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Final Review Report 2018 Second phase of review of national air pollution emission inventory data pursuant to the Directive on the Reduction of National Emissions of Certain Atmospheric Pollutants (Directive (EU) 2016/2284 or ‘NECD’) Belgium 30 November 2018 1

Transcript of Introduction - European Commissionec.europa.eu/.../2018NECD-FinalReviewReport_Belgium_v1.docx ·...

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Final Review Report2018

Second phase of review of national air pollution emission

inventory data pursuant to the Directive on the Reduction of

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

Belgium30 November 2018

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

Umweltbundesamt GmbHSpittelauer Lände 5

1090 ViennaAustria

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

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

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

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

V. Findings and Conclusions from the Technical Expert Review Team (TERT) for the first phase of the in-depth review of national emission inventories of POPs and heavy metals........................................26

VI. Cross cutting recommendations on HMs and POPs....................................................................32

VII. Effect of revised estimates, technical corrections and adjustments recommended to be approved on the national total and national total for compliance.........................................................32

VIII. Statement from Belgium on the conclusions presented by the TERT.........................................34

IX. Findings and Conclusions from the Technical Expert Review Team (TERT) for the Review of adjustment applications.........................................................................................................................35

ANNEX I Technical corrections deemed necessary by the TERT and revised estimates provided by Belgium...................................................................................................................................................36

ANNEX II Review of the 2018 adjustment application of Belgium: TERT report for the EC....................40

References and Supporting Documents.................................................................................................46

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List of tablesTable 1: Scope of the comprehensive technical review NECD 2018 (under (EU) 2016/2284)..................8Table 2: Recommendations from the NECD Review 2017, considering revised estimates (RE), technical corrections (TC) and their status of implementation in the inventory submission 2018........................10Table 3: Additional recommendations made during the NECD Review 2018 for NOX, NMVOC, SOX, NH3, PM2.5 considering revised estimates (RE), technical corrections (TC).....................................................25Table 4: Recommendations from the NECD Review 2018 concerning the first phase of the in-depth review of national emission inventories of POPs and heavy metals.......................................................27Table 5: National totals as reported and national totals including revised estimates (RE), technical corrections (TC) and adjustments for NOX, NMVOC, SOX, NH3, PM2.5 .....................................................32Table 6: Summary tables of Technical Corrections and/or Revised Estimates........................................36Table 1: Summary information on the Submitted Adjustment Applications, Belgium, 2018..................40Table 2: The 2018 Review team of new and previously accepted adjustment applications...................42Table 3: Conclusions and recommendations from the review team on previously accepted adjustment applications............................................................................................................................................43Table 4: Recommendations following the 2018 review of new and previously accepted adjustment applications............................................................................................................................................45Table 5: Information Provided by Belgium.............................................................................................45Table 6: Additional Information Provided by Belgium............................................................................46

Abbreviations

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

c. an expert review of

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

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

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

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

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

8. For the first phase of the in-depth review of national emission inventories of POPs and heavy metals the TERT focused on the completeness and consistency in the emission reporting of PAHs, dioxins/furans, PCBs, HCB, Cd, Hg and Pb with special emphasis on the review of identified key categories.

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

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

11. The review was split in two phases:

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

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

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

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

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

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

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

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

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

Element Scope Further information

Member StatesEU geographical coverage of the Member State

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

Years

Issues raised in 2017 review:2005, 2010, 2015, 2016HMs and POPs:1990, 2005, 2016

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

Pollutants

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

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

According to NECD Article 1(1)

Categories

All NFR categories, including selected memo items

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

National totals

National total and National total for compliance

Rows 141 and 144 in Annex I to reporting Guidelines

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

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

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

18. Belgium did not provide any resubmission.

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

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

b. Technical corrections and revised estimates: Belgium implemented some of the technical corrections and revised estimates from the NECD Review 2017. Those technical corrections and revised estimates not fully implemented have been passed to the Commission which, in accordance with Article 10.3 last subparagraph of Directive 2016/2284, may adopt a decision laying down the technical corrections to be applied. The TERT were not satisfied with the implementation of 2 technical corrections from the 2017 NECD review but notes that they are either below the threshold of significance for a technical correction or related to a transparency issue in the IIR.

20. The TERT noted that there were no recommendations which have not been implemented related to the use of the 2013 EMEP/EEA Guidebook following the NECD review 2017.

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

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

Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC4

GB 2016 Issue5

2017 BE-1A1a-2018-0001

Yes 1A1a Public Electricity and Heat Production, SO2, 2000-2015

For 1A1a Public Electricity and Heat Production, SO2, 2000-2015, the TERT noted that for the Flemish region, the IIR page 51 states that 'the calculation of SO2 emissions originating from installations not equipped with continuous measurements is not applicable: it concerns gas turbines, CHP (combined heat and power), gas motors or turbojets'. The TERT understands that Belgium considers the SO2 EF to be zero for fuel with very low sulphur content. In response to a question raised during the review, Belgium explained that fuels with low sulphur content are natural gas in gas turbines, CHP and gas motors and lamp oil in turbojets. For other fuels, no EFs are used because SO2 emissions are measured continuously. Belgium highlighted a national study which showed that the natural gas consumed contains very little sulphur (source: Eandis), so almost no SO2 is released during combustion. The TERT acknowledged the explanation provided by Belgium and that any emission would be below the threshold of significance. However, the TERT noted that there are still emissions and therefore there is an under-estimate of SO2 emissions from natural gas and lamp oil in the Flemish region. The TERT recommends that Belgium considers adding SO2

No For SO2 from 1A1a the TERT needed to verify the correct implementation of the 2017 recommendation BE-1A1a-2017-0003. In response to a question raised during the review, Belgium provided information on the emissions of SO2 from gas fired power stations not using continuous measurement and showed that these sources make a small contribution (0.06% of the total SO2 emission from the Flanders region). The TERT interpreted this information to mean that SO2 emissions from these sources are not currently included in the inventory. The TERT recognises that the sources make a small contribution, but nevertheless recommends that Belgium includes the emissions in their next inventory and documents the methodology in the IIR.

No No No

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

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

emissions from natural gas and lamp oil in the Flemish region in its next submission or provide a clear justification of sulphur free content of natural gas and lamp oil in its IIR.

2017 BE-1A1b-2018-0001

No 1A1b Petroleum Refining, NH3, 2015

The TERT noted in 2015 NFR table, for category 1A1b Petroleum Refining, that NH3 emissions are reported as ‘NE’. The TERT noted that for all other years of the period 2005-2014, NH3 emissions for this category have been estimated in the NFR tables and thus understands that Belgium has a methodology to estimate these emissions. In response to a question raised during the review, Belgium explained that NH3 emissions are estimated using a single annual measurement and that in 2015, there was no measurable presence of NH3 registered by the equipment. The TERT acknowledges the explanation provided by Belgium. The TERT notes that the issue is far below the threshold. However, the TERT recommends that Belgium ensures that it can make reliable estimates by applying expert judgement and some form of interpolation or averaging when measurements are not providing the expected results. The TERT also recommends that Belgium provide some additional explanation about the measurements made, their reliability and back-up approaches to ensuring a complete estimate.

No The TERT noted that Belgium did not fully implement a recommendation of the 2017 NECD review (BE-1A1b-2017-0002), which was about missing estimates of NH3 emissions from category 1A1b. In response to a question raised during the review, Belgium explained that NH3 emissions (originating from a single facility) are missing in 2015 because the facility has not reported NH3 emissions in that year and that the methodology will be revised. The TERT reiterates the recommendation that Belgium estimates NH3 emissions from category 1A1b for the complete time series and all regions.

