Review Comments by Governments on the Second Order Draft of Volume 4 of 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories

Comment
VolumeID

Chapter

7184

4

2

general

7298

4

2

general

9320

9220

4

4

2

2

From line

To lineCountry

GENERAL COMMENT: we have identified several changes to the GLs that haven't beenmarked, making it very difficult to track the new additions or deletions. This is very
disappointing for reviewers, and reduces the trust of governments in the work done. It
Spain
also can risk the final adoption of the document. We kindly request authors and IPCC
secretariat to take the necessary measures to avoid this situation in the next round ofdraft texts.
We have identified several elements in this chapter that don't correspond with the colour
code explained in the note of page 3.6. This makes very difficult to identify wherechanges have taken place. ACTION: we kindly ask IPCC secretariat and authors to make Spainsure that changes with respect to 2006 GLs are appropriately identified in the next versionof the refinement.
In general, the guidance in chapter 2 is becoming highly complex and quite difficult todigest, let alone apply. Too much space is devoted to (very specific!) Tier-3 level
methods, including 4 pages in section 2.2 (pp. 2.48 to 2.52) , the entire section 2.5 (over12 pages) and some significant text sections elsewhere (e.g. lines 604-620, 1163-1180). Canada
Review the chapter in light of its intent to provide guidance on generic approaches
applicable to all land categories and reduce the amount of guidance on T3 methods.
Additional work is needed to avoid duplication with new guidance in vol 1, chapter 6.

general38

Comment

39

5774

4

2

147

147

7186

4

2

147

226

5776

4

2

151

192

7138

4

2

164

164

Section 2.3 is missing (both in the Contents and later).

CanadaWhy is “Inventory Framework” included under 2.11, rather than maintaining thenumbering in the 2006 Guidelines where “Inventory Framework is under 2.2? By doing
this the entire numbering scheme for Chapter 2 of the AFOLU volume in the 2019
United States of America
Refinement differs from Chapter 2 of the 2006 Guidelines. Changing the numbering
scheme will make comparing the 2019 Refinement to the 2006 Guidelines morechallenging for the inventory compiler.
Not relevant for this refinement. Guidelines are for National GHG emissions inventories. If
and how these can be applicable to projects or subnational schemes shall not be
Spainconsidered here. ACTION: delete information box.
Pages 2.7-2.8, Box 2.0A: Suggest removing box or placing in an annex. This guidance
document is for inventory compilers of national GHG inventories. Inserting several pagesof text at the beginning of the Generic Methodologies section only confuses andcomplicates the already challenging task of understanding how the guidance should be
used for national inventories. Anyone who is planning to do MRV on AFOLU projects orUnited States of America
other activities based on IPCC Guidance should have a very strong understanding of theguidelines and thus how they may be applied at the project level depending on the uniquecharacteristics of their project. Attempting to provide information on how this might bedone in a couple of pages is not very useful and clutters an already technically dense
section of the AFOLU guidance.
We think that EF stands for Emission Factors. Emission Factors are written out most
Norwayplaces in the report please consider to do that here as well

9308

4

2

180

185

It is unclear how useful it is to cite a particular government program not knowing how long
Canadathis program is going to last and its website link staying open.

6232

4

2

183

185

Box 2.0A – suggest amendment as concept of ‘fungibility’ is more of an accounting
construct. Suggest replacing 'fungible' with 'consistent'.

Australia

Response

Author's Note

Noted

Thank you for the comment. Every effort has been made to
be transparent in the Refinement.

Accepted

Existing IPCC 2006 text is highlighted in grey where as new
text is shown in white - this should make it easy to see
what's new in the 2019 Refinement.

Noted

It is not a requirement to gain an understanding of all
methods presented in this guidance. However, the new
information is useful for compilers considering thedevelopment of an inventory using a higher Tiermethodology. The guidance provides examples that would
illustrate these applications and some of the requirementsof using or moving to higher Tiers.

NotedThis is an error in the section numbering. Whole of Section
2.2 is actually Section 2.3. The sub-section 2.1.1 is actually
Section 2.2. The numbering will be corrected.

Rejected

Mapping tables are provided to facilitate understanding therefinements made and the relationship between thenumbering

Rejected

As already noted for FOD this issue is within the outline ofthis Refinement

Rejected

As already noted for FOD this issue is within the outline ofthis Refinement

Accepted
Noted
Accepted

Authors believe citing some concrete actual examples arehelpful to inventory compilers, in spite of the potential issue
pointed out in this comment.

Comment
VolumeID

Chapter

6010

2

4

From line

240

To lineComment

240

5778

4

2

257

538

9222

4

2

258

268

9222

4

2

258

2835

7188

4

2

329

338

7190

4

2

332

334

9224

4

2

363

363

7192

4

2

376

376

Country

Response

Author's Note"a. Identification of the lands affected by natural disturbances" - It may help to provide
guidance on how lands affected by natural disturbance can be identified (e.g.
United States of America
georeferenced, statistically). There have been some who interpret spatial tracking of lands
as the only acceptable approach.

NotedLine 240 does not contain any text.

These sections read more like a textbook than methodological guidance. The authors
should consider reducing the length of this discussion and providing references for theinventory compiler rather than the detailed descriptions currently provided.

Rejected

The section provides additional guidance for Tier 2 method,in relation to the potential use of allometric models in theestimation process of C stock changes; Definition anddescription of most commonly used allometric models areincluded in the section in order to supply the reader with
sufficient background information to implement the Tier 2
method.

Noted

Harmonized how references are included in all tables

United States of America

Please address the following inconsistencies: -Citations: e.g., Chave et al 2005 vs Paul etal. (2016) vs Lopez-Serrano et al. 2005 vs Jucker et al, 2017 vs Calders et al., 2015 vsCanadaChambers et al. (2001)/ -Use of “burned” vs “burnt” / -Use of “clear cut” vs “clear-cut”
Please address the following inconsistencies:-Citations: e.g., Chave et al 2005 vs Paul et al. (2016) vs Lopez-Serrano et al. 2005 vs
CanadaJucker et al, 2017 vs Calders et al., 2015 vs Chambers et al. (2001)-Use of “burned” vs “burnt”-Use of “clear cut” vs “clearcut”
Editorial. Delete "these conditions" in line 338, as reference to "conditions such as" isSpainalready included in line 331.
it is irreal to expect that the model will be valid for all trees, out of the sample populationand even within the sampled population. What matters is that uncertainty is maintained
Spain
within acceptable values. ACTION: delete last sentence of the bullet, from "individual" to"sampled population".
Define LiDAR the first time this abbreviation is used. It is spelled later (p. 484).
CanadaNot 100% of the times higher tiers mean higher accuracy of methods, parameters andSpainestimations. ACTION: add "usually" before "results in an increased accuracy"

Accepted

Accepted

The quoted text has been deleted.

Accepted with
Modification

The text has been modified, adding a new bullet point onmodel representativeness

Noted

Harmonize how references are included in all tables -TSU

Accepted

Text has been modified, by inserting "usually".

9310

4

2

388

2882

Errors or typos:- Line 388: “… methods can be find…” Should be “found”.
- Line 402: “The replacement of generalised m”. Define m.
- Line 2472: … “time series of annual emission and removals” should be “emissions” inplural.
- Line 2582: a “to” seems to be lacking
between 1990 and estimated.
- Line 2820: “challenging to separate emissions from dead organic matter that was
created” should be “were”.

7194

4

2

441

441

ACTION: redraft: "sensed data for ABOVEGROUND biomass estimation". This will
ensure the interpretation that the application of density maps is proposed foraboveground biomass only.

537

Re-order the entire section by starting with text relevant to the intented audience(inventory compilers): begin with lines 498-536, then lines 444-468. Inventory compilers
are very unlikely to develop biomass density maps, but they should understand their
Canadaadvantages and limitations. Lines 483 to 497 are textbook material: it should be sufficient
to provide reference to a standard text on remote sensing technologies for the interested
reader.

Accepted with
Modification

482

We are concerned that this biomass maps can be used for estimating other than AGB
pool. ACTION: redraft the paragraph: "because AG woody biomass is the ONLY variable
Spain
that can be predicted from remotely sense data, additional information such as country
specific data for rood-to-shoot rations IS NEEDED to estimate carbon stocks in otherpools."

Accepted with
Modification

9226

7196

4

4

2

2

442

480

These changes have been made.

CanadaAcceptedWill be addressed, at least, in the final copy-edit work.

Spain

Accepted

Editorial. Harmonized how references are included in all
tables
The subsection on remote sensing technology moved to
new box to address the comment and to not distract thereader.
Text is not reordered, since it is considered as importantthat the inventory compiler reads the considerations for themap development before considering how to used a map.
The word primarily is deleted. In addition, It is notnecessarily the case that BGB is estimated applying therood to shoot ration, but for example can be predicted byallometric models.

Comment
VolumeID

Chapter

From line

To lineComment

Country

Response

Author's Note

NorwayAccepted with
Modification

A sentence is added to the second paragraph on remotesensing technologies (now a Box), indicating that “a seriesof targeted space-based missions will improve thecapabilities for forest biomass predictions….” . Since these
new missions are not yet operational and there are othermissions than just GEDI, GEDI is not mentioned
specifically.

NorwayRejected

The document is guidance for estimation of GHG, albedo
issues are beyond the scope of these guidelines

7142

4

2

483

497

May be "Global Ecosystem Dynamics Investigation (GEDI)" is applicable in somecountries. "GEDI will use three NASA-developed lasers, each coupled with a Beam
Dithering Unit (BDU) to produce three sets of staggered footprints on the Earth's surface
to accurately measure global biomass". It will assess the significant contribution of
deforestation to CO2 concentration and effect on the global biodiversity

7144

4

2

483

497

Application of albedo for assessing radiative forcing and NIBIO has started to undertakesuch evaluations. Albedo changes are increasingly included in climate change impact
assessments of forestry and other land sector projects.

As an alternative carbon cycling, plant productivity and biomass can be assessed along a
Norwayrainfall gradient

7146

4

2

483

497

5780

4

2

537

537

9228

4

2

602

602

9230

4

2

604

620

7198

7200

4

4

2

2

621

635

In Box 2.0D, insert "The" before the word "Aim" in the 2nd sentence.
What is the meaning of the sentence "When the gain-loss method is chosen, inventory
measurements may provide estimates"?

Rejected

United States of America

Accepted

CanadaAccepted

This text is highly technical and relevant to the development of tier-3 models; re-locate
elsewhere as appropriate or delete.

CanadaRejected624

We assume that this equation is also applicable for land conversions, although thechapter 2.2.2.2 doesn't reflect any update, we would like to make sure that rightreferences to this formula are done. ACTION: ensure right reference to formula 2,19 insection 2.2.2.2.

Spain

Noted

636

We disagree that the area used has to be the one at the end of the inventory period. This
only work if the area has decreased. With increases in area this assumption doesn't work.
In addition to this, we think that the sentence could be more precise (it is confusing sayingthat the area of land remaining in the same land use category will be defined at the end of
the inventory period). ACTION: replace the sentence "it is good practice to use the area Spainat the end of the inventory period (t2) to define the area of land remaining in the land use
category" by something along the following lines: "it is good practice to use the smallerarea , between the area in t1 and the area in t2, to define the area to be used for
calculations in equation 2.19."

Rejected

7202

4

2

639

719

we miss indications on how to calculate DOM out.

Spain

Rejected

7204

4

2

689

690

We believe that this affirmation is true for all the factors/parameters in the AFOLU sector.
Therefore, we don't see the need to highlight it only for input of DOM. ACTION: move it to Spain
the introduction of the section (2.2. generic methods) or delete it.

Rejected

6926

4

2

723

724

The range of variation of default values is much higher than those of 2006 IPCC. It isnecessary to reduce range of variation for improving
uncertainty.

Republic of Korea

Rejected

7206

4

2

723

724

the table refers only to DOM in forests, therefore, we don't see the need to place it here.
ACTION: delete from here and move it to chapter 4, where it belongs (forest lands).

Spain

Rejected

The document is guidance for estimation of GHG,
ecological studies related to the behaviour of productivity
along environmental parameter gradients is out of thescope of the GLs.
Editorial
We have revised the text to clarify the meaning of thesentence.
This content relates to the application of the model
specified in this section not the development of Tier-3
models.
This model at the application was not part of the 2019
Refinement so no additional text was added to specify use
beyond Land Remaining in a Land Use Category. Thatsaid, it is generally agreed that this model may be used in
the Land Conversion to a New Land Use Category.

We thank the reviewer for the comment, but it refers to text
already agreed in the 2006 GL and changes here werebeyond the scope and the mandate of the 2019
Refinement.

We thank the reviewer for the comment, but it refers to text
already agreed in the 2006 GL and changes here werebeyond the scope and the mandate of the 2019
Refinement.
We thank the reviewer for the comment, but it refers to text
already agreed in the 2006 GL and changes here werebeyond the scope and the mandate of the 2019
Refinement.
Thank you for the comment. We included new data tocover a wider range of conditions and the min and max
estimates reported reflect the range of data included in the
updated table.
Thank you for the comment. The placement of the tablehas been agreed in the original 2006 GL and changing thisis beyond the mandate of this refinement.

Comment
Volume
ID

7208

9232

7210

4

4

4

Chapter222From line

757

773

778

To line757

Comment

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Country

Spain

773

Reference is only made to drained organic soils. Organic soils may also be excavated,
impacted through compaction, changes in vegetation cover resulting from various
different land use changes. Since this is general guidance, the guidelines should provide Canada
text that makes reference to how to resolve issues related to organic soil impacts that are
not related to “drainage” per se.

778

ACTION: replace "Greater" by "Different" at the end of the line. In our view, as long as soil
depth is consistent along the timeseries, it could be smaller than 30 cm. See text inSpainchapter 4, page 4.7, lines 177 to 179. "depth for evaluating C stock changes can bedifferent. "Response

Rejected

Author's Note
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

The text (Line 762-763) indicates that for organic soils CO2
emissions due to enhanced microbial decomposition
caused by drainage and associated management activity
needs to be addressed. This is handled by identifying
Accepted with Mod values for L within the chapters for each land use. Also,
only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope for updated in this refinement.
For Tier1 accounting all reference stocks and stock change
factors have been developed for a 0-30cm soil layer. If thedefault values are to be used then the account can only
operate to 30 cm.
For Tier2 which will use country specific values it isrecognised that a different depth could be used: either
shallower or deeper than the 30 cm. However, the country
Accepted with Mod
will have to justify the use of the depth selected and should
ensure that in selecting that depth no bias related to
management practice is introduced into the estimates. For
example, if soils are tilled and mixed to 25 cm, soil carbon
stocks should be defined to at least this depth. If a depth
shallower than 25 cm was adopted, then tilled soils may
falsely appear to have a lower soil carbon stock.

Comment
VolumeID

Chapter

From line

To lineComment

Country

9234

4

2

790

790

IPCC guidance is not "conservative" - it should be "unbiased", that is, neither deliberately
under-estimating nor over-estimating emissions and removals. Correct sentence andCanadaapproach accordingly.

9344

4

2

824

825

Reprojection does not cause error' if done correctly. Different projections will result indifferent distortion and everyone should pick a projection that is appropriate to reduce
distortion.

Canada

Spain

7212

4

2

837

837

After millions of years of human interaction with the environment, the expression "native
vegetation" here doesn't reflect the reality of the factor. ACTION: delete reference to"under native vegetation" and replace it by something along the lines of "under the initialconditions of the land use".

7214

4

2

840

841

more explanation is going to be needed to understand this note. What is Find? When is it
substituted by Flu? ACTION: clarify the sentence or delete it. In addition, it would beSpainbetter placed in the forest land chapter if it is only referred to forests.

5782

4

2

859

860

6522

4

2

862

863

6524

4

2

884

884

Response

Author's Note

The word conservative was perhaps not the best choice to
use in describing the methodology developed aroundbiochar permanence in soil. Our goal was to provide amethod that is valid for a Tier 1 methodology. Based on
the biochar literature, there is high confidence in estimating
the long-term 'permanent' component of biochar
amendments that is sequestered in soils. The literature isnot sufficient for estimating the shorter term dynamics ofthe less stable C in biochar. Moreover, estimating the
dynamics of the less stable organic matter fractions inbiochar requires more information than is feasible for a Tier
1 method. Therefore to be consistent with the current
understanding, the authors defined Fperm as the fraction of
Accepted with mod biochar remaining after 1000 years given that the literature
is sufficient for estimating this component, and the moretransient components can be estimated with higher tiermethods. This is consistent with other Tier 1 methods that
do not always address the full impact of management,
requiring higher tier methods to incorporate othercomponents if the country has sufficient data andresources. The text has been altered to reflect therationale for the method.

Text has been modified "reprojection of spatial data should
not cause errors if applied correctly using appropriate typeof projection for a given location".
The term "under native vegetation" applies to thereference stocks of soil carbon. A definition appears at
Accepted with Mod line 1066 that defines what the reference condition is. Thisdefinition needs to be moved forward to follow the first
appearance of the term "reference stocks".
No change is required as the terms are defined. However
the reference to the location where Fnd is discussed should
Accepted with Mod be added to the end of the note: (see Chapter 4, Section
4.2.3 for more discussion). Also note the absence of aclosed parenthesis.
Accepted

Page 2.27, Table 2.3: An overarching comment on this table and other data tables in thischapter is that there should be greater consistency in how the default values arepresented. For example, when comparing the tables 2.2, 2.3 and 2.3A, each has a
It has been accepted that all tables provide uncertainty as adifferent approach for presenting the default values and uncertainty, greater consistency
United States of America Accepted with Mod +/- value for 95% confidence intervals. Tables have been
in table format for default values would be useful throughout the AFOLU volume. Specificmodified to present the uncertainty in this format.
to Updated Table 2.3, the uncertainty ranges do not seem realistic. For most of thevalues the uncertainty ranges are so large that the 95% CI would result in soils withnegative carbon values, which is not possible.
Figure 2.4. Typo?: "Are there changes in C stocks in mineral soils a Key category?"
United Kingdom (of Great
Agreed.
Acceptedshould read "Are the changes..."Britain and Northern
United Kingdom (of GreatTypo, should read: "assuming D is 20 years..."Accepted
This change has been made.
Britain and NorthernComment
Volume
ID

6526

4906

4900

4902

7216

4

4

4

4

4

Chapter

2

2

2

2

2

From line

888

913

916

929

935

To lineComment

888

United Kingdom (of Great
Missing equation number: "Two alternative formulations are possible for Equation 2.25..." Britain and Northern
Rejected
Ireland)

913

916

929

935

Country

We suggest to add the two following references in the parenthesis. They are excellent
meta-analysis of empirical studies on SOC changes following land-use change and assuch can be used to define region-specific FLU values:
Poeplau, C., Don, A., 2013. Sensitivity of soil organic carbon stocks and fractions todifferent land-use changes across Europe. Geoderma 192, 189 – 201.
Francedoi:10.1016/j.geoderma.2012.08.003
Poeplau, C., Don, A., Vesterdal, L., Leifeld, J., van Wesemael, B., Schumacher, J.,
Gensior, A., 2011. Temporal dynamics of soil organic carbon after land-use change in thetemperate zone – carbon response functions as a model approach. Global Change
Biology 17, 2415–2427. doi:10.1111/j.1365-2486.2011.02408.x"Regardless of the data source, it is good practice that the plots being compared have
similar histories andmanagement as well as similar topographic position, soil physical properties and belocated in close proximity." From experience this crucial sentence is often overlooked
Franceand/or not understood. Adding a sentence specifying that "In particular, the use ofnational averages per land use is usually not appropriate because different land uses
seldom have a similar average topographic position and soil physical properties. Forests,
for example, tend to be located on steeper and poorer soils than cropland on average at anational level.""It is good practice to provide the results of model evaluation, citing published papers in
the literature and/or placing the results in the inventory report."
A welcome improvement would be to recommend that a Tier 1 or simpler Tier 2
calculation be applied in parallel, and that the possible difference with the Tier 3 results beinterpreted. This is not to question the overarching principle that Tier 3 should be
preferred to Tier 1, but it would greatly improve the transparency of the advanced Tier 2 France
or Tier 3 method and its comparability with other countries. We therefore recommend
adding after the above sentence:"It is also good practice to compare the implementation of the model with a Tier 1 orsimpler Tier 2 estimate and to explain what drives the possible differences between thehigher and lower Tier estimates."

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Spain

Response

Rejected

Noted

Noted

Rejected

Author's Note
The equation number is correct, and has been retained
from the 2006 Guidelines as directed by the report's
steering committee (i.e., equations retained from the 2006
guidelines must also retain the same number).

The text describes the example calculations. There is noneed to add additional references.

Searching the Refinement to find this text showed that thiscomment was from line 1088. This was located within asection not identified for revision.

This is a broader issue for the guidance, which is not
specific to soil C, and would need to be addressed inVolume I, General Guidance, and the General Tier 3
guidance in Volume IV, Chapter 2.

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Thank you
7118

4

2

936

1006

We fully support the inclusion of biochar in the 2019 refinement

NorwayNoted

Comment
Volume
ID

7122

9236

5784

7120

6234

4

4

4

4

4

Chapter

2

2

2

2

2

From line

936

943

943

943

951

To lineComment

Country1006

The calculation in tier 1 using a simple equation with two factors (FCp and FPERMp) e.g.
in table 2.3B is reasonable. However, the scientific basis for the 600-degree threshold forincreased biochar stability is not very strong, and in our opinion the large difference
Norwaybetween 0.24 and 0.38 in FPERMp is not justified. We suggest that the difference be
reduced so that only the differences in biochar carbon content not captured by FCp isaccounted for. The current configuration may influence market production of higher
temperature biochars at a time when pyrolysis technologies are still being developed

943

IPCC guidance is not "conservative" - it should be "unbiased", that is, neither deliberately
under-estimating nor over-estimating emissions and removals. Correct sentence andCanadaapproach accordingly.

947

The point about using Fpermp being used as a conservative estimate of carbon
accumulation in soils is stated twice. There may be a good technical reason for stating it
twice, but the authors should check.

950

966

Author's Note

The values produced were data driven based on a range ofstudies. The derivation process and references areincluded in annex 2A.2. We must respect the calculations
derived from the data used and cannot alter values based
Accepted with Mod
on opinion.

The word conservative was perhaps not the best to use indescribing the methodology developed around biochar
permanence in soil. It is important that the biochar
considered to be stable in soil is only the fraction that iscounted as being sequestered. The reasoning for defining
Fperm as the fraction of biochar remaining after 1000 years
Accepted with mod was to be confident that the values derived from equation
2.26A provided a valid estimate of the sequestration ofbiochar C. The text should be altered to express this.

Agreed.
United States of America

We do not understand why a 1000-year time frame was chosen over the more reasonable
and traditional 100-year time frame for forestry and soil C measures used by IPCC. It ishighlighted that a 1000 years timeframe gives a conservative estimate over the normal
100 year timeframe. At the same time it is said in vol 4, Ch. 8, line 3933 that the estimateis "conservatively estimated by fitting a two-pool double-exponential. This seems to give a Norway
rather conservative approach compared to other estimates in the 2019 refinement of the2006 Guidelines.
model to only those datasets that exceeded one year and allowed a two-pool model to be
fitted following the rationale outlined"

Box 2.2A - GHG emissions sources with biochar production can be excluded by thereporting country if feedstocks or amendments are imported.

Response

Australia

Accepted

Noted

Noted

Given uncertainties in biochar composition and variationsin production conditions, along with the uncertainties in theinitial decades, a 1000 year time frame is consideredscientifically justified to ensure that there is no bias
introduced into in the estimation. That is, the amount of C
permanently sequestered is not over-estimated because
these calculations are not tracking decomposition of morelabile components of the biochar, which could addressedwith a higher tier method.

The decisions about reporting emissions will be made in
UNFCCC negotiations. This guidance is only providing themethodologies.

Comment
Volume
ID

9238

9240

4704

4

4

4

Chapter222From line

993

1000

1005

To line

997

1000

1006

Comment

Country

IPCC guidance is not "conservative" - it should be "unbiased", that is, neither deliberately
under-estimating nor over-estimating emissions and removals. Correct sentence andCanadaapproach accordingly.

The number of significant digits on the error values (last column of table 2.3A) ismisleading: how certain are authors that "errors" are 39% and not 40%? Is this statisticalerror or uncertainty?

For the figures of Fpermp, we would like to ask some clarifications;- the time and temperature for pyrolysis and gasification used in the literature- the treatment of moisture content in the literature- the reasons of setting "1000 years"

CanadaJapan

Response

Author's Note

The word conservative was perhaps not the best choice to
use in describing the methodology developed aroundbiochar permanence in soil. Our goal was to provide amethod that is valid for a Tier 1 methodology. Based on
the biochar literature, there is high confidence in estimating
the long-term 'permanent' component of biochar
amendments that is sequestered in soils. The literature isnot sufficient for estimating the shorter term dynamics ofthe less stable C in biochar. Moreover, estimating the
dynamics of the less stable organic matter fractions inbiochar requires more information than is feasible for a Tier
1 method. Therefore to be consistent with the current
understanding, the authors defined Fperm as the fraction of
Accepted with mod biochar remaining after 1000 years given that the literature
is sufficient for estimating this component, and the moretransient components can be estimated with higher tiermethods. This is consistent with other Tier 1 methods that
do not always address the full impact of management,
requiring higher tier methods to incorporate othercomponents if the country has sufficient data andresources. The text has been altered to reflect therationale for the method.

Noted

This is a calculated statistical error based on the data
extracted from the referenced papers. Changing these
uncertainties would create an inconsistency between the
published data and the resulting factors in this report, which
the authors consider inappropriate.

The details of the time and temperature of pyrolysis andgasification, as well as the treatment of water content canbe found within the references provided in Annex 2A.2. All
studies from which data were derived are provided in thisannex.
The reason for defining Fperm as the fraction of biochar
remaining after 1000 years was to be confident that thevalues derived from equation 2.26A provided an accurate
Accepted with Mod
estimate of the sequestration of biochar C. The amount ofbiochar C sequested in the short term is considerably more
uncertain, and could lead to biases in the estimates.
However, compilers can use higher tier methods to address
the shorter term dynamics.

Comment
Volume
ID

5170

4706

4

4

Chapter22

From line

1016

1049

To lineComment

1020

Tier 2 should not prevent the use of country specific SOC data derived from national soil
inventories performed under different purposes, that may characterize the SOC undermanagement/climate/soil conditions at equilibrium. SOCref and the 3 factors are
extremely difficult to characterize at country level, however it may be possible to find SOC
databases (e.g. LUCAS ) or relevant studies (e.g. Chiti et al 2017) that allow to define the
SOC at the equilibrium direct. It is therefore strongly recommended to include a further
Italy
option in approach 1 of tier 2 that allows the use of country data for deriving the change in
SOC and can represent the final result of the combination of the SOCrefx3 Factors. As
reported in the IPCC 2011, facility level data should be always encouraged. On the otherside the use of facility level data at tier 2 should be allowed when the data are notsufficient enough represent annual variations of land-use and management impacts on
soil C stocks, but rather as a linear shift from one equilibrium state to another.

1054

7218

4

2

1056

1056

9242

4

2

1163

1180

7220

1810

4

4

2

2

1181

1181

1539

1560

For comparability, soil categories and climate regions should be follow IPCC default
classification. We suggest to delete country specific soil categories and climate regions(i.e. Instead if using the IPCC default classification)

ACTION: delete reference to "under native vegetation". See comment for line 837

Country

Noted

Author's Note

Tier 2 does not prevent the use of country specific values indeed country specific values are required to move to Tier
2. If a country has its own reference stocks and stockchange factors derived from country data, then thecompiler could move to Tier 2. The ability of a country toadopt a different reference condition and use different
depths is described in the text.

While there would be advantages from a consistency pointof view if countries were requested to do so, it is not arequirement at a Tier 2 level in which compilers develop
factors that better meet national circumstances. For
example a countries own soil classification system may
differ from the soil types used in IPCC or the country may
decide to define more climatic regions than currently in the
IPCC classification with the goal of deriving more accurate
emission factors given national circumstances. What is
critical is that the soil carbon stock data to support bothreference condition and land use change factors exists andthat the compiler describes the process to derive the Tier 2inventory.

Japan

Noted

Spain

The term "under native condition" needs to be replacedwith "reference condition" and a definition for "reference
Accepted with Mod condition" should be provided.

Bottom part of box is highly technical and relevant to the use of tier-3 models; re-locate
Canadaelsewhere as appropriate or delete.
First, this section talks about three different pools under the COS pool. We think this isconfusing. We should only refer as pools to those defined in "1.2.2 Carbon pooldefinitions and non-CO2 gases". Otherwise the text will be very confusing.
Second, for us, this is a Tier 3 approach, and shouldn't be reflected as tier 2 in theSpain
Refinement.
ACTION: delete the section referring to this model. We could accept its description in Tier
3 section or in an annex, but not as part of the tier 2 guidance. In any case, references topools should be changed by sub-pools.

Considering the complexity of “Three-Pool Steady-State C Model”, and the availability ofno calculation parameter, it is not applicable as Tier 2. Instead, it is suggested to classify
it as Tier 3.

Response

China

Accepted

OK

Agreed. The term pool in its use here needs to be replacedwith sub-pool. Information justifying the classification of thesteady state modelling approach at the Tier 2 level has
Accepted with Mod
been added.

