Review of the 2017 Adjustment Applications by Germany

in accordance with article 5(1) and 5(6) of Directive 2016/2284 (NECD)

Date: 14 June 2017

Review conducted by: EC, DG Environment, unit C.3 – Clean Air

Contents1. Introduction....................................................................................................................................2

2. Context and organization of the review.........................................................................................3

3. Overview of 2017 adjustment applications....................................................................................4

4. Assessment of reporting formalities...............................................................................................5

5. Assessment of consistency with requirements of NEC Directive....................................................7

6. Assessment of consistency with corresponding approved adjustments under CLRTAP.................9

7. Conclusions...................................................................................................................................13

8. Information provided....................................................................................................................14

9. References....................................................................................................................................15

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1. Introduction

Article 5 of the European Union's National Emission Ceilings Directive 2016/2284/EU (NECD) explains that Member States may draw on a number of different flexibilities in order to address some of the uncertainties inherent in setting national emission reduction commitments. This includes the option set out in paragraph 1 of applying for an adjustment to the national total, under selected circumstances.

Article 21(2) of the NECD allows the use of the adjustment flexibility set out in article 5(1) also for the 2010 ceilings as laid down in Directive 2001/81/EC. As specified in article 21(1) of the NECD the 2010 ceilings will remain applicable until 31/12/2019.

Article 5(1) permits Member States - for the purpose of checking compliance with the emission ceilings - to establish adjusted annual national emission inventories where non-compliance with their emission reduction commitments would result from applying improved emission inventory methods updated in accordance with scientific knowledge.

In accordance with Annex IV part 4(1)(d) of the NECD an adjustment to a national emission inventory must be consistent with at least one of the following three circumstances:

(i) emission source categories are indentified that were not accounted for at the time when the emission reduction commitments were set(ii) emission factors used to estimate emissions are significantly different to those used when the emission reduction commitments were set(iii) methodologies used to estimate emissions are significantly different to those used when the emission reduction commitments were set

Member States that intend to apply for an adjustment shall in accordance with article 5(5) of the NECD inform the Commission thereof by 15 February of the reporting year concerned. In accordance with Article 10(2), one month later, by 15 March, the Member States concerned shall provide the adjusted national emission inventories and supporting information prepared in accordance with Annex IV of the NECD. Article 8(4) and part 4 of Annex IV of the NECD further specify that Member States that opt for the adjustment flexibility must include the supporting information in the Informative Inventory Report, including a demonstration that the use of the adjustment procedure fulfils the relevant conditions set out in article 5(1) and part 4 of Annex IV. The minimum supporting information required is highlighted in part 4(1) of Annex IV (which is based on paragraph 2 of the Annex to LRTAP EB Decision 2012/12). In the chapeau of Annex IV of the NECD 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 LRTAP EB decisions 2012/3 and 2012/12, as amended by 2014/1), while also explaining that reliance upon these EMEP Reporting Guidelines is without prejudice to the additional arrangements specified in Article 5(1) second

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subparagraph and part 4 of Annex IV. Additional technical guidance for making adjustment applications is made available in LRTAP report ECE/EB.AIR/130.

2. Context and organization of the review

As set out in article 5(6) of the NECD, an adjustment application submitted by a Member State must be reviewed by the Commission, with the assistance of the European Environ-ment Agency, within 9 months from the date of receipt of the supplementary information as included in the informative inventory report. This means at the latest by 15 December if the reporting date of the informative inventory report is respected. Where the Commission has raised no objections in this period, the adjustment application shall be considered as valid and accepted for that year. In case of rejection the Commission shall adopt a decision within these 9 months informing the Member State concerned that the adjustment application cannot be accepted and stating the reasons for that refusal.

The adjustment applications for NOX, NMVOC and NH3 that Germany - in accordance with articles 5(5) and 10(2) of the NECD - has submitted to the Commission in the first quarter of 2017, have already been reviewed and approved under the LRTAP Convention (CLRTAP) in previous years1.

The Commission, with technical support from the European Environment Agency, has reviewed Germany's adjustment applications again independently, but with due considera-tion of the findings and conclusions of the corresponding adjustment reviews conducted under CLRTAP in 2014, 2015 and 2016, and in particular relying on the technical assessments of the quantification of the impact of the adjustments as performed by the expert review teams under CLRTAP.

In line with articles 5(6) and 10(2) of the NECD the Commission's independent review concentrated on consistency checks with (i) the requirements of the NECD (fulfilment of the relevant conditions set out in article 5(1) and part 4 of Annex IV) and (ii) the corresponding approved adjustments under CLRTAP (requirement of consistency with reporting to CLRTAP).

In accordance with article 5(8) of the NECD the Commission took into account the relevant guidance documents developed under CLRTAP for conducting its review.

