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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’)

Ireland30 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........................................28

VII. Effect of revised estimates, technical corrections and adjustments recommended to be approved on the national total and national total for compliance.........................................................34

VIII. Statement from Ireland on the conclusions presented by the TERT...........................................37

IX. Findings and Conclusions from the Technical Expert Review Team (TERT) for the Review of adjustment applications.........................................................................................................................37

ANNEX I Technical corrections deemed necessary by the TERT and revised estimates provided by Ireland....................................................................................................................................................38

ANNEX II Review of the 2018 adjustment application of Ireland: TERT report for the EC......................41

References and Supporting Documents.................................................................................................51

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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 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.......................................................29Table 5: National totals as reported and national totals including revised estimates (RE), technical corrections (TC) and adjustments for NOX, NMVOC, SOX, NH3, PM2.5 .....................................................34Table 6: Summary tables of Technical Corrections and/or Revised Estimates........................................38Table 7: Summary information on the Submitted Adjustment Applications, Ireland, 2018.................41Table 8: The 2018 Review team of new and previously accepted adjustment applications................43Table 9: Conclusions and recommendations from the review team on previously accepted adjustment applications........................................................................................................................44Table 10 Ireland’s NOX Adjustment Applications for Agriculture, 2010-2016.......................................47Table 11: Conclusions and recommendations following the review of new adjustment applications.48Table 12: Recommendations following the 2018 review of new and previously accepted adjustment applications............................................................................................................................................49Table 13: Information Provided by Ireland............................................................................................50Table 14: Additional Information Provided by Ireland..........................................................................50

Abbreviations

Adj AdjustmentAD Activity DataEC European CommissionEEA European Environment AgencyEF Emission Factor EMEP European Monitoring and Evaluation ProgrammeEMRT Emission Review ToolEU European UnionGB GuidebookHMs Heavy MetalsIE Included Elsewherekt KilotonnesLR Lead Reviewer MS Member StateN NitrogenNA Not Applicable NE Not EstimatedNECD National Emissions Ceilings DirectiveNFR Nomenclature for ReportingNH3 Ammonia

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NMVOC 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

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

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

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

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

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

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

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

c. an expert review of

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

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

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

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

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

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

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

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

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

11. The review was split in two phases:

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

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

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

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

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

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

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

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

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

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

Element Scope Further information

Member StatesEU geographical coverage of the MS

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

Years

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

HMs and POPs:1990, 2005, 2016

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

Pollutants

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

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

According to NECD Article 1(1)

Categories

All NFR categories, including selected memo items

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

National totals

National total and National total for compliance

Rows 141 and 144 in Annex I to reporting Guidelines

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

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

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

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

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

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

b. Revised estimates: Ireland implemented most of the revised estimates from the NECD Review 2017. Those technical corrections and revised estimates not implemented have been passed to the Commission which, in accordance with Article 10.3 last subparagraph of Directive 2016/2284, may adopt a decision laying down the technical corrections to be applied. The TERT were not satisfied with the implementation to 1 revised estimate from the 2017 NECD Review. The TERT asked Ireland to provide a revised estimate. Ireland did not provide a revised estimate. The TERT provided a technical correction and recommended that Ireland include the technical correction in its next submission. The technical correction exceeds the threshold of significance (2%) for at least one year of the inventory under review (but not necessarily all the years of the time series). The technical correction has 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 additionally reiterated 1 revised estimate 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 all of the recommendations related to the use of the 2013 EMEP/EEA Guidebook were implemented.

21. The TERT considers that it received responses from Ireland 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 IE-1A1a-2018-0002

No 1A1a Public electricity and heat production, SO2, NOX, PM2.5, 2000-2015

For the Energy sector (including Waste Incinerator with Energy Recovery), the TERT noted that these sectors are estimating NECD emissions using annual emissions reported by operators based on 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 used validated average values (after having subtracted the value of the confidence interval) although this subtraction must not be applied in the context of reporting annual emissions. In response to a question raised during the review, Ireland explained that it can't provide confirmation that the values used for the estimation of national emissions are not validated average values with the confidence limits subtracted. In the opinion of the TERT, bottom-up data based on the "validated average values" defined in the IED cannot be used by the inventory team without adjustment in the framework of a national inventory. The TERT notes that this issue could relate to an under-estimate for the energy sector, which could correspond to 20% of SO2, 20% of NOX, 30% of dust of the sector (depending on the fraction of the operators subtracting

No The TERT reiterates the previous recommendation IE-1A1a-2017-0001 from the 2017 NECD Review in which the TERT recommended Ireland to organise a survey among operators to identify if the emissions have been reported on the basis of the validated average values and to try to derive a methodology to adjust the national emissions over the time series in order to compensate the fact that national emissions would be estimated on the basis of data reported by operators using validated average values. During the 2018 NECD Review, Ireland explained that most of the plants have responded to the survey, all stating that they do not subtract the confidence interval when calculating the emissions and that they will resolve the issue with complete responses from all plants. Ireland confirmed that the recommendation would be addressed by the 2019 submission, including a description in the IIR. The TERT recommends Ireland to include this

No No No

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

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Tier 1 KC

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confidence interval). The TERT recommends Ireland to organise a survey among operators to identify which ones are reporting emissions on the basis of the validated average values and try to derive a methodology to adjust the national emissions over the time series in order to compensate the fact that national emissions are estimated on the basis of data reported by operators using validated average values.

information in the IIR and kindly notes that progress of inclusion of the information in the IIR will be reviewed in 2019.

2017 IE-1A2gvii-2018-0001

No 1A2gvii Mobile Combustion in manufacturing industries and construction: Other, SO2, NOX, NH3, NMVOC, PM2.5, 1990-2015

For category 1A2gvii Mobile Combustion in Manufacturing Industries and Construction: Other, the TERT noted that activity data and emissions are reported as 'included elsewhere' ('IE') with contradictory information provided in the IIR (for 1A2g, "all emissions are reported under 1A2gvii".) In response to a question raised during the review, Ireland agreed to correct this erroneous IIR statement. The TERT welcomed this plan; further recommending including overview tables for categories reported as ‘not estimated’ and ‘included elsewhere’ in future IIR submissions as part of the general assessment of the completeness. Furthermore, in order to improve the inventory’s transparency and comparability, the TERT asks Ireland to put additional effort into the disaggregation of NFR categories 1A2gvii and 1A2gviii.

No With reference to the previous review recommendation IE-1A2gviii-2017-0001, for categories 1A2gvii and 1A2gviii and for all pollutants and all years, the TERT noted that emissions are not disaggregated between the two categories but sufficient explanations on the notation keys used are provided in the IIR. In response to a question raised during the review, Ireland explained that they will include further information such as an overview table in the IIR for the next submission. The TERT notes that this issue does not relate to an over or under-estimate and recommends that Ireland makes an effort to disaggregate emissions between the two categories in order to improve the transparency and comparability of the inventory. The TERT kindly notes that progress in the implementation of the improvement will

No No No

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be reviewed in 2019.