Information justifying the classification of the steady statemodelling approach at the Tier 2 level has been added.
Values are provided for all model parameters in Table 2.3C.
Accepted with Mod Note that the method has been moved to Cropland
Remaining Croplands based on other comments.

Comment
Volume
ID

9244

5786

5788

5790

1812

7222

4

4

4

4

4

4

Chapter

2

2

2

2

2

2

From line

1196

1201

1221

1241

1279

1541

To lineComment

Country1202

It is not enough to simply say that different activity data is required. It would be helpful if
there was a Table that describes the required activity data for the two methods, such that
Canadacompilers could easily identify which method is more appropriate for their national
circumstances.

1202

It was stated earlier that the Tier 2-Approach 2 method can only be used for cropland andgrassland. If that’s the case the it seems that “forest land” should be removed from thisUnited States of America
sentence.

1221

Insert after “Model” the following “(Tier 2-Approach 2)”. It may even be preferable to justuse the term Tier 2-Approach 2 instead of the Three-Pool Steady-State C Model as it isUnited States of America
more consistent with how the guidance is presented across AFOLU. Depending on theauthors decision on whether to implement this suggestion, it may also be good to makethis change in the individual equation boxes for equation 2.26B, 2.26C, 2.26D, and 2.26E.

1241

1439

1541

Box 2.2C: Insert “-Approach 2” after “Tier 2”

In lines 1279-1300, 1315-1343, 1346-1371, and 1414-1439, the dimensions of variablesin the formulas are wrong.

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

United States of America

China

Spain

Response

Author's Note

Examples of the activity data required for two Tier 2
methods are provided in the text, and additional information
Accepted with mod has been added to better clarify the data requirements.

Accepted

Agreed, and moreover the authors discussed this issue
further and concluded that the method as currently
presented is only appropriate for croplands because thestudies underlying the Bayesian parameterisation are only
from cropland sites. Consequently, the method has been
moved to the cropland chapter since it is no longer
considered a general method for application across multiple
land uses.

The term "Approach" has been replaced with "Method" andeach method has been given a name which has been usedthroughout the text. Note that the method has been moved
Accepted with Mod to Cropland Remaining Croplands based on othercomments.

Accepted with Mod

Accepted

Rejected

All boxes have been renamed with a new naming
convention.

Units of the first line of the equation were not correct - the kvalue left a unit of y-1 in the right side of the equation,
which must be balanced in order to produce units of t C/hain the result. We added a new term D which defines theduration of the time step and is set to 1 year for the Tier 2
Steady state method. This additional term in the model
cancels the y-1 units associated with the value of k.

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Comment
Volume
ID

9246

7224

4

4

Chapter22

From line

1633

1646

To line1636

Comment

Country

It would be useful in these boxes to provide a brief description of how each country
documents their application of the models in a transparent way, applying the principals
that are outlined in Volume 1 Chapter 9, section 6.11 for the application of Tier 3 models. CanadaThis does not need to be elaborate, but simply describes how each country reports andwhat the key elements are in transparent reporting and use of Tier 3 models.

1646

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

This paragraph notes spatial and temporal variability, but does not address this in thediscussion of representative sample design. The guidance recommends that sampling be
representative of the range of environmental and management conditions (i.e. sufficient
strata) – however it should also state that sampling should be representative of the scale Australiaof spatial and temporal variability in stocks, in order to accurately represent the trend not
local or short-term variability. For example it is difficult to accurately represent the longterm trend in soil organic carbon through sampling, due to spatial and temporal variability.

6236

4

2

1875

1880

6528

4

2

2011

2384

9248

4

2

2017

2384

9250

4

2

2023

2024

Spain

Response

Noted

Rejected

Accepted

why is peer-review explicitly mentioned in section 2.5.1 while only the description ofUnited Kingdom (of GreatQA/QC procedures is referred to in section 2.5.2. The text could be clearer to avoid the
Britain and Northern
Accepted
impression that some types of models need less peer-review than others.
Ireland)Tier 3 models are by nature unique and complex; in most cases a full description is rarely
available. Rather, their credibility and reliability are based on the number of scientific,
peer-reviewed publications demonstrating that the model indeed produced representative,
credible and valid outputs. Taking this into consideration, the entire section 2.5 needs tobe streamlined and made more generic. For example, group all guidance related to
documentation (e.g. lines 2060 to 2069, lines 2132 to 2141) in step 9 at the end of thesection. Documentation requirements seem very specific to some types of model (e.g.
see lines 2060-2069 and lines 2234-2243) - and sometimes reporting requirements quite
CanadaAccepted
unrealistic (e.g. lines 2237-2238, 2277-2284). Simplify documentation and reporting
requirements and identify the type of information that is best published in the scientific
literature. Some requirements are unclear or redundant: for example in step 2 lines 2094
and 2095 ask if accuracy and uncertainty of a candidate model can be assessed, andwhether the model accuracy is sufficient for the inventory: accuracy assessment overlaps
with model evaluation (step 4). In addition, a more relevant question would be whether
one can demonstrate a reduction in uncertainty with the T3 model. Overall, this sectionneeds a thorough review and streamlining.
This statement could be revised as it assumes that models automatically increase
accuracy. They can only make that claim when they have been validated against an
independent data set and the results compared to a lower Tier method that has beencorrectly and rigorously applied: “In all cases models used in Tier 3 methods ensure
CanadaAcceptedhigher accuracy only when they have been effectively validated against an independent
data set, are correctly applied and capable of representing the population of interest.” Asis, the statement confuses precision of output with accuracy. Models can provide very
detailed precise output that is completely inaccurate.

Author's Note
The application of the Tier 3 approach in each country is
supported by papers published in international scientificjournals which are identified within the box. This provides
justification of the approaches used. Guidance is provided
for documenting Tier 3 methods in Chapter 6 of Volume 1
and Chapter 2 of Volume 4 of the 2019 Refinement.

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Text edited to address concern

The QA/QC text was edited to be the same in both sections
to remove any impression that some models need lesspeer review than others..

The authors would like to thank the reviewers for this usefulcomment. A thorough review of Chapter 2.5 wasundertaken and we believe that all the points made here
have been addressed.

Suggested text edit added.

Comment
VolumeID

Chapter

9252

4

2

2053

2054

9254

4

2

2053

2054

9256

4

2

From line

2055

To line

2075

6530

4

2

2133

2135

6532

4

2

2211

2228

9258

4

2

2237

2238

9260

4

2

2358

2363

9262

4

2

2364

2367

7226

4

2

2385

2683

7672

4

2

2385

2882

7674

4

2

2385

2882

Comment
These references are missing in the list of references: Kurz & Apps, 2006, Kurz et al.,2009, Kurz et al., 2013. In addition, a ref to our NIR2018 (in relation to our landreconciliation framework) should be added. Suggest to add "Environment and Climate
Change Canada 2018". Please see reference details in the next column.
Is it correct to say that Canada integrates multiple models? Canada may reconcile theresults of different models but the models are not integrated.

Country

Response

Author's Note

CanadaAcceptedThank you for the additional references. All have been
added as requested.

CanadaAccepted

Text edited as suggested

Accepted

Checks for consistency between Vol 1, chap 6 and this text
have been made. A reference to the Figure that now
resides there has been included. The steps listed areconsistent with this figure. Text relating to validation ofmodels against independent data sets has beenstrengthened.

There are inconsistencies between Volume 1 Chapter 6 and this section, in particular theemphasis on the validation of models against independent data sets is not stressed.
CanadaThere is a schematic in that Section, why doesn’t this Section refer to that part of the
Guidelines? Greater consistency in language and conceptual presentation is required.
could be worthwhile clarifying that for inventory purposes, the emphasis is more on
reducing the bias when there is a bias-variance trade-off, or that it is "compensating
errors" in specific pools/ecozones that are mentioned (as bias are defined in the new box
2.2f but not bias that translate at the aggregated level?
No doubt that it is good practice to keep large samples for "external validation". But
considering that available data can be very scarce, it would be good to include morearguments/justify to keep half of the available data for external validation. Can't data inother geographic context be used to contribute to the external validation and thus makebetter use of the often scarce available information?
The meaning of the following sentence is unclear: "the limits need to be provided in theinventory report)". What is the meaning of these "limits" and where are they provided in
the NIR?

How was the question of spatial independence of estimates addressed when combining
the results from the 20 different regions when there were no doubt parameters in themodel that were not regionally specific and therefore applied to all or multiple regions?
Should this be addressed in this example?

United Kingdom (of GreatBritain and Northern
Accepted
Ireland)

The text of this section has been completely revised in
response to this and a number of other comments andauthor reviews.

United Kingdom (of GreatBritain and Northern
Accepted
Ireland)

Added text on the use of techniques such as bootstrapping
when datasets are limited.

CanadaAccepted

The text in the brackets at the end of the bullet wasremoved.

Noted

This question is not entirely clear. Table 1 in Kurz et al.
2009 describes the spatial scales at which parametervalues were applied. If a parameter value was applied athe national scale, in each of the 20 projects, it was varied
using the probability distribution that was applied for the
100 MC simulations for this parameter. This is explained in
Metsaranta et al. 2017, but is a level of detail that need not
be carried forward to this short box.

Accepted

Deleted the carbon stock discussion in the text.

Rejected

The section is not only about "guidance for thedisaggregation of emissions from disturbances"

Accepted

Reference Updated

Rejected

Due to limit time and information available such guidance
could not be included in the section

CanadaHow does the quantification of uncertainties in carbon stocks relate to inventory
Canadaestimates?
This section is not mandated in the table of content as adopted by the IPCC.
Nevertheless, we think it contains valuable information, but we would like to see a numberSpainof changes here. The first one, changing the name of the section, as it mainly refers to
disaggregation of emissions from natural disturbances. ACTION: change the name of thesection to "6.2. Guidance for the disaggregation of emissions from disturbances".
Several references in Chapter 2.6 to manuscripts under a review cannot be assessed inthis review of SOD which is a shortcoming taking into account that this is the last review Finlandround of the 2019 Refinement.
Please provide some guidance for taking into account the carbon storage in soil as well as
Finlandin DOM pools in case of natural disturbances.

Comment
Volume
ID

5794

5792

4

4

Chapter22

From line

2385

2385

To lineComment

Country

Response

Author's Note

Noted

Forest management including fire suppression, choice oftree species (where tree species are not regenerating
naturally), salvage logging of dead trees that could becomesources of bark beetles, and other management activities
can have impacts on short term and long-term disturbancerisks. This is one of the issues that makes it so difficult tocompletely separate anthropogenic from natural
disturbance impacts. And that is why this text refers to theapproach as a second order approximation. It represents
an improvement over the MLP without disaggregation, but
it does not represent a complete disaggregation of naturalfrom anthropogenic impacts.

2883

General comment: While natural disturbance events are those "beyond the material
control of a Party," it must be recognized that land use policies, forest management
regimes, etc have an effect on emissions from natural disturbance events. How is thisaddressed?

2883

General Comment on section 2.6 IAV: While innovative and potentially helpful to a subset
of countries using the 2019 Refinement, based on the following considerations andobservations we believe that the material presented in this section on IAV is better suited
for an appendix rather than in the main body of Volume 4, Chapter 2, reasons include:
From a review of the approved Table of Contents for the 2019 Refinement, there appears
to be no mention of including new guidance on Inter-Annual Variability in Volume 4,
Chapter 2. Additionally, the guidance could confuse inventory compilers that will beapplying the IPCC Guidelines. The IPCC Guidelines should be very clear on what are theUnited States of America
Tier 1, 2 and 3 methods, this IAV approach is not associated with the IPCC Tiers, it is aseparate sub-analysis that allows countries to more clearly identify, separate and report
fluxes from natural disturbance and is not consistent with the application of the Managed
Land Proxy. Inclusion in an appendix is more consistent with recognition that thisguidance is optional for countries. A "text box" in Chapter 2 could be provided briefly
mentioning this IAV approach and then refer the reader to an appendix where theguidance would be provided. This would help minimize confusion among inventory
compilers using the 2019 Refinement and be just as useful for those countries that choseto perform this supplementary analysis.

Rejected

The purpose of the GHG reporting is to estimate
anthropogenic emissions and removals. The described
approach is a refinement of the MLP that countries canelect to implement.

Unclear whether drought is a natural disturbance or a climate extreme. Does it matter inthe context of this section? Please clarify.

Accepted with
Modification

We have removed explicit references to drought being a
ND (a country can still chose to define it as such).
References to drought now are limited to those where it isdescribed as a precursor to fires.

9264

4

2

2385

2882

5796

4

2

2386

2391

6534

4

2

2386

2883

5798
5800

4
4

2
2

2390
2392

2390
2392

7228

4

2

2395

2399

7230

4

2

2400

2401

5802

4

2

2402

2402

9266

4

2

2403

2407

United States of America

CanadaGood to see reference to the managed land proxy as only universally applicable approach
United States of America
to estimating anthropogenic emissions and removals in the AFOLU sector.
Would it not be closer to what the atmosphere sees to continue to present the emissions
and removals for Managed Land ? The proposed approach to addressing interannual
United Kingdom (of GreatBritain and Northernvariability seems more relevant for accounting than reporting and therefore notappropriate here. The result of this proposed approach could be retained in the reporting Ireland)
as a memo item that could be later used for accounting purposes.
Change "reported" to "estimated".
United States of America
Add "Some" to the beginning of the sentence, before "Emissions and removals".
United States of America
no problems with content, but we would like to avoid references to KP supplement.
ACTION: delete "as described in the IPCC KP supplement 2013, " and start the sentence Spain
with "The two largest causes of..."We don't see the need to explain here the purpose of the refinement. ACTION: delete
Spainfrom the beginning ("this refinement") up to "emissions and removals" in line 2401.
Add "quantitative" between "clear" and "understanding". It seems that a qualitative
comparison or cross-walk between known disturbance events and MLP-only inventory
United States of America
results can help to understand those results, but won't provide a quantitative
understanding.
Two consecutive sentences have the same meaning: merge them.
CanadaNoted

Rejected

The purpose of the GHG reporting is to estimate
anthropogenic emissions and removals. The described
approach is a refinement of the MLP that countries canelect to implement.

Accepted
Accepted
Accepted

Edited text and added more references.

Accepted

Text deleted

Accepted

Text modified

Accepted

Deleted second sentenceComment
VolumeID

Chapter

5804

2

5806

5808

4

4

4

2

2

From line

2404

2423

2428

To lineThis approach does represent a refinement of theestimates of the anthropogenic E/R and by using
refinement the text reaffirms that this is consistent with the
MLP. The text also makes it clear that this is neither a goodpractice requirement nor that it is mandatory by stating thatcountries can choose to disaggregate.

2424

Change "wish to increase the transparency of anthropogenic GHG flux estimates on
managed lands" to "wish to carry out this disaggregation of results". All countries using
the IPCC GL want to maximize transparency, which is a core aspect of good practice. A
country that does not wish to disaggregate natural disturbances can still be fullytransparent in its inventory if it clearly documents its results according to IPCC goodpractice.

Accepted

2458

This section introduces useful information on how to think about interannual variability,
and why a country might want to use the methods that follow to make a quantitative
estimate of natural disturbances. It should however take a bit more care not to undermine
or contradict the MLP guidance in Volume 4 chapter 1 but suggesting implicitly via the
choice of words that a country that uses the methods below is being more transparent or
has made a higher "tier" or more refined estimate than a country that doesn't use themethods below. It is certainly important and useful to provide the guidance for countries United States of America
that wish to do it, but take care not to go beyond the mandate for the 2019 refinement.
Also, missing in this section is a recognition that the importance of IAV to a country may
be a factor of the magnitude of AFOLU as a sector as part of combined economy-wide
national totals of GHG emissions and removals. Countries for which AFOLU plays anmajor role in overall trends may have more interest in using the methods described below
than a country in which AFOLU plays a minor role.

2434

2434

9268

4

2

2435

2436

4710

4

2

2436

2438

2437

Author's Note

Rejected2

2

Response

Change "refined estimates of" to "additional information on". Use of "refined" indicatesthat these estimates would necessarily be the preferred good practice results, rather than United States of America
part of a broader presentation of results.

4

4Country

2404

4708

7612

Comment

2440

United States of America

Check the status of this article (Grassi et al. submitted).If a cut-off date is over, delete thesentence below. ”Describing how the various effects are reflected (…) policyJapancommunities.”
First, the colouring of this Figure is confusing. Secondly, in the indirect-human induced
effects portion there is discussion of the natural disturbance regimes, but in the Natural
Effects, it is simply inter-annual variability. In reality, the interannual variability is due tothe expression of natural cycles (or regimes if you like) that are not expressed on an
Canadaannual basis, these include fire regimes, but also insect cycles, disease cycles andweather cycles (not climate change). Many of these cycles may not be represented
effectively in inventory modelling or even stock change estimates. This Figure doesn’treally provide an effective “conceptual illustration of the complexity of this question andcould be removed from the text.
Check the status of this article (Grassi et al. submitted).If a cut-off date is over, deleteJapanfrom line 2436 to 2438 including the Figure 2.7A.

There is growing amount and quality of "attribution studies", i.e. how much of the risk foran extreme event (or type of events)
should go to anthropogenic climate change and how much should go to random climate
Finlandvariability. Figure 2.7A holds but authors might consider revising text to include
explanation that it is sometimes possibility estimate role of climate change in extreme
events affecting GHG emissions.

Accepted with
Modification

Thank you for the feedback that the information is useful.
The comment is broadly applicable to the section and anumber of changes have been made throughout thechapter to address these recommendations. For example,
the introduction to the section now states: These
approaches may be of interest to countries with AFOLU
sector emissions that have high IAV or trends due tonatural effects. Note also that all remaining references to"transparency" are in the context of documenting themethods used, not that the methods make the results moretransparent. The Canada example box, is the only
exception, because that country chose the disaggregation
approach with the express intent to increase transparency
of reporting of the anthropogenic emissions and removals.

Accepted

Reference Updated

Accepted with
Modification

Modified the figure to reduce the confusion. Remainder ofthe comment is unclear.

Accepted

Reference Updated

Accepted with
Modification

The three examples provided in the text all demonstratethat at the landscape level attribution is feasible and thatchange in climate will change the partitioning of the E/R
that are anthropogenic. However, a brief review of theliterature shows that attribution analyses are still
controversial, and certainly very complex and beyond thescope of a national GHG inventory. E.g. see
http://www.pnas.org/content/115/33/8232.short as an
example of the complexities involved. And as the reviewers
stated - it is only sometimes possible.

Comment
VolumeID

Chapter

7666

4

2

2437

2440

9270

4

2

2447

2448

9272

4

2

2450

2452

7668

4

2

2456

2458

5810

4

2

2457

2458

From line

To line

5174

4

2

2459

2479

9274

4

2

2460

2461

5812

4

2

2461

2461

6238

4

2

2462

2464

9276

4

2

2467

2470

Comment

Country

The theoretical framework behind the Figure 2.7A and Chapter 2.6 is a simplification. For
instance, extended periods of drought can be in some cases considered to be a result ofa changing climate, i.e. "natural disturbance" at least partly attributable indirectly to humanFinlandactivity. However, this type of disturbances and the subsequent secondary disturbancessuch as insect damage cannot be prevented in most cases, thus the term " natural
damage" fits.
This sentence is unclear. By stating “are of relevance to annual GHG inventories” do you
Canadamean “can have an important impact on annual GHG inventories”? Please clarify.
Wording is unclear - could be read as implying that both emissions and removals occur atthe same time. Also, this description lacks a reference to the fact that these impacts canaffect emissions and removals over long time horizons - so not just about addressing
short-term IAV. Therefore, suggest rewording to state: "Land sector GHG emissions andCanadaremovals are affected by both human and natural factors, and to varying degrees. The
impacts of human and natural factors can also have an impact on emissions andremovals over long time horizons (e.g. complete regrowth of post-disturbance forest cover
can take up to -and sometimes over - 100 years).
Please rephrase the sentences because calculated this way, the refined estimate ofemissions and removals from anthropogenic causes will still include the effect ofFinlandinterannual variability of weather patterns because only natural disturbances or a verysmall proportion of the impact of natural disturbances (see Box 2.2L for instance) aretaken into account.
Delete the last sentence starting with "This second order approximation…", as it implies
that only countries that use the methods below are producing good practice results,
United States of America
whereas others are not. The value of the exercise has already been demonstrated earlier
in this section.
No definition of natural disturbance is provided in section 2.6.1.2. It is strongly
recommended to include a definition that clearly delineate what is considered as "natural
Italy
disturbance", e.g. (IPCC 2013) non-anthropogenic events or non-anthropogenic
circumstances that cause significant emissions in forests and are beyond the control of,and not materially influenced by a Party.
“The frequency and intensity of fire events is strongly controlled by climate” should be
rephrased to include the four most important variable families: “The frequency andCanadaintensity of fire events is strongly controlled by weather/climate, fuels, ignition sources,and human activities”. This will facilitate the understanding of the following text.
Fire intensity is also strongly influenced by weather.
United States of America
The proposition may oversimplify the cited reference and could be misleading: Frequent
fires can affect ecosystem structure and carbon stocks across time: for instance,
savannas are frequently affected by fire events that reduce average tree basal area
across time (Lehmann et al. 2014). This sentence implies that a policy of fire exclusionfrom fire-adapted savanna ecosystems would lead to increased woody biomass.
However, the key findings of the paper are that fire has a much smaller influence on basal
area than other environmental variables, and that a single conceptual model for savannas
Australia
cannot be applied across continents (see Figure 3). (See e.g. Murphy Brett P., Liedloff
Adam C., Cook Garry D. (2014) Does fire limit tree biomass in Australian savannas?.
International Journal of Wildland Fire 24, 1-13.). Suggest modifying this text as follows:
While fires are largely controlled by climate, frequent fires can themselves affectecosystem structure and carbon stocks across time to vary degrees in different regions
and ecosystems: for instance, in savannas frequently affected by fire events average treebasal area is affected by both climate and fires (Lehmann et al. 2014).
As natural disturbances of all kinds can have long-term impacts on emissions (dependingon the type of disturbance, area affected, and recovery rate), suggest deleting "Unlike
Canadafires" at the beginning of this sentence.

Response

Author's Note

RejectedNatural disturbance is the term used consistently in thescientific literature and the introduction of an new term
"natural damage" is not supported.

Accepted

Text implemented

Accepted with
Modification

Revised wording, removed simultaneously, but did not
accept all suggested wording.

Accepted

We added to the sentence that effects of interannual
variation may still be included.

Accepted

Deleted.

Accepted

We have moved the existing definition of natural
disturbances so that it appears earlier in the section andrevised the text to further improve clarity.

Accepted

Revised text accordingly

Accepted

Accepted

Accepted

Accept and revised text as suggested

Comment
VolumeID

Chapter

From line

To line

6240

4

2

2474

2475

5814

4

2

2477

2479

7232

4

2

2489

2490

4712

4

2

2490

2490

6536

4

2

2490

2490

7234

4

2

2493

2494

7236

4

2

2496

2501

4714

4

2

2515

2515

5816

4

2

2515

2518

5172

4

2

2530

2530

7238

4

2

2530

2530

5818

4

2

2530

2530

Comment
Reference to Australia’s 2015 NIR – note that the 2016 NIR has been submitted. The
updated table reference is Table 6.21.
Delete "and even in all other sectors" as it is misleading. Economic fluctuations are
typically larger for other sectors.
we don't think this table (table 2.6C) is necessary, and we disagree with some of theinformation provided in it. ACTION: delete the table.

Country

Response

Author's Note

Australia

Accepted

Reference has been added

United States of America

Accepted

Deleted.

Rejected

We have further improved the table but did not delete it as
this was the only comment against it and the reviewer
provided no information about which information the
disagree with - or why. Therefore no specific response ispossible.

Accepted

We spelled out all abbreviated terms.

Rejected

The term "distinguish' between drivers was carefully
chosen, because it is not simply about "accounting for" allof the impacts - but to truly distinguish between andquantify the impact of each driver.

Accepted with
Modification

We modified the text to state that Periodic assessments
without auxiliary data cannot quantify interannual variability.

Rejected

We modified the text to state that Periodic assessments
without auxiliary data cannot quantify interannual variability.
By definition, interannual refers to single years and yes
variability over multi-year periods can be estimated andthen assigned as average across single years - but that is
no longer a measure of interannual variability.

Rejected

The first sentence clearly reaffirms the MLP and thestatements that the MLP is currently recognised as the only
universally applicable approach.

Accepted with
Modification

Revised the first part of the text - but there is no reference
to reporting in the original wording.

Accepted

The definition has been revised and moved to Section
2.6.1.1

Accepted with
Modification

The definition has been provided and moved to Section
2.6.1.1

Accepted with
Modification

The definition has been provided and moved to Section
2.6.1.1

Spain

Add the explanation of abbreviation for “Live AGB & BGB pools” and "DOM & SOM pools”
Japanin the table 2.6C.
The subtitle of the table: "does the estimation method distinguish between the impact ofthe drivers" can be confusing. Rather than "distinguish", would an expression like
United Kingdom (of Great"account for" be more appropriate. E.g. even with ancillary data, annual measurements of Britain and Northern
Ireland)stock difference would not always enable to distinguish the IAV induced by the various
drivers but account for all.
We don't agree with the affirmation that periodic stock assessment don't provide
information on drivers of interannual variability. ACTION: delete the sentence with thisSpainaffirmation.
We don't agree that only with annual measurements IAV emissions and removals can bequantified. Biennial measurements, or even more separate measurements can provide
also information to quantify these emissions and removals. Uncertainty could be bigger, Spainbut quantification can be done. ACTION: delete this paragraph, or redraft to reflect theidea that quantification can be done anyway, although the uncertainties would increase.
The sentence "It is good practice for countries to apply the Managed Land Proxy" maymean countries should apply to disaggregate emissions and subsequent removals fromnatural disturbances. Also, this sentence seems to be contradict with the sentence "TheJapan
Managed Land Proxy (MLP) is currently recognised as the only universally applicableapproach to estimating anthropogenic emissions and removals in the AFOLU sector(IPCC 2010)". To avoid this misunderstanding / confusion, we would suggest to delete
this sentence here.
Change starting with the second sentence to "This section describes a genericmethodological approach that countries who choose may apply to estimate emissions andsubsequent removals from natural disturbances. The original text confuses thedescription of the method, which is to isolate and quantify the effects of natural
United States of America
disturbances, with the subsequent step of reporting a national total with these effects
excluded. These are two completely different things. Revised wording is more consistent
with what is described at the end of the paragraph as the aim of the methodologicalapproach.
No definition of natural disturbance is provided in section 2.6.1.2. It is strongly
recommended to include a definition that clearly delineate what is considered as "natural
Italy
disturbance", e.g. (IPCC 2013) non-anthropogenic events or non-anthropogenic
circumstances that cause significant emissions in forests and are beyond the control of,and not materially influenced by a Party.
having in mind that there is no definition of natural disturbances in 2.6.1.2., but only adescription of what could be considered ND, we would like to change the wording.
Spain
ACTION: change from "recalling the generic DEFINITION of NDs" to "Recalling thegeneric DESCRIPTION of natural disturbances".
"Recalling the generic definition of natural disturbances provided in section 2.6.1.2…"
Note that the cited section does not provide a generic (or any) definition of natural
United States of America
disturbances.

Comment
VolumeID
9278
4

Chapter

From line

To lineComment

Country

Response

2

2530

2530

Definition of natural disturbances is provided in section 2.6.1.1, not 2.6.1.2.
We don't think that the methods and criteria to identify the areas affected by adisturbance are part of the national description or definition of NDs, it is part of themethod to quantify E/R due to these disturbances. ACTION: delete "as well as themethods and criteria to identify the areas affected by such disturbances".
See comment to lines 2532 to 2533. ACTION: add here "a(bis)) description of methods
and criteria for identifying areas under natural disturbances"
The sentence "Consequently…." is confusing. Why would emissions and removals
subsequent to a human intervention in the landscape be split between anthropogenic annatural causes? This seems to be a needlessly complicated exercise and inconsistent
with the entire "managed land" prescription. Post-disturbance emissions and removals
should be deemed anthropogenic from the point of a post-disturbance humanintervention.
This section should be re-framed so that it avoids characterizing the goal of the guidanceas producing a "refined" total that is preferred to a total where these methods are notused. The goal of this section should be to provide clear guidance on how the effects ofnatural disturbances can be isolated and quantified. Whether or not the results aresubsequently used to produce a different AFOLU total as part of a national inventory
report is a decision that goes beyond the IPCC Guidelines. An example box would be abetter place to show the results of the Australian inventory.

CanadaAccepted

Spain

Accepted

Text deleted

Spain

Accepted with
Modification

The definition has been provided and moved to Section
2.6.1.1

Rejected

To achieve a balance between emissions and removals
from ND, it is necessary to ensure that removals that are
following ND are not considered anthropogenic only
because of human intervention.

Rejected

The text does not state that there is a revised TOTAL butthat there is a revised estimate of the anthropogenic
component within the total MLP. The total remains as thesum of the refined anthropogenic estimate PLUS thenatural disturbance estimate. The results of the Australianinventory have been deleted here.