1 See: http://www.ceip.at/ms/ceip_home1/ceip_home/adjustments_gp/adj_country_data/

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3. Overview of 2017 adjustment applications

Table 1 shows the details of Germany's adjustment applications submitted to the Commission in 2017. All emission adjustments included in the applications for NO X, NMVOC and NH3 have been originally approved under CLRTAP in either 2014, 2015 or 2016. The emission adjustments concern the road transport sector (NFR 1A3b) for NOX and the agricultural sector (NFR 3B-3D-3I) for NOX, NMVOC and NH3.

With respect to NOX, the transport adjustment was originally approved under CLRTAP in 2014. The road transport adjustment submitted by Germany in 2016 included significant recalculations and hence was again subjected to a full review. This 2016 updated adjustment was also approved.

Table 1: Adjustment applications to emission inventories submitted under NECD in 2017

Pollutant NFR source category yearscode description

NOX 1A3bi, ii, iii and iv a Road transport 2010-2015NOX 3B b Manure management 2010-2015NOX 3Da1 Inorganic N-fertilizers 2010-2015NOX 3Da2a Animal manure applied to soils 2010-2015NOX 3Da3 Urine and dung deposited by

grazing animals2010-2015

NOX 3Da2c Other organic fertilisers applied to soils (including compost)

2010-2015

NOX 3I Agriculture other 2010-2015NMVOC 3B b Manure management 2010-2015NMVOC 3De Cultivated crops 2010-2015NH3 3Da2c Other organic fertilisers applied

to soils (including compost)2010-2015

NH3 3I Agriculture other 2010-2015Abbreviations: NFR = Nomenclature for Reporting; NOX = nitrogen oxides; NMVOC = non-methane volatile organic compounds; NH3 = ammoniaa 1A3bi = passenger cars, 1A3bii = light duty vehicles, 1A3bii = heavy duty vehicles and buses, 1A3biv = mopeds and motorcycles

b 3B covers the entire source category

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4. Assessment of reporting formalities

The reporting formalities are set out in articles 5(5), 8(4), 8(5) and 10(2) of the NECD.

a. Assessment of reporting formalities of article 5(5)

"Member States that intend to apply paragraph 1, 2, 3 or 4 shall inform the Commission thereof by 15 February of the reporting year concerned. That information shall include the pollutants and sectors concerned and, where available, the magnitude of the impacts upon national inventories."

Germany notified the Commission of its intention to apply for adjustments to its NOX, NMVOC and NH3 emission inventories on 13 February 2017 and thus in time for the legal deadline of 15 February2. The notification makes reference to the pollutants (NOX, NMVOC, NH3) and sectors (road transport and agriculture) concerned. The notification letter also makes reference to the related adjustment applications under CLRTAP and previous IIR for more detailed information on the adjustments concerned. The main emissions reporting template submitted by the deadline of 15 February reports on the magnitude of the adjustments in row 143 (sum of the adjustments).

b. Assessment of reporting formalities of article 8(4)

"Member States that opt for a flexibility under Article 5 shall include the information demonstrating that the use of that flexibility fulfils the relevant conditions set out in Article 5(1) and Part 4 of Annex IV or in Article 5(2), (3) or (4), where applicable, in the informative inventory report of the year concerned."

Germany provided the requested supporting information in chapter 11 of its 2017 informative inventory report and associated excel file3.

No additional information or clarification was requested by the Commission during the review. No additional information was provided by Germany.

c. Assessment of reporting formalities of article 8(5)

"Member States shall prepare and update the national emission inventories (including if appropriate adjusted national emission inventories), national emission projections, spatially disaggregated national emission inventories, large point source inventories and the accompanying informative inventory reports in accordance with Annex IV."

2 See: http://ec.europa.eu/environment/air/pollutants/pdf/emission_inventory_adjustment_applications_2010_ceilings_of_directive_2001.pdf3 Chapter 8 contains a full overview of the information provided

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In Annex IV of the NECD it is specified that adjusted emission inventories should be prepared using the EMEP Reporting Guidelines (which in its turn contains references to the relevant LRTAP EB decisions 2012/3 and 2012/12, as amended by 2014/1), while also explaining that reliance upon these EMEP Reporting Guidelines is without prejudice to the additional arrangements specified in Article 5(1) second subparagraph and part 4 of Annex IV.

In reference to corresponding approved adjustments under CLRTAP (approved in previous years), Germany reported summary information on the adjustments using the excel reporting template Annex VII of the EMEP Reporting Guidelines (used for the reporting of the approved adjustments under CLRTAP).

d. Assessment of reporting formalities of article 10(2)

"Member States shall provide their national emission inventories and projections, spatially disaggregated national emission inventories, large point source inventories and the informative inventory reports referred to in Article 8(1), (2) and (3) and, where relevant, in Article 8(4), to the Commission and the European Environment Agency in accordance with the reporting dates set out in Annex I.

