fuel related as explained in quoted
reference ("The combustion process is not
homogenous and is incomplete, resulting in
significant quantities of polycyclic aromatic
hydrocarbons (PAHs) being produced.").                   Noted
In the Tables erase the row relative to NOx, CO,
NMVOC and SOx and put these pollutants in the
box "Not applicable" in conformity with other                       Harmonized with Reporting
chapters                                                 Accepted   Template

Chapter consists mainly of headings. It includes
one table with one emission factor: this is not
enough for inventory of emissions from this sector. Noted




Ferroalloys production: use PM EFs from BREF             Accepted

The notation keys given in Table 3-1 for Total PAH
(NE) do not correspond to the notation keys given                   Harmonized with Reporting
for the PAHs included in PAH-4 (NA).               Accepted         Template
                                                                    Harmonized with Reporting
In the list of main pollutants PAH are not included. Accepted       Template
Table 3-1: no EF for dioxins/furans; no EF for PAH
except benso(a)pyrene.
                                                     Noted

The notation keys given in Table 3-1 for Total PAH
(NE) do not correspond to the notation keys given                   Harmonized with Reporting
for the PAHs included in PAH-4 (NA).               Accepted         Template
SOx, NOx and VOC comes from process and are
not evaluated elsewhere. Insert EF here from IPPC
BREF. See BREF for details of the process
emissions description.                             Accepted         Added to tables
Tables 3-1, 3-2, 3-3: benzo(a)pyrene EF are the
same for Tier 1 and Tier 2 for both technologies of
primary aluminium production: this is not so.
                                                   Noted
Tables 3-1, 3-2 and 3-3 include CO emission factor
while other gases are estimated in the chapter
1.A.2                                              Noted
                                                                EF removed, other EFs
The EF given for benzo(a)pyrene is not valid for the            (Netherlands contribution
PreBake-process.                                     Accepted   for POPs) used instead
In the BREF-document SO2 and NOx
emissionfactors (from sulfur and nitrogen in the
anodes) are given. These emission factors might
be useful for estimating emissions using higher
Tier than Tier 1.                                    Accepted   Added

The notation keys given in Table 3-2 for Total PAH
(NE) do not correspond to the notation keys given               Harmonized with Reporting
for the PAHs included in PAH-4 (NA).               Accepted     Template
Tables 3-2, 3-3 and 3-4: PM emission factors
shown the same for primary (both technologies)
and secondary aluminium production. This is not
so.                                                Noted        Corrected

The notation keys given in Table 3-3 for Total PAH
(NE) do not correspond to the notation keys given               Harmonized with Reporting
for the PAHs included in PAH-4 (NA).               Accepted     Template
In the BREF-document SO2 and NOx
emissionfactors (from sulfur and nitrogen in the
anodes) are given. These emission factors might
be useful for estimating emissions using higher
Tier than Tier 1.                                  Accepted     Added
Table 3-4: no EF for dioxins/furans (important for
secondary aluminium); no EF for PAH.
                                                   Noted
tab 3-4 NFR Source cat. Should be 2.C.3 not 2.C.1
also in tab 3-3                                    Accepted     Corrected

The legend for Table 4-3 refers to emission factors
for primary aluminium production. In row four in the
table it says "Secondary aluminium....."             Accepted   Corrected
Proposals: tier 2 emission factor tables are
suggested for primary (limited control and
advanced control) and secondary copper
production in EECCA based upon average values
of unabated dust emissions, emission control
levels and content of metals in dust.                Accepted   Tables included
It is shown that emissions from secondary copper
production are considered in the Chapter 1.A.2.b.
But Table 3-3 proposes EF for secondary copper
production, Tier 1 (Table 3-1) emission factors are             Sentence removed, not
for all copper.                                      Accepted   applicable here!
"The emissions from the production of secondary
copper are due to energy use only and therefore                       Sentence removed, not
treated in the combustion chapter 1.A.2.b".                Accepted   applicable here!

In the sector 2.3 Emissions SO2 emission are
mainly considered in spite of the fact that gaseous
emissions are not estimated in this chapter;
scarce information about PM emission.                      Noted
Subchapter 3.2.2: methods of estimation of Tier 1
emission factors are not described and in general
common table for primary and secondary copper
looks artificial.                                          Noted
Table 3-1: error in unit (aluminium is shown);
emission factors for heavy metals seem
underestimated especially for Pb; no emission
factor for Zn; no emission factor for copper while
copper production is the main source of copper
emission; emission factor for PCDD/F looks                            Unit corrected. Cu EF
overestimated.                                             Accepted   added.
The emission factors are expressed in terms of
mass of pollutant per mass of aluminium produced.
Please take into account that the activity
considered is copper production.                           Accepted   Corrected
SOx, NOx and VOC comes from process and are
not evaluated elsewhere. Insert EF here from IPPC
BREF. See BREF for details of the process
emissions description.                                     Rejected
Chapter not contains technologically specific
emission factors as necessary: only tables for
primary and secondary copper with the same
errors (see comment to the table 3-1).
                                                           Noted
Table 3-2: error in title: not Tier 1, but it is Tier 2;
Error in unit (aluminium is shown); no EF for Zn
and Cu.
                                                           Accepted   Corrected
The title of the table 3-2 refers to Tier 1 when it
should be Tier 2.                                          Accepted   Corrected
Table 3-3: error in unit (not „aluminium‟); no EF for                 Unit corrected. EF for Cu
Zn and Cu.                                                            added, for Zn no
                                                           Accepted   information available.
Warning: the emission factor value considered for
Pb matches with one of the 95% confidence
interval value, is this correct?                           Accepted   Corrected
The 95% confidence interval for Cr in Table 3-1 is
0-0, but the emission factor proposed is 16 g/Mg
aluminium.                                                 Accepted   Corrected
The title of the table 3.3 refers to Tier 1 when it
should be Tier 2.                                          Accepted   Corrected
Same comment for tables 3-2 and 3-3.                       Noted
In Table 3-1, emission factors for As, Cd, Cr, Hg,
Ni and Pb do not coincide with the values that
appears in the indicated reference (ESPREME).          Accepted   Harmonized
The PST, PM10 and PM2.5 emissions factors that
appears in Table 3-2 for Tier 2 are the same that
appears in Table 3-1 for Tier 1.                       Noted
The 95% confidence interval for Cr in Table 3-2 is
0-0, but the emission factor proposed is 21 g/Mg
aluminium.                                             Accepted   Corrected
In Table 3-3, emission factors for As, Cd, Ni and
Pb do not match with the values that appears in the
indicated reference (ESPREME).                         Accepted   Harmonized
In Table 3-2, emission factors for As, Cd, Cr, Ni
and Pb do not match with the values that appears
in the indicated reference (ESPREME).                  Accepted   Harmonized
Dioxins and furans are indicated as not estimated
but there is an emission factor proposed in Table 3-
1.                                                     Accepted   Corrected

In Table 3-1, for SOx, NOx, NMVOC and CO,
emissions are indicated as estimated elsewhere.
Where are these emissions estimated? In the case
of SOx, are not process emissions (other than
those related to the fuel consumption) that should
be computed in this Chapter 2C5a?                  Noted

This statement does not match with the presence
of the table 3-3, which presents emissions factors
for secondary copper production.                       Accepted   Corrected
Same comment for subsequent tables in this
Chapter.                                               Noted
In addition, as a big surprise, there is no Cu
emission factor for the very copper production,
although there are emission factors for other heavy
metals.                                                Accepted   Cu EF added
PCB is indicated as not applicable but there is an
emission factor proposed in the Table 3-1.             Accepted   Corrected
General comment: chapter should be substantially
reworked. Necessity and methods of aggregation
of primary and secondary lead production should
be discussed.                                          Noted
Chapter should be edited: 'Lime production' (P.5),
'Cement production' (P.5), "Cement industry" (P.4),
'Production of cement' (P.6), 'Zinc production'
(P.2), 'Copper plants" (P.18) et. al. are not
considered here.                                       Accepted   Corrected
Table 3-1: HM emission factors are
underestimated; no EF for zinc; principals of Tier 1
EF calculation should be discussed.                    Noted
SOx and NOx comes from process and are not
evaluated elsewhere. Insert EF here from IPPC
BREF. See BREF for details of the process
emissions description.                                Rejected
Table 3-2: there are no differences with Tier 1 table
for PM, but large differences for HM.                 Noted
Tier 2 Tables 3-2 – 3-10: emission factors in the
tables were not harmonized, i.e relations between
dust and HM were not accounted (HM emission
factors can‟t be higher than PM; abatement affects
PM similar way as most HM. Applicability of                      Text in section added to
proposed emission factors is limited because no                  make it more clear that PM
geographical indications are given for technologies              factors are generic, not
distribution.                                         Rejected   specific for the technology
Proposals: two Tier 2 emission factors for primary
lead tables were prepared applicable for EECCA:
first – for low level of abatement (about 98%) and
second – for high level (>99%).One emission
factors table was prepared for secondary lead
production (abatement <99%).
                                                      Accepted   Tables included
Table 3-3: not understandable: if it is a BAT table
why EF for HM are higher than in the Table 3-2
(Typical abatement); lead emission factor is higher              All ESPREME factors
than for TSP.                                         Accepted   checked again for errors

Table 3-5: EF for TSP is the same as in the Table                Text in section added to
3-3 (BAT), but for HM emission factors are                       make it more clear that PM
significantly lower than in Table 3-3. Lead emission             factors are generic, not
factor is underestimated.                            Noted       specific for the technology

                                                                 Text in section added to
                                                                 make it more clear that PM
                                                                 factors are generic, not
Table 3-6: the same comment as for Table 3-5.        Noted       specific for the technology
Table 3-7 (secondary lead): PM EF is the same as
in the Table 3-2 (primary lead) and in the Table 3-1             Text in section added to
(Tier 1). PM emission factors are underestimated.                make it more clear that PM
PCB and PCDD/F emission factors – errors in                      factors are generic, not
units.                                               Noted       specific for the technology

                                                                 Text in section added to
                                                                 make it more clear that PM
Table 3-8: HM emission factors are higher for BAT                factors are generic, not
than for typical abatement (Table 3-7).           Noted          specific for the technology

Tables 3-8 - 3-10: PM emission factors are the                   Text in section added to
same for different technologies but HM emission                  make it more clear that PM
factors are different. Dependence of HM emission                 factors are generic, not
factors from abatement is not understandable.       Noted        specific for the technology
                                                                    Text in section added to
                                                                    make it more clear that PM
Table 3-9: HM emission factors are higher for ESP                   factors are generic, not
than for typical abatement (Table 3-7).           Noted             specific for the technology

Proposals: chapter should be significantly
supplemented and reworked. Tier 2 region-specific
and technology-specific tables are necessary.      Noted
It is shown that only primary zinc emissions are
considered but emission factors also for secondary
are included in the tables 3-5-3-8.                Accepted

It is written, that „Emissions from nickel production
are not significant, since the contribution to the total
national emissions is thought to be insignificant, i.e.
less than 1 % of the national emissions of any
pollutant‟. It is not right: in Russian Federation
according to rough estimates about 1 mln. tons of
SO2 are emitted annually from nickel production –
about 20% of national total.                             Accepted   Sentence removed
SOx, CO, VOC and NOx comes from process and
are not evaluated elsewhere. Insert SOx and CO
EF here from IPPC BREF. See BREF for details of                     SOx included in this
the process emissions description.                       Rejected   chapter
Table 3-1 (Tier 1) should be updated: it includes
only 2 emission factors: for TSP and Ni. These
factors if considered EMEP-wide are
underestimated. During nickel production other
heavy metals are emitted.                                Noted

It is written, that 'Emissions of SOx, NOx, NMVOC
and CO are due to the combustion activities and
subsequently treated in source category 1.A.2.b' .
This is not so: in nickel production from sulphidic
ore SO2 emission is not due to combustion                           SOx included in this
activities so should be treated in 2.C.5.c chapter. Accepted        chapter
References include only one source (IPPC BREF) -
it is not enough.                                   Noted

Proposals: chapter need to be substantionally
reworked. Two Tier 2 emission factors Tables for
primary zinc production by electrochemical
technology were prepared applicable for EECCA:
first – for low level of abatement (about 90%) and
second – for high level (>99%). Electrochemical
technology is dominant in the EECCA countries
zinc industry (more than 90% of total primary zinc). Accepted       EECCA tables included.
It is shown, that the most important pollutants
emitted from these processes are heavy metals
(particularly zinc) – but there are no emission                     Zn EFs added to each
factors for zinc in the Tables 3-1 – 3-8.            Accepted       table
"This chapter only discusses primary zinc
production. Secondary zinc production causes only
emissions from combustion activities and is                       Sentence removed, not
therefore treated in chapter 1.A.2.b".            Accepted        applicable here!

"The most important pollutants emitted from these                 Zn EFs added to each
processes are heavy metals (particularly zinc)".       Accepted   table
Subchapter 2.4 Controls: no description of
abatement systems.                                     Noted
Table 3-1 (Tier 1): heavy metals emission factors
are significantly underestimated; no EF for Cu; no
EF for Zn which is the main pollutant from zinc
production; EF for PCB and PCDD/F are dubious.
Error in unit for PCDD/F.                              Noted      Unit errors corrected
PCB is indicated as not applicable but there is an
emission factor proposed in the Table 3-1.             Accepted   Corrected
It is written that “This section provides technology
specific emission factors for the two techniques …
the electrochemical process and the thermal
smelting process” but below there are no                          Sentence removed, no
descriptions of these technologies and no emission                specific EFs for these
factors.                                               Accepted   processes available!

In Table 3-2, why are used the emission factors for               Espreme factors checked.
Tier 1 from ESPREME like emission factors for                     Some inconsistencies
Tier 2?                                             Noted         remain however.

Tables 3-2, 3-5: PM emission factors for primary
(Table 3-2) and secondary (Table 3-5) zinc are the
same while technologies are different.                 Noted
Tables 3-2-3-8 Tier 2: tables were not harmonized
with Tier 1 table and with each other; PM emission
levels do not correspond HM emissions and
sometimes lower than HM emission factors; no                      Zn EFs added to each
zinc emission factors.                                 Accepted   table
Table 3-3 (BAT technologies table): emission
factors for Cd and Pb are higher than for typical                 Espreme factors checked.
abatement; emission factor for Cr appeared not                    Some inconsistencies
included in Table 3-2.                                 Accepted   remain however.
In Table 3-3, 95% confidence interval values for
Cd, Cr, Hg and Pb do not match with the values                    Espreme factors checked.
that appears in the indicated reference                           Some inconsistencies
(ESPREME).                                             Accepted   remain however.

Table 3-4: PM emission factors are the same as in
the Table 3-3 but HM emission factors are lower 4
orders of magnitude.                              Noted
In Table 3-4, 95% confidence interval values for
Cd, Cr, Hg and Pb do not match with the values                    Espreme factors checked.
that appears in the indicated reference                           Some inconsistencies
(ESPREME).                                        Accepted        remain however.
Table 3-5: PM emission factors are the same as for
primary zinc which is not true; HM emission factors             Zn EFs added to each
are underestimated; no Zn emission factor.          Accepted    table
In Table 3-5, 95% confidence interval values for
As, Cd, Hg and Pb do not match with the values                  Espreme factors checked.
that appears in the indicated reference                         Some inconsistencies
(ESPREME).                                          Accepted    remain however.
Table 3-6: BAT technology, but HM emission
factors compared with typical abatement (Table 3-               Espreme factors checked.
5) are 2-3 order of magnitude higher, PM – the                  Some inconsistencies
same, PCB and PCDD/F – lower.                       Accepted    remain however.

In Table 3-6, emission factors for As, Cd, Hg and               Espreme factors checked.
Pb do not match with the values that appears in the             Some inconsistencies
indicated reference (ESPREME).                      Accepted    remain however.
In Table 3-7, 95% confidence interval values for
As, Cd, Cr, Hg and Pb do not match with the                     Espreme factors checked.
values that appears in the indicated reference                  Some inconsistencies
(ESPREME).                                          Accepted    remain however.
In Table 3-8, 95% confidence interval values for
As, Cd, Cr, Hg and Pb do not match with the                     Espreme factors checked.
values that appears in the indicated reference                  Some inconsistencies
(ESPREME).                                          Accepted    remain however.

Table 3-9: abatement efficiencies for modern plant
is shown lower than for conventional installations.
Error: not „Lead production‟ but „Zinc production‟. Accepted    Corrected
The information that is showed in Table 3-9 is for
lead production, not for zinc production.           Accepted    Corrected

It is written that Tier 2 tables were compiled using
country data from Table 3-10. But data in Tier 2
tables do not correspond to the data in the Table 3-
10. It is not clear enough how Tier 2 tables were               New EFs inserted from
obtained and for what countries data was used.                  ESPREME, they are now
Region-specific emission factors are necessary.      Accepted   used in all Tier 2.

In Table 3-1, for SOx, NOx, NMVOC and CO,
emissions are indicated as estimated elsewhere.
Where are these emissions estimated? Same
comment for subsequent tables in this Chapter.       Accepted
Dioxins and furans are indicated as not estimated
but there is an emission factor proposed in Table 3-
1.                                                   Accepted   Corrected

In Table 3-1, emission factors for As, Hg and Pb do             Espreme factors checked.
not match with the values that appears in the                   Some inconsistencies
indicated reference (ESPREME).                      Accepted    remain however.
This statement does not match with the presence
of the Tables 3-5, 3-6, 3-7 and 3-8, which presents
emissions factors for secondary zinc production.    Noted

This statement does not match with the rest of the
capitule because there is no Zn emission factor.    Noted
Chapter consists of 8 pages and one table Tier 1
emission factors for source category 2.C.5.c Nickel
production (probably error) with one emission
factor (for TSP). This is not enough for emission
estimation from Other metals production. Chapter
should be supplemented.                             Noted           Error corrected


Table 3-1: the title and content of the table are not
harmonized.                                             Accepted    Corrected



References include only one source.                     Noted



transport of "cement" is not correct                    Accepted    Corrected
Instead of "…hardwood…" I recommend wood or
cellulose-bearing materials                             Accepted    Done
Instead of "…wood…" I would recommend "wood
or other cellulose-bearing materials…"                  Accepted    Done
It is not described where ensillary fuel used in
recovery furnace (e.g. oil) should be taken into
consideration. See also page 7, lines 5-6.              Noted
THE should be written as the.                           Accepted    Corrected
using annual national total cement production?          Editorial   Corrected
AR - national total cement production???                Editorial   Corrected
Kraft process: the values for NMVOC and SOX are
wrongly copied from BREF                                Accepted    Corrected
Table 3-2, for TSP, PM10, PM2,5 unit is kg/Mg
coal produced?                                          Accepted    Corrected
Acid sulphite process : the values for PM are
wrongly copied from BREF                                Accepted    Corrected
Table 3-1: I would recommend "air dried pulp"
instead of "dried pulp".                                Accepted    Done
Neutral sulphite semi-chemical process: wrong
reference (see the text)                                Accepted    Corrected
Several polutants are given in the EF-tables to be
NA. From Swedish experiences there are
emissions of metals, NH3 and also some PAH-4                        Reporting template now
and dioxins from the process (Kraft and acid                        used to automatically fill
sulphite) why the notation should be NE.                Noted       NA and NE boxes.
Tables 3-7, 3-8, 3-9: kg/MG alcohol: what
concentration of alcohol?                               Noted
                                                                 Some descriptive text
It is unclear when Table 7-9 and when Table 28-32                added in beginning of Tier
should be used.                                       Accepted   2 section
Cakes, biscuits and breakfast cereals: wrong copy
EF from old GB: verify                                Accepted   Corrected
In table 3-19 instead of SNAP 040605 must be
SNAP 040627 (meat..)                                  Accepted   Corrected
In table 3-20 instead of SNAP 040605 must be
SNAP 040625 (sugar)                                   Accepted   Corrected
replace kg/Mg meat etc with kg/Mg product             Accepted   Done
Tables 3-28 to 3-22: kg/hl alcohol: what
concentration of alcohol?                             Noted

Chapter should be significantly supplemented
taking into consideration importance of POPs
production for total POPs emission. Now it consists
of 3 pages and one table with similar emission
factors for all POPs which are not grounded.
Chapter should also include production of POPs-
containing products like PCB transformers,
capacitors, dyers etc. which is important for
retrospective emission assessment.                    Noted
What confidence can we give to this chapter? Very
poor at first view. This chapter has to be worked
more deeply. What is the definition of products
used in the table 3.1.                                Noted
There are no any references.                          Noted
Due to increase pressure on Member states for
providing emission inventories for POP, the quality
of this chapter is too low.                           Noted
Who is the expert for expert judgement                Noted

Chapter is based upon chapter “Electrical
equipment with PCB” from the Guidebook 2006
which was reduced. Chapter need to be
significantly supplemented and reworked (maybe
with division into a few chapters) to show overall
picture of consumption of POPs and heavy metals. Noted
Table 3-1: table should be revised - it is not
reliable, for instance it shows emission factors 1
kg/ton from consumption of heavy metals like Cr
or Ni which is not understandable.                   Noted
This section is not very clear. What do you to say ?
'"Pharmaceutical products manufacturing (SNAP
060306)" does not correspond to "application of                   Pharmaceutical products
coatings during the manufacture of a number of                    manufacturing removed
other industrial products"                           Accepted     from this list
                                                     Consult with
It's not clear where leather finishing is included   Expert Panel
substitute "for architectural or furniture
applications"                                        Accepted
In the discussion of emissions there is no indication
what happens with VOC's emitted from cleaning
equipemtn, brushes, guns, rollers, etc. Dilution is
also mentioned marginally but it might be quite
important. It certainly should be clear if this is
included or not. In case of emission factors later
shown from the model the model developers
should be asked if the factors include these
components or refer only to solvent in paint.         Noted

I would suggest to apply an uniform emission factor
of 95 % for open applications instead of 100%          Accepted
These products are covered by the Product
Directive 2004/42/EC on the limitation of emissions
of volatile organic compounds due to the use of
organic solvents in certain paints and varnishes…
When EGTEI document was done, the directive
was not yet implemented.                               Accepted   Updated
The results of this are the Solvent Emissions
Directive (1999/13/EC) and the Product Directive                  Updated. Decopaint
(2004/42/EC). This latter regulation will be….         Accepted   directive added to text.
EU directive 2004/42/EC ((Decopaint directive")        Accepted   Directive added
third column 10th row: 150                             Accepted
third column second row: 75                            Accepted
third column third row: 400                            Accepted
third column fifth row: 400                            Accepted
third column sixth row: 75                             Accepted
third column seventh row: 450                          Accepted
third column 8th row: 150                              Accepted
third column 9th row: 400                              Accepted
fourth column 10th row: 130                            Accepted
fourth column 9th row: 300                             Accepted
Some of the values table 2-2 are not correct. The
right ones are in Annex II B of the Decopaint
directive (2004/42/EC)                                 Accepted   Values corrected
VOC content limit values in table 2.2 have to be
modified according to the Product Directive
mentioned above                                        Accepted   Values corrected
Mention the EU Solvents Emissions Directive
1999/13/EC for this sector                             Accepted   Directive mentioned
Solvent Directive 1999/13/EC mentions that:
"coating activities which cannot be applied under
contained conditions (as shipbuilding, aircraft
painting) may be exempted from emission limit
values : the reduction scheme is then to be used,
unless it is demonstrated that this option is not
technically and economically feasible. In this case,
the operator must demonstrate to the satisfaction
of the competent authority that the BAT is being
used.                                                  Accepted   Text added
Mention the EU Solvents Emissions Directive
1999/13/EC for this sector                               Accepted   Directive mentioned
Car repairing is regulated under the Product
Directive 2004/42/EC and was removed from the
Solvent emissions Directive 1999/13/EC                   Accepted   Text updated accordingly
Please quote the regulations of the Decopaint
directive for Car repairing (2004/42/EC, Annex II
B).                                                      Accepted   Directive mentioned

VOC contents in paints used for car repairing are
regulated by the Product Directive 2004/42/EC :
only 1 phase which came into force in 2007 (see
table of VOC content in the Directive)                   Accepted   Text updated accordingly
Mention the EU Solvents Emissions Directive
1999/13/EC for this sector                               Accepted   Directive mentioned
In the equation the activity rate refers to the
application of paint while later in line 13 on page 15
it says that national production data are used. I
think this is wrong, in time of multinational
consortia producing vertain paints in few locations
and distributing them to many countries we cannot
rely on production figures, not too mention stocks
changins from year to year and exports outside
Europe or imports. I think one needs to refer her to
the paint use and industrial associations need to be
consulted for this data. They do exist and are
available for most countries, for the others one
wouldhave to make assessment based on per
capita use of paint or something like that which I
think would still give better result than production                Text adapted, discussion
figures.                                                 Accepted   should be about paint used
Should emission factor be distinguished according
to the year : 1990, 2000 and 2010 (after
implementation of the Directive) : if yes, data are
available from CEPE. CITEPA has this type of
information.                                             Noted
I would go for even more caution when suggesting
as a default value a 2000 average Europen
number. I think it could be better to refer to
developed and developing coutnries and try to
develop two factors at least. We need to
remember that there are very often historical or
cultural differences, say how and from what
materials the houses are built, e.g. if one compares
Scandinavia and Mediterranean countries, the
construction materials are so different that the
standard typical paint applications must be
different. I feel these things should be mentioned.
This type of information will be useful also for the
Tier 1 approach. All that in spite of that fact that I
do agree that the 95% conf.int does cover that
largely.                                               Noted
                                                                       Description on how Tier 1
In the tables 3-1 to 3-3 the development of the Tier                   has been derived has been
1 emission factors must be further explained.        Accepted          updated
…. Member States to bring decorative or vehicle
refinishing paint products …..                       Accepted          Corrected
Decorative paints (060103 + 060104)                  Rejected

Specific EF for 1990, 2000 and 2010 are available
from CEPE and have been used in RAINS                       Noted
Again the issue of production versus use. Please
make sure this is consitent, while for cars, coated
area, etc, it is ok for decorative paint is not the right
appraoch.                                                   Accepted   Text updated accordingly
The sector "industrial coating applications" is very
wide : SNAP codes should be precised                        Noted
Don‟t refer to abatement documents that preceed
the Product Directive 2004/42/EC from April 2004.
The actual abatement regulations in EU-27 should
be from that publication onwards. The EGTEI and
RAINS/GAINS nomenclature used here is not
applicable for DECO.                                        Noted

The sentence "products containing 50 wt-%
solvent" is not compatible with EF replace with
"products containing 25 wt-% solvent" or correct EF Rejected

The sentence "products containing 50 wt-%
solvent" is not compatible with EF replace with
"products containing 25 wt-% solvent" or correct EF Rejected
The EF in not applicable; where we can found the
data m2 coated. The EF in this form can be useful
to estimate the new paint technology penetration
but non the emissions. EF MUST be expressed as
g/t of paint or g/t product. Consideration about
transfer efficiency of paint on object can be useful
to estimate future paint consumption but not for
emission inventory. Eventually maintain g/m2 for                          Version calculated in terms
emissions but define default value for m2/t as                            of g/kg paint applied.
surface painted for tonnes of products. This default                      Conversion factor
values can be extracted from original EF source.     Accepted             mentioned in text.

The EF is wrong!! The value is referred to g/m2!
And for this is valid the previous comment: where
we can found the data m2 coated. The EF in this
form can be useful to estimate the new paint
technology penetration but non the emissions. EF
must be expressed as g/t of paint. Consideration
about transfer efficiency of paint on object can be
useful to estimate future paint consumption but not        Consult with Error corrected. EF should
for emission inventory.                                    Expert Panel be g/m2 indeed
There is an emission factor of 200 kg/Mg for
Leather Finishing from BREF that must be taken             Consult with
into account!                                              Expert Panel
I don't think these are always "abatement", new
technology/new products are often considered. It's
better produce EFs tables (non reductions) with
technology/products and put them in section 3.3.2
as in others chapters of GB. I think the approach
must be unique!                                            Rejected
The table is not applicable. At statistical level is not
known the m2 of wood painted. We need EFs for
tonne of paint.                                            Rejected
For wire, area is not the relevant activity which is
the mass of wire coated                                    Accepted       Corrected

The BAT reference is only applicable to the deco
products applied in a factory (installation). The
majority of the volume in DECO, however, is going
into profeesional use (painters) and do-it-yourself.
For that majority (~75%) there is no accepted BAT. Accepted               Added to the BAT section

Coating of agricultural and construction equipment:
this falls in the industrial coating application (not                     Moved to Industrial coating
the decorative coating application)                   Accepted            application
I think in this chapter should be described
methodologies to ensure time consistency and
recalcualtion and not methodologies to generate                           Text removed; does
temporally resolved emission data sets                Noted               indeed not belong here
What is the meaning of time series? I believed that
it is about emission s changing from year to year
and so here the issues of changing emissions
factors owing to technological change and
legislation might be touched upon. As is it is a very             Text removed; does
difernt story. Verify.                                Accepted    indeed not belong here
It probably does not belong here as I think wood
preservation is a separate chapter and is not part                Removed; belongs in wood
of coating. Suggest ot simply delete.                 Noted       preservation chapter
Coating of plastic parts is defined separately in the
BREF: it should be added somewhere and the
place is in the industrial coating.                   Rejected

For all source categories: National import, export
and production statictics for single chemicals can
be used as activity data. Used amounts can be
differentiated into activities and facilities.         Noted
Emission factors can be applied for use of single
chemicals in products and/or activities.               Noted
With respect to harmonization to Directive
1999/13/EC, which is e.g. employed in performing
emission projections: In many technologies a
solvent consumption is warranted at facility level.
cont. below                                            Noted
continued from above, This requires knowledge on
Tier 3 level, which may not be avaliable. The
guideline could suggest how to differentiate a total
use amount of solvent on a facility level.             Noted

FYI: Norway is adopting a different approach to
estimating emissions from the use of solvent
containing products than the ones described in the
Guidebook. Like in the Swedish inventory, volume
data from the national Product Register on the
solvents themselves is used. Emission factors are
specific for combinations of product types and
industrial sectors. The 2008 Guidebook does not
provide us with information that can be used in the
emission model directly. However, the information
provided may help to correctly allocate emission
figures (pertaining to the combinations of product
type and industrial sectors) into the different source
categories and help us to improve our emission
factors. More information on the new Norwegian
model on NMVOC emissions from the use of
solvent containing products can be provided on
demand.                                                Noted
NO EFs for paint application: boat building (SNAP
06 01 06) - Important in some countries, there is an
EF from BREF!                                          Accepted   EF added
More information is required in relation to the
emission factors from EGTEI. A specific reference
is required to the background documentation in the
GAINS model so that emission factor values can
be examined for applicability to national
circumstance. The emission factors are not clear in              Description on how Tier 1
terms of their derivation. The units differ between              has been derived has been
sources. A common emission factor unit would be                  updated, reference to
helpful.                                            Accepted     GAINS for documentation

A very important refernce is missing I think. It is
"DECOPAINT - Study on the Potential for Reducing
Emissions of Volatile Organic Compounds (VOC)
Due To The Use Of Decorative Paints and
Varnishes for Professional and Non-professional
Use", EC DG Environment Tender
E1/ETU/980084, June 2000. I believe it is available
from the Commission web site. This wouldbe very                  Mentioned in the text as an
valuable for the section on decorative paints, even              interesting background
if it was certainly used by EGTEI group.            Noted        document
Cleaning products to be considered are only
organic solvents. This has to be precised. Many
products used for degreasing do not produce
NMVOC                                               Accepted     Text updated accordingly

More information is required in relation to the
emission factors from EGTEI. A specific reference
is required to the background documentation in the
GAINS model so that emission factor values can
be examined for applicability to national                        Reference corrected; old
circumstance. The referecence to EGTEI for this                  methodology put back but
sector is to a document published in 2005 and not                only as a "reference"
2003 as indicated. In respect of dry cleaning i                  methdology, industry has
suggest reverting to the old simple methodology                  insisted on removing
approach rather than an emission factor based on                 information because it was
kg of garment cleaned.                             Accepted      outdated!