2017 IE-1A2gviii-2018-0001

No 1A2gviii Stationary combustion in manufacturing industries and construction: Other, SO2, NOX, NH3, NMVOC, PM2.5, 2000-2015

For category 1A2, Stationary Combustion in Manufacturing Industries and Construction, the TERT noted an inconsistency between the IIR - page 45 where it is stated that "There is no disaggregation between mobile and stationary machinery, so all emissions are reported under 1A2gvii" and the NFR tables where the notation key ‘IE’ is applied for the NFR 1A2gvii Mobile Combustion in Manufacturing Industries and Construction: Other and not for NFR 1A2gviii Stationary Combustion in Manufacturing Industries and Construction: Other. In response to a question raised during the review, Ireland explained that Ireland's national Energy statistics do not provide an estimate of fuel used in mobile construction. All emissions associated with the category 1A2g are reported in 1A2gviii. The IIR should state 1A2gviii and not 1A2gvii. Mobile emissions (NFR 1A2gvii) should use the notation key ‘IE’ in 1A2gviii. All fuel is assumed stationary. The TERT recommends that Ireland corrects the IIR. The TERT recommends Ireland to collect the necessary activity data or to contact national experts to make assumptions on fuel split, and to estimate emissions separately in its next submission as the emission factors for stationary and mobile combustion differ significantly.

No The TERT reiterates the previous recommendation IE-1A2gviii-2017-0001 in which the TERT encouraged Ireland to collect the necessary activity data or to contact national experts to make assumptions on fuel split, and to estimate emissions separately in its next submission as the emission factors for stationary and mobile combustion differ significantly. This issue could potentially have an impact that is around the threshold of significance. During the 2018 NECD Review, Ireland confirmed that they have started this research. The TERT also recommends that Ireland reports on the results in the next submission or includes a schedule for implementation of this recommendation in its next IIR. The TERT kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

No No No

2017 IE-1A3bi-2018-0001

Yes 1A3bi Road transport:

For category 1A3bi Road Transport: Passenger Cars and pollutants NH3 and PM2.5 for years 2005-2010,

No For category 1A3bi and for pollutants NH3 and PM2.5 with reference to the

No No No

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Passenger cars, NH3, PM2.5, 2005, 2006, 2007, 2008, 2009, 2010

the TERT noted that with reference to the NFR tables (with new provided Activity data, see IE-1A3b-2017-0001) that there is a lack of transparency regarding the trends in emissions and implied emission factors. For NH3, the emissions jump by 36 per cent between 2004 and 2005 and the IEF by 27 per cent. For PM2.5, the IEF jump by 12% between 2006 and 2010. In response to a question raised during the review, Ireland explained that Ireland applies a Tier 3 methodology to estimate emission from road transport using COPERT 4. v11.3. COPERT generated NH3 emission factors (g/km) for gasoline passenger cars for emission technology Euro 1 & Euro 2 are 30 percent and 52 per cent, respectively higher than those for 2004. In addition, gasoline use increased by 5.3 per cent between 2004 and 2005. The increase in emissions of PM2.5 can be explained by a combination of an increase in diesel passenger cars between the years 2006 and 2010, in part due to the indirect effect of motor taxation policy and economic growth leading to increased number of diesel cars less than 2L in the vehicle population, which more than offset reductions associated with the introduction of Euro 4. The TERT agreed with the explanation provided by Ireland. The TERT recommends that Ireland includes such explanations in its next submission.

previous review recommendation, IE-1A3bi-2017-0002, the TERT noted fluctuations in emission factors particularly between the years 2004 to 2007. In response to a question raised during the review, Ireland provided sufficient explanations for the trend in PM2.5 emission factors and also explained that the observed fluctuation in NH3 emission factors are due to a reduction in sulphur content in petrol and diesel from 2004 to 2005. The TERT notes that this issue does not relate to an over- or under-estimate and recommends that Ireland includes these explanations in the IIR. The TERT kindly notes that progress in the inclusion of this information in the IIR will be reviewed in 2019.

2017 IE-1A3bii-2018-0001

No 1A3bii Road transport: Light

For category 1A3bii Road Transport: Light Duty Vehicles and pollutant NH3 for years 2000-2010,

No For category 1A3bii, pollutant NH3 and years 2015-2016, with reference to the

No No No

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duty vehicles, NH3, 2000-2015

the TERT noted that with reference to the NFR tables (with new provided Activity data, see IE-1A3b-2017-0001) there is a lack of transparency regarding the trends in emissions and Implied emission factors. For NH3, the IEF is between 1.8 and 5.2 times lower than the EU28 median IEF for the whole time series. The NH3 emissions jump by 55 per cent between 2014 and 2015 and the IEF by 38 per cent. In response to a question raised during the review, Ireland explained that both gasoline fuelled, and diesel fuelled light duty vehicles exist in Ireland. The IEF (g/km) for gasoline and diesel fuelled LDVs is between 0.001 and 0.002 g/km for the entire time series using the Tier 3 COPERT 4v11.3 model. These are similar to the Tier 2 diesel exhaust emission factors presented in the 2016 EMEP/EEA Guidebook. Furthermore, it should be noted that in 1990 85.7 per cent of the total mileage for LDVs was from diesel fuelled vehicles with the remainder being petrol fuelled. This has grown to 99.8 per cent in 2015. The introduction of Euro 6 LDV vehicles in 2015, which have an increased emission factor (g/km) above Euro 1, 2, 3 and 4 and an associated 5.4 per cent increase in total mileage for diesel powered LDVs between 2014 and 2015, explains the 55 per cent increase in emissions of NH3 identified by the TERT. The TERT agreed with the explanation provided by Ireland. The TERT recommends that Ireland includes such explanations in its next submission.

previous review recommendation, IE-1A3bii-2017-001, the TERT noted that emissions increased substantially compared to the previous years, however the information provided in the IIR still was not sufficient. In response to a question raised during the review, Ireland explained that this is due to the introduction of Euro 6 diesel Light Commercial Vehicles in the Irish vehicle fleet and an increase in activity. The TERT notes that this issue does not relate to an over- or under-estimate and recommends that Ireland includes a detailed explanation in the IIR for the next submission. The TERT kindly notes that progress of inclusion of the information in the IIR will be reviewed in 2019.

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2017 IE-1A3dii-2018-0001

Yes 1A3dii National navigation (shipping), NOX, 1990-2015

For category 1A3dii National Navigation (Shipping) and NOX, the TERT noted that Tier 1 default emission factors are applied to a key category. In response to a question raised during the review, Ireland explained that due to a lack of input data, the implementation of a Tier 2 approach is not possible at the moment, further stating that they would consider the Tier 2 approach from the 2016 EMEP/EEA Guidebook for the next annual submission. The TERT acknowledged the answer provided by Ireland, stating that the application of Tier 1 default emission factors may result in either over- or under-estimates of national emissions, depending on the actual composition of the Irish fleet. The TERT further notes that these over- or under-estimates would be below the threshold of significance for a technical correction. However, as the contribution of category 1A3dii to the national total NOX emissions have been increasing over time, this might change for future years. Therefore, the TERT recommends implementing a Tier 2 approach with the next annual submission.