Accepted with
Modification

The guidance provides methods for disaggregation of MLP
E/R estimates into anthropogenic and ND components andthe table provided further down in this section shows thatthe total MLP estimate of emissions and removals does notchange - but that it is merely disaggregated into two
components. How countries then report this information in
their CRF tables is beyond the scope of IPCC Guidance.

Rejected

In the context of an IAV discussion, fires are clearly themost relevant example. The national approaches areprovided as examples only - they need not be consensual.

Accepted with
Modification

Used "is expected to have" instead of "can have"

Accepted with
Modification

Used "is expected to have" instead of "can have". Yes - on
the other sources of interannual variability but unless theremoved IAV has the opposite variation then the othersources of IAV, removing ND IAV will reduce overall IAV.

Noted

Not sure what the reviewer is trying to say here: if forest
harvest rates are more rapid then the typical recovery times
post disturbance, then the landscape-level carbon stocks
will decline - and this will be captured correctly in thereported anthropogenic emissions. The expectation of thebalance between emissions and removals applies to natural
disturbances.

7240

4

2

2532

2533

7242

4

2

2540

2540

9280

5820

5822

4

4

4

2

2

2

2545

2547

2548

2546

2554

2549

6538

4

2

2548

2554

5824

4

2

2550

2551

7670

9282

4

4

2

2

2550

2555

2552

2596

CanadaUnited States of America

This is unclear, are countries removing the natural disturbances emissions/removals fromtheir inventory totals? This should be more explicit. If emissions and removals are
occurring on managed lands, regardless of natural or anthropogenic, those emissions
United States of America
should be captured in national totals. This could easily lead to countries reporting more
emissions from natural disturbances when in fact they were anthropogenic in nature,
reducing their LULUCF emissions. Recommend this be more explicit.
Fires on managed forest land might not be the most relevant example considering that
United Kingdom (of Great
policies to minimize their extent can reduce their scale (including Box 2.2.J is fine, but one
Britain and Northern
could argue with such citation of national approaches in the main text of the guidelines,
Ireland)considering that they are not consensual)
Insert the word “can”. The refined MLP flux can have a lower interannual variability….
(Australia or Canada may not be representative of other countries that have lower levels United States of America
of natural disturbances).
Lower interannual variability after removal of the effect of natural disturbances is notnecessarily true: 1)interannual variability in demand for timber creates variability 2)
Finlandinterannual variability of weather and possibly a part of natural disturbances createsvariability
Is there not an interaction between forest management and the “carbon balance”
concept? If in a given country, harvest is being carried out in a forest management area
at a rate that is more rapid than the typical recovery times post-disturbance, how could
this be captured? The forest management strategy may in fact impose a change incarbon stocks in their FMA and if reporting rules are based on carbon recovery than it is
Canadalikely that the going to misrepresent what is actually occurring on the land base. While thisconcept is understandable from a theoretical perspective, it is inconsistent with theobjective of capturing anthropogenic trends and impacts on the carbon stocks which a
country would wish to achieve by attempting to removal natural disturbances from theirreporting framework.

Author's NoteComment
VolumeID

Chapter

From line

To lineComment

Country

7244

4

2

2567

2570

we see a number of inaccuracies in this paragraph. First, it is assumed that emissions will
occur as consequence of the land use change. This wouldn't be the case, for example, if
a land with very little carbon (for example, some classified as "other land" are burned andconverted afterwards to shrublands or grasslands, or a cropland is burned and converted
Spain
to forest). Second, the paragraph refers to "deforestation" limiting the application ofguidelines to a single land use change after a disturbance. ACTION: FIRST, redraft theparagraph to reflect what would happen if the land use after the natural disturbance has,or is supposed to have, higher carbon stocks in the short term. SECOND, delete"(deforestation)" in line 2569

9284

4

2

2568

2568

Sentence should read, “may not be valid if land use or land management change occurs”. Canada

9286

4

2

2568

2579

5826

4

2

2569

2570

7246

4

2

2571

2579

5828

4

2

2573

2575

7248

4

2

2580

2580

6242

4

2

2595

2596

6540

4

2

2595

2596

5830

4

2

2595

2596

7250

4

2

2608

2608

7252

4

2

2609

2609

7678

4

2

2609

2632

7254

4

2

2610

2610

Why would a land-use change following a disturbance result in the initial disturbanceemissions being deemed anthropogenic instead of natural? This is illogical. Rather, it is
Canadathe human intervention (the land-use change) that alters the nature of the emissions or
removals. Post-disturbance emissions and removals should be deemed anthropogenic
from the point of a post-disturbance human intervention.
Change "are reported as" to "considered to be"
United States of America
we see that this paragraph causes unnecessary burden to inventory compilers, and thisguidance won't provide any useful additional information. It is useless for reporting, as
Spainemissions and removals will be the same, and has no effects on accounting, as
accounting is done to the future, not to the past. ACTION: delete the paragraph.
Delete "and to report these removals as part of the natural disturbance component"
United States of America
ACTION: replace "regrow forest" in this line by "recover C stocks". Text as it is now is
Spainassuming that NDs only occur on forests.
The comment that non-CO2 emissions do not permanently accumulate in the atmosphere
may not be so relevant (this is addressed by the use of agreed 100 year GWPs). Suggestthat a stronger argument would be: While non-CO2 emissions are not balanced bysubsequent removals, under the second-order approach described in this chapter, nonAustralia
CO2 emissions from natural disturbances are not considered to be anthropogenic(although it is not possible to completely separate human impacts) and are therefore notreported. This is similar to for example methane emissions from peatlands that have notbeen drained or undergoing active peat extraction, which may still be influenced byindirect human activity.
The sentence "However, such emissions [non-CO2] do not accumulate permanently inthe atmosphere since biochemical and physical processes contribute to their
United Kingdom (of GreatBritain and Northern
degradation." is slightly misleading. Some non-CO2 gases, while not strictly considered
Ireland)permanent, do remain in the atmosphere for an extremely long time which could beconsidered almost permanent. Suggest this is reworded.
"However, such emissions do not accumulate permanently in the atmosphere sincebiochemical and physical processes contribute to their degradation." The point of thisUnited States of America
sentence is unclear. Is it suggesting that CH4 and N2O emissions from natural
disturbances should not be estimated, even though they are short-lived climate forcers?

Response

Author's Note

Accepted with
Modification

Accepted with
Modification

This reviewer comment is internally inconsistent. If the landis burned - as in this example - then clearly there are
emissions - even if the carbon stocks are "very little". The
emissions will just be smaller but that is no reason not toreport them. However, we have edited and moved theparagraph further up in the text, because we agree with thereviewer that it contained inaccuracies - in particular theissues was not one of balance between E/R but an issue of
how to deal with ND emissions if the land was subsequently
subject to land-use change.

Rejected

Accepted

This sentence has been deleted.
Because the human activity changes the land use andtherefore precludes the removal by the forest sink in the
post-fire years.

Accepted with

If the approach described here is not used then an artificial
trend will arise with natural sinks (regrowth fromdisturbances prior to the start of the GHG time series)
attributed to the anthropogenic component within the MLP.
Text revised

Accepted

Text revised

Accepted with
Modification

Revised text

Accepted with
Modification

Revised text

Accepted with
Modification

Revised text

Rejected

We have deleted not only the text in brackets but the entire
box as the definition that is now in the text makes this levelof detail redundant.
We have deleted the box as the definition that is now in the
text makes this level of detail redundant.

ACTION: delete the text in brackets in the title. We would like to avoid any referents to KP
Spain
supplement

Accepted with
Modification

NDs can occur in any land use, description of NDs shouldn't be limited to forests.
ACTION: delete "forest" and replace it by "ecosystems"
Examples of natural disturbances originate from Decision 2/CMP.7, for reporting andaccounting under the second commitment period of the KP, and are cited in the KP
Supplement, i.e. not defined by the KP Supplement.
NDs can occur in any land use, description of NDs shouldn't be limited to forests.
ACTION: delete "forest" and replace it by "these"

Spain

Accepted with
Modification

FinlandAccepted with
Modification

See comment 7252 above

Spain

Accepted with
Modification

See comment 7252 above

Comment
VolumeID

Chapter

From line

To line

7256

4

2

2619

2620

7258

4

2

2628

2628

5832

4

2

2654

2654

9288

4

2

2654

2805

9290

4

2

2667

2669

4716
5834

4
4

2
2

2674
2685

2674
2685

5836

4

2

2685

2686

4718

4

2

2685

2743

9292

4

2

2702

2703

9294
9296
5838

4
4
4

2
2
2

2710
2711
2733

2710
2712
2733

7260

4

2

2748

2748

5840

4

2

2748

2805

7680

4

2

2749

2805

7676

4

2

2761

2764

7614

4

2

2768

2773

5842

4

2

2773

2773

Comment
NDs can occur in any land use, description of NDs shouldn't be limited to forests.
ACTION: delete "forest" in line 2619 and "forested" in line 2620
NDs can occur in any land use, description of NDs shouldn't be limited to forests.
ACTION: replace "forests" by "ecosystems".
Box 2.2J title - change "managing" to "estimating".
Description of examples is too long: limit to 1 page each - and refer to other publications
as necessary.

Country
Spain
Spain
United States of America
CanadaDescription of how "outliers" are addressed is unclear. Suggest rewording to better
explain how the double threshold concept (national and state) is applied, what happens
with the value for the years which are determined as "outliers" and what values are
Canadaultimately reported in the inventory. This approach is considerably different from thedisaggregation approach used by Canada as it replaces the "outlier" value with an"average" value instead - so this should be made very clear.
There is no “Figure2.7B”. Remove “Figure2.7B”.
Japan
Box 2.2K title - change "managing" to "estimating".
United States of America
Pages 2.84 and 2.84, Box 2.2K: This box might be better titled "Canada's approach toreporting on interannual variability." The box reflects an inventory reporting approach, notUnited States of America
an approach to managing interannual variability on the ground. The first sentence in thebox also seems somewhat less than objective.
Four articles (Kurz et al. in review) are cited in this Box 2.2K. Please check the status ofJapan
these articles. If a cut-off date is over, delate the referenced sentence.
Grammatical: Sentence lacks a subject. The word “This” is not a subject. Also, Thephrase “background level of natural disturbance” seems odd. Would it not be more
Canadaaccurate to refer to “normal forest mortality”.
Grammatical: new paragraph beginning in the middle of a sentence.
CanadaSpecify the “re-entry age”.
CanadaBox 2.2K title - change "managing" to "estimating".
United States of America
as mentioned repeatedly, we would like to avoid references to KP supplement. ACTION:
Spainchange the title of the box.
It is unclear why "country Z" is not identified and the technical example does not have acitation, and contrasts clearly in this regard with the Australia and Canada example. It
United States of America
would add more credibility to the 2019 refinement if the country were identified and theinformation cited so that users could go to the original analysis.
Box 2.2L: Please check if the interpretation that statistical outliers (specifically outside the
95% confidence interval of variability) are a reflection of natural disturbances beyond
country's control is actually that of the KP Supplement (as stated in the title of Box 2.2L).
Approach in the KP Supplement is that of background level of natural disturbances which
Finlandhas to be exceeded (with a margin) so that emissions from natural disturbances can betaken into account in accounting of emissions and removals whereas Box 2.2L uses thedefinition of outliers to be a definition of what cases of disturbances can be called natural
disturbances and beyond country's control.
Definition of natural disturbances originates from Decision 2/CMP.7, for reporting andaccounting under the second commitment period of the KP, and is cited in the KP
Finland
Supplement, i.e. not defined by the KP Supplement.
The described procedure is simplistic. For example, an extreme event like large scale
forest fire may cause a peak in GHG
emissions caused by changes in forest management. If due to changed forest
Finlandmanagement practises more biomass is left in the forest (e.g. residue), increased GHG
emissions is due to management change, but in the case of forest fire it would be
calculated as due to "natural disturbance".
The wording of footnote 20 is cryptic and unclear. What does the following text mean?
United States of America"while the KP addresses it in the accounting"Response
Accepted with
Modification
Accepted with
Modification
Accepted
Accepted with
Modification

Accepted with
Modification

Rejected
Accepted

Author's Note
See comment 7252 above
See comment 7252 above
Deleted the box
Boxes have been shortened but not to the extent requestedby the reviewer. For the details of the explanation readers
are referred to other publications.
The description has been shortened and for the details of
the explanation readers are referred to other publications.
Each of the boxes is an example of a country-specificimplementation but the authors refrain from comparison
across methods.
Figure 2.7B is present

Accepted with
Modification
Accepted

Published and reference added

Accepted with
Modification

Revised wording but did not accept the change to "normal
forest mortality" because that is not the meaning of thesentence.

Accepted
Rejected
Accepted

Information is already listed in the same paragraph.

Accepted
Accepted with
Modification

Country Z is now+K127 identified in a footnote

Noted

KP reference has been removed. The current description is
the interpretation contained in the EU legislation forreporting on natural disturbances in forest. Checked theinterpretation and found to be correct.

Acceptedreference removed

Rejected

The use of a marging addresses the variability ofmanagement activities across time. Where this occurs andemissions are less than the threshold, the emissions are
deemed anthropogenic.

Accepted

Text revised

Comment
VolumeID

Chapter

9298

2

4

From line

2783

To line

2798

5844

4

2

2806

2882

5846

4

2

2808

2812

7262

4

2

2811

2811

7264

4

2

2828

2829

7682

4

2

2828

2831

5848

4

2

2828

2831

7266

4

2

2835

2836

9300

4

2

2835

2836

5850

4

2

2838

2840

5852

4

2

2841

2841

7268

4

2

2841

2842

Comment

Country

How this approach is applied to identify "outliers" is clear; however, what is unclear iswhat values ultimately are reported in the National GHG inventory as the anthropogenic
Canadaimpacts on forests. Suggest adding further explanation to clearly address what values
Parties should report.
This section appears to suggest that separating emissions and removals from natural
disturbances in national GHG inventory reporting is the only possible approach toincreasing transparency on anthropogenic emissions and removals in forest land. This is
not the case. Similar (or arguably more) transparency could be achieved by following theUnited States of America
guidance in ACCOUNTING FOR any national GHG target or commitment. This provides
full transparency on what a country itself considers to be beyond its control (itself ananthropogenic policy construct to a degree), without interfering with the holistic estimatesprovided by the national GHG inventory.
Delete the first paragraph as it is value-laden and goes beyond the MLP approach
outlined in the 2006 GL. Transparency is related to how clearly a country "shows its
work", and whether or not an independent observer can understand how the results weregenerated. Transparency is not related to whether or not a country chooses to implement
a method to separate/isolate the effects of natural disturbances. A country that quantifies United States of America
natural disturbances is not necessarily more transparent than a country that does not.
The reporting of the results of quantifying IAV should be presented below objectively as ameans of showing how the results were generated by countries that have decided to use
these methods.
the reference "IPCC 2010 and papers therein" is quite vague. ACTION: include the rightSpainreference or delete the paragraph.
we disagree with the view that providing estimates associated with NDs reduces theinterannual variability, we only see that transparency is increased. ACTION: replaceSpain"greatly reduces interannual variability" by "increases transparency of national GHG
reports"
Please rephrase to "…can greatly reduce the interannual variability of anthropogenic
emissions and removals" as it may not in countries with smaller interannual variability of Finland
natural disturbances but greater variability in harvesting for instance.
Change "Providing" to "Developing", as it more accurately reflects the guidance in thissection. Change "greatly reduces" to "identifies and describes the impact of". IAV is what United States of America
it is and doesn't change by virtue of a country estimating it.
We suggest to delete the table. We would like to see a table for all emissions andremovals and a separate table for NDs. Then it would be easy to make calculations of
Spain
what is the remaining managed areas and what are the emissions not caused by these
disturbances. This table duplicates work and can be confusing. ACTION: example of thetable, or modify it to reflect only NDs emissions/removals.
Box 2.2M, footnote 28: "past emissions" should be made more specific by adding "since
Canadathe occurrence of the natural disturbances" at the end of the footnote.
Change to "For those countries that choose to identify, quantify and disaggregate natural
disturbance emissions, it is good practice to provide information that describe theUnited States of America
approaches and methods that are used."
Change to "For those countries that choose to disaggregate natural carbon fluxes using
United States of America
these methods, it is also good practice to…"
we see the need to add a new bullet between these two lines. ACTION: add a new bullet"define natural disturbances nationally" or "include national definition of natural
Spain
disturbances"

Response

Author's Note

Accepted with
Modification

EU Box Discussion - when this box is revised the text will
be modified.

Accepted with
Modification

The references in the text that indicate that this method
increases transparency have been removed. However, thesuggestion to refer to accounting methods has been
rejected as beyond the scope of this refinement. IPCC
Guidance does not address accounting issues.

Accepted with
Modificationtext revised to respond to comment

Accepted with
Modification

Accept and included only IPCC 2010 reference

Accepted with
Modification

We revised the test but because of other reviewers'
opposing comments did not use "transparency".

Accepted with
Modification
Accepted with
Modification

We revised the text to address several comments on thissection - but did not use the wording suggested by thisreviewer.

Accepted with
Modification

We did not delete the table but modified its structure toaddress the reviewers comments.

Accepted
Accepted
Accepted with
Modification
Acceptedsee previous comment

Comment
VolumeID

Chapter

9302

4

2

2841

2883

7270

4

2

2850

2850

9304

4

2

2862

2862

7272

4

2

2874

2874

7274

4

2

2880

2882

4720

6542

9306

9312

4

4

4

4

2

2

2

2

From line

3935

4163

1577

730

To line3936

Comment

CountryOver-prescribed documentation requirements on disturbances: from this text, it would
appear that countries would be expected to maintain documentation within their inventory
system of the all fire management efforts and information about individual fire events
demonstrating their cause and even weather conditions. If this were an inventory
Canadadocumentation requirement, it would not be practicable. Documentation requirements
should be balanced and realistic - keeping in mind that disturbance data might be but one
input in a GHG inventory. Keep lines 2841 to 2847, delete lines 2848 to 2871 and movethe remainder in box 2.2i with the KP material.
As commented above, we think that NDs can happen in all land uses. ACTION: replaceSpain"forest type" by "ecosystem type".
Grammatical: Administrative, not administrational.
Canadait is not clear at all how a method can be consistent with an expectation. ACTION: redraft.
Spain"how the method addresses the condition that the CO2 emissions from..."it is not clear from the current text what emissions and subsequent removals associated
Spainwith human activities mean. ACTION: please, clarify further.

The meaning of "The Fperm estimate was also adjusted for CH4 and N2O emissions " isunclear. If it means some compensating rate is adopted for the Fperm estimate, pleaseJapan
indicate the numbers.

typo? size n= 1,000,000 (and not 1,000,00) assuming the rest of the sentence is correct.

1644

This section provides model-based approaches that can capture the influence of land use
and management on processes controlling carbon input and soil microbial decomposition
along with four examples from Australia, Finland, Japan, and United States of America.
What it lacks in this section is to outline basic requirements for model-based methods to Canada
assure that Tier 3 methods indeed provide more accurate estimates than Tier 1 and Tier
2 methods; more specifically more guidance on minimal model validation and transparent
documentation is required.

The organic matter content of “Organic Soils” seems too low.

Author's Note

Accepted with
Modification

We greatly reduced the detailed documentation
requirements

Accepted with
Modification
Accepted

The reference to forest type has been deleted (but noreference to ecosystem type has been added).

Rejected

The term expectation has been used throughout thechapter and should not be changed on the last page.

Accepted

Revised the text.

The inclusion of this sentence was a mistake. The
calculation of Fpermp did not include any adjustment forCH4 or N2O emission. This needs to be corrected in the
text and equations added to estimate the CH4 and N20
Accepted with Mod
emissions associated with pyrolysis.

United Kingdom (of GreatBritain and Northern
Accepted
Ireland)

4163

731

Response

CanadaValue should be 1,000,000

We agree with your points. Guidance on model evaluationand documentation has been further developed in Chapter
6 of Volume 1 and Chapter 2 of Volume 4 of the 2019
Refinement. These sections provide the guidance on theseAccepted with mod topics, and the authors decided to not duplicate theguidance with further elaboration here.

Accepted

9314

4

2

794

795

Organic soils are generally acidic, suggesting to delete “or organic soils”.

CanadaRejected

9316

4

2

2397

2397

“ wind throw” should be referred to as “windthrow”.

CanadaAccepted

Note that the text was out of scope for the review.
However, the value provided does indeed seem low whenused to express organic matter content. It should be
expressed in terms of organic carbon content. This was
confirmed by checking the 2006 Guidelines.

For terrestrial systems where organic soils develop on
acidic sediments/rocks the reviewer's comment may beappropriate. However for organic soils developed overlimestone or in coastal systems (e.g. mangroves and tidal
marshes) significant quantities of inorganic carbon may bepresent within organic soils.

Comment
VolumeID

Chapter

From line

To line42

Box 2.2

9542

4

3

125

308

9544

4

3

164

168

7276

4

3

181

182

7278

4

3

188

188

5854

4

3

198

200

7280

4

3

199

199

6244

4

3

207

208

4

3

263

CountryThis could use some additional instruction on how to address areas that are affected bymultiple disturbances - i.e. the total area may not increase from year to year, but thesame area may be affected by multiple natural disturbances (e.g. pest infestation followed Canada
by wildfire). Should clarify whether this kind of table would be required for each
disturbance type - or if it would aggregate all natural disturbance-affected areas.

9318

7282

Comment

Lines 125, 308, 381, 426 mention RS data here but haven't defined the acronym yet.
Define RS acronym at first appearance in text (line 125?).
Edit this section to reflect the guidance of the IPCC Wetlands Supplement which
expanded the wetlands category (included other wetlands categories) and guidance in
Chapter 7 of this Refinement for Flooded Land (Reservoirs and other constructedwaterbodies).
we believe that it is more accurate to refer to years instead of reporting period. ACTION:
replace "reporting period" by "year" at the end of the sentence.
we believe that it would be more precise to refer to current land use management insteadof land cover management. ACTION: replace "land cover" by "land use"

This sentence needs to be edited, it’s not clear as currently written.

263

RS was removed as acronym. All RS converted to "Remote
Sensing"

CanadaAccepted with
Modification

Reference to Wetlands Supplement added.

Spain

Accepted

This sentence has been deleted as part of the revision.

Spain

Accepted

United States of America

AcceptedSpain

Re-drafted to improve expression and clarify the intent.

Accepted

the paragraph has been edited to include reference to"subsidies for land use changes or land management".

Accepted with
Modification

This table is now included as a box (3.1a) and has beenthoroughly revised considering all other comments.

Spain

Accepted with
Modification

We have modified the table to account for these issues andbelieve we have addressed this in the reviewed text.

Spain

Accepted with
Modification

Text rewritten both for clarity but also to remove thereference to a specific threshold. Rather it simply notes thatcountries need to consider the definition of FL and how it
may affect CL.

297

7284

4

3

296

297

difficult to provide comments without numbers for lines. ACTION: delete thresholds in theSpaindefinition of forests, these are KP thresholds that shouldn't be included in the refinement

7286

4

3

296

297

7288

4

3

296

297

7290

4

3

296

297

297

Noted

Spain

296

296

In response to other comments the text has been modified
so the reference to 'areas of land-use' has been removed.

Accepted with
Modification

3

3

Accepted with
Modification

Spain

4

4

This section has been revised thoroughly to address thisand other comments related to this section.
This sentence has been edited to the following: 'To ensure
consistency, it is good practice that the total reported landarea (the sum of all managed and unmanaged lands)
remain constant through the time-series.'

This table just illustrates a few example. It is not the bestplace to insert Wetlands Supplement Reference. However,this reference is included elsewhere in this chapter.
We have deleted the threshold ranges (i.e. 10-30% coveretc) as the reviewer is correct that these are KP. We haveleft the examples of structural measures that could be used
to help define forest though as these are consistent with thenational definition of Forest Land. We are assuming thereviewer only meant the values rather than the example
measures.
We agree with this comment. We have reviewed the text tobetter address issues of natural disturbance.

9546

7292

The box presents the calculations required to implement
the Tier 1 method where land use change has occurred. It
does not deal with disturbances. Guidance on how to deal
with disturbances can be found in Volume 4, Chapter 2,
Section 2.6 of the 2019 Refinement.

Accepted with
Modification

Include reference to the IPCC Wetlands Supplement, especially when considering
different wetland categories.

difficult to provide comments without numbers for lines. ACTION: add "or natural
disturbances" after forest harvesting in the cell referring to forest cover lost.
difficult to provide comments without numbers for lines. ACTION: in the cell starting with"countries often" add "in some countries, land use is assumed to continue, even if
destocked, unless change is proved by land use maps or any other information source"difficult to provide comments without numbers for lines. ACTION: In the cell starting with"where the forest does not..." we would like to replace the first sentence by "Where theland cover does not recover after a number of years, land would be moved to aconversion category unless its permanence in the original category is duely justified".
difficult to provide comments without numbers for lines. ACTION: delete the line startingwith "consider how the threshold...". First, nothing forces countries to define their forests
with thresholds, second, classification of land in some countries does not depend on
forest cover, but on land use. This line creates confusion.

Noted

Author's Note

Canadawhen the text refers to "areas of land-use" we would like to see "areas under the differentSpainland uses". ACTION: replace the text as proposed.
Excluding lands that exit country reporting due to changes in political boundaries risks
global incompleteness unless paired with the inclusion in the full series of lands that enter Australia
country reporting.
after "concession boundaries" we would like to see "subsidies for land use changes orland management" as an example of auxiliary information. ACTION: add the text as
proposed.

Response

CanadaRejected

Accepted

Comment
VolumeID

Chapter

7294

4

3

296

297

7296

4

3

296

297

6544

4

3

296

297

6546

4

3

296

297

6548

4

3

296

297

6550

4

3

296

297

6552

4

3

296

297

5856

4

3

359

373

While the guidance presented here is relatively clear, a quick example of how this works
in practice would be useful i.e., a side box with example.

Rejected

Accepted withAccepted

From line

To lineComment

Countrydifficult to provide comments without numbers for lines. ACTION: in line for grassland, inthe second cell, we would like to change "definition for forest used" by "definitions forSpainforest and croplands used". We think both definitions can have impact in the classificationof GL.
difficult to provide comments without numbers for lines. ACTION: in line for wetlands,
instead of "use of existing definitions" write "use of national definitions", as definitions will Spain
be developed nationally (in line with GLs).
Table 3.1A. Forest Land rows. Change "How to identify systems with a vegetation
United Kingdom (of Greatstructure that currently fall below, but in situ" to "How to identify systems with a vegetation
Britain and Northern
structure that currently fall below, but in future" and "potential to reach a minimum height
Ireland)in situ (2-5 m)" to "potential to reach a minimum height in future (2-5 m)"
United Kingdom (of Great
Table 3.1A. Forest Land rows. Blank row should be removed.
Britain and Northern
Table 3.1A. Forest Land rows. Clarify "(consistent with the need for structural
United Kingdom (of Great
thresholds...", should this be "(needs to be consistent with structural thresholds..."?
Britain and Northern
Table 3.1A. Forest Land rows. "e.g. land undergoing a process of conversion to forest
United Kingdom (of Greatland" should be in brackets.
Britain and Northern
Table 3.1A. Forest Land rows. "minimum width (meters)." Should an example width be
United Kingdom (of Great
included, such as "minimum width (100 meters)"?
Britain and Northern
United States of America

7300

4

3

360

361

the affirmation in this sentence is not true. For example, for croplands, where they are all
assumed to be managed lands (at least in most countries), and this area is yearlySpainreduced due to abandonment of lands or reforestation (for example). ACTION: wesuggest to redraft the section taking this into account.

5858
5860

4
4

3
3

421
423

421
423

Change "Parties" to "countries", and change "reporting" to "estimating".
Insert "statistical" before "products". Or change to "datasets".

The word "map" is used in two different ways, which is confusing. Reword to use "map" inthe sense of "cartographic representation" only, not as a verb meaning "cross-walk" as in Canada"map to new RS products".

9322

4

3

426

427

7302

4

3

443

444

6554

4

3

476

482

United States of America
United States of America

Response

Author's Note

Accepted

Agree with this comment and have made this change

Accepted

Agreed, text revised

Accepted with
Modification

Made changes but with reference to forest land rather thana threshold definition

Accepted

Deleted.

Accepted with
Modification

We have changed this text given the issues with structuraldefinitions raised by other reviewers

Accepted

Closed brackets

Rejected
Accepted with
Modification

Accepted

there is the need to evaluate the accuracy and consistency of land cover and land use
Accepted with
Spain
classification, but also to report about it. ACTION: replace "evaluate" by "report"
Modification
To give an idea of the underreporting of the changes when using only information on net
changes rather than on gross changes, a reference to the work of Tomlinson (2018) could United Kingdom (of GreatBritain and Northern
Rejected
have been made. This would be useful to gives examples that can guide "expert
Ireland)judgement" to try to estimate gross changes from information on net changes only (incontext fairly similar to the UK).

9324

4

3

622

623

Explain why and when approach 1 (no data on conversion between land uses) could
result in inconsistent maps; and why would approach 2 (total land use area, includingchange between categories) not track through time series?

CanadaAccepted with
Modification

7304

4

3

651

651

ACTION: replace "IPCC cover type" by "IPCC category".