No No No

2017 BE-1A2c-2018-0001

Yes 1A2c Stationary Combustion in Manufacturing

The TERT noted that in the NFR tables, for NFR 1A2c Stationary Combustion in Manufacturing Industries and Construction: Chemicals, NOX

No The TERT noted that Belgium did not implement the recommendation of the 2017 NECD review (BE-1A2c-2017-0001),

No No No

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

Industries and Construction: Chemicals, NOX, 2014-2015

implied EF is not consistent through the time series. The NOX IEF is around 50-75 g/GJ from 2005 to 2013 and rise to 108 g/GJ in 2014 and 2015. The TERT observes no change in the fuel mix (mainly gaseous fuels are consumed). There is no specific explanation in the IIR explaining this rise in NOX emissions. In response to a question raised during the review, Belgium explained that the high IEF values of NOX in 2014 and 2015 originate from high emissions in these years for the chemical sector in Flanders (combustion emissions), estimated via the collective approach (description of the methodology in the IIR p. 6 and p. 68). For each year and for each company and for each pollutant, missing emissions are identified. When a company reports emissions, the fuel consumption of this company is subtracted from the total energy consumption in the regional energy balance. When the company does not report emissions, it is assumed that the energy consumption is part of the total energy consumption. When a company implements abatement measures and the emissions fall below the reporting threshold set by the Flemish legislation (VLAREM), the energy consumption will not be subtracted from the total energy consumption. The emissions that are estimated on a collective basis are calculated by multiplying the total energy consumption (minus the energy consumption of the companies that report emissions) with an emission factor. Emission factors originate from the 2013

which was about inconsistent reporting of NOX emissions from 1A2c. In response to a question raised during the review, Belgium explained that the methodology to estimate combustion emissions in a collective way will be revised in a study that is planned in 2019/2020. The TERT reiterates the recommendation that Belgium estimates NOX emissions from category 1A2c for the complete time series and all regions in a consistent way.

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

EMEP/EEA Guidebook or the emission limit values as described in VLAREM II (NOX, CO) (Sleeuwaert F. et al., 2010). This results in relatively high emissions from the component estimates from the remaining energy consumption. The TERT thinks that this approach leads to over-estimation where 'default NOX factor' (EMEP or VLAREM) is applied because the fuel consumption for plant with abatement technology and emissions below threshold is not subtracted. The TERT noted that the issue is below the threshold of significance for a technical correction. The TERT recommends that Belgium revises its methodology in order to avoid IEF variation due to a bias in the approach chosen. The TERT recommends that Belgium: (1) identifies operators with abatement technologies that are under the threshold for annual emissions reporting; (2) subtracts the corresponding consumption from the energy balance; (3) applies to this consumption an appropriate EF corresponding to their real abated emissions (based on previous annual reports or direct annual contact with operators) and estimates emissions for both the plant specific and remaining energy consumption.

2017 BE-1B2aiv-2018-0003

No 1B2aiv Fugitive Emissions Oil: Refining/ Storage, NMVOC, 2005-

For category 1B2aiv Fugitive Emissions Oil: Refining/Storage and pollutant NMVOC for all years the TERT noted that there is a lack of transparency regarding the way emissions are calculated in the IIR. In response to a question

No The TERT noted that Belgium did not fully implement the recommendation of the 2017 NECD review (BE-1B2aiv-2017-0001), which was about lack of transparency of NMVOC emissions from

No No No

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

2015 raised during the review, Belgium explained that emissions are taken from the environmental reports of the 4 refineries in Belgium, and that the reports contain many detailed information that are confidential. The TERT recommends that Belgium highlights that the methods are based on the confidential environmental reports and provides some non-confidential information that illustrates that the methods are comparable to those suggested in the 2016 EMEP/EEA Guidebook.

category 1B2aiv. In response to a question raised during the review, Belgium provided an emission rate in the unit of kg NMVOC/t Crude Oil input. The TERT recommends that Belgium includes this emission rate in its next IIR.

2017 BE-2C2-2018-0001

No 2C2 Ferroalloys Production, SO2, NOX, PM2.5, 2000-2015

For NFR category 2C2 Ferroalloys Production the TERT noted that in response to a question raised during the review Belgium explained that SO2, NOX and CO emissions are not available from the producer for the years 2008-2015. Belgium also explained that particle emissions from ferroalloys production cannot be separated from other production processes and are therefore included under NFR 2C1 Iron and Steel Production. The TERT noted that the issue is below the threshold of significance for a technical correction. The TERT recommends that Belgium completes the time series by estimating emissions for 2008-2015, e.g. using IEFs, AD and an abatement efficiency for the desulphurisation installation. The TERT also recommends that Belgium uses the proper notation keys for particle emissions (i.e. ‘IE’) and includes information in the IIR on where particle emissions are allocated.

No For SO2, NOX and PM2.5 emissions from category 2C2 the TERT notes that a time series inconsistency exists in reporting. A recommendation made during the 2017 review to resolve this time series inconsistency was not implemented to date. In response to a question asked during the review, Belgium explained that this is due to companies not reporting since their emissions are below the threshold for reporting, and that the development of a new methodology to estimate currently missing emissions is foreseen for 2019-2020. The TERT notes that this issue is below the threshold of significance and recommends that Belgium includes all missing emissions based on the new methodology for the next submission.

No No No

2017 BE-2C3- No 2C3 Aluminium For NFR category 2C3 Aluminium Production in No The TERT reiterates recommendation No No No

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

2018-0002 Production, SO2, NOX, PM2.5, 2000-2015

response to a question raised during the review Belgium explained that NOX and SO2 emissions for 2009-2015 and 2004-2015 respectively are unavailable from the producers. Belgium also explained that particle emissions from aluminium production are included under NFR 2C7c Other Metal Production. The TERT noted that the issue is below the threshold of significance for a technical correction. The TERT notes that emissions from both primary and secondary aluminium production should be reported under NFR category 2C3 and recommends that Belgium allocates particle emissions from all aluminium production to the proper NFR category 2C3. The TERT further recommends that Belgium completes the time series by estimating NOX and SO2 emissions for 2009-2015 and 2004-2015 respectively, e.g. using IEFs and AD.

BE-2C3-2017-0001 from the 2017 NECD Review. For SO2, NOX and PM2.5 emissions from category 2C3 the TERT notes that there is a potential under-estimate of emissions. In response to a question asked during the review, Belgium explained that this is due to companies not reporting since their emissions are below the threshold for reporting, and that the development of a new methodology to estimate currently missing emissions is foreseen for 2019-2020. The TERT notes that this issue is below the threshold of significance and recommends that Belgium includes all missing emissions based on the new methodology in the next submission.

2017 BE-2D3a-2018-0002

Yes 2D3a Domestic Solvent Use Including Fungicides, NMVOC, 1990-2015

For Key Category 2D3a Domestic Solvent Use, NMVOC, whole time series, the TERT noted that Belgium used per capita EFs, corresponding to the Tier 1 approach in the 2016 EMEP/EEA Guidebook. In response to a question raised during the review, Belgium explained that a study (2010) in the Brussels Capital Region compiled all information available for the category Decorative Coating Application and Domestic Solvent Use (NMVOC emissions through domestic solvent use and the use of paints in the Brussels Capital Region, Arcadis, 2010). From this study, the NMVOC

No The TERT reiterates recommendation BE-2D3a-2017-0001 from the 2017 NECD Review. For NMVOC emissions from category 2D3a the TERT notes that other, more accurate activity data have not been used in the 2018 submission. In response to a question asked during the review, Belgium explained that it has tried to collect other data but so far without success. Belgium explained that for the next submission, they will attempt again to get data from industry.