No For category 1A3dii National navigation (shipping), for pollutant NOX and for the time period 1990-2015, the TERT noted that there is a lack of transparency regarding the use of Tier 1 method for the calculation of emissions for this key category. In response to a question raised during the review, the TERT noted that Ireland was unable to prioritise resources to look at this emissions source in greater detail during this reporting round. The TERT notes that this issue does not relate to an over- or under-estimate and recommends implementing a Tier 2 approach in the next annual submission. The TERT kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

No No No

2017 IE-1A5a-2018-0001

No 1A5a Other stationary (including military), SO2, NOX, NH3, NMVOC, PM2.5, 2000-2015

For category 1A5a Other Stationary (Including Military) for the entire time series, the TERT noted that in the NFR tables, the notation key ‘IE’ is reported, but no explanation is provided in the IIR to know in which sector emissions are taken into account. In response to a question raised during the review, Ireland explained that Ireland does not report any emissions under category 1A5 Other

No The TERT reiterates the previous recommendation, IE-1A5a-2017-0001 in which the TERT recommended that Ireland adds in the IIR the justification of the notation key ‘IE’ used in 1A5a. During the 2018 NECD Review, Ireland confirmed that the recommendation would be addressed in the future

No No No

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Combustion. The notation key is used to indicate that military emissions (mobile and stationary) are included elsewhere. All stationary emissions from military are reported in sector 1A4a Commercial/Institutional Combustion and all mobile military emission are reported under 1A3 (aviation and road). The TERT notes that this issue does not relate to an over- or under-estimate. In accordance with a recommendation of the 2015 LRTAP review, the TERT recommends that Ireland adds information in the IIR detailing the use of the notation keys.

submissions of the IIR. The TERT recommends Ireland add in the IIR the justification of the notation key for 1A5a and kindly notes that progress in implementation of the improvement will be reviewed in 2019.

2017 IE-1B2b-2018-0001

No 1B2b Fugitive emissions from natural gas (exploration, production, processing, transmission, storage, distribution and other), NMVOC, 1990-2015

For category 1B2b Fugitive Emissions from Natural Gas and pollutant NMVOC the TERT noted that ‘NE’ notation key has been used. In response to a question raised during the review, Ireland explained that the offshore Wells are on the seabed, the only onshore natural gas refinery in Ireland has commenced production in December 2015 and the total network losses of natural gas have been estimated to be negligible. The TERT partly agreed with the explanation provided by Ireland. The TERT recommends that the time series of NMVOC emissions from natural gas production, storage, transmission and distribution be estimated in the next submission in order to enhance the completeness of the inventory. The TERT also recommends Ireland to apply an estimate of the natural gas speciation to estimate the NMVOC emissions based on the CH4 and CO2

No The TERT reiterates the previous recommendation IE-1B2b-2017-0001 from the 2017 NECD Review in which the TERT recommended that the time series of NMVOC emissions from natural gas production, storage, transmission and distribution will be estimated to the next submission in order to enhance the completeness of the inventory. The TERT also recommended Ireland to apply an estimate of the natural gas speciation to estimate the NMVOC emissions based on the CH4 and CO2 estimates reported in Ireland's GHG emission inventory. During the 2018 NECD Review, Ireland explained that they are in conjunction with the operator of the gas refinery investigating

No No No

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estimates reported in Ireland's GHG emission inventory.

the estimation of NMVOC from 1B2b for 2016. The operator did not report fugitive emissions from the site in its PRTR returns for 2016 and 2017 as they not exceed the threshold under Annex II of the Regulation (EC) No 166/2006. Furthermore, Ireland notes that the emission factor presented in the 2016 EMEP/EEA Guidebook is based on CORINAIR (1990) and as such may not be reflective of site activities at this new state of the art gas refinery. The TERT recommends that Ireland calculates the emissions either in conjunction with the gas refinery operator or with a country-specific emission factor for the next submission and includes information on the emission source and the methodology applied to estimate the emissions in the IIR of the next submission. The TERT kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

2017 IE-1B2c-2018-0001

No 1B2c Venting and flaring (oil, gas, combined oil and gas), SO2, NOX, NMVOC, PM2.5, 1990-2015

For category 1B2c Venting and Flaring (Oil, Gas, Combined Oil and Gas) and all NECD pollutants, the TERT noted that ‘NE’ notation key had been reported. In response to questions raised during the review, Ireland explained that there had been episodes of flaring at offshore gas facilities in 1999 and 2001, during commissioning of new Wells, and

No The TERT reiterates the previous review recommendation IE-1B2c-2017-0001 in which the TERT recommended that Ireland estimates emissions from flaring at off-shore gas facilities in the next submission. During the 2018 NECD Review, Ireland confirmed that the

No No No

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at the on-shore gas refinery one day in 2015. Ireland stated that these emissions might be estimated and reported in the next submission. Regarding the flares at refineries, Ireland explained that the emissions had been included within the category 1A1b Petroleum Refining, as site emissions were calculated based on total metered fuel use. The TERT noted that the issue would be below the threshold of significance for a technical correction. The TERT recommends that Ireland investigates whether all gas flared, including residual gas from the refining process, have been considered for estimating emissions from fuel combustion at the refinery and explore the possibility for distinguishing the amounts of fuel burned from the combustion for energy purposes. The TERT recommends that Ireland includes an estimation of emissions from this category in the next submission.

recommendation would be addressed by the next submission and that they will include emissions from flaring episodes at the off-shore gas facilities in 1999 and 2001 and from the on-shore gas refinery in 2016/2017. Ireland stated in the previous review that emissions from flaring, if occurring would be reported with other emissions reported under 1A1b as site emissions are based on total metered fuel use and informed the TERT that they will include further explanatory text in the IIR of the next submission to further clarify the issue. The TERT recommends Ireland to include this information in the IIR and kindly notes that the progress of the implementation of the improvement will be reviewed in 2019.

2017 IE-2A2-2018-0001

No 2A2 Lime production, PM2.5, 1990-2015

For category 2A2 Lime Production and pollutant PM2.5, the TERT noted that the ‘NA’ notation key had been reported. Ireland had assumed that all emissions from lime production were estimated within NFR 1A2f Stationary Combustion in Manufacturing Industries and Construction: Non-metallic Minerals using a Tier 1 approach drawing a comparison between the estimates based on fuel consumption (NFR 1A2f) and those based on lime production (NFR 2A2). The TERT recommended Ireland to use a Tier 2 approach for the category

No For category 2A2 and pollutant PM2.5 for the years 1990-2015 the TERT noted that with reference to the observation IE-2A2-2017-0001 that was raised during the 2017 NECD Review that Ireland has still reported the notation keys ‘NA’ and ‘NO’ inconsistently over the years instead of ‘IE’ for PM2.5, although Ireland has stated in the IIR that those emissions are assumed to be included in those reported within NFR 1A2f. In

No No No

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1A2f, as it was a key category for this pollutant, and the estimation and reporting of PM2.5 emissions within category NFR 2A2. In response to a question raised during the review, Ireland stated that the recommendation would be considered for the next submissions and provided a preliminary estimate based on the lime production of the emissions for 2015 using the Tier 2 method for NFR 2A2. Furthermore, Ireland explained that distinguishing between combustion and process emissions was difficult since no fuel data were available prior to 2005 (prior to EU ETS). Also, in the main facility in Ireland, lime is only an intermediate product. The TERT has not been able to assess whether the impact of the methodological review would be above the threshold of significance since no data on fuel consumption for lime production were provided to the TERT. The TERT recommends that Ireland research the amounts of fuel consumed for this process via talks with the plants or national association.

response to a question raised during the review, Ireland explained that Ireland has 3 lime producing plants which all use multiple fuels, one of them produce Periclase where lime is an intermediary product, and because of that it is not possible to ascertain which fuel is used and the amount used for lime production only. Preliminary estimates indicate the issue is below the threshold of significance and due to current resource constraints Ireland considers this not feasible to calculate the emissions for the whole time series before the review ends. Ireland stated that they will consider this issue for the 2019 reporting of emissions. The TERT agreed with the explanation provided by Ireland and noted that the issue is below the threshold of significance for technical correction. The TERT recommends that Ireland estimates PM2.5 emissions from the lime production separately from the fuel combustion activity and includes those estimates in its next submission. In case this is not possible, the TERT recommends Ireland to use the correct notation key in the NFR tables and explain the use of this notation key in the IIR. The TERT kindly notes that

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progress in the implementation of the improvement will be reviewed in 2019.