Spain

Accepted with
Modification

We have removed reference to meters here but notincluded example as it is not applicableThis comment refers to existing IPCC 2006 text. Consistentuse of land area has been discussed elsewhere in thischapter.
Firstly, this is existing IPCC 2006 text. Secondly, theexample provided by the reviewer is not an example ofmanaged land becoming unmanaged. In the case ofcroplands being abandoned or reforested the land remains
managed, but moved between land use categories. As
such the existing text is correct.
Sentence has been updated as suggested.
Replaced: "products" with "datasets"
Text has been updated and now reads as "Even where thedefinitions are the same, existing forest type maps
generally cannot compare to new RS products due todifferences in spectral and geometrical resolutions and themethods applied for land-use classification.''Deleted bullet point as reporting accuracy of land usechange is covered elsewhere.
The paper is out of the cut-off date for literature review:
June 2018.
The reviewer has misread the purpose of the table: thepoint is that inconsistent maps with no data on LUC means
the maps will lead to Approach 1 methods. Approach 2 will
not track multiple changes in land use, but where these do
not occur it is the same as approach 3. These are further
described in the text and the table is an example only. We
have redrafted parts of this table based on other comments
and hope this will resolve these issues.
Figure 3.2 has been revised and new text has been added
to explain the decision tree. Terminology adjusted
consistently.

Comment
VolumeID

Chapter

From line

To lineComment

6556

4

3

657

658

Figure 3.2. "Classify as the initial use type." Should this be "Classify as land remaining
land of the initial use type."?

6558

4

3

657

658

6560

4

3

657

658

6562

4

3

657

658

7306

4

3

672

672

7308

4

3

673

673

9326

4

3

686

690

9328

4

3

707

708

Country

United Kingdom (of GreatBritain and Northern
Ireland)United Kingdom (of Great
Figure 3.2. "Classify as land remaining land." It would be clearer to say "Classify as land
Britain and Northernremaining land of the new cover type."
Ireland)Figure 3.2. It seems that "cover type" and "land use" are used interchangeably, it would
United Kingdom (of Greatbe less confusing if only one term were used. (e.g. in "Do the cover types for the present Britain and Northernand next step..." and in "Did the cover type change back to a previous land use...")
Ireland)United Kingdom (of Great
Figure 3.2. "Classify as cropland." Should this be "Classify as cropland remaining
Britain and Northern
cropland."?
Ireland)ACTION: replace "land cover and land cover change" by "land use and land use change".
In most cases, land cover change doesn't imply a land use change. For example, a forest
Spainwith crown cover of 90% that changes to 85%. Some times these changes are not even
identifiable in cartography or other information sources.
ACTION: replace "land cover" by "land use". See comment to line 672,
Spain
For clarity, suggest to reword as "when doing so it is good practice to demonstrate thatthe changes tracked through time are consistent and to report possible bias and known
Canadauncertainties of the change analysis"
Challenge of inferring land use from land cover has been mentioned already. Suggest to
Canadaremove.

Response
Accepted

Accepted

Accepted

Accepted

Updated text as suggested. Additionally a full check andupdate to ensure consistent use of terms was triggered bythis comment.

Accepted

Change made as suggested

Accepted

This section has been revised thoroughly to address thisand other related comments.

Accepted

Bullet removed.

4

3

711

712

We disagree with the idea that it is unlikely that land uses will be specially consistentthrough time in maps developing using different data. We believe that it is difficult orchallenging but not unlikely. ACTION: replace "unlikely" by "challenging".

Spain

Accepted with
Modification

9330

4

3

711

715

This section is unclear. Explain why, if two highly accurate land use maps for different
points in time are produced from different method/data, the land-use change may not be
accurate or consistent.

CanadaAccepted

9332

4

3

716

716

9334

4

3

717

717

5862

4

3

724

724

7312

4

3

725

725

Figure 3.2 has been revised and new text has been added
to explain the decision tree. Terminology adjusted
consistently.
Figure 3.2 has been revised and new text has been added
to explain the decision tree. Terminology adjusted
consistently.
Figure 3.2 has been revised and new text has been added
to explain the decision tree. Terminology adjusted
consistently.
Figure 3.2 has been revised and new text has been added
to explain the decision tree. Terminology adjusted
consistently.

Accepted

7310

Again (see comment on lines 426-427) the word "map" seems to mean different things, inthis particular case "data" (as in the images used in creating the land use maps) but it is
Canadaunclear. Only use the word map when talking about a "cartographic representation".
Differentiate between land cover data (= the result of a land cover classification) andimagery data (pixel values).
Unclear why this can't be done using Approach 3?
CanadaShould "National Forest Inventory" be capitalized? It is meant generically here, notUnited States of America
specifically.
Some countries combine their inventory sampling methods on remote sensing images.
Spain
ACTION: add "or a combination of both" after "lidar)"

Author's Note

Accepted

Accepted withAccepted
Accepted

Text was edited to remove 'unlikely' and add 'challenging'which also required further editing of the text for grammar.
the text now reads as follows "It is challenging to maintain aspatially consistent time series where maps have beendeveloped using different data (e.g., different sensors) or
methods (different algorithms or operators in visualinterpretation). In such cases it may not be possible to use
this data in an Approach 3 context, however such data may
be used in to stratify samples used in the application ofApproach 2 (GFOI 2016)."
While the land cover maps may be accurate to representchanges between two time periods, the text here isreferring to consistency across the entire time series used
between the two dates, so not just consistency between
two dates. The new text reads as "Where different land
cover maps have been developed using different data (e.g.
, different sensors) or methods (different algorithms or
operators in visual interpretation) it is unlikely that the landuses will be spatially consistent through time in the timeseries..."Text updated, now reads as"' describe the differences
between the land cover data in the time series;"
Text updated, deleted "Approach 2"
Replaced: "National Forest Inventory" by "national forest
inventory"
Added: "or a combination of both"Comment
VolumeID
9336

4

Chapter

3

From line731

To lineComment

732

The third option - using whatever data are available - may also involve inconsistentmethods; clarify.

7610

4

3

740

741

5864

4

3

743

743

7314

4

3

748

748

Country

CanadaIt is also possible to use temporary sample plots for Approach 2 and 3 methods. This wasstated earlier in 2006 IPCC guidelines, V4 Ch3, page 3.33. Besides of auxiliary data, while
carrying out field inventory of sample plots, land use changes can also be assessed in thefield, e.g., by observing the surroundings of the plot, existing vegetation, decay rates oftree stumps etc. I suggest to modify the text: ...Where temporary sample plots are used, it
Finlandis not possible to apply Approach 2 or 3 methods -> CORRECTION:... unless a time
dimension can be introduced into the sample. This can be done by drawing on auxiliary
data, for example maps, remote sensing or administrative records about the state of landin the past or assessing in the field. See also 2006 IPCC Guidelines, V4ch3, page 3.33
about temporary plots and time dimension
Does the sampling network really need to be applied to the whole country to be usable? It
United States of America
should be applied to a whole land category or sub-category.
We believe that not always additional information from other sources is needed to convert
Spainsamples to land uses. ACTION: add "if needed" after "used with other information".

Response

Author's Note

Accepted

Revised this dot point to clarify that by simply removing thenotes on consistency, thus leaving it open to bothconsistent and inconsistent methods, the main point being
they are for different locations

Accepted with
Modification

See comment 5188.

Accepted

Sentences redrafted: "... the sampling method should beapplied to the whole area of interest …."

Accepted

Added: "if needed" after "used with other information".
The detection rate indeed may improve with a higher
sampling frequency, but the resulting rate of change is notconsistent across time series. This means that where
frequency of sampling changes (10 years to annual), thisneeds to be accounted for in the inventory to ensure
consistency across time series. Changed the text and is
now "'samples are collected with sufficient temporalconsistency that detection rates of change do not alter due
to differences in sampling frequency."'
The authors appreciate this recommendation. However, it
is not useful to add this reference without providing
additional guidance on how to use such methods. This isbeyond the scope of the current revision. Authors believe
revised text does not preclude use of such advanced
methods even though it is not referenced here.

9338

4

3

752

753

Bullet point unclear: if in the past measurements were collected every 10 years, but now
they can be collected every year, will this improve the detection rate?

Canada

6564

4

3

783

884

Reference to Levy (2018) and adjustment of the text to take into account suchapproaches would have been useful.

United Kingdom (of GreatBritain and Northern
Accepted
Ireland)804

Current GIS systems do not require to have all data in same map projection as GIS
systems can project on the fly in doing most types of analysis. What is important is
knowing the projection that was used in doing the area calculation. Equal area projections
Canadashould be used, but still result in some distortion. Provide more guidance. Perhaps
suggest an equal area project that everyone should use (e.g. a global projection vslocal?).

Accepted with
Modification

Authors agree with the comment in the case of GIS
visualization. However, for undertaking spatial analysis andarea calculations it is necessary to consider appropriate
coordinate systems specific to a country. This information
was clarified in the text.

We think that is totally impossible to ensure that all data is in the same map projection.
ACTION: delete bullet.

Accepted with
Modification

Spatial data can be in any format and projection. However,when combining data from different sources it is preferable
to have the data in same map projection to facilitate spatial
data analysis. Text has been edited to clarify that spatial
datasets to conform to national mapping standards toensure accurate area estimates.

9340

7316

4

4

3

3

804

804

805

Spain

Accepted

Comment
VolumeID

7318

4

Chapter

3

From line809

To lineComment

Country810

We disagree with this bullet. Each land use change can have different conversion
periods. As long as the total national area is maintained, and there is avoidance of double
allocation of lands to different land uses, there is no need to ensure that conversion
period is the same. One simple example is deforestation, where most of the AGB will be
released in one single year, and no conversion period is needed. Using a conversion
Spainperiod of, for example, 20 years, would be reducing the accuracy of the inventory.
ACTION: replace the bullet with "ensure that the use of conversion periods doesn't resultin gaps or overlaps between land uses/categories/subcategories." We would also preferto see this lines in a different section (for example, land-use conversions, page 3.8.), we
don't think this sentence belongs here.

Response

Author's Note

Accepted with
Modification

Agree that land use changes can have different conversion
periods, if supported by data. For each land-use category
the conversion period should be consistent across time.
Authors agreed that this bullet will remain in this place as
this concept applies for all land-use categories.

6566

4

3

811

812

As applied in Levy (2018), Bayesian approaches that take into account various data
sources and weight them depending on their uncertainties rather than just use theinformation conveyed by the higher quality data-stream. It would be worth adding areference to that work

9342

4

3

815

815

What does "ensure the accuracy" mean? Is the intended meaning "report the accuracy"? Canada

Spain

Rejected

CanadaAccepted

7320

4

3

820

829

Most of these good practices, if not all, are impossible to achieve, it is not realistic formost of the countries. Therefore, this creates problems for countries that land t use
spatially explicit information, making very difficult for them to elaborate national
inventories. ACTION: delete these bullets.

9346

4

3

827

827

Should it be "the data aligns" or "the pixels align? (e.g. see next bullet).

9348

4

3

828

829

7322

4

3

946

948

9350

4

3

1270

United Kingdom (of GreatBritain and Northern
Accepted
Ireland)Unclear what the word "alignment" is referring to in the context of this sentence; alignment
Canadawith what?
ACTION: move definition of stratification to glossary
Spain

Accepted

Text replaced: "ensure" to "report".
Justification: While it is true that not all countries can apply
spatially explicit methods, this does not prescribe theguidance. Even if it is not achievable, IPCC should provide
guidance on the best way possible to have a consistent
representation of lands.
Text modified to clarify that alignment of pixels with thesame ground coordinates (whatever projection or datum isused).

Accepted

Deleted the word alignment.

Accepted with

Definition added to the Glossary
Ground truth data can be any variable measured in thefield. Deleted reference to canopy cover. In this context,
the text refers to use of ground data to validate RS outputs.
We agree with the comment that canopy cover can bemapped in the field or using very high resolution imagery to
train the classification algorithm.
Text modified that use of high resolution remote sensing
data can be cost effective to validate RS outputs. Most
countries use a combination of ground sampling andremote sensing.
Reference data is clarified in line 1267 of the SOD. No
further action required.
Deleted reference to remote sensing in line 1280, which
was confusing. Dot points under line 1278 of SOD havebeen redrafted to provide better explanation of what
constitutes good practice in this context.
Lines 1278 to 1298 of SOD have been revised andsimplified to clarify what constitutes good practice whenvalidating remote sensing maps without being prescriptive.
Lines 1278 to 1298 of SOD have been revised andsimplified to clarify what constitutes good practice whenvalidating remote sensing maps without being prescriptive.
Lines 1278 to 1298 of SOD have been revised andsimplified to clarify what constitutes good practice whenvalidating remote sensing maps without being prescriptive.

1273

Clarify what ground data is: land-use? carbon stocks? Sentence below says that canopy
cover is more easily assessed with RS data than ground data- but canopy cover is usually
Canadaderived from a model of RS-ground data relationships, and therefore this sentence
doesn't make sense.

Accepted

Accepted

9352

4

3

1274

1276

This paragraph is unclear: RS data does not directly measure things like canopy coverand carbon stocks. To obtain these parameter it requires some sort of model production
Canadaand validation (e.g. ground data to be collected). So re-word to "all countries should use acombination of RS and ground data".

9354

4

3

1279

1279

Does reference data mean data used to validate? Please clarify and/or reword.

CanadaAccepted with
Modification

9356

4

3

1280

1281

Clarify whether this means to use additional remotely sensed data to validate productsthat were derived from remote sensing at lower resolution?

CanadaAccepted

9358

4

3

1283

1283

9360

4

3

1284

1284

9362

4

3

1285

1285

Selection of plot size and sample size must also consider variability in the physical featureof interest, not only the pixel resolution of the image? This is highly variable in the
Canadaliterature. Clarify, remove or reword.
Clarify: positional accuracy does not hinder one from "locating" a sample on a land use
map. Is the desired accuracy here in relation to the need to "identify" a specific feature in Canada
a land use map?
This seems highly specific. Why the focus on canopy cover? What other physicalparameters might be measured?
CanadaReword to "where ground data are used for estimates of biophysical parameters..."

The authors appreciate this recommendation. However, it
is not useful to add this reference without providing
additional guidance on how to use such methods. This isbeyond the scope of the current revision. Authors believe
revised text does not preclude use of such advanced
methods even though it is not referenced here.

Accepted with
Modification
Accepted

Accepted

Comment
VolumeID

Chapter

6568

4

3

1347

1347

Much of the initial information used is cited, but it is not the case of MERIS and Landsat.
Including this information could be useful for the reader.

United Kingdom (of GreatBritain and Northern
Rejected
Ireland)

6570

4

3

1347

1347

Examples are limited to optical products. It would have been interesting to include
examples of use of LiDAR and RADAR products

United Kingdom (of Great
Accepted with
Britain and Northern
Modification
Ireland)

9364

4

3

1462

1465

While well written, this section contains a lot of basic information about remote sensing(textbook-like). Suggest to replace with references to textbooks

CanadaRejected

1548

Millions of points in what area? Generally we state points per square meter (i.e. 2 pts per
square meter will result in a 1 m spatial resolution grid). Lidar data points should be
Canadarepresented as points per area, not as a total.

Accepted

1577

GCP's are important for all data. what do GCP's have to do with time series data
specifically? Clarify how to keep GCPs " consistent through time" as well as how to"improve them over time".

CanadaAccepted

1591

different sensors will use slightly different wavelengths as well. e.g. see the difference
between the wavelengths in Landsat7 and Landsat 8 even for the same "name" band. L7
Canadared = 0.63-0.69 nm; L8 red = 0.636 - 0.673 nm. Add something about this issue as it willaffect time series analysis.

Accepted

1631

Nowadays most classification is not always done in an "image processing package". Most
people are using home-grown techniques (e.g. process the imagery in a software
package and then to image classification in R, matlab, or using TensorFlow). This is
Canadabecause the world of "classification" is exploding for all sectors, not just image
classification. Delete "most image processing packages include several algorithms forimage classification".

Accepted

We need sharper and higher resolution figure (Figure 3.A.5.1 ).

Accepted

9366

9368

9370

9372

6930

7150

4

4

4

4

4

4

3

3

3

3

3

4

From line

1548

1577

1587

1631

1794

72

To line

1794

79

Comment

Species composition can have an effect on the productivity, biomass and soil organic
matter and carbon stocks, especially in tropical forest on poor soils

Country

Republic of Korea

NorwayResponse

Noted

Author's Note
This table shows a few examples of global land coverdatasets. Landsat global datasets are already included inthis table. The intent here is not to list all sensors instead
the focus here is to provide a list of existing global land
cover products that can help countries if they don't havenational datasets.
Radar based global land cover datasets are included in thistable. There are no lidar based global land cover datasets
which we can be included here. The intent here is not to list
all products as mentioned above.
We assume this comment applies to the entire section (notjust lines 1462-1465 as noted here). While this is basic
info, in this section, we have highlighted information
relevant to compilers of national inventories which theauthors believe is useful in selecting suitable remotesensing products for carbon accounting. This text was
modified in response to earlier comments and suggestions
for improvements from the First Order Draft (FOD) review.
Replaced "millions" with "stream".
New text added to clarify the point - "For example, whenusing Landsat data from the USGS, it is important to use
data from the same collection and tier for the entire timeseries."Updated text: Overlap techniques can be used when a newhigher resolution sensor data becomes available in recent
years but such data are not available in the past. In suchcases, data from old and new sensors can be compared forat least one year (preferably more) to establish a consistent
relationship between the two products which could takecare of spectral bandwidth differences and calibration
variations. This technique can be used, for example, toconstruct a consistent time-series using historic Landsat
sensors and the more recent Sentinel-2 sensors (Zhang etal, 2018).

Deleted sentence as suggested.

Figure 3.A.5.1 has been replaced with a higher resolution
image reproduced at 600 dpi. Also added new text to
explain how this figure is derived.
We address the possible influence of tree species
composition on forest management effect in the new
guidance for Tier 2 stock change factors in Box 4.3.A. We
do not have the similar degree of detail in this introductory
section that remains as it was in the 2006 guidelines except
one correction.

Comment
VolumeID

Chapter

7160

4

4

76

77

7154

4

4

101

102

7152

7324

7148

7326

9374

4

4

4

4

4

4

4

4

4

4

From line

102

163

165

202

205

To lineComment

Country

It is written that "... soil organic matter tends to concentrate in the upper soil horizons, withroughly half of SOC in the upper 30 cm". However, to same extent, the existence of soil
Norwaycarbon can prolong to a depth of 1-2m (Kirschbaum 2000). Limiting to ploughing depth(3o cm) may be applicable for cropland and grassland, but it might underestimate theamount of soil carbon in forest land.
Besides, forest land classes can be stratified according to level of disturbance. For
example, intermediate level of disturbance hypothesis assumes that species diversity is
Norwayhigh at the intermediate level of disturbance. Moreover, some studies show a unimodal
relationships.

Response

Author's Note

Accepted

We modified the text accordingly.

Accepted with
Modification

We added "for Tier 1" to the original sentence and added asentence "Further stratification may be useful fordevelopment of Tier 2 or 3 methodology for a country".

102

Soil can be classified based on national and international systems of classification. For
consistency, standard ways of classification system might be applicable, ex. FAO system Norway
of classification.

Noted

164

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Rejected

199

Both mineral and organic soils can be influenced by aspect and position of landscape that
can have a direct effect on rates of soil erosion and accumulation. These are most likely
Norwayrelated to status of soil fertility and productivity. Moreover, the response of landscapes
position to CO2 emission is different.

203

250

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

The entire box is an in-depth literature review; while this review may be of interest to avery small subset of specialized scientists, it is not required in this guidance. Re-write a
simpler, condensed version with clear and concrete conclusions.

Spain

Spain

CanadaNoted

Rejected

Rejected

Guidance aims to allow inventory compilers to select theclassification that produces the most accurate results
although existing systems of classification are a good
resource and essential for data compilation from several
countries.
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

More guidance on soil erosion and deposition can be foundin Box 2.2D Chapter 2. Factors mentioned in the commentin total can be addressed best with Tier 3 methods forwhich more detailed guidance is given in Chapter 2.
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Scientific findings do not allow for clear and concreteconclusions on the effect of forest management on soil
carbon stock change. Considerable effort was made toprovide at least some quantification for forest management
impacts but results of analyses were in part contradictory
as described in Box 4.3A and treatment of controls
challenging for developing default stock change factors orproviding clear conclusions. The box is supplementary
information and not required 'reading' for a compiler to
conduct inventory. Yet, it does provide information andreferences to be used as a starting point for developing
Tier 2 factors as well as to point out some challenges one
would need to be aware. Therefore, the authors havedecided to leave this supplementary information forcompilers who decide to develop higher tier methods.

Comment
VolumeID7164

4

Chapter

4

From line

206

To lineComment

239

Besides, techniques of harvesting (traditional vs heavy vehicles), size of harvested forest
and age of harvested stands can be used as evaluating parameters. Harvestingmachineries can affect soil bio-physio-chemical properties, for example., structural
disturbance due to compaction and this leads to increase runoff and erosion. The effect ismost likely site dependent. Moreover, a study by Yuan in 2014 showed that rate of
Norwaycarbon sequestration by invasive species in the 1 meter soil profile was by far higher thanin the native plant marshes. Thus, carbon sinks should be associated with properties ofthe dominated plant species. Some invasive species have an allelopathy effect which canhave effect on species diversity composition and productivity. Productivity and soil carbon
stocks are most likely positively related.

7328

4

4

287

288

9376

4

4

334

334

7162

4

4

353

354

7158

4

4

358

358

7330

7332

4

4

4

4

414

492

415

493

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Country

Spain“Metsäranta et al. 2017” should be “Metsaranta”.
CanadaForest land conversions can also modify or reduce carbon storage of mineral soils. Thesemight increase the rate of mineralization because of exposure different atmosphericconditions, temp., rainfall, etc. Since change rate of SOC increase with temperature andNorwayrainfall. Moreover, the amount of soil loss per unit area, example estimated by the
Universal Soil Loss Equation (USLE) model, can be changed because of change in
vegetation cover (C) and management factor (P).
"Conversion from cropland will tend to decrease emission". Does this assumption
consider rice farming as well, paddy field? This is related to drainage status. Besides, it
Norwaydepends on frequency of farming, fallowing period/ no-till farming, rainfall, etc.

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Spain

Spain

Response

Author's Note

Noted

Countries may develop their own Tier 2 or Tier 3
methodology to take into account the effect of different
harvesting regimes, including the effect of different
machinery, but at the moment there is no meta-analyses orreviews to quantify the effect of machinery on change insoil carbon stocks and we could not accommodate this levelof detail in this one-page box. Effect of species in relation
to the effect of forest management regimes or practices isbriefly discussed in Box 4.3A in question but it is alsostressed that the apparent effect of tree species is often
confounded by other variables - which makes it difficult to
add something definite and detailed on this topic.

Rejected

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Accepted

Corrected.

Noted

This kind of level of detail can be addressed best with Tier
3 methods for which more detailed guidance is given in
Chapter 2.

Noted

Rejected

Rejected

This kind of level of detail can be addressed best with Tier
3 methods for which more detailed guidance is given in
Chapter 2.
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Comment
Volume
ID

7334

9378

9380

4910

4

4

4

4

Chapter

4

4

4

4

From line

533

552

To line534

593This guidance is likely only applicable to Tier 3 models: simplify and make it more generic
Canadafor all types of interpolation.

618

When updating table 4.4, beware that the current version contains two problematic points:
1) The values from Mokany et al (2006) for tropical moist forest are not specific to"deciduous" forests so the term "deciduous" should be deleted.
France2) The values from Mokany cover 3 continents, are more recent and based on a larger
dataset than the older Fittkau and Klinge (1973). The Fittkau and Klinge (1973) reference
should be dropped and the Mokany et al (2006) values should be preferred for all tropicalrainforests.

619

4

641

642

4722

4

4

662

664

4724

4

4

1143

1143

5866

4

5

152

152

5

Spain

615

4

4

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Country

Box 4.3B: First paragraph: they refer to Volume 4, Chapter 2.3 for a case in which thestock difference method is applied to construct a consistent time series between 1990
and 2015, but section 2.3 does not exist. Second paragraph: an additional explanation
should be added to understand how historical GHG emissions can be extrapolated
through “functional relationships”.

6928

6572

Comment

226

226

Country-specific emission factor for LULUCF

CanadaRepublic of Korea

A "References" part of UPDATED1-TABLE 4.7
Japan
ABOVE-GROUND BIOMASS IN NATURAL FORESTS [TONNES D.M. HA-1] is missing.
The description should be as:
Sato, T. (2010) Stocks of coarse woody debris in old-growth lucidophyllous forests inJapansouthwestern Japan. J For Res 15, 404-410 https://doi.org/10.1007/s10310-010-0198-5
The explanation on how to calculate harvest area is not clear. Are the units for rotation
United States of America
length in days? It would be useful to clarify.

Response

Rejected

Author's Note
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Noted

Generic guidance is provided in Chapter 5, Volume 1 as
explained in this section, therefore it is not necessary toinclude generic guidance here. However, this section will befurther refined.

Noted

In Chapter 2, there is an error in the section numbering.
Section 2.3 exists, but it is errorneously numbered as
Section 2.2. The numbering in Chapter 2 will be corrected,
so the cross-reference here can remain unchanged.

Rejected

The original data from the Mokany et al. paper was used toreclassify estimates according to the new Table 4.4.

Noted

Thank you for the comment. The authors will review thetable to ensure the estimates are consistent with theavailable data. If additional data is available, since lastcompilation, it will be incorporated into the estimates.

Accepted

Rodel will add references to the bottom of the Table.

AcceptedThank you for the comment. The complete reference has
been added.

Accepted

Clarification on units has been made.

Some of the suggested default values seem surprising (e.g. the maturity cycle of only 20 United Kingdom (of Great
Accepted withyears for Olive trees). Besides, the reference from which it comes from, Canaveira et al., Britain and Northern
Modification
2018, is missing in the bibliography.
Ireland)

Table were compiled by experts from peer-reviewed studies
that are publicly available. All citations and references havebeen checked and revised where necessary. The estimatesfor Olive groves in the Mediterranean Basin, where harvestof olives starts after 10 yr. and at 20 years trees are in fullproduction. correspond to the report Canaveira, P., Manso,
S., Pellis, G., Perugini, L., De Angelis, P., Neves, R.,
Papale, D., Paulino, J.,
Pereira, T., Pina, A., Pita, G., Santos, E., ScarasciaMugnozza, G., Domingos, T., and Chiti, T. (2018).
Biomass Data on Cropland and Grassland in the
Mediterranean Region. Final Report for Action A4 of
Project MediNet. http://www.lifemedinet.com/.

Comment
VolumeID

Chapter

From line

To lineComment

Country

Response

Author's Note

Accepted

We have changed to defining as steady-state method. Notethat the method has been moved to Cropland Remaining
Cropland based on other comments.

5868

4

5

342

342

In chapter 2 this alternative Tier 2 approach is also called “Tier 2-Approach 2”. By clearlystating that this is an alternative Tier 2 approach as is done by stating that this is a “Tier
2-Approach 2 “, I believe it will be clearer to inventory compilers and make it distinct from
United States of America
the single Tier 2 approach in the 2006 Guidelines. Across Volume IV, the terminology
used in Chapter 2 to describe the Three-Pool State-State C Model should be harmonized
and consistent with the associated text in the cropland and grassland chapters.

4726

4

5

350

350

References are oldJapan

Accepted with
Modification

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Spain

Rejected

7350

4

5

365

367

5870

4

5

394

394

9382

4

5

394

395

5872

7352

4

4

5

5

399

431

400

433

7372

4

5

525

533

5874

4

5

527

527

Page 5.19, Table 5.5: For the table title it would be useful to mention that these are
United States of America“Carbon” stock change factors.
Table 5.5. It is surprising that the tillage factor was larger for the moist cool temperate
climate zone than the dry cool temperate climate zone. It is the experience of someresearchers that tillage strongly interacts with other soil and management factors in thecool moist temperate regions and that zero till does not necessarily have a positive impact Canada
on carbon stocks. Could there be other factors that are driving these results, particularly
type of tillage, soil texture, depth of analysis or presence of drainage that have resulted inthese strong differences between wet and dry climates.
For the most part, I think the revised factors properly represent the accumulated evidence
published since the 2006 guidelines were derived. However, the factor for tropical dry
under annual cropping (1.02) does not appear to make sense as this implies thatconversion from the native condition is likely to result in a small amount of C storage. For
dry systems converted to cropping, are there any assumptions regarding irrigation? If it isUnited States of America
assumed that these systems are irrigated, then some C storage would make sense
because inputs would be higher. But increased inputs due to irrigation and other factors
are included separately. My only other concern is that some of the factors for reduced
tillage are lower than for full tillage implying that conversion to reduced tillage is likely toresult in a small loss of C. This seems counter-intuitive, and justification should be
mentioned in the text.

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Spain

as mentioned in comments to chapter 2, we don't think three-pool steady state C model isa tier 2 model. ACTION: delete method from tier 2. Move it to tier 3 guidance or to anSpainannex.
Should the reference to “Equation 5.1” be “Equation 5.0A” which is the number of theUnited States of America
equation starting on line 529

This general reference added to Ch.2 section 2.2.3.1
under Tier 3
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Accepted

Noted

The new factors are based on many more studies and so
can be considered more representative of the impacts.