No No No

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

emissions of paint application for construction and building and domestic use have been revised in 2010. The population based EFs for the different product groups (office products, leather and furniture care, cosmetics and personal care, cleaning products, car products, adhesives/DIY consumer, insecticides & plant protection products) have been determined by the 2010 study of Arcadis for the Brussels Capital Region for 2008. The EFs have been slightly adapted for Flanders and Wallonia. For the Flemish, Walloon and Brussels Capital Region, the total emission factors are respectively 1.324, 1.412 and 1.219 kg/person for 2008. The TERT recommends that Belgium investigates the possibilities for using AD, such as used products and/or used solvents, and to calculate emissions based on these AD. This will enable a compile Tier 2 estimates using methods in the 2016 EMEP/EEA Guidebook and to compare its country specific EFs with those in the 2016 EMEP/ EEA Guidebook. The TERT recommends that Belgium adds the table with calculated EFs for product groups, delivered during the review, to its IIR for its next submission.

The TERT recommends that Belgium collects this data for the next submission and explains the progress made on this issue in the next submission of the IIR.

2017 BE-2G-2018-0001

No 2G Other Product Use, SO2, NOX, NH3, NMVOC, PM2.5, 1990-2015

For category 2G Other Product Use, NOX, SO2, NMVOC, whole time series, the TERT noted that ‘NE’ or "0" is reported for potential Key Categories fireworks and tobacco. In response to a question raised during the review, Belgium explained that in the Belgian inventory submitted in 2017, the

No The TERT reiterates recommendation BE-2D3a-2017-0001 from the 2017 NECD Review. The TERT notes that for fireworks only Cu emissions were estimated. In response to a question asked during the review, Belgium

No No No

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

calculation of dust emissions coming from tobacco consumption was only made in Flanders (AD for Flanders was attached). These emissions were not estimated in the other regions, however, emissions from tobacco smoke will be estimated for Belgium in the next submission assuming that tobacco consumption in Flanders in relation to the total tobacco consumption in Belgium is 55 %. Belgium stated that the AD used with an estimated emission factor of 40 kg PM2.5/t (Tier 2 2016 EMEP/EEA Guidebook: 27 kg PM2.5/t) is only half of the consumption as it is assumed that only half of the tobacco smoke is emitted outdoors. An estimate of PM2.5 emissions using these data for Belgium yields less than 2% of the national total, which is below the threshold of significance. Furthermore, concerning PM emissions from fireworks, it is not possible to find Eurostat data (zero or confidential) and a request for data from PRODCOM was made, but these are at the earliest foreseen by the end of June. The TERT recommends that Belgium provides a reference to the source explaining that tobacco smoke indoors does not affect outdoor air, as this is taken into account in other emission inventories. The TERT furthermore recommends that Belgium includes AD, EFs and emissions for tobacco smoke and fireworks in its next submission.

explained that the Cu emission is based on a Dutch study and only for Flanders, for the next submission it will also be estimated for the other regions. In addition, Belgium explained that it wants to apply the Guidebook methodology and is trying to acquire the activity data for the next submission. For tobacco smoking, emissions are reported already and will be harmonized between the 3 regions for the next submission. The TERT recommends that Belgium implements these improvements foreseen for fireworks and tobacco and include emissions for all relevant pollutants. The TERT also recommends that Belgium unifies, or at least clearly describes, the methods used in all 3 regions in the IIR for the next submission.

2017 BE-3B-2018-0002

No 3B Manure Management,

The TERT notes that for both Flanders and Wallonia 2013 EMEP/EEA Guidebook default Tier 1

No Please refer to observation BE-3B-2018-0005.

No No No

17

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

PM2.5, 2000-2015

is used to estimate the PM2.5, PM10 and TSP emissions from NFR 3B Manure Management 2005-2015. In response to a question raised during the review, Belgium confirmed that it intends to use updated emission factors from the 2016 EMEP/EEA Guidebook (Table 3.5 or Annex Table A1.6) in the next submission.

2017 BE-3B1a-2018-0001

Yes 3B1a Manure Management - Dairy cattle, NH3, 2005-2015

The TERT noted that the NH3 IEF for NFR 3B1a dairy cattle was significantly lower than other comparable European countries. In 2015 the NH3 IEF for dairy cattle is 6.5 kg NH3/cow/yr (based on NFR data; 3.915 kt NH3/603444 cows), and this emission is close to half of the emission in Austria, Denmark, Finland, Germany, Netherlands, Sweden and United Kingdom (refer to attached Excel “NH3 IEF BE compared with other EU countries”). The TERT noted in response to question raised during the review, that Belgium, for dairy cattle in Flanders, use an average NH3 emission factor of 7.53 kg NH3/cow/yr (9.12 for dairy cattle and 5.04 for brood cows) and for Wallonia is used 15-17 kg NH3/cow/yr. The fact that Flanders does not correctly include the brood cows in NFR 3B1a dairy cattle can in some way explain the lower NH3 IEF. However, this cannot be the only reason, because the NH3 emission factor used for both Flanders and Wallonia is higher than the NH3 IEF. The TERT is aware that the NH3 emission from housing in Belgium is likely to be lower than the default values. However, Belgium did not provide a clear

TC For 3B1a Manure Management – Dairy Cattle and NH3 emission the TERT noted that Belgium has performed the recalculations originally requested, leading to higher IEF. In response to a question on further details raised during the review, Belgium provided further information on the EF used and abatement techniques considered. The TERT recommends that Belgium includes this additional information regarding EFs used and the consideration of abatement techniques in its next IIR.

No No No

18

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

response to questions from the TERT, to explain the reason why the NH3 IEF Belgium is significantly lower than other comparable European countries. The TERT therefore decided to calculate a technical correction for NH3 emission from NFR 3B1a for the years 2005, 2010 and 2015, which was not accepted by Belgium. The estimates demonstrate that the issue is above the threshold of significance. The TERT recommends that Belgium includes a revised estimate in its next submission.

2017 BE-3B4giv-2018-0001

No 3B4giv Manure Management - Other Poultry, PM2.5, 2005-2015

The TERT noted that the PM2.5, PM10 and TSP emissions from NFR 3B4giv Other Poultry are not estimated for 2005-2015. The TERT also noted that emissions of NH3, NOX and NMVOC are estimated from NFR 3B4giv Other poultry for the years 2015, 2010 and 2005, which indicates that some considerations regarding activity data (by type of poultry) is undertaken for these estimates. During the review, Belgium responded that in Flanders, ducks and geese are no longer included in statistics by the Flemish Land Agency (VLM) from 2007 and for Wallonia, the data for ducks and geese is known and PM emissions will be calculated for the next submission. The TERT recommend Belgium to investigate the possibility of providing activity data for NFR 3B4giv Other Poultry for both Wallonia and Flanders, so PM2.5 emissions can be calculated and included in the next submission.