NO EFs for Electronic components manufacturing        Noted
The old GB emission factors for units in operation
can be useful as Tier 1 meth and must be
maintained in the new GB                              Rejected
I think in this chapter should be described
methodologies to ensure time consistency and
recalcualtion and not methodologies to generate                  Text removed; does
temporally resolved emission data sets                Accepted   indeed not belong here
In the "old" Guidebook is present an EF in
kg/inhabitant year that can be useful for countries
with no other information. Transfer the EF in new
GB please.                                            Accepted   Number placed in text
In this Chapter 60301 (Polyester processing)
should be also considered                             Noted
It is not correct to say that all these activities are
insignificant. According to characteristic of the
industry and member states, several of these
activities are significant.                               Accepted   Text updated accordingly

In the expanded polystyrene, pentane is the most
often blowing agent used. In extruded polystyrene
other types of chemicals are used. In polyurethane
CFC were used but presently other types of
blowing agents are used. In polyurethane, the
types of blowing agents used depend on the final
use of the foam. Butane, pentane can be used as
many substitutes of CFC such as HFC and HCFC.
Some polyurethane foams can be expanded
directly with CO2 resulting from a reaction between                  Information added to
polyols and water.                                  Accepted         chapter

The description is a little bit too old . A description
of the present situation would be necessary.              Noted

The title of the paragraph does not correspond to
the SNAP 060306 definition (manufacturing of
pharmaceutical product) We agree and support the
extension of the scope of SNAP 060306. The
speciality organic chemical industry aims at
producing different types of chemical products
including pharmaceutical products but not only.   Noted
the description comes from the EGTEI document
which is not quoted.                              Accepted           Quote fixed

Explanations coming from EGTEI to be cited                Accepted   Quote fixed
For expanded polystyrene, pentane is exclusively
used.                                                     Accepted   Text updated accordingly
F11, F12 are forbidden today and cannot be used
anymore. Give the names of the present blowing
agents.                                                   Accepted   Text updated accordingly

The reduction techniques available for polystyrene
and polyurethane are different. It would be useful to
distinguish the two applications. For polystyrene,
low pentane content expandable polystyrene can
be used (4.5 to 5 %) but just for some specific
application. Emissions can be captured and treated                   Information added to
by oxidation.                                         Accepted       chapter
Add on techniques can be used. Applications exists
in several countries. Oxidation techniques are the
most often used techniques but waste gases
containing pentane can be also destroyed in a                        Information added to
boiler.                                               Accepted       chapter
The EC Directive has been implemented but many
member states have their own regulation going
further the EC directive. Polyurethane foam
processing, Polystyrene foam processing, asphalt
blowing, the non pharmaceutical part of the
speciality chemical industry are not covered by this
directive.                                           Accepted         Text updated accordingly

                                                               Small list of products
Give the list of products to be considered.       Accepted     added, but is not complete
Here is a strong mistake. The suspension process
is a process to produce the PVC from VC
monomers. In this chapter only PVC processing
has to be considered. All the paragraph has to be
removed if no data are available for PVC          Consult with
processing.                                       Expert Panel

the title is not the correct one                       Editorial      Corrected
The confidence interval should correspond to
something like 55 to 65 g / kg.                        Rejected

This chapter is outdated                               Noted
In Table 3-6 is meant pharmaceutical products
manufacturing                                          Editorial      Corrected
An emission factors of 50 kg/ton of product (from
two factory in Italy) can also be proposed             Noted
the title of the table if not the correct one. For
rubber it is possible to distinguish tyre production
and other rubber processing. For tyre the EGTEI
default emission factor is 10g/ kg rubber
processed. This emission factor is larger for other                   Title updated; rubber
application. The 8 proposed if perhaps                                production now also
underestimated.                                        Accepted       includes tyre production
In the SNAP Code should be only considered
"Asphalt blowing " a special asphalt production
process and not the application of asphalt. The
emissionsfactors are very outdated and very
large!!! The asphalt application is considered under   Consult with
40610 and SNAP 40611                                   Expert Panel
The definition of solvent used is the same as the
definition used by the EC directive 99/13. It
corresponds to new solvents or bought solvents +
solvents recycled. It has to be reminded that in the
EC directive fugitive emissions are expressed in %                    Information added to
compared to solvent used. .                            Noted          chapter

The definition of asphalt should be provided. Does
it included only the hydrocarbons or hydrocarbons
+ all additives and ingredient used (stones…)?     Noted
Give the list of products to be considered. In fact
they are at east paints, varnishes, glues, inks. In
fact this emission factor comes from EGTEI which
provides the emission factors for solvent borne
products, water based products which can be used
by experts if they have the knowledge on the share
of each type of products.                           Accepted          Text updated accordingly
Under 60314 should not be considered Tyre
manufacturing. This is considered under rubber
processing. Under 60314 is considered the
manufacturing of solvent containing products        Accepted          Corrected
This description is the same for all the speciality
fine chemical industry. Lower rates of emissions
can be achieved in the newest plants. In existing
ones also. Check if we stay with a definition of
pharmaceutical products or use the speciality
chemical industry?                                  Noted

the title is the correct one                           Editorial      Corrected
NO EF (and NO TABLE!!) for 060313 Leather
Tanning                                                Noted
An emission factor for 060311 Adhesive Tape
Manufacturing is present in BREF                       Accepted       EF added
NO EF (and NO TABLE!!) for 060312 Textile
Finishing                                              Noted
US EPA insert a lot of other fiber manufacturing
activities that must be evaluated: ryanoin, acetate,
acrylic, nylon, etc.                                   Noted
NO EF (and NO TABLE!!) for 060301 Polyester
Processing there are data from EPA AP 42.MUST          Consult with
BE INSERTED!!                                          Expert Panel
Most of this information can be founded by direct
uses of plant data.                                    Noted

More information is required in relation to the
emission factors from EGTEI. A specific reference
is required to the background documentation in the
GAINS model so that emission factor values can                        Link to GAINS website
be examined for applicability to national                             provided where
circumstance. Emission factors for each sub sector                    background info can be
could be presented in one table.                       Accepted       found
But this process has to be considered in chapter
2B                                                     Noted
There is a good description of the suspension
process in EGTEI                                       Noted
In polyurethane foam manufacturing a large part of
VOC emissions is due to the use of solvents for
cleaning moulds and blowing instruments.               Noted
This section only concerns heatset web offset,
being only one of the three groups of printing
porcesses addressed in the previous section. This
should be clearly mentioned. The other two
processes should also be adressed.                 Accepted             Other processes added
newspapers are not printed in rotogravure. Mention
magazines, brochures, and catalogues               Accepted             Corrected

This section is dangerous and absolutely useless.
The two halves of the industry (i.e. a) everything to
do with publications and b) everything to do with
packaging) are completely independent of each
other; different techniques, different markets,
different import and export positions, different
solvents etc etc. It is wrong to put them in the same
boat. This section must be deleted. It is as of
vehicle refinishing (i.e. painting) and solvent
consumption in shipbuilding (i.e. also painting) are
taken together.                                       Rejected

I table 3.8 the line 'technoclogy/process'reads
'heatset offset'. This should be publication gravure.    Editorial
"audits" could be replaced by "solvent management
plan"                                                    Editorial
I don't think these are always "abatement", often
new technology/new products are considered. It's
better produce EFs tables (non reductions) with
technology/products and put them in section 3.3.2
as in others chapters of GB. I think the approach
must be unique!                                          Rejected
In general, 2 other processes could be added:
sheet fed and coldset offset. EF and abetment
efficiencies have been defined by P. Verspoor for
the revision of RAINS. CITEPA has also data on
these emissions.                                         Noted
Suggest using the previous simple methodlogy
approach and presenting emission factors in one
table.                                                   Rejected
Figure 3-1 seems to be copied into several
documents but it is not always appropriate. This is                     Decision tree and
such case where including TIER 3 on chart is not                        corresponding text
of relevance.                                            Accepted       updated
Figure 3.1, decision tree is not correct: the facility                  Decision tree and
level for domesticsector not available and no Tier 3                    corresponding text
for this NFR.                                            Accepted       updated
Tier 1 default emission factors is incoherent with
Tier 2 as EF (Tier 1) < SUM (EFs(Tier2)) and
different from old one. Change Tier1 or remove           Consult with
Tier 2                                                   Expert Panel
Althogh the two approaches presented in the
algorithm are principally applicable here, the
formulation (obioviously copied in several chapters)
is not appropriatre, specifically talking here about
industry is not what this sector is exactly about, it is
use of products and their characteristics
(formulation=solvent content) and then shares in                    Description updated
total use are of interest. Please adapt accordingly. Accepted       according to comments
cooling liquid (ethylene glycol) may also contribute
to emissions                                             Accepted   Added
This must be a missunderstanding. What are these
'add on ' measures that couldbe applied here, a
little incinerator in the bathroom to burn the VOCs                 Corrected; abatement
from the hairspray used? Apologies for trying to be                 indeed not applicable as
funny :-)                                                Accepted   such

An important and very useful reference is missing
and certainbly it could be used for improvement of
the chapter - BIPRO, 2002. "Screening study to
identify reductions in VOC emissions due to the
restrictions in the VOC content of products" -Final
report for the European Commission.                    Accepted     Added
should read "2.1.2.3 Organic solvent borne
preservatives"                                         Editorial
Why is "adhesive tape" the unique sector described
in Industrial application of adhesives. Many other
type of application are existing.                      Accepted     Section headings renamed
Could it be possible to define which sectors are                    Reference to GAINS
considered in IND_OS                                   Accepted     added for documentation
When it is said that 3 sectors have the same
activity units (Mg product used), it is not totally
exact as we have Mg of glue, Mg of seed and Mg
of others… how do you deal with these
differences? Give examples.                            Rejected
                                                                    Update: must be
Why is "use of shoes" a source of NMVOC? The                        manufacturing of shoes,
manufacture of shoes is a source of NMVOC, but                      not use of shoes. Moved to
the "use of shoes" is a source of PM!!!                Accepted     chapter 3.C as well
The title should be Wood preservation and not Fat,
edible and non edible oil extraction                   Editorial
In this Chapter is not considered (forgotten) glass
and mineral wool enduction                             Noted
add all subsections to the table of contents           Editorial    Done

sometimes (e.g. p 18, l 33) there is only one                       Not sure about this, I don't
subsection 3.3.1, but no 3.3.2; subsections need at                 see the need, but can
least two chapters                                  Editorial       Nicola discuss with Tinus
                                                                    Nicola, this was mentioned
Equations and legends: inconsistent notation, not                   earlier so probably done by
in line with IUPAC                                     Accepted     now
The chapter is difficult to read. It is not a really
whole ist a summary previous chapters.Title should
be expanded to livestock husbandry and manure.
Nobody would search for PM emissions in manure                    The structure has been
management. The structure is not suitable for                     revised and hopefully is
agriculture. PM is not really integrated and is added             now much more
only.                                                 Accepted    accessible
maybe it would be useful to say that N2O
emissions, even if part of the N mass-flow
emission cycle, are not considered here because
GHG                                                   Accepted    Done

it must be specified that the emissions from
grazing animals have to be calculated but not (??)
reported under chapter 4B. In the general scheme
of the chapters it appear they are under 4D            Accepted   Done
Overview too short, gives too little information       Accepted   Overview expanded
Expand overview to give more background
information                                            Accepted   Overview expanded
To avoid misunderstanding it should be pointed
out, that the emission from grassing animals has to
be reported in NFR category 4D2c                       Accepted   Done
Table 1-1 shows that NOx emission from the
agricultural sector contribute by 1.8% of total NOx.
This indicate the important of develop a Tier 1
methodology. Is is possible to recommend a Tier 1
approach based on the reference of the data given                 Simple Tier 1 approach
in table 1-1?                                          Accepted   now included
There is no mention of NH3 being produced from
urine except for the comment in brackets on line
23. It woul read better for the non-ag expert if a                No longer relevant as we
sentince on NH3 from urine and faeces began the                   have revised these
paragraph                                              Rejected   sections
"a small percentage of this N (is in the form of)
urea or NH4+…………"                                      Accepted   Done
Suggest re-wording the overview. Appears as if
some text was deleted and as a consequence its                    Overview revised and
structure does not read well                           Accepted   expanded
Suggest moving this comment to the bottom of the                  Footnotes are irritating to
page as a footnote                                     Rejected   the reader
The reference Jarvis etal doesn't cover pigs. For
pigs 70% of N is in urine and 90% of urine-N =                    Reference for pigs now
urea-N.                                                Accepted   included
add: for EU-27                                         Accepted   Done
add N2O and CH4 to the emissions created from                     No longer relevant due to
manure                                                 Rejected   re-structure of chapter
There is no abbreviation expansion for TSP. This
concerns the whole text. I suggest to add the
glossary of all abbreviations in chapter 4B            Accepted   Done
"in particular (the) handling of manures                          No longer relevant due to
as……………"                                               Rejected   re-structure of chapter
Groenestein, C.M. and H.G. van Faassen, 1996.
Volatilization of ammonia, nitrous oxide and nitric
oxide in deep-litter systems for fattening pigs.
Journal of Agricultural Engineering Research 65:
269-274                                               Accepted   Done
                                                                 Process descriptions now
Process description is too short                      Accepted   expanded

                                                                 More information provided
                                                                 on processes and clearly
Provide more information about processes (put                    linked with supplementary
extended description in an appendix)                  Accepted   data in Appendix
An example of "movements activities"?                 Accepted   That text now deleted

It is correct that only a small percent of faeces is
NH4+, but the sentence needs further
development, because most manure is managed in                   This section is dealing with
a combination of urine and faces (both slurry and                'fresh' N excreta, so
solid waste). The sentence need to clarify that the              comment not releveant,
TAN content i in solid based stable systems                      but revision of chapter now
contains large amounts of TAN (30-50%). So the                   gives more explanatory
NH3 emission is not "sufficient small".              Rejected    text.
please change Van Fassen and Van Dyke into Van
Faassen and Van Dijk                                 Accepted    Done
The reference = Van Faassen and Van Dijk             Accepted    Done
                                                                 This entire section has
Sentence incorrect                                    Accepted   been revised
ist obvious that PM belonges not to manure                       There is now a separate
mangement                                             Accepted   section for PM
Dust mainly origins from poultry and pig farms.
Dust from poultry houses is mainly caused by
feathers and manure, dust in pig houses mainly
comes from feed, skin particles, faeces and                      Nicola, can you please
bedding (Aarnink & Ellen, 2007, see                              locate the reference and
www.dustconf.com)                                     Accepted   insert
" e.g. at pasture or on yards, and (in) animal
(housing)……"                                          Accepted   Done
Replace with text from original final draft, which
was structured according to pollutant                 Accepted   Have done
Replace with text from original final draft, which
was structured according to pollutant                 Accepted   Have done
                                                                 Incomprehensible
Appendix A2.2.3 ??                                    Rejected   comment
Repace "NIMVOC inventory is further
complicated……." with "Estimates of NMVOC                         That sentence has been
emissions are further complicated………."                Rejected   deleted
                                                                 Section has been re-
Delete activity                                       Rejected   written
                                                                 Section has been re-
on animal?                                            Rejected   written
Delete "The" from "The significant emissions of                  No longer relevant due to
PM…….."                                               Rejected   re-structure of chapter
"The types of feed consumed will have a major                         No longer relevant due to
affect (on) emissions"                              Rejected          re-structure of chapter
Order of items does not seem logical, better follow                   No longer relevant due to
order of figure 2-1                                 Rejected          re-structure of chapter
TAN needs proper explanation first, unless TAN is                     Explanation now give,
introduced earlier? Also mention UAN                Accepted          including UAN

Add after building: and the storage system. I think it                This section re-written to
shoud be included here instead of in line 26           Rejected       include original text

Delete -the storage system- and add -ventilation
system-. The latter is very important in determining
air velocity and thus emission of ammonia                  Accepted   Change made
"the height and density of (the) canopy of the crop                   No longer relevant due to
or grassland"                                              Rejected   re-structure of chapter
Figure 2-1 appears twice                                   Accepted   Done
Authors not cited in chapter 5                             Accepted   Reference now given
General: Distuinguish between indoor and outdoor
storage like you did on the previous page in
summing up important elements. Distuinguishing is
very important because reduction strategies for
indoor storage are totally different from outdoor
storage. Indoor storage is a component of the                         The figure is to illustrate
housing system.                                            Rejected   the principals.
General: I assume the symbols for variables are
scientifically correct, but it is also very confusing, I              The figure has not
got lost. Please find better solution                      Rejected   confused other reviewers
Dammgen and Hutchings is not in References                 Accepted   Reference now included
Can't find "Dämmgen and Hutchings, 2007) at the
reference-list                                             Accepted   Reference now included
                                                                      These are not major
the treatment of manure (i.e.: aeration, separation,                  sources and not explicitly
composting) is not cited here neither considered in                   accounted for in the
the following                                              Rejected   methodology
reference?                                                 Accepted   Reference added
Replace with text from original final draft, which
was structured according to pollutant                      Accepted   Have done
Replace with text from original final draft, which
was structured according to pollutant                      Accepted   Have done
A good idea to clarified that the NMVOC is related
to the methane in manure.                                  Noted

Odour (of pigs) can be characterised by 20 main                       Do not agree with the
components (putting those compounds together                          comment, we already state
creates artificial odour). The formulation used in                    that most of the emission
these lines suggest something else. Please check.          Rejected   is from 20 compounds
the number of Figure 2-1 is double                         Accepted   Done
There are two figure 2.1. Some explanation is                         Same comment as 16 and
needed for this figure in page 7.                          Accepted   19 above
This chapter only covers NH3. Please expand on
other compounds or incorporate in 2.4.1 (which                        We have revised this
then should become 2.3.1)                                  Accepted   section
Figure should be shown in 2.1 before               Accepted        If the figure remains
Figure 2-1; should consider to show a figure based
on different compounds instead of production
states.                                            Rejected        May delete the figure

It is not possible "reducing the rate of
transformation of TAN to NH4". This is incorrect.
NH4 is part of TAN. It is possible to change the                   NH4 is part of TAN, but not
distribution between NH3 and NH4 by altering pH.       Rejected    all of it
If animal feed is silage, NH3 can emit. If not taken
into account as losses, please note so                 Rejected
replace -mainly from feed- with not only from
excreta, but also from feed, animal skin, flees or
plumage and bedding                                    Accepted    Text now amended
between brackets: two third of the total. Of what?
Total NMVOC?                                           Accepted    Sentence clarified
                                                                   No longer relevant due to
Replace "Excreta" with "excreta"                       Rejected    re-structure of chapter

better to say also that the measures to reduce
emissions are listed and explained in Appendix A3 Accepted         Done
why manure drying via conveyor belts would
reduce PM emissions?                                Accepted       Comment deleted
list measures to reduce NH3 emissions (e.g.                        Not the purpose of the
reduction of air contact, lowering of the pH value)                Guidebook to give detailed
instead of manure management stages where NH3                      appraisal of abatement
emissions can be reduced                            Rejected       techniques
                                                                   We have revised this
See remark 5                                           Accepted    section
Not all NH3-emission-reducing techniques in
housing systems reduce odour emission (Mol, G.                     We do not state that all
and N.W.M. Ogink (2004). The effect of two                         techniques to reduce NH3
ammonia emission reducing pig housing systems                      emissions reduce odour.
on odour emission. 2nd IWA Conference on Odour                     We state that techniques
& VOCs: Measurement, Regulation and Control                        with reduce either or odour
Techniques, Singapore. Published in: Water                         can reduce NMVOC.
Science and Technology, 2004, issue 4, p.335-                      Have changed 'can' to
340)                                                   Rejected    'may'
2.4.4 written 2 times                                  Editorial   Done
Cleaning the air with air scrubbers is also an                     Scubbers are now
abatement option (optional as BAT)                     Rejected    mentioned elsewhere
add after N: and/or TAN                                Accepted    TAN inserted
Delete "way" from "The latter is the most effective
way"                                                   Editorial   Done
In the expert Group of Ammonia Abatement
(UNECE) air scrubbers are considered to be
category 1 abatement options. Some information
on effectivity in: Melse, R.W. and N. W. M. Ogink
(2005). Air Scrubbing Techniques for Ammonia
and Odor Reduction at Livestock Operations:
Review of On-Farm Research in the Netherlands.
Transactions of the ASAE. Vol. 48(6): 2303-2313.                      Text amended to report air
                                                          Accepted    scrubbers as category 1
the abatement means are theoretical but not                           We do not suggest
applicable or state of art                                Rejected    otherwise
Decision tree: ask first if it is a key source and then
the other questions (tier 3 available, MMS                            Nicola, can you please
distribution available, etc.)                             Accepted    amend
before this line insert a heading: Ammonia                Editorial   Done
Section title 'Ammonia' is missing                        Editorial   Done
Section title 'Ammonia' is missing                        Editorial   Done
                                                                      We now state the EF
The dafault emission factors include emissions                        includes grazing for
from grazing animals? (better to specify)                 Accepted    ruminants
                                                                      We provide all the
                                                                      information needed, the
I think it will be easier for the user to work with one               reference to IPCC is to
document instead of looking for                                       enable access to more
information/explanation in IPCC (2006)                  Rejected      detail.
Restore text from original draft but removing the
discussion of emission factors                          Accepted      Text restored
Restore text from original draft but removing the
discussion of emission factors                          Accepted      Text restored
                                                                      The chapter is already in
It could be useful to add the exact reference to                      the reference list, and we
IPCC 2006. Example. I suppose it is refered to                        have added the section to
Chapter 10 section 10.2                                   Accepted    the reference
General remark: NO emissions from manure
mangement are not presented (only an estimate is
said to be presented in the section on ammonia
emissions for losses during storage (step 10 page
22 with reference to an Appendix Table 5.9 which
cannot be found; it seems to be the Table on p 57).
However, no NO emf is presented for manure
application to soil??                                     Accepted    Tier 1 approach added
Average Annual Population or as IPCC2006                              Has already been taken
Annual Average Population?                                Editorial   out - discuss with J
Is it required to distinguish between time in stable
and time on grass in Tier 1? I assume that the Tier                   It is stated in the text the
1 EF for NH3 given in Table 3-1 to 3-15 only                          EF includes grazing
includes the emission in stable? EF for NMVOC                         emissions based on
and PM - is it for 365 days in stable?                    Rejected    average grazing periods
Could supply with a sentence like "No Tier 1
approach is available for emission of NOx"                Accepted    Sentence added
                                                                    Incomprehensible
Appendix A3.1.4??                                       Rejected    comment

A lot of misunderstanding and miscommunication
can be caused by the definition of the activity data.
Definition of AAP is not in agreement with p. 4 lines
23-26. I do not think it is appropriate to deal with
this matter only with referring to IPCC 2006 for                    AAP now defined
fuller explanation.                                     Accepted    consistently
Delete "in tables" from "Netherlands, Denmark and
Germany in tables…."                                    Editorial   Done
PM10 and PM2.5 are higher for FYM (straw based)
than for liquid systems. Please make a
differentiation                                         Noted
Specify in the text which regions is applicable the
EF                                                      Noted       This is 4D
References used to proposing new EFs are not
published and not available yet. The National                       Published references now
Inventory Report of a single country can be                         provided for the EFs from
considered a scientific reference?                      Accepted    each national inventory
Inconsistent citation of references.                    Editorial   Has already changed

PM10 EF values presented seem to be not in line
with values used by the Netherlands for several
animal categories. However, since the basis for the
pm10 emf is rather unclear it is very hard to make
a good comparison. See below questions on
categories included and on the time spend in the
meadow:
• It is unclear where the calves and piglets are
included. Eg for cattle it is unclear whether dairy
cattle only includes female adult dairy cows or also
young (dairy) cattle? And what animal numbers
should be used if dairy cattle is a mixed category?
Since calves have a much lower emission factor
their emission will be overestimated if the
presented emf for other cattle should be used. The
same remark can be made for swine: in what
category should the piglets (weaners) be included?
(specifiek place in the tekst: page 12, line 5 to page
13, line 3 and page 14, line 7 to page 15, line 5)     Noted

                                                                    The text will be corrected
Dammgen et al 2008 is not in References             Accepted        to Dammgen 2007 - Nicola
In table 3-1 to 3-14 concerning the PM2.5 emission
referees to "Dämmgen et al., 2008" - this reference                 The text will be corrected
is not on the reference list.                       Accepted        to Dammgen 2007 - Nicola
In table 3-1 to 3-15 Propose one table for each
compounds - then it is more easy to compare the                     We have restored such
emission levels for all livestock categories.       Accepted        tables to the text
The emission factors for NMVOC and PM are
given in incorrect units (kg NH3!). This is valid for
all tables. Both "a-1" and "per AAP" is used. The                   Nicola, can you please
same nomenclation should be used all over, eg.                      make these corrections in
either "a-1" or "per annum"                             Accepted    the tables
                                                                    Will change with new
the unit has to be differentiated by pollutants (not                tables (what are we doing
always kgNH3 a-1 per AAP)                               Editorial   about tables?!
General remark: Incorrect units used in Tables for                  Will change with new
most pollutants except NH3 (all units are                           tables (what are we doing
expressed as kg NH3)                                    Editorial   about tables?!
                                                                    Concise summary tables
I would prefer fewer tables in the text                 Accepted    now provided
                                                                    Have replaced text and
                                                                    tables from original draft.
Remove tables to an appendix (correcting the EFs                    Have not yet placed
for PM where appropriate) and replace the text and                  template tables into
tables from the original draft, adding more                         Appendix as we need to
information about EFs                              Accepted         agree this with TNO
Tables are confusing and should be presented in a                   Concise summary tables
condensed form.                                    Accepted         now provided
                                                                    It is not appropriate to
                                                                    insert large numbers of
the Reidy et al, 2007 reference is insufficient, it                 references in the text, the
does not contain the specified NH3 emission                         full list is now given in the
factors. Please give more references                    Accepted    Appendix.
Please indicate in the text that all animal manure is
surface applied                                         Accepted    Text changed
Please indicate in the text that all manure storages
are open                                                Accepted    Text changed
the tables are not the best, previous solution had                  Agree, but we need to
been better                                             Accepted    agree with TNO

The detailed tables provided even though
numerous are user friendly and allow the user to be
able to calculate upper and lower estimates of
emissions for each gas. It may be possible to
included all the info in one large table however, it                This is not the view of the
may become too cluttered and diificult to use.                      great majority of
There appears to be some discrepancies with the                     respondents, and for the
livestock categories used in 4B and 4D. Suggest a                   final version we propose
closer look at the discriptions in the emission factor              having the detailed tables
database especially for cattle sub-categories.         Rejected     in the Appendix
Remove tables to an appendix (correcting the EFs
for PM where appropriate) and replace the text and                  Have done this. Nicola,
tables from the original draft, adding more                         can you please see to EF
information about EFs                                  Accepted     corrections
I am afraid the units for NMVOC, PM10,PM2,5 are
not quite clear for me - for all these parameters is                Will change with new
"kg NH3 per AAP"correct? This concerns tables                       tables (what are we doing
3.1 to 3.15                                            Editorial    about tables?!
                                                                   Will change with new
                                                                   tables (what are we doing
Tables: References inconsistent with Chapter 5        Editorial    about tables?!
                                                                   Will change with new
change units for NMVOC, PM10, PM2.5 from NH3                       tables (what are we doing
into appropiate units                             Editorial        about tables?!
Explain abbreviation "AAP" (explanation comes in
the next section, but should be given when AAP is
used for the first time)                          Accepted         Done
Why are the last two rows relevant? The same                       Can't change the table
remarks goes for every table 3-.                  Rejected         template

The reference publication Reidy et al, 2007 is
mentioned as basis for the values presented in the
Guidelines 2008 draft for tier 1 NH3 emf (on pages
12 till 17 in Tables 3-1 till 3-15) and for tier 2 NH3
(on pages 24 till 31 in Tables 3-16 till 3-30).
However, it only provides some (not all, yard values
are not included) tier 2 data for dairy cows and
fattening pigs. It is unclear what is the basis for the
tier 1 emf for all animal categories (not even for
dairy cattle and fattening pigs the chosen defaults
are presented in Reidy et al, 2007). Also is it
unclear what is the basis for the tier 2 emf for other
animal categories than dairy cows and fattening
pigs and for the tier 2 Yard emf for dairy cows and
fattening pigs.
It is recommended to make clear what the basis is
for all chosen emf (to provide information on the
publications where these data originate from).
(specifiek place in the tekst: page 12, line 5 to page
17, line 2 and page 24, line 16 to page 31, line 2)     Accepted   More references given
Table 3.1 and all other. 95% confidence interval is
often the same and should prefrenctially be given
as +-xx%. Especially to avoid upper emission                       Nicola, can you please see
levels above 100.                                       Accepted   to this
                                                                   Will change with new
                                                                   tables (what are we doing
Check units of Table 3-1                              Editorial    about tables?!
same comment as for dairy cattle                      Noted
PM is higher for FYM then for liquid systems
fattening pigs                                        Noted
PM10 EF values presented seem to be not in line
with values used by the Netherlands for several
animal categories. However, since the basis for the
pm10 emf is rather unclear it is very hard to make
a good comparison. See below questions on
categories included and on the time spend in the
meadow:
• Pm10 EF values in Tables are not always clearly
based on table A3-5 in appendix: eg eg for
fattening pigs, sows and laying hens in Table A3-5
2 different values are presented for 2 different
housing types, while in Table 3-8 en 3-9 (page 14
and 15) only one (mean?) value is presented for
the different systems.                              Noted
please lower PM2.5 because these figures are now
higher then PM10                                    Noted
PM is higher for FYM then for liquid systems for
sows                                                Noted

For PM10 (Table 3-12) emf are provided for all
manure management systems. Since there are big
differences in the two manure management                        The distinction between
systems cages and perchery) it is recommended to                cages and perchery is in
provide emf for the two management systems.          Accepted   the new table
please differentiate within poultry for solid
(bedding) and liquid systems                         Rejected   Not for Tier 1
Cleaning period: the unit (in day) is lacking        Accepted   Unit inserted
better to add in the table also a definition of n-
round = average number of production cycles per
year                                                 Accepted   Definition inserted
n-places: add usually occupied                       Accepted   Definition expanded
Empty period: I prefer to add "average" duration
during the year….                                    Accepted   average' inserted
The link to “FAO Production Yearbook” is:
http://faostat.fao.org/
Under item “Latest news” FAO Statistical
Yearbooks 2005/2006 (issue 1 and issue 2) are
available.
Issue 1:
http://www.fao.org/statistics/yearbook/vol_1_1/inde
x.asp and Issue 2:
http://www.fao.org/statistics/yearbook/vol_1_2/inde
x.asp
(Livestock numbers are available from Issue 1,
Table A9).