This reporting shall be consistent with the reporting to the Secretariat of the LRTAP Convention."

The reporting date for the annual reporting of the informative inventory reports set in Annex I is 15 March.

Germany provided its informative inventory report together with its quantitative information in excel format by the legal deadline of 15 March.

Germany’s reporting of its national emission inventories, adjusted national emission inventories and informative inventory report to the Commission is fully consistent with Germany's corresponding reporting to CLRTAP. Germany also provided the Commission a separate Declaration on consistency with reporting of the approved adjustments under CLRTAP (see more in chapter 6).

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5. Assessment of consistency with requirements of NEC Directive

The relevant conditions are set out in article 5(1) and part 4 of Annex IV of the NECD.

a. Assessment of requirement of paragraph 1(a) of part 4 of Annex IV

"Evidence that the concerned national emission reduction commitment/s is/are exceeded"

Table 2 provides the overview of the reported national emissions totals for NOX, NMVOC and NH3 for the time series 2010-2015, submitted under the NECD by Germany on 13 February 2017.

Table 2: National emission totals (fuel sold based)

National emission total 2010 2011 2012 2013 2014 2015NOX (kt) 1334,03 1313,90 1271,55 1267,82 1220,89 1187,45NMVOC (kt) 1216,12 1130,91 1105,07 1091,94 1016,28 1020,18NH3 (kt) 681,43 723,24 704,76 729,52 737,37 759,27

The reported national totals for NOX for the years 2010 to 2015 exceed the 2010 NOX NEC ceiling of 1051 kt. The reported national totals for NMVOC for the years 2010 to 2015 exceed the 2010 NMVOC NEC ceiling of 955 kt. The reported national totals for NH 3 for the years 2010 to 2015 exceed the 2010 NH3 NEC ceiling of 550 kt.

b. Assessment of requirement of paragraph 1(b) of part 4 of Annex IV

"Evidence of the extent to which the adjustment to the emission inventory reduces the exceedance and contributes to compliance with the concerned national emission reduction commitment/s"

Germany provided information on the impact of the proposed adjustments to its emission inventories for NOX, NMVOC and NH3. The adjusted national emission inventories for NOX

would reduce Germany’s exceedance of its NOX ceiling in 2010 from 27% to 2% and bring Germany by 2015 9% below its NOX ceiling. The adjusted national emission inventories for NMVOC would reduce Germany’s exceedance of its NMVOC ceiling in 2010 from 22% to 2% and bring Germany in 2015 18% below its NMVOC ceiling. The adjusted national emission inventories for NH3 would reduce Germany’s exceedance of its NH3 ceiling in the period 2010 to 2015 with 7 to 12 % points (from 24-38% to 17-26%).

c. Assessment of requirement of paragraph 1(c) of part 4 of Annex IV

"An estimation of whether and when the concerned national emission reduction commitment/s is/are expected to be attained based on national emission projections without adjustment"

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The national 'unadjusted' WM4 emission projections that Germany in accordance with article 10(2) of the NECD submitted to the Commission on 16 March 2017 show that NOX and NMVOC emissions are projected to drop to respectively 847,4 kt and 987,7 kt by 2020. Based on linear interpolation between reported unadjusted national totals in 2015 (1187,4 kt for NOX and 1020,2 kt for NMVOC) and projected unadjusted WM national totals in 2020 (847,4 kt for NOX and 987,7 kt for NMVOC), it can be expected that the NOX and NMVOC ceilings will be attained (without the application of adjustments) by 2017 and 2019 respectively. The reported national 'unadjusted' WM emission projections further show that the NH3 ceiling of 550 kt will not be attained with current legislation by 2030 (projected estimate for 2030 is 780,0 kt). The reported national 'unadjusted' WaM5 projections (including current planned additional measures) show possible compliance with the 2010 ceiling on the basis of the unadjusted NH3 inventory between 2025 and 2030.

d. Assessment of requirement of paragraph 1(d) of part 4 of Annex IV and article 5(1)

"Evidence that the adjustment is consistent with one or several of the three circumstances ...'

The three circumstances in paragraph 1(d) account for (i) new emission source categories, (ii) significant changes in emission factors and (iii) significant changes in methodologies.

The requirement in paragraph 1(d) of part 4 of Annex IV follows the main condition set in article 5(1) that the adjustment flexibility is allowed where non-compliance is the result from applying improved emission inventory methods updated in accordance with scientific knowledge.