2017 IE-2A3-2018-0002

No 2A3 Glass production, PM2.5, 1990-2015

For category 2A3 Glass Production, the TERT noted a potential over-estimation of process emissions for glass production as it had calculated emissions for category 2A3, while Tier 1 emission factors had been applied for category 1A2f Stationary Combustion in Manufacturing Industries and Construction: Non-metallic Minerals. In response to a question raised during the review, Ireland explained that the data on fuel consumption by the glass industry were not able to be isolated from the national energy statistics. The TERT noted that the issue is below the threshold of significance for a technical correction. The TERT recommends Ireland to consider ways to eliminate this over-estimation.

No For category 2A3 and pollutant PM2.5 for the years 1990-2015, with reference to the observation IE-2A3-2017-0001 the TERT noted that it is not clear from the IIR 2018 whether a recommendation to disaggregate process related emissions from fuel-derived emissions has been acted on. In response to a question raised during the review, Ireland explained that they will include process emissions for PM2.5 from 2A3 Glass production in the inventory using the Tier 2 emission factors presented in Tables 3.3, 3.5 and 3.6 from Chapter 2A3 of the 2016 EMEP/EEA Guidebook in the next submissions. Ireland also stated that they will add further explanatory text in the IIR of its next submission. The TERT agreed with the explanation provided by Ireland and recommends that Ireland include the PM2.5 estimates from the glass production in the inventory in its next submission. The TERT also kindly notes that progress of the implementation of the improvement will be reviewed in 2019.

No No No

2017 IE-2D3b-2018-0001

No 2D3b Road paving with

For category 2D3b Road Paving with Asphalt, the TERT noted that PM2.5 emissions have not been

RE For category 2D3b and pollutant PM2.5 for the years 2005, 2010, 2015 and 2016

TC No No

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asphalt, PM2.5, 2005, 2010, 2015

estimated for the activity 'Road paving with asphalt'. In response to a question raised during the review, Ireland provided a revised estimate for PM2.5 for years 2005, 2010 and 2015. The TERT agreed with the revised estimate provided by Ireland. The TERT noted that the issue is below the threshold of significance for technical corrections. The TERT recommends that Ireland includes the revised estimate in its next submission.

the TERT noted that the PM2.5 emissions were reported 10 fold higher for the whole time series than they were calculated for the Revised Estimate (IE-2D3b-2017-001) provided by Ireland during the 2017 NECD Review. In response to a question raised during the review, Ireland acknowledged that by mistake an incorrect emission factor was used, and explained that it would be corrected in its next submissions. Ireland did not provide a revised estimate in response to the question.The TERT decided to calculate a technical correction for the years 2005, 2010, 2015 and 2016 which was accepted by Ireland. The estimates demonstrate that the issue is above the threshold of significance. The TERT recommends that Ireland include a revised estimate in its next submission.

2017 IE-2D3c-2018-0001

No 2D3c Asphalt roofing, NMVOC, PM2.5, 1990-2015

For category 2D3c Asphalt Roofing, the TERT noted that emissions from category 2D3c are not estimated. In response to a question raised during the review, Ireland explained that they have been investigating possible sources of activity data for asphalt roofing and are yet to identify a reliable time series of asphalt production data for using in roofs. Ireland stated the intention to report emissions from this source, once a suitable data

No For category 2D3c and pollutants NMVOC and PM2.5 for the years 1990-2015, with reference to the previous review recommendation IE-2D3c-2017-0001, the TERT notes that Ireland has still not reported NMVOC and PM2.5 emissions for this category and has labelled them with the notation key ‘NE’ (Not Estimated). The TERT also noted

No No No

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source and a robust methodology have been identified. The TERT agreed with the explanation provided by Ireland. The TERT noted that the issue is below the threshold of significance for a technical correction. The TERT recommends that Ireland continues to look into that issue and when a reliable source for the activity data has been identified then include the calculated emissions in the inventory.

that there was no further information in the IIR 2018 on that issue. In response to a question raised during the review, Ireland explained that due to resource constraints the issue of possible sources of activity data for asphalt roofing is not solved, because they are yet to identify a reliable time series of asphalt production data for roofing use. Ireland has requested data from the Irish Asphalt Producers association (IAPA) and the PRODCOM data was requested from the national statistics agency (CSO), however neither of these organisations could provide a suitable data source and a robust methodology has not yet been identified. Ireland stated that they do not envisage that emissions will be reported in time for the 2019 submission, but they will endeavour to find a suitable data source and report emissions when this is achieved. The TERT agreed with the explanation provided by Ireland and recommends that Ireland continues to investigate possible sources for suitable activity data and include in the IIR an explanation on why this activity has not yet been included in the inventory and information on the steps and schedules for the improvement. In case suitable

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activity data becomes available the TERT recommends Ireland to estimate and report the emissions in the next submission. The TERT kindly notes that progress in the implementation of the recommendation will be reviewed in 2019.

2017 IE-3Da2b-2018-0001

No 3Da2b Sewage sludge applied to soils, NH3, 1990-2015

For category 3Da2b Sewage Sludge Applied to Soils and pollutants NH3 and NOX for years 1990-2015, the TERT noted that the 2006 IPCC Guidelines volatilisation factor is used. However, The TERT notes that 2006 IPCC Guidelines fraction refers to total N volatilised as NH3 and NOX. The TERT noted that this issue is below the threshold of significance for a technical correction. The TERT recommends the use of the 2016 EMEP/EEA Guidebook in the next submission.

No For category 3Da2b Sewage sludge applied to soils and pollutants NH3 and NOX for the years 1990-2016 the TERT noted that Ireland used the 2016 EMEP/EEA Guidebook as recommended in the previous review recommendation IE-3Da2b-2017-0002. However, the NH3 EF defined in the Guidebook is not 0.13 kg NH3-N per kg N applied but 0.13 kg NH3 per kg N applied (see 2016 EMEP/EEA Guidebook, Annex 1, p. 30) and no conversion to the mass with the factor 17/14 is needed. The TERT considered this as a potential over-estimate of NH3 emissions but noted that the issue is below the threshold of significance for a technical correction. Regarding the calculation of NO2 emissions the TERT encourages Ireland to use the EF provided in Annex 2, p.32 of the 2016 Guidebook because N amounts are available in the Irish inventory. In response to a question

No No No

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raised during the review, Ireland explained that it will recalculate NH3 emissions without using the conversion factor of 17/14. The effect would amount in a reduction in emissions of 48.6 t NH3 annually across the Time Series. Additionally, Ireland will examine calculations on the basis of N quantities rather than a per capita basis. The effect of such a recalculation would amount to a 0.06 kt reduction in emissions of NO2 annually. The TERT recommends that Ireland revises the methodology to the next submission as announced in Ireland’s answer to the TERT. The TERT also kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

2017 IE-3Dc-2018-0001

No 3Dc Farm-level agricultural operations including storage, handling and transport of agricultural products, PM2.5, 1990-2015

For category 3Dc Farm-level Agricultural Operations Including Storage, Handling and Transport of Agricultural Products and pollutant PM2.5 for years 1990-2015, the TERT noted that emissions are reported as ‘NE’. In response to a question raised during the review, Ireland explained that it intends to report emissions in the correct NFR category and use updated emission factors and methodology as presented in the 2016 EMEP/EEA Guidebook in its next submission. The TERT recommends that the emissions are estimated and reported using the 2016 EMEP/EEA

No For category 3Dc Farm-level agricultural operations including storage, handling and transport of agricultural products and pollutant PM2.5, with reference to the previous review recommendation IE-3Dc-2017-0001, the TERT notes that Ireland reported PM2.5 emissions from agricultural operations under NFR category 3Dc, as recommended by the TERT in 2017. Estimates were based on annual fertilizer weights and EFs provided in CEPMEIP (2001).