No The TERT reiterates recommendation BE-3B4giv-2017-0001 from the 2017 NECD Review. The TERT recommended Belgium to investigate the possibility to provide activity data for NFR 3B4giv Other poultry for both Wallonia and Flemish region, so PM emission can be calculated and included in the next submission. During the 2018 NECD Review, Belgium explained livestock numbers for Flemish is not available for the period 2007-2016 and that the origin of statistics is different in the Walloon and Flemish region, so a split of a Belgian total to the regional level cannot be made. The TERT recommends that Belgium improves completeness of these emissions in its next submissions, by including emissions in Flanders beyond 2007.

No No No

19

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

2017 BE-3Da1-2018-0001

Yes 3Da1 Inorganic N-Fertilizers (Includes also Urea Application), NOX, NH3, 2005-2015

For calculation of NH3 emission from NFR 3Da1 Inorganic N-fertilisers 2005-2015, the description in the IIR is not transparent. In response to a question raised during the review, Belgium provided a time series for 2005-2015 for the total amount of N in inorganic fertilisers, allocation of different fertiliser types and NH3 EF used – all for Flanders. Based on these data, it is clear that the weighted NH3 EF is based on a change in the allocation of fertilizer type. However, in the case of Wallonia, an EF of 4.2% is used for all years and no information is provided for this estimate. The TERT recommends that Belgium includes information in the IIR for N amount in inorganic fertiliser, allocation of fertiliser types and EF used for each fertiliser type for all years.

No For 3D1a Inorganic N-fertilizers and NH3 emissions the TERT noted that there is a lack of transparency. In response to a question raised during the review, Belgium clarified which EFs were used, how emissions were estimated and that EFs are kept constant along the time series. The TERT recommends that Belgium updates the text in IIR to be more clear and includes clarification for the EF used.

No No No

2017 BE-3Da1-2018-0002

No 3Da1 Inorganic N-Fertilizers (Includes also Urea Application), PM2.5, 2005-2015

The TERT notes that the IEF for PM2.5 emissions 2015, 2010 and 2005 is estimated based on an emission factor of 0.03 kg PM2.5 per ha, which is half of the default EF (0.06 kg PM2.5/ha – 2013 EMEP/EEA Guidebook Table 3-1). In response to a question raised during the review, Belgium explained that the PM2.5 emissions only include emissions from the Walloon region and no emissions from Flanders are estimated. The TERT noted that the issue is below the threshold of significance for technical correction. The TERT recommends that Belgium estimates the PM2.5, PM10 and TSP emissions for all regions for the next submission. Activity data and 2016 EMEP/EEA

No For PM2.5 emissions from 3Dc Farm-level agricultural operations including storage, handling and transport of agricultural products, the TERT reiterates recommendation BE-3Da1-2017-0002 from the 2017 NECD Review and recommends that Belgium estimates the PM2.5, PM10 and TSP emissions for all regions for the next submission. The TERT recommends that Belgium reports these particulate matter emissions under 3Dc in line with 2016 EMEP/EEA Guidebook (instead of under 3D1a Inorganic N-fertilizers as it was

No No No

20

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

Guidebook Tier 1 EF are available. wrongly indicated in 2013 EMEP/EEA Guidebook, please refer to the updated Table 3-1 in the agriculture chapter). During the 2018 NECD Review, Belgium confirmed that the recommendation will be addressed as part of the 2019 submission.

2017 BE-5C-2018-0001

No 5C Waste Incineration, SO2, NOX, NH3, NMVOC, PM2.5, 2005;2010;2015

For 5C the TERT noted that Belgium is estimating NOX, SO2, NMVOC, NH3 and TSP emissions from waste incinerators with and/or without energy recovery using annual emissions reported by operators on the basis of stack measurements. When continuous measurements are used to estimate annual emissions, there is a risk that operators have misinterpreted the IED (Industrial Emissions Directive) and have subtracted the value of the confidence interval (IC95) although this subtraction must not be applied in the context of reporting annual emissions. In response to a question raised during the review, Belgium explained that operators have been contacted and that there is evidence that at least a part of them are estimating annual emissions on the basis of measurement concentration data "reduced" of the confidence interval. The TERT notes that this issue relates to an under-estimate, which could correspond, at a maximum, to 20% of SO2, 20% of NOX, 30% of dust of the sector, depending on the fraction of the operators subtracting IC95. The TERT is aware that such an analysis cannot be

No For sector 5C the TERT noted that Belgium did not fully implement the 2017 TERT recommendation BE-5C-2017-0001. Estimates for PM2.5 and NH3 are not (re)calculated, there is no (re)calculation for pre-2008 years and in the IIR no planned improvements (for the Wallonian region) on this issue are included. In response to the question on the issue raised during the 2018 review Belgium replied that in Wallonia, no recalculation was needed for pre-2008 years because the operators did not use the continuous measurements to estimate their annual emissions before 2008. The operators confirmed us that they used periodic measurements without subtraction of the confidence interval to estimate their annual emissions before 2008. In Flanders, the recalculation will be implemented in the next submission. The TERT recommends that Belgium further investigates getting

No No No

21

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

performed during the time scale of the current NECD review and recommends Belgium to organise a survey among operators to identify which ones are reporting under-estimated emissions and try to derive a methodology to adjust national emissions over the time series. The TERT also encourages Belgium to prevent under-estimated reporting from operators in the future.

activity data for 5C (for all three regions Flanders, Brussels and Wallonia) and include activity data and emission estimates for the entire time series in its 2019 submission, or that Belgium includes a schedule for implementation of this study in its next IIR.

2017 BE-5D-2018-0001

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

For 5D the TERT noted that NMVOC emissions are not estimated (‘NE’ notation key) although there is a default emission factor proposed in the 2016 EMEP/EEA Guidebook. In response to a question raised during the review Belgium indicated that it assumes, as with the greenhouse gas inventory, that emissions from waste water treatment are not included in the Belgian inventory because most of the industrial waste water is treated in an aerobic way. The TERT notes that although emissions of CH4 are dependent on the presence of anaerobic conditions, NMVOC emissions occur from centralised waste water treatment plants whatever the type of treatment. Belgium did not provide a revised estimate but the TERT noted that the issue is expected to be below the threshold of significance for a technical correction. The TERT recommends that Belgium estimates NMVOC emissions from domestic and industrial waste water handled in waste water treatment plants for future submissions.

No For sector 5D the TERT noted that Belgium did not implement the 2017 TERT recommendation (BE-5D-2017-0001). Belgium stated that estimates for NMVOC were not calculated because of limited resources available. In the IIR no planned improvements on this issue are included. In response to the question on the issue raised during the 2018 review Belgium provided a file with detailed information on NMVOC emissions from waste water for the three regions. Belgium stated that the result seems to be negligible (0.006% of total NMVOC emissions). The TERT thanks Belgium for providing the detailed information. The TERT recommends that Belgium includes for sector 5D (for all three regions Flanders, Brussels and Wallonia) the detailed information on emission estimates, activity data and methodology for the entire time series

No No No

22

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Review year of initial recommendation

ObservationKey Category

NFR, Pollutant(s), Year(s)

Recommendation made in previous review reportRE or TC in 2017

Assessment of ImplementationRE or TC in 2018

Tier 1 KC

GB 2016 Issue

in its 2019 submission.