Please note that the yearbook is updated on an
annual basis. Providing the URL
http://faostat.fao.org/ is probably the best.
(Just a thought regarding section 3.2.3 Activity
Data (line 4-6)… if a country do not carry out
annual surveys on animal numbers how would                         References included.
ESTAT or FAO get these numbers?)                       Accepted    Thanks to the reviewer
Check definition with earlier explanations on p 4                  Text amended to be
(line 23-26) and p. 11 (line 26)                       Accepted    consistent

Sometimes the two sources of activity data
information do not match. EUROSTAT information
for european countries is updated every year and
have definitive data available. FAOSTAT important
source, but nowadays data available only till 2004                 Have amended wording
year. Probably the best is to encourage at first                   slightly to reflect the
national statistics and after other sources.       Accepted        comment
Same comment: define is using Average Annual
population or annual average population            Editorial       Done
                                                                   No, statement made that
                                                                   default based on surface
Are there no activity data on storage and spreading                application and open
to be mentioned here?                               Rejected       stores

The formula should be elaborated further. For most
animal types AAP is given in the national statistis.
For animals having a life cycle> 1year, the cencus
in most countries thus takes into account empty
places. The formula is therefore more a correction
formula for amimals haveing a life cycle <1year.                   This section has been re-
The same is valid for the subsequent formulas.         Accepted    written to make clearer
I prefer to have the methodology to estimate
animal number/acivity data before the methodology                  The TNO chapter structure
for EF                                                 Rejected    does not allow this
"present on a particular day (will)……….."              Editorial   Done
(A)nnual agricultural cenus (data) can supply (this                Sentence changed with
information)                                           Editorial   other comments
                                                                   Grammar was already
"seasonal production cycle(s), ……"                     Rejected    correct
"is seaonal or because the (housing) is being
cleaned"                                               Editorial    Done
Table 3-1 (to Table 3-15)                              Editorial    Done
after the word "rounds" specify per year               Accepted     Done
                                                                    No, there are three
Third method seems second method                         Rejected   methods
default data for N excretion: where?                     Accepted   Reference to table given
The basis for a Tier 2 approach is mentioned in line
14-16. In these calculations it‟s not exactly clear if a
breakdown of the different livestock categories
(cattle, pigs etc.) into sub-categories (e.g. sows,
piglets etc.) is taken into account. However from
sections 3.3.1 “Algorithm” + 3.3.2 “Technology
Specific Emission Factors” it appears that different                Text has been
livestock sub-categories are taken into account.                    substantially revised so
Perhaps the introduction of section 3.3 could be a                  comment no longer
bit clearer on this.                                     Rejected   relevant (Step 1 onward)
                                                                    The time spent grazing is
                                                                    needed in order to
For PM emission is mentioned that "For grazing                      accurately estimate the
animals… the grazing season and the daily grazing                   time spent in the building
time is needed" BUT at page 9,7 is written that PM                  where most emissions
emission from "cattle, pigs ect…. are considered to                 take place. This is now
be negligible during grazing"??                     Accepted        made clear.
Suggest deleting the heading PM and begin the                       The guidebook template
paragraphs as follows: " In the case of PM,                         requires clear sub-
information is required……………."                      Rejected        headings

                                                                    Text amended in response
                                                                    to previous comment to
                                                                    state that default based on
                                                                    surface application and
No information on application required?             Rejected        open stores
activity data listed under the heading PM are not
only required for PM emission estimates but for the                 Yes, to confirm specific
other gases as well                                 Rejected        requirements for PM
                                                                    Yes, but this is for Tier 1,
emphasis only on livestock numbers; much more                       the need for activity data
activity data are needed for an accurate inventory;                 emphasised in Tiers 2 and
give those more room in the chapter                    Rejected     3
                                                                    Manure treatment is not a
information on manure treatment is needed, please                   major factor in national
add this to the list                              Rejected          emissions
                                                                    Text has changed and the
formulate stronger e.g "Tier 2 is RECOMMENDED"                      passage referred to
instead of "proposed"                          Rejected             removed.

Why is PM mentioned separately, this infromation                    Yes, to confirm specific
is also needed for other components?                   Rejected     requirements for PM
                                                                    Changed with earlier
section 2.1.1 where is it?                             Editorial    comment
                                                                    Not sure about this - J
                                                                    please could you take a
"PM" - misprint ?                                       Noted       look
In which way are soil PH included?? - is this shown                 Reference to soil pH
in figure 2-1 (process scheme)?                         Accepted    deleted
Remove this Tier 2 description and replace with the                 The original text has been
text from the original draft (i.e. With more                        re-inserted, with some
explanation and without the formating errors)           Accepted    improvements
Remove this Tier 2 description and replace with the
text from the original draft (i.e. With more                        Duplicate of row 103
explanation and without the formating errors)           Accepted    above?
                                                                    This section has been re-
See comment to page 17 line 19.                         Accepted    written to make clearer
This chapter heading can be left out. Instaead
emphasize that Tier 2 is just ammonia (although
already mentioned in line 32).                          Accepted    Done
"the types of stores in which (manure) is                           Changed with earlier
kept……….."                                              Accepted    comment
                                                                    Changed with earlier
PH = pH                                                 Accepted    comment
I do not understand why you mention soil PH? Key                    Reference to soil pH
variables are not shown in Figure 2-1                   Accepted    deleted
after N excretion: add : and TAN or UAN                 Accepted    done
Table 3-1, section 3.3.1 and also many times in the
following: the ref is wrong or lacking                  Accepted    Nicola is dealing with this
mexcreted is not a self-explaining symbol for total
nitrogen excreted, it seems total matter excreted, it
would be better to use mNexcreted, by analogy
with mTAN                                               Accepted    Changed to mN excreted
after milk add "eggs or offspring"                      Accepted    Done
                                                                    Nicola, can you check
It seems to me, references to Tables 3-1 and                        table references once we
Paragraph 3.3.1 are wrong                               Accepted    finish the text
I would prefer to find IPCC equations10.32,10.33                    We should avoid simply
right in the Guidebook,                                 Rejected    repeating IPCC text
                                                                    The derivation of the
The source of the stepwise approach should be                       approach is given in
cited.                                                  Accepted    section 3.2.2.1
Treatment of units: "kg N a-1" means kilogram
newton per year!                                        Accepted    changed to 'kg a-1 N'
                                                                    Need to sort out the tables
Table 3-1 does not exist in that form                   Editorial   in these steps
in IPCC organic matter is defined as Volatile                       The sentence referred to
Solids: wy not to use the same here?                    Rejected    has been superceded

it is not clear how do you use xfaeces and xurine: I
suppose xurine is not the same as xslurry and x
faeces is not the same as xFYM. So it is not clear                  This section has been re-
how to translate xfaeces and xurine in mTAN;         Accepted       written to make clearer
proportion of total excreta or proportion of total N in
excreta? (is the assumption that Nitrogen split in                 This section has been re-
the same way as mass into faeces and urine?)            Accepted   written to make clearer
mfaeces: definition?                                    Accepted   Defined

use the same symbols in the text and in the
formulas: mTAN_slurry is mbuild_slurry,TAN? Etc. Accepted          Same symbols now used
I would prefer to see IPCC equations10.24 right in                 Reference to equation no
the Guidebook                                      Rejected        longer made
                                                                   Need to sort out the tables
Where is table 3-3?                                   Editorial    in these steps

                                                                   J - there is now a missing
                                                                   equation - would you like
check subscripts                                      Editorial    me to renumber these?
                                                                   This section amended to
And how should we calculate x(Nfaeces)?               Accepted     make clearer

                                                                   To make step 7 grazing
                                                                   would interrupt the
                                                                   sequence from excretion
I would prefer step 7 to be grazing. This manure is                through housing to storage
not in storage                                      Rejected       and then to application.
any references for the value of fmin?               Accepted       Reference inserted

at this point of the calculation xFYM is the
proportion (without bedding!) of manure excreted,
handled as FYM. I believe it woul be better specify                Have checked formulae
that the proportion is in mass (kg/kg) and that it                 and they do account for
doesn't take into account the bedding material…     Rejected       bedding
mbedding don't appear in the formulas…              Rejected       It appears in Eq 23
any references for the value of fimm?               Accepted       Reference inserted
                                                                   Need to sort out the tables
Where are Tables 3-3 and 5.9?                         Editorial    in these steps
                                                                   Nicola, when re-drafting
Table 3-3 shows Tier 1 emission factor for Other                   complete please check
Cattle on slurry which give no relevans in the text                accuracy of references to
describtion.                                          Rejected     Tables
                                                                   Nicola, when re-drafting
Table 3-3 shows Tier 1 emission factor for Other                   complete please check
Cattle on slurry which give no relevans in the text                accuracy of references to
describtion.                                          Rejected     Tables
                                                                   Incomprehensible
Appendix Table 5.9??                                  Rejected     comment
                                                                   Incomprehensible
Appendix Table 5.3??                                  Rejected     comment
Do you have a refence for 0.68?                       Accepted     Reference inserted
Do you have a refence for 0.1?                        Accepted     Reference inserted
                                                                   mm storage N, correction
mm (storage,org) or mm (storage, N)?                  Accepted     made
" it does (however) require much more………."            Editorial    Done
                                                                  Nicola, when re-drafting
Table 3-3 shows Tier 1 emission factor for Other                  complete please check
Cattle on slurry which give no relevans in the text               accuracy of references to
describtion.                                          Rejected    Tables
Would a formula not normally be written as: Kg                    Not according to one of the
NH3-N a-1 ??                                          Rejected    other reviewers
                                                                  It was supplied for the
the active axcel file is necessary!!                  Accepted    review!
                                                                  It was supplied for the
Does Appendix B exist?                                Rejected    review!
                                                                  It was supplied for the
Do there exist an Appendix B?                         Rejected    review!
The ammonia emission report unit in NFR is NH3                    Which is what we have
and not NH3-N                                         Rejected    written!?
Wher is Figure 1-1?                                   Editorial   Done
As the EF is a percentage of TAN, there is no                     The evidence we have
reason to differentiate in EF yard and for grazing                indicates that there is a
between dairy cows and other cattle                   Rejected    reason
                                                                  Have replaced text and
                                                                  tables from original draft.
                                                                  Have not yet placed
Remove tables to an appendix and replace the text                 template tables into
and tables from the original draft, adding more                   Appendix as we need to
information about EFs                             Accepted        agree this with TNO
Tables are confusing and should be presented in a                 Concise summary tables
condensed form.                                   Accepted        now provided

                                                                  The concise tables have
                                                                  been restored and we
                                                                  propose the template
same remark regarding the terrible table              Accepted    tables go to the Appendix
                                                                  Have replaced text and
                                                                  tables from original draft.
                                                                  Have not yet placed
To many tables - all data could relativly simple be               template tables into
represented in one or two tables without missing                  Appendix as we need to
important information.                                Accepted    agree this with TNO

                                                                  The Guidebook only needs
                                                                  to cover the NFR codes.
                                                                  Section 3.4, Tier 3 states
                                                                  that 'if data are available,
                                                                  emission calculations may
Only emission factors for dairy cows and other                    be made for a greater
cows are included. Emission factors for other cattle              number of livestock
sub-categories are required here. See comment 14                  categories than listed
for further issues.                                  Rejected     under Tier 2'.
Remove tables to an appendix and replace the text
and tables from the original draft, adding more                   Have re-inserted text and
information about EFs                                Accepted     concise tables
The chosen tier 2 default emf NH3 in the Tables 3-
16 till 3-30 on pages 24 till 31 seem to be an
average of the figures presented in the appendices
page 48 till 50 (Table A3-1 a till d). However there
are some deviations: Yard emf are not available in
the appendix Tables and a figure of 0.15 is
presented for broilers (one value only for the                  Further footnotes now
Netherlands), while in Table 3-28 a value of 17 is              added to new summary
presented. What's the basis for this figure?         Accepted   tables
                                                                Will change with new
Check proper width of cells. Why are last two rows              tables (what are we doing
relevant?                                          Editorial    about tables?!
Now it is NH3-N conversion despite the formula
consists of "Estorage, NH3". It should be changed               This equation no longer in
in all formuals to "Estorage, NH3-N".              Rejected     chapter
All tables has the unit as %TAN. It should
preferentially be "% of TAN" and no 95% upperlimit              We think the meaning is
above 100%                                         Rejected     clear
                                                                Will change with new
All tables could be written more easily. To much                tables (what are we doing
unnessary data                                     Editorial    about tables?!
Figure 1-1 not presented in the document           Editorial    Done
same comment as for dairy cattle                   Rejected     And the same riposte
                                                                Will change with new
                                                                tables (what are we doing
not "Other cows" but "other cattle"                Editorial    about tables?!
the EF for yard is extremely high and not
explainable, so please adjust to 53                Rejected     Source of EF now given
the EF for grazing is too high, so please change
into 10                                            Rejected     Source of EF given
There is no EF for outdoor sows?                   Accepted     EF added using UK data
                                                                We do not think there is
Is the manure of the laying hens considered always              enough evidence to
as solid manure and not slurry?                     Rejected    discriminate
broilers and other poultry are mostly kept on solid
manure systems, so here no need for EF liquid                   I cannot see that we have
systems                                             Rejected    an EF for broiler slurry (?)
                                                                Will change with new
                                                                tables (what are we doing
Table 3-29 - no data for "other poultry"??         Editorial    about tables?!

(Table 3-29 Other poultry) no figures are included. Accepted    Corrected
(Table 3-27) emf are provided for all manure
management systems. However, since these
figures are based on the Appendix tables it turns
out that only solid manure is included. Since liquid
manure systems (cages) still exist and since their
emf are different from solid manure systems, also
liquid manure management emf should be                          Not enough evidence to
provided.                                            Rejected   differentiate
please make a differentiation into solid (bedding)              Not enough evidence to
and liquid.                                          Rejected   differentiate
                                                                Nicola, can you please see
Check Values and confidence interval in table        Accepted   to this
                                                                This section is specific to
3.3.3 Abatement: why not Controls as in section                 the incorporation of
2.4? Abatments seems more appropriate to end-of-                abatement techniques in
pipe techniques…                                 Rejected       the calculation
add a reference to Appendix A3                   Accepted       Done

                                                                All inventory makers surely
As it seems to me, table 10.19 of IPCC chapter 10               have IPCC available as
Default N excretion data is necessary to be                     well (and can look the
included in the Guidebook                         Rejected      default values up)
As it seems to me, paragraphs 3.3.3 and 3.3.4 are
not complited                                     Accepted      Text now amended
                                                                The section now makes
No technique to reduce emissions in livestock                   reference to housing
houses? In the ILF BREF there is a long list of                 techniques in UNECE and
BATs for animal houses..                             Accepted   BREF docs
The EF for inside storage and outside storage
differ, mainly due to differences in temperature.
Moreover by removing the manure quicker to
outside, is an abatement technique. As I do not
have the data from Reidy et al, I cannot check the
presented EF. If necessary I will be helpful to
elaborate this in more detail.                       Rejected
                                                                The intention was to put
                                                                information on activity data
I dont't understand why this section is here and not            specific to the Tier with
within 3.2.3                                         Rejected   that Tier
                                                                And manure application
after "storage" add "and after field application"    Accepted   inserted
Reinsert sections for the different polluntants.
Remove second paragraph (not valid for all
abatement measures (eg optimised feeding)            Accepted   Have done
                                                                Table in Appendix gives
Refer to IPCC data on manure management                         cross reference to IPCC
systems                                              Accepted   definitions
Likely the choosen approach is that most of the
animal manure does not stay for a long time inside              Fair commenr, but text
the animal house and is stored outside.              Rejected   already covers this
This reviewer has the opinion that a lot of
European animal production systems store their                  Contradicts previous
manure inside the animal house                       Rejected   comment
Referer to Appendiks A - chapter A.3.1 for further
information                                          Accepted   Done
Reinsert sections for the different polluntants.     Accepted   Have done
                                                                Reader referred to
                                                                Appendix and other
add abatement measures from the house                Accepted   documents
not only housing activity data are relevante, but
storage and spreading as well; please add these      Accepted     done
                                                                  The concise tables have
I cannot find these notes in the Tables?             Accepted     the footnotes
check subscripts                                     Editorial    Done

                                                                  Because there is only a
Abatement deals with ammonia only                    Rejected     Tier 2 method for ammonia

Is the formula correct? The value calculated is my
view an implied emission factor and not an EF for
abated techonlogy. N_abatement is not defined.       Rejected     Formula no longer used
see remark 13 about differentiation of inside and
outside storage                                      Accepted     Text amended
Emissions are not solely governed by fouled area.
Change formulation?                                  Accepted     Paragraph re-worded
There is no restriction on the form of Tier 3,
provided it can supply estimates that are more                    Have re-worded to make
accurate than Tie 2.                                 Accepted     this point.
Mentioned an example of double counting.             Accepted     Example now given
Same comment: for european countries the best
cross check is to be done with EUROSTAT
information. FAOSTAT statistics at this moment
are not updated.                                     Accepted     Changed as suggested
Probably an example of "manure management sub-
categories within the livestock categories" could be
useful. Otherwise, define it in Figue 3.1 or at page
18 line 27 where this term is used.                  Accepted     Example now given
                                                                  Quoted uncertainty now
There is also a figure for overall uncertainty in the             included, Nicola, can you
Netherlands, using a Tier 3 approach. The Dutch                   please find the full
uncertainty is 17% (TNO, 2004)                        Accepted    reference
TNO, 2004. Uncertainty assessment of NOx, SO2
and NH3 emissions in the Netherlands, TNO report                  Quoted uncertainty now
R 2004/100, TNO, Apeldoorn                            Accepted    included

In the text is mentioned "Consequently, there are
large uncertainties associated with the default EF                Text reworded to refer to
for this source". BUt no NOx defalut value is                     emission estimates, not
recommended - not even for Tier1 methodology.        Accepted     specific EF

also in Mol and Ogink 2004 (see also remark 22)      Rejected     No need for action
MS(T,S) ??                                           Rejected     These terms are defined

it is not clear from the previous methodology that
the emissions from grazing animals have to be
reported under 4D. How could you do it in the case
of tier1 methodology? If I understood it correctly, it
is necessary to highligh somewhere else that you                  This has now been made
make the calculation under chapter 4B and to                      clearer at the beginning of
report the results under chapter 4D                    Accepted   the chapter
why are these sentences reported under "external                    The statement has been
review?                                                  Accepted   deleted
Has this been copied directly from the IPCC
guidelines? It contradicts the statement p3, l 1 - 9
where all NH3 emissions are reported under                          The statement has been
manure management and not under soils.                   Accepted   deleted
All references should be available on the internet at               Nicola, can you check this
EEA homepage                                             Accepted   with TNO
van Fassen etc should read: Van Faassen, H.G.
and Van Dijk, H. 1987. Manure etc In: H.G. Van
der Meer, R.J. Unwin, T.A. Van Dijk and G.C.                        Reference seems to have
Ennik etc                                                Noted      been removed
no overview for ammonia?                                 Accepted   Now added
PM definitions are not target orientatet.Its a mixture
of differnt defin. Ist to separate why in the past
other defin. Are used and which will be used in the
future. The relevant difference in comparision with
gases should be explained.Its nice to see my
figure(A1-1)but no quoting?                              Noted

I miss some further describtion for NH3 and NOx          Accepted   Now added
Amount of science in the Guidebook is just right,                   The revision now gives a
but it is better to place it in one place, it is                    more coherent balance
unimportant where -in the main body text or in                      between chapter and
appendix                                                 Rejected   Appendix
the Appendix is toolong.The author could not
decide wether he gives information(scientific(in the                The Appendix is now
body or the appendix.                                    Accepted   shorter
General: Why is this information in the appendix                    We have restored much of
and other information in text. When is it                           the explanatory text to the
background information and when not? Choice is                      main chapter and now
not clear and seems arbitrarely. Please explain                     think the division between
protocol or change the way information is                           text and Appendix is
presented without shattering.                            Accepted   coherent.
The appendices are misplaced and should be                          It makes more sense to
included at the end of the agriculture chapter (i.e.                have the Appendices
after 4G) in future drafts.                              Rejected   closer to the main text
A clear guidebook definition of "Inhalable dust" and                Discuss with JG - put into
"Respirable dust" are needed.                            Noted      the GG chapters
Appendices will require revision, since some
material will be moved from the current appendices
back into the body of the text                           Accepted   Have done
Appendices will require revision, when comments                     Appendices have been
above have been taken into account                       Accepted   revised
                                                                    J - is this correct? Is this
Caption: "aerodynamic" instead of "airodynamic"          Noted      your graph to change?
This paragraph appears to be misplaced. Suggest                     Panel Chairs are happy
re-wording                                               Rejected   with text
                                                                    Because this is the
                                                                    Appendix where we
why the information here are related only to                        include specific additional
grazing?                                                 Rejected   information
"measured" instead of "made"                             Editorial   Done

• For cattle housing system values on pm10 EF are
lower for litter (=solid manure=FYM) compared to
slurry. This is in contradiction with the text on page
44 line 38 (section PM), which says that it is
expected to find higher pm10 emissions from litter
compared to slurry. This was also found comparing
English dairy cows with litter to German dairy cows
in cubicles (slurry).
Directly below this alinea (page 45 line 8) this is
once more contradicted by the remark that cubicle
houses (slurry based) give higher pm10 emissions
compared to litter based systems (depending on
several factors). This is in line with the presented
pm10 emf. However, no reference is presented
here. Where are the default pm10 values
presented based on then?
It is recommended to rewrite this text to present a
clear line of reasoning.                                 Noted
In a deep litter system PM emissions can be
reduced by 50% because the dust is incorporated
into the bed and held there because of moist.
Activity of animals will not have an effect anymore:
CIGR-working group No 13 "Climatization
Environmental Control in Animal Housing". 1994.
Aerial environment in                                                Have incorporated
animal housing. Concentrations in and emissions                      comment. Nicola, could
from farm buildings. CIGR-rapport Report Series                      you ask TNO for the full
No.                                                                  reference to CIGR 13,
94.1, CEMAGREF, Groupement de Rennes,                                authors etc, it seems to
Rennes Cedex, France, 116 pp.:                           Accepted    have got cut off in cell H 48
Why this sentence is here and not at page 46
under Reduce emissions during and after                              Because this is where we
landspreading?                                           Rejected    discuss management
landspreading instead of spreading                       Accepted    done
please give the source of table A2.1, Expert Group
on Ammonia Abatement                                     Accepted    Reference now given
"Emissions following (the) spreading (of)
manures….."                                              Accepted    Sentence expanded
please give the source of table A2.2, Expert Group
on Ammonia Abatement                                     Accepted    Reference now given
Asterix and "a/" not explained                           Accepted    Now explained
it has to be specified which values are expressed                    TAN, Table heading
as %TAN or % total N                                     Accepted    corrected
Table A3-1 Where is the note explenation?                            The notes are redundant
Reference?                                               Rejected    and have been deleted
The notes in the table (1,2,3 in the first row of the                The notes are redundant
table) are not explained                                 Rejected    and have been deleted
Table A3-1 There is no text ontroducing the table.
In which way can this table be used?                     Accepted    Now added
For NH3 as far as dairy cows and fattening pigs are
considered, the figures presented in the
appendices should be the same as those
presented in the publication of Reidy et al, 2007. In
general this seems to be the case. However, there
are some deviations. Some examples:

19.2 is presented for dairy cows in the Netherlands,
while in the Reidy et al, 2007 publication a value of
16.3 is presented (for both models). Is the value of
19.2 wrong or is it based on another publication?

Netherlands and the UK a figure of 13.3 and 7.7 is
presented for dairy cows respectively, while in the
Reidy et al, 2007 publication a figure of 13.6 and
10.0 is presented.

figure of 33.2 is presented for fattening pigs, while
in the Reidy et al, 2007 publication a figure of is
presented.                                                       References for each
We recommend to present and provide all                          national Inventory now
references used.                                      Accepted   given in the Appendix
Use full text or abbreviations of countries, not both
(Netherlands = NL and not Nl)                         Accepted   All countries now full text

the title of table A3.1 is misleading with repect to
the EF, or it is % of TAN either % of total N
available. Maybe an additional column is desirable.              Heading clarified,
Please give also the corresponding references        Accepted    references given
Numbers in heading not explained                     Rejected    Numbers now deleted
Are the emission factors expressed as %TAN or
total N available.                                   Accepted    Made clear it is % TAN
For PM10:
• It seems from table A3-5 that the EF for dairy
cattle are valid for dairy cattle with a weight of 500
kg. So if there is information on the mean weight of
cattle categories a recalculation could be made.
However, Table A3-3 and A3-5 are not in line with
eachother: according to Table A3-3 calves have a
weight from 50-100 kg, while in Table A3-5 they
have a weight of 150kg. Beef cattle is not
mentioned in Table A3-3. Since young cattle in this
Table has a weight between 450 and 650 they
cannot be compared with the beef cattle in Table
A3-5 (weight of 350 kg).
• It is unclear what transfer factor should be used.
For young cattle it says in Table A3-3 0.6 till 1.2; so
for the lower weight of 450 kg the lower transfer
factor of 0.6 should be used. But in Table A3-5 for
beef cattle with a weight of 350 kg a conversion
factor of 0.7 is used!
• For cattle it is unclear whether in the EF pm10
presented the time spend in the meadow is taken                    The tables are now
into account? If it is, how has this been done. And if             consistent in their use of
it hasn't how should this be done?                      Accepted   livestock weights
                                                                   calf weight now 50-150,
please change the liveweight for calves into 50 to                 transfer factors scaled
300 kg                                                Accepted     accordingly
                                                                   These factors are
                                                                   explained in the text
                                                                   above. The uncertainty
Transformation factors for poultry don't make                      and need for more work
sense?                                               Accepted      are acknowledged
this reviewer does not agree with the conversion
factor of 1.0 for poultry. Takay et al, 1998 gives
information over the conversion factors even for
poultry.                                             Noted
"Seedorf and Hartung, unpubliched" - can´t find this
reference on the reference list.                     Noted

the conversion factor for fattening pigs is here 0.16
and in table A3.3 0.12. Please change it into 0.12 Noted
A lot of EF values for PM2.5 are physically
impossible. RD is measured as PM5.0 and should
therefore be higher then PM2.5. So, please lower
the PM2.5 values for dairy cattle, beef cattle,
calves and weaners                                    Noted
as a consequence of the remark on conversion
factor of 1.0, the PM10 and PM2.5 values for laying
hens and broilers should be lower                     Noted
                                                                   Not hyphenated anywhere
Hyphenation "Fattening pigs"                          Rejected     else
What are information in Table A3-7, Table A3-9,                    To provide supplementary
Table A3 and Tbales on page 57 used for??             Rejected     information
Passive composting: for the IPCC equivalent
seems more appropriate "Composting - passive
windrow"                                           Accepted     Done

What is reference for the values in this table? As a
General comment I want to add that literature                   Table heading now given
references are sometimes given, but not always.      Accepted   and referred to in text.
I suggest to consider including all IPCC references
right in the text                                    Rejected
It should be considered to move some of the more
scientific description in appendix to the main text.
E.g. explaining why the NMVOC emission is an                    Have restored much of the
important environmental issue.                       Accepted   text to the main chapter

It is nessary to explain much more in detail the
difference between Tier 1 and Tier 2 in the
emission factors because they are so
fundamentally different. Is NH3 in Tier 1 converted
to NH3 from NH3-N? Spend much more space on
explaining the emission factors in Tier 2 and the
difference between slurry and solid. Explain why                The restoration of text now
NH3-N is used in Tier 2 compared to Tier 1.         Accepted    gives more explanation
                                                                There is no confusion, Tier
It is a big confusion between NH3-N and NH3.                    2 calculations have to be
Sometimes is NH3 reported and sometimes is NH3-                 as N, but reporting has to
N reported. Please clarify.                     Rejected        be NH3-N


The chapter on manure management is not very
well written. There is a strong need for clear
references, a better explanation of the complex
system with N and ammonia. It looks like that there
should be no dublicate between this guidebook and
the IPCC 2006However, for clarification there could
be some tables on Nex for typical animal types.
Stabletype distribution from the RAINS dataset etc.
to give more information on the basic situation in              Much of the original text
many countries. And reduce the number of tables                 has been restored to
because they are really unessesary in many cases. Accepted      improve clarity

General comment. National agriculture inventory
consistency (CLRTAP-UNFCCC): Is this new
CORINAIR update methodology (Tier2) for manure
management compatible with the IPCC 2006?       Rejected
General: Reference to Appendix A (see Appendix                  These cross references
A) is not consequently done looking at                          have been corrected.
corresponding chapters in the appendix, please                  Nicola, when finished can
check. Also check table numbers                 Accepted        you double-check.
                                                                Will change with new
                                                                tables (what are we doing
Units for PM are wrong not kg NH3                  Editorial    about tables?!
                                                               Will change with new
General: References to tables and figures in the               tables (what are we doing
text are not correct, please check.                Editorial   about tables?!
                                                               Will change with new
                                                               tables (what are we doing
General: I miss Table with notations               Editorial   about tables?!
                                                               Don't understand what is
Accordning to the reporting purposes Tier 1 and                meant by the comment. It
Tier 2 methodologies will be used. For comparision             is no more than a
needs it will be necessary to recalculate the                  statement not appearing to
emission values                                    Rejected    require an answer.
                                                               Don't understand what is
Accordning to the reporting purposes Tier 1 and                meant by the comment. It
Tier 2 methodologies will be used. For comparision             is no more than a
needs it will be necessary to recalculate the                  statement not appearing to
emission values                                    Rejected    require an answer.
                                                               Don't understand what is
Accordning to the reporting purposes Tier 1 and                meant by the comment. It
Tier 2 methodologies will be used. For comparision             is no more than a
needs it will be necessary to recalculate the                  statement not appearing to
emission values                                    Rejected    require an answer.
                                                               Don't understand what is
Accordning to the reporting purposes Tier 1 and                meant by the comment. It
Tier 2 methodologies will be used. For comparision             is no more than a
needs it will be necessary to recalculate the                  statement not appearing to
emission values                                    Rejected    require an answer.
                                                               Don't understand what is
Accordning to the reporting purposes Tier 1 and                meant by the comment. It
Tier 2 methodologies will be used. For comparision             is no more than a
needs it will be necessary to recalculate the                  statement not appearing to
emission values                                    Rejected    require an answer.
                                                               Don't understand what is
Accordning to the reporting purposes Tier 1 and                meant by the comment. It
Tier 2 methodologies will be used. For comparision             is no more than a
needs it will be necessary to recalculate the                  statement not appearing to
emission values                                    Rejected    require an answer.
Accordning to the reporting purposes Tier 1 and
Tier 2 methodologies will be used. For comparision
needs it will be necessary to recalculate the                  Don't understand what is
emission values                                    Rejected    meant by the comment.
Accordning to the reporting purposes Tier 1 and
Tier 2 methodologies will be used. For comparision
needs it will be necessary to recalculate the                  Don't understand what is
emission values                                    Rejected    meant by the comment.
                                                               Don't understand what is
Accordning to the reporting purposes Tier 1 and                meant by the comment. It
Tier 2 methodologies will be used. For comparision             is no more than a
needs it will be necessary to recalculate the                  statement not appearing to
emission values                                    Rejected    require an answer.
                                                                  Don't understand what is
Accordning to the reporting purposes Tier 1 and                   meant by the comment. It
Tier 2 methodologies will be used. For comparision                is no more than a
needs it will be necessary to recalculate the                     statement not appearing to
emission values                                    Rejected       require an answer.