No No No

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Guidebook in the next submission. Additionally, Ireland reported PM2.5 emissions under category 3Da1 Inorganic N-fertilisers. Estimates were calculated following the default Tier 1 methodology provided in the 2016 EMEP/EEA Guidebook, as recommended by the TERT in 2017 (Table 3.1). In response to a question raised during the review, Ireland explained that it reported emissions in two different categories due to transparency reason but can in its next submission report all emissions under 3Dc if suggested to be a better approach by the TERT. The TERT recommends that Ireland reports all PM emissions from agricultural operations under source category 3Dc in its next submission in line with the default allocation provided in Table 3.1 of the 2016 EMEP/EEA Guidebook. The TERT also kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

2017 IE-5D-2018-0001

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

For category 5D Wastewater Handling and pollutant NMVOC for the years 2005, 2010, 2015, the TERT noted that Ireland does not report emissions. In response to a question raised during the review, Ireland provided an initial assessment of NMVOC emissions from wastewater handling. This assessment showed that the emissions are far

No For sector 5D the TERT noted that the previous recommendation IE-5D-2017-0001 is addressed in the IIR Chapter 6.5 Wastewater handling where the use of the notation key ‘NE’ is justified with the 0.006 % contribution of the source to the national total emissions and thus

No No No

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below the threshold of significance. The TERT recommends that Ireland includes NMVOC emissions from wastewater handling in the next submission.

deemed negligible. The TERT agrees to the minor importance of this source, however, the reporting guidelines do not give any thresholds for not reporting emissions. In response to the question on the issue raised during the 2018 review Ireland replied that they will endeavour to include this observation in the inventory improvement plan for 2018 and provide an appropriate response to the issue in its next annual submission. The TERT recommends that Ireland starts a study on collecting activity data for 5D and includes activity data and emission estimates for the entire time series in its 2019 submission, or that Ireland includes a schedule for implementation of this study in its next IIR. The TERT kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

2017 IE-5E-2018-0001

No 5E Other waste, PM2.5, 2005, 2010, 2015

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

RE The TERT noted with reference to implementing recommendation IE-5E-2017-0001 that estimates for PM2.5 are presented for all relevant 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 a question raised during the 2018 review Ireland submitted a file

No No No

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the IIR. which details the methodological approach, activity and emission factors used in the estimation of PM2.5 emissions from category 5E. The TERT thanks Ireland for providing the detailed information. The TERT recommends that Ireland includes the detailed information on activity data, emission estimates and the methodology description for 5E in its 2019 submission. The TERT kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

27

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 Ireland pursuant to (Directive (EU) 2016/2284).

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

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

25. The TERT considers that it received responses from Ireland 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 that the information in the IIR was not sufficient, except for Agriculture, but Ireland provided explanatory information on request.

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

28. The TERT noted that Tier 2 methods are in general used for key categories. Instances where a Tier 1 method was used for a key category are flagged in Table 4.

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

30. The TERT noted that the submitted HMs and POPs inventory is only partly compiled in line with the 2016 EMEP/EEA Guidebook, because of some missing estimates for which methods exist in the Guidebook (sector IPPU), and is in line Directive (EU) 2016/2284.

31. The TERT noted that for HMs and POPs reported national total for compliance (row 144) differs from national total (row 141) due to the sources included on row 153. The TERT also noted that national total for compliance (row 144) is reported in line with NEC Directive.

32. The TERT noted that Ireland 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 Ireland (see Table 3).

28

Table 3: Recommendations from the NECD Review 2018 concerning the first phase of the in-depth review of national emission inventories of POPs and heavy metals6



RecommendationTier 1 used for a key category

Issue related to use of GB prior to the 2016 version

IE-1A2f-2018-0002

Yes 1A2f Stationary Combustion in Manufacturing Industries and Construction: Non-metallic minerals, Cd, Hg, 2000-2016

For Cd and Hg emissions from category 1A2f, Stationary Combustion in Manufacturing Industries and Construction: Non-metallic minerals, which is a key category for these emissions, Ireland responded to a question raised during the review that a Tier 1 method is applied to calculate the emissions. The TERT notes that according to the reporting guidelines, countries should make every effort to use a Tier 2 or higher (detailed) methodology, including country-specific information, for a key source. The TERT recommends that Ireland calculates the emissions of Cd and Hg in category 1A2f using a Tier 2 or Tier 3 methodology for the next submission. The TERT also kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

Yes No

IE-1A4bi-2018-0002

Yes 1A4bi Residential: Stationary, PAHs, PCBs, Cd, Hg, Pb, PCDD/F, 2000-2016

For PAH, PCB, Cd, Hg, Pb and dioxin emissions from category 1A4bi Residential: Stationary, which is a key category for these emissions, Ireland responded to a question raised during the review that a Tier 1 method is applied to calculate the emissions in this category. The TERT notes that according to the reporting guidelines, countries should make every effort to use a Tier 2 or a higher (detailed) methodology, including country-specific information, for a key category. The TERT recommends that Ireland calculates PAH, PCB, Cd, Hg, Pb and PDCC/F emissions from category 1A4bi using a Tier 2 or a Tier 3 methodology for the next submission. The TERT also notes that progress in the implementation of the improvement will be reviewed in 2019.

Yes No

IE-1A1a-2018-0001

No 1A1a Public Electricity and Heat Production, Cd,

For Cd, Hg and HCB emissions from category 1A1a, Public Electricity and Heat Production, which is key category for these emissions, Ireland responded to a question raised during the review that a Tier 1 method is applied to calculate the emissions. According to the reporting guidelines, countries should make every effort to use a Tier 2 or higher (detailed) methodology, including

Yes 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.

29





Hg, PCBs, 1990, 2005, 2016

country-specific information. The TERT recommends that Ireland calculates the emissions of Cd, Hg and HCB in category 1A1a using a Tier 2 or Tier 3 methodology for the next submission. The TERT also notes that progress in the implementation of the improvement will be reviewed in 2019.

IE-1B2aiv-2018-0001

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

For Cd, Hg and dioxin emissions from NFR 1B2aiv Fugitive Emissions Oil: Refining /Storage, the TERT noted that no emissions are reported while a method is available in the 2016 EMEP/EEA Guidebook. In response to a question raised during the review, Ireland explained that the emissions reported by the oil refinery and included under NFR 1A1b. The TERT notes that this issue does not relate to an over- or under- estimate and recommends that Ireland changes the notation key in 1B2aiv to ‘IE’ and include an explanation in the IIR in the next submission. The TERT kindly notes that progress in the implementation of the improvement of the IIR will be reviewed in 2019.