Noted

Good points that value would be expected to be <1. This is
the case after additional quality control that uncovered anerror in the initial model fit, which did not include a modelintercept. This had created an error in the model that led toa high value for tropical dry systems. The data werereanalysed and determined that 0.92 was representative ofthe loss of C with long term cultivation in tropical dry
climates.

Rejected

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Rejected

We provided a box providing rationale for it inclusion as
Tier 2.

Acceptedchanged to reference equation 5.0A

Comment
VolumeID

Chapter

8326

5

7354

7374

7356

7358

7360

4

4

4

4

4

4

5

5

5

5

5

From line

561

575

656

919

936

1011

To lineComment

Country

Response

564

Tillage management data are complex and not available in many developing countries,
therefor, there is a need for a specific instruction and format for data collection andprovision

Iran

Noted

577

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Spain

Rejected658

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

923

as mentioned in comments to chapter 2, we don't think three-pool steady state C model isa tier 2 model. ACTION: delete method from tier 2. Move it to tier 3 guidance or to anSpainannex.

Accepted with
Modification

938

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Rejected1013

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Spain

Spain

Spain

Rejected

Rejected

Author's Note
Agree that there are challenges to compiling activity dataon tillage. However, the mechanisms for collecting suchdata will differ among countries so it is not feasible toprovide guidance for providing this specific activity data.
Vol 1 of Guidelines provides guidance on data collectionthat can provide guidance for tillage data collection.
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Note that the method has been moved to Cropland
Remaining Cropland based on other comments, and more
information is provided about the rationale for including thisoption in Tier 2.
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Comment
Volume
ID

7362

7364

1814

1816

4

4

4

4

Chapter

5

5

5

5

From line

1071

1151

1176

1232

To line1073

Comment

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Country

Spain

1153

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

1181

The CH4 emission from rice cultivation should include that the rice growing and nongrowing seasons. It is not clear whether CH4 emissions from the rice paddy during thenon-growing season (e.g. CH4 emission from winter rice paddy during a fallow period) are
included in the calculation. It is suggested to reformulate “……Nouchi et al., 1990）……
before and during cultivation period,……)” as “……Nouchi et al., 1990) and ebullition (SchChina
ütz et al., 1989; Wassmann et al., 1996). The annual amount of CH4 emission from ricecultivation includes the CH4 emissions during the period of rice growing and the flooded
fallow period preparing for rice planting. The amount of CH4 emitted from a given area ofrice is a function of duration of crops grown, water regimes before and during cultivation
period,……”.

1247

Equation 5.2 shows the way to scale the default emission factor EFc with the scaling
factors of SFw , SFp , SFo and SFs,r, which stands for the impacts of water regime(during and before the rice cultivation, SFw and SFp), organic matter application (SFo)and soil text and rice cultivar (SFs,r), respectively. The EFc is, herein, defined as themethane emission from a field with no pre-season flooding for less than 180 days prior torice cultivation (SFp=1) and continuously flooded fields (SFw=1) without organic
amendments (SFo=1). It is not clear with what soil texture and/or rice cultivar the EFc willbe 1. In this situation, the SFs,r is impossible to evaluate even if we had sufficient data of
the impacts of soil texture and rice cultivar on methane emissions.
China
Recommended revision):
Option 1：Remove SFs,r from Equation 5.2.
Option 2：Make SFs,r into two scaling factors: SFs for soil texture and SFr for ricecultivar, as already stated afterwards (Line 1353-1357) in the GUIDE.
SFs = 0.325+0.0225×Sand，where Sand(%) is the percentage content of sandcomponent in the paddy soil. When Sand=30(%)，SFs=1. According to a comparison
study (Huang et al., 1997), SFr had the value of 1 for the majority of rice cultivars whilesome might have higher values up to 1.5.

Spain

Response

Rejected

Rejected

Author's Note
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Noted

Noted, but this comment is out of scope of this refinement
work mandated by the IPCC.

Accepted with
Modification

Option 2 is a better option since it has been known that soil
type and rice cultivar influence methane emission. We havesubdivided the SFs,r term into two separate scaling factors
as suggested. However, since there is still limited data
addressing these impacts for the 2019 Refinement, theAuthors decided to not provide default values. Large
variations still exist in the limited amount of data for theeffect soil and rice cultivar on methane emission. However,compilers have the option to develop country-specificscaling factors if they have the emission data for different
soil types and rice cultivars that can be used to derive SFs
and SFr, respectively (as in the case of Huang et al., 1997;
Huang et al. 1998). Providing both terms in the equation
will make it more transparent that compilers can derivefactors for both scaling factors as a Tier 2 method.

Comment
VolumeID

Chapter

From line

To lineComment

Country

Response

Author's Note

Rejected

The effects of N application on methane emissions arecomplex and not yet conclusive as reviewed by Xie et al.
(2010); Cai et al. (2010; and Corton et al. (2000).

1818

4

5

1298

1298

Ammonium nitrogen, which is derived directly from the composition of the fertilizer or fromthe hydrolysis of urea applied to the rice paddy, reduces CH4 emission by promoting theoxidation of newly produced methane in the flooded rice paddy soils. This is an important
finding about CH4 emission from the rice paddy in recent years, which should be included
Chinain the methodology report. Therefore, it is suggested to add “In particular, recent studies
also find that widespread application of urea or ammonium nitrogen fertilizer to ricecultivation also alters CH4 emission from the rice paddy.” (Bodelier et al., 2000; Dong etal., 2011; Xie et al., 2010; Yao et al., 2012) before “Inventory agencies …”.

4728

4

5

1391

1396

Brackets are misplaced or mistaken in directions.

Japan

Accepted

1820

4

5

1457

1457

Considering the latest progress in uncertainty assessment, it is suggested to modify thissection appropriately. For example: Zhang et al.(2014, 2017)

China

Accepted

6574

4

5

1662

1663

Reference seems not to be cited anywhere?

4730

4

5

1744

1852

4732

4

5

3210

3215

Directions of the brackets are wrong.
The mixed model is the statistical model that has both random and fixed effects, but notclear which were random or fixed.
Equation 5A.2.1 is inconsistent in units and confusing. The general linear model shouldJapantake form of Y=XB + Error, where X is the matrix of the variables, B is that for coefficientsof each variable. Please rewrite. Or if this is not the model for prediction, consider todelete the equation to avoid confusion.

United Kingdom (of Great
Noted
Britain and NorthernJapan
Accepted

Accepted

4734

4

5

3219

3219

CONSTANT in Equation 5A.2.1 looks like a y-intercept and "A" is a coefficient forcovariate LN(SOC).

4736

4

5

3232

3234

It is not clear why pH should be treated as a categorical variable even though it is acontinuous variable.

Japan

Noted

4738

4

5

3254

3254

Not clear about the unit consistency of Equation 5A.2.2. Please present units for all
variables for the equation.

Japan

Accepted

9548

7366

4

4

5

6

Japan

Accepted

Table 5-5Errors associated with the IPCC default factors for land use (FLU), tillage (FMG), andinput (FI), are provided in Table 5.5. Through references are provided, it’s unclear how
errors are calculated; most of these errors are so small (from ±3% to ±7% for Tillage, andCanadafrom ±10% to ±13% for Input – all regions but tropical montane). These errors are so
optimistic, and if so how low would errors be when countries use Tier 2 or Tier 3 C
factors?

91

as mentioned in comments to chapter 2, we don't think three-pool steady state C model isa tier 2 model. ACTION: delete method from tier 2. Move it to tier 3 guidance or to anSpainannex.

96

Corrected
In Section 5.5.5, the following sentence was added in thefirst paragraph "Reducing the total uncertainty in thenational methane inventory depends on a better
understanding of both the complexity of the mechanismsthat lead to methanogenesis and also the spatial correlationof the factors that influence methane emissions from ricepaddies (Zhang et al. 2017).
Will be checked and deleted if necessary.

Authors identified and explained parameters that are fixed
and random.

Authors have now defined clearly the variables in Equation
5.A.2.1 of the Annex 5A.2 (e.g. separating parameter SOC
with constant A, etc.).
pH is indeed a continuous variable but the effect is not
linear. Optimum soil pH (5.0-5.5) was observed for CH4
emission, and leads to a critical threshold for estimating
emissions in the model. To capture this, pH has been usedin this model as a categorical variable.
Units and equations were corrected (Eq. 5A.2.1 and
5A.2.2) to be consistent with the rest of the text.

Noted

These errors are provided in the 2006 Guidelines, and thisTable 5.5 in the 2019 Refinement is its updated version
derived in a consistent manner with the 2006 Guidelines. In
the final draft a list of sources of data will be included formore transparency.

Accepted with
Modification

Information justifying the classification of the steady statemodelling approach at the Tier 2 level has been added.
Values are provided for all model parameters in Table 2.3C.
Note that the method has been moved to Cropland
Remaining Croplands based on other comments.

Comment
Volume
ID

7368

7370

7380

7382

7384

7386

7388

4

4

4

4

4

4

4

Chapter

6

6

6

6

6

6

6

From line

113

151

153

177

290

375

480

To line

116

151

153

179

292

377

483

Comment

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

CountrySpain

it is mentioned that reference C stocks should be consistent across the land uses. Not
clear at all what this means. Consistency in sampling for its estimation? Consistency inSpainlaboratory protocols? Consistent in depth of the sample? ACTION: please, clarify further
or delete.
there will be cases where the land use has more impact on reference C stocks thanclimate zone or soil type. Why should the reference stock should be the same
Spainindependently of the land use? This deserves an explanation, or a deletion of theaffirmation in the text. ACTION: delete "therefore, the same reference... regardless of theland use."

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Spain

Spain

Spain

Spain

Response

Rejected

Accepted

Accepted with
Modification

Rejected

Rejected

Rejected

Rejected

Author's Note
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Good point. We removed sentences 151-153 regarding
reference C stock. Note similar sentences deleted to Ch 5
The impact of land use is estimated based n the land use
factor, and not the reference C stock. However, we do
accept that the sentence is confusing and not necessary inthis chapter since the concept is covered in Ch2. Note thechange to the same sentences in Ch.5
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Comment
VolumeID

7390

4

Chapter

6

From line

558

To line

561

7392

4

6

629

632

6300

4

7

18

18

6302

4

7

59

59

6304

4

7

73

73

6306

4

7

94

94

6308

4

7

97

97

Comment

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

We can't accept references to 2013 WL supplement, as they are text that we are nothaving the opportunity to review. If no refinement is done in 2006GLs text, we would liketo keep the text as it is in the 2006 GLs, or, if text from 2013 WL supplement is going tobe the reference, we would like to have the chance to comment on in, and makecomments as appropriate. ACTION: delete any references to 2013 WL supplement.

Please correct capitalisation of A in land: "Land"
Unmanaged land converted to flooded land, previously "Land converted to flooded land"in FOD. Would it be better to replace "unmanaged land" with "Other Land", which is adefined land-use category in the 2006 IPCC Guidelines?

Country

Spain

Rejected

Spain

Rejected

Australia

Accepted

Australia

Table 7.9 CH4 Emissions for reservoirs > 20 years old … Do you mean "Emission Factors
Australia
for reservoirs" or "EF values for reservoirs"? Please correct spelling of "reservoirs".
FOD provided a refinement to the Introduction that included reference to the expanded
methodologies presented for flooded lands. This was removed in the SOD and leaves acontextual and informational gap. Please provide an appropriate expansion of theintroduction to address inclusion of the expanded advice on flooded land in thisrefinement.
Should this be "additional guidance" rather than just "guidance", with relevant
chap/section references? The main guidance on peatlands, for example, is provided in
Sect 7.2 of this chapter rather than the 2013 Wetlands Supplement (see remarks for line
196, below)

Response

Author's Note
Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Only the section on organic carbon in mineral soils was
identified for revision based on the approved Table ofContents by the IPCC panel. Organic soils were out of
scope and the 2013 Wetlands Supplement provides thelatest guidance associated with organic soils, which has
been reviewed and approved by the IPCC plenary.

Heading of Figure will be updated and new figure moved to
Accepted with Mod the "Introduction of Factoring out" in section 7.3 Flooded
Land
Accepted

Australia

Accepted

The expanded methodology will be introduced/explained
under Chapter 7.3 Flooded Land

Australia

Rejected

The original guidance in the 2006 GL is still relevant

NotedWill be taken into account together with other comments inrevising the draft.

Accepted

A text was added in the Annex.

9550

4

7

102

210

A lot of cross-referencing with Annex 7.1 was required to understand the guidance in themain chapter (e.g. to understand why and how downstream emissions were included).
CanadaTherefore, suggest including more background information in the introduction section ofthis chapter.

5876

4

7

105

106

A footnote to explain how altering sedimentation rates could result in altering the natural
flux of GHGs would be useful.

Rejected

There is a chapter describing CO2 emissions from Flooded
Land Remaining Flooded Land, although they are set tozero based on the managed land proxy, there are removals
that would occur on these lands if they remained
unmanaged. Therefore there are calculations for thiscategory when applying the factoring-out methods.

NotedWill be taken into account together with other comments inrevising the draft.

United States of America

5878

4

7

108

109

Page 7.7, Table 7.7: When describing the emissions from reservoirs it would be useful tostate that CO2 from reservoirs is only estimated for land converted to flooded land. One
United States of America
way to do this would be to split the final column in two with one column for flooded landremaining flooded land and the other column for land converted to flooded land and thenindicate for each flooded land type what emissions are estimated.

9552

4

7

113

121

To improve clarity, add text in this section to indicate in the beginning of the chapter thatLand converted to Flooded Land is for the first 20 years and Flooded Land remaining
Flooded Land is after 20 years.

CanadaComment
VolumeID

4740

4

Chapter

7

From line

114

To lineComment

Country

Response

Author's Note

117

The explanations of lines 114-117 and 302-308 are almost the same. The followings aresuggestion of the possible modification of this part.
- In lines 114-117, giving an explanation that CO2 emissions are considered separately
under Flooded land remaining Flooded land and Land converted to Flooded land first.
Then continuing explanations about remaining land and converted land. Also suggestingthat only brief introduction of no guidance of CO2 for remaining land with the explanationof the further guidance is provided in the other part here in lines 114 and 117. Theninserting the text that "see section 7.3.1.1 for further details.

Japan

Accepted

Text revised according to suggestion.

Accepted

Text modified accordingly

Acceptedchanged to "estimated" all over

5880

4

7

116

119

You only mention forest land and cropland, but it would also include grassland andsettlements. Rather than mentioning the specific sections where CO2 soil emissions are
United States of America
estimated for each land use, it may be preferable and shorter to say “…accounted forelsewhere (i.e., Volume IV Forest Lands, Croplands, Grasslands and Settlements)…”

4742

4

7

117

117

The word of "accounted"(or accounting) in the context of LULUCF has special meaning
historically. It is better to use "estimated" here.

120

After “CO2 emissions” suggest inserting “resulting from biomass, dead organic matter
and/or soil carbon that was present in the pre-flooded area”. Also should thedecomposition of organic matter from internal biomass production also be included here. United States of America
It’s important for the inventory compiler to know what should and shouldn’t be covered so
additional explanation is useful.

Accepted

Text modified accordingly

138

Add text in this section to indicate in the beginning that guidance is provided to estimatesCH4 emissions from both Land converted to Flooded Land is for the first 20 years andCanadaFlooded Land remaining Flooded Land is after 20 years.

Noted

Will be taken into account together with other comments inrevising the draft.

Accepted

We have included that drainage of ponds "Emissions ofCH4 from aquaculture ponds may be reduced as part ofaquaculture management, including mixing or aeration,
periodic drainage or when water is saline (Vasanth et al.,2016, Yang et al., 2017, Robb et al., 2017). "Accepted

We have added this reference

5882

9554

4744

4

4

4

7

7

7

120

123

124

138

5884

4

7

133

133

5886

4

7

143

143

5888

4

7

148

148

6784

4

7

161

165

4746

4

7

162

162

Japan

Drainage of a small pond/lake is undertaken as a part of management practice in order toimprove water quality. It is really welcome including some text that what effect isJapanconsidered in terms of GHG emissions due to this practice.
Very relevant citation for the effects of agriculture on GHGs: Tangen BA, Finocchiaro RG,
Gleason RA (2015) Effects of land use on greenhouse gas fluxes and soil properties ofUnited States of America
wetland catchments in the Prairie Pothole Region of North America. Science of the Total
Environment 533:391-409
Change sentence to “This guidance on Flooded Lands does not consider these emissions
United States of America…”
A subtitle to introduce the types of flooded lands included in this guidance would be
useful. Currently it goes from explaining the various gases covered directly into
United States of America
reservoirs, which is a little confusing.
Some researches show that in boreal and moderate temperate conditions zone the GHG
emissions from newly established water bodies returns to the natural levels that are
typical for the respective climatic zone within 2-4 years after establishment (Tremblay A.,
Varfalvy L., Roehm C. and Garneau M. (eds.). Greenhouse Gas Emissions: Fluxes andProcesses, Hydroelectric Reservoirs and Natural Environments. Environmental Science Russian Federation
Series, Springer, New York, 2005,732 p.). However, the method given in the SOD
proposes higher GHG emissions up to 20 years. It should be clearly stated in the text that
there are such studies and results that show much shorter period when the discharges
from the reservoirs of the boreal and temperate zones go into a natural state.
Based on the 2006GL, land conversion category is explained as remaining conversion
category for 20 years. Thus, "less than 20 years ago" is considered necessary to beJapanclearer sentence that 20 years is included in conversion category.

Accepted
Noted

A new decision tree will be added

Noted

While some boreal reservoirs have exhibited rapid
recovery, the temporal evolution used here is the result of
the modelling of reservoirs with a worldwide distribution. It
is important to note that the emission factors provided inTable 7.9 and 7.14 represent the integrated emissions
expressed as a 20 year average (see Annex 1 for details)
appropriate for each climate zone.

Accepted

Added text "less than and equal to"Comment
VolumeID

Chapter

6310

4

7

167

167

5890

4

7

171

171

5892

4

7

174

174

6312

4

7

179

179

5894

4

7

181

196

4748

4

7

196

196

6314

4

7

196

196

6316

4

7

199

199

5896

4

7

200

200

5898

4

7

204

204

4750

4

7

204

205

From line

To lineComment

Country

Can you please provide some comment in this section on how to differentiate between"Reservoirs" and "Other flooded land: constructed ponds etc"? For example, large
agricultural dams constructed for on-farm irrigation can fit into either definition. However Australia
the applicable EF values will be different depending on which land-use category is
chosen.
Change “exhibit” to “emit”
United States of America
After “…same for all age classes of other flooded lands” insert “(i.e., there is no distinction
between Land Converted to Flooded Land and Flooded Land Remaining Flooded Land)…” However, since that is unusual in comparison to other IPCC Guidance in the AFOLU United States of America
sector it also seems like you should state here which of these two categories these otherflooded lands should be reported in.
The guidance provided in the 2013 Wetland Supplement is currently voluntary undercurrent Annex 1 Party reporting requirements. Can you please clarify the status of any
Australia
reference to or text from the 2013 Wetlands Supplement that is included in the refinement
text? Such a clarification might be provided as a statement in the introduction.
In the prairie potholes, small wetlands are drained and consolidated into larger wetlands.
United States of America
Is there any accounting for the increase in size for consolidated wetlands?
It is considered the reference of "2013 wetlands supplement, chapter 2" is missing in therow of "Canals and drainage channels, ditches" in Table 7.8. CH4 emissions from ditches Japanin organic soil area is covered in the chapter 2 of the 2013 WLSL.
Table 7.8 lists Ramsar classes of human-made wetlands and proposes IPCC equivalents
and associated methodology. In Annex B: Ramsar classification system for wetland type
(Ramsar, 2009), peatlands are classified as either non-forested or forested peatlands
under Inland wetlands. Human-made wetlands are classified separately within Annex B
and include those created through excavation, e.g. gravel/brick/clay pits; borrow pits,
mining pools, but does not include peatlands managed for peat extraction. It therefore
appears that there is a misalignment between the Ramsar wetland class andAustralia
corresponding IPCC land-use category recorded in this table. Also, the main guidance on
peatlands "managed for peat extraction" is provided in Chap 7, Vol 4, 2006 IPCC
Guidelines, in the first instance. Chap 2, 2013 Wetland Supplement (Drained Inorganic
Soils), provides a new EF for CO2 for boreal and temperate peatland managed forextraction (Table 2.1) for on-site CO2 emissions from drained peat deposits and refers to
Vol 4, Chap 7 Wetlands for all other guidance and EF values regarding managed
peatlands.
Use of a decision tree is recommended in 2006 IPCC Guidelines, Vol1 Chap 4"Methodological Choice and Identification of Key Categories". Could you please provide
Australia
an appropriate decision tree (was present in FOD) in this section. Figure 7.2 may be abranch of the decision tree for the activities covered in this chapter.
Change “We provide guidance” to “ Guidance is provided”
United States of America
Delete “scientific evidence” and replace with “emission factors”. Delete “always” andreplace with “generally” because in some cases low-quality/biased country-specificUnited States of America
data/factors can be less accurate than the defaults
The sentence of "Country-specific scientific evidence and data are always preferable toTier.1 default data" is confusing. Does this mean countries should provide countryspecific evidence even when using Tier.1 default? If so, the requirement is considered
demanding in terms of general Tier.1 procedure. Could you rephrase the sentence? For Japan
example; "country-specific scientific evidence and data are preferable than Tier. 1 default
data" or "it is good practice to examine country-specific scientific evidence and data toconsider the appropriateness of Tier. 1 default data ".

Response

Author's Note

AcceptedA decision tree has been added (Fig 7.2) to provide thisguidance

Accepted
Inserted the suggested text as requested. We did not
Accepted with Mod prescribe in which category emissions should be reported
as this is dependent on activity data.

Rejected

This is a UNFCCC process and should not be discussed
here.

Noted

An expansion of flooded lands would increase theemissions in proportion to the area change

Accepted

Added reference to Table 7.8

Accepted

Text was modified considering that there is no equivalent in
Ramsar classification

Accepted

Decision trees for flooded land classification andmethodological guidance is now present.

Accepteddone

Accepteddone

Accepted

Comment
Volume
ID

6318

7686

7124

9384

9556

4

4

4

4

4

Chapter

7

7

7

7

7

From line

209

211

211

211

211

To lineCountry

Response

Australia

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
Accepted with Mod
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

Finland

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
Accepted with Mod
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

Please make sure that valuable information from Figure 7.2 in the FOD is covered by themuch simpler Figure 7.2. in the SOD. It is, important that information is not lost in the new Norway
Figure 7.2.

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
Accepted with Mod
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

290

Although the IPCC prescribed authors to provide guidance on estimating "net" emissions,guidance to factor out pre-flooding emissions and removals should not be provided as an
Canadaexample applicable to national inventories. Re-write sentence starting on line 220 as"However, this box provides an overview of an approach that could be used to factor out
these emissions and removals..."Accepted with
Modification

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

290

This box is presented as additional information, but situated within the guidelines it could
be perceived as IPCC guidance. Factoring-out is an accounting approach rather than an
inventory approach. Many of the statements in the text are not backed up by scientificevidence. For example, there are no citations to support the claims that net CO2
emissions and removals from most land categories should be near zero or that it’s only
necessary to factor out CH4 emissions from wetlands. The text is biased towards
factoring out CH4 emissions from unmanaged wetland pre-flooding but not accounting for
Canadathe loss of carbon sequestration in the pre-flooded landscape.
Therefore, recommend deleting this box to not make a precedent for including accounting
approaches in IPCC methodological guidelines for GHG inventories and jeopardize thelegitimacy of the guidance contained in the rest of this chapter. In particular, delete thedecision tree, as it greatly resembles IPCC guidance. Instead this material could becontained in an external document that is referenced for those who are interested inconsidering factoring out in their accounting approaches.

Noted

See the authors' note above.

209

290

291

Comment

There is a statement on the managed land proxy and how it applies to wetlands in the
introduction to the 2013 IPCC Wetland Supplement. Can you please also cite thatstatement here?

Box 7.1 is not consistent with the managed land proxy; guidance on factoring out of
natural emissions is allowed/required for other land-use changes, PLEASE provide
justification why it is important for land converted to flooded land.

Author's NoteComment
VolumeID

Chapter

From line

To line

7684

4

7

214

216

6320

4

7

222

222

6322

4

7

226

226

9386

4

7

228

231

9388

4

7

232

253

9390

4

7

297

309

9392

4

7

299

308

4752

4

7

304

304

Comment

Country

The text that "if this land area is already managed land, these emissions will be includedin the inventory, and changes in the emissions will be captured by this guidance" isFinlandwrong. When managed land is converted to flooded land, all emissions from this land area
will be reported based on guidance to land converted to flooded land.

Should be Box 7.3.; Box 7.2 presents a discussion on "Additional information on
Australia
sedimentation and carbon burial in reservoirs".
Appendix 7.2 does not exist. Possibly Appendix 7.1.2?
Australia
That part of a reservoir should remain "unmanaged land" forever because it was already awater body prior to flooding is unrealistic and even absurd: once the area is flooded, theentire reservoir is involved in the new nutrient dynamics triggered by the flooding andtherefore becomes managed. In addition, as pointed out further in the chapter, emission
factors post-20 year would largely reflect the fate of a sustained carbon input either fromthe watershed or from large flooded C stocks (such as organic soils). In the 1st caseemissions are not related to the land status pre-flooding and in the 2nd one the emission
Canadafactors only represent the C input from the organic soils that were actually flooded: scaling
those emissions down by some area factor would actually under-estimate emissions
caused by flooding. Finally, even if pre-flooding emissions or removals from lakes were a
consideration, they should be dealt with when considering land converted to flooded land,
not flooded land remaining flooded land (especially the SOCj,k in equation 7.13): it makes
no sense to continue "discounting" such pre-flooding emissions or removals every year of
the time series for ever. Delete sentence.
Authors rightly point out that an assessment of the carbon balance of natural ecosystems
is highly linked to both temporal and spatial scales; however, there is no widely applicableevidence of the spatial and temporal scales at which "unmanaged land" has a balanced C
budget: such scales (if they exist) are likely to be very specific to combinations of timeintervals, ecosystems, landscapes and climates. Further, and unless authors provide
Canadaevidence to the contrary, there is no scientific basis for treating "unmanaged wetlands"
differently in this regard. It is strongly recommended to merge paragraph 2 and 3 of thebox into a single one; clarify that a T1 methodology should assume a balanced C budget
for all unmanaged land (consistent with the "managed land proxy") and that only T2 or T3
methods could credibly estimate pre-flooding C balance of an area of unmanaged land
over appropriate temporal and spatial scales.
Since emissions are now being discounted from flooded lands, would it not make sense toconsider the loss of wetland and the associated carbon sink as an emission in Flooded
Land remaining Flooded Land? It could be assumed that other upland ecosystems that
Canadawere flooded were net 0 emission sources, but if wetlands were flooded, this represents apermanent loss of a sink, which should automatically be included according to theapproach that is used throughout this chapter.
Include citations to the scientific literature that were used to justify the assumption that all
CO2 emissions from Flooded Land remaining Flooded Land are not attributable to the
Canadaflooding and are included in the estimation methodologies of other land categories.
The word of "accounted"(or accounting) in the context of LULUCF has special meaningJapanhistorically. It is better to use "estimated" here.

Response

Author's Note

Noted

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

Accepted
Accepted

Accepted with
Modification

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

Accepted with
Modification

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

Accepted

See '7.3.1.1CO2 EMISSIONS FROM FLOODED LANDREMAINING FLOODED LAND'

Accepted

Reference to Prairie et al 2017 inserted

Accepted

Changed to "estimated" all overComment
Volume
ID

6324

7688

9394

4

4

4

Chapter77

7

From line

318

318

318

To lineComment

319

Several reviews on wetland carbon kinetics conclude that established freshwater wetlands
are likely net carbon sinks (small), or neutral, due to primary productivity andsedimentation leading to burial of organic carbon under anaerobic conditions (seeKayranli et al., 2010, Mitsch, et al., 2013, Brix et al., 2001). Inundation of preimpoundment wetlands will destroy the primary productivity component and, althoughburial of allochthonous carbon through sedimentation is still possible, may convert the
impacted wetland area to a source. Inundation also removes any wetting/drying cycles
that have been demonstrated to significantly reduce CH4 emissions compared topermanently inundated lands (Altor and Mitsch, 2004). Therefore permanent inundation ofa wetland can modify its physical, hydrological and biogeochemical profile that results in achanged carbon emission/removal profile. Any such transition, which is the result of direct Australia
anthropogenic action, should record the entire area impacted in the activity data over atransition period (default for Tier 1 is 20 years). After the transition period the area offormer wetland is likely to have stabilised its biophysical properties so that the emission
factor values for that reservoir now apply to it. This is the case for reservoirs classified as
Flooded Land Remaining Flooded Land as they are more than 20 years old. Can you
please provide details of the explicit circumstances under which an adjustment to the total
flooded area of a reservoir (>20 years old) can be made? This impacts equation 7.10. It issuggested that a note be attached to Aflooded , j,I stating the explicit circumstances
under which it used in preference to Atotal , j,I, and under what circumstances Atotal , j,Ishould replace Aflooded , j,I .