NF3 4.D.1 is not agricultural soils. It should be 4.D Accepted    Done
Inconsistent citation of references.                  Accepted    Done
                                                                  In the absence of concrete
Same remarks in generall as given for 4.B. I am                   suggestions for
not happy with th PM                                   Rejected   improvement..
Specify where have to be reported emissions from
grazing animals. It is not clear if they have to be
calculated and reported under 4B or calculated
under 4B but reported under 4D. The same for                      Text inserted to explain
manure application                                     Accepted   and cross-reference
NFR 4D and CRF 4D codes do not include the
same source categories: Application of manure to
soil and production of animal manure in the
meadow is not included in NFR 4D while it is                      Clear explanation given in
included in CRF 4D.                                    Rejected   text
Editorial comment not removed                          Accepted   Done
Persistent Organic Pollutants - what could this e.g.
include?                                               Noted
In the overview emission from legumes is
mentioend. In the text separat NH3 emission from
legumes are only included in Tier 3 approach - is                 EF for legumes now
that correct?                                          Accepted   restored

In the overview harvesting is missing                  Accepted   Harvest mentioned in 2.1.4
this appendix is missing                               Accepted
                                                                  Text already includes
Emissions occur from both soil and crops!          Rejected       crops
Reference to the chapter where they are dealt with
is missing.                                        Accepted
                                                                  Have changed data using
                                                                  updated webdab
                                                                  emissions sent by Anne
                                                                  Wagner. NMVOC
the PM10 emissions reported in the table = 0 are in               emissions are now at 4%
contrast with the sentence page 23 line 33. Does                  of total so is in contrast to
the value = 0 in the table mean that the emissions                what it said in the previous
are not estimated?                                  Noted         paragraph.
                                                                  The detail is found in the
Add more detail about processes                        Rejected   text below
add also in the heading: for EU-27                     Accepted   Done
Delete process diagram - deal with processess by
pollutant not source                                   Noted      Done
Good figure to give an overview, but maybe more
useful to describe the different emission sources                 Earlier text now restored
based on each substance.                               Accepted   as appropriate
The Emission section should be expanded and
structured according to pollutant not source.                      Earlier text now restored
Include some of the omitted text from earlier drafts Accepted      as appropriate

Needs much more scientific background                              Earlier text now restored
information on emission of NO, NMVOC and PM.            Accepted   as appropriate
explain the variables                                   Accepted   Now done
A paragraph on NO emissions is missing                  Accepted   Now inserted
appendix 4, where is it?                                Noted      Included in this version
                                                                   No longer relevant section
and soils' should be added to title                     Accepted   has changed.
                                                                   Possibly no longer
The appendices have disappeared!                  Accepted         relevant?
A paragraph on PM emissions from soil cultivation
is missing                                        Noted            Included in this version
Suggest removing the sentence "The effects of Efs
from grassland……"                                 Accepted         Now deleted

NH3 emission from growing crops are mentioned
in section 2.2.3. Are this NH3 emission short after
apllication of fertiliser included in the recommended
Tier 2 emission factors?                                Accepted   yes.
This reviewer does not understand why a double
EF for grassland is needed in comparison with
arable land. There are also arguments that the EF
for arable land is higher due to for instance the
absence of a canopy. Please give more                              More explanation now
explanation.                                            Accepted   given in text
nothing found about Pm                                  Accepted   Text restored
CAN not explained                                       Accepted   It is now
In the suggested protocol, the NH3 emission factor
for N fertilizer application to grassland is a factor 2
greater than for arable land. The higher emission
factor for grassland is based on reviews by Van der
Weerden and Jarvis (1997) and Harrison and
Webb (2001). However, the study of Van der
Weerden and Jarvis (1997) is a paper in which flux
measurements on grasslands were carried out. In
this paper, there is only one reference of a study on
arable land, i.e.. a study of Black et al. (1984) in
New Zealand in which losses from urea applied to
grassland and arable land were compared. The
paper of Harrison and Webb (2001) is a review
paper. However, they only refer to the paper of Van
der Weerden and Jarvis (1997). Thus, the
difference in the emission factor between
grassland and arable land is based on only study.
By contrast, in a review Bouwman et al. (2002) of
148 research papers it was concluded that the
mean NH3 emission from grassland is 20% lower
than for upland crops (the balanced median
showed almost no difference). This paper was not
used for the guidebook.
Thus, there is no firm scientific basis to use
different emission factors for grasslands and           Noted
why the Efs of the different fertilizers which where
reported in the old CORINAIR handbook are not
used here? The consumption of the different
fertilizers is normally available at a national level,             Tier 1 agreed with Panel
so a better estimate is possible                        Rejected   Chairs
                                                                   The EF for legumes now in
Tier 1 method for unfertilised legumes is missing     Accepted     the text

Deafault values in the body of the text and detailed
tables according to the needs as an appendix.        Rejected      Not Tier 1
According to EFMA consumption for 2006/, urea is
the third most used, after CAN and AN                Accepted      Text amended
The 3 in NH3 should be subscripted                   Accepted      Done
                                                                   Section has been re-
                                                                   written but instances of
Use chemical notation not words (e.g. for                          words rather than chemical
ammonia)                                              Accepted     notation

The unit for NMVOC is defined as kg NMVOC/kg                       Reference now made to
crop - is it kg harvest crop?? The equation (page 6,               the Appendix where more
line 7-8) is mentioned use of crop area (ha??)       Rejected      information is provided.
 A default emf of 2.57 kg NO per kg fertilizer-N
applied is presented (reference Steinbrecher et al,
2008). It seems the wrong unit is used here. If
2.57% is meant (= 25.7 g/kg fertilizer N) it is not
clear how this could be in line with the value of 0.7
% NO-N (equals 0.9 % NO/kg fertilizer = 9 g NO/kg
fertilizer) presented by Stehfest and Bouwman
(2006) and until now also presented in the
Guidebook.
The value of 0.7 is the fertilizer induced emf, but in
the former Guidebook also for cultures without
direct fertilizer (but with crop residues and indirect
emissions as a consequence of ammonia-N
deposition and N-leaching from fertilizer use) this
value is recommended to be used.                       Accepted
Why is this value presented with 2 decimal places;
this seems unrealistic concerning the high                        Nicola,please change in
uncertainty for NO measurements.                       Accepted   template to 2.6
General remark on NH3: Appendices A1-A4 are
not included, so information on assumptions is not                Appendices are now in the
available.                                             Accepted   chapter
More specific on NH3

presented for other fertilizer types than urea. For
countries where urea is not commonly used as
fertilizer and where not enough data are available
to use the tier 2 method also tier 1 emf for the
different types of fertilizer should be available. In
the former guidebook also tier 1 emf were
presented for other fertilizer types (p90 table 4.1 of
the Guidebook). It is recommended present tier 1
emf for the different types of fertilizer. This could be
the former emission factors or new tier 1 emf
derived for different fertilizer types from the tier 2
values.


0.18 NH3 per kg fertilizer N applied). Based on the
current proposed tier 2 method for urea emf the
mean value would be 0.23 (mean of lowest and
highest values for all regions and for grass and
arable land: (0.11 + 0.35)/2). For region B it should
be 0. 21 ((0.14 + 0.28)/2): What's the basis for
0.22?                                                 Rejected
On basis of table 3-1 in the proposed Guidelines it
is unclear whether the proposed PM10 emission
factor should only be applied to arable land or also
to grassland (at the presentation in Dublin also hay
making was mentioned; this seems to refer to
grassland) and whether the application of fertilizer
and pesticide use is included. It is recommended to
make this clear.                                     Noted
The basis for the presented TSP, pm10 and pm2,5
emf (Table 3-1) should be the reference publication
Vd Hoek and Hinz (2007). However, this basis
cannot be found there:


in the Reference publication it seems that for pm10
the highest value (eg 4.56 kg pm10/ha for oat with
no reduction applied of for redeposition of pm10 on
the field) is picked to be used as a default for pm10
(4.5 in Table 3-1). However, this is not clearly
explained and some questions rise if this is the
case:
-Why is the average value of 0.25 (for soil
cultivation) in Reference Table 3 (and discussed in
the text on page 18) not in line with the figures on
soil cultivation presented in Table 2? Here even
with wet soil conditions the total pm10 emf for soil
cultivation is 5,2 kg/ha. That's a factor 20 higher!
-Why is no correction term applied for rapid near
source deposition?
-Why are the harvesting emf in Table 3 lower
(between 2.0 and 3.4 kg pm10/ha) compared to the
values presented in the text on p 18 (lowest value
3.3; highest 6.9).
-What's the basis for the values for cleaning and
drying in Table 3
                                                        Accepted

The reference publication (vd Hoek & Hinz, 2007)
mentioned is not easily attainable; I had to
approach one of the authors to get it. On basis of
the reference it seems hay making is not included.
Fertilizer use seems to be included, but it is not
clear. Pesticide use is not included. It is
recommended to make the references available.      Rejected
A revision of the guidebook should include the
newest knowledge and lead to more accurate
inventory. I was surprised that the NH3 Tier1
methodology is simpler than given in the old
guidebook and the emission factor is only based on
use of urea.                                       Noted
No equation for Tier 2 methodology?                Accepted        Equation now restored
Equations and legends: inconsistent notation, not
in line with IUPAC                                      Noted      done
In tables 3-1 to 3-14 emission factors for NH3 are
presented for the different fertilizer types. It
suggested that these emission factors are all
derived from Harrison & Webb (2001) and Van der
Weerden and Jarvis (1997). However, the
quantification of the effects of temperature and pH
on the emission factors is not found in these
papers.
In the review paper of Bouwman et al. (2002)
effects of crop type, fertilizer type, application
mode, N application rate, temperature, pH, and
other soil properties on NH3 emission are
statistically assessed. This paper maybe a valuable
source for the guidebook.
Reference: Bouwman et al. (2002) Estimation of
global NH3 volatilization loss from synthetic
fertilizers and animal manure applied to arable
lands and grasslands. Global Biogeochemical
Cycles 16.                                              Rejected
Please indicate clearly in the text that the NH3
emission = 17/14 * EF.                                  Noted
The NO emission is 2.57 kg NO per kg fertilizer N
applied. This means that more N is lost than the N                 The EF should be g/kg -
input by the fertilizer. This is quite impossible                  Nicola, can you please
because about 50% of the N fertilizer is taken up                  amend in the template
by the crop                                             Accepted   table.
It is necessary to explain in the text how the EF for
TSP, PM10 and PM2.5 are derived. If necessary
the reviewer will assist.                               Noted

limiting fertilizer to urea only is a step backwards    Accepted   New Tier 1 EF developed

I do not agree with the use of the urea EF as the
default EF. The previous approach in the simpe
methodology in the old Guidebook should be
maintained. Even though the use of urea according
to world fertiliser consumption statistics is currently
approx 50% of total N consumed, it does not
warrant its use as the default. Many counties use
urea only in the spring when weather conditions are
wet and cold and therefore emissions are low.
Using urea as a default in such circumstances
would lead to a gross over estimation of emission
levels.                                                 Accepted
Unit for particulates should be kg ha-1 a-1.            Accepted   Done
at which depth the soil temperature has to be                      Text amended to make
measured?                                               Accepted   clear it is air temperature

More explanation on how to use and apply new
proposed EF is needed as done also in tier2 4B.         Rejected
Tier 2 equation is missing                       Accepted          Done
Tier 2 emissions should be calculated using the
actual spring temperature. Replace equatoin and
the original compact version of equation
parameters. Example emission factor tables could                   Original compact table now
be put into an appendix                          Accepted          restored

It is a bit confusing with so many tables showing
the emission factor for Tier 2 - mineral fertiliser. Is
it possible to reduce the number of tables? Instead
of a table for each fertiliser type, it could be chosen
to show a table from each temperature region A, B
or C (t >13 C, T=6-13 C or t < 6 C).                    Accepted
Tables are confusing and should be presented in a                  Concise tables have been
condensed form.                                         Accepted   restored.

                                                                   Yes, but this explains how
Controlling emissions has already been covered on                  account may be taken in
p 4 and 5                                         Rejected         calculating emissions
Using AN instead of urea may reduce The NO                         Abbreviation now defined
emission. Definition of AN??                      Accepted         at first point of mention
abatement without note with PM concern            Accepted         Text restored
                                                                   Text changed, no longer
Activity without concern of PM, area treated, yields Rejected      relevant
                                                                   This section has been
section 2.1.1 where is it?                            Accepted     added

                                                                   In this specific case expert
The sentence on expert judgement is not related to                 judgement may be needed
consisten time series, maybe more to Uncertainty Rejected          for a consistent time series
                                                                   This is the agreed format
It is not necessary a specific chapter 4.5.1, put the              for each Guidebook
sentence under line 21                                Rejected     chapter
soil N content: where is it used?                     Accepted     Now deleted
Is the mentioned uncertainty range (+-50%) for all
substances exept from NMVOC? The uncertainty
range for NO and PM emission is properly much
higher?                                               Rejected

To explain the differences between the default
value and tha national value, a robust bacground
information and documentation for the default
value is needed. Otherwise you do not support and                  Don't understand the point
promote the meber states to use national values.    Accepted       that is being made
is the temperature, which is necessary for tier 2,                 Air temperature now
the air or the soil temperature?                    Accepted       specified in the text
IFA - please write the name of the organisation
(maybe in chapter 5 "Glossary"). Are data from this
organisation available for all member states for                   Now given in full in the
free??                                              Accepted       reference list
                                                                  The references have now
The reference list include a lot of references which              been sorted following the
is not mentioned in the main text. I prosume this list            various revisions of the
include the references from the appendices!            Accepted   text.
                                                                  Citations were consistent
                                                                  in that two authors used
                                                                  "and" and more than one
Citation inconsistent (e.g. "and")                     Accepted   author was bloggs et al
For NO the reference Stehfest and Bouwman
(2006) is included in the references (however                     Spelling in reference list
misspelled as Stefest and Bowman), but not                        corrected and relevant text
mentioned in the text.                                 Accepted   restored
Missing Appendix A! There are links to this a
couple of places. It‟s hard to judge references to
activity data when the appendix is missing.            Accepted

Deafault values in the body of the text and detailed
tables according to the needs as an appendix.        Accepted     Not Tier 1

By reading of the draft I really missed the
appendices - especially because the main text
does not content many references or scientific
explanations. At my point of view more specific
scientific description and explanation is needed in
the main chapter. It is very important to know the
scientific documentation for the default value.The
guidebook should not only be useful to calculate
the emission inventory,but also a guideline to find
more scientific information to check the conditions
are comparable with the conditions in the member
states and to encourage member states to
continue the work to develop more accurate
inventory with national data.                          Accepted
That each answer max can be 255 characters is
very frustrating                                       Noted

Deafault values in the body of the text and detailed
tables according to the needs as an appendix.          Noted      Not Tier 1
No guidelines available?                               Rejected   No page reference given
It is rather strange to find an NFR 4D2 here (animal
production) since this source is not included in
NFR4D but in NFR4B                                     Rejected   No page reference given
Inconsistent citation of references.                   Accepted

To my knowledge is there no EU-regulation on agr.
waste burning, only national legislation. This should
be verfied. The text indicate that it is very easy to
burn agr. crop residues and waste in Denmark.
This is not the case. Burning of plant residue has                We know, the object was
been prohibited i Denmark since 1990 and may                      to point out that under
only takes place in connection with continuos                     some circumstances
cultivation of seed grass.                            Noted       burning may take place
AR is not defined                                      Accepted   Done
Couldn‟t the link to “FAO Production Yearbook                     Yes, up-to-date reference
(FAO, 1991)” be updated?                               Accepted   given

                                                                  J - should there be any Efs
EF for NH3 missing from table                          Accepted   for NH3 in this chapter?
                                                                  Yes, up-to-date reference
A source published in 1991 is inadequate.              Accepted   given

                                                                  The comment specifically
Table 3-1. There should not be different units in a               refers to agricultural
table, ie.kg/ kg dry matter and kg/ tonne. It will give           activity data, so reference
errors in the reporting                                 Noted     to forest fires is irrelevant

Table 3-1. There are errors in the data. Generally
contains crop residues (straw) 0,3% N or eqv. to
1.2% NOx after burning if all N is emitted as NOx.
Tier 1 indicates that 24% is NOx or that at lot of                Because they are not
inert N2 is conveted to NOx.                           Noted      needed for the calculation
If default N/C ratios are given in the IPCC
guidelines why aren't they included in table 3.2
which have the same origin?                            Noted
Tier 2 does not appear to provide the basis of
better estimates than Tier 1. Remove Tier 2            Noted
                                                                  J - have changed this in
Default data is not taken from IPCC 2006 but from                 track changes, is this the
IPCC GPG 2000                                     Accepted        correct reference?

The source data is taken from IPCC guidebook,
GPG 2000 and not from IPCC 2006. Crop/crop
residues has been changed very much from GPG
2000 to IPCC 2006. See Table 11.2 i the new
guidelines for data. GPG 2000 is not appropriate
for European conditions.The authors of these
UNCEC-guidelines should read Strehler and
Stützle. The paper is about utilisable biomass and
not field burning and based primarily on conditions
in the praerie in the US.The figure should be used
vith caution especially under European conditions
where there is other crop/crop residue ratios due to
high fertilisation rates.                              Accepted
Three years average should not be used if we want
to model the emissions in short time spans. Should
then forest fires be averaged over three years too?
Averaging is not in line with the new IPCC
guidelines                                             Noted
Where is nitrogen mentioned?                           Noted
Souce in not in the table                              Accepted
Tables should be combined. Omit superfluous
information.                                           Noted
The value is app. the same as for Tier 1, but now it
is in g/GJ not in kg/kg dry matter. See my comment                Changed back to kg/kg dry
page 4 line 1.                                       Editorial    matter

Three different Units are used for the same source                Changed back to kg/kg dry
(wheat straw). This is also true for the other tables Editorial   matter
                                                                  I can't see what this person
Table 3.2 is dublicated                               Rejected    is talking about

Why should Tier 3 be aggregated at a sub-national
scale to fine grid scale if the data/model is superior.
It is a direct copy from IPCCC 2006 and maybe not                 The chapter was based on
valid for UNECE conditions.                             Noted     the information available
General: The chapter gives an impression of lack
of agricultural knowledge and is more or less a                   No, I sourced the data
copy and paste of the IPCC guidelines                   Noted     from 2006
                                                                  My mistake, in converting
The mentioned cases in the text are seldom, and it                from %, these EF are all
is very difficult to burn rotten straw, so the                    x10 too big. Can you
importance is very limited.                        Accepted       please reduce
Incorrect SNAP                                     Accepted

This statement is indeed very surpising given that
many pesticices are considered as POPs (where
agriculture use is the only source). Please properly
explain POPs in the context of this chapter            Noted
NFR category include SNAP 1006 "Use of
pesticides and limestone" - but in the text
"overview" is mentioned that this sector ia a "catch
all" for the agricultural sector. So this NFR category
covers more than SNAP 1006. In the Danish
inventory this sector covers sewage sludge, which
are used as fertiliser and applied on agricultural
soils.                                                 Noted
For use of pesticides no method is provided. New
methods are available in the Netherlands and the
EU which could be refered to: Nie (2002), Linden et
all (2006), and Linden et all (2008; in preperation)

Nie DS de (eds), 2002
Emissie-evaluatie MJP-G 2000; Achtergronden en
berekeningen van emissies van
gewasbeschermingsmiddelen
[ Emissions of plant protection products to the
environment. Evaluation of the policy goals of the
Long-term Crop Protection Plan ]
RIVM Rapport 716601004

Linden AMA van der, Beelen P van, Berg GA van
den, Boer M de, Gaag DJ van der, Groenwold JG,
Huijsmans JFM, Kalf DF, Kool SAM de, Kruijne R,
Merkelbach RCM, Snoo GR de, Vijftigschild RAN,
Vijver MG, Wal AJ van der
Evaluatie duurzame gewasbescherming 2006:
milieu
[Midterm evaluation of the plant protection policy of
the Netherlands; environment ]
RIVM rapport 607016001

In preperatation
Linden AMA van der, Groenwold JG, Kruijne R,
Luttik R, Merkelbach RCM
Dutch Environmental Indicator for plant protection
products, version 2
Input, calculation and aggregation procedures
RIVM Report 607600002/2008                              Noted
Chapter should be supplemented: now in contains
headings, one table without EF, one literature
source.                                                 Noted
The chapter is incomplete.                              Noted
Add: "Also PM emissions from waste handling are
generated but no estimate of emission factors is
available."                                             Accepted   Done
add ", NH3" after "CO"                                  Accepted   Done
Add: "Also PM emissions from waste handling are
generated but no estimate of emission factors is
available."                                             Accepted   Done
substitute "very minor" with "minor"                    Accepted   Done
add ", NH3" after "CO"                                  Accepted   Done
An incomplete and unexplained algorithm is given
for emissions from pulp and paper only?                 Accepted   Corrected
why process emissions from pulp and paper in this
connection ?                                            Accepted   Corrected
too less explanation, only reference to GHG             Noted
substitute "Emissions are considered to be
negligible in most cases." With "Small quantity of
NMVOC and nitrate compounds are emitted. For
NMVOC US EPA evaluate that 98,7% of landfill
gas is methane and 1,3% other VOCs such as
perchloroethylene, pentane buthane, etc. (EPA,
1990). Also PM emissions from waste handling are
generated but no estimate of emission factors is
available."                                        Accepted       Done
change position of NH3, TSP, PM10 and PM2,5 in
"not estimated" section                            Accepted       Done

no emission factors estimated or applicable. Not                  NMVOC estimated now
even for NMVOC and CO ...I miss some support.          Noted      from UK inventory
US EPA (1990), Air Emissions Species Manual,
Volume I; Volatile Organic Compounds Species
profiles, Second Edition, EPA-4502-90-001a,
United States Environmental Protection Agency,
Office of Air Quality Planning and Standards,
January 1990                                           Accepted   Added to references
An estimate of NMVOC emissions from landfills
was made using an emission factor of 0.01 t
NMVOC/ t methane produced which is equivalent
to 5.65g NMVOC/ m3 landfill gas (UK inventory,                    EF used as Tier 1 default
2004).                                                 Accepted   EF
EF should be defined depending on the kind of
waste deposited                                        Noted
                                                                  Chapter discussed in
                                                                  meeting with C&I Expert
                                                                  Panel Leader. Latrines
                                                                  moved to Tier 2. Tier 1 EF
Chapter should be supplemented: now it contains 2                 for NMVOC estimated
tables, including one table with one emission factor Consult with from one of the suggested
(for NH3) and list of References with 2 sources.     Expert Panel papers.
The chapter is incomplete. See examples below        Noted

An aspect of importance not described in this
chapter is the importance of industrial effluents to
the sewer system and i.e.contribution to the                      NMVOC from WWTP
centralised WWTPs and i.e. NMVOC emissions.            Accepted   mentioned
NMVOC emissions may occur during sewage
collection and are very dependent upon treatment
processes at different stages at the WWTPs (see                   Some text about this issue
refs row23-35))                                        Accepted   has been added
The chapter states that it focusses on biological
treatment plants, however, the text deals in no                   Text taken from former
detail with biological processes and                              GB; adapted to fit better in
dephosphorization is a chemical process                Noted      revised chapter
The chapter states that 'NMVOC and NH3 is of
minor and only of local importance' as compared to
landfills where these emission are referred to as
'emitted in smal quantities'.                          Noted
From the Inventory of U.S. Greenhouse Gas
Emissions, however, it may be observed that the
emission of NMVOC from wastwater treatment
processes are a factor two of the estimated                          Information on NMVOC
emisions from landfills; ranging from 57 to 68 Gg/yr                 added; see other
in 1990 and 2001.                                    Noted           comments
The text on latrines
(http://reports.eea.europa.eu/EMEPCORINAIR4/en
/B9107vs2.1.pdf) are overpresented compared to
section 2.1 considering the relevance of the two
activities                                           Noted
change position of NH3, and NMVOC in "not
estimated" section                                   Accepted
                                                                     Done following discussions
Erase NH3 EF and related information and change                      with C&I EP. A Tier 1 for
position of NH3 and NMVOC in "not estimated"                         NMVOC has also been
section                                         Accepted             derived

I don't think the similarity of latrines with animals
was correct and then latrines are not equal to
"waste water treatment plants". Substitute "The
default emission factor for ammonia from waste
water handling is provided in Table 3-1. It is equal
to the estimated emission factor for ammonia from
latrines, which has been determined from the
similarity between latrines and open storage of
animal manure in lagoons or ponds (Guidebook,                        Done following discussions
2006)." with "Also NH3 and NMVOC emissions                           with C&I EP. A Tier 1 for
from waste water handling are generated but no                       NMVOC has also been
estimate of emission factors is available."               Accepted   derived
Air emissions of POPs as well as NMVOCs, CO
and ammonia are occurring eventhough maybe at
insignificant levels, still not very well investigated.              Some info added to
However some scientific studies do adress such                       chapter; see earlier
emissions.                                                Noted      comments
Examples from the scientific literature documenting
such emissions of aromatic and halogenated                           Some info added to
compounds from urban WWTPs are Sree et al,                           chapter; see earlier
2000                                                      Accepted   comments
Oskouie,A.K., Lordi, D.T., Granato, T.C. and
Kollia, L. (2008). Plant-specific correlations to
predict the total VOC emissions from wastewater
treatment plants.Atmospheric Environment, In                         Some info added to
Press, Corrected Proof, Available online 13                          chapter; see earlier
February 2008.                                            Noted      comments

Baillod, C., Crittenden, J.C., Mihelic, R., Rogers,
T.N., Grady, C.P.L., 1990. Critical evaluation of the
state of technologies for predicting the transport
and fate of toxic compounds in wastewater                            Some info added to
facilities. WPCF research Foundation Project 90-1.                   chapter; see earlier
CAAA. U.S. EPA, 1990.                                 Noted          comments
Corsi, R.L., Card, T.R., 1991. Estimation of VOC             Some info added to
emissions using the Baste model. Environmental               chapter; see earlier
Progress 10 (4), 290.                               Noted    comments
Dobbs, R.A., Wang, L., Govind, R., 1989. Sorption
of toxic organic compounds on wastewater solids:
correlation with fundamental properties.                     Some info added to
Environmental Science and Technology 23 (9),                 chapter; see earlier
1092.                                               Noted    comments
Easter et al.. Odor and air emissions control using
biotechnology for both collection and wastewater
treatment systems. Chemical Engineering Journal,             Some info added to
Volume 113, Issues 2-3, 20 October 2005, Pages               chapter; see earlier
93-104                                              Noted    comments

Escalasa et al. Time and space patterns of volatile          Some info added to
organic compounds in a sewage treatment                      chapter; see earlier
plant.Water Research 37 (2003) 3913-3920            Noted    comments
In urban areas, VOC emissions from WWTPs may                 Some info added to
be a significant fraction of the total hydrocarbon           chapter; see earlier
emissions                                           Noted    comments

whereas the corresponding NMVOC emissions                    Some info added to
from whole Austria were reported as 5% (25000 t              chapter; see earlier
yr) of the total anthropogenic NMVOC emissions.      Noted   comments

more focus should be given to Urban wastewater
treatment plants and separate industrial                     Some info added to
wastewater treatment plants.(see references as               chapter; see earlier
commnt to list of reference below, page 6 line 8)   Noted    comments
According to the IPPC guidelines such releases
into the domestic sewer system should be included            Some info added to
in the 'Waste water treatment in                             chapter; see earlier
residential/commercial sectors'.                    Noted    comments
Air emissions of NMVOC prevails in pre-treatment
and primary clarifiers, whereas biodegradation and
sorption compete in aerobic biological reactors...
Air emission prevails in secondary clarifiers (e.g.          Some info added to
Escalas et al. 2003, Water Research 37,                      chapter; see earlier
3913–3920).                                         Noted    comments

Most plants have highly techological developed
primary, secodary and tertiary treatment processes
including mechanical, chemical, biological                   Some info added to
anaerocic and aerobic processes and emission                 chapter; see earlier
may occur at several stages of treatment.          Noted     comments

Reference for inspiration: P. Tata, J. Witherspoon
and C. Lue-Hing, Editors, VOC Emissions from
Wastewater Treatment Plants: Characterization,               Some info added to
Control and Compliance, Lewis Publishers, Boca               chapter; see earlier
Raton, USA (2003) ISBN 1-56676-820-9, p. 415         Noted   comments
BOD characterisation , which is the main source for
NMVOC emission, is totally missing in analogy to                 Some info added to
the missing precess descriptions which are                       chapter; see earlier
potential for NVVOC emissions as well as POPs.      Noted        comments

Reference for statements in row 26 to 28: Atasoy
et al. (2004).The estimation of NMVOC emissions                  Some info added to
from an urban-scale wastewater treatment plant.                  chapter; see earlier
Water Research,Volume 38, 3265-3274                Noted         comments
latrines are not relevant at all for many European
countries                                          Noted
NMHC or non-methane VOC may occur for
controlled as well as uncontrolled aeration
processes.                                         Noted

Sree, U., Bauer, H., Fuerhacker, M., Ellinger, R.,
Schmidt, H. and Puxbaum, H. (2000).
Hydrocarbons Emissions From A                                    Some info added to
Municipalwastewater Treatment Pilot Plant In                     chapter; see earlier
Vienna. Water, Air, & Soil Polution, 124, 177-186    Noted       comments

Schmid, ´H., Bauer, H., Ellinger, R., Fuerhacker,
M., Sree, U. and Puxbaum, H. (2001). Emissions of
NO, TVOC, CO2, and aerosols from a pilot-scale                   Some info added to
wastewater treatment plant with intermittent                     chapter; see earlier
aeration Atmospheric Environment, 35, 1697-1702.     Noted       comments
Wua, B.-Z., Fenga, T.-Z., Sreea,U., Chiuc, K.-H.
and Loa, J.-G. (2006). Sampling and analysis of
volatile organics emitted from wastewater
treatment plant and drain system of an industrial                Some info added to
science park. Analytica Chimica Acta , 576, 100-                 chapter; see earlier
111                                                  Noted       comments
For example, NMVOC contribution from WWTPs in
Vienna, as an urban area, was estimated to be                    Some info added to
around 7.5% of the total anthropogenic NMVOC                     chapter; see earlier
emissions …                                          Noted       comments
Glossary, AR production - the AR for the lime
production?                                          Accepted    Corrected

Tables 3-1– 3-6: HCB and PCB emission factors
are the same (in spite of the abatement); NOx, CO                Differences in abatement;
and SOx EF are not harmonized, as well as TSP.                   literature references are
For example: TSP EF in the Table 3-1 (Tier 1) is                 not complete. This causes
the same with EF in the tables 3-4, 3-5 and 3-6   Consult with   differences. How else to
(Tier 2, different abatement, including BAT).     Expert Panel   deal with this???