No No

IE-2-2018-0001

No 2 Industry, Hg, 1990, 2005, 2016

For NFR 2, Industry, and pollutant Hg for the years 1990, 2005 and 2016 the TERT noted that the 2016 EMEP/EEA Guidebook provides Hg emission factors for NFR categories 2D3c Asphalt roofing and 2K Consumption of POPs and heavy metals, for which Ireland has not reported emissions and which may have a significant impact on the overall Hg emissions in the Industry/Product Use sectors. In response to a question raised during the review, Ireland explained that they are aware of the emission factors for Hg in the 2016 EMEP/EEA Guidebook for NFR sector 2D3c and explained that they have requested data from the Irish Asphalt Producers association (IAPA), and that the PRODCOM data was requested from the national statistics agency (CSO), however, neither of these organisations could provide suitable data. Until a suitable source of activity data is identified this category cannot be assessed for potential Hg emissions. In relation to emissions of Hg, Ireland notes that a Tier 1 approach is available in the 2016 EMEP/EEA Guidebook and that they will investigate whether mercury containing button cell batteries are either in use in Ireland or are banned and that they will include that information in the IIR/NFR of future submissions. The TERT agreed with the explanation provided by Ireland and recommends that Ireland continues to investigate the possibilities to include Hg emission estimates in the inventory from the Industry/Product Use sectors in their future submissions and that Ireland includes an improvement plan with a schedule in the IIR.

No No

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The TERT kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

IE-2A3-2018-0001

No 2A3 Glass Production, Cd, Hg, Pb, 2016

For category 2A3 , Glass Production, and pollutants Cd, Hg, Pb for the year 2016 the TERT noted that with reference to the NFR table that Ireland has reported the notation keys ‘NE’ (Not Estimated) for Cd, Hg and Pb in the NFR category 2A3 for the year 2016, although the notation key ‘IE’ (Included Elsewhere) has been used for NOX, NMVOC, SO2, CO and also the notation key ‘NE’ has been used for HCB. For other pollutants Ireland has used the notation keys ‘NO’ (Not Occurring). In response to a question raised during the review, Ireland explained that the manufacture of glass was not a predominant industry in Ireland, being limited to three sectors: lead crystal, container glass, and glass wool. The only container glass plant closed in 2002, one of the lead crystal plants closed in early 2006, the glass wool plant closed in 2008 and the last one, (second of the two) lead crystal plant closed in 2009. Therefore, after this period emissions of all pollutants should be reported as ‘NO’. Ireland stated that they will review the use of notation keys for category 2A3 for its next submission. The TERT agreed with the explanation provided by Ireland and recommends that Ireland corrects the incorrect notation keys in its next submission and provides information on the history of this source in the IIR. TERT kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

No No

IE-2C1-2018-0001

No 2C1 Iron and Steel Production, HCB, 1990, 2005, 2016

For category 2C1, Iron and Steel Production, and pollutant HCB for the years 1990, 2005 and 2016 with reference to the NFR tables the TERT noted that Ireland used the notation key ‘NE’ for HCB emissions for the whole time series, although the 2016 EMEP/EEA Guidebook provides Tier 1 and Tier 2 emission factors for HCB for NFR category 2C1. In response to a question raised during the review, Ireland explained that the notation key for this category should be ‘IE’ (included elsewhere). Ireland added that emissions of HCB are reported and accounted for under NFR 1A2a as it has not been possible to separate process and fuel combustion related HCB emissions for the period 1990-2002 for which there was an iron and steel industry in Ireland. The TERT agreed with the explanation provided by Ireland and recommends that Ireland corrects the incorrect notation keys to its next submission and includes the explanation in the IIR. The TERT kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

No No

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IE-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 for the years 1990, 2005 and 2016 the TERT noted that Ireland reported the notation key ‘NA’ while the 2016 EMEP/EEA Guidebook provides Tier 1 and Tier 2 EFs for Hg from fluorescent tubes. In response to a question raised during the review, Ireland explained that they will review the 2016 EMEP/EEA Guidebook emission factor for Hg for fluorescent tubes with a view to include the emissions in the next submission. The TERT agreed with the explanation provided by Ireland and recommends that Ireland includes Hg emissions from 2D3a in its next submission or explains in the IIR where the emissions are allocated or why the emissions are not occurring, and in that case provides a schedule for the improvement. The TERT kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

No No

IE-2D3g-2018-0001

No 2D3g Chemical Products, PAHs, 1990, 2005, 2016

For category 2D3g Chemical Products and PAH emissions for the years 1990, 2005 and 2016 the TERT noted that Ireland has reported the notation key ‘NE’ (Not Estimated) for the whole time series, although the 2016 EMEP/EEA Guidebook provides an emission factor for benzo(a)pyrene from asphalt blowing. In response to a question raised during the review, Ireland explained that as asphalt blowing does not occur in Ireland and that they will correct the notation ‘NE’ to ‘NO’ (Not Occurring) to the next submission. The TERT agreed with the explanation provided by Ireland and recommends that Ireland corrects the notation key and includes the justification for the use of the notation key to its next submission. The TERT also kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

No No

IE-5C2-2018-0003

No 5C2 Open Burning of Waste, PAHs, 1990-2016

For sector 5C2 Open Burning of Waste the TERT noted that for PAHs there is an increase in emission values in the period 2005-2011. A clear justification for this increase and for the subsequent drop cannot be found in the IIR. In response to the question on the issue raised during the 2018 review Ireland replied that emissions from 5C2 are as the IIR describes (page 128) due to the burning of farm plastics in open fires. Historical information in relation to the collection/recycling/burning of farm plastics has been difficult to obtain, therefore a number of sources are used in deriving the activity data. Ireland also provided a file with detailed information on this subject. The TERT thanks Ireland for providing the detailed information and recommends that Ireland starts a study on getting activity data for 5C2 and includes activity data and emission estimates for the entire time series in its 2019 submission, or that Ireland

No No

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includes a schedule for implementation of this study in its next IIR. The TERT kindly notes that progress in the implementation of the improvement will be reviewed in 2019.

33

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 Ireland:

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

b. 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.

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

7

Description ReferencePollutant estimates (kt)

2005 2010 2015 2016

NOX

National total (row 141) Annex1, 15/03/2018 168.602 117.026 111.276 112.277

National total for compliance (row 144) 161.690 98.652 89.113 91.234

Adjustment provided by Ireland and recommended to be accepted by the TERT

3B Manure management and 3D Crop production and agricultural soils

- -30.961 -30.769 -31.766

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

Calculated using above data

168.602 117.026 111.276 112.277

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.

34


2005 2010 2015 2016

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


161.690 67.691 58.345 59.468

NMVOC





120.205 109.488 106.687 108.408



119.245 55.297 47.856 46.839

SOX





71.803 26.345 15.011 13.771



71.762 26.342 15.004 13.766

NH3





113.433 108.256 111.162 116.723



113.294 108.230 111.121 116.700

PM2.5



Difference between original estimates and technical correction deemed necessary by the TERT

2D3b Road paving with asphalt IE-2D3b-2018-0001 -3.060 -2.070 -1.710 -1.710



20.497 17.424 14.445 13.758

35


2005 2010 2015 2016



19.769 16.92 13.84 13.231

36

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

36. Ireland did not raise any issues with the calculated estimates in Table 4 or the calculated estimates for the technical correction deemed necessary by the TERT, presented in Table 5.