With respect to NOX Germany submitted an adjustment application to account for new emission source categories (NFR 3B, 3Da1, 3Da2a, 3Da2c, 3Da3 and 3I) and significant changes in emission factors (NFR 1A3bi-iv). With respect to NMVOC Germany submitted an adjustment application to account for new emission source categories (NFR 3B and 3De). With respect to NH3 Germany submitted an adjustment application to account for new emission source categories (NFR 3Da2c and 3I).

Germany provided sufficient evidence in its supporting information to demonstrate that the proposed adjustments for NOX, NMVOC and NH3 are consistent with the respective circumstances. The expert review team under CLRTAP reached the same conclusions in its review reports for Germany (review reports 2014, 2015 and 2016).

4 WM = projections with measures: projections that encompass the effects, in terms of air pollutant emission reductions, of policies and measures that have been adopted at the time the projections were calculated.5 WaM = projections with additional measures: projections that encompass the effects in terms of air pollutant emission reductions of policies and measures which have been adopted, as well as policies and measures which are planned at the time the projections were calculated.

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6. Assessment of consistency with corresponding approved adjust-ments under CLRTAP

The adjustments for Germany regarding NMVOC in manure management (NFR 3B) and cultivated crops (NFR 3De), regarding NOX in road transport (NFR 1A3bi-iv), manure management (NFR 3B), agricultural soils (NFR 3D) and agriculture other (NFR 3I) and regarding NH3 in organic fertilizers applied to soils (NFR 3Da2c) and agriculture other (NFR 3I) have been approved under CLRTAP, originally in 2014 (for NOX road transport and agriculture), 2015 (for NMVOC agriculture) and 2016 (for NH3 and NOX agriculture).

Germany submitted a 'declaration on consistent reporting of approved adjustments' on the 10th of February 2017 declaring that "the methods / emission factors and activity data used for the calculation of emissions for the years 2010 - 2015 are the same for all sectors and pollutants as in the year the adjustments were approved".

The national emission inventories and adjustment applications for NOX, NMVOC and NH3

submitted under the NECD in February 2017 are fully consistent (identical) with the 2017 LRTAP submissions.

In accordance with point 1(a) and (b) of part 4 of Annex IV of the new NECD, adjustments are in principle only eligible for the years were they are really necessary to reach compliance. It should be noted that although part of the adjustment applications, while needed to reach compliance with applicable ceilings for the first couple of years are no longer needed for reaching compliance in the more recent years, the approach followed in the review was to also accept the application of all adjustments to the more recent inventories including those adjustments that are no longer required to reach compliance in the more recent years, this in order to preserve consistency with already approved adjustments under CLRTAP.

a. NOX adjusted emissions

Table 3 provides an overview of the NOX adjusted emissions, as submitted in 2014, 2015 and 2016 under CLRTAP and as submitted in 2017 under CLRTAP and the NECD, together with the reported emission totals for the respective sectors for which the adjusted emissions apply.

Table 3: NOX adjusted emissions - overview

NFR source category Description 2010 2011 2012 2013 2014 2015Submission 2017 - NECD and CLRTAPNational total (kt) Fuel sold based 1334,03 1313,90 1271,55 1267,82 1220,89 1187,45NEC 2010 ceiling (kt) Stricter than 2010 GP ceiling 1051 1051 1051 1051 1051 1051 Exceedance of NEC 2010 ceiling (kt) 283,03 262,90 220,55 216,82 169,89 136,451A3bi, ii, iii, iv Sector estimate (kt) Road transport - fuel sold based 502,12 478,36 463,00 455,03 432,10 403,54

Adjustment (kt) -151,30 -146,80 -145,00 -142,40 -127,20 -100,903B Sector estimate (kt) Manure management 2,05 2,01 1,98 1,98 1,99 1,97

Adjustment (kt) -2,05 -2,01 -1,98 -1,98 -1,99 -1,973Da1, 3Da2a, Sector estimate (kt) Agricultural soils 102,28 111,08 105,93 106,84 108,52 114,12

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3Da3 Adjustment (kt) -102,28 -111,08 -105,93 -106,84 -108,52 -114,123Da2c Sector estimate (kt) Other organic fertilizers applied 6,51 8,14 8,97 10,82 11,37 11,44

Adjustment (kt) to soils (including compost) -6,51 -8,14 -8,97 -10,82 -11,37 -11,443I Sector estimate (kt) Agriculture other 0,16 0,18 0,15 0,17 0,16 0,16

Adjustment (kt) -0,16 -0,18 -0,15 -0,17 -0,16 -0,16 Total adjustments (kt) -262,30 -268,21 -262,03 -262,20 -249,24 -228,59Submission 2016 - CLRTAP (accepted adjustments) National total (kt) Fuel sold based 1336,73 1315,88 1274,96 1272,41 1224,29 GP 2010 ceiling (kt) Less strict than 2010 NEC ceiling 1081 1081 1081 1081 1081 Exceedance of GP 2010 ceiling (kt) 255,73 234,88 193,96 191,41 143,291A3bi, ii, iii, iv Sector estimate (kt) Road transport - fuel sold based 502,12 478,41 463,09 455,10 435,15