Table 3-1. According to the UNEP Toolkit PCDD/F
EF value of 0,525 mg for the high control       Consult with
equipment efficiency                            Expert Panel
Table 3-2. PCCD/F EF is 40 mg I-TEQ/Mg waste.
There is no contrudictions in values of these two      Consult with
tables?                                                Expert Panel
Abetment factors are derived from EPA not
controlled/controlled EFs. These abetments cannot
be used for Table 3-6 EFs, related to EU BAT
technologies . Also dioxins abatement table is not
present in the text and is related to unabated EF                     Corrected; abatement
different from Table 3-6 one. Please introduce                        factors only applicable to
unabated EFs or all the pollutants or erase the                       EPA factors in Tables 3-2
entire chapter!                                        Accepted       and 3-3!
Error of table 3-9                                     Accepted       Corrected
Table 4-1. It is correct PCDD/F emission factor unit
- mg/Nm3?                                              Accepted       Corrected
Are emissions from flared landfil gas (the part of
the gas not used for energy purposes) missing?         Consult with
Norway reports these emissions under 6C                Expert Panel
Industrial waste is extremely heterogenous group                    No new info available,
with very different levels of emissions from their                  therefore addition of more
combustion. But in the chapter industrial waste                     Tier 2 methods could not
considered without differentiation even at Tier 2      Consult with be done. Issue has been
level. Chapter should be supplemented.                 Expert Panel discussed with C&I EP.

Figure 2-1: scheme is too simplified.              Rejected
Change "Much of the information on pollutant
emissions has been reported as emission
concentrations rather than emission factors. These
have been converted using a specific flue gas
volume of 5000 m3 at 11% O2 per tonne of waste.
" with "Emission factors for heavy metals are
assumed to be the same as for clinical waste
incineration."                                     Accepted           Done


Table 3-1: EF for TSP and PM seem very low; EF         Consult with
for Pb, Hg and Zn are higher than EF for TSP.          Expert Panel
Data are from Table 8.2.2 of old GB and are
assumed to be the same as for clinical waste
incineration Use the same EFs of Tier 1 in Table
3.1 Replace the chapter with "Technology specific
emission factors are not available for this source     Consult with
category. "                                            Expert Panel
Table 3-2 (Uncontrolled): PCDD/F, HCB, PCB and
PAH emission factors are the same as in the
Table 3-1 (Tier 1 – typical situation) but TSP and
HM emission factors are more high. EF for
PCDD/F – need to be updated (UNEP Chemicals
Standartized Toolkit, 2005 might be for instance       Consult with
used).                                                 Expert Panel
Table 3-3: TSP and PM emission factors seem to
be overestimated.                                      Noted
Table 4-1: PCDD/F emission factor – error in units. Accepted            Corrected

Figure 2-1: scheme is too simplified.                    Rejected
Tables 3-1, 3-2 should be updated, for instance
EF for PCDD/F from the UNEP Chemicals
Standartized Toolkit (2005).                             Rejected

Tables 3-1 (Tier 1) and 3-2 (Tier 2) were not
harmonized: EF for PCDD/F, HCB, PCB and PAH
compounds are the same while EF for TSP and
HM are more high in Tier 2. If Tier 2 factors are the
same as Tier 1 what are the reasons to include in Consult with
the chapter choice of methods procedure?              Expert Panel
NO TABLE ?                                            Rejected

Tables 3-4 – 3-16 which are shown as Tier 3 tables
can be hardly considered as Tier 3: they are out-of
date (main reference - EPA 1995) and do not
provide emission factors for complete list of       Consult with
installations and types of wastes.                  Expert Panel

Table 4-1: PCDD/F emission factor – error in units. Accepted            Corrected
There are still only default emission factors for
priority metals. No emission factors for other
metals are included.                                Noted

Waste incineration could potentionally be a large
emission source of the other metals therefore            Consult with
guidance on these metals should be included.             Expert Panel
Table 3-1: emission factors need to be updated           Noted
It should be possible to provide some rough
guidance on the particle size distribution, so that
PM10 and PM2.5 can be estimated.                         Accepted
Chapter should be supplemented: it include only
Open burning of agricultural wastes, while other
types of open burning are also important source of                      Link to more detailed
emission especially POPs.                                Noted          methods of AP42 inserted

Tables 3-1– 3-10: error in unit for PM10. Emission
factors for PCDD/F need to be updated.                   Accepted       Corrected
Table 3-4: title of the table do not coincide with the
content (Orchard crops – in the title; Leaf Burning –
in the table).                                           Accepted       Corrected
Chapter should be supplemented: now there are 4
tables with one EF for NH3. No references.               Noted
Figure 2-1: Process scheme consists of one box
and three arrows and do not provide any                  Consult with
information about the processes.                         Expert Panel
Table 3-1 (Tier 1) and Table 3-3 include the same
NH3 EF for compost production.                           Noted
Table 3-2 (Tier 1) and Table 3-4 (Tier 2) include
the same NH3 EF for sludge spreading.                Noted
lots of EF seem to be missing, for ex. NMVOC or
total PAH                                            Noted
original references should be named (not
Guidebook 2006)                                      Rejected

Data are the same as Tier 1. Replace the chapter
with "Technology specific emission factors are not
available for this source category. "                Accepted   Done
Are emissions from car and house fires missing?
See EF_Comments                                      Noted
Are emissions from tobacco missing? See
EF_Comments                                          Noted
No emission factors for PM, HM and POPs.             Noted
Comments
The contractors and indeed many of the individuals in
the project team have many years experience in
support of inventories and combustion emissions. If
this is an unsupported comment it is neither
constructive nor factual.
The factors represent a wide range of technologies, for
most pollutants there will be varying degrees of
abatement and in some instances the factors could
represent unabated emission. In terms of an emission
inventory the key issue is whether they can represent a
national emission. At Tier 1 and Tier 2 inclusion of
factors for specific abatement technologies is
achievable but would require many tables and is
considered inappropriate.


Inlude HCB and other POPs



 Note that 1B2a.iv covers fugitive releases from
refining, venting and flaring from oil-refining are 1B2c
& d respectively.




Covered by next comment


Text and indeed emission factors from the previous
chapter could be included as an appendix but including
the whole chapter is not appropriate. Where the
expert panel feels that more text would be helpful then
I propose to ask them to determine what should be
included (as an appendix).




I accept that more detail can be provided but it is
intended as general information only - we can go into
detail but there is information elsewhere such as the
LCP BREF.
Firetube boilers more typically at sizes lower than 20
MWth.
text in prentheses modified to state 'mainly relevant to
solid and liquid fuels'. Gaseous fuels can contain
nitrogen compounds but natural gas contains nitrogen
as N2 other nitrogen compounds are only present at
trace levels (compared to biomass, coal and fuel oil).
Some emission factors are high but whether they are a
large emitter depends on overall technology mix. This
section is about formation of Nox in general rather
than for different technologies).




As taken from the previous guidebook. Please note
commentary elsewhere on mercury in gas.


The text was in the original guidebook but may have
been contrary to the guidebook EF which was omitted
in compilation. Guidebook factor has been restored.


Much of the detail in the current chapter is not relevant
to someone preparing a national inventory. The BREF
provides relevant data.

As stated in the introduction to 3.3 details are in the
BREF. Inclusion of SO2, NOX but not PM is not
consistent but it reflects the original guidebook where
PM controls were considered, as commented, with
heavy metals controls.



Abatement efficiencies are indicative only - efficiencies
are dependent on a range of factors and emission
reductions, particulary for retrofit applications, are very
variable.




Generic text, note that it is not just about emission
data; more detailed approaches may also need to
address fuel use.


Yes, 'all' is unlikely and there will always be new data
to consider.
Yes, 'all' is unlikely and there will always be new data
to consider.




The technology used will differ for each country and
will change over time. A representative factor for all
users is not achievable, these factors provide a first or
second level estimating tool for the sector.
Yes, 'all' is unlikely and there will always be new data
to consider.

Note this also applies to 'other liquid fuels' which
includes refinery gas - these are NAPFUE
classifications.




European PCDD/F data ?




Guidebook factor missed, also data in Ap-42.




An oversight, technology identified but failed to include
table




We accept that combustion emissions can depend on
combustion unit size but, there has to be a degree of
simplification otherwise the number of tables becomes
unmanageable.




Asked for European-based data.
Dry and wet bottom boiler classifications are as used
in current guidebook but it is recognised that these are
not the only technology distinctions




Abatement efficiencies are dependent on a range of
factors and reductions, particulary for retrofit
applications are very variable.

These dsitinctions are not in current guidebook but are
in AP-42 and are reasonable distinctions for unabated
plant (with downfiring as a potential additional
technology). However, these technologies are less
relevant for new and abated plant.
The factors do not represent a specific level of
emission control, where countries have knowledge of
abatement levels then this knowledge should be used
to develop appropriate country-specific emission
factors.




Some inconsistencies - incorrect mapping of some
factors in database ?




Some inconsistencies - incorrect mapping of some
factors in database ?



Where Tier 2 and Tier 1 defaults are the same then we
don't have data to provide a Tier 2 factor and have
included Tier 1
See previous comment



Where there no data to provide a Tier 2 factor, we
have included Tier 1 data




It was not the intent




The work by Concawe is referenced and tables have
been revisited to incorporate relevant data

Have taken out this table




Is this correct?




Note that Concawe references are generally to USEPA
see other comments on Concawe data




Is this right - perhaps one for Justin/Tinus
The terminology used is not ideal but combustion unit
would not be appropriate either (it could be used to
describe engines, gas turbines, conceivably flares).
Suggest process furnace may be more appropriate.




In general this is correct but there are significant
ranges which indicate that some abatement measures
are present.




see other related comments




see other related comments




see other related comments
We accept that the emission is dependent on fuel
composition but combustion and lubricants are also
relevant. We also accept that USEPA VOC figure also
excludes ethane however, in the absence of other
data, it provides a reasonable value for nmVOC. An
alternative would be to apply the the USEPA TOC
figure. At least one member state applies an emission
limit for formaldehyde but inventory is about total
nmVOC not individual components.




see other related comments




see other related comments


Not sure what table this refers to but tables revised
Title modified but, we have no data for other activities




The completeness or othewise of facility emission
reporting is a key issue but is not unique to refineries.
Further guidance is provided in cross-cutting chapters.




Can the expert panel provide any further input on coke
manufacture outside iron & steel plant or other
manufactured solid fuel processes
See row 57




see above
I think this may be a timing issue, FOD may have been
completed shortly before document finalised




Where the references are for AP42, the dates refer to
the chapter dates rather than the current edition.



Calculated with reference to USEPA Method 19




Add a footnote ?
Done
See earlier notes re engines

Not at Tier 1 but is needed at Tier 2
Not clear what this comment is about




2B


Yes (for combustion)
Note that emission is not generally associated with
combustion processes in 1A2 and may be assigned to
the process emission




See 133
Where we have broadly similar fuels we have provided
the same emission factors rather than provide no
factors


Yes, this is correct but the Tier 1 and Tier 2 default
factors are for application to a wide range of
technologies with aggregated activity data. The
compexity of individual furnace fuel mix is more
consistent with a Tier 3 approach.
see above


see above




Actually table revised




See 169




The table titles were incorrect, these factors are for
heating/reheating
These are assigned through NFR 2 emission guidance



See earlier
Yes, this would be impossible.




Emissions should not be included in 1A1
Use tier 1




However note that for cement the Tier 2 tables will
include all emissions except PM



Not possible according to editorial requirements.
However such data can be found in BREF documents




Petcoke is a fuel but by no means the major fuel in all
countries
In general PCDD/F emissions are not increased by
use of waste in cement kilns (if applying BAT)




In the absence of facility-specific data or specific fuels
then use Tier 1
Yes, other liquid fuel includes gas oil
metals should be assigned to process.




At Tier 1 we have brought together by main fuel
classifications
Text and tables now modified to reflect discussion with
EP leader
Suggest applying same factors as for coal in cement
kilns




see above
update




include especially the last suggestion


rejected


could be improved
There are some errors: e.g. we should divide
emissions by LTO and Cruise not by take off and
landing; it could be improved
In my view default EF should refer only to IFR flight




see the comment above (row 38)




see the comment above (row 38)
see the comment above (row 38)




I agree with the comment. In Tier 2 it is not sufficient
clear how to estimate cruise emissions (domestic and
international): the suggested methodology could be
reported with a complete example (taking in account
an average domestic and international distance for the
country).In my view data needed for the Tier 2 are n°
of flight by type of aircraft and by
domestic/international; total fuel consumption (if
possible domestic and international separately);
average national distances for domestic and
international flights. So the first step should be to
estimate LTO fuel consumption for domestic and
international, and cruise fc for domestic on the basis of
tables 3.11, 3.12 and 3.15. International cruise fuel
consumption should be calculated anyway by
difference with the total FC in the energy balance. Step
3 probably is the first step, step 4 the second one and
step 1 and step 2 are a results of the method. In my
knowledge no countries have information n fuel
consumption distinguished by domestic and
international; also Tier 3 methodologies, as Pagoda
model by EUROCONTROL, estimated the fuel
consumption on the basis of the distance of the flights




I disagree with the comment in general; if the IPCC
2006 guidelines report new emission factors before not
available in my view they should be used
It is correct, emission from military mobile, including
aviation, are reported in 1A5B with exception for those
referring to multilateral operation that shoul be
reported in memo items
It could be useful to describe the Tier 2
Done




Equation is correct as it is
will clarify

will clarify


will check and clarify units need correcting


will check and clarify units need correcting
will clarify


Will be clarified
will check and clarify units need correcting and linking
to EF tables.
will check and clarify units need correcting and linking
to EF tables.
will correct
will check and clarify units need correcting and linking
to EF tables.

will correct


will correct

Need to add EFs where appropriate
Need to add EFs where appropriate

Will incorporate where appropriate to the tier
methodology or reference given to detailed datasets.

Will incorporate where appropriate to the tier
methodology or reference given to detailed datasets.
Will incorporate where appropriate to the tier
methodology or reference given to detailed datasets.




Will incorporate where appropriate to the tier
methodology or reference given to detailed datasets.




Will incorporate where appropriate to the tier
methodology or reference given to detailed datasets.




Will incorporate where appropriate to the tier
methodology or reference given to detailed datasets.

Will incorporate where appropriate to the tier
methodology or reference given to detailed datasets.

Units will be added.




Will clarify

Will clarify
Will add
Will incorporate where appropriate to the tier
methodology or reference given to detailed datasets.

Will clarify
Will clarify




Will incorporate where appropriate to the tier
methodology or reference given to detailed datasets.
Will be redrafted to fit with Guidebook and reference
made to IPCC 2006
Will clarify
Will add




Will add




Will add


Will clarify



Will review

Will update
Will update




Will update




Will update


Will update

Will incorporate where appropriate

Can't find any later data on ship fleet make up.
clarified


Will include originals




Will update




Will update

Will update

Will update


Need clarifying


Will incorporate where appropriate


Will incorporate where appropriate


Will incorporate where appropriate


Will incorporate where appropriate

Will clarify reference

Will clarify reference

Will clarify reference

Will clarify reference

Will include reference

Will clarify reference
Will clarify reference

Will clarify reference

Will clarify


Will clarify

Will clarify


Will clarify

Will clarify reference

Will incorporate where appropriate


Will incorporate where appropriate

Will incorporate where appropriate


Will incorporate where appropriate




Will incorporate where appropriate




Will incorporate where appropriate




Will revise
Will revise




Will revise




Will incorporate where appropriate



will be deleted




Will incorporate where appropriate




Will incorporate where appropriate
Will incorporate where appropriate




Will incorporate




Will incorporate




Will incorporate


Will clarify reference
Will incorporate where appropriate




Will incorporate where appropriate
Will incorporate where appropriate




Will incorporate where appropriate




Tables will be revised and clarified


References will be added
will incorporate

Will be clarified

Will be clarified

Will be clarified

Will be clarified



Will incorporate where appropriate to the tier
methodology or reference given to detailed datasets.




As applied to 1A4a/c




Agreed at Overview and Table 1-1, subsequent use
modified to align with NFR terminology




Accepted but, tried to retain much of the original text
(B216) as it has only recently been revised. The
technologies are not all NFR sector specific.

Diagram is generic
Not sure these comments are being held together that
I can follow the references made.



Some removal of detail, no additional CHP detail




These technology descriptions are largely taken from
the existing chapter




accepted however waterheaters are also devices
which heat water ! EuP ecodesign Lots 1 and 2 are
distinguishable on this basis.
HCB emissions very uncertain




Tier 1 is based on fuel not technology


The factors for some of these activities are highly
uncertain, this is partly due to the movement away
from technology to fuel categories but also reflects
variability in source data.
several coments here, tables reviewed




Some more obvious splitting included.
Additional data in appendix




many tables have been revised#
The factors were in the appendix of B216 of the 2006/7
guidebook. If they can help a country elaborate the
emissions better and the country has resources to do
this, then why not use them ?

To be improved



To be revised




The BLT test reports are type-approval tests for use in
Austria and other countries.




Winiwarter reference
Can we do as a x-reference




BAT figures ?




This is a fair point but we have tried to avoid applying
different sizes as the number of tables will become
unmanageable for the guidance.




??
1A2 ?


will clarify

Will include summary table of limits

will clarify


These are described in 2.2.


Table labelling is miss leading and will be corrected.

Will be clarified in a footnote


will clarify


will clarify

Will add




Will update



Will update


Will update


Will elaborate


Will update



Table will be revised
Will update



Will update


Will update

Will update


Will update



Will update


Will update

Will update



Will update



Will update

Will update


Will update

Will update


Will update



Will update


Will update


Will update
Will update

Will update


Will update

Will update

Will update

Will update


Will update


Will update


Will update

Will update


Will update



Will update


Will update


Will update

Will update



Will update

Will update



Will update

Will update
Will update



Will update



Will update




We'll follow the reporting template on this issue.



We'll follow the reporting template on this issue.



We'll follow the reporting template on this issue.




Relates to Tier 3 methodology comment
We don't have any information for this… consult with
EP
Not true. Gas distribution must be in this chapter.




Not sure what is meant here.
Not sure what is meant here.
For full reference see later comment
Still to do if there is time

I suppose this comment is applicable to chapter
1.B.2.a.vi. Reference added therein; not here since it is
not referred to
These values could indeed be useful for the
Guidebook, but we don't have them and cannot find
easily.


These values could indeed be useful for the
Guidebook, but we don't have them and cannot find
easily.


These values could indeed be useful for the
Guidebook, but we don't have them and cannot find
easily.


These values could indeed be useful for the
Guidebook, but we don't have them and cannot find
easily.


These values could indeed be useful for the
Guidebook, but we don't have them and cannot find
easily.
Not sure. Were listed under 050501 in former
Guidebook




These values could indeed be useful for the
Guidebook, but we don't have them and cannot find
easily.
A reference for this…?

This chapter has been drafted in close cooperation
with Concawe.




Explanation is not too late - this is the section for
activity data.
Don't know what this is applicable to




Why?
Cannot find text at indicated location. Furthermore, this
text has been added by Concawe themselves.
Tier 1 & Tier 2 must be as complete as possible
What table is this comment about?




In this chapter! What is the question here?

We think that this is probably not the majority. And
since we cannot split we chose to report these in the
combustion chapter

Emission expected in reporting template from source
category 1.A.2.f.i, therefore emission factor in that
chapter (either factor itself or a Not Estimated). Will be
corrected in final draft

PM is in process chapter (2.A.1), emission factors of
all other pollutants are in 1.A.2. Description describes
complete cement production process, since we want to
be complete in this respect.

Don't know what is meant by "misunderstood". In
which way?




No idea why this should be removed. I don't see any
reason to do so.
Not Estimated / Not Applicable are filled using the
reporting template. There is NOx and SOx from
process, but it has not been estimated here and
included in the combustion SOx in chapter 1.A.2.f.i.

Tier 2 EFs from EECCA now inserted




EECCA data now inserted as Tier 2



We think most HMs from cement are from the fuels
rather than the raw meal and therefore they are
accounted for in 1A2. Everything is emitted together
from the kiln (process & combustion), but we have to
make a split somewhere.


Needed for electronic emission factor database, EFs
not the same anymore in Final Draft
Indication I.E. will not be presented anymore in the
final draft




Probably also a significant contribution is from the
fuels. The question is which one is the most
significant, since a split is not possible. We think the
majority is from combustion.
Ammonia emissions treated in combustion chapter
1A2fi (according to reporting template); should not be
a NA




These are accounted for in the combustion chapter, as
indicated. See chapter 1.A.2.




We anticipate that dust is mainly from the processes
and HMs are mainly from the fuel combustion. Could
be updated, but only if HMs are in majority from the
process (which we do not think is true).




Chapter mainly important for GHGs, as indicated
Error made when copying value - will be corrected
Why?




Must be chapter 3.C, not 1.A.2.f.i (I think this is also
the point made in the comment, although I'm not
sure?)
To be added

Good suggestion, unfortunately I could not easily find a
conversion factor.



Decision tree updated to include product use besides
production. Don't know what else to change.

Dates back to 1995 while old Guidebook uses 1994.
All EFs the same, so I think this is not newer.

Dates back to 1995 while old Guidebook uses 1994.
All EFs the same, so I think this is not newer.

Dates back to 1995 while old Guidebook uses 1994.
All EFs the same, so I think this is not newer.




This issue has been identified as a problem from the
beginning of the project. Needs to be discussed, I
think!
Table 3-2 does not exist. Comment not applicable
here.




We have to stick to the NFR structure, which does not
identify glass as a separate source category.




Source = Expert judgement
We don't have any better information. If provided, we
would like to include this.


We don't have any better information. If provided, we
would like to include this.




We don't have any better information. If provided, we
would like to include this.


We don't have any better information. If provided, we
would like to include this.




NMVOC EFs from combustion and treated in chapter
1.A.2




All consistent tables will be produced for the final draft




Would be a nice report to use in a next version, but
since not published yet it will be difficult to incorporate
this now. Many emission factors have been revised
following other comments however.
True, but no figures available to quantify this
I'm not sure what is meant: Since all references have a
year, I think the person commenting refers to which
year the EFs are valid for. Our Tier 2 EFs do in
principle not have a reference year, because they are
technology-based.
We don't use a class I-III for HMs in the Guidebook.




True, but if these more accurate EFs are not available
they cannot be used.

Probably this is indeed not correct, but unfortunatly
complete information is not available from literature.
We have to deal with what we have.




Complete information is not available from literature.
We have to deal with what we have.
Sentence needs to be added to the preceding section
saying that all tables have been made complete by
adding Tier 1 EFs where Tier 2 EFs for that specific
technology were not available
no suggestion for




The 040501 and 040502 were separate chapters in old
guidebook, but indeed referring tot the same
naftacracking process - this is mentioned in the text
also .. Question on the expert panel to combine the
both SNAPS to one paragraph?


060306 is on pharmaceutical products, action asked
from task force on SNAP

SNAP 040622 is Explosives manufacturing




Suggested is BAT associated emission levels.
BREF LVIC AAF 2007: The tail gas composition
depends on the applied process conditions. Table 3.3
gives an overview of tail gas properties .. Used 200 -
4000 Nm3 / ton and 200 - 4000 mg/Nm3 .. Results in
620 - 13.200 g / ton - Guidebook values: 10.000 with
lower upper 5000 and 15000
Adipic acid production is relevant for emissions of
greenhouse gasses (N2O), but not considered
significant or a key source for other air emissions
included in the protocols.

The source is indeed Table 7.10 in BREF LVIC SAO
"Emission sources and data on typical dust emissions
from the Austrian plant at different process stages "
- because we need a Tier 1 we made a aggregated EF
from the different pprocess stages

The Guidebook has to give Tier 1 EF's for all NFR's…
including this one. This table therefore includes Tier 1
emission factors for the NFR Other chemical industry,
generated with Eurostat and EPER data – shoud be
used with care, and is a very rough estimate! ..

The Guidebook has to give Tier 1 EF's for all NFR's…
including this one. This table therefore includes Tier 1
emission factors for the NFR Other chemical industry,
generated with Eurostat and EPER data – shoud be
used with care, and is a very rough estimate! ..

There is already a separate BAT reference in the
chapter on BAT for Ammonia




the both processes, steam reforming and partial
oxidation are controlled processes


This seems a left over from the former version of the
Guidebook .. Will be corrected, we now assume a
lower value of 2000
This seems a left over from the former version of the
Guidebook .. Will be corrected
it is actually the other way round, 5000 refers to US
plants
we will use a value in the range for the European
plants - 500




see comment on TIER 1 EF comment .. Not a key
source




SNAP paragraph on Silicium production removed




TSP and NH3: compiled new EF's from the different
unit operations listed in EPA42, considering also new
developments in taking upper and lower limits


Note:
Used the EPA AP42 (1996) reference instead , same
values
 old chapter B443 guidebook states: A specific
methodology for these activities has not been prepared
because the contribution to total national emissions is
thought to be currently insignificant, i.e. less than 1%
of national emissions of any pollutant (2006)
reference to: COV from Economopoulos -> not clear!

 old chapter B443 guidebook states: A specific
methodology for these activities has not been prepared
because the contribution to total national emissions is
thought to be currently insignificant, i.e. less than 1%
of national emissions of any pollutant (2006)
We received a TIER 1 EF from ESPREME - chlorine-
Tier 1 (not in FOD) we will use
mercury cell: compiled an EF from the current
emission levels cell room ventilation 0.17 - 1.93,
proces exhaust 0.01 - 1.0 g , Caustic soda after the
decomposer: 0.009 - 0.05 and storage: 2.6 -> 3: (1 to
6), these correspond with the ESPREME value, which
is included in the revision
please provide us with a suitable EF

BREF LVOC: Suitable
feedstocks for olefins production range from light
gases (e.g. ethane and LPGs) to the refinery
liquid products (naphtha, gas-oil). Heavier feedstocks
generally give a higher proportion of coproducts
(propylene, butadiene, benzene) and need larger /
more complex plants. A large proportion of Europe‟s
propylene demand (and all of the butadiene demand)
can be
satisfied by the steam cracking of naphtha and gas-oil.
The balance of propylene demand is
essentially supplied from extraction of propylene from
refinery Fluidised Catalytic Cracker offgas
and imports. There is one PDH (propane
dehydrogenation) plant in Europe, but it is only
economic when propane prices are low. A similar
process for butadiene production (by the
dehydrogenation of n-butane) is also available but is
not used in Europe where there is generally
a surplus of butadiene from steam cracking.


Where to find this list?
Correct, use the EF's from the BREF, Table 7.5
summarises the principle pollutants and their sources,
together with the range of emission levels met in most
European crackers.

Eliminated the other table for proylene .. We do not
expect however that the EF of 0.6 underestimates the
emissions .. Most European plants are having lower
emissions
Information from the BREF LVOC were Ethylene is an
illustrative process

Suggested is BAT associated emission and
consumption levels. Current emissions are:
BREF Polymers, Table 3.9: Emission and
consumption data of LDPE plants:
LDPE European Average (benchmark 1999 average)
2400 g/t
VOC to air emissions in grams per tonne of product
(g/t). VOC includes all hydrocarbon and other organic
compounds including fugitive emissions . We will
include this information in the BAT chapter




Suggested is BAT associated emission and
consumption levels. Current emissions are:
BREF Polymers, Table 3.11: Emission and
consumption data of HDPE plants
HDPE European Average (benchmark 1999 average)
2300 g/t
VOC to air emissions in grams per tonne of product
(g/t). VOC includes all hydrocarbon and other organic
compounds including fugitive emissions. We will
include this information in the BAT chapter
Suggested is BAT associated emission levels. There is
also an split view on BAT which resuts in higher BAT
values. We will include this information in the BAT
chapter
Suggested is BAT associated emission levels. There is
also an split view on BAT which resuts in higher BAT
values. We will include this information in the BAT
chapter




BREF states that 85g/t is only for the top50% facilities
..European average is 120 g/t .. EF will therefore not
be adapted, reference will be made to the BREF
(Table 4.12: Emission and consumption data per tonne
of product of HIPS plants) in stead of Guidebook 2006


BREF states that 85g/t is only for the top50% facilities
..European average is 120 g/t .. EF will therefore not
be adapted, reference will be made to the BREF
(Table 4.10: Emission and consumption data per tonne
of product from GPPS plants) in stead of Guidebook
2006




. For more information see also the BREF document
on Large Volume Organic Chemicals where the
production of acrylonitrile is described as one of the
illustrative processes
These should indeed be consistent .. Propose to adapt
the approach on neglible emissions with production
comparde to product use




what information to use then?




plakken in excel
Suggested is BAT associated emission and
consumption levels. Current emissions are:
BREF Polymers, Table 3.9: Emission and
consumption data of LDPE plants:
LDPE European Average (benchmark 1999 average)
2400 g/t
VOC to air emissions in grams per tonne of product
(g/t). VOC includes all hydrocarbon and other organic
compounds including fugitive emissions . We will
include this information in the BAT chapter
BREF states that 85g/t is only for the top50% facilities
..European average is 120 g/t .. EF will therefore not
be adapted, reference will be made to the BREF
(Table 4.10: Emission and consumption data per tonne
of product from GPPS plants) in stead of Guidebook
2006
new table in BAT chapter, referring to table Table 7.3:
Emission and consumption data from ESBR plants
(per tonne of product)




what units are most suitable?
Sentence on this to be added

Sentence on this to be added




A Tier 1 is required for every NFR. It may be useful
however to stress in the text that the Tier 1 can only be
used for an Integrated Iron and Steel facility with all the
subfacilities on site.




Comment not understood; suggested to list all EFs in
g/kg or in another unit?




Comment not understood; suggested to list all EFs in
g/kg or in another unit?




Comment not understood; suggested to list all EFs in
g/kg or in another unit?
Tier system here a bit different: iron/steel industry
seperated in 3: sinter/pellets, pig iron and steel for Tier
2. Different technologies identified within each of
these. Problem with inconsistent values appears
because of different references. Try to avoid this as
much as possible, but will not be complete
unavoidable!

Comment not understood; suggested to list all EFs in
g/kg or in another unit?

Comment not understood; suggested to list all EFs in
g/kg or in another unit?
Why?



Majority is still combustion, I suppose. Since we have
always put NOx/SOx/CO/etc. in combustion when
combustion and process must be separated, I think it's
better to keep this approach here as well.




ESPREME data to be checked




ESPREME data to be checked
Split has been agreed with Expert Panel. Some of the
pollutants are process- and combustion-related and it's
not possible to split. A choice must be made where to
allocate these emissions, which has been done.