2017 BE-5E-2018-0001

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

For 5E the TERT noted that Belgium doesn't estimate emissions from car and building fires although a default EF is proposed in the 2016 EMEP/EEA Guidebook. In response to a question raised during the review Belgium explained that no information is available regarding the accidental fire data for 2005, 2010 and 2015 and did not provide a revised estimate for car and building fires. The TERT decided to calculate a technical correction for the years 2005, 2010 and 2015 and the estimates done by the TERT demonstrate that the issue is above the threshold of significance. Belgium accepted the TC but noted that the ADs used for the TC may be too high comparing to data available for other years. Following questions from the TERT on NH3 emissions from sludge spreading, Belgium provided a revised estimate concerning NH3 emissions from sludge spreading in Wallonia. This revised estimate is below the threshold of significance but has been included in the Technical Revision calculation for 5E. The TERT recommends that Belgium includes an estimation of PM2.5 and NH3 from 5E in its next submission.

TC The TERT noted with reference to implementing recommendation BE-5E-2017-0001 that estimates are presented for all relevant substances and years, but there is a lack of transparency regarding the activity data (per type of fire, per year) used for calculating the estimates. In response to the question on the issue raised during the 2018 review Belgium submitted a file which details the activity data per type of fire and per year for the three regions. As mentioned in the IIR, for the years 2012, 2013 and 2014 the number of fires is obtained from the Belgian fire brigade. For the other years (also for 2015 and 2016) the number of fires is calculated based on total population. The TERT thanks Belgium for providing the detailed information. The TERT recommends that to provide sufficient transparency Belgium includes for sector 5E (for all three regions Flanders, Brussels and Wallonia) the detailed information on emission estimates, activity data and methodology for the entire time series in its 2019 submission.

No No No

23

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

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

RecommendationRE or TC in 2018

Tier 1 used for a key category

Issue related to use of GB prior to the 2016 version

BE-3B-2018-0005 No 3B Manure Management, PM2.5, 1990-2016

For 3B Manure Management and PM2.5 and years 1990-2016 the TERT noted that there was an over-estimate because the total livestock numbers were being used for the activity data, whereas the 2016 EMEP/EEA Guidebook methodology indicates that only housed livestock should be used as AD (except for poultry). In response to a question raised during the review, Belgium provided revised estimates for 1990-2016. The TERT agreed with the revised estimate provided by Belgium and attached to the annex of the review report. The TERT recommends that Belgium includes the revised estimate in its next submission.

RE No No

24

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

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

23. Belgium did not provide any resubmission.

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

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

26. Transparency and Consistency: The TERT found the information in the IIR was not sufficient but Belgium provided explanatory information on request.

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

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

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

30. The TERT noted that the submitted HMs and POPs inventory is in general compiled in line with the 2016 EMEP/EEA Guidebook and Directive (EU) 2016/2284.

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

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

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

25

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

ObservationKey Category

NFR, Pollutant(s), Year(s)

RecommendationTier 1 used for a key category

Issue related to use of GB prior to the 2016 version

BE-2A1-2018-0001

Yes 2A1 Cement Production, PCBs, 1990-2016

For category 2A1 Cement Production and pollutant HCB the TERT noted that emissions from PCB show a large increase in 2010-2011 compared to other years. In response to a question raised during the review, Belgium explained that this was because of the use of an alternative raw material containing high concentrations of PCB. The removal of the raw material causing high PCB emissions at the end of 2011 has allowed returning to a normal level of emissions. The TERT notes that this issue does not relate to an over- or under-estimate and recommends that Belgium includes the explanation for this peak in the time series in the IIR for the next submission.

No No

BE-2D3g-2018-0001

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

For category 2D3g and pollutant PAHs the TERT noted that emissions are not estimated (NA) for all years in the time series, despite the availability of emission factors for asphalt blowing in the 2016 EMEP/EEA Guidebook. In response to a question raised during the review, Belgium explained that only Flanders estimates these emissions, amounting to 0.3 g, and that Brussels and Wallonia do not estimate this source. The TERT recommends that an estimate is also made for Brussels and Wallonia and not only for Flanders. At the moment the EF given in the Guidebook is wrong, but it will be replaced with a correct EF. The TERT recommends the Belgium to collect AD for this emission source for all regions and to calculate PAHs emissions and to document the methodology as soon as the corrected EF becomes available.

No No

BE-5C1biii-2018-0002

Yes 5C1biii Clinical waste Incineration, PCDD/F, 2016

For sector 5C1biii Clinical Waste Incineration the TERT noted that the notation key ‘NE’ is reported for PCDD/F for the year 2016 although an EF is included in the 2016 EMEP/EEA Guidebook. In response to the question on the issue raised during the 2018 review Belgium replied that the notation key ‘IE’ should have been used for all the pollutants in category 5C1biii instead of ‘NE’. The TERT recommends that Belgium reports the proper notation key ‘IE’ where applicable (sectors, years and substances) in its 2019 submission.

No No

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

26

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ObservationKey Category

NFR, Pollutant(s), Year(s)

RecommendationTier 1 used for a key category

Issue related to use of GB prior to the 2016 version

BE-1A1c-2018-0001

No 1A1c Manufacture of Solid Fuels and Other Energy Industries, Hg, 2016

For category 1A1c Manufacture of Solid Fuels and Other Energy Industries, pollutants Cd, Hg, Pb and PCCD/F the TERT noted that Hg emissions are not reported for the full time series and that Cd, Pb and PCCD/F emissions or not reported at all, although the Guidebook 2016 offers a Tier 1 methodology. In response to a question raised during the review, Belgium explained that Cd, Hg and Pb are included in categories 1A2a, 2C1 and 1B1b and that PCDD/F emissions are not estimated. The TERT notes that this issue relates to an under-estimate of PCCD/F emissions and recommends that Belgium estimates PCDD/F emissions from category 1A1c in their next submission. The TERT also recommends that Belgium changes the notation keys properly, e.g. reports Hg emissions 1997-2016 as ‘IE’ instead of ‘NE’ and that Belgium explains in the IIR, where heavy metals emissions of 1A1c are included.

No No

BE-1A3b-2018-0003

No 1A3b Road Transport, PCBs, Hg, 1990-2016

For sector 1A3b Road Transport, all years, the TERT noted that pollutants Hg and PCB are reported as 'NE' in the NFR tables. However, the 2016 Guidebook provides emission factors in p. 93 (table 3.77) and p. 91-92 (Tables 3.75 and 3.76), respectively. In response to a question raised during the review, Belgium answered that Hg and PCB are available in COPERT 5, but Belgium still uses COPERT 4 version 11.4 for calculation of road transport emissions. Belgium stated that efforts are made to prepare and customize input and tools to calculate emissions with COPERT 5 from the 2020 submission onwards. The TERT welcomes this plan and recommends that this issue is checked again in the next 2019 review in order to check progress.

No No

BE-1B2aiv-2018-0001

No 1B2aiv Fugitive Emissions Oil: Refining/ Storage, Cd, Hg, 1990

For category 1B2aiv Fugitive Emissions Oil: Refining/Storage and pollutants Cd and Hg the TERT noted that there may be an under-estimate of emissions for the years 1990-1995 and 1997 because emissions are reported as ‘NE’ while they are reported for other years. In response to a question raised during the review, Belgium explained that data has been provided by the facilities and that in the 1990s, the emission reporting of heavy metals was preliminary and incomplete. Belgium further explained that in 2009 a study was performed to establish a complete heavy metal emission inventory, but only from 2000 onwards. Finally, Belgium explained that it is planned to estimate missing emissions in a collective way and that a study is planned in 2019/2020. The TERT welcomes the plan of Belgium and recommends that Belgium includes estimates for Cd and Hg for the years 1990-1995 and 1997, using a consistent methodology for the full Time series.