Adjustment (kt) -151,27 -146,86 -145,10 -142,50 -128,093B Sector estimate (kt) Manure management 2,05 2,01 1,98 1,98 1,99

Adjustment (kt) -2,05 -2,01 -1,98 -1,98 -1,993Da1, 3Da2a, Sector estimate (kt) Agricultural soils 102,27 111,08 105,93 106,83 108,463Da3 Adjustment (kt) -102,27 -111,08 -105,93 -106,83 -108,463Da2c Sector estimate (kt) Other organic fertilizers applied 6,51 8,14 8,97 10,81 11,68

Adjustment (kt) to soils (including compost) -6,51 -8,14 -8,97 -10,81 -11,683I Sector estimate (kt) Agriculture other 0,16 0,18 0,15 0,18 0,19

Adjustment (kt) -0,16 -0,18 -0,15 -0,18 -0,19 Total adjustments (kt) -262,26 -268,27 -262,14 -262,29 -250,42Submission 2015 - CLRTAP (accepted adjustments) National total (kt) Fuel sold based 1333,74 1310,81 1270,16 1269,18 GP 2010 ceiling (kt) Less strict than 2010 NEC ceiling 1081 1081 1081 1081 Exceedance of GP 2010 ceiling (kt) 252,74 229,81 189,16 188,181A3bi, ii, iii, iv Sector estimate (kt) Road transport - fuel sold based 505,44 478,51 463,49 460,76

Adjustment (kt) -101,00 -96,00 -91,00 -86,003B Sector estimate (kt) Manure management 2,06 2,03 2,00 2,01

Adjustment (kt) -2,06 -2,03 -2,00 -2,013Da1, 3Da2a, Sector estimate (kt) Agricultural soils 102,26 111,06 105,91 106,733Da3 Adjustment (kt) -102,26 -111,06 -105,91 -106,73 Total adjustments (kt) -205,32 -209,09 -198,91 -194,74Submission 2014 - CLRTAP (accepted adjustments) (with use of pre-2014 NFR codes) National total (kt) Fuel sold based 1328,07 1293,64 1273,38 GP 2010 ceiling (kt) Less strict than 2010 NEC ceiling 1081 1081 1081 Exceedance of GP 2010 ceiling (kt) 247,07 212,64 192,381A3bi, ii, iii, iv Sector estimate (kt) Road transport - fuel sold based 508,23 480,27 460,01

Adjustment (kt) -101,00 -96,00 -91,004B Sector estimate (kt) Manure management 1,93 1,89 1,88

Adjustment (kt) -1,93 -1,89 -1,884Da1, 4D2a, Sector estimate (kt) Agricultural soils 101,82 110,29 104,804D2c Adjustment (kt) -101,82 -110,29 -104,80 Total adjustments (kt) -204,75 -208,17 -197,69

In its 2014 submission to CLRTAP Germany applied for adjustments to its reported NOX

emissions from road transport (NFR 1A3bi-iv). The adjustment application for the road transport sector was reviewed and accepted under CLRTAP. It was acknowledged that current applicable emission factors for road transport are significantly different from emission factors used when ceilings were set. The NOX adjustment application for road transport was renewed under CLRTAP in 2016 with adjustment values being recalculated. Due to the significant recalculations a full review under CLRTAP was conducted again in 2016. The recalculated adjustment values - around 50 to 60% higher than the originally approved adjustments in 2014 - were again accepted. The 2017 submission of the NOX

application for road transport under NECD and CLRTAP presents almost identical adjustment values than those approved under CLRTAP in 2016.

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In 2014 Germany applied in addition to its adjustments for road transport, also for NO X

adjustments to its reported emissions from the agricultural sector (NFR sectors 3B and 3Da1, 3Da2a and 3Da3) under CLRTAP. The adjustment application for these NFR sectors, being acknowledged as new source categories, was reviewed and accepted under CLRTAP. This 2014 adjustment application was extended in 2016 with adjustments to account for emissions from NFR 3Da2c and 3I, also acknowledged as new sources which were not accounted for when ceilings were set. The 2017 NOX submission of the adjustment applications under NECD and CLRTAP for the agricultural sector includes adjustment values that are only marginally different from adjustment values submitted and approved under CLRTAP in 2014 to 2016. Small changes are due to small revisions in activity data. Given that the adjustment applications for the agricultural sector are to account for new source categories for which emissions were not considered when ceilings were set, the quantified adjustment values remain equal to the sectoral emissions. There is no need to reconsider the original approvals of these adjustment applications under CLRTAP in 2014 / 2016.

b. NMVOC adjusted emissions

Table 4 provides an overview of the NMVOC adjusted emissions, as submitted in 2015 and 2016 under CLRTAP and as submitted in 2017 under CLRTAP and the NECD, together with the reported emission totals for the respective sectors for which the adjusted emissions apply.