Unfortunately BREF does not provide generic factors
for Tier 1, only for different ferroalloys and
subprocesses within the ferroalloy production.
Furthermore, the overview in the BREF is not
complete. Therefore difficult to use in the Guidebook
and not included.
Also not included in Tier 2 because of non-
completeness, but references made.
Not anymore
NFR does not distinguish Primary/Secondary, so at
Tier 1 level we cannot separate them




Primary and secondary copper production are process
with contact, therefore we should treat these similarly
to cement and lime production.
Should be in combustion cahpter 1.A.2.f.i.
Same as for copper production: process with contact



Comment is true, but not too much can be done at this
stage. EFs from different references have been
combined and this causes inconsistencies (most
obvious between PM and HMs). However we cannot
just simply scale down the PM with HM, that is too
simple. I think however that this is an issue that needs
further discussion in the future.




Combining information from different references and
completing Tier 2 tables with typical EFs causes this
problem. There is no simple way to solve this however.


Combining information from different references and
completing Tier 2 tables with typical EFs causes this
problem. There is no simple way to solve this however.


Combining information from different references and
completing Tier 2 tables with typical EFs causes this
problem. There is no simple way to solve this however.


Combining information from different references and
completing Tier 2 tables with typical EFs causes this
problem. There is no simple way to solve this however.


Combining information from different references and
completing Tier 2 tables with typical EFs causes this
problem. There is no simple way to solve this however.


Combining information from different references and
completing Tier 2 tables with typical EFs causes this
problem. There is no simple way to solve this however.
Combining information from different references and
completing Tier 2 tables with typical EFs causes this
problem. There is no simple way to solve this however.




Comment refers to wrong chapter. Correction made in
zinc chapter (2.C.5.d)




Same as for copper production: process with contact




No more data available!
Look at this issue (same as in copper/lead)




CHECK ESPREME DATA

Combining information from different references and
completing Tier 2 tables with typical EFs causes this
problem. There is no simple way to solve this however.


Combining information from different references and
completing Tier 2 tables with typical EFs causes this
problem. There is no simple way to solve this however.




Combining information from different references and
completing Tier 2 tables with typical EFs causes this
problem. There is no simple way to solve this however.
Check for Zn EF; other comments noted




Should be in combustion cahpter 1.A.2.f.i.
Fuel combustion in 1A2 as indicated multiple times in
chapter




We use the reporting template as the master to check
whether emission are expected or not.

No info on this available.
No info on this available.




Chapter needs to be discussed. Where to collect all
this information?
If no information is found, I suggest to move all
relevant pollutants to NE and delete the emission
factors, since they're all wrong!




Chapter needs to be discussed. Where to collect all
this information?
If no new information is found, I propose to delete all
obviously wrong EFs and move to NE




I do not know where this should be allocated, discuss
with EP
Check this and add some text to make this clear.
Mention this somewhere in the description? These can
be considered technology-specific in a way
Only NFR is considered here, not SNAP




Should be paint used, not paint produced. Update
necessary!




What to use if EGTEI and/or GAINS data cannot be
used?



Values correct according to EGTEI



Values correct according to EGTEI
Check if default value is available in EGTEI document
to recalculate in terms of mass of paint




Discuss with EP, conversion factor difficult to find


Will be added. Should this be in chapter 3.A?



We have considered this, but then we get huge
numbers of tables (>100) which will make the
document practically non-readable

Table does not provide EFs, only abatement
efficiencies. Tier 2 EFs will be revised (g/kg paint).
This is not in Executive Summary of BREF document
(where the other text is taken from). Cannot find.




Perhaps we can add some wording on this in Tier 3



Perhaps we can add some wording on this in Tier 3
Cannot be Tier 1 since the old factors are technology
specific; these new factors have been derived in
contact with industrial representatives
Must be checked, what is meant here?


This is too vague. Reference needed for changing
numbers.




How to deal with this? Differs significantly from present
value and unreferenced, so left out.




Source needs discussion. What is meant here? EFs
indeed seem too high, but no other information
available!?




Source needs discussion with EP
EF to be added to chapter




Published in 1982, outdated?


Cannot find proper EFs in AP42

Don't know what text this comment is applicable to




Don't know what text this comment is applicable to

Don't know what text this comment is applicable to
Printing is one NFR, therefore a Tier 1 EF is necessary




This has been considered, but would generate many
tables with all just one EF and therefore expand the
document quite heavily.




Table structure cannot be changed at this stage




Problem is that references are different. How to solve
this?
Product masses can be added to obtain some kind of
generic EF
Emissions mentioned in the text should be in the table
as well (as NE in this case since no numbers are
available)




No idea what the point is here; we would be happy
even with a Tier 1!
This solution looks quite ok to me
Tier 1 represents averaged factors, Tier 2 tables are
basically uncontrolled factors (reduction efficiency to
be applied when abatement is in place). Discuss if also
Tier 1 should be unabated.
This is the uncontrolled one. In Tier 2, abatement
efficiencies should be applied when in operation, while
in Tier 1 there is an "averaged" factor (already
accounting for an average abatement)




A sentence will be added to make clear that the
abatement efficiencies are to be applied to the US
EPA factors only; the type 1/2/3 factors already have
their abatement in there


Must be ng I-TEQ/Nm3

To be discussed; I don't know how to take this into
account




How to define differentiation and where to find EFs?

What more can be said? It's just burning of waste…




Problem: TSP from BREF while HM EFs from former
GB (values are much older and therefore higher).
Obviously HM EFs should be updated, but where to
find EFs?




This again raises the question how to deal with Tier 2
in this chapter




Discuss with Expert Panel!
Must be ng I-TEQ/Nm3

What more can be said? It's just burning of waste…
EF for PCDD/F from UNEP already used; if more
updates necessary then please specify which ones to
update and where to find EFs!


Extra information in Tier 2 available is only the
unabated-abated EFs; Tier 2 uses unabated factors
where available (you can use abatement efficiencies
where applicable) while Tier 1 makes a best estimate
when no better info is available
Comment not understood




Consult EP: should we remove this or leave it in?

Must be ng I-TEQ/Nm3




Discuss if factors are available; where to find



No indication given on where to find this information.




Unit will be corrected.


Table to be corrected


Remove scheme? It does not provide information,
because a variety of process may occur within this
source category. Left in for now.
There is no original reference for this factor




If EFs are provided, we are happy to include them!
Chapter                                  TableNu             Present Propose
_ID     Chapter_Name          NFR_Code   mber    Pollutant   Value   dValue



      1 Energy industries     1.A.1      3-14     SOx          349.9       20

      1 Energy industries     1.A.1      3-14     NMVOC           10      2.3

      1 Energy industries     1.A.1      3-14     As          0.0125    0.004

      1   Energy industries   1.A.1      3-14     Cd           0.025   0.0012
      1   Energy industries   1.A.1      3-14     Cr          0.0625    0.015
      1   Energy industries   1.A.1      3-14     Cu           0.025    0.012
      1   Energy industries   1.A.1      3-14     Hg           0.025         0
      1   Energy industries   1.A.1      3-14     Ni           0.875      1.03

      1 Energy industries     1.A.1      3-14     Pb          0.0325   0.0046
      1 Energy industries     1.A.1      3-14     Zn           0.025    0.049

      1 Energy industries     1.A.1      3-14     PM10




      1 Energy industries     1.A.1      3-15     SOx           0.25

      1 Energy industries     1.A.1      3-15     CO              15       39

      1 Energy industries     1.A.1      3-15     NMVOC           10      2.6

      1 Energy industries     1.A.1      3-15     PM10           0.2     0.89

      1 Energy industries     1.A.1      3-15     TSP            0.2     0.89

      1 Energy industries     1.A.1      3-15     PM2.5          0.2     0.89




      1 Energy industries     1.A.1      B4       NOx             75      200




      1 Energy industries     1.A.1      B4       NOx                     400
1 Energy industries   1.A.1     B4    NOx              1600


1 Energy industries   1.A.1.b   4-3   SOx     349.9      20

1 Energy industries   1.A.1.b   4-3   CO        30       15

1 Energy industries   1.A.1.b   4-3   NMVOC     10      0.84

1 Energy industries   1.A.1.b   4-3   Cd      0.001   0.0012
1 Energy industries   1.A.1.b   4-3   Cr       0.01    0.015
1 Energy industries   1.A.1.b   4-3   Cu       0.01    0.012

1 Energy industries   1.A.1.b   4-3   Pb      0.005   0.0046
1 Energy industries   1.A.1.b   4-3   Zn       0.05    0.049

1 Energy industries   1.A.1.b   4-3   PM10


1 Energy industries   1.A.1.b   4-4   SOx        30       20
1 Energy industries   1.A.1.b   4-4   NMVOC     1.3     0.65


1 Energy industries   1.A.1.b   4-4   As      0.002   0.0018


1 Energy industries   1.A.1.b   4-4   Cd      0.001   0.0014


1 Energy industries   1.A.1.b   4-4   Cr      0.001   0.0014


1 Energy industries   1.A.1.b   4-4   Cu      0.003   0.0027


1 Energy industries   1.A.1.b   4-4   Hg      0.001   0.0014


1 Energy industries   1.A.1.b   4-4   Ni      0.001   0.0014


1 Energy industries   1.A.1.b   4-4   Pb      0.004   0.0041


1 Energy industries   1.A.1.b   4-4   Zn      0.002   0.0018

1 Energy industries   1.A.1.b   4-4   PM10       2       3.2
1 Energy industries     1.A.1.b   4-5   SOx         2        20

1 Energy industries     1.A.1.b   4-5   CO         35        16

1   Energy industries   1.A.1.b   4-5   NMVOC      1.8      1.5
1   Energy industries   1.A.1.b   4-5   As        0.03 0.00003
1   Energy industries   1.A.1.b   4-5   Cd        0.01 0.00001
1   Energy industries   1.A.1.b   4-5   Cr        0.09 0.00009


1 Energy industries     1.A.1.b   4-6   SOx       100        20


1 Energy industries     1.A.1.b   4-6   CO         75        39


1 Energy industries     1.A.1.b   4-6   NMVOC       2        2.6


1 Energy industries     1.A.1.b   4-6   As      0.0003 0.00034


1 Energy industries     1.A.1.b   4-6   Cd       0.001 0.00071


1 Energy industries     1.A.1.b   4-6   Cr       0.003   0.0027


1 Energy industries     1.A.1.b   4-6   Cu       0.002   0.0022


1 Energy industries     1.A.1.b   4-6   Hg      0.0001   8.6E-05


1 Energy industries     1.A.1.b   4-6   Ni       0.004   0.0036


1 Energy industries     1.A.1.b   4-6   Pb       0.002   0.0018


1 Energy industries     1.A.1.b   4-6   PM10                0.89




1 Energy industries     1.A.1.b   4-7   SOx       100

1 Energy industries     1.A.1.b   4-7   CO         40        39

1 Energy industries     1.A.1.b   4-7   NMVOC      3.1       2.6
1 Energy industries     1.A.1.b   4-7    PM10          0.9       0.89

1 Energy industries     1.A.1.b   4-7    TSP           1.1       0.89

1 Energy industries     1.A.1.b   4-7    PM2.5         0.4       0.89

1 Energy industries     1.A.1.b   4-8    NOx           100        400




1 Energy industries     1.A.1.b   4-8    SOx           100

1 Energy industries     1.A.1.b   4-8    CO             40        270

1 Energy industries     1.A.1.b   4-8    NMVOC         3.1         56

1 Energy industries     1.A.1.b   4-8    PM10          0.9      0.037

1 Energy industries     1.A.1.b   4-8    TSP           1.1      0.037

1   Energy industries   1.A.1.b   4-8    PM2.5          0.4      0.037
1   Energy industries   1.A.1.b    4-2   Arsenic    0.0001    0.00034
1   Energy industries   1.A.1.b    4-2   Cadmium    0.0001    0.00071
1   Energy industries   1.A.1.b    4-2   Chromium   0.0002    0.00274
1   Energy industries   1.A.1.b    4-2   Mercury    0.0001    8.6E-05
1   Energy industries   1.A.1.b    4-2   Nickel     0.0036     0.0036
1   Energy industries   1.A.1.b    4-2   Lead       0.0018    0.00179

1 Energy industries     1.A.1.b   4-3    Arsenic     0.004       3.98

1 Energy industries     1.A.1.b   4-3    Cadmium     0.001        1.2

1 Energy industries     1.A.1.b   4-3    Chromium     0.01       14.8

1 Energy industries     1.A.1.b   4-3    Mercury

1 Energy industries     1.A.1.b   4-3    Nickel          1       1030

1 Energy industries     1.A.1.b   4-3    Lead        0.005       4.56

1 Energy industries     1.A.1.b   4-4    Arsenic     0.002       1.81

1 Energy industries     1.A.1.b   4-4    Cadmium     0.001       1.36

1 Energy industries     1.A.1.b   4-4    Chromium    0.001       1.36

1 Energy industries     1.A.1.b   4-4    Mercury     0.001       1.36

1 Energy industries     1.A.1.b   4-4    Nickel      0.001       1.36
1 Energy industries   1.A.1.b   4-4   Lead       0.004    4.07

1 Energy industries   1.A.1.b   4-x   Arsenic             3.98

1 Energy industries   1.A.1.b   4-x   Cadmium              1.2

1 Energy industries   1.A.1.b   4-x   Chromium            14.8

1 Energy industries   1.A.1.b   4-x   Mercury

1 Energy industries   1.A.1.b   4-x   Nickel             1030

1 Energy industries   1.A.1.b   4-x   Lead                4.56


1 Energy industries   1.A.1.b   4-x   Arsenic


1 Energy industries   1.A.1.b   4-x   Cadmium             2.52


1 Energy industries   1.A.1.b   4-x   Chromium            6.26


1 Energy industries   1.A.1.b   4-x   Mercury             7.31


1 Energy industries   1.A.1.b   4-x   Nickel              79.3


1 Energy industries   1.A.1.b   4-x   Lead                13.6


1 Energy industries   1.A.1.b   4-x   Arsenic            0.343


1 Energy industries   1.A.1.b   4-x   Cadmium            0.712


1 Energy industries   1.A.1.b   4-x   Chromium            2.74


1 Energy industries   1.A.1.b   4-x   Mercury            0.086


1 Energy industries   1.A.1.b   4-x   Nickel               3.6


1 Energy industries   1.A.1.b   4-x   Lead                1.79
1 Energy industries   1.A.1.a   3.23   CO            1       1.5

1 Energy industries   1.A.1.a   3.23   NMVOC        0.2     0.19

1 Energy industries   1.A.1.a   3.23   PM10         10        2


1 Energy industries   1.A.1.a   3.23   Cd         0.002   0.0022


1 Energy industries   1.A.1.a   3.23   Ni        0.0005 0.00054




1 Energy industries   1.A.1.a   3-3    Dioxins




1 Energy industries   1.A.1.a   3-3




1 Energy industries   1.A.1.a   3-3    TSP          40       20

1 Energy industries   1.A.1.a   3-3    PM10         30       15

1 Energy industries   1.A.1.a   3-3    PM2.5        10        5




1 Energy industries   1.A.1.a   3-3    NMVOC        30       0.4




1 Energy industries   1.A.1.a   3-4    Dioxins
1 Energy industries   1.A.1.a   3-4   TSP         60      20

1 Energy industries   1.A.1.a   3-4   PM10        30      10

1 Energy industries   1.A.1.a   3-4   PM2.5       20       7




1 Energy industries   1.A.1.a   3-4   NMVOC       30      0.4



1 Energy industries   1.A.1.a   3-5   PM10




1 Energy industries   1.A.1.a   3-5   NMVOC       30      0.5



1 Energy industries   1.A.1.a   3-6   TSP


1 Energy industries   1.A.1.a   3-7   SOx        350     250




1 Energy industries   1.A.1.a   3-7   Arsenic    0.01   0.002




1 Energy industries   1.A.1.a   3-7   Cadmium    0.01   0.002




1 Energy industries   1.A.1.a   3-7   Chromium   0.03   0.008
1 Energy industries   1.A.1.a   3-7    Mercury   0.008   0.0003




1 Energy industries   1.A.1.a   3-7    Nickel      0.7      0.2




1 Energy industries   1.A.1.a   3-7    NMVOC       30       0.6



1 Energy industries   1.A.1.a   3-8    PM10




1 Energy industries   1.A.1.a   3-11   Dioxins


1 Energy industries   1.A.1.a   3-11   Dioxins




1 Energy industries   1.A.1.a   3-11   TSP         40       20

1 Energy industries   1.A.1.a   3-11   PM10        30       15

1 Energy industries   1.A.1.a   3-11   PM2.5       10        5




1 Energy industries   1.A.1.a   3-11   NMVOC       30       0.4
1 Energy industries   1.A.1.a   3-12   TSP       60   20

1 Energy industries   1.A.1.a   3-12   PM10      30   10

1 Energy industries   1.A.1.a   3-12   PM2.5     20    7




1 Energy industries   1.A.1.a   3-12   Dioxins




1 Energy industries   1.A.1.a   3-12   NMVOC     30   0.4




1 Energy industries   1.A.1.a   3-13   TSP       60   20

1 Energy industries   1.A.1.a   3-13   PM10      30   10

1 Energy industries   1.A.1.a   3-13   PM2.5     20    7




1 Energy industries   1.A.1.a   3-13   TSP       60   20

1 Energy industries   1.A.1.a   3-13   PM10      30   10

1 Energy industries   1.A.1.a   3-13   PM2.5     20    7
1 Energy industries   1.A.1.a   3-13   Dioxins




1 Energy industries   1.A.1.a   3-13   NMVOC     30   0.4




1 Energy industries   1.A.1.a   3-16   TSP       40   20

1 Energy industries   1.A.1.a   3-16   PM10      30   15

1 Energy industries   1.A.1.a   3-16   PM2.5     10    5




1 Energy industries   1.A.1.a   3-16   Dioxins




1 Energy industries   1.A.1.a   3-16   NMVOC     30   0.4




1 Energy industries   1.A.1.a   3-17   TSP       60   20

1 Energy industries   1.A.1.a   3-17   PM10      30   10

1 Energy industries   1.A.1.a   3-17   PM2.5     20    7
1 Energy industries   1.A.1.a   3-17   Dioxins




1 Energy industries   1.A.1.a   3-17   NMVOC     30   0.4




1 Energy industries   1.A.1.a   3-19   TSP       40   20

1 Energy industries   1.A.1.a   3-19   PM10      30   15

1 Energy industries   1.A.1.a   3-19   PM2.5     10    5




1 Energy industries   1.A.1.a   3-19   Dioxins




1 Energy industries   1.A.1.a   3-20   TSP       60   20

1 Energy industries   1.A.1.a   3-20   PM10      30   10

1 Energy industries   1.A.1.a   3-20   PM2.5     20    7




1 Energy industries   1.A.1.a   3-20   Dioxins
1 Energy industries     1.A.1.a   3-22   TSP            -0.8


1 Energy industries     1.A.1.a   3-22   SOx           0.25

1 Energy industries     1.A.1.a   3-22   NMVOC          1.6         1

1 Energy industries     1.A.1.a   3-22   PM10           0.2       0.91
1 Energy industries     1.A.1.a   3-22   TSP            0.2       0.91
1 Energy industries     1.A.1.a   3-22   PM2.5          0.2       0.91


1 Energy industries     1.A.1.a   3-23   SOx           14.2        20


1 Energy industries     1.A.1.a   3-23   Pb           0.006     0.0063



1 Energy industries     1.A.1.a   3-24   PM10


1 Energy industries     1.A.1.a   3-24   SOx            0.5        20


1 Energy industries     1.A.1.a   3-24   CO              10        39


1 Energy industries     1.A.1.a   3-24   NMVOC          2.5         1

1 Energy industries     1.A.1.a   3-24   PM10             2       0.91
1 Energy industries     1.A.1.a   3-24   TSP              3       0.91
1 Energy industries     1.A.1.a   3-24   PM2.5            1       0.91



1   Energy industries   1.A.1.a   3-25   TSP
1   Energy industries   1.A.1.a    3-3   Arsenic       0.004   0.00502
1   Energy industries   1.A.1.a    3-3   Cadmium     0.0002    0.00093
1   Energy industries   1.A.1.a    3-3   Chromium      0.003   0.03071
1   Energy industries   1.A.1.a    3-3   Mercury       0.002   0.00329
1   Energy industries   1.A.1.a    3-3   Nickel        0.005   0.00916
1   Energy industries   1.A.1.a    3-3   Lead          0.008   0.02333
1   Energy industries   1.A.1.a    3-4   Arsenic       0.004    0.0173
1   Energy industries   1.A.1.a    3-4   Cadmium     0.0002    0.01537
1   Energy industries   1.A.1.a    3-4   Chromium   0.00281    0.03071
1   Energy industries   1.A.1.a    3-4   Mercury       0.003   0.00125
1   Energy industries   1.A.1.a    3-4   Nickel        0.005    0.0599
1   Energy industries   1.A.1.a    3-4   Lead          0.008   0.05357
1   Energy industries   1.A.1.a    3-7   Arsenic        0.01   1.01147
1   Energy industries   1.A.1.a    3-7   Cadmium        0.01   1.58945
1   Energy industries   1.A.1.a    3-7   Chromium       0.03   23.1193
1   Energy industries             1.A.1.a       3-7   Mercury     0.008 0.13596
1   Energy industries             1.A.1.a       3-7   Nickel         0.7 23.1193
1   Energy industries             1.A.1.a       3-7   Lead        0.025 4.33487
1   Energy industries             1.A.1.a      x-x    Hg(0)                   0.5
1   Energy industries             1.A.1.a      x-x    Hg(II)                  0.4
1   Energy industries             1.A.1.a      x-x    Hg(p)                   0.1



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-19   As            0.8       3.8



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-19   Cd            2.6     4.73



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-19   Cr           12.4   23.825



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-19   Ni           33.6    29.85



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-19   Pb           107    176.26



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-19   As            10      67.5



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-19   Cd        13.2038 22.3778



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-19   Cr        669.234 2310.99



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-19   Ni        463.144 326.515
  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-19   Pb      3126.03 6071.81


  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-5    TSP      0.0096 0.06209


  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-5    PM10     0.0064 0.00931


  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-5    PM2,5    0.0035   0.0005


  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-7    TSP       0.041 0.34928


  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-7    PM10      0.027 0.02794


  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-7    PM2,5     0.015   0.0014



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-9    TSP       0.011 0.00907



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-9    PM10     0.0073 0.00798



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-9    PM2,5    0.0039 0.00404



  Road transport, automobile tyre
6 and brake wear                  1.A.3.b.vi   3-11   TSP       0.048 0.04273
   Road transport, automobile tyre
 6 and brake wear                  1.A.3.b.vi       3-11   PM10           0.032 0.03762



     Road transport, automobile tyre
 6   and brake wear                    1.A.3.b.vi   3-11   PM2,5          0.017    0.01903
10   Small combustion                  1.A.4.b       3-5   Arsenic       0.0003    10.8891
10   Small combustion                  1.A.4.b       3-5   Cadmium        0.001    17.1114
10   Small combustion                  1.A.4.b       3-5   Chromium       0.002    248.893
10   Small combustion                  1.A.4.b       3-5   Mercury             0   1.20059
10   Small combustion                  1.A.4.b       3-5   Nickel           0.01   248.893
10   Small combustion                  1.A.4.b       3-5   Lead                0   46.6674
10   Small combustion                  1.A.4.b       3-6   Arsenic       0.0005    0.00017
10   Small combustion                  1.A.4.b       3-6   Cadmium        0.001    0.00017
10   Small combustion                  1.A.4.b       3-6   Chromium       0.002    0.01333
10   Small combustion                  1.A.4.b       3-6   Mercury       0.0005    0.00967
10   Small combustion                  1.A.4.b       3-6   Nickel         0.002    0.00017
10   Small combustion                  1.A.4.b       3-6   Lead                0   0.00097
10   Small combustion                  1.A.4.b.i    3-5    Mercury             0        0.1
10   Small combustion                  1.A.4.b.i    3-5    Lead                0
10   Small combustion                  1.A.4.b.i    3-6    Lead                0        40


10 Small combustion                    1.A.4.b.i    3-14   TSP              550        350


10 Small combustion                    1.A.4.b.i    3-14   PM10             530        330


10 Small combustion                    1.A.4.b.i    3-14   PM2,5            531        330


10 Small combustion                    1.A.4.b.i    3-14   Copper         0.019       0.02


10 Small combustion                    1.A.4.b.i    3-14   Mercury       0.0007      0.001


10 Small combustion                    1.A.4.b.i    3-14   Chromium       0.001       0.01


10 Small combustion                    1.A.4.b.i    3-14   NMVOC            800        600



10 Small combustion                    1.A.4.b.i    3-15   SOX              0.7          0
                                                           Dioxins and
10 Small combustion                    1.A.4.b.i    3-15   Furans             2        1.5
10 Small combustion                 1.A.4.b.i    3-15   TSP       0.2     0.5
10 Small combustion                 1.A.4.b.i    3-15   PM10      0.2     0.5
10 Small combustion                 1.A.4.b.i    3-15   PM2,5     0.2     0.5

10 Small combustion                 1.A.4.b.i    3-16   NOX      120       50

10 Small combustion                 1.A.4.b.i    3-16   CO       320       10

10 Small combustion                 1.A.4.b.i    3-16   SOX      0.01   6000

10   Small combustion               1.A.4.b.i    3-16   HM
10   Small combustion               1.A.4.b.i    3-20   PM2.5       0      10
10   Small combustion               1.A.4.b.i    3-24   TSP      -0.8     0.8
10   Small combustion               1.A.4.b.i    x-x    Hg(0)             0.5
10   Small combustion               1.A.4.b.i    x-x    Hg(II)            0.3
10   Small combustion               1.A.4.b.i    x-x    Hg(p)             0.2

13 Solid fuel transformation        1.B.1.b      3-1    PM10             100

13 Solid fuel transformation        1.B.1.b      3-1    PM2,5              90

16 Refining / storage               1.B.2.a.iv   3-6    NMVOC     0.2     0.2




16 Refining / storage               1.B.2.a.iv   3-7    PM10      0.8     0.6
18 Geothermal energy extraction     1.B.2.a.vi   3-1    NOX         0




18   Geothermal energy extraction   1.B.2.a.vi   3-1    SOX        16
18   Geothermal energy extraction   1.B.2.a.vi   3-1    NH3      300    2100
18   Geothermal energy extraction   1.B.2.a.vi   3-1    PST         0
18   Geothermal energy extraction   1.B.2.a.vi   3-1    PM10        0
18   Geothermal energy extraction   1.B.2.a.vi   3-1    PM2,5       0
18   Geothermal energy extraction   1.B.2.a.vi   3-1    Hg        0.2    0.44
18   Geothermal energy extraction   1.B.2.a.vi   3-1    As              0.025
19   Venting and flaring            1.B.2.c      3-3    NOx        4       3.7



20 Cement production                2.A.1        x-x    Hg(0)             0.8



20 Cement production                2.A.1        x-x    Hg(II)           0.15
20 Cement production             2.A.1     x-x        Hg(p)                0.05



23 Soda ash production and use   2.A.4     tab. 3-1   NH3        0.3873      1


25 Road paving with asphalt      2.A.6     No. 3-6    NMVOC        200      30


29 Other mineral products        2.A.7.d   3-2        SOx            0    1900



29 Other mineral products        2.A.7.d   3-2        Arsenic      0.12    0.08



29 Other mineral products        2.A.7.d   3-2        Cadmium      0.15   0.068


29 Other mineral products        2.A.7.d   3-2        Chromium      2.4    0.08



29 Other mineral products        2.A.7.d   3-2        Copper        0.6   0.007



29 Other mineral products        2.A.7.d   3-2        Mercury      0.05   0.003


29 Other mineral products        2.A.7.d   3-2        Nickel        1.9    0.74


29 Other mineral products        2.A.7.d   3-2        Lead          12      0.4


29 Other mineral products        2.A.7.d   3-2        Selenium      18     0.15


29 Other mineral products        2.A.7.d   3-2        Zinc          11    0.366



29 Other mineral products        2.A.7.d   Table 3-2 PM2.5         320     10.8
29 Other mineral products      2.A.7.d   Table 3-2 PM10       360       19.6



29 Other mineral products      2.A.7.d   Table 3-2 Se          18       1.36

30 Chemical industry           2.B.5.a   3-x      Arsenic

30 Chemical industry           2.B.5.a   3-x      Cadmium

30 Chemical industry           2.B.5.a   3-x      Chromium

30 Chemical industry           2.B.5.a    3-x     Nickel
30 Chemical industry           2.B.5.a   x-x      Hg(p)                   0

31 Iron and steel production   2.C.1     3-2      Lead         0.5 3.54308

31 Iron and steel production   2.C.1     3-2      Arsenic     0.02 0.01789

31 Iron and steel production   2.C.1     3-2      Cadmium    0.009 0.00394

31 Iron and steel production   2.C.1     3-2      Chromium    0.02       2.3

31 Iron and steel production   2.C.1     3-2      Nickel     0.009 0.08947

31 Iron and steel production   2.C.1     3-2      Mercury     0.05 0.01838

31 Iron and steel production   2.C.1     3-x      Cadmium            0.21766

31 Iron and steel production   2.C.1     3-x      Chromium               2.3

31 Iron and steel production   2.C.1     3-x      Mercury            0.05059

31 Iron and steel production   2.C.1     3-x      Nickel             0.72553

31 Iron and steel production   2.C.1     3-x      Lead               2.61191

31 Iron and steel production   2.C.1     3-x      Arsenic            0.40069

31 Iron and steel production   2.C.1     3-x      Cadmium            0.06678

31 Iron and steel production   2.C.1     3-x      Chromium               2.3

31 Iron and steel production   2.C.1     3-x      Mercury            0.00137

31 Iron and steel production   2.C.1     3-x      Nickel             0.13356

31 Iron and steel production   2.C.1     3-x      Lead               4.00691
31 Iron and steel production   2.C.1     3-x    Nickel             10



31 Iron and steel production   2.C.1     x-x    Hg(0)             0.7



31 Iron and steel production   2.C.1     x-x    Hg(II)            0.3

31 Iron and steel production   2.C.1      3-x   Mercury       0.00014
31 Iron and steel production   2.C.1     x-x    Hg(p)               0

31 Iron and steel production   2.C.1     3-x    Arsenic

31 Iron and steel production   2.C.1     3-x    Arsenic       0.01451

31 Iron and steel production   2.C.1     3-x    Chromium          2.3

31 Iron and steel production   2.C.1     3-x    Lead              300

31 Iron and steel production   2.C.1     3-x    Nickel

31 Iron and steel production   2.C.1     3-x    Lead           0.0006

31 Iron and steel production   2.C.1     3-x    Arsenic

31 Iron and steel production   2.C.1     3-x    Cadmium       0.00011

31 Iron and steel production   2.C.1     3-x    Chromium

31 Iron and steel production   2.C.1     3-x    Mercury

31 Iron and steel production   2.C.1     3-x    Nickel        0.00599

31 Iron and steel production   2.C.1     3-x    Lead          0.00336

31 Iron and steel production   2.C.1     3-x    Arsenic            30

31 Iron and steel production   2.C.1     3-x    Cadmium           0.8

31 Iron and steel production   2.C.1     3-x    Chromium          2.3

31 Iron and steel production   2.C.1     3-x    Mercury

31 Iron and steel production   2.C.1     3-x    Cadmium


34 Copper production           2.C.5.a   3-1    Arsenic    39 38.7632
34 Copper production   2.C.5.a   3-1   Cadmium      12 11.4866