No No

27

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ObservationKey Category

NFR, Pollutant(s), Year(s)

RecommendationTier 1 used for a key category

Issue related to use of GB prior to the 2016 version

BE-2A3-2018-0001

No 2A3 Glass Production, Pb, 1990-2016

For category 2A3 Glass Production and pollutant Pb the TERT noted strong variations in Pb emissions from glass production in the time series 1990-2016. In response to a question raised during the review, Belgium explained that high Pb emissions in 1994-1997 are due to a Flemish glass production plant that was active only during this period, while the sharp decrease of emissions in 2010 is due to the installation of an electrostatic precipitator in a Walloon glass plant in 2009. The TERT notes that this issue does not relate to an over- or under-estimate and recommends that Belgium includes these explanations in the IIR for the next submission.

No No

BE-2C1-2018-0001

No 2C1 Iron and Steel Production, PAHs, 1990-2016

For category 2C1 Iron and Steel Production and pollutant PAHs the TERT noted strong variations in PAHs emissions from iron and steel production in the time series 1990-2016. In response to a question raised during the review, Belgium explained how the EFs used over the time series were derived and reported some errors found in the data. The TERT recommends that Belgium corrects the emissions for the next submission and includes a clear explanation of the different EFs used over time, including explanation on how it is ensured that these result in a consistent time series.

No No

BE-2C3-2018-0001

No 2C3 Aluminium Production, HCB, 1990, 2005, 2016

For category 2C3 Aluminium Production and pollutant HCB the TERT noted that emissions from HCB are not reported by Belgium, despite the availability of an emission factor for HCB from secondary aluminium production in the 2016 EMEP/EEA Guidebook. In response to a question raised during the review, Belgium explained that it is assumed that no emissions occur as high efficiency abatement is installed. The TERT recommends that Belgium investigates HCB emissions from this source category, including the years before 2000. In case the conclusion remains, that emissions are negligible, the TERT recommends providing evidence for this assumption in the IIR and to use the notation key ‘NE’ instead of ‘NA’.

No No

BE-2C5-2018-0001

No 2C5 Lead Production, PCBs, 1990, 2005, 2016

For category 2C5 Lead Production and pollutant PCBs the TERT noted that emissions from PCB are not reported by Belgium, despite the availability of an emission factor for PCB from the 2016 EMEP/EEA Guidebook Tier 1 and Tier 2 methodologies. In response to a question raised during the review, Belgium explained that emissions only occur in Flanders and are negligible (0.05 g). The TERT recommends that Belgium reports these emissions for the next submission or uses the correct notation key 'NE'. The TERT also recommends that Belgium explains the methodology

No No

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ObservationKey Category

NFR, Pollutant(s), Year(s)

RecommendationTier 1 used for a key category

Issue related to use of GB prior to the 2016 version

used to estimate these emissions in the IIR for the next submission.

BE-2D3a-2018-0001

No 2D3a Domestic Solvent Use Including Fungicides, Hg, 1990, 2005, 2016

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

No No

BE-5C1a-2018-0001

No 5C1a Municipal Waste Incineration, HCB, 1990-2016

The TERT noted that HCB emissions in sector 5C Municipal Waste Incineration are a factor 10 higher in 2013 relative to 2012 and 2014. No justification is provided in the IIR. In response to the question on the issue raised during the review, Belgium explained that this is because the activity data is a factor 10 higher in 2013 relative to 2012 and 2014. A small part of the emissions from municipal waste incineration is still allocated in the waste sector (5C1a) when waste is incinerated without energy recovery because of occasional problems in the energy recovery systems. The TERT recommends that Belgium provides an explanation in the IIR for this feature of the historical time series.

No No

BE-5C1biii-2018-0001

No 5C1biii Clinical Waste Incineration, HCB, 2016

For sector 5Cbiii Clinical Waste Incineration the TERT noted that the notation key ‘NE’ is reported for HCB for the year 2016 although an EF is included in the 2016 EMEP/EEA Guidebook. In response to the question on the issue raised during the 2018 review Belgium replied that the notation key ‘IE’ should have been used for all the pollutants in category 5C1biii instead of ‘NE’. The TERT recommends that Belgium reports the proper notation key ‘IE’ where applicable (sectors, years and substances) in its 2019 submission.

No No

BE-5C2-2018-0001

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

For sector 5C2 Open Burning of Waste the TERT noted that the notation key ‘NE’ is reported for Cd from 5C2 for the years 1990, 2005 and 2016 although an EF is proposed in the 2016 EMEP/EEA Guidebook. No comments on this issue were found in the IIR. In response to the question on the issue raised during the 2018 review Belgium replied that the sector 5C2 contains emissions from the burning of garden waste and municipal waste in open air in

No No

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ObservationKey Category

NFR, Pollutant(s), Year(s)

RecommendationTier 1 used for a key category

Issue related to use of GB prior to the 2016 version

Flanders (the activity data are decreasing strongly the latest years). Belgium also replied that Cd emissions will be calculated with the same activity data (as in sector 3F) and the emission factor mentioned of the EMEP/EEA Guidebook for the next submission. The TERT recommends that Belgium reports for sector 5C2 (for all three regions Flanders, Brussels and Wallonia) emission estimates, activity data and methodology for the entire time series in its 2019 submission.

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VI. Cross cutting recommendations on HMs and POPs

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

a. Completes its emission inventory by estimating currently missing emissions;

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

c. Calculates all emissions for which methods are provided in the 2016 EMEP/EEA Guidebook;

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

e. Presents the emission inventory as one consistent national dataset, rather than three different, barely compatible datasets for Flanders, Wallonia and Brussels.

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

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

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

7

Description ReferencePollutant estimates (kt)

2005 2010 2015 2016

NOX

National total (row 141) Annex1, 15/02/2018 317.869 245.922 201.644 193.104

National total for compliance (row 144) 304.215 167.494 131.490 125.684

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

3B Manure management BE-3B-2018-0003 -0.11 -0.113 -0.119 -0.12

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

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Description ReferencePollutant estimates (kt)

2005 2010 2015 2016

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

Calculated using above data

317.759 245.810 201.525 192.984

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

Calculated using above data

304.106 167.382 131.372 125.564

NMVOC

National total (row 141) Annex1, 15/02/2018 175.661 141.927 114.529 114.355

National total for compliance (row 144) 173.401 110.961 113.600 113.475

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

Calculated using above data

175.661 141.927 114.529 114.355

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

Calculated using above data

173.401 110.961 113.600 113.475

SOX

National total (row 141) Annex1, 15/02/2018 142.128 60.168 41.448 42.331

National total for compliance (row 144) 142.086 60.150 41.434 42.317

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

Calculated using above data

142.128 60.168 41.448 42.331

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

Calculated using above data

142.086 60.150 41.434 42.317

NH3

National total (row 141) Annex1, 15/02/2018 75.191 70.562 68.089 67.958

National total for compliance (row 144) 74.970 70.423 67.974 67.841

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

Calculated using above data

75.191 70.562 68.089 67.958

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

Calculated using above data

74.970 70.423 67.974 67.841

PM2.5

National total (row 141) Annex1, 15/02/2018 34.798 32.475 24.017 25.368

National total for compliance (row 144) 34.064 31.652 23.537 24.92

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

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Description ReferencePollutant estimates (kt)

2005 2010 2015 2016

3B Manure management BE-3B-2018-0005 -0.169 -0.157 -0.151 -0.15

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

Calculated using above data

34.629 32.317 23.866 25.218

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

Calculated using above data

33.894 31.495 23.386 24.770

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

36. Belgium agrees with the calculated estimates in Table 5.

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

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

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

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

39. The TERT calculated technical corrections for cases

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

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

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

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

1

EMRT ID: BE-3B-2018-0003

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

Member State: Belgium

Sector: 3B Manure management

Gases: NOX

Completed by (SE): Beatriz Sánchez

Reviewed by (LR): Chris Dore

Reviewed by QC Controller: Chris Dore

The underlying problem: NOX emission factor was not correctly applied in Flanders

The rationale for the corrected estimate:

In the Guidebook 2013, emission factors are reported as NO (Nitric oxide), in the EMEP/EEA Guidebook 2016 as NO2. In Flanders, this has not been interpreted correctly (the EF was seen as NO instead of NO2).