Table 4: NMVOC adjusted emissions - overview

NFR source category Description 2010 2011 2012 2013 2014 2015Submission 2017 - NECD and CLRTAPNational total (kt) Fuel sold based 1216,12 1130,91 1105,07 1091,94 1016,28 1020,18NEC 2010 ceiling (kt) Equal to 2010 GP ceiling 995 995 995 995 995 995Exceedance of NEC 2010 ceiling (kt) 221,12 135,91 110,07 96,94 21,28 25,183B Sector estimate (kt) Manure management 191,74 191,70 194,11 198,36 199,70 198,63

Adjustment (kt) -191,74 -191,70 -194,11 -198,36 -199,70 -198,633De Sector estimate (kt) Cultivated crops 9,49 8,99 10,02 10,32 11,34 9,85

Adjustment (kt) -9,49 -8,99 -10,02 -10,32 -11,34 -9,85 Total adjustments (kt) -201,23 -200,69 -204,13 -208,68 -211,04 -208,48Submission 2016 - CLRTAP (accepted adjustments)National total (kt) Fuel sold based 1235,61 1165,66 1133,68 1110,35 1041,36GP 2010 ceiling (kt) Equal to 2010 NEC ceiling 995 995 995 995 995Exceedance of GP 2010 ceiling (kt) 240,61 170,66 138,68 115,35 46,363B Sector estimate (kt) Manure management 191,74 191,70 194,11 198,36 199,70

Adjustment (kt) -191,74 -191,70 -194,11 -198,36 -199,703De Sector estimate (kt) Cultivated crops 9,49 8,99 10,02 10,32 11,34

Adjustment (kt) -9,49 -8,99 -10,02 -10,32 -11,34 Total adjustments (kt) -201,23 -200,69 -204,13 -208,68 -211,04Submission 2015 - CLRTAP (accepted adjustments)National total (kt) Fuel sold based 1238,75 1169,00 1136,06 1138,24GP 2010 ceiling (kt) Equal to 2010 NEC ceiling 995 995 995 995Exceedance of GP 2010 ceiling (kt) 243,75 174,00 141,06 143,243B Sector estimate (kt) Manure management 191,74 191,71 194,13 198,39

Adjustment (kt) -191,74 -191,71 -194,13 -198,393De Sector estimate (kt) Cultivated crops 9,49 8,99 10,02 10,32

Adjustment (kt) -9,49 -8,99 -10,02 -10,32 Total adjustments (kt) -201,23 -200,70 -204,15 -208,71

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In its 2015 submission to CLRTAP Germany applied for adjustments to its reported NMVOC emissions from the agricultural sector (NFR sectors 3B and 3De). The adjustment application for the agricultural sector, being acknowledged as a new source category, was reviewed and accepted under CLRTAP. The 2017 NMVOC submission of the adjustment application under NECD and CLRTAP for the agricultural sector (NFR sectors 3B and 3De) includes adjustment values that are almost identical to the adjustment values submitted and approved under CLRTAP in 2015 to 2016. Small changes are due to revisions in activity data. Given that the adjustment applications for the agricultural sector are to account for new source categories for which emissions were not considered when ceilings were set, the quantified adjustment values remain equal to the sectoral emissions. There is no need to reconsider the original approvals of these adjustment applications under CLRTAP in 2015 / 2016.

b. NH3 adjusted emissions

Table 5 provides an overview of the NH3 adjusted emissions, as submitted in 2016 under CLRTAP and as submitted in 2017 under CLRTAP and the NECD, together with the reported emission totals for the respective sectors for which the adjusted emissions apply.

Table 5: NH3 adjusted emissions - overview

NFR source category Description 2010 2011 2012 2013 2014 2015Submission 2017 - NECD and CLRTAP National total (kt) Fuel sold based 681,43 723,24 704,76 729,52 737,37 759,27 NEC 2010 ceiling (kt) Equal to 2010 GP ceiling 550 550 550 550 550 550 Exceedance of NEC 2010 ceiling (kt) 131,43 173,24 154,76 179,52 187,37 209,273Da2c Sector estimate (kt) Other organic fertilizers applied 36,94 46,34 48,45 57,74 60,42 60,73

Adjustment (kt) to soils (including compost) -36,94 -46,34 -48,45 -57,74 -60,42 -60,733I Sector estimate (kt) Agriculture other 3,00 3,40 2,88 3,17 3,03 3,05