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
Accepted with Mod
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

Factoring out is not consistent with the managed land proxy. If text kept, please change toread "can be adjusted for the area of unmanaged land prior to reservoir construction" Finland
otherwise emissions from managed land prior to the construction of the reservoir would
be subtracted twice"

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
Accepted with Mod
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

Remove text in the main guidance on how countries can factor out emissions, as that is
only relevant for accounting and not inventory estimation guidance. Information related to Canada
factoring out some pre-flooding emissions is already provided in box 7.1.

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

319

320

4754

4

7

323

323

7690

4

7

328

335

"less than 20 years old" should be modified to "less than and equal to 20 years old" (orother description that makes clear 20 years old is included in Land converted to Flooded
Lands category) in order to be consistent with the general definition of land conversion
category.
Unclear why newly flooded areas are included in the estimation of emissions fromreservoirs more than 20 years old -please explain or correct.

Country

Response

RejectedJapan

Accepted

FinlandAccepted

Author's Note

This term has been replaced.

Comment
VolumeID

Chapter

From line

To lineComment

Country

Response

Author's Note

6326

4

7

330

334

May need to adjust equation 7.10 and associated explanatory notation. See discussion
318-319

Australia

Noted

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

9396

4

7

334

334

Delete "that is newly" and replace with "area flooded for more than 20 years".

CanadaAccepted with
Modification

New text incorporated taking care of the comment. "Newly
flooded" is no longer in use

4756

4

7

340

340

Accepted

Done.

6328

4

7

346

347

Noted

Tier 2 factoring out approach allows for the use country
specific emission factors for natural waterbodies.

7692

4

7

355

361

Finland

Noted

Scaling by trophic status is a practical and achievableapproach at the Tier 2 level and is based on the science.

Australia

The methodology has been revised to improvetransparency by first providing guidance on estimating total
emissions from flooded land (consistent with the MLP) andthen how to factor out emissions from pre flooding sources,
Accepted with Mod
as requested in the mandate provided by the IPCC Plenary(to “develop consistent methodologies that take into
account factoring out of emissions and removals that would
otherwise occur in the absence of the flooded area”).

Why would factoring out be acceptable for reservoirs but with no guidance for other land
categories and sectors? The text indicating that countries can factor out emissions andCanadaremovals should be deleted as it’s misleading guidance suggesting it’s ok to factor out
emissions and removals in inventories. This is not consistent with the inventory approachas it’s introducing accounting constructs.

The mandate from IPCC plenary is to "Update CO2
emission factors for land converted to flooded land
(Wetlands) and to develop, on the basis of comprehensive
review of available literature, consistent methodologies thattake into account factoring out of emissions and removals
that would otherwise occur in the absence of the flooded
area for estimating CO2 and CH4 emissions from flooded
lands (both land converted to flooded land and flooded landremaining flooded land)." The new guidance is following
this principle.

6330

9398

4

4

7

7

362

362

362

363

"reservoir of this age class" is a little unclear. Does this mean "reservoir > 20 years old"Japanlike the other terms of this equation? If so, it is better to use the same text here as well.
Depending on circumstances, damming a natural water course may change its
hydrological character through substantial changes to water levels and/or water transition
times, and alter its emissive profile. It is therefore likely that individual assessments may Australia
need to on whether to include the natural water course area taken into the account. See
discussion 318-319.
Is this a pragmatic and implementable Tier 2 method?

The statement on factoring out may need to be qualified based on outcomes from thediscussion on box 7.1 and Annex 7.1

Rejected

Comment
VolumeID

Chapter

From line

To lineComment

Country

Response

Author's Note

Russian Federation

Noted

It is possible to implement such methods at Tier 3.

Rejected"Sluicing" is commonly used for this practice, sluicing
sediments through gates

Accepted

Reference added

Accepted

Reference to Annex 7.1.2.1 inserted and all the references
deleted. The table shows arithmetic means of model
outputs.

Rejected

It is true that the EF's in Table 7.9 are different from 2006
Guidelines. There has been a lot more observations anddata available since the 2006 Guidelines was written. This
has now been taken into account, hence EF's are different

It is declared in box 7.2 SOD, that sediments of reservoirs can depose carbon and lead tocarbon sink activity of reservoir. But the presence of set of factors does not establish
exact origin of carbon and to produce quantitative estimations of the process. In Russia
the big amount of data are collects for sedimentation, concentration and origin carbon in
sediments. The sedimentation and carbon accumulation is continued in reservoirs withage 70 years and more. The rate of carbon accumulation with sedimentation is 0.10-0.60
т C/ha/year (Butorin et al, 1975; Bikbulatova, 1993, Zakonov, 1994 and others). It is
recommended to change the text of box, to refer the quantitative estimations o carbon
removals due to sedimentation with possible presenting of table for different climate types(data in example of table is preliminary).
Table. Carbon removal with sedimentation win reservoirs of temperate climate.

8446

4

7

364

386

Trophic ClassCarbon removal, t C/ha/year
Oligotrophic0.018
Mesotrophic0.075
Eutrophic
0.3
Literature
Butorin N.V., Zimina N.A., Kurdin V.P. Sediments of reservoirs of Upper Volga.
Leningrad, Nauka, 1975. 159 P. (In Russian)Bikbulatova E.M. Assessment of rates of sedimentation of organic matter ofphytoplankton in Rybinskoe reservoir. In: Organic matter of sediments of Volga
reservoirs. Materials of I.D. Papanin’s Institute of biology of inland water. Issue 66, SanctPetersburg, Gidrometeoizdat, 1993. P. 16-23.

9400

4

7

377

377

6332

4

7

397

397

6334

4

7

443

443

6336

4

7

443

443

Zakonov V.C. Accumulation of biogenic elements in sediments of Volga reservoirs
In: Organic matter of sediments of Volga reservoirs. Materials of I.D. Papanin’s Institute of
biology of inland water Issue 66 Sanct-Petersburg Gidrometeoizdat 1993 P 3-15 (InThe word ‘sluicing’ may be a typo. Please define otherwise.
CanadaReference "UNESCO/IHA 2010", not in bibliography, assumed to be "GHG Measurement
Guidelines for Freshwater Reservoirs". It would be useful to have a summary of theAustralia
guidance provided in UNESCO/IHA 2010.
Table 7.9 It is stated that the emission factor values are prepared by empirical modelling(line 421). If so then the references, which provide the raw data, should be removed from
Australia
the table footnotes and replaced with a single reference that fully describes the work todevelop the EF values. Also, is the "average value" an arithmetic mean or geometricmean, given that the data summary (Figure A3) consists of log transformed data?
Please review apparent inconsistencies between derived EF values recorded in Table 7.9.
In the draft table, the CH4 EF values for reservoirs in dry zones have greater CH4
emissive potential relative to wet zone reservoirs in both tropical and warm temperate
climate regions. This is inconsistent with the trend in CH4 EF values previously recordedin the 2006 IPCC guidance; specifically Vol 4, Table 3A.2. It also runs counter to theAustralia
observed soil organic carbon content, which is generally greater in moist/wet zones
compared to dry zones in any climate region (e.g. see Table 5.2 in the 2013 Wetlands
Supplement). A similar trend reversal also occurs with respect to temperature in thistable, wherein the warm temperate/dry EF has a greater value than that of the tropicalmoist/wet EF. This is also counter to the trend recorded in the 2006 IPCC guidance, Vol
4, Table 3A.2.

Comment
VolumeID

Chapter

From line

To line

6338

4

7

443

443

6340

4

7

443

443

6366

4

7

443

443

6376

4

7

443

443

Comment

Country

The calculations and assumptions underpinning the empirical modelling approach (using
the G-Res tool) are not provided in any detail in the G-Res technical document, so thatthe validity of the modelled EF values cannot be tested statistically against the fieldmeasurements.Are the data sets used in establishing the models and deriving the EF
values available for study or use? Is there further documentation, beyond the G-Res tooltechnical documentation, that explicitly explains all aspects of the modelling processes
used to develop the G-Res tool and the derived EF values? Some of the modelled EF
values in Table 7.9 are inconsistent with those reported previously in the 2006 IPCC
guidance and 2013 wetlands supplement, both in absolute terms and in relative terms
regarding climate zones. Figure A3 is therefore briefly reviewed here as it is assumed tosummarise both the model outputs directly relevant to Table 7.9, and the fieldmeasurements on which the modelling is based. Figure A3 comprises box plots of log
transformed data for both model outputs and field measurements. The extended lower
whisker, non-central position of the median within each box, and non-equivalence of the Australia
median with the arithmetic mean reported in Table 7.9, indicate skewed distributions foreach data set. It is therefore probably not correct to classify all of the "filled circles" asoutliers. Seven to eight percent of regular data may be expected to exceed the upperbound of a box distribution when data is skewed. Were any/all of the "outliers" excluded
from estimates of the EF values? The distribution of modelled EF values is significantly
constrained relative to that of the measured data for each of the climate zones. In almost
all cases the modelled median value exceeds that of the field measurement values,
except for the Boreal (almost equal) and tropical wet (less than field measurement for thatclimate zone as well as the tropical dry climate zone). This last reversal in the tropics
accounts for the lower EF value recorded for tropical wet vs tropical dry. There is norecord for warm temperate dry field measurements in Figure A3 (it is noted as
unavailable), so a similar conclusion cannot be drawn regarding the warm temperate dry
and warm temperate moist climate zone EF values.
Do the EF values incorporate shallow (< 3m) and deep water emission data, or are they
based on shallow water emission data only? Sturm et al., 2014 demonstrate that, although
total CH4 emissions (diffusive + ebullitive) from deep waters in a stratified reservoir areless than those from shallow waters, they are still substantial. Development of scaling
factors (based on climate zones and edaphic factors, both of which are considered inAustralia
development of the G-Res model) to distinguish shallow and deep water emissions might
be considered at this time, with additional guidance provided on compiling areas for"shallow" and "deep" part of the reservoir. Sturm's work also suggests that employing
Aflooded , j,I in equation 7.10 will lead to an under-estimation of CH4 emissions from thereservoir surface.
Please review apparent inconsistencies between derived EF values recorded in Table 7.9.
If the available data do not comply with the principles established in the terms ofAustralia
reference, this table should be deleted.

Please remove the differentiations of factors by climate zone presented in Table 7.9 (andTable 7.14). The evidence provided in Figure A3 would seem to indicate that the averagerate of emissions from 'cool temperate'; 'tropical dry'; 'tropical wet'; and 'warm temperate
Australia
moist' are not significantly different from each other. Are you able to conduct such astatistical test to prove the contrary? If not, a single factor for all reservoirs should beapplied regardless of climatic zone.

Response

Author's Note

Noted

The G-res Technical document does provide acomprehensive compendium of the calculations andassumptions used in the G-res. More generally, Prairie etal. (2017a) describes the scientific basis of the overall
approach. Figure A3 is provided for transparency but itshould be noted that the model output and direct
measurements are not strictly comparable. These
differences and the rationale for using EF derived frommodel outputs are described in detail in Section A7.1.2.1 .
The overall validation of the approach is best illustrated in
Figure A4 where GHG emissions estimated from thetabulated climate-specific EFs (Table 7.9 and 7.14) arecompared with field measurements. No outliers were
removed in the estimation of the climate-specific EFs.

Noted

EF incorporate emissions both from shallow and deep
watersUnclear what this comment means, but it's probably
expressed in comment 6336. Please see answer to thiscomment
The apparent and real overlap in the model outputs andfield measurements (Figure A3) does not preclude the factthat that the mean climate-specific EFs are significantly
different from one another. In fact, such test formed thebasis of the aggregation of several climate zones (seeAccepted with Mod
Section 7.1.2.1, point 5). However, we agree that theconfidence intervals on the individual predictions reported
in Table 7.9 and 7.14 were misleading. We have now
modified the tables to report the mean EF and the CIs on
the mean (not the individual observations).
Rejected

Comment
VolumeID

Chapter

From line

To lineComment

United States of America

Noted

Russian Federation

Rejected

5900

4

7

443

444

Very odd that 'warm temperate/dry' has double emission than 'warm temperate/moist'.
This is counter-intuitive and may be due to insufficient data to characterize theseecosystems

6780

4

7

443

444

The proposed default emission factor for the boreal zone is too high. The much lower
estimates are published in the literature.

6782

8440

4

4

7

7

443

443

444

444

6342

4

7

447

447

9402

4

7

464

465

9404

4

7

471

487

9406

4

7

483

487

5902

4

7

486

487

Country

Within the one boreal zone there are big differences among countries and regions on theice period and period without ice during the year. We believe that it is important to take it
Russian Federation
into account in the 7.10. It should be more correct to give the coefficients not in kg CH4
per year, but in mg CH4 per day in order to allow each country to implement their national
data.
When the table 7.9 SOD was developed, the change of climate classification from
Koeppen to standard IPCC 2006 climate was performed. This change is relevant to makecalculations more consistent with other chapters. But values, presented for some climatic
zones, arise a questions. It is evident from table 7.3 FOD, that for boreal subzones (SnowFully Humid Warm Summer, Snow Fully Humid Dry Summer) typical values of CH4
emission are 3.7-5.0 kg/ha/year, but in table 7.9 SOD value for boreal climatic zone is
Russian Federation
13.6 kg/ha/year, this is overestimated value. Likely, the procedures to recalculate values
from Koeppen climate to standard IPCC was not completely adequate, it could not take
into account the areas of subzones, which were combined to generalized “boreal” zone. It
is necessary to make revision of this value, which likely could be in limits 3.7-5.0
kg/ha/year. Also the value 54 kg/ha/year for “cool temperate climate” is strange, because
in table7.3 FOD this value is 21.3 kg/ha/year.
Reservoirs are established across a diverse range of habitats and may be subject tosignificant shifts in regional/continental weather patterns that may last for a season, or up
to a decade or more. The default EF values represent a baseline that may not properlyreflect methane emissions as environmental/climate conditions change. Scaling factorsthat apply to specific environmental factors rather than regions provide an alternative
Australia
approach to significant resources required to develop regionally-specific EF values.
Available data (GRanD and empirical model databases) should be sufficient to develop
appropriate scaling factor values for T1 and T2 models. Could an approach using scaling
factors to adjust for changes in conditions be considered here? Also see the previous
discussion, line 174.
It doesn’t make sense why it is good practice to factor out CH4 emission from wastewater
treatment and discharge, when methods to factor out emissions and removals are not
Canadagenerally included in IPCC guidance for inventories. Suggest deleting or providing arational explanation.
Why wouldn't the eutrophication modifier to the EF, including default values, not beapplicable at the T2 level? It is suggested to use the same approach as in equation 7.14
Canada(T1 estimation of CH4 emissions from land converted to flooded land) and have α = 1 at
T1.
Many of the components of Table 7.11 are not explained in the main text or glossary (e.g.
CanadaSecchi depth). Provide explanations of what these values are.
The 'state adjustment factor' is based on relatively little data, but can have a huge impact
United States of America
on emissions estimates. I recommend using lowest values of the range to be conservative

Response

Author's Note
While this may be counter-intuitive, the values are theaverage of hundreds of systems to which the models wereapplied to. The resulting EF estimates are therefore morerobust than a few measurements of various temporal
coverage.
There must be a unit mistake. The public literaturesuggested by the reviewer and the proposed default
emission factor are at the same order of magnitude

Rejected

The Emission Factors are derived from models predicting
annualized values that have taken the reduced emissions
in the ice covered reservoirs .

Rejected

The values 3.7-5 from the FOD were medians, and notmeans, of measurements on a few reservoirs (total of 12).
Individual reservoirs varied between 0 and 76. Our value of
13.6 seems appropriate.

Noted

The provided EFs (table 7.9 and 7.14) are climate specific.
They are derived from the application of G-res to several
thousand reservoirs each with their own specificcharacteristics (see Annex 1 for details) and aggregatedper climate zone. Countries wishing to develop Tier2
country specific EFs could use a similar approach.

NotedEmissions from wastewater treatment are estimated inother chapters in line with the Managed Land Proxy

Accepted

Agreed, editorial mistake not to put this in Tier 2

Accepted

Glossary have been updated

Rejected

These coefficients are based on the best available data.
As such As such arbitrarily chosen low-end estimates would
be biased.

Comment
VolumeID

Chapter

8442

4

7

486

487

5904

4

7

492

498

From line

To lineComment

Country

Including of this table is very useful act because there is a lot of different classifications oftrophic classes. The recommendation is to add column “Nitrates”, because this is mostoften measured hydrochemical parameter (in Russia the registration of nitrates isperformed in 100% point of hydrochemical monitoring, otherwise “total phosphorus” ismeasured only in 5% points. The value can be next (follow classification of Kitaev, 1984).
Russian Federation
Trophic ClassNitrates, mg/L
Oligotrophic0-0.12
Mesotrophic0.12-0.24
Eutrophic
0.24-0.95
Hypereutrophic>0.95
This only describes how to obtain the total area of reservoirs. Given the equation alsoasks for the “area of land that is newly flooded as a result of reservoir construction,” itseems like some guidance should be provided on how to obtain/estimate that data. This
United States of America
is key because it responds directly to the mandate in the approved TOC regarding
factoring out emissions and removals that would otherwise occur in absence of theflooded area.
The Tier 3 description does not seem to deal with the activity data required to estimate
reservoir flooded land area, rather it provides further explanation of Tier 3 approaches,
which is discussion that relates to Choice of Method and should be included in the section
on page 7.15 Lines 393-415. The text that goes into Page 7.18, lines 510-517 should
United States of America
provide some explanation of the activity data required for measurement of modelling
approaches. Possibly a generic statement such as “Tier 3 approaches will likely require
more detailed activity data on for example climate and reservoir management, but theexact requirements will depend upon the model or measurement design.” (Please note
this is just example text that the authors should adapt to Tier 3 reservoir methods.)

Response

We looked for but could not find the Kitaev (1984)
Accepted with Mod reference given by the reviewer. Instead, we have added a
TN-based trophic status criterion to table 7.11.

Accepted with Mod Guidance now included in FD

5906

4

7

510

517

7694
7706

4
4

7
7

510
511

517
512

9408

4

7

519

528

6344

4

7

522

522

5908

4

7

523

525

Could this method also apply to ponds in settlement areas where they are quite common?
If so, then it would be useful to mention that specifically so inventory compilers will know United States of America
to include them in their estimates.

Accepted

528This sentence could confuse inventory compilers about the proper reporting of emissions
from drainage ditches used to drain organic soils in the forest land, cropland, grasslandand settlements land use categories which should be included with “Organic Soils” in theappropriate land use category. While the methods may be similar to what is being usedhere for other constructed water bodies, it would be inappropriate to include the emissions United States of America
from drained organic soils in the flooded lands category since the draining of the organicsoils converts them from wetlands to another other land use. In addition, the method
proposed here does not include the CO2-C emissions from drained organic soils, which
are included in the method described in the Wetlands Supplement.

Accepted

5910

4

7

525

Even for Tier 3 activity data on the areas are needed.
Finland
UNESCO reference is not included in the list of references, IHA 2010 is.
FinlandIs it possible for the authors to provide clear definitions of what constitutes an emitting
drainage ditch or canal, or even pond? Without clear guidance of what these “constructed
Canadawaterbodies” are it will be very difficult for compilers to quantify the total areas of thebodies in their countries and apply to appropriate emission factors. What about ditches
that only have water periodically? Clear descriptions are needed.
Is this chap 2, drained inland organic soils, specifically Section 2.2.2 and Annex 2A.2
Australia
Table 2A.1.?

Author's Note

Accepted

Added suggested text

Accepted
Accepted

The sentence was added
Same reference, ref.name will be corrected

Updated definitions of water bodies and corresponding
Accepted with Mod decision tree are included. Methods to identify areas ofwater bodies are included in methods for Activity data
Acceptedreference to correct section in the wetlands supplement isprovided. Section 2.2.2.1; Table 2.4
Yes. This includes ponds within settlements, however, notethat CH4 emissions associated with wastewater are
considered elsewhere (Volume 5, Chapter 6, 2019
Refinement).
Clarified the reporting of emissions from drainage ditches
on organic soils "For Managed Land categories on organicsoils Inventory inventory compilers may also choose to‘embed’ emissions from small channels such as drainage
ditches within their reporting of other Managed Landcategories (applying the methodology described here,
together with using Equation 2.6 of the 2013 Wetlands
Supplement for drained organic soils). The sameemissions should however not be included in Flooded
Lands both if they are included other Managed Landcategories. "Comment
VolumeID

Chapter

7696

7

4

From line

525

To line

527

6346

4

7

530

530

9410

4

7

542

548

6348

4

7

549

549

Comment

Country

Do both methods produce the same emissions - alternative methods should be reasoned,
Finlandwhy is the new method introduced?

There are currently insufficient data to derive EF values specific to various combinationsof climate zones, environmental factors and management practices experienced by "otherconstructed water bodies" for Tier 1 modelling. In addition, seasonal and inter-annual
variation in weather patterns (e.g. drought years vs flood years) may change the emissive
potential of water bodies between annual accounts. Could you please discuss theapplicability and development of scaling factors that adjust either the base-line EF values
provided in Table 7.12, or Equation 7.12 outputs, to account for conditions encountered inthat reporting year? Precedence is already established in this refinement in Section
7.3.2.1: CO2 emissions from land converted to flooded land. Table 7.13 provides scaling
factors to account for CO2 emissions or removals from newly flooded land in various
climate zones. Could you develop for this document one or more sets of scaling factors toAustralia
account for climate zones, soil type, and/or wetting/drying cycles for methane emissions
from "other constructed water bodies"? To illustrate the potential improvement this would
bring, in Australia many small farm dams undergo periods of drying due to low rainfall
and/or usage patterns. Work by Altor and Mitsch (2004) demonstrated that "intermittently
flooded wetland zones, when inundated, emitted significantly less methane thanpermanently inundated areas, (which) indicates a difference in soil conditions or microbialcommunity structure and dynamics between these areas." Therefore, an unmodified
equation for methane emissions (Equation 7.12), quantified by a generic methane EFvalue for ponds (Table 7.12) will not provide a reliable estimate of methane emissions
from that proportion of ponds that experienced one or more dry spells during the reporting
period.
From the explanation of variables it seems the equation is just for the total flux ofmethane from “ponds and channels”, but the section is for all other constructed
Canadawaterbodies. Clarify if the equation is just for ponds and channels (and if so why) or thewhole category.
Some practical considerations that impact the quality and therefore the materiality of theflooded land inventory item could be explored here. These include advise on how to (1)establish database of annual stocks of relevant categories of water bodies from 1987
onwards (establish a time series) (2) over the time series, estimate the period of time
during each year in which there is water in each water body, (3) the average area of water
Australia
during this period (unlikely to be 100% of the water body area), and (4) monitoring farmdams are less than a Landsat pixel in size (816 m2) in size, so how to monitor if remotesensing (Landsat) not reliable? Can you please discuss alternative strategies toestablishing a time series for areas of "Other constructed water bodies" where
documentation and/or remote imagery are insufficient?

Response

Author's Note

Accepted

We anticipate similar emissions. We have clarified that
equation 2.6 was for organic soils. "For Managed Landcategories on organic soils Inventory inventory compilers
may also choose to ‘embed’ emissions from small channels
such as drainage ditches within their reporting of other
Managed Land categories (applying the methodology
described here, together with using Equation 2.6 of the2013 Wetlands Supplement for drained organic soils). The
same emissions should however not be included in Flooded
Lands both if they are included other Managed Landcategories. "We have added guidance to say modifications due to interannual (and other variations) in inundation could beaccommodated at Tier 2 and Tier 3 level. Inter-annual
Accepted with Mod
variation in rainfall is likely to alter the area of the water infarm dams and thus variation would be accommodated inthe "A" term in Equation 7.12

Accepted

Changed to "other constructed water bodies"

Accepted

We have added guidance to address many of theseconcerns. Line 549 was the definition of term A in theequation. We have provided discussion around the area ofwaterbodies in Choice of Activity Data section. "TheRamsar Convention provides guidance on mapping of
wetlands (Annex III) which can be used to determine thearea of other Other constructive constructed water bodies.
The minimum recommended scale of mapping is 1:5000(50m x 50m or 0.25 ha) which could be used if appropriate
data are available, for example from Landsat remotelysensed imagery (Pekel et al., 2016) or other higher
resolution satellite imagery. "Comment
VolumeID

Chapter

From line

To lineComment

Country

Response

6350

4

7

558

558

Can you please comment on the possibility of development and use scaling factors foradjusting the total annual flux equation to take account of variations due to local
geography (soil type), weather patterns (drought and floods), usage/management
practices, all of which can contribute to variation in wetting/drying cycles of small
constructed water bodies?

9412

4

7

565

566

Clarify if the Tier 3 guidance is just for “constructed ponds and channels used for
agricultural purposes” (and if so why) or the whole other constructed waterbodies
category.

CanadaAccepted

582

This sentence should be deleted. Ditches used to drain organic soils are addressed in
the Wetlands Supplement and are not part of the flooded lands category, the exception
may be for peatlands.

United States of America

Rejected

589

Table 7.12 - saline ponds: Previous advice in the 2013 wetlands supplement (Table 4.14)
assumes that the Tier 1 default CH4 emissions are zero for water with salinity greater
Australia
than 18ppt. Has this advice changed or are there other factors that need to beconsidered?

5912

6352

4

4

7

7

581

589

6368

4

7

589

589

6370

4

7

589

589

7708

4

7

589

590

7698

4

7

603

611

Australia

Accepted

Please ensure consistency with other parts of the GLs. Other constructed water bodies
are subject to significant shifts in regional/continental weather patterns that may last for aseason, or up to a decade or more with significant impacts on methane emissions profile.
Australia
This is recognised in other parts of the GLs. Please ensure consistency with thetreatment, for example, of rice paddies which provides for a 'drought-prone' scaling factorof 0.16 (Vol4, chapter 5 Table 5.12)
Please ensure consistency with other parts of the GLs. Other constructed water bodies
are subject to significant differences in depth with significant impacts on methane
Australia
emissions profile. This is recognised in other parts of the GLs. Please ensure
consistency with the treatment, for example, of rice paddies which provides for a 'deepwater' scaling factor of 0.06 (Vol4, chapter 5 Table 5.12)
Please add a note that EF's for drainage ditches in organic soils can be found in Table 2.4
Finlandin the Wetland Supplement.

Where would countries get the activity data - is it collected presently, by whom, if not what
Finlandwould be the method to collect the data - please provide guidance on this.

Noted

Author's Note
This is possible at Tier 2 and 3. We have clarified the text
to make this more obvious. "In addition, it may be possible
to incorporate additional modifiers such as soil type (e.g.
mineral versus organic); water flow rate; inter-annual andseasonal variation in water levels; salinity; presence of
emergent vegetation (which may increase emissions) andspecies (for aquaculture); or take account of sitemanagement activities that may increase or decrease
overall CH4 emissions (e.g., controlling organic matterloadings or aeration, including pond drainage)."Removed reference to agricultural ponds. "A Tier 3
approach for constructed ponds and channels may takeaccount of soils and land-use within the catchment area of
each waterbody as controls on organic matter and nutrient
inputs."Ditches are included in flooded lands. Ditches in organicsoils have already been considered in the Wetland
Supplement, but ditches in other Land cover categories
have not been considered elsewhere.
This advice has not changed. Saline aquaculture ponds
have high levels of organic matter inputs that support low
levels of methane emissions (compared to freshwater
ponds). A statement has been added to clarify. "However,
although because seawater suppresses production of CH4,
emissions from saline aquaculture ponds are lower undersaline compared to freshwater ponds"

Accepted

We have provided Guidance for inclusion of modifying
factors at Tier 2 and 3.

Accepted

We have provided Guidance for inclusion of modifying
factors at Tier 2 and 3.

Accepted

Added at note c to the Table 7.8

Accepted

We provide descriptions of where data may be available in
the Tier level descriptions. These have been improved.
Sentences added include: "The Ramsar Convention
provides guidance on mapping of wetlands (Annex III)
which can be used to determine the area of other Other
constructive constructed water bodies. The minimum
recommended scale of mapping is 1:5000 (50m x 50m or
0.25 ha) which could be used if appropriate data are
available, for example from Landsat remotely sensed
imagery (Pekel et al., 2016). "Comment
VolumeID

Chapter

6354

7

4

From line

604

To lineComment

Country

Response

Author's Note

604

The level error in methane emission estimation, due to a differences between default EF
and actual CH4 flux values, can be treated statistically if the observed water bodies areco-located and all experience similar environmental and management profiles. However,when the water bodies are spread across diverse landscape and climate types, andexperience a variety of management strategies, then a common Tier 1 approach is likely
to present significant error that cannot be treated statistically. Available emission factors
values are unable to be disaggregated according to climate zone, yet temperature is an
important factor and there is no advice provided for the wet/dry cycles that small dams
may experience between seasons or during periods of drought or flood. A national
inventory, therefore, will accumulate significant error that cannot be treated statistically,
and which will adversely affect the accuracy and confidence in the account.

Australia

Noted

We provide guidance that changing water levels andstratification over climatic and environmental factors could
be handled at Tier 2 and 3

6372

4

7

604

604

Please provide for the possibility for compilers to apply a minimum size threshold,consistent with the treatment of some other land use types, given materiality concerns.

Australia

Accepted

6374

4

7

604

604

Please provide for the possibility for compilers to apply a minimum size threshold given
detection limits of readily available monitoring systems and the appropriate application of Australia
scarce inventory resources.