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

37. Ireland did submit in 2018, 5 adjustment applications undergoing review under this contract.

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 Ireland

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 EMEP/ EEA 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 5: Summary tables of Technical Corrections and/or Revised Estimates

1

EMRT ID: IE-2D3b-2018-0001

EMRT URL:https://emrt-necd.eionet.europa.eu/2018/IE-2D3b-2018-0001

Member State: Ireland

Sector: 2D3b Road paving with asphalt

Gases: PM2.5

Completed by (SE): Ardi Link

Reviewed by (LR): Kristina Saarinen

Reviewed by (Counterpart): Jeroen Kuenen

Reviewed by QC Controller: Chris Dore

The underlying problem: An emission factor 1000 g/Mg asphalt was used.

The rationale for the corrected estimate:

Correct emission factor is 100 g/Mg asphalt.

Summarise the methodology used:

The emission factor is taken from the 2016 EMEP/EEA Guidebook, Chapter 2.D.3.b Road paving with asphalt, Table 3.2. The emission factor is multiplied with the amount

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

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of produced asphalt.

2

Details of the corrected estimate

Original estimate (kt)Notes

Year NOX SO2 NMVOC NH3 PM2.5

IE-2D3b-2018-0001-OE 2005 3.4 Taken from the NFR tables




Was a Revised Estimate received from the MS? no

Revised Estimate received from MS (kt)Notes


IE-2D3b-2018-0001-RE 2005

IE-2D3b-2018-0001-RE 2010

IE-2D3b-2018-0001-RE 2015

IE-2D3b-2018-0001-RE 2016

Was the Revised Estimate accepted by the TERT?

Technical Correction calculated by TERT (kt)Notes


IE-2D3b-2018-0001-TC 2005 0.34Taken from the spreadsheet '2D3b Road Paving'




Was the Technical Correction accepted by the MS?

yes

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

Table 6: Summary information on the Submitted Adjustment Applications, Ireland, 2018

Source Sector Years Pollutant Application type 3B Manure management3D Crop production and agricultural soils

2010-2016 NOX New adjustment application in 2018

1A3b Road transport1A3c Railways 1A3dii National navigation (shipping)1A4ciii Agriculture /Forestry/Fishing: National fishing;

2010-2016 NOX Previously accepted

1A4ai Commercial/institutional: Stationary1A4bi Residential: Stationary

2010-2016 NOX Previously accepted

2H2 Food and beverages industry 2010-2016 NMVOC Previously accepted3B Manure management;3D Crop production and agricultural soils

2010-2016 NMVOC Previously accepted

1 Introduction 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.

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 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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bring compliance and be invited to withdraw one or more of its adjustments. In making an adjustment application, Member States must demonstrate that extraordinary circumstances have given rise to revisions to their emissions estimates. These extraordinary circumstances fall into three broad categories:

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

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.

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.

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.

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.

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The reviews of submitted adjustments were performed by an expert review team. The team was formed of the experts identified in Table 7.

Table 7: The 2018 Review team of new and previously accepted adjustment applications

Role Sectors NameAdjustment lead reviewer(s) All Chris Dore

Ole- Kenneth NielsenExpert reviewer(s) Energy: Stationary and fugitives Rianne Dröge

Katrina Young Expert reviewer(s) Energy: Transport and off-road Jean-Marc André

Giorgos MelliosTim MurrellsGiannis Papadimitriou

Expert reviewer(s) Industrial processes and product use Ardi Link

Expert reviewer(s) Agriculture Michael AnderlBernard HydeMette MikkelsenBeatriz Sánchez

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

2 Review of Adjustments approved prior to 2018 Ireland had 4 adjustments granted prior to 2018, details of which can be found in Table 8. Ireland included information on these adjustments in its submission under the National Emissions Ceilings Directive (Directive (EU) 2016/2284) of 15/02/2018, reporting sectoral level data in Annex VII to the reporting guidelines and in line 143 of Annex I. Along with Annex VII, Ireland 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 12 lists the documentation provided by Ireland.

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 was checked in detail during the review when the adjustment application was first made.

The reviewers noted that some substantial recalculations had been undertaken, and asked for additional information to clarify the reasons for the recalculations. Ireland provided information that explained the recalculations arise from a change from COPERT 4 v11.3 to COPERT 5, and included detailed information regarding recalculations. The reviewers were fully satisfied with the information provided, and therefore conclude that the adjustment should continue to be accepted.

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Table 8: 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

Ireland 1A3b Road transport1A3c Railways 1A3dii National navigation (shipping)1A4ciii Agriculture /Forestry/Fishing: National fishing;

2010-2016 NOX Significantly different EFs

The TERT reviewed the information submitted by Ireland on the previously accepted adjustment for categories 1A3bi, 1A3bii, 1A3biii, 1A3biv, 1A3c, 1A3dii and 1A4ciii, for NOX and for the years 2010 through 2016. The TERT found it necessary to ask Ireland for clarifications, and Ireland did answer these questions satisfactorily.Following the review of the information made available prior to and during 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 these sources and pollutant.

-11.9 % in 2016Accept

Ireland 1A4ai Commercial/institutional: Stationary1A4bi Residential: Stationary

2010-2016 NOX Significantly different EFs

The TERT reviewed the information submitted by Ireland on the previously accepted adjustment for NOX from 1A4ai and 1A4bi. The TERT did not find it necessary to ask Ireland for clarifications. The IIR indicates that the methodology is unchanged from last years’ submission. The magnitude of recalculations are in the range of 0.00-0.03% for 1A4ai and 0.02% for 1A4bi. This is caused by small changes in activity data (mainly in 2015) and an update of the NOX emission factor of biomass from the EMEP/EEA Guidebook 2013 to the EMEP/EEA Guidebook 2016. 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 these sources and pollutant.

-2.4 % in 2016Accept

Ireland 2H2 Food and beverages industry

2010-2016 NMVOC New Source The TERT reviewed the information submitted by Ireland on the previously accepted adjustment for 2H2 for NMVOC for 2010 - 2016. The TERT did not find it necessary to ask Ireland for clarifications, or 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 this source and pollutant.

-14.3 % in 2016Accept

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Conclusions text Recommendation & Impact on National Total

Ireland 3B Manure management;3D Crop production and agricultural soils

2010-2016 NMVOC New Source The TERT reviewed the information submitted by Ireland on the previously accepted adjustment for NMVOC emissions from categories 3B and 3D and years 2010 – 2016. In its IIR 2018 Ireland declared that Ireland's adjustment application for NMVOC submitted under NECD is based on the same methodology as used for the original approved adjustment application which has been reviewed and approved by the EC. The TERT checked the numbers against the NMVOC emission amounts reported in the NFR Annex I under sectors 3B and 3D and found out that the adjustment values are correct. However, the allocation of NMVOC emissions provided in Ireland’s adjustment application was not consistent to Ireland’s annual inventory submission 2018. The reason was that following a recommendation of the 2017 NECD expert review, Ireland had shifted its NMVOC emissions from source category 3Da1 Inorganic N-fertilisers to source category 3De Cultivated crops but did not change the allocation in its adjustment applications (NFR Annex II, Annex VII and IIR chapter 9.4.3). The TERT found it necessary to ask Ireland for clarification. Ireland confirmed that the adjustment reported as 3Da1 in NFR Annex II, Annex VII and IIR section 9.4.3 should refer to 3De Cultivated crops. This typographical error will be amended for Ireland's next submission and NECD Review 2019. Following the review of the information made available prior to and during 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 does continue to accept the most recent submission as a valid adjustment for these sources and pollutant.