34 Copper production   2.C.5.a   3-1   Chromium     16 16.0136


34 Copper production   2.C.5.a   3-1   Mercury    0.023 0.02335


34 Copper production   2.C.5.a   3-1   Nickel       14    14.439



34 Copper production   2.C.5.a   3-2   Cadmium      15 14.5531


34 Copper production   2.C.5.a   3-1   Lead        160 159.566



34 Copper production   2.C.5.a   3-2   Chromium     21 21.3515



34 Copper production   2.C.5.a   3-2   Mercury    0.031 0.03113



34 Copper production   2.C.5.a   3-2   Nickel       19 19.2101



34 Copper production   2.C.5.a   3-2   Lead        170 174.637

34 Copper production   2.C.5.a   3-x   Arsenic           1.37223

34 Copper production   2.C.5.a   3-x   Cadmium           2.28705

34 Copper production   2.C.5.a   3-x   Chromium

34 Copper production   2.C.5.a   3-x   Mercury

34 Copper production   2.C.5.a   3-x   Nickel            0.12579

34 Copper production   2.C.5.a   3-x   Lead              114.352



34 Copper production   2.C.5.a   3-2   Arsenic      51 51.2268
35 Lead production     2.C.5.b   3-x   Mercury

35 Lead production     2.C.5.b   3-x   Nickel

35 Lead production     2.C.5.b   3-x   Lead                425.926

35 Lead production     2.C.5.b   3-x   Cadmium             1.10153

35 Lead production     2.C.5.b   3-x   Arsenic             3.45147

35   Lead production   2.C.5.b   3-x   Chromium
35   Lead production   2.C.5.b   3-1   Arsenic     0.89    0.87417
35   Lead production   2.C.5.b   3-1   Cadmium     0.33    0.32563
35   Lead production   2.C.5.b   3-1   Chromium        0
35   Lead production   2.C.5.b   3-1   Mercury       0.7   0.69407
35   Lead production   2.C.5.b   3-1   Nickel          0
35   Lead production   2.C.5.b   3-1   Lead         120    115.903

35 Lead production     2.C.5.b   3-2   Arsenic    0.015 0.01507

35 Lead production     2.C.5.b   3-2   Cadmium    0.067      0.067

35 Lead production     2.C.5.b   3-2   Chromium       0

35 Lead production     2.C.5.b   3-2   Mercury     0.93 0.92542

35 Lead production     2.C.5.b   3-2   Nickel         0

35 Lead production     2.C.5.b   3-2   Lead          13 12.5621



35 Lead production     2.C.5.b   x-x   Hg(0)                  0.84



35 Lead production     2.C.5.b   x-x   Hg(II)                  0.1



35 Lead production     2.C.5.b   x-x   Hg(p)                  0.06

37   Zinc production   2.C.5.d   3-2   Nickel         0
37   Zinc production   2.C.5.d   3-1   Arsenic     0.12    0.11956
37   Zinc production   2.C.5.d   3-1   Cadmium      2.5    2.53319
37   Zinc production   2.C.5.d   3-1   Chromium       0
37   Zinc production   2.C.5.d   3-1   Mercury      3.8    3.78578
37   Zinc production   2.C.5.d   3-1   Nickel         0
37   Zinc production   2.C.5.d   3-1   Lead          14    14.0846

37 Zinc production     2.C.5.d   3-2   Arsenic        0
37 Zinc production     2.C.5.d   3-2   Cadmium    2.4 2.43188

37 Zinc production     2.C.5.d   3-2   Mercury     5 5.04556

37 Zinc production     2.C.5.d   3-2   Lead       17 17.0232

37 Zinc production     2.C.5.d   3-x   Arsenic          0.47826

37 Zinc production     2.C.5.d   3-x   Cadmium          2.83712

37 Zinc production     2.C.5.d   3-x   Chromium

37 Zinc production     2.C.5.d   3-x   Mercury          0.00645

37 Zinc production     2.C.5.d   3-x   Nickel

37 Zinc production     2.C.5.d   3-x   Lead             5.26895

37 Zinc production     2.C.5.d   3-2   Chromium    0



37 Zinc production     2.C.5.d   x-x   Hg(0)                0.8



37 Zinc production     2.C.5.d   x-x   Hg(II)              0.15



37 Zinc production     2.C.5.d   x-x   Hg(p)               0.05




46 Paint application   3.A.3     3-3   NMVOC      200      380




46 Paint application   3.A.2     3-2   NMVOC      400      266
46 Paint application             3.A.1   3-1   NMVOC      150      80




46 Paint application             3.A     new   COV                125


47 Degreasing                    3.B.1   new   COV                740

52 Other product use             3.D.3   new   COV                 5.5



59 Clinical waste incineration   6.C           MNVOC                0



59 Clinical waste incineration   6.C           SO2                0.02



59 Clinical waste incineration   6.C           CO                 0.04



59 Clinical waste incineration   6.C           Paricles           0.14



59 Clinical waste incineration   6.C     x-x   Hg(p)               0.2



59 Clinical waste incineration   6.C           CH4                0.37



59 Clinical waste incineration   6.C           N2O              0.0015



59 Clinical waste incineration   6.C           HM
59 Clinical waste incineration         6.C     x-x       Hg(0)                  0.2



59 Clinical waste incineration         6.C     x-x       Hg(II)                 0.6



59 Clinical waste incineration         6.C               Nox                   0.17

60 Industrial waste incineration (d)   6.C.b   3-1       Cadmium         3 0.10158

60 Industrial waste incineration (d)   6.C.b   3-1       Chromium       0.3

60 Industrial waste incineration (d)   6.C.b   3-1       Mercury        35 0.08665

60 Industrial waste incineration (d)   6.C.b   3-1       Nickel         56 0.13544

60 Industrial waste incineration (d)   6.C.b   3-1       Lead           0.1 1.25766

60 Industrial waste incineration (d)   6.C.b    3-1     Arsenic        0.05 0.01645
                                               house
                                               and care TSP, HM and
64 Other waste                         6.D     fires    dioxin

                                                         NOx, NMVOC,
                                                         CO, TSP,
                                                         PAH,HM and
64 Other waste                         6.D     tobacco   dioxin
LowerLi UpperLi                                                  Proposed
mit     mit     Reference                                        decision

                     Chemistry, assuming all sulphur
                     converted (values to be multiplied with
    19.9       20    S = wt% S in fuel)                          Accepted
                     US EPA AP-42 Ch 1.3, Table 1.3-3
     1.8      2.8    (rated A)                                   Noted
                     US EPA AP-42 Ch 1.3, Table 1.3-11
   0.002    0.008    (rated C)                                   Noted
                     US EPA AP-42 Ch 1.3, Table 1.3-11
  0.0006   0.0024    (rated C)                                   Accepted
   0.005    0.045    API Publication 348 (rated D)               Rejected
   0.004    0.036    API Publication 348 (rated D)               Rejected
                     API Publication 348 (not detected)          Rejected
    0.33      3.1    API Publication 348 (rated D)               Rejected
                     US EPA AP-42 Ch 1.3, Table 1.3-11
  0.0023   0.0092    (rated C)                                   Rejected
   0.016      0.15   API Publication 348 (rated D)               Rejected
                     US EPA AP-42 provides algorithm
                     relating PM to sulphur content              Noted
                     Page 8, line 17 of this chapter states
                     sulphur in natural gas is negligible. If
                     this proposal is not accepted, then the
                     algorithm 20*S should be used - see
                     above.                                      Accepted
                     US EPA AP-42 Ch 1.4, Table 1.4-1
     23        55    (rated B)                                   Accepted
                     US EPA AP-42 Ch 1.4, Table 1.4-2
     1.3      5.2    (rated C)                                   Accepted
                     US EPA AP-42 Ch 1.4, Table 1.4-2
    0.53      1.3    (rated B)                                   Accepted
                     AP-42 (as above) states that all PM <
    0.53      1.3    1 micron                                    Accepted
                     AP-42 (as above) states that all PM <
    0.53      1.3    1 micron                                    Accepted
                     See:
                     http://www.ifc.org/ifcext/enviro.nsf/Atta
                     chmentsByTitle/gui_EHSGuidelines20
                     07_GeneralEHS/$FILE/Final+-
                     +General+EHS+Guidelines.pdf                 Noted
                     For dual fuel engines operated with
                     gas, overtake World Bank proposal,
                     see General EHS Guidelines:
                     http://www.ifc.org/ifcext/enviro.nsf/Atta
                     chmentsByTitle/gui_EHSGuidelines20
                     07_GeneralEHS/$FILE/Final+-
                     +General+EHS+Guidelines.pdf                 Noted
                   For gas diesel engines, see:
                   http://www.ifc.org/ifcext/enviro.nsf/Atta
                   chmentsByTitle/gui_EHSGuidelines20
                   07_GeneralEHS/$FILE/Final+-
                   +General+EHS+Guidelines.pdf                 Noted
                   Chemistry, assuming all sulphur
                   converted (values to be multiplied with
  19.9       20    S = wt% S in fuel)                          Noted
                   US EPA AP-42 Ch 1.3, Table 1.3-1
   12        18    (rated A)                                   Noted
                   US EPA AP-42 Ch 1.3, Table 1.3-3
  0.67        1    (rated A)                                   Noted
                   US EPA AP-42 Ch 1.3, Table 1.3-11
0.0006   0.0024    (rated C)                                   Noted
 0.005    0.045    API Publication 348 (rated D)               Noted
 0.004    0.036    API Publication 348 (rated D)               Noted
                   US EPA AP-42 Ch 1.3, Table 1.3-11
0.0023   0.0092    (rated C)                                   Noted
 0.016      0.15   API Publication 348 (rated D)               Noted
                   US EPA AP-42 provides algorithm
                   relating PM to sulphur content              Noted
                   Chemistry, assuming all sulphur
                   converted (values to be multiplied with
  19.9       20    S = wt% S in fuel)                          Noted
  0.52     0.78    E-PRTR                                      Noted
                   US EPA AP-42 Ch 1.3, Table 1.3-10
                   (rated D); ; present value rounded up
0.0006   0.0054    to one significant figure                   Accepted
                   US EPA AP-42 Ch 1.3, Table 1.3-10
                   (rated D); present value rounded up to
0.0007   0.0042    one significant figure                      Noted
                   US EPA AP-42 Ch 1.3, Table 1.3-10
                   (rated D); present value rounded up to
0.0007   0.0042    one significant figure                      Accepted
                   US EPA AP-42 Ch 1.3, Table 1.3-10
                   (rated D); present value rounded up to
0.0009   0.0081    one significant figure                      Noted
                   US EPA AP-42 Ch 1.3, Table 1.3-10
                   (rated D); present value rounded up to
0.0007   0.0042    one significant figure                      Noted
                   US EPA AP-42 Ch 1.3, Table 1.3-10
                   (rated D); present value rounded up to
0.0007   0.0042    one significant figure                      Noted
                   US EPA AP-42 Ch 1.3, Table 1.3-10
                   (rated D); present value rounded up to
0.0014    0.012    one significant figure                      Noted
                   US EPA AP-42 Ch 1.3, Table 1.3-10
                   (rated D); present value rounded up to
0.0006   0.0054    one significant figure                      Noted
                   US EPA AP-42 Ch 1.3, Table 1.3-10
    1       9.6    (rated D)                                   Noted
                   Chemistry, assuming all sulphur
                   converted (values to be multiplied with
   19.9      20    S = wt% S in fuel)                         Noted
                   US EPA AP-42 Ch 1.5, Table 1.5-1
     8       32    (rated D)                                  Accepted
                   US EPA AP-42 Ch 1.5, Table 1.5-1
   0.49      4.4   (rated D)                                  Noted
1.5E-05 0.00006    Guidebook, 2006 gives units as g/TJ        Accepted
  5E-06 0.00002    Guidebook, 2006 gives units as g/TJ        Noted
4.5E-05 0.00018    Guidebook, 2006 gives units as g/TJ        Noted
                   Chemistry, assuming all sulphur
                   converted (values to be multiplied with
   19.9      20    S = wt% S in fuel)                         Noted
                   US EPA AP-42 Ch 1.4, Table 1.4-1
                   (rated B); Assuming refinery gas
    23       55    equivalent to natural gas                  Noted
                   US EPA AP-42 Ch 1.4, Table 1.4-2
                   (rated C); Assuming refinery gas
    1.3      5.2   equivalent to natural gas                  Noted
                   API Publication 348 (rated D); present
                   value rounded up to one significant
0.00011    0.001   figure                                     Noted
                   API Publication 348 (rated D); present
                   value rounded up to one significant
0.00024   0.0021   figure                                     Noted
                   API Publication 348 (rated C); present
                   value rounded up to one significant
 0.0014   0.0054   figure                                     Noted
                   API Publication 348 (rated c); present
                   value rounded up to one significant
 0.0011   0.0044   figure                                     Noted
                   API Publication 348 (rated C); present
                   value rounded up to one significant
4.3E-05 0.00017    figure                                     Noted
                   API Publication 348 (rated C); present
                   value rounded up to one significant
 0.0018   0.0072   figure                                     Noted
                   API Publication 348 (rated C); present
                   value rounded up to one significant
 0.0009   0.0036   figure                                     Noted
                   US EPA AP-42 Ch 1.4, Table 1.4-2
                   (rated B); assuming refinery gas
   0.53      1.3   equivalent to natural gas                  Noted
                   Page 8, line 17 of this chapter states
                   sulphur in natural gas is negligible. If
                   this proposal is not accepted, then the
                   algorithm 20*S should be used - see
                   above.                                     Noted
                   US EPA AP-42 Ch 1.4, Table 1.4-1
    23       55    (rated B)                                  Noted
                   US EPA AP-42 Ch 1.4, Table 1.4-2
    1.3      5.2   (rated C)                                  Noted
                      US EPA AP-42 Ch 1.4, Table 1.4-2
   0.53           1.3 (rated B)                                  Noted
                      AP-42 (as above) states that all PM <
   0.53           1.3 1 micron                                   Noted
                      AP-42 (as above) states that all PM <
   0.53           1.3 1 micron                                   Noted
                      US EPA AP-42 Ch 3.2, Table 3.2-2
    240          560 (rated B)                                   Noted
                      Page 8, line 17 of this chapter states
                      sulphur in natural gas is negligible. If
                      this proposal is not accepted, then the
                      algorithm 20*S should be used - see
                      above.                                     Noted
                      US EPA AP-42 Ch 3.2, Table 3.2-2
    160          380 (rated B)                                   Noted
                      US EPA AP-42 Ch 3.2, Table 3.2-2
     28          110 (rated C)                                   Noted
                      US EPA AP-42 Ch 3.2, Table 3.2-2
  0.011         0.11 (rated D)                                   Noted
                      AP-42 (as above) states that all PM <
  0.011         0.11 1 micron                                    Noted
                      AP-42 (as above) states that all PM <
   0.011        0.11 1 micron                                    Noted
 0.0002     0.0005 ESPREME-Table 25                              Noted
 0.0005       0.001 ESPREME-Table 25                             Noted
   0.001      0.004 ESPREME-Table 25                             Noted
0.00005    0.00015 ESPREME-Table 25                              Noted
   0.002      0.006 ESPREME-Table 25                             Noted
 0.0012     0.0021 ESPREME-Table 25                              Noted
                      ESPREME-Table 24 (called in the
      2             6 FOD under Tier 2)                          Noted
                      ESPREME-Table 24 (called in the
    0.8           1.5 FOD under Tier 2)                          Noted
                      ESPREME-Table 24 (called in the
     10            20 FOD under Tier 2)                          Noted
                      ESPREME-Table 24 (called in the
                      FOD under Tier 2) (not in FOD)             Accepted
                      ESPREME-Table 24 (called in the
    500        1500 FOD under Tier 2)                            Accepted
                      ESPREME-Table 24 (called in the
      3             7 FOD under Tier 2)                          Noted
                      ESPREME-Table 23 (called in the
    1.5           2.5 FOD under Tier 2)                          Noted
                      ESPREME-Table 23 (called in the
      1           1.8 FOD under Tier 2)                          Accepted
                      ESPREME-Table 23 (called in the
      1           1.8 FOD under Tier 2)                          Accepted
                      ESPREME-Table 23 (called in the
      1           1.8 FOD under Tier 2)                          Accepted
                      ESPREME-Table 23 (called in the
      1           1.8 FOD under Tier 2)                          Noted
              ESPREME-Table 23 (called in the
  3         6 FOD under Tier 2)                        Noted
              ESPREME-gas turbines-destillate oil-
  2         6 table 26 (not in FOD)                    Accepted
              ESPREME-gas turbines-destillate oil-
 0.8      1.5 table 26 (not in FOD)                    Noted
              ESPREME-gas turbines-destillate oil-
 10        20 table 26 (not in FOD)                    Noted
              ESPREME-gas turbines-destillate oil-
              table 26 (not in FOD)                    Noted
              ESPREME-gas turbines-destillate oil-
500    1500 table 26 (not in FOD)                      Noted
              ESPREME-gas turbines-destillate oil-
  3         7 table 26 (not in FOD)                    Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 27 (not in
              FOD)                                     Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 27 (not in
  1         5 FOD)                                     Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 27 (not in
  3         9 FOD)                                     Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 27 (not in
  4        10 FOD)                                     Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 27 (not in
 50      100 FOD)                                      Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 27 (not in
 10        20 FOD)                                     Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 28 (not in
 0.2      0.5 FOD)                                     Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 28 (not in
 0.5      1.2 FOD)                                     Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 28 (not in
 1.5        4 FOD)                                     Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 28 (not in
0.05    0.15 FOD)                                      Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 28 (not in
  2         5 FOD)                                     Noted
              ESPREME-gas turbines-natural gas
              and refinery fuel gas-table 28 (not in
  1         3 FOD)                                     Noted
                   US EPA AP-42 Ch 3.1, Table 3.1-1
                   (rated C); present value rounded up to
    0.7       3    one significant figure                   Noted
                   Present value rounded up to one
    0.1      0.6   significant figure                       Noted
                   US EPA AP-42 Ch 3.1, Table 3.1-2a
    0.5       4    (rated C)                                Noted
                   US EPA AP-42 Ch 3.1, Table 3.1-5
                   (rated C); present value rounded up to
  0.001   0.0044   one significant figure                   Noted
                   US EPA AP-42 Ch 3.1, Table 3.1-5
                   (rated C); present value rounded up to
0.00025   0.0011   one significant figure                   Noted
                   EF are much too high being based on
                   1998 data; according to own
                   measurements on power plants the
                   majority of dioxins/furans are not
                   detectable; we suggest to use the
                   EURELECTRIC data of 6E-10                Noted

                   As the EURELECTRIC data are based
                   on more actual measurements the
                   ranges of the EF should be extended
                   to include the EURELECTRIC EF; they
                   should also include the EF calculated
                   in appendix B                         Noted

                   The proposed EF seems too high -
                   under the LCPD plant >500
                   MW(thermal) have an ELV of 50
                   mg/Nm3 (17.5 g/GJ), so the suggested
                   value would seem more appropriate.
                   According to our data, the lower 95%
                   confidence intervals for TSP are too
     2             high. We recommend                       Noted
                   Recalculated from proposed TSP EF
                   factor                                   Noted
                   Recalculated from proposed TSP EF
                   factor                                   Noted
                   EF seems very high - NMVOC
                   emission generally related to
                   combustion conditions and is often
                   below instrument detection limits.
                   Suggest using EURELECTRIC value
                   of 0.4                                   Accepted
                   EF are much too high being based on
                   1998 data; according to own
                   measurements on power plants the
                   majority of dioxins/furans are not
                   detectable; we suggest to use the
                   EURELECTRIC data of 6E-10                Accepted
        The proposed EF seems too high -
        under the LCPD plant >500
        MW(thermal) have an ELV of 50
        mg/Nm3 (17.5 g/GJ), so the suggested
        value would seem more appropriate.
        According to our data, the lower 95%
        confidence intervals for TSP are too
   2    high. We recommend                           Accepted
        Recalculated from proposed TSP EF
        factor                                       Accepted
        Recalculated from proposed TSP EF
        factor                                       Accepted
        EF seems very high - NMVOC
        emission generally related to
        combustion conditions and is often
        below instrument detection limits.
        Suggest using EURELECTRIC value
        of 0.4                                       Accepted

        Lower 95% confidence limit value for
        PM10 is lower than that of PM2.5 -
 0.02   suggest that they should be the same         Accepted
        EF seems very high - NMVOC
        emission generally related to
        combustion conditions and is often
        below instrument detection limits.
        Suggest using EURELECTRIC value
        of 0.5                                       Accepted

        Lower 95% confidence limit value for
        TSP is lower than that of PM10 -
  0.1   suggest that they should be the same         Accepted
        Limit for sulphur in fuel oil is 1% - this
        equates to an emission of around 250
        g/GJ                                         Accepted
        EF given appears to be for a 1.5%
        sulphur fuel - as fuel sulphur has
        decreased so has the heavy metal
        content. Suggest using the
0.001   EURELECTRIC value of 0.002 g/GJ              Accepted
        EF given appears to be for a 1.5%
        sulphur fuel - as fuel sulphur has
        decreased so has the heavy metal
        content. Suggest using the
0.001   EURELECTRIC value of 0.002 g/GJ              Accepted
        EF given appears to be for a 1.5%
        sulphur fuel - as fuel sulphur has
        decreased so has the heavy metal
        content. Suggest using the
0.005   EURELECTRIC value of 0.008 g/GJ              Accepted
         EF given appears to be for a 1.5%
         sulphur fuel - as fuel sulphur has
         decreased so has the heavy metal
         content. Suggest using the
0.0002   EURELECTRIC value of 0.0003 g/GJ        Accepted
         EF given appears to be for a 1.5%
         sulphur fuel - as fuel sulphur has
         decreased so has the heavy metal
         content. Suggest using the
   0.1   EURELECTRIC value of 0.2 g/GJ           Accepted
         EF seems very high - NMVOC
         emission generally related to
         combustion conditions and is often
         below instrument detection limits.
         Suggest using EURELECTRIC value
         of 0.6                                  Accepted

         Lower 95% confidence limit value for
         PM10 is lower than that of PM2.5 -
   0.1   suggest that they should be the same    Accepted
         EF are much too high being based on
         1998 data; according to own
         measurements on power plants the
         majority of dioxins/furans are not
         detectable; we suggest to use the
         EURELECTRIC data of 6E-10               Accepted

         It should be stated which TEF factors
         are used (I-TEF or WHO-TEF)?            Accepted

         The proposed EF seems too high -
         under the LCPD plant >500
         MW(thermal) have an ELV of 50
         mg/Nm3 (17.5 g/GJ), so the suggested
         value would seem more appropriate.
         According to our data, the lower 95%
         confidence intervals for TSP are too
    2    high. We recommend                      Accepted
         Recalculated from proposed TSP EF
         factor                                  Accepted
         Recalculated from proposed TSP EF
         factor                                  Accepted
         EF seems very high - NMVOC
         emission generally related to
         combustion conditions and is often
         below instrument detection limits.
         Suggest using EURELECTRIC value
         of 0.4                                  Accepted
    The proposed EF seems too high -
    under the LCPD plant >500
    MW(thermal) have an ELV of 50
    mg/Nm3 (17.5 g/GJ), so the suggested
    value would seem more appropriate.
    According to our data, the lower 95%
    confidence intervals for TSP are too
2   high. We recommend                     Accepted
    Recalculated from proposed TSP EF
    factor                                 Accepted
    Recalculated from proposed TSP EF
    factor                                 Accepted
    EF are much too high being based on
    1998 data; according to own
    measurements on power plants the
    majority of dioxins/furans are not
    detectable; we suggest to use the
    EURELECTRIC data of 6E-10              Accepted
    EF seems very high - NMVOC
    emission generally related to
    combustion conditions and is often
    below instrument detection limits.
    Suggest using EURELECTRIC value
    of 0.4                                 Accepted

    The proposed EF seems too high -
    under the LCPD plant >500
    MW(thermal) have an ELV of 50
    mg/Nm3 (17.5 g/GJ), so the suggested
    value would seem more appropriate.
    According to our data, the lower 95%
    confidence intervals for TSP are too
2   high. We recommend                   Accepted
    Recalculated from proposed TSP EF
    factor                               Accepted
    Recalculated from proposed TSP EF
    factor                               Accepted

    The proposed EF seems too high -
    under the LCPD plant >500
    MW(thermal) have an ELV of 50
    mg/Nm3 (17.5 g/GJ), so the suggested
    value would seem more appropriate.
    According to our data, the lower 95%
    confidence intervals for TSP are too
2   high. We recommend                   Accepted
    Recalculated from proposed TSP EF
    factor                               Accepted
    Recalculated from proposed TSP EF
    factor                               Accepted
    EF are much too high being based on
    1998 data; according to own
    measurements on power plants the
    majority of dioxins/furans are not
    detectable; we suggest to use the
    EURELECTRIC data of 6E-11              Accepted
    EF seems very high - NMVOC
    emission generally related to
    combustion conditions and is often
    below instrument detection limits.
    Suggest using EURELCETRIC value
    of 0.4                                 Accepted

    The proposed EF seems too high -
    under the LCPD plant >500
    MW(thermal) have an ELV of 50
    mg/Nm3 (17.5 g/GJ), so the suggested
    value would seem more appropriate.
    According to our data, the lower 95%
    confidence intervals for TSP are too
2   high. We recommend                     Accepted
    Recalculated from proposed TSP EF
    factor                                 Accepted
    Recalculated from proposed TSP EF
    factor                                 Accepted
    EF are much too high being based on
    1998 data; according to own
    measurements on power plants the
    majority of dioxins/furans are not
    detectable; we suggest to use the
    EURELECTRIC data of 6E-10              Accepted
    EF seems very high - NMVOC
    emission generally related to
    combustion conditions and is often
    below instrument detection limits.
    Suggest using EURELECTRIC value
    of 0.4                                 Accepted

    The proposed EF seems too high -
    under the LCPD plant >500
    MW(thermal) have an ELV of 50
    mg/Nm3 (17.5 g/GJ), so the suggested
    value would seem more appropriate.
    According to our data, the lower 95%
    confidence intervals for TSP are too
2   high. We recommend                   Accepted
    Recalculated from proposed TSP EF
    factor                               Accepted
    Recalculated from proposed TSP EF
    factor                               Accepted
    EF are much too high being based on
    1998 data; according to own
    measurements on power plants the
    majority of dioxins/furans are not
    detectable; we suggest to use the
    EURELECTRIC data of 6E-10                  Accepted
    EF seems very high - NMVOC
    emission generally related to
    combustion conditions and is often
    below instrument detection limits.
    Suggest using EURELECTRIC value
    of 0.4                                     Accepted

    The proposed EF seems too high -
    under the LCPD plant >500
    MW(thermal) have an ELV of 50
    mg/Nm3 (17.5 g/GJ), so the suggested
    value would seem more appropriate.
    According to our data, the lower 95%
    confidence intervals for TSP are too
2   high. We recommend                   Accepted
    Recalculated from proposed TSP EF
    factor                               Accepted
    Recalculated from proposed TSP EF
    factor                               Accepted

    EF are probably too high being based
    on 1998 data; we have not measured
    these on fluidised bed plants but the
    values are likely to be similar to those
    from PF plants so we suggest using
    the EURELECTRIC data of 6E-10              Accepted

    The proposed EF seems too high -
    under the LCPD plant >500
    MW(thermal) have an ELV of 50
    mg/Nm3 (17.5 g/GJ), so the suggested
    value would seem more appropriate.
    According to our data, the lower 95%
    confidence intervals for TSP are too
2   high. We recommend                   Noted
    Recalculated from proposed TSP EF
    factor                               Noted
    Recalculated from proposed TSP EF
    factor                               Noted

    EF are probably too high being based
    on 1998 data; we have not measured
    these on fluidised bed plants but the
    values are likely to be similar to those
    from PF plants so we suggest using
    the EURELECTRIC data of 6E-10              Noted
                      negative value?                           Noted

                      Page 8, line 17 of this chapter states
                      sulphur in natural gas is negligible.     Noted
                      US EPA AP-42 Ch 3.1, Table 3.1-2a
    0.5          2    (rated C)                                 Noted
                      US EPA AP-42 Ch 3.1, Table 3.1-2a
   0.45        1.8    (rated C)                                 Noted
   0.45        1.8    Assuming all PM < 1 micron                Noted
   0.45        1.8    Assuming all PM < 1 micron                Noted
                      Chemistry, assuming all sulphur
                      converted (values to be multiplied with
   19.9         20    S = wt% S in fuel)                        Noted
                      US EPA AP-42 Ch 3.1, Table 3.1-5
                      (rated C); present value rounded up to
  0.003      0.013    one significant figure                    Noted

                      Lower 95% confidence limit value for
                      PM10 is lower than that of PM2.5 -
    0.1               suggest that they should be the same      Noted
                      Chemistry, assuming all sulphur
                      converted (values to be multiplied with
   19.9         20    S = wt% S in fuel)                        Noted
                      US EPA AP-42 Ch 3.1, Table 3.1-1
                      (rated A); assumed refinery gas
     30         47    equivalent to natural gas                 Noted
                      US EPA AP-42 Ch 3.1, Table 3.1-2a
                      (rated C); assuming refinery gas
    0.5          2    equivalent to natural gas                 Noted
                      US EPA AP-42 Ch 3.1, Table 3.1-2a
   0.45        1.8    (rated C)                                 Noted
   0.45        1.8    Assuming all PM < 1 micron                Noted
   0.45        1.8    Assuming all PM < 1 micron                Noted