Accepted

5914

4

7

604

606

5916

4

7

608

608

5918

4

7

619

619

7700

7702

4

4

7

7

623

634

Delete these first two sentences, they do not relate to choice of activity data. Perhaps
this information could be included a the beginning of the Other Constructed Waterbodies United States of America
sections on page 7.18.
After “…over time,” insert “countries should consider this in developing their time series ofactivity data”. The later part of the sentence “countries should use updated and recent
United States of America
data” should be rewritten to ensure inventory compilers also refer to older data sources aswell to better understand when new non-reservoir waterbodies were constructed.
The use of the term Fracditch here is confusing as it is not a term used in equation 7.12
on page 7.19. It seems you are using the methods in the Wetlands Supplement as an
example of how to obtain some of the activity data for your method. If so, then you should United States of America
make this clearer, or preferably just adapt that text and include it in this section so it iseasier for inventory compilers to use this guidance.

We provide guidance in the Activity data section and also
in the Uncertainty Assessment section: "The Ramsar
Convention provides guidance on mapping of wetlands(Annex III) which can be used to determine the area ofother Other constructive constructed water bodies. The
minimum recommended scale of mapping is 1:5000 (50m x
50m or 0.25 ha) which could be used if appropriate data
are available, for example from Landsat remotely sensed
imagery (Pekel et al., 2016). " and "Uncertainties in
estimating emissions and removals from other constructedwater bodies (ditches, canals, farm ponds and aquaculture
ponds) are to a large extent derived from assumptions anduncertainties in the area to which the EFs are applied."
We have provided guidance on this matter. "The Ramsar
Convention provides guidance on mapping of wetlands(Annex III) which can be used to determine the area ofother Other constructive constructed water

Accepted

ponds- These two lines have been deleted as they do not
relate to the 'Activity' section

Accepted

Change implemented

Accepted

Reference is made to the Wetlands Supplement which isthe source of the Fracditch parameter and describes its
calculation.

623

the FAO database does not provide areas for aquacultures as stated in the text - pleasecorrect; if area data cannot be found in any statistics is it realistic that countries can use
the guidance?

FinlandAccepted635

It is unclear from the text how these articles could be used in developing a Tier 3 method.
Please expand - especially as the article Yang et al 2015 is available only when
Finlandpurchased, and Gusmawate et al. 2017 talks mainly about management not how it islinked to emission estimation.

Accepted

We have removed the link (which was to yield estimates)
and incorporated alternative text and reference. "For areaof aquaculture ponds, estimates of area may be available
from remote sensing imagery (Ottinger et al., 2017) or
national databases."
We have clarified these statements. "National level
information capturing the differing pond management (e.g.
whether ponds are intensively managed or abandoned(Gusmawati et al., 2017), particularly where the effects ofpond management (e.g. drainage, Yang et al., 2015) or
activity (Gusmawati et al., 2017) influences CH4 emissions(e.g. drainage, Yang et al., 2015) may also be appropriate
to incorporate within a Tier 3 method."Comment
VolumeID
5920
4

Chapter

From line

To lineComment

7

641

641

Replace “impounded” with “flooded”
United States of America
Are there differences between CO2 and CH4 as it relates to this discussion on the surgeof emissions following flooding. Also, the word “return” on line 657, does not seem
United States of America
appropriate since the previous emissions pattern was that of unflooded land and it’s not
returning to that emissions profile.
This is not an issue of recalculating the times series, but rather of adding a new category
and ensuring time series consistency. Perhaps direct reference to Section 5.2.2 inUnited States of America
Volume 1, Chapter 5 on “Adding new categories” would be a better way to describe thisthan a recalculation, which is when modifications are made to existing estimates that
require recalculating the time series.
This text is not necessary as it’s understood that unmanaged land categories can beconverted to many of the LULUCF managed land categories. Therefore recommend
Canadadeleting as it does not add relevant guidance to the text.
It’s not clear from reading the text here and in Annex 7.1 if the EF for the first 20 years
represents estimates of average emissions during this period or if it is estimating
emissions over 100 years but then calculated in the 20 year reporting period. Also it’s not
Canadaclear if the EFs represent the total emissions or emissions after natural emissions levels
have been subtracted. Text should be edited to clarify what the emission estimates using
the EFs in the table represent.
Is the reference to HWP chapter 12 the correct one for slash and stumps?
FinlandThis sentence would seem to indicate that the method requires separating the amount ofcarbon in the drawdown zone from the carbon not in the drawdown zone, but the method United States of America
in equation 7.13 does not seem to make that distinction. Is clarification needed here?
The title of equation suggests, that the equation suitable for calculation of C-CO2“emissions/removals”. Only C-CO2 emissions can be calculated by this equation, so it is Russian Federation
expedient to remove the word “removal”.
"less than 20 years ago" should be modified to "less than and equal to 20 years old" toJapanmake it clear that 20 years old is included in Land converted to Flooded Lands category.
Variable SOCj,k of equation 7.13 should be clearly related to generic methods in chapter
2 for estimating SOC. In particular, should the Mj scaling factor depend on the distribution
Canadaof SOC stocks among the active, slow and passive pools (see new box 2.3c andequations 2.26b to 2.26h)?
Table 2.3 in the 2006 IPCC Guidelines has been updated as part of the 2019 Refinement,
United States of America
therefore this should direct them to the updated Table 2.3 in the 2019 Refinement.

Accepted

5922

4

7

655

661

5924

4

7

661

662

9414

4

7

668

671

9416

4

7

674

678

7704

4

7

686

687

5926

4

7

691

692

8444

4

7

700

705

4758

4

7

709

709

9418

4

7

712

714

5928

4

7

713

713

5930

4

7

723

723

5932

4

7

727

728

9420

4

7

730

731

9422

4

7

740

742

Country

The reference to Table 2.3 in the 2006 IPCC Guidelines has been updated as part of the2019 Refinement, therefore this should direct them to the updated Table 2.3 in the 2019
United States of America
Refinement. Also, note that the updated Table 2.3 has added a Polar climate, not surethat matters.
Is this really necessary to mention here? Mangroves and tidal marsh are alreadywetlands and they remain wetlands if used for aquaculture i.e., there is no additional
United States of America
flooding of land.
Explain what “nb reservoir” represents. Is it the number of reservoirs sampled?
CanadaSince the emission factors for Tier 1 were developed externally with the G-res model, it’sdifficult to understand from the new guidance how Tier 2 EFs could be developed to beconsistent with guidance in this chapter. Many of the variables in equations A1-A3 require
Canadaparameters directly from the G-res model that would be difficult to obtain (e.g. solar
irradiance, dimensionless temperature factor derived from air temperature). Recommend
providing more detailed guidance on how Tier 2 estimates could be produced fromnational GHG measurements.

Response

Author's Note

Accepted
Accepted with Mod Text modified to reflect differences among gases.

Accepted

Changed as suggested

Accepted

Deleted in FD

Accepted

The principle of calculating the CO2 emissions from land
converted to flooded land has been edited for better
clarification.

Noted

Reference is correct

Accepted

Sentence deleted

Accepted

Changed as suggested

Accepted

Corrected as suggested

Noted

The scaling factor is based on the ratio between SOC stockproxy from the FAO harmonised soil map and empirical flux
rates. The impact of different OC fractions are thus
embedded in the scaling factor.

Accepted

Accepted

Sentence deleted

Accepted

Nb changed to "Number of" in text

Accepted

Added reference to G-res supporting documentation wheremore detailed information about G-res formulation anddevelopment of supporting parameters can be found.

Comment
VolumeID

Chapter

From line

To line

9424

4

7

743

748

5934

4

7

748

748

5936

4

7

750

756

5938

4

7

789

789

5940

4

7

802

803

5942

4

7

810

810

5944

4

7

825

826

5946

4

7

865

865

5948

4

7

876

883

5950

4

7

886

887

9426

4

7

892

895

5952

4

7

908

908

9428

4

7

951

985

Comment

Country

The removal of the level of the natural annual background release of CO2 isn’t consistent
with other LULUCF guidance. For example this is not done when wetlands are converted
Canadaduring land-use change to other categories (e.g. drainage in the IPCC Wetlands
Supplement). Recommend editing text so that guidance is consistent with the rest of
LULUCF guidance for other land-use change categories.

Delete “until”
United States of America
This paragraph should be integrated in the Choice of Emission Factor section on page
United States of America
7.24 line 766-773
Not sure the first sentence is relevant for guidance on developing Tier 2 and 3 activity
United States of America
data.
It’s not clear why there is a mention of aquaculture on coastal wetlands, mangroves, tidal
marsh and seagrass meadows are already wetlands and they remain wetlands if used for United States of America
aquaculture i.e., there is no additional flooding of land.
Insert after “flooding” suggest to insert the following or other explanation for the highlevels of CH4 in the 20 years following flooding: “as a result of anaerobic decomposition United States of Americaof C in biomass, dead organic matter and soil carbon on the land prior to flooding”
There does not appear to be any guidance on how to estimate the area of land that is
newly flooded. It seems like some guidance should be provided on how to
obtain/estimate that data. This is key because it responds directly to the mandate in the United States of America
approved TOC regarding factoring out emissions and removals that would otherwise
occur in absence of the flooded area.
After “information to” insert “develop an alternative methodology or”
United States of America
An additional clarification that could be discussed here is the uncertainty in estimating thearea of land that is newly flooded—distinct from total area of flooded surface area. This is
United States of America
an additional data requirement as a result of the need to factor out the emissions andremovals that would otherwise occur in the absence of the flooded area.
It’s not clear why there is a mention of aquaculture on coastal wetlands, mangroves, tidal
marsh and seagrass meadows are already wetlands and they remain wetlands if used for United States of America
aquaculture i.e., there is no additional flooding of land.
Suggest moving this description of downstream emissions up to section 7.3.1.2 to better
explain to inventory compilers what emission estimates are included in the main
guidance. For example it wasn’t clear at first that the Rd constant in equation 7.10 would
result in including downstream emissions in flooded lands estimates.

CanadaDelete “for EF”
United States of America
This text and figure are specific to reservoirs so put in a reservoir section. It would be
helpful to include this section in the main chapter before the calculations. This would help Canada
with understanding the calculation steps for Tier 1, 2 and 3.

Response

Author's Note

Rejected

Flooded land is a special case, not covered by the previous
IPCC methodology. Flooding of previously water-saturatedorganic matter continues to preserve a large proportion of
the C stock. For non-water saturated OM thedecomposition rate may decrease, differently than afterdrainage of water saturated OM such as peat. The CH4
emissions are continued, modified, or newly established forearlier non-CH4 emitting organic carbon stocks. The
process of CO2 surge after flooding is covered by theempirically based CO2 emission factors and the conversionof organic matter to CH4 is covered by the empirically
based CH4 emission factors, respectively. Therefore the
MLP methods for other land use changes do not accurately
describe the changes in fluxes in flooded lands

Accepted

DeletedAccepted

Implemented

Accepted with Mod Text has been corrected.
Rejected

Conversion of coastal wetlands to aquaculture results inconversion to flooded land and therefore a change inemissions

Accepted

Text modified as suggested

Accepted

Guidance now included in FD

Accepted
Accepted

Rejected

Rejected

Accepted
Rejected

New text better describing how to estimate additional areaof land flooded is included, as well as new text about
uncertainty
Conversion of coastal wetlands to aquaculture results inconversion to flooded land and therefore a change inemissions
In the SOD, downstream emissions aren't defined until after
equation 7.10 is presented. We agree this is not optimal.
The definition is now presented in the "CH4 Emissions",
which appears very early in the guidance. The text on lines
892-895 are relevant to uncertainty and will remain in the'Uncertainty Assessment' section.
Thank you for the comment. This is a quite technicaldescription that fits best in the Annex for those who seek
better understanding

Comment
Volume
ID

6356

6358

9430

4

4

4

Chapter77

7

From line

1195

1195

1202

To lineComment

1195

Can you please clarify some aspects of the empirical models used to derive the methane
EF values provided in this document? The G-Res tool technical document (Prairie, et al.,2017, pp 8 and 10) provides a list of studies used in establishing a GHG emissions
database from which the mathematical equations underpinning the empirical models were
derived. The empirical models were then applied to the larger GRanD database of values
to calculate a set of Reservoir EF values (Tables 7.9 and 7.14). Could you pleasecomment on the method used to validate the empirical models as described in Annex 7.1 Australia(1195 onwards)? The method does not appear to comply with common practice invalidating empirically derived models; i.e. to use half the data in the database to prepare
the models and then validate against the other half. Rather model estimations wereregressed against direct measurements that were also used to estimate EF values usedby the models themselves. That is, the test data is not independent of the simulated
values.

1195

Does the G-Res tool factor out pre-impoundment emissions prior to calculating the EF
values? The current level of G-Res technical documentation is not entirely clear on thispoint. It appears it does so for CO2 emissions but not necessarily CH4 emissions. Also, in
applying the G-Res tool at Tier 3, CH4 emission/removal estimations will under-estimate
emissions and could potentially turn a source into a sink. It is unclear at this time whether
Australia
the G-Res tool cumulatively: (1) utilises an EF value already adjusted to factor out preimpoundment emission, (2) subtracts pre-impoundment emissions from the estimate, and(3) reduces the activity data to "newly flooded land" (see Prairie et al., 2017, p38), for landthat has finished its transition to Flooded land remaining flooded land. Can you pleaseclarify the modelling approach used, and provide an explanation if pre-impoundment
emissions are adjusted for in multiple ways.

1208

Outlier patterns suggest highly skewed data distributions. In addition, in all climate zones
except the Cool Temperate one, "outliers" of the box plots for modelled estimates lie
about one order of magnitude higher than the median, while the lower whiskers of the plot
Canadaextend over 2 orders of magnitude below the median. It is difficult to understand how such"outliers" have been defined for measured and modelled estimates. Something needs tobe explained about the distribution of the modelled estimates.

6378

4

7

1210

1217

5954

4

7

1253

1253

6360

4

7

1289

1289

9432

4

7

1289

Country1290

Is the claim that 'the model estimates capture both the variability and central tendency inCH4 emission rates' a claim that has been reported and tested in peer reviewed scientific
Australia
literature? If not, the basis for the emission factors differentiated by climatic zone would
be highly questionable.
Please make it clear that the 2019 Refinement provides updated values for Table 2.3 that
United States of America
is in the 2006 IPCC Guidelines
A4 should be A5 (figure below at line 1312)
Australia
Provide more clarity on why the emissions over the 100 year period are reported in the 20
year period. It’s not clear in the main chapter what emission estimates produced from the Canada
equations represent.

Response

Author's Note

Noted

The overall validation of our approach is not amenable tothe procedure referred by the reviewer. The empirical data
was used strictly to develop the empirical models. The
models were then applied to the >6000 reservoirs
contained in the GranD database and the model outputs
were then aggregated by climate zones to produce
Emissions Factors. The validation of our approach is best
illustrated in Figure A4 where GHG emissions estimatedstrictly from the tabulated climate-specific EFs (Table 7.9
and 7.14) are compared with GHG emissions fromreservoirs in which field measurements were made.

Noted

For CH4, the Emissions Factors (Table 7.9 and 7.14)
represent our best estimates of CH4 emissions for eachclimate zone. These EFs do not factor out any preimpoundment emissions. However, the guidance(Equations 7.10 and 7.13) does provide a methodology tofactor out CH4 emissions from unmanaged lands such as
wetlands or lakes that existed prior to the flooding. For
CO2, as detailed in section A7.1.2.2 and in G-res technicaldocument section 3.1.2), our approach aims at providing
EFs that factor out CO2 emissions that would haveoccurred regardless of the presence of the reservoir. These
calculations depend in part on the time evolution of CO2
emissions after flooding and the amount of soil carbon thatwas flooded. This approach is also discussed moregenerally in Prairie et al. 2017. Greenhouse Gas
Emissions from Freshwater Reservoirs: What Does the
Atmosphere See? Ecosystems 19:1–14. The methodology
provided here regarding the factoring out due the presenceof a former lake or wetland in the reservoir area is
independent.

Noted

Once the empirical models were developed, they wereapplied to several thousand reservoirs and because of theirindividual configurations and environmental conditions, they
produce a wide range of estimates for each climate zone.
While the range of prediction is wide, the average value iswell constrained (see new table with standard errors.

Rejected

Figure A4 demonstrates that the model estimates capture
both the variability and central tendency in CH4 emission
rates. No bias can be observed with respect to measured
vs estimated values.

Noted
Accepted

Noted

While most of the CO2 emissions attributable to thereservoir do occur within the first two decades, the return to
new equilibrium conditions was assumed to be equal to the
expected lifetime of reservoirs (100 years). As explained in
Figure A4, those values were reported as a 20 years
average for consistency and simplicity..

Comment
VolumeID
6362
4

Chapter

From line

To lineComment

7

1312

1312

Figure A4 should be Figure A5 (Figure A4 is above at line 1227 and refers to CH4 flux)
Australia
Page 7.41, Table A3: If the * in the cool temperate moist and dry cell relates to the Noteat the bottom of the table there should also be an * at the bottom of the table in front of
United States of America
the note.
Sturm et al., 2014. Gold Creek (Brisbane), IPCC climate zones places Brisbane in "warmAustralia
temperate moist" climate zone

Accepted

Provide examples of silvicultural practices that involve creation of waterbodies.

Noted

5956

4

7

1339

1340

6364

4

7

1339

1339

9434

4

7

1371

1371

5958

4

7

1371

1380

9436

4

8

82

82

Country

CanadaCould this method also apply to ponds in settlement areas where they are quite common?
If so, then it would be useful to mention that specifically so inventory compilers will know United States of America
to include them in their estimates
Editorial comments: settlements instead of Settlements (ex. Line 167, 168, 212, 221, 222,
227, 228, 234 etc.)
Inconsistency in the document: C vs carbon (ex. Line 111, 131, 144, 151, 169, 321, 348,
378, etc.) 5.0t (line 101) vs 4.0 t (line 102) , missing before etc. line 107
Inconsistency in the document: settlements remaining settlements in lower case vs upper
case (ex. Line 231, 235, 243, 291, etc.)
CanadaInconsistency in the document: country-specific vs country specific (ex. Line 172, 174,
242, etc.) -Inconsistency in the document: t vs tonne (ex. Line 259, etc.)
Inconsistency in the document: Land-use vs land use at line 227 (ex. Line 241, 294, 304,
305, 313, 318, 319, 320, 326, 327, etc)
Inconsistency in the document: DOM vs dead organic matter / DOC dead organic carbon(DOM: abbreviation explain at line 2148…)

Response

Accepted
Rejected

Accepted

Accepted

9438

4

8

83

89

Not clear how to take into account urban conditions, such as local air quality, to assess
tree growth. Maybe add a reference for guidance and ensure consistency on how toaccount for those effects.

9440

4

8

84

84

CO2 vs CO2 Misplace abbreviation (CRW)?

CanadaAccepted with
Modification

9442

4

8

94

94

If there is so much discrepancy, please add a definition.

CanadaAccepted with
Modification

111

The removal factors of urban parks in Japan (Tonosaki, 2018) are shown as values perpark area rather than as values per crown cover. The sentence ", and the averagedJapan
removal factor of urban parks in Japan can be represented as 2.50 tonnes C (ha crowncover)-1 yr. -1 (Tonosaki 2018) " should be removed.

4760

4

8

110

Canada

Noted

Author's Notethe asterisk was removed from the table
According to the map of IPCC climate zone, the location ofGold Creek Reservoir is in the "tropical dry and montane"
The text describes that silviculture sometimes requires theconstruction of ponds for irrigation, canals to provide wateretc
Yes. Comment has been added "In Settlements ponds may
be created for recreation, aesthetic or stormwater
management."
Editorial - TSU. Note that for Settlements vs settlement theland-use category name was capitalized.
C vs carbon: should be consistent with the 2006GL
Country-Specific (with hyphen) is the correct way.
t vs tonnes: basically use "t C"
land use vs land-use: general meaning of land use is
without hyphen. category name or LUC context is withhyphen.
DOM vs dead organic matter: use dead organic matter
here.
The current guidance includes several references related to
impact of e.g. air quality on tree growth and mortality insettlements area. In case of higher Tiers application
additional information would be applied for country specificmodelling.
Sub index typo corrected in the grey text. No CRW
abbreviation in the sentence found.
Additional text was included to clarify that the large
variation is due to the national definition of the land-use
category Settlement.

Accepted

Suggested text has been deleted.

For settlement estimation of biomass carbon stock changes
the application of Tier 1 method implies the assumption ofan equilibrium between the changes in biomass carbon
stocks due to growth in biomass and the decreases incarbon stocks due to removals. Therefore, the methods
and values presented in this section refer to countryspecific estimates which is why they are considered Tier 2.

7394

4

8

121

163

we feel that the discussion in these paragraphs belongs to tier 1 section. ACTION: movethese paragraphs after line 119 and before line 120

Spain

Rejected

9444

4

8

125

127

It is a US factor, not a global factor. Add examples from outside the US.

CanadaAccepted with
Modification

9446

4

8

139

140

The 0.26 ratio comes from Cairns et al. (1997), not Nowak et al. 2002. The ratio could be
Canadamore region specific and based on a more recent publication (ex. Poorter et al. 2012).

Accepted with
Modification

Text has been revised deleting "global default value" andreferring to updated studies.
Reference was corrected as the reviewer suggested. The
suggested publication (Poorter et al. 2012) was examined
but it was decided that no additional shoot-root ratios, to bepotentially referred to in the guidance, are included in theabovementioned paper.

Comment
VolumeID

Chapter

From line

To lineComment

Country

Is it supposed to be included? If yes, there is an issue about double counting theemissions from the peat drained for horticulture. For the Wetland category, we assume
Canadathat peat dedicated to horticulture is immediately converted to emissions in the inventory
year.
"Rationale" instead of "rational".
CanadaConversion of wetlands to settlements should also be mentioned here and discussed
further under the carbon pool sections similar to what is provided for forest land, cropland United States of America
and grassland

Response
Accepted with
Modification

Author's Note
Text has been revised to clarify that the paragraph related
to perennial crops included in Settlement land-use
category. The reference to horticulture has been removed
since it is not mentioned in chapter 5.
The term rationale is used in the sentence.

9448

4

8

150

151

9450

4

8

174

174

5960

4

8

197

198

9452

4

8

243

244

What is the definition of urban green space? Does it includes soccer field (no trees) as
well as golf courses (scattered trees) and Parks (variable tree density)?

CanadaAccepted with
Modification

9454

4

8

263

263

"cropland" instead of "Cropland". "grassland" instead of "Grassland".

CanadaAccepted with
Modification

9456

4

8

322

322

Remaining should be lower case. Same at line 325.

CanadaRejected

9458
9460

4
4

8
8

383
494

383
494

Accepted
Accepted

4762

4

8

496

496

Accepted

Done, page numbers were inserted.

7634

4

10

174

175

7616

4

10

436

444

7618

4

10

451

456

7620

4

10

471

473

within in italic
Canada"Gu¨neralp" instead of "Güneralp".
CanadaThe description should be as: Tonosaki, K. (2018). Carbon Accumulation Rate by Trees inJapan
Urban Parks in Japan, Urban Green Tech, 106,18-21
Table 10A.2-8 in Annex : Please check if EF for reindeer is correct when using
Finlandparameters mentioned in the table (VS, Bo, MCF)
Please emphasize that slaughtering weights can be utilized in live weight estimations if
Finlandslaughtering ages and growth curves are also available.
Please add a sentence emphasizing that mature weights of bulls are 1.5 times higher as
cows in the same genotype. A reference for this: Table 9, p.1443, in Doren, P.E., Baker,
FinlandJ.F., Long, C.R. and Cartwright, T.C. 1989. Estimating parameters of growth curves ofbulls. Journal of Animal Science. 67: 1432–1445.
FinlandJohnson (1986) is missing in the references.

Text has been revised and "crown cover area" is usedinstead of "urban green space" to be consistent with default
factor.
Cropland and Grassland in this table as land-use categoryname were capitalized.
To be consistent with Chp. 8 of the 2006GL, Remaining aspart of the category name is capitalized.
Editorial - TSU
Editorial; done.

7622

4

10

471

Noted
Accepted with
Modification

Text has been revised to include the reference to wetlands.

Accepted
Rejected

There is already a description of the use of slaughter
weights in the text.

Accepted
Accepted

Should be added t the reference list
Countries should apply that temperature equation in aconsistent manner than has been explained in the NRC
2018. It is applied in during periods where cattle are
outdoors and temperatures are transitioning from warm tocool until the animals become acclimatized. The Johnson
reference has been added to the reference list.

473

Please specify the temperature range intended, i.e. starting from what temperature therelationship described in Equation 10.2. is applicable? How could one access thereference behind this relationship? Via IPCC archives? How about countries with coolsummers? Or should this be used when animals have an outdoor shelter as well?

Finland

Rejected

Finland

Rejected

The answer would be yes, but this is out of the scope of the2019 Refinement.

Finland

Rejected

No action can be taken because comment is out of scopeof 2019 Refinement.

7624

4

10

637

649

Does the Equation 10.6. mean that different mature weight values will be used forfemales, castrates and bulls - in addition to the difference created by the coefficientdiffering from 1 for these cattle subgroups? This is an important issue because of thegreat difference in mature weights between sexes.

7626

4

10

637

649

Calculation examples for a bull and a heifer would be useful.

827

Suggested re-wording: “It is also possible to predict dry matter intake for mature andgrowing cattle based on the body weight of the animal, using either the dietary net energy
Canadaconcentration of the feed NEmf (MJ kg-1 DM) (National 827 Academies of Sciences &Medicine 2016) or DC, and if lactating dairy cow, fat corrected milk production.”

Noted

Will be taken into account together with other comments inrevising the draft.

931

Ym has not yet been defined. We suggest to add "This variation is captured by Ym,
defined as the percentage of gross energy intake converted to CH4." after the sentence"The extent to which feed energy is converted to CH4 depends on several interacting feed France
and animal factors.". Or at least refer to equation 10.24 coming two pages later where Ym
is defined.

Rejected

Out of scope, proposed edit occurs in greyed text. No
action can be taken because comment is out of scope of2019 Refinement.

9464

4898

4

4

10

10

826

931

Comment
VolumeID

Chapter

1822

4

10

1039

1039

7420

4

10

1298

1938

6576

4

10

1301

1301

From line

To lineComment

Country

For Table 10.10, it is suggested that “developed countries” and “developing countries” beused in place of “High Productivity Systems” and “Low Productivity Systems” in the Table China
by following the classification given in the 2006 IPCC Inventory Guidelines.

7422

4

10

1329

1607

6578

4

10

1376

1379

‘change ‘day. then’ into ‘day. Then’.

1607

Emission factors by productivity and climate zone are provided, but the definitions of
productivity and climate zone are not provided. In the section of enteric fermentation, thelevel of livestock weight are showed with productivity (ex.Table10.10), and the definitions Japanof climate zone are showed in Annexes of Ch.10. The definitions of those should be
provided in the section of manure management as well.

4

10

1437

Author's Note

Noted

The shift from reporting of EFs for developed/developing
countries to low- and high productivity systems was made.
As this approach permits to track changes in GHG
emissions occurred from transition from low- to highproductivity systems within developing countries, inparticular.

Many references to tables or equations are misleading (including references to nonexisting tables or equations). Therefore, we were unable to follow the instructions. Please Germany
Acceptedrevise.
Add the words "Volatile Solid" following the use of VS. (first time use of that abbreviation United Kingdom (of Great
Acceptedin the document)
Britain and Northern

To us the new Tier 1A and Tier 1B methodology for methane emissions from manure
management is too complicated. It covers more than 20 pages of tables and equations
Germany(not to speak of additional tables in the annex) and is, at least, a Tier 2 methodology. Dueto the length of the description, this methodology lacks transparency. Please revise.

4764

Response

Accepted with
Modification

United Kingdom (of Great
Accepted
Britain and Northern

The references to the tables and equations were verified
and changed as appropriate.

As noted in comment 1176, the Tier 1 method for manuremethane has been modified to maintain consistency with
the Tier 1 method for nitrous oxide. This is to assure that
there is consistency between manure N2O and manure
CH4, whereas in the 2006 guidelines, this was not thecase. Therefore there are changes to the Tier 1 method formanure methane. However, the reviewer's comment isnoted and the choice of emission factors for the Tier 1
method has been reduced significantly, furthermore, theapplication of the method using the Tier 1A and Tier 1B
method has been simplified and better explained such that
there is only one additional equation from the 2006
Guidelines, that required to calculate volatile solids

Rejected

It is preferred to avoid repetition in the livestock Chapter.
The definitions of climate zones have already been
repeated from Chapter 3 of Volume 4 and we havecompiled all animal weights in Annex Tables. We feel thatcompilers have all the information that they require without
repeating the information in each section.

Rejected

The emission factor for forced aerated systems is only
applicable for 'biological treatment of municipal andindustrial wastewaters with negligible N2O emissions', as
noted in Table 10.21. For all other systems using aeration
the emission factor for natural aeration systems has to be
used. Countries are always welcomed to use countryspecific emission factors.