Summarise the methodology used:

The emissions are estimated by multiplying livestock numbers by EF in table 3.3 chapter 3D of the Guidebook. No conversion factor NO to NO2 needs to be used, since EF in 2016 EMEP/EEA Guidebook is in NO2 emissions by animal.

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

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2

Details of the corrected estimate

Original estimate (kt)Notes

Year NOX SO2 NMVOC NH3 PM2.5

BE-3B-2018-0003-OE 2005 0.83803

BE-3B-2018-0003-OE 2010 0.82957

BE-3B-2018-0003-OE 2015 0.83071

BE-3B-2018-0003-OE 2016 0.83152

Was a Revised Estimate received from the MS? yes

Revised Estimate received from MS (kt)Notes

Year NOX SO2 NMVOC NH3 PM2.5

BE-3B-2018-0003-RE 2005 0.72842

BE-3B-2018-0003-RE 2010 0.71707

BE-3B-2018-0003-RE 2015 0.71203

BE-3B-2018-0003-RE 2016 0.71134

Was the Revised Estimate accepted by the TERT?

yes

Technical Correction calculated by TERT (kt)Notes

Year NOX SO2 NMVOC NH3 PM2.5

BE-3B-2018-0003-TC 2005

BE-3B-2018-0003-TC 2010

BE-3B-2018-0003-TC 2015

BE-3B-2018-0003-TC 2016

Was the Technical Correction accepted by the MS?

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1

EMRT ID: BE-3B-2018-0005

EMRT URL:https://emrt-necd.eionet.europa.eu/2018/BE-3B-2018-0005

Member State: Belgium

Sector: 3B Manure management

Gases: PM2.5

Completed by (SE): Beatriz Sánchez

Reviewed by (LR):

Reviewed by (Counterpart):

Reviewed by QC Controller: Chris Dore

The underlying problem:The TERT notes with reference to PM2.5 emissions of 3B Manure management that the EF have not been updated to those of the 2016 EMEP/EEA Guidebook and that there may be an over-estimate.

The rationale for the corrected estimate:

The TERT notes that this over-estimate may be because Belgium used total livestock numbers as AD instead of housed livestock numbers in line with 2016 EMEP/ EEA Guidebook (see page 18 of chapter 3B Manure management, poultry is an exception). Although this over-estimate may be under the threshold of significance for each of the different animals’ categories, the over-estimate may have an overall impact above the threshold of significance when considering all 3B.

Summarise the methodology used:

Tier 1. Emissions = housed animal number * EF

2 Details of the corrected estimate

Original estimate (kt)Notes

Year NOX SO2 NMVOC NH3 PM2.5

BE-3B-2018-0005-OE 2005 0.69701

BE-3B-2018-0005-OE 2010 0.68742

BE-3B-2018-0005-OE 2015 0.70014

BE-3B-2018-0005-OE 2016 0.70239

Was a Revised Estimate received from the MS? yes

Revised Estimate received from Member State (kt)

Notes

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Year NOX SO2 NMVOC NH3 PM2.5

BE-3B-2018-0005-RE 2005 0.52776

BE-3B-2018-0005-RE 2010 0.53001

BE-3B-2018-0005-RE 2015 0.54963

BE-3B-2018-0005-RE 2016 0.55260

Was the Revised Estimate accepted by the TERT?

yes

Technical Correction calculated by TERT (kt)Notes

Year NOX SO2 NMVOC NH3 PM2.5

BE-3B-2018-0005-TC 2005

BE-3B-2018-0005-TC 2010

BE-3B-2018-0005-TC 2015

BE-3B-2018-0005-TC 2016

Was the Technical Correction accepted by the MS?

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ANNEX II Review of the 2018 adjustment application of Belgium: TERT report for the EC

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

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

2010-2016 NOX Previously accepted

3B Manure management3De Cultivated Crops

2010 NMVOC Previously accepted

1 Introduction 41. Article 5.8 of the NECD (Directive (EU) 2016/2284) explains that “The Commission, when exercising its powers under paragraphs 6 and 7 (reviewing the use of flexibilities), shall take into account the relevant guidance documents developed under the LRTAP Convention.” Article 8.4 and Part 4 of Annex IV of the NECD text further specify that Member States that opt for the adjustment flexibility must include supporting information in the Informative Inventory Report, including a demonstration that the use of the adjustment procedure fulfils the relevant conditions set out in Article 5.1 and Part 4 of Annex IV. The minimum supporting information required is highlighted in Part 4.1 of Annex IV (which is based on Part 1, paragraph 2 of the Annex to LRTAP Executive Body Decision 2012/12). In the chapeau of Annex IV it is further specified that adjusted emission inventories should be prepared using the EMEP reporting guidelines (which in its turn contains references to the relevant EB decisions 2012/3 and 2012/12, as amended in 2014/1), while also adding that reliance upon these EMEP reporting guidelines is without prejudice to the additional arrangements specified in Part 4 of Annex IV. Consequently, the review of Adjustment applications under the NECD will in principle follow the process for reviewing Adjustment applications made under the CLRTAP (as presented in relevant EB decisions), however without prejudice to the additional arrangements specified in Part 4 of Annex IV of the new NECD.9 It allows inter alia the submission of additional information during the review, necessary for a proper and full assessment of the adjustment application.

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

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

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

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

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

“Technical corrections” and “revised estimates” arise when the review team identifies substantial quality issues with the emissions inventory. The emissions inventory data is revised during the review to address the issue. Consequently, technical corrections and revised estimates change the national emission totals, which can make a specific adjustment no longer necessary or make a specific adjustment incompatible/invalid when applied to the same category for which a technical correction or revised estimate was approved. Adjustment applications that are affected by technical corrections or revised estimates should be reviewed, but the finalised outcome of the work on technical corrections and revised estimates must first be established before the review of the associated adjustment application.

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

43. Any Member State submitting an application for an adjustment to its inventory is required to notify the European Commission by 15 February at the latest. As explained above the supporting information must be included in the Informative Inventory Report (by 15 March of the same year) including a demonstration that the use of the adjustment procedure fulfils the relevant conditions set out in Article 5.1 and Part 4 of Annex IV. The minimum supporting information required is specified in Part 4.1 of Annex IV.

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

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

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

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

Role Sectors NameAdjustment lead reviewers All Chris Dore

Ole- Kenneth NielsenExpert reviewers Energy: Stationary and fugitives Rianne Dröge

Katrina Young Expert reviewers Energy: Transport and off-road Jean-Marc André

Giorgos MelliosTim MurrellsGiannis Papadimitriou

Expert reviewers Industrial processes and product use Ardi Link Expert reviewers Agriculture Michael Anderl

Bernard HydeMette MikkelsenBeatriz Sánchez

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

1 Review of Adjustments approved prior to 201847. Belgium had 3 adjustments granted prior to 2018, details of which can be found in Table 9. Belgium included information on these adjustments in its submission under the National Emissions Ceilings Directive (Directive (EU) 2016/2284) of 15/02/18, reporting sectoral level data in Annex VII to the reporting guidelines and in line 143 of Annex I. Along with Annex VII, Belgium submitted the “Declaration on consistency” with a short summary of recalculations of these granted adjustments. Additional documentation was provided during the review in response to requests from the reviewers. Table 11 lists the documentation provided by Belgium.