Adjustment (kt) -3,00 -3,40 -2,88 -3,17 -3,03 -3,05 Total adjustments (kt) -39,94 -49,74 -51,33 -60,91 -63,45 -63,77Submission 2016 - CLRTAP (accepted adjustments) National total (kt) Fuel sold based 681,61 723,57 705,10 729,95 739,79 GP 2010 ceiling (kt) Equal to 2010 NEC ceiling 550 550 550 550 550 Exceedance of GP 2010 ceiling (kt) 131,61 173,57 155,10 179,95 189,793Da2c Sector estimate (kt) Other organic fertilizers applied 37,03 46,45 48,58 57,83 62,54

Adjustment (kt) to soils (including compost) -37,03 -46,45 -48,58 -57,83 -62,543I Sector estimate (kt) Agriculture other 3,00 3,40 2,88 3,31 3,58

Adjustment (kt) -3,00 -3,40 -2,88 -3,31 -3,58 Total adjustments (kt) -40,03 -49,85 -51,45 -61,15 -66,13

In its 2016 submission to CLRTAP Germany applied for adjustments to its reported NH3

emissions from the agricultural sector (NFR sectors 3Da2c and 3I). The adjustment application for these NFR sectors, being acknowledged as new source categories, was reviewed and accepted under CLRTAP. The 2017 NH3 submission of the adjustment application under NECD and CLRTAP for the agricultural sector (NFR sectors 3Da2c and 3I) includes adjustment values that are slightly lower than the adjustment values submitted and approved under CLRTAP in 2016. Given that this adjustment application for the agricultural sector is to account for new source categories for which emissions were not considered when ceilings were set, the quantified adjustment values remain equal to the sectoral

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emissions. There is no need to reconsider the original approval of this adjustment application under CLRTAP in 2016.

7. Conclusions

The national emission inventories and adjustment applications for NMVOC, NOX and NH3

submitted under the NECD in February/March 2017 are the same as those submitted under CLRTAP in February/March 2017.

Furthermore, as demonstrated in chapter 6 of this report the 2017 adjustment applications submitted under the NECD are consistent with the adjustment applications submitted, reviewed and accepted under CLRTAP in previous years (submissions 2014, 2015 and 2016).

Also, the emission totals for the sectors (NFR source categories) for which the 2017 adjustment applications are proposed under the NECD are in line with the sector totals reported for historic years 2010-2014 in the previous LRTAP submissions 2014, 2015 and 2016.

Given the consistency of the NEC reporting with the CLRTAP reporting and given that the assessments in chapter 5 and 6 of this report have demonstrated that the adjustment applications for NMVOC, NOX and NH3 fulfil the relevant conditions set out in art 5(1) and part 4 of Annex IV of the NECD, the Commission considers the use of the proposed adjustment applications to be valid and accepted for this year.

It should be noted that this review is carried out solely on the basis of the information reported by Member States in February and March 2017 in accordance with Article 10 of the NECD and, where necessary, additional information submitted by 31 May 2017 at the latest. This review does not take into account the preliminary outcomes of the on-going 'emission inventory review' in accordance with Article 10 (3) of the NECD. The conclusions of this review are therefore without prejudice to the outcomes of a future review of an adjustment application for the same NFR categories which shall also consider any changes to reported sector emissions and adjustment values resulting from the 2017 emission inventory review and review recalculated adjustments.

8. Information provided

Table 5 below lists the information provided by Germany in its adjustment applications under the NECD. The information provided by Germany can be downloaded from the Central Data Depository (CDR) of EIONET's Reportnet at following link:

http://cdr.eionet.europa.eu/de/eu/nec_revised/

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In accordance with Article 14(2) of the NECD, the Commission shall also publish this review on its website at the following link:

http://ec.europa.eu/environment/air/pollutants/implem_nec_directive.htm

Table 5: Information provided by Germany

Filename Short description of contentDE - Mitteilung an EU-Kommission zu EBerichterstattung und InvAdj 2017.pdf

Word file that includes the notification of reporting of emission inventories and adjustment applications and also includes a declaration on consistent reporting of the approved adjustments under CLRTAP

German IIR 2017 wiki-based website for the German 2017 IIR that includes a summary and details on the adjustments in chapter 11

DE_2017_Table_VII_Approved_Adjustments.xls

Excel file containing the summary of approved adjustments under CLRTAP

DE_2017_Table_IV_Projections.xls Excel file with latest emission projections which provide an indication as to when DE expects to meet its NMVOC, NH3 and NOX ceiling without adjustments

No additional information or clarification was requested by the Commission during the review. No additional information was provided by Germany.