-43.3 % in 2016Accept

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3 Review of New Adjustments Submitted in 2018

a) Assessment of Formal Criteria

Ireland notified the European Commission through the EIONET Central Data Repository (CDR) partnership network of the EEA through the Executive Secretary of its intention to apply for a new adjustment on 15/02/2018. All supporting information requested by Directive 2016/2284, Article 5.1, Article 8.4 and Annex IV, Part 4 was provided as part of the Informative Inventory Report by the legal deadline of the 15 March of the same year. No additional documentation was provided during the review in response to requests from the reviewers. Table 12 lists the documentation provided by Ireland.

Ireland submitted an application for emissions adjustments to 2010-2016 for the pollutants and sectors indicated below:

a. NOX, NMVOC – Agriculture 3B, 3D.

Ireland provided information on exceedance of emission ceilings (DIRECTIVE 2001/81/EC) for NOX in 2010-2016.

Ireland provided information on the impact of the adjustment to its emission inventory, and the extent to which it would reduce the current exceedance and possibly bring the Party in compliance with emission reduction commitments.

Ireland did include information on when it will meet its emission ceilings for both NOX and NMVOC without the adjustment in the supporting documentation. Under the WAM scenario, Ireland is expected to come into compliance with the NOX emission ceiling in 2018, but would not reach compliance with the NMVOC ceiling before compliance requirements change to emission reduction commitments from 2020 onwards.

The adjustment application requires the provision of specific supporting information to demonstrate compliance with specific criteria (Directive 2016/2284, Annex IV, Part 4.1(d), and EB Decision 2012/3, para 6a-c as amended by EB Decision 2014/1, Annex, para 3). Ireland provided supporting documentation and the reviewers have reviewed this information (see Table 12) with regard to these criteria. The reviewers considered the supporting information provided by Ireland to be complete.

b) Manure Management 3B (NOX and NMVOC), Agricultural Soils 3D (NOX, NMVOC)

Assessment of Consistency with Requirements of EB Decision 2012/3 as amended by EB Decision 2014/1

Ireland made an application based on criteria: “a new source”.

The reviewers noted that no methodologies for the estimation of NOX emissions from manure management (including manure application on land), and agricultural soils were included in the EMEP/CORINAR Inventory Guidebook 1999 and conclude that the provided supporting evidence does comply with the criteria presented in Decision 2012/3, and that the circumstances on which the adjustment is based could not have been reasonably foreseen by the Party when the emission ceilings were established for 2010.

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The reviewers studied the documentation that was provided to support the application (listed in Table 12).

The supporting information provided by Ireland clearly presented the adjustment totals, and the method of calculation was transparent. As the adjustment application is for a new source, the quantification is equal to the sectoral emissions.

Assessment of the Quantification of the Impact of the Revision

The adjustment application process requires that Ireland submits a quantification of the impact of the adjustment for which an application has been submitted. Table 2 provides an overview of the NOX adjustment applications of Ireland in the Agriculture sector.

Table 9 Ireland’s NOX Adjustment Applications for Agriculture, 2010-2016

Reference number

Pollutant NFR14 unit 2010 2011 2012 2013 2014 2015 2016

IE_3B_NOX NOX 3B kt -0.768 -0.760 -0.808 -0.802 -0.798 -0.815 -0.837

IE_3D_NOX NOX 3D kt -30.193 -27.474 -28.073 -30.538 -29.811 -29.954 -30.929

NOX Total kt -30.961 -28.234 -28.881 -31.339 -30.609 -30.769 -31.766

The reviewers concluded that the quantification of the recalculations, as calculated by Ireland, included no calculation errors and is in line with the most up-to-date available EMEP/EEA Inventory guidebook and scientific literature.

In its application for an adjustment Ireland provide information that allowed the reviewers to conclude that its national totals of NOX emissions would be below their ceilings in accordance with the NECD from 2010 onwards, if the proposed adjustments are accepted.

The TERT concluded that increased emissions are based on “new” emission sources reported by Ireland. The reviewers is therefore of the opinion that this is a valid case for an adjustment.

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c) Summary of review of new adjustment applications

Table 10: Conclusions and recommendations following the review of new adjustment applications



Conclusions text Recommendation & Impact on National Total11

Ireland 3B Manure management3D Crop production and agricultural soils

2010-2016 NOX New Source The TERT reviewed the information submitted by Ireland on the application for an adjustment for 3B Manure Management and 3D Agricultural Soils for NOX. The TERT did find it necessary to ask Ireland for clarifications. Following the review of the information made available prior to and during the review, the TERT concludes that the new application for an adjustment, does meet the requirements stated in the NECD for an adjustment, and therefore recommends that the European Commission does accept the new application as a valid adjustment for these sources and pollutant.

Accept

-28.3 % in 2016

11 The national total used in this calculation excludes adjustments and is on the basis of fuel sold. The data are presented for context only, and not for compliance purposes.

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4 Conclusions and Recommendations of TERT concerning adjustment applications

The reviewers have undertaken a full and thorough assessment of the application for an adjustment of the NOX emissions inventory that was submitted by Ireland in 2018 for Agriculture 3B and 3D. Adjustments approved prior 2018 were also reviewed for NOX emissions from Road Transport 1A3b, Railways 1A3c, National navigation (shipping) 1A3dii, Agriculture/ Forestry/ Fishing 1A4ciii, Commercial/ institutional: Stationary 1A4ai and Residential: Stationary 1A4bi and NMVOC emissions from Food and beverages industry 2H2 and Agriculture 3B and 3D.

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.

Table 11 below provides a summary of the adjustment applications received from Ireland, and the subsequent recommendations made by the reviewers to the European Commission.

Source Sector Years Pollutant Application type Recommendation3B Manure management3D Crop production and agricultural soils

2010-2016 NOX New adjustment application in 2018

Accept

1A3b Road transport1A3c Railways 1A3dii National navigation (shipping)1A4ciii Agriculture /Forestry/Fishing: National fishing;

2010-2016 NOX Previously accepted Accept

1A4ai Commercial/institutional: Stationary1A4bi Residential: Stationary

2010-2016 NOX Previously accepted Accept

2H2 Food and beverages industry

2010-2016 NMVOC Previously accepted Accept

3B Manure management;3D Crop production and agricultural soils

2010-2016 NMVOC Previously accepted Accept

Table 11: Recommendations following the 2018 review of new and previously accepted adjustment applications

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5 Information Provided by IrelandTable 12 lists the information provided by Ireland in its adjustment application. The information provided by Ireland was stored on the EMRT-NECD review platform.

Table 12: Information Provided by Ireland

Filename Short description of content

IE_ApprovedAdj_IE_2018 The notification of a 2018 adjustment application and previously accepted adjustments

Annex_II_Adjustment_Application_IEv2 The detailed calculations for the quantification of the 2018 adjustments new and previously accepted.

Annex_VII_Adjustments_summary_IEv2 Individual adjustment details and aggregated sum of adjustments

IE_IIR_2018 The Informative Inventory Report provided by IE.

The reviewers found it necessary to ask Ireland for further information in one instance. Details are given below in Table 13.

Table 13: Additional Information Provided by Ireland

Filename Short description of content

Q/A exchange on EMRT-NECD 26/07/18

The reviewers asked for more information regarding the consistency of the adjustment allocation between the NFR Annex I and the NFR. IE replied with an explanation and clarified that there was a typographical error and the adjustment reported as 3Da1 in NFR Annex II, Annex VII and IIR section 9.4.3 should refer to 3De.

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References and Supporting Documents

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

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

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

EU 2018, Guidance for TERT 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/?uri=CELEX:32001L0081

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

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

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001L0081

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

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

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

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

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

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

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