                      Lower 95% confidence limit value for
                      TSP is lower than that of PM10 -
     0.1              suggest that they should be the same      Noted
 0.0035       0.007   ESPREME                                   Noted
0.00047     0.0014    ESPREME                                   Noted
0.02142    0.04285    ESPREME                                   Noted
0.00235     0.0047    ESPREME                                   Noted
0.00583    0.01458    ESPREME                                   Noted
 0.0175       0.035   ESPREME                                   Noted
0.00439    0.02196    ESPREME                                   Noted
0.00439    0.02635    ESPREME                                   Noted
0.00779    0.03897    ESPREME                                   Noted
0.00062     0.0025    ESPREME                                   Noted
0.02196    0.13174    ESPREME                                   Noted
0.01757    0.10539    ESPREME                                   Noted
0.72248    1.44496    ESPREME                                   Noted
0.72248    2.88991    ESPREME                                   Noted
16.5138    33.0276    ESPREME                                   Noted
0.09064 0.36257 ESPREME                                     Noted
7.22479 43.3487 ESPREME                                     Noted
2.16744 6.50231 ESPREME                                     Noted
     0.4     0.6 ESPREME                                    Noted
     0.3     0.5 ESPREME                                    Noted
    0.05     0.2 ESPREME                                    Noted
                 Hjortenkrans et al. 2007, Uexküll et al.
                 2005, Warner et al. 2002, Westerlund
                 2001, Legret & Pagotto 1999,
                 Stechmann 1993, Hildemann et al.
     1.6       6 1991, Heinrichs 1993                       Noted
                 Hjortenkrans et al. 2007, Uexküll et al.
                 2005, Warner et al. 2002, Westerlund
                 2001, Legret & Pagotto 1999,
                 Stechmann 1993, Hildemann et al.
     1.4       9 1991, Heinrichs 1993                       Noted
                 Hjortenkrans et al. 2007, Uexküll et al.
                 2005, Warner et al. 2002, Westerlund
                 2001, Legret & Pagotto 1999,
                 Stechmann 1993, Hildemann et al.
       2      61 1991, Heinrichs 1993                       Noted
                 Hjortenkrans et al. 2007, Uexküll et al.
                 2005, Warner et al. 2002, Westerlund
                 2001, Legret & Pagotto 1999,
                 Stechmann 1993, Hildemann et al.
     2.4      63 1991, Heinrichs 1993                       Noted
                 Hjortenkrans et al. 2007, Uexküll et al.
                 2005, Warner et al. 2002, Westerlund
                 2001, Legret & Pagotto 1999,
                 Stechmann 1993, Hildemann et al.
     6.3    670 1991, Heinrichs 1993                        Noted
                 Hjortenkrans et al. 2007, Uexküll et al.
                 2005, Warner et al. 2002, Westerlund
                 2001, Legret & Pagotto 1999,
                 Stechmann 1993, Hildemann et al.
      10    130 1991, Heinrichs 1993                        Noted
                 Hjortenkrans et al. 2007, Uexküll et al.
                 2005, Warner et al. 2002, Westerlund
                 2001, Legret & Pagotto 1999,
                 Stechmann 1993, Hildemann et al.
     1.5      57 1991, Heinrichs 1993                       Noted
                 Hjortenkrans et al. 2007, Uexküll et al.
                 2005, Warner et al. 2002, Westerlund
                 2001, Legret & Pagotto 1999,
                 Stechmann 1993, Hildemann et al.
114.938    8050 1991, Heinrichs 1993                        Noted
                 Hjortenkrans et al. 2007, Uexküll et al.
                 2005, Warner et al. 2002, Westerlund
                 2001, Legret & Pagotto 1999,
                 Stechmann 1993, Hildemann et al.
      80    660 1991, Heinrichs 1993                        Noted
                  Hjortenkrans et al. 2007, Uexküll et al.
                  2005, Warner et al. 2002, Westerlund
                  2001, Legret & Pagotto 1999,
                  Stechmann 1993, Hildemann et al.
   120    20000   1991, Heinrichs 1993                       Noted
                  TNO 2001, BUWAL 1992, Gebbe et al.
                  1997, CARB 1993, Garben et al. 1996,
                  Baumann 1997, Legret and Pagotto
  0.017    0.12   1999, Lükewille et al. 2001                Noted
                  TNO 2001, BUWAL 1992, Gebbe et al.
                  1997, CARB 1993, Garben et al. 1996,
                  Baumann 1997, Legret and Pagotto
0.00255   0.018   1999, Lükewille et al. 2001                Noted
                  TNO 2001, BUWAL 1992, Gebbe et al.
                  1997, CARB 1993, Garben et al. 1996,
                  Baumann 1997, Legret and Pagotto
0.00014 0.00096   1999, Lükewille et al. 2001                Noted
                  TNO 2001, BUWAL 1992, Gebbe et al.
                  1997, CARB 1993, Garben et al. 1996,
                  Baumann 1997, Legret and Pagotto
  0.034   0.768   1999, Lükewille et al. 2001                Noted
                  TNO 2001, BUWAL 1992, Gebbe et al.
                  1997, CARB 1993, Garben et al. 1996,
                  Baumann 1997, Legret and Pagotto
0.00272 0.06144   1999, Lükewille et al. 2001                Noted
                  TNO 2001, BUWAL 1992, Gebbe et al.
                  1997, CARB 1993, Garben et al. 1996,
                  Baumann 1997, Legret and Pagotto
0.00014 0.00307   1999, Lükewille et al. 2001                Noted
                  Garg et al. 2000, Legret&Pagotto
                  1999, Warner et al. 2002, Rauterberg-
                  Wulff 1998, Johansson et al. 1998,
                  Westerlund 2001, Buwal 2001, TNO
0.00179    0.02   2001                                       Noted
                  Garg et al. 2000, Legret&Pagotto
                  1999, Warner et al. 2002, Rauterberg-
                  Wulff 1998, Johansson et al. 1998,
                  Westerlund 2001, Buwal 2001, TNO
0.00158 0.01761   2001                                       Noted
                  Garg et al. 2000, Legret&Pagotto
                  1999, Warner et al. 2002, Rauterberg-
                  Wulff 1998, Johansson et al. 1998,
                  Westerlund 2001, Buwal 2001, TNO
 0.0008 0.00891   2001                                       Noted
                  Garg et al. 2000, Legret&Pagotto
                  1999, Warner et al. 2002, Rauterberg-
                  Wulff 1998, Johansson et al. 1998,
                  Westerlund 2001, Buwal 2001, TNO
0.00347    0.09   2001                                       Noted
                      Garg et al. 2000, Legret&Pagotto
                      1999, Warner et al. 2002, Rauterberg-
                      Wulff 1998, Johansson et al. 1998,
                      Westerlund 2001, Buwal 2001, TNO
0.00306 0.07924       2001                                    Noted
                      Garg et al. 2000, Legret&Pagotto
                      1999, Warner et al. 2002, Rauterberg-
                      Wulff 1998, Johansson et al. 1998,
                      Westerlund 2001, Buwal 2001, TNO
0.00155    0.04009    2001                                    Noted
7.77791    15.5558    ESPREME                                 Noted
7.77791    31.1116    ESPREME                                 Noted
177.781    355.561    ESPREME                                 Noted
 0.8004    3.20158    ESPREME                                 Noted
77.7791    466.674    ESPREME                                 Noted
23.3337    70.0012    ESPREME                                 Noted
0.00011    0.00028    ESPREME                                 Noted
0.00011    0.00028    ESPREME                                 Noted
0.00889    0.02222    ESPREME                                 Noted
0.00556    0.01667    ESPREME                                 Noted
0.00011    0.00028    ESPREME                                 Noted
0.00056    0.00167    ESPREME                                 Noted
    0.03        0.1   Guidebook 2006. unit mg/GJ              Noted
                                                              Noted
                      Guidebook 2006, unit mg/GJ              Noted

                      ERROR IN COPY FROM "OLD" GB or
                      wrong reference                Accepted

                      ERROR IN COPY FROM "OLD" GB or
                      wrong reference                Accepted

                      ERROR IN COPY FROM "OLD" GB
                      *** Proposed value > PM10 one           Accepted

                      ERROR IN COPY FROM "OLD" GB
                      or wrong reference                      Accepted

                      ERROR IN COPY FROM "OLD" GB or
                      wrong reference                Accepted

                      ERROR IN COPY FROM "OLD" GB or
                      wrong reference                Accepted

                      ERROR IN COPY FROM "OLD" GB or
                      wrong reference                Accepted

                      I WE SPEAK ABOUT "NATURAL"
                      GAS EF=0, if we speak of other gases
                      (i.e. LPG) then mut be declared      Noted
                      ERROR IN COPY FROM "OLD" GB or
                      wrong reference                      Noted
             EF of old GB has less uncertainty             Noted
             EF of old GB has less uncertainty             Noted
             EF of old GB has less uncertainty             Noted
             It's inaudite that consultant it's not able
             to copy "old" in "new" Efs                    Noted
             It's inaudite that consultant it's not able
             to copy "old" in "new" Efs                    Noted
             It's inaudite that consultant it's not able
             to copy "old" in "new" Efs                    Noted
             ERROR IN COPY FROM "OLD" GB or
             wrong reference                               Noted
             Guidebook 2006, unit g/GJ                     Noted
                                                           Accepted
 0.4     0.6 ESPREME                                       Noted
 0.2     0.4 ESPREME                                       Noted
 0.1     0.3 ESPREME                                       Noted
             estimated fraction of PM by US EPA
 45     180 data                                           Accepted
             estimated fraction of PM by US EPA
 40     160 data                                           Accepted
             Upper limit as per Table 3-1 of this
 0.1     0.4 NFR                                           Accepted

             Refinery BREF provides a range of
             abatementefficiencies for cyclones
             between 30% and 90%Propose lower
             limit set to BREF value.Propose default
 0.3     0.9 efficiency is taken at mid range        Accepted
           0 ARPAT, 2007                             Accepted

              ARPAT, 2007 Note that the proposed
              value is wrong! The reference quoted
              say: "While geothermal plants do not
              emit sulfur dioxide directly, once
              hydrogen sulfide is released as a gas
              into the atmosphere, it spreads into the
              air and eventually changes into              Accepted
800     9000 ARPAT, 2007                                   Accepted
              ARPAT, 2007                                  Accepted
              ARPAT, 2007                                  Accepted
              ARPAT, 2007                                  Accepted
0.26      1.3 ARPAT, 2007                                  Accepted
0.02   0.045 ARPAT, 2007                                   Accepted
              Guidebook 2006                               Accepted



 0.7     0.9 ESPREME                                       Rejected



 0.1     0.2 ESPREME                                       Rejected
0.01      0.1 ESPREME                                      Rejected
              BREF "Large Volume Inorganic
              Chemicals - Solids and Other Industry
              (LVIC - SAO) October 2006, chapter
 0.6      1.5 2.3.3.5), unit kg/ton                        Accepted
              used EF of german NIR, referenced on
              VDI 2283 Aufbereitungsanlagen für
              Asphaltmischgut                              Accepted
              Average of measurements coming
              from members of the federation (only
1360    2170 flat glass)                                   Accepted
              Average of measurements coming
              from members of the federation (only
              flat glass), lower limit = below detection
         0.18 limit                                        Accepted
              Average of measurements coming
              from members of the federation (only
              flat glass), lower limit = below detection
         0.25 limit                                        Accepted
              Average of measurements coming
              from members of the federation (only
0.01     0.13 flat glass)                                  Accepted
              Average of measurements coming
              from members of the federation (only
              flat glass), lower limit = below detection
       0.011 limit                                         Accepted
              Average of measurements coming
              from members of the federation (only
              flat glass), lower limit = below detection
       0.039 limit                                         Accepted
              Average of measurements coming
              from members of the federation (only
0.54     0.97 flat glass)                                  Accepted
              Average of measurements coming
              from members of the federation (only
0.23     0.68 flat glass)                                  Accepted
              Average of measurements coming
              from members of the federation (only
0.02      0.4 flat glass)                                  Accepted
              Average of measurements coming
              from members of the federation (only
0.13     0.56 flat glass)                                  Accepted

             unpublished report on emission factors
             of the German glas and mineral fibre
             industry for the year 2005             Accepted
                   unpublished report on emission factors
                   of the German glas and mineral fibre
                   industry for the year 2005             Accepted

                   unpublished report on emission factors
                   of the German glas and mineral fibre
                   industry for the year 2005               Accepted
                   ESPREME - chlorine-Tier 1 (not in
                   FOD)                                     Accepted
                   ESPREME - chlorine-Tier 1 (not in
                   FOD)                                     Accepted
                   ESPREME - chlorine-Tier 1 (not in
                   FOD)                                     Accepted
                   ESPREME - chlorine-Tier 1 (not in
                   FOD)                                     Accepted
                   ESPREME-Chlor alkali production          Accepted
                   ESPREME-(called in the FOD under
1.78944 5.36831    Tier 2)                                  Accepted
                   ESPREME-(called in the FOD under
0.00895 0.02684    Tier 2)                                  Accepted
                   ESPREME-(called in the FOD under
0.00179 0.00537    Tier 2)                                  Accepted
                   ESPREME-(called in the FOD under
   1.15     3.45   Tier 2)                                  Accepted
                   ESPREME-(called in the FOD under
0.05368 0.16105    Tier 2)                                  Accepted
                   ESPREME-(called in the FOD under
0.01225 0.03676    Tier 2)                                  Accepted
                   ESPREME - Electric arc -Tier 1 (not in
0.14511 0.29021    FOD)                                     Accepted
                   ESPREME - Electric arc -Tier 1 (not in
   1.15     3.45   FOD)                                     Accepted
                   ESPREME - Electric arc -Tier 1 (not in
0.03794 0.05691    FOD)                                     Accepted
                   ESPREME - Electric arc -Tier 1 (not in
0.21766   1.0883   FOD)                                     Accepted
                   ESPREME - Electric arc -Tier 1 (not in
 1.0883 4.35318    FOD)                                     Accepted
                   ESPREME - Basic oxygen-Tier 1 (not
0.26713 0.53426    in FOD)                                  Accepted
                   ESPREME - Basic oxygen-Tier 1 (not
0.05343 0.08014    in FOD)                                  Accepted
                   ESPREME - Basic oxygen-Tier 1 (not
1.53333 3.06667    in FOD)                                  Accepted
                   ESPREME - Basic oxygen-Tier 1 (not
0.00069 0.00206    in FOD)                                  Accepted
                   ESPREME - Basic oxygen-Tier 1 (not
0.06678 0.66782    in FOD)                                  Accepted
                   ESPREME - Basic oxygen-Tier 1 (not
2.67128 6.67819    in FOD)                                  Accepted
                  ESPREME - open hearth furnace-Tier
     8         15 1 (not in FOD)                     Accepted



    0.6        0.8 ESPREME                                   Rejected



    0.2         0.4 ESPREME                                  Rejected
                    ESPREME -pig iron-Tier 1 (not in
6.9E-05   0.00021 FOD)                                       Accepted
                    ESPREME                                  Rejected
                    ESPREME -pig iron-Tier 1 (not in
                    FOD)                                     Accepted
                    ESPREME - Electric arc -Tier 1 (not in
0.00726   0.02177 FOD)                                       Rejected
                    ESPREME -pig iron-Tier 1 (not in
   1.15       3.45 FOD)                                      Accepted
                    ESPREME - open hearth furnace-Tier
   200         500 1 (not in FOD)                            Accepted
                    ESPREME -pig iron-Tier 1 (not in
                    FOD)                                     Rejected
                    ESPREME -pig iron-Tier 1 (not in
 0.0003   0.00091 FOD)                                       Accepted
                    ESPREME - cast iron-Tier 1 (not in
                    FOD)                                     Rejected
                    ESPREME - cast iron-Tier 1 (not in
 9E-05    0.00015 FOD)                                       Accepted
                    ESPREME - cast iron-Tier 1 (not in
                    FOD)                                     Rejected
                    ESPREME - cast iron-Tier 1 (not in
                    FOD)                                     Rejected
                    ESPREME - cast iron-Tier 1 (not in
 0.0048   0.00719 FOD)                                       Accepted
                    ESPREME - cast iron-Tier 1 (not in
 0.0018    0.0042 FOD)                                       Accepted
                    ESPREME - open hearth furnace-Tier
    20           50 1 (not in FOD)                           Accepted
                    ESPREME - open hearth furnace-Tier
    0.5         1.5 1 (not in FOD)                           Accepted
                    ESPREME - open hearth furnace-Tier
1.53333   3.83333 1 (not in FOD)                             Accepted
                    ESPREME - open hearth furnace-Tier
                    1 (not in FOD)                           Rejected
                    ESPREME -pig iron-Tier 1 (not in
                    FOD)                                     Rejected
                    ESPREME - primary copper-Tier 1
                    The unit (g/Mg) aluminium should be
26.3385   52.9057 corrected in g/Mg copper                   Accepted
                  ESPREME - primary copper-Tier 1
                  The unit (g/Mg) aluminium should be
9.01773 18.6072   corrected in g/Mg copper                 Accepted
                  ESPREME - primary copper-Tier 1
                  The unit (g/Mg) aluminium should be
10.9184 21.8367   corrected in g/Mg copper                 Accepted
                  ESPREME - primary copper-Tier 1
                  The unit (g/Mg) aluminium should be
0.01557 0.03891   corrected in g/Mg copper                 Accepted
                  ESPREME - primary copper-Tier 1
                  The unit (g/Mg) aluminium should be
8.74614 21.8725   corrected in g/Mg copper                 Accepted
                  ESPREME - primary copper-Tier 1
                  (called in the FOD under Tier 2) - The
                  unit (g/Mg aluminium) should be
11.6425 23.2849   corrected in g/Mg copper                 Accepted
                  ESPREME - primary copper-Tier 1
                  The unit (g/Mg) aluminium should be
101.613 275.472   corrected in g/Mg copper                 Accepted
                  ESPREME - primary copper-Tier 1
                  (called in the FOD under Tier 2) - The
                  unit (g/Mg aluminium) should be
14.5578 29.1156   corrected in g/Mg copper                 Accepted
                  ESPREME - primary copper-Tier 1
                  (called in the FOD under Tier 2) - The
                  unit (g/Mg aluminium) should be
0.02075 0.05189   corrected in g/Mg copper                 Accepted
                  ESPREME - primary copper-Tier 1
                  (called in the FOD under Tier 2) - The
                  unit (g/Mg aluminium) should be
11.6425 29.1062   corrected in g/Mg copper                 Accepted
                  ESPREME - primary copper-Tier 1
                  (called in the FOD under Tier 2) - The
                  unit (g/Mg aluminium) should be
116.425 291.062   corrected in g/Mg copper                 Accepted
                  ESPREME - secondary copper-Tier 1
0.57176 2.05834   (not in FOD)                             Accepted
                  ESPREME - secondary copper-Tier 1
1.14352 4.57409   (not in FOD)                             Accepted
                  ESPREME - secondary copper-Tier 1
                  (not in FOD)                             Rejected
                  ESPREME - secondary copper-Tier 1
                  (not in FOD)                             Rejected
                  ESPREME - secondary copper-Tier 1
0.05718 0.17153   (not in FOD)                             Accepted
                  ESPREME - secondary copper-Tier 1
57.1762 228.705   (not in FOD)                             Accepted
                  ESPREME - primary copper-Tier 1
                  (called in the FOD under Tier 2) - The
                  unit (g/Mg aluminium) should be
34.9274 69.8548   corrected in g/Mg copper                 Accepted
                    ESPREME - secondary lead-Tier 1
                    (not in FOD)                            Rejected
                    ESPREME - secondary lead-Tier 1
                    (not in FOD)                            Rejected
                    ESPREME - secondary lead-Tier 1
146.871 587.485     (not in FOD)                            Accepted
                    ESPREME - secondary lead-Tier 1
0.73436 2.93742     (not in FOD)                            Accepted
                    ESPREME - secondary lead-Tier 1
2.20307 5.14049     (not in FOD)                            Accepted
                    ESPREME - secondary lead-Tier 1
                    (not in FOD)                            Rejected
 0.5583 1.3002      ESPREME - primary lead-Tier 1           Accepted
0.22128 0.80973     ESPREME - primary lead-Tier 1           Accepted
                    ESPREME - primary lead-Tier 1           Rejected
0.55525 0.83288     ESPREME - primary lead-Tier 1           Accepted
                    ESPREME - primary lead-Tier 1           Rejected
42.9988 159.433     ESPREME - primary lead-Tier 1           Accepted
                    ESPREME - primary lead-Tier 1 (called
0.01005    0.0201   in the FOD under Tier 2)                Accepted
                    ESPREME - primary lead-Tier 1 (called
0.05025    0.1005   in the FOD under Tier 2)                Accepted
                    ESPREME - primary lead-Tier 1 (called
                    in the FOD under Tier 2)                Rejected
                    ESPREME - primary lead-Tier 1 (called
0.74034 1.11051     in the FOD under Tier 2)                Accepted
                    ESPREME - primary lead-Tier 1 (called
                    in the FOD under Tier 2)                Rejected
                    ESPREME - primary lead-Tier 1 (called
8.37472 16.7494     in the FOD under Tier 2)                Accepted



    0.7       0.9 ESPREME-primary lead                      Rejected



   0.05      0.15 ESPREME-primary lead                      Rejected



   0.01       0.15 ESPREME-primary lead                     Rejected
                   ESPREME - primary zinc-Tier 1 (called
                   in the FOD under Tier 2)                 Rejected
 0.0608   0.18239 ESPREME - primary zinc-Tier 1             Accepted
1.13487   3.93152 ESPREME - primary zinc-Tier 1             Accepted
                   ESPREME - primary zinc-Tier 1            Rejected
1.51447   6.05709 ESPREME - primary zinc-Tier 1             Accepted
                   ESPREME - primary zinc-Tier 1            Rejected
4.45843   27.5613 ESPREME - primary zinc-Tier 1             Accepted
                   ESPREME - primary zinc-Tier 1 (called
                   in the FOD under Tier 2)                 Rejected
                ESPREME - primary zinc-Tier 1 (called
0.97275 3.89101 in the FOD under Tier 2)                    Accepted
                ESPREME - primary zinc-Tier 1 (called
2.01822 8.07289 in the FOD under Tier 2)                    Accepted
                ESPREME - primary zinc-Tier 1 (called
4.86376 34.0463 in the FOD under Tier 2)                    Accepted
                ESPREME - secondary zinc-Tier 1 (not
0.24318 0.72955 in FOD)                                     Accepted
                ESPREME - secondary zinc-Tier 1 (not
1.62121 4.05304 in FOD)                                     Accepted
                ESPREME - secondary zinc-Tier 1 (not
                in FOD)                                     Accepted
                ESPREME - secondary zinc-Tier 1 (not
0.00323 0.00968 in FOD)                                     Accepted
                ESPREME - secondary zinc-Tier 1 (not
                in FOD)                                     Accepted
                ESPREME - secondary zinc-Tier 1 (not
3.24243 8.10607 in FOD)                                     Accepted
                ESPREME - primary zinc-Tier 1 (called
                in the FOD under Tier 2)                    Accepted



    0.7      0.9 ESPREME-zinc                               Rejected



    0.1      0.2 ESPREME-zinc                               Rejected



   0.01       0.1 ESPREME-zinc                              Rejected
                  The Emission factor is specific for
                  Germany; Reference: J. Theloke.
                  NMVOC-Emissionen aus der
                  Lösemittelanwendung und
                  Möglichkeiten zu ihrer Minderung. Fort-
                  schritt-Berichte VDI Reihe 15 Nr. 252.
                  Düsseldorf: VDI-Verlag, (Dissertation),   Consult with
      5     1900 2005                                       Expert Panel
                  The Emission factor is specific for
                  Germany; Reference: J. Theloke.
                  NMVOC-Emissionen aus der
                  Lösemittelanwendung und
                  Möglichkeiten zu ihrer Minderung. Fort-
                  schritt-Berichte VDI Reihe 15 Nr. 252.
                  Düsseldorf: VDI-Verlag, (Dissertation),   Consult with
     66      530 2005                                       Expert Panel
          The Emission factor is specific for
          Germany; Reference: J. Theloke.
          NMVOC-Emissionen aus der
          Lösemittelanwendung und
          Möglichkeiten zu ihrer Minderung. Fort-
          schritt-Berichte VDI Reihe 15 Nr. 252.
          Düsseldorf: VDI-Verlag, (Dissertation), Consult with
60    200 2005                                    Expert Panel

          g/m2 European Commission (2006d),
          Integrated Pollution Prevention and
          Control (IPPC), Reference Document
          on Best Available Techniques (BREF)
          for the Surface Treatment of Metals
          and Plastics, August 2006           Accepted

          electronic components kg/t wafer Carlo
          Trozzi (Private Communication, 2008)     Accepted
          g/m2 060311 Adhesive Tape
          Manufacturing (BREF)                     Accepted
          http://www.ssb.no/emner/01/04/10/rap
          p_emissions/rapp_200738_en/rapp_20
          0738_en.pdf page 110, tabel 7.2, unit
          = kg/ton                                 Rejected
          http://www.ssb.no/emner/01/04/10/rap
          p_emissions/rapp_200738_en/rapp_20
          0738_en.pdf page 110, tabel 7.2, unit
          = kg/ton                                 Accepted
          http://www.ssb.no/emner/01/04/10/rap
          p_emissions/rapp_200738_en/rapp_20
          0738_en.pdf page 110, tabel 7.2, unit
          = kg/ton                                 Accepted
          http://www.ssb.no/emner/01/04/10/rap
          p_emissions/rapp_200738_en/rapp_20
          0738_en.pdf page 110, tabel 7.2, unit
          = kg/ton                                 Accepted



0.1   0.3 ESPREME                               Rejected
          http://www.ssb.no/emner/01/04/10/rap
          p_emissions/rapp_200738_en/rapp_20
          0738_en.pdf page 110, tabel 7.2, unit
          = kg/ton                              Rejected
          http://www.ssb.no/emner/01/04/10/rap
          p_emissions/rapp_200738_en/rapp_20
          0738_en.pdf page 110, tabel 7.2, unit
          = kg/ton                              Rejected

          http://www.ssb.no/emner/01/04/10/rap
          p_emissions/rapp_200738_en/rapp_20
          0738_en.pdf page 110, tabel 7.2      Accepted
    0.1      0.3 ESPREME                              Rejected



    0.5      0.7 ESPREME                               Rejected
                 http://www.ssb.no/emner/01/04/10/rap
                 p_emissions/rapp_200738_en/rapp_20
                 0738_en.pdf page 110, tabel 7.2, unit
                 = kg/ton                              Accepted

0.04837 0.14511 ESPREME                               Accepted

                 ESPREME                              Rejected

0.06302 0.11817 ESPREME                               Rejected

0.04837 0.19349 ESPREME                               Accepted

0.48371 1.93486 ESPREME                               Accepted

0.00967 0.01935 ESPREME                              Accepted
                http://www.ssb.no/emner/01/04/10/rap
                p_emissions/rapp_200738_en/rapp_20
                0738_en.pdf, page 112                Accepted


                 http://www.ssb.no/emner/01/04/10/rap
                 p_emissions/rapp_200738_en/rapp_20
                 0738_en.pdf page 112                 Accepted
Action taken             Comments
                         Need to address Sulphur emissions - will
                         replace with S = wt%S in fuel and default
                         EF using default sulphur content (made
                         explicit in text)

Replaced with AP42 Efs

Replaced with AP42 Efs

Replaced with AP42 Efs
Replaced with AP42 Efs
Replaced with AP42 Efs
Replaced with AP42 Efs
Replaced with AP42 Efs

Replaced with AP42 Efs
Replaced with AP42 Efs

                         Robert - please can you look into this




                         Robert - please can you look into this

Done

Done

Done

Done

Done
I-TEF
See first comment
See first comment
See first comment
See first comment
See first comment
Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.
Not included at this stage. Could be done at
later stage.


Not included at this stage. Could be done at
later stage.


Not included at this stage. Could be done at
later stage.


Not included at this stage. Could be done at
later stage.


Not included at this stage. Could be done at
later stage.


Not included at this stage. Could be done at
later stage.


Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.



Not included at this stage. Could be done at
later stage.
                                            Not included at this stage. Could be done at
                                            later stage.



                                            Not included at this stage. Could be done at
                                            later stage.




Old' Guidebook references will all be
updated and referenced to original source   Done

Old' Guidebook references will all be
updated and referenced to original source   Done

Old' Guidebook references will all be
updated and referenced to original source   Done

Old' Guidebook references will all be
updated and referenced to original source   Done

Old' Guidebook references will all be
updated and referenced to original source   Done

Old' Guidebook references will all be
updated and referenced to original source   Done

Old' Guidebook references will all be
updated and referenced to original source   Done
Updated

Updated

Updated




Updated
Value = 0, so not taken into account




Updated
Updated
Value = 0, so not taken into account
Value = 0, so not taken into account
Value = 0, so not taken into account
Updated
Updated
Updated
                                       Not included yet. Is not one of the pollutants
                                       in the protocol. Perhaps this can be
                                       included in separate (not Tier 1/2 tables)
                                       somewhere in the text?
                                       Not included yet. Is not one of the pollutants
                                       in the protocol. Perhaps this can be
                                       included in separate (not Tier 1/2 tables)
                                       somewhere in the text?
Not included yet. Is not one of the pollutants
in the protocol. Perhaps this can be
included in separate (not Tier 1/2 tables)
somewhere in the text?




95% confidence interval estimated
           95% confidence interval estimated



           95% confidence interval estimated

accepted   ESPREME list only EF's for mercury

accepted   ESPREME list only EF's for mercury

accepted   ESPREME list only EF's for mercury

accepted   ESPREME list only EF's for mercury
accepted
Not included yet. Is not one of the pollutants
in the protocol. Perhaps this can be
included in separate (not Tier 1/2 tables)
somewhere in the text?
Not included yet. Is not one of the pollutants
in the protocol. Perhaps this can be
included in separate (not Tier 1/2 tables)
somewhere in the text?


Value = 0



No value




No value



No value



No value

No value




No value

No value
No value

No value
No value

No value




No value


No value

No value




No value



No value


Not included yet. Is not one of the pollutants
in the protocol. Perhaps this can be
included in separate (not Tier 1/2 tables)
somewhere in the text?
Not included yet. Is not one of the pollutants
in the protocol. Perhaps this can be
included in separate (not Tier 1/2 tables)
somewhere in the text?
Not included yet. Is not one of the pollutants
in the protocol. Perhaps this can be
included in separate (not Tier 1/2 tables)
somewhere in the text?

No value


No value

No value


No value
                                        No value



                                        No value




                                        Not included yet. Is not one of the pollutants
                                        in the protocol. Perhaps this can be
                                        included in separate (not Tier 1/2 tables)
                                        somewhere in the text?
                                        Not included yet. Is not one of the pollutants
                                        in the protocol. Perhaps this can be
                                        included in separate (not Tier 1/2 tables)
                                        somewhere in the text?
                                        Not included yet. Is not one of the pollutants
                                        in the protocol. Perhaps this can be
                                        included in separate (not Tier 1/2 tables)
                                        somewhere in the text?




Not included for now. GAINS weighted    Should we use this as the Tier 1? Or the
average over all countries seems more   weighted average of GAINS as we have
appropriate as Tier 1                   now?




Not included for now. GAINS weighted    Should we use this as the Tier 1? Or the
average over all countries seems more   weighted average of GAINS as we have
appropriate as Tier 1                   now?
Not included for now. GAINS weighted    Should we use this as the Tier 1? Or the
average over all countries seems more   weighted average of GAINS as we have
appropriate as Tier 1                   now?




                                        I suppose NMVOC is meant (COV?)
Added to chapter and database           EF is for boat building


Added to chapter and database           I suppose NMVOC is meant (COV?)

Added to chapter and database



                                        No idea what this means



Inserted



Inserted



Inserted
                                        Not included yet. Is not one of the pollutants
                                        in the protocol. Perhaps this can be
                                        included in separate (not Tier 1/2 tables)
                                        somewhere in the text?



                                        GHG



                                        GHG



HMs included where EF available
               Not included yet. Is not one of the pollutants
               in the protocol. Perhaps this can be
               included in separate (not Tier 1/2 tables)
               somewhere in the text?
               Not included yet. Is not one of the pollutants
               in the protocol. Perhaps this can be
               included in separate (not Tier 1/2 tables)
               somewhere in the text?



Inserted

Inserted

               No new value suggested

               BREF value used instead

Inserted

Inserted

Inserted


EFs included




EFs included

				
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