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9. References

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/EChttp://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32016L2284&from=EN

Directive (EC) 2001/81 of the European Parliament and of the Council of 23 October 2001 on national emission ceilings for certain atmospheric pollutantshttp://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32001L0081

1999 Gothenburg Protocol: Protocol to the 1979 Convention on Long-range Transboundary Air Pollution to Abate Acidification, Eutrophication and Ground-level Ozonehttps://www.unece.org/env/lrtap/multi_h1.html

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 (Executive Body, CLRTAP)https://www.unece.org/fileadmin/DAM/env/documents/2013/air/ECE_EB.AIR_111_Add.1__ENG_DECISION_3.pdf

Decision 2012/4 (ECE/EB.AIR/111/Add.1): Provisional application of amendment to the Protocol to Abate Acidification, Eutrophication and Ground-level Ozone (Executive Body, CLRTAP)https://www.unece.org/fileadmin/DAM/env/documents/2013/air/ECE_EB.AIR_111_Add.1__ENG_DECISION_4.pdf

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 (Executive Body, CLRTAP)https://www.unece.org/fileadmin/DAM/env/documents/2012/EB/Decision_2012_12.pdf

Decision 2013/4 (ECE/EB.AIR/122/Add.1): Reporting of emissions and projections data under the Convention and its protocols in force (Executive Body, CLRTAP)https://www.unece.org/fileadmin/DAM/env/documents/2013/air/eb/2013_4.pdf

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 (Executive Body, CLRTAP)https://www.unece.org/fileadmin/DAM/env/documents/2014/AIR/EB/Decision_2014_1.pdf

Document ECE/EB.AIR/125: Guidelines for Reporting Emissions and Projections Data under the Convention on Long-range Transboundary Air Pollution, 13 March 2014 (Executive Body decision 2013/3, CLRTAP)https://www.unece.org/fileadmin/DAM/env/documents/2013/air/eb/ece.eb.air.125_E_ODS.pdf

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Document ECE/EB.AIR/130: Technical Guidance for Parties Making Adjustment Applications and for the Expert Review of Adjustment Applications, 28 April 2015 (Executive Body report ECE/EB.AIR/127 para 25, CLRTAP)https://www.unece.org/fileadmin/DAM/env/documents/2014/AIR/EB/ECE_EB_AIR_130_ENG.pdf

Emission Inventory Guidebook 2016: EMEP/EEA air pollutant emission inventory guidebook - 2016http://www.eea.europa.eu/publications/emep-eea-guidebook-2016

Emission Inventory Guidebook 1999: EMEP/CORINAIR atmospheric emissions inventory guidebook - second edition 1999http://www.eea.europa.eu//publications/EMEPCORINAIR

Relevant data submitted by Germany to the EC for the review of the adjustmentshttp://cdr.eionet.europa.eu/de/eu/nec_revised/

Document ECE/EB.AIR/GE.1/2014/10: Review of adjustment applications, Report by CEIP, 6 August 2014 (EMEP Steering Body, CLRTAP)https://www.unece.org/fileadmin/DAM/env/documents/2014/AIR/EMEP/ECE_EB.AIR_GE.1_2014_10_ENG.pdf

Document ECE/EB.AIR/GE.1/2015/10 - ECE/EB.AIR/WG.1/2015/13: Review of adjustment applica-tions, Report by CEIP, 6 July 2015 (EMEP Steering Body, CLRTAP)https://www.unece.org/fileadmin/DAM/env/documents/2015/AIR/EMEP/ECE_EB.AIR_GE.1_2015_10_ECE_EB.AIR_WG.1_2015_13_ENG.pdf

Document ECE/EB.AIR/GE.1/2016/10 - ECE/EB.AIR/WG.1/2016/18: Review of adjustment applica-tions, Report by CEIP, 4 July 2016 (EMEP Steering Body, CLRTAP)https://www.unece.org/fileadmin/DAM/env/documents/2016/AIR/EMEP/ECE_EB.AIR_GE.1_2016_10_E.pdf

2014 Review report Germany: Review of the 2014 Adjustment Application by Germany, Expert Review Team Report for the EMEP Steering Body, 1 September 2014 (EMEP Steering Body, CLRTAP)http://webdab1.umweltbundesamt.at/download/adjustments2014/Adjustment_Review_Report_GERMANY_2014.pdf?cgiproxy_skip=1

2015 Review report Germany: Review of the 2015 Adjustment Application by Germany, Expert Review Team Report for the EMEP Steering Body, 1 September 2015 (EMEP Steering Body, CLRTAP)http://webdab1.umweltbundesamt.at/download/adjustments2015/Germany2015-adj.pdf?cgiproxy_skip=1

2016 Review report Germany: Review of the 2016 Adjustment Application by Germany, Expert Review Team Report for the EMEP Steering Body, 24 August 2016 (EMEP Steering Body, CLRTAP)http://webdab1.umweltbundesamt.at/download/adjustments2016/Germany2016-adj.pdf?cgiproxy_skip=1

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