Concerning Aerobic treatment of TABLE 10.14B
AVERAGE REGIONAL METHANE EMISSION FACTORS OF CATTLE.
Judgement of IPCC Expert Group are underestimate of Methane emission. Methane
emission surely occur during storage in actual (Average 0.91% (kgCH4 / kg volatile solids–1) 0.1%–3.0%, kg CH4/volatile solids–1), and thus emission factor of 0.0 isinappropriate.

4774

4

10

1527

1527

According to the IPCC 2006 guidelines, under aerobic treatment
conditions, the CH4 emission should be negative fromwastewater treatment (0%; kgCH4/kg volatile solids–1).
The CH4 emission from the individual aeration tanks(aerobic reactor of activated sludge process) was certainly
negligible in our previous lab scale studies.
However, methane is generated from organic degradation
under anaerobic conditions by microorganisms inmanure or wastewater. It is possible that the IPCC2006
calculation of the CH4 emission factor may not account for
the full reactors of the wastewater purification treatment
facility. Such CH4 emissions were reported at sewer
treatment plants.
See Supporting document

JapanComment
VolumeID

Chapter

5962

10

4

From line

1527

To line

1528

4772

4

10

1540

1540

5964

4

10

1606

1607

7632

4

10

1636

1636

9462

4

10

1694

1694

Comment

Country

Page 10.58-10.59, Table 10.14B: The values for Dairy Cattle, both High and Low
Productivity, with Liquid/Slurry, and Pit storage below animal confinements > 1 month inTropical climate are shown as 0.9, this is also the case for Deep bedding > 1 month which
United States of America
are shown as 0.5. These values seem much lower than they should be when comparing
to other values in the table. There is also a similar issue in Tables 10.14C, 10.14D and10.14E
Concerning Aerobic treatment of TABLE 10.14C
AVERAGE REGIONAL METHANE EMISSION FACTORS OF SWINE.
Methane emission surely occur during this storage in actual (Average 0.91% (kgCH4 / kg
volatile solids–1) 0.1%–3.0%, kg CH4/kgvolatile solids–1), so emission factor of 0.0 isinappropriate. See Supporting document.
According to the IPCC 2006 guidelines, under aerobic treatment conditions, the CH4
emission should be negative fromwastewater treatment (0%; kgCH4/kg volatile solids–1).
The CH4 emission from the individual aeration tanks (aerobic reactor of activated sludge
Japanprocess) was certainly
negligible in our previous lab scale studies.
However, methane is generated from organic degradation under anaerobic conditions by
microorganisms inmanure or wastewater. It is possible that the IPCC2006 calculation of the CH4 emission
factor may not account for
the full reactors of the wastewater purification treatment facility. Such CH4 emissions
were reported at sewer
treatment plants.
See Supporting document
Page 10.75, Table 10.16A: There are footnote notations for Deer, Reindeer and Rabbits,
United States of America
but the footnotes seem to be missing.
Please check Equation 10.23, formula does not give kgCH4/VS - not grams and not per
FinlandVS
Reference should be made to section 10.20 and not section 10.2.

Response

Author's Note

Accepted

These values were verified and modifications were madewhere appropriate

Rejected

See comment 4774

Accepted
Accepted

Equation was corrected

CanadaRejected

Reference to Section 10.2 is correct. Probably, thiscomment refers to "page 10.20".

Japan

Rejectedsee previous version of this comment

Concerning Aerobic treatment of TABLE 10.17
METHANE CONVERSION FACTORS FOR MANURE MANAGEMENT SYSTEMS.
Judgement of IPCC Expert Group are underestimate of Methane emission. Methane
emission surely occur during treatment of this treatment system in actual(Average 0.91%(kgCH4 / kg volatile solids–1) 0.1%–3.0%, kg CH4/kgvolatile solids–1).

4776

4

10

1755

1755

According to the IPCC 2006 guidelines, under aerobic treatment
conditions, the CH4 emission should be negative fromwastewater treatment (0%; kgCH4/kg volatile solids–1).
The CH4 emission from the individual aeration tanks(aerobic reactor of activated sludge process) was certainly
negligible in our previous lab scale studies.
However, methane is generated from organic degradation
under anaerobic conditions by microorganisms inmanure or wastewater. It is possible that the IPCC2006
calculation of the CH4 emission factor may not account for
the full reactors of the wastewater purification treatment
facility. Such CH4 emissions were reported at sewer
treatment plants.
See Supporting document

Comment
VolumeID

Chapter

7628

4

10

1755

1756

7630
5160
4766
5162
4768
5166
4770

4
4
4
4
4
4
4

10
10
10
10
10
10
10

1755
1829
1829
1855
1855
1873
1873

1756
1829
1829
1855
1855
1873
1873

5168

4

10

1894

1894

7638

4

10

1925

2534

6932

4

10

From line

To line

7430

4

10

1985

1988

5966

4

10

2086

2101

5968

4

10

2103

2155

7636

4

10

2205

2206

9558

4

10

2437

2438

Comment

Country

Table 10.17: How is crust cover considered in practice? When is there a thick, dry crust?
What about open storages in a country where there are big changes in weather during theyear and between years? Can a thick, dry crust to be expected only when there is a solid Finlandroof above the storage. MCFs by climate zone is missing for deep litter for other thancattle/swine.
Table 10.17: MCFs by climate zone is missing deep litter for other than cattle/swine.
FinlandReplace equation 10.26 with equation 10.24B
Italy
The word "equation 10.26" should be revised by "equation 10.24B".
Japan
Replace equation 10.30A with equation 10.24G
Italy
The word "equation 10.30A" should be revised by "equation 10.24G".
Japan
Replace equation 10.30B with equation 10.24H
Italy
The word "equation 10.30B" should be revised by "equation 10.24H".
Japan
The reference "was recommended in. T able 10A-4 to T able 10A-9 of 2006 IPCC
Italy
guideline" is wrong.
Chapter 10.4.3 (row 1925) says The borderline between dry and liquid can be drawn at
Finland
15% dry matter content and Table 10.21 says the borderline is 20%
Canada submitted the comment about the calculation method of CH4 emissions related tomonthly volatile solid excretion per animal.
Because there are four seasons in the Republic of Korea like Canada and it is very cold in
Republic of Korea
winter season, if you accept the comment of
Canada, it is expected that CH4 emissions from stored liquid swine manure may bedecreased.

List of considerations for estimating the N excretion by growing pigs appears to be
missing from the text

Author's Note

Noted

see response to comment 636 and 638.

Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted
Accepted

Editorial error. The 10% of MCF for biogas digesters was
replaced by 10% of MCF for biogas digesters。

Accepted

We changed the footnote value to 15%

Noted

Korea would apply the method according to the Guidelines
as defined in this refinement.

Accepted

The proposed reporting tables that consistent with CRF
reporting tables 3.B(a)s1, 3.B(a)s2, and 3.B(b) have been
updated to allow the estimation of VS input and Bo for codigestates, and N available in co-digesters, respectively.
The new sub-category '5. Co-digestates' have been
introduced with sub-categories '5.1. Crop residues', '5.2
Food Waste' and '5.3 Other'. The sub-categories 'Crop
residues' and 'Food waste' are important for ensuringconsistency with the N2O emissions from soils and the
Waste sector, respectively. Energy crops are to be reported
under '5.3. Other'. CH4 emissions from anaerobic digestion
are to be estimated with a Tier 2 method. The text has
been updated. *** Do we need default VS and B0
values???***or/and do values come from the waste
sector?***Anyhow, this needs to be resolved in the text
(Hong Min)

United States of America

Accepted

Reference to Table updated

United States of America

Rejected

Default values for FracLEACHMS are given in Table 10.22

FinlandAccepted

No numeric values of EF5 are given, just the reference toTable 11.3

CanadaAccepted

This sentence has been deleted.

Co-digestion of energy crops and animal manures in the context of direct N2O emissions
from manure management: The text more or less suggests that N from energy crops mustbe treated as if it were part of the N pool constituted by animal manures. However, CRF
table 3B(b) is designed for animal husbandry data only (animal numbers, animal
excretions) and cannot account for such an atypical N source like energy crops. In
addition, the draft of the revised guidelines does not mention co-digestion of energy crops
in the context of CH4 from manure management. This implies an inconsistent guidanceGermany
on how to deal with anaerobic digestion of energy crops (co-digestion of energy crops
considered for N2O but not for CH4). In order to enable proper accounting of emissions
due to animal husbandry on the one hand and emissions due to anaerobic digestion ofenergy-crops on the other hand, we suggest to make separate emission calculations foranimal manures and energy crops (as it is done in the German inventory, cf. NIR 2018,
Chapter 5.1.4.1, see supporting document). Depending on the solution to these problems,
the inventory compiler must be made aware of possible double-counting with the waste
sector (5B2).
In the list of variables for Equation 10.26A, there should be a note that FracGasMS canbe found in Table 10.22. It is stated above the equation that the value can be found in
Table 10.24, which is a mistake (line 2086-- should be changed to Table 10.22).
It should be more clear what the Party should do with the N losses calculated fromleaching using Tier 1. If there is no emissions estimate available, should the Party markthis as NA, NE, or NO in their CRF tables? There should be explicit instructions in thissection what to do, and that the N-leach (and N-vol) should be subtracted from N
available for cropland.
Default EF5 (lines 2205-2206) in chapter 'Indirect N2O emissions from Manure
Management' is 0.0075 kg N2O-N (kg N leaching/runoff)-1 but in Updated table 11.3 it is
0.011

Response

Comment
VolumeID

Chapter

From line

To line

5154

4

10

2354

2354

5164

4

10

2533

2533

4778

4

10

2533

Response

Author's Note

Rejected

No action can be taken because comment is out of scopeof 2019 Refinement.

Accepted

Table header adjusted

Japan

Noted

The emission factor for forced aerated systems is only
applicable for 'biological treatment of municipal andindustrial wastewaters with negligible N2O emissions', as
noted in Table 10.21. For all other systems using aeration
the emission factor for natural aeration systems has to be
used. Countries are always welcomed to use countryspecific emission factors.

Japan

Rejected

The median is generally used to return the central tendency
for skewed number distributions as it is the case here

Accepted

Reference to Table 10.22 corrected

Rejected

There is no reference to the Tier level

138

While this section is on N2O from managed soils, it may be worth mentioning (possibly ina footnote) that the method for drained organic soils in the 2013 Wetlands Supplement
United States of America
also provides a method for estimating CO2 and CH4.

Noted

183

If mitigation options such as application of nitrification inhibitors are implemented, too
small emission factors compared with the actual emissions may be used. A description
such as "conservative or reasonable emission factors with clear scientific rationale should Japanbe used if country-specific emission factors considering the effects of mitigation options
are used" should be added in order to avoid the underestimation.

The compiler is directed to the 2013 Wetlands Supplement
for additional guidance on drained organic soils, and willfind the methods for CO2 and CH4 when reviewing the
supplement. It is not necessary to mention the methods
here.

Noted

This is true for any emission factor, i.e., EF values need tobe accurate regardless of the actions that they represent.

2534

Comment

Country

Section 10.2.2. The reference to the equation or table or text of the paper from NRC 1996
(as reported in line 2354, section 10.5.2, EQUATION 10.33A N RETAINED RATES FOR Italy
CATTLE) could be inserted.
In Table 10.21 "EF3 [kg N2O" the rest of the unit of measurement is not seen.
Italy
Concerning Aerobic treatment of TABLE 10.21
DEFAULT EMISSION FACTORS FOR DIRECT N2O EMISSIONS FROM MANUREMANAGEMENT
Judgement of IPCC Expert Group are underestimate of Nitrous oxide emission. N2Oemission factor of "Aerobic treatment Forced Aeration system" in actual are more high
(Average 2.87% (kg N2O-N$ kg totalN–1), 0.3%–9.1%, kg N2O-N$g total N–1)..
See Supporting document.
Same range of emission factor were reported other similar organic wastewater treatment
systems.
Judgement of IPCC Expert Group are underestimate of Nitrous oxide emission in thiscategory.
N2O emission factor of "Solid storage" (bacical data:0.005) and "Composting – passive
windrow" (bacical data:0.005)
in actual are more high.

4780

4

10

2533

2534

See Table 2 in Paldo et al.2015 of source of this judgement.
N2O emission factor from this report, we should be use Average emission factor not
Median from Table 2 and Table 3.
("Solid storage" Median 0.005 Mean 0.17 /"Composting – passive windrow" Median 0.005 Mean 0.12 ),This expert judgement is high risk of environment in future.
Because so many nitrogen are excrete from Livestock's.

5970

4

10

2618

2621

5972

4

10

2620

2621

5974

4782

4

4

11

11

136

160

See Supporting document, some of then were introduced in Paldo etal. 2015
FracGasMS and FracLeach MS can both be found in Table 10.22, not table 10.24. Typo. United States of America
FracLeachMS may also be a country-specific value, if the Party used a Tier 2
United States of America
methodology. This should be noted in the list of variables for Eq. 10.34B.

Comment
VolumeID

Chapter

From line

To lineComment

Country

Response

Accepted

Author's Note
Thank you for the suggestions. The reference to 'individualsoils' has been changed to 'individual fields'. The text
stating that "This method will require activity data on
specific fertiliser application rates to soils in order to apply
the rate specific emission factors that capture theexponential response." was replaced by "This method will
require activity data on specific fertiliser application rates toindividual fields in order to apply rate-specific emission
factors that capture the exponential response. "The text has been changed to "According to Equation 11.1,
direct emissions of N2O from managed soils are calculated
in the Tier 1 approach on the basis of total N applied tosoils as synthetic and organic fertilisers and/or soil N
mineralisation."
It is up to individual countries to define the method used in
the inventory with higher tier methods. A reference
illustrating the N flow principle has been added. The
impacts can be addressed with a Tier 3 method where thecompiler uses a more complex method that tracks N flows
rather than the simple EF approach based on total N input.
The corresponding text was therefore moved to the Tier 3
section.

7406

4

11

162

181

If a non-linear relationship concerning the response of N2O emissions to N applications isallowed, a guidance on data aggregation is required. Studies that found an exponential
relationship always used data from measurements on individual fields. Typically, activity
data is not available at the field level. Unfortunately, for a nonlinear model f theGermany
relationship sum(f(x)) = f(sum(x)) does not hold, which should be addressed explicitly
here. Please revise. In addition, footnote 6 on page 11.8 refers to "individual soils". Wesuggest to change this to "individual fields" to avoid confusion with stratification by soil
classes.

5976

4

11

187

188

Before “managed soils “insert “animal manure applied to”. The way the sentence
currently reads it seems to imply that direct N2O emissions from managed soils arecalculated only from animal manure applied to soils.

United States of America

Accepted with
Modification

5978

4

11

196

197

This sentence does not provide sufficient guidance for an inventory compiler to adopt an“N-flow principle” approach as mentioned in the paragraph.

United States of America

Accepted with
Modification

5980

4

11

219

219

United States of America

Accepted

5982

4

11

222

222

United States of America

Accepted

The text was changed to "for both organic and synthetic N."

5984

4

11

231

232

Before “values” insert “updated”. After “Table 2.5” insert “and replace the values in the2006 IPCC Guidelines”

United States of America

Noted

The sentence relating to the Wetlands supplements has
been deleted, following advice from another reviewer
comment.

238

Updating the important and fundamental emission factor EF1 should be based on a peerreviewed publication. To us, the description in 11A.2 is insufficient regarding transparency
and reproducibility. After the data was made available, we reanalysed the data and came
Germany
to the conclusion that the data does not support the proposed disaggregation sufficiently.
Thus, we recommend that the disaggregation should be retracted until more (and better)data is available. See supporting document for more details.

Accepted with
Modification

Thank you for analysing the dataset. Annex 11A.2 wasfurther elaborated to improve understanding, transparency
and reproducibility. Furthermore, the final order draft has an
updated analysis for the EF1 after inclusion of additional
data to the database, as requested by other reviewers.

238

I think the revised factors properly represent the accumulated evidence published sincethe 2006 guidelines were derived. In particular, the disaggregated factors make sense
and are defensible based on results from field studies. The revised uncertainty ranges are
United States of America
also reasonable and consistent with observations. My only minor concern is the lower
bound of the range being 0 in some cases. This seems counter-intuitive but does appear
to be based on observational evidence so perhaps is still justified.

Noted

Thank you for the comment. The null lower bound of therange for EF1FR was based on observational data, whilenull lower bound of the range for EF1 was slightly negative
based on original analysis. However, the analysis for EF1
was rerun after inclusion of additional data (as requested bysome reviewers) and uncertainty ranges were recomputed.

238

Page 11.10, Table 11.1: It would be useful to insert a footnote in this table indicating thatthe values for EF2 are provided in Table 2.5 of the 2013 Wetlands Supplement. Inventory
United States of America
compilers could refer back to the 2006 Guidelines for EF2 if they don’t read the guidancein the 2019 Refinement carefully.

AcceptedThanks for the suggestion, a footnote was added to refer
the compiler to the 2013 Wetlands Supplement.

7432

5986

5988

4

4

4

11

11

11

237

237

237

Consider changing “form” to “type” as is done on line 220
The use of the term “confounded” is unclear, please consider rewording for improved
clarity.

Comment
VolumeID

8318

4

Chapter

11

From line

237

To line

238

7408

4

11

237

238

5990

4

11

274

278

5992

4

11

344

344

Comment

Country

In Table 11.1 A, an absolute value is determined for N content of residues and dry matter
fractions of harvested in different product, while these values can change based on thecrop cultivar or cropping system (ex. for irrigated or rainfed lands). A results of theresearch in Iran shows that there is significant difference between 1000-grain weight,
grain yield and harvest index of two different wheat cultivars. The type of cultivar canaffect the crop residues and crop residues can affect soil organic carbon (Sadeghi andBahrani, 2009). Halvorson et al. (1999) showed that increased crop residue rates returnedIranto soil in semiarid dry land region of Central Great Plains, USA, accompanied byincreased N rate resulted in increased soil organic carbon levels which contribute toimproved soil quality and productivity, and increased efficiency of carbon sequestration
into the soil (Halvorson et al., 1999). In crop models, the input parameters can be asource of uncertainty (Wang et al., 2005), they should be considered in min and max
range. Therefore, it is suggested that an uncertainty range is considered for cropparameters and indexes based on different cultivars and cropping system (ex. forirrigated or rainfed lands).
Many countries already experience effects of climate change. It should be clarified,whether Figure 3.A.5.1 in Vol. 4 Ch. 3 should be used to stratify wet/dry or, if not, overwhich time period precipitation and potential evapotranspiration should be averaged. Or
should this be updated annually? Vol. 4 Ch. 3 apparently suggests a 30 year average from
Germany
1985 to 2015. However, in Figure 3.A.5.1 Germany is depicted as entirely moist, whereas
data from the German weather service designates some regions (mainly in east
Germany) as dry. (cf. supporting document: Here, the difference instead of the quotient is
depicted). Please revise.
This section is referring the inventory compiler to the 2006 Guidelines, however, there
have been updates to the manure management text and even equation 10.34 (in addition
United States of America
to a new equation 10.34B that estimates FRACloss) in the current version of the 2019refinement, therefore the authors should review the manure chapter in the 2019
Refinement and ensure the guidance is referring to the most updated text/equations.
There are updates to Table 2.6 in the 2019 Refinement relative to crop burning, you
should specify that they should refer to the Table 2.6 in Chapter 2 of the 2019
United States of America
Refinement.

Response

Author's Note

AcceptedExpert-based judgment uncertainty (75%) was added for N
content of above-ground residues and N content of belowground residues.

Noted

The compilers can use their own data to classify the climate
zones. The global dataset presented in Figure 3.A.5.1, Vol.
4, Ch. 3 may be too coarse in resolution to reflect some ofthe variation discussed by the reviewer. Country-specificclassifications can be updated over time, but it is notrecommended to change the climate annually due todroughts and other weather events that deviate from longterm averages.

Noted

The text and equation numbers were correct for therefinement. No edit is needed in the refinement.

AcceptedThank you, we have corrected the cross-referencing.

5994

4

11

399

400

New Table 11.1A: This looks more like an updated Table 11.2 rather than a new Table
11.1

7410

4

11

399

400

In table 11.1A a few values are missing. How should they be handled? E.g., should for(R:S(T)) of rye the value of generic grains be applied? Please specify.

Germany

Accepted

Rejected

Noted

United States of America

Rejected

7412

4

11

399

400

Footnote f: Please specify the definition of root turnover used here. Gill and Jackson(2000, see supporting document) report a turnover of 53 % for grasses (Root turnover =Germany
annual belowground production / maximum belowground standing crop) and also a strong
dependence on annual temperature (Q10 = 1.6).

4784

4

11

590

592

Please add a description such as "conservative or reasonable emission factors with clearJapanscientific rationale should be used if country-specific emission factors are used".

Table 11.1A is a new Table created from Table 11.2 in the2006 guidelines. Its numbering is "11.1" since thenumbering is not specific to the updated table, but rather tothe table that is provided before it in the chapter.
Clarification was added in a footnote as follows ,"No
estimate is available. The most appropriate generic value
can be used based on expert judgment, in absence of more
specific information available to develop a country-specificvalue."
Footnote f explains how the proposed 0.8 +/- 50% wasderived based on root turnover in the range 30 to 50%. The
53% and associated uncertainty found by Gill and Jackson(2000) falls within the uncertainty range of the value in thetable. Temperature dependence of root turnover can beaddressed in higher tier methods, but is to complicated forTier 1.
This is true for any emission factor, i.e., EF values need tobe accurate regardless of the actions that they represent.
This is discussed in the general guidance, Volume I.

Comment
VolumeID

Chapter

4786

4

11

590

592

We would like to add the application of nitrification inhibitor to mitigation option to developJapancountry specific emission factor.

Rejected

7414

4

11

602

604

We suggest to add a remark that emission factors must take into account the losses, i.e.,
in contrast to the Tier-1 emission factors they need to be defined and determined as EF = Germany
Emission / (input - losses).

Accepted with
Modification

Rejected

Rejected

From line

To lineComment

Country

7424

4

11

602

606

In order to ensure in a simple manner that techniques reducing NH3 emissions fromspreading have adequate impact on N2O emissions from soil, EF1 should refer to the N
remaining in the soil (considering N losses due to NH3-N and NO-N emissions) and not tothe amount of N applied to the soil. Referring to the amount of N applied to the soil was
Germany
the basis of the N-flow based approach already used in the IPCC 1996 Guidelines.
However, as the current EF1 is not consistent with this approach, we suggest to modify
EF1 accordingly (e.g. by an IPCC expert judgment, in the case there is no or not enoughdata for a new definition of EF1).

5996

4

11

605

606

This sentence does not provide sufficient guidance for an inventory compiler to adopt an“N-flow principle” approach as mentioned in the paragraph.

7416

4

11

621

621

5158

4

11

621

623

7640

4

11

621

651

7426

4

11

651

652

United States of America

The value of 0.32 mentioned here is different to the value of 0.236 as stated in Table
Germany
11.3. Please revise.
Section 11.2.2.2. The default FracLEACH-(H) is wrong. Replace 0.32 with 0.236 as
Italyreported in Table 11.3.
FracLeach is mentioned to be 0.32 (line 621) but in table 11.3 it is 0.236.
Finland
In case of water-holding capacity (FracLEACH-(H)) it is misleading to use terms like „rainyseason“. This implies that emissions are calculated for periods shorter than a year. If thisGermany
is really intended, the guidance on how to do this in practice is completely missing. Pleaserevise.

Response

Author's Note
Nitrification inhibitor could slow down emissions of NOx
associated with nitrification and denitrification but is not a
mitigation option for NH3 emission. Given that the fractionof N applied that volatilises is a major component of
FracGASM, nitrification inhibitor is expected to have arelatively small influence on FracGASM.
A reference was provided in Section 11.2.1.1 that reflects N
flow through the manure management 'continuum' including
practices that affect direct and indirect N emissions fromsoils. The impacts can be addressed with a Tier 3 method
where the compiler uses a more complex method thattracks N flows rather than the simple EF approach based
on total N input. The corresponding text was therefore
moved to the Tier 3 section.
The authors of the 1996 guidelines who worked on the2006 guidelines changed this approach because the data
underlying Tier 1 EF1 did not subtract the N emitted fromvolatilization. That is to say, the EF was based on the total
N input, and subtracting this N led to a bias in thecalculation. It is not simple to derive an EF based on theflow and reducing the available N as losses occur due tovolatilization, leaching, plant and microbial uptake because
most experiments are not conducting a full accounting of all
N flows. Most measurements of emissions relate thoselosses to the N inputs, and therefore we are constrained todeveloping EF values based on the N inputs. However,such impacts can be addressed at higher tier methods if
there are adequate data or models for this purpose.
It is up to individual countries to develop higher Tiermethodology, including alternative EF and Frac values, toaccount for the N flow effect. A reference was provided in
Section 11.2.1.1 that reflects N flow through the manure
management 'continuum' including practices that affectdirect and indirect N emissions from soils. The impacts canbe addressed with a Tier 3 method where the compiler
uses a more complex method that tracks N flows rather
than the simple EF approach based on total N input. The
corresponding text was therefore moved to the Tier 3
section.

Accepted

Revised as suggested.

Accepted

Revised as suggested.

Accepted

Revised as suggested.
FracLEACH-(H) was calculated mainly from annual data.
Thus both note and table were revised.

Accepted

Comment
VolumeID

Chapter

7428

4

11

651

652

5998

4

11

651

652

From line

To line

7418

4

11

651

652

6000

4

11

726

727

7404

4

11

1151

1278

4908

5156

4

4

11

11

139

139

Comment

Country

FracGASF and FracGASM:
The new defaults (0.112 instead of 0.1 and 0.110 instead of 0.2) are questionable due tothe fact that many (mid-European) countries report totally different country-specific values
Germany
with FracGASF < FracGASM.
In the case a country is reporting NH3 and NOX emissions (CLRTAP), we suggest to
mention that the fractions FracGASF and FracGASM should NOT be used to calculate
indirect N2O emissions from atmospheric deposition.
I think the revised factors properly represent the accumulated evidence published sincethe 2006 guidelines were derived. In particular, the disaggregated factors make sense
United States of America
and are defensible based on results from field studies. The revised uncertainty ranges arealso reasonable and consistent with observations.
Many countries already experience effects of climate change. It should be clarified,whether Figure 3.A.5.1 in Vol. 4 Ch. 3 should be used to stratify wet/dry or, if not, overwhich time period precipitation and potential evapotranspiration should be averaged. Or
should this be updated annually? Vol. 4 Ch. 3 apparently suggests a 30 year average from
Germany
1985 to 2015. However, in Figure 3.A.5.1 Germany is depicted as entirely moist, whereas
data from the German weather service designates some regions (mainly in east
Germany) as dry. (cf. supporting document: Here, the difference instead of the quotient is
depicted). Please revise.
Page 11.27, Table A2-1: There appears to be information on what the letters “A” and “B”
United States of America
are in terms of significance, but what is the “C” for in the “120 < days ≤ 180” row
Several references, which are cited in the text, are missing in the library.
Germany"The essence of the publications by Bouwman, later mentioned (l. 227-228) as therationale for updating EF1 default values is that the N2O emissions from N inputs are aquadratic or exponential - rather than linear - function of N inputs. Accordingly, in thisequation, (FSN + ... + FSOM) * EF1 should be changed to (FSN + ... + FSOM) * EF1a +(FSN + ... + FSOM)^2 * EF1b or exp(EF1a + (FSN + ... + FSOM) * EF1b). Default values
for EF1a and EF1b can be derived from the already quoted Bouwman publications or from
more recent existing publications/calculators updating them such as:
Gerber, J.S., Carlson, K.M., Makowski, D., Mueller, N.D., Garcia de Cortazar-Atauri, I.,
FranceHavlík, P., Herrero, M., Launay, M., O’Connell, C.S., Smith, P., West, P.C., 2016.
Spatially explicit estimates of N2O emissions from croplands suggest climate mitigation
opportunities from improved fertilizer management. Global Change Biology 22, 3383–
3394. https://doi.org/10.1111/gcb.13341
Hillier, J., Walter, C., Malin, D., Garcia-Suarez, T., Mila-i-Canals, L., Smith, P., 2011. A
farm-focused calculator for emissions from crop and livestock production. Environmental
Modelling & Software 26, 1070–1078. https://doi.org/10.1016/j.envsoft.2011.03.014"
Section 11.2.1.3. Paragraph "Crop residue N, including N-fixing crops and forage/ pasturerenewal, returned to soils, (FCR)". The following text could be inserted: as regards Crop
residue N a cross check with the amount of NbeddingMS of the Equation 10.34 "Managed
manure N available for application to managed soils, feed, fuel or construction uses" andItaly
the categories "Field Burning of Agricultural Residues" (3F CRF category - volume 4chapter 5 section 5.2.4 Non-CO2 greenhouse gas emissions from biomass burning),
relative to the amount of agricultural residues that is returned to soils other than theamount of agricultural residues that is removed for other purposes (e.g. bedding) or burnt
should be done. This is important to eliminate the possibility of double counting.

Response

Author's Note

Accepted with
Modification

FracGASM was revised as suggested, while the CLRTAP
reporting can be used for Tier 2 or 3 if a compiler isdeveloping a higher Tier method.

Noted

Thank you for the comment.

Accepted with
Modification

The compilers can use their own data to classify the climate
zones. The global dataset presented in Figure 3.A.5.1, Vol.
4, Ch. 3 may be too coarse in resolution to reflect some ofthe variation discussed