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

49. The reviewers noted that for the applied adjustment in the sector 3B Manure Management for NOX emissions in years 2010-2016 substantial recalculations have occurred. Belgium provided a recalculation of the quantification of the adjustment. The review of the recalculations and the supporting information showed that the method has not been changed and thus the reviewers conclude that the adjustment should continue to be granted. Following some clarification of the adjustment quantification to NMVOC estimates in 3B Manure management, the reviewers concluded that all other adjustments continue to meet the requirements under the NECD for an adjustment.

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

Country Sector Inventory year

Poll. Basis of Adjustment

Conclusions text Recommendation & Impact on National Total10

Belgium 1A3b Road transport

2010-2016 NOX Significantly different EFs

The TERT reviewed the information submitted by Belgium on the previously accepted adjustment for sector 1A3b, pollutant NOX, years 2010-2016. The TERT did not find it necessary to ask Belgium for clarifications, since sufficient explanation is provided in the document "ApprovedAdj_BE_2018.docx" and IIR. Following the review of the information made available prior to the review, the TERT concludes that the adjustment continues to meet the requirements stated in the NECD for an adjustment, and therefore recommends that the European Commission continues to accept the most recent submission as a valid adjustment for this source and pollutant.

-22.3 % in 2016Accept

Belgium 3B Manure management3D Crop production and agricultural soils

2010-2016 NOX New Source The TERT reviewed the information submitted by Belgium on the previously accepted adjustment for NOX emissions from 3B Manure management and 3D Crop production and agricultural soils, for 2010-2016. The TERT found it necessary to ask Belgium for clarifications, and Belgium did answer these questions satisfactorily. The TERT found it necessary to ask Belgium to recalculate the quantification of the adjustment, and Belgium did recalculate the quantification of the adjustment to the TERTs satisfaction. Following the review of the information made available prior to and during the review, the TERT concludes that the adjustment, taking into account recalculations to the adjustment quantification made within this review, does continue to meet the requirements stated in the NECD for an adjustment, and therefore recommends that the European Commission does continue to accept the most recent submission as a valid adjustment for this source and pollutant. The TERT reviewed the information submitted by Belgium on the previously accepted adjustment for 3Da1 Inorganic N-fertilizers and 3Da2a Animal manure applied to soils, for NOX in 2010-2016. The TERT found it necessary to ask Belgium for clarifications, and Belgium did answer these questions satisfactorily. The TERT did not find it necessary to ask Belgium to recalculate the quantification of the adjustment. Following the review of the information made available prior to the review, the TERT concludes that the adjustment does continue to meet the requirements stated in the NECD for an adjustment, and therefore recommends that the European Commission does continue to accept the most recent submission as a valid adjustment for these sources and pollutants.

-6.9 % in 2016Accept

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Country Sector Inventory year

Poll. Basis of Adjustment

Conclusions text Recommendation & Impact on National Total

Belgium 3B Manure management3De Cultivated Crops

2010 NMVOC New Source For NMVOC emissions from 3B Manure management and 3De Cultivated Crops the TERT noted that there were recalculations not explained in the IIR. A Tier1 method is used, but 3B1a Dairy-cattle, 3B1b Non-dairy cattle, 3B3 Swine and 3B4gii Broilers are key categories. In response to a question raised during the review, Belgium indicated that there must have been an error in 2017 submission and that the correct values are those in 2018 submission. Belgium also indicated they will investigate the use of a Tier2 method. The TERT recommends that Belgium review the performance of their QA/QC methods that are designed to avoid reporting errors. The TERT recommends that Tier2 is used at least for cattle and swine, by using the information reported in its GHG inventory to UNFCCC (MJ for cattle and VS for Swine). The TERT reviewed the information submitted by Belgium on the previously accepted adjustment for 3B Manure management, NMVOC in 2010. The TERT found it necessary to ask Belgium for clarifications regarding recalculations and the use of T1, and Belgium did answer these questions satisfactorily. The TERT did not find it necessary to ask Belgium to recalculate the quantification of the adjustment. Following the review of the information made available prior to and during the review, the TERT concludes that the adjustment does continue to meet the requirements stated in the NECD for an adjustment, and therefore recommends that the European Commission does continue to accept the most recent submission as a valid adjustment for this source and pollutant.

-20.8 % in 2010Accept

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2 Conclusions and Recommendations of TERT concerning adjustment applications

50. The reviewers have undertaken an assessment of the previously accepted applications for an adjustment of the NOX and NMVOC emissions inventory that was submitted by Belgium in 2018 for Transport 1A3b and for Agriculture 3B, 3D and 3De.

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

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

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

(first submitted in 2017)Accept

3B Manure management3D Crop production and agricultural soils

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

Accept

3B Manure management3De Cultivated Crops

2010 NMVOC Previously accepted(first submitted in 2017)

Accept

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

3 Information Provided by Belgium 53. Table 11 lists the information provided by Belgium in its adjustment application. The information provided by Belgium was stored on the EMRT-NECD review platform.

Table 11: Information Provided by Belgium

Filename Short description of content

Cover_letter_NEC2018.docx The notification of a 2016 adjustment application

ApprovedAdj_BE_2018.docx Declaration on consistent reporting of Approved Adjustments

Annex_VII_Adjustments_summary_BE2018_NEC.xlsx

The detailed calculations for the quantification of the 2018 adjustment applications

BE_IIR_2018.pdf The Informative Inventory Report provided by Belgium.

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54. The reviewers found it necessary to ask Belgium for further information. This is documented in Table 12.

Table 12: Additional Information Provided by Belgium

Filename Short description of content

Review_NECD_BE-3B-2018-0003(NOX).xlsx

File provided in response to review team request for clarification of estimates. Belgium supplied activity data and emission factors for the timeseries of estimates made for NOX from 3B Manure Management.

3B_2018_0003_recalculated.xlsx Belgium provided an update to the emissions estimates for NOX category 3B Manure management.

Annex_VII_Adjustments_summary_BE2018_NEC_CetnralisedReview.xlsx

Updated quantification of the adjustment for NOX emissions from 3B Manure Management.

EMRT_NECD QA Exchange, 26/06/18-28/06/18

The review team asked for clarification on the NMVOC emissions from 3B manure management. In response to the question Belgium indicated that there must have been an error in 2017 submission and that the correct values are those on 2018 submission.

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References and Supporting DocumentsAnnex I emission reporting template. Available at http://www.ceip.at/ms/ceip_home1/ceip_home/reporting_instructions/

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

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

EU 2018, Guidance for TERTs. Available upon request.

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

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

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

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

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

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

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

NEC Directive 2001, DIRECTIVE 2001/81/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL, of 23 October 2001 on national emission ceilings for certain atmospheric pollutantshttps://eur-lex.europa.eu/legal-content/EN/TXT/?toc=OJ%3AL%3A2016%3A344%3ATOC&uri=uriserv%3AOJ.L_.2016.344.01.0001.01.ENG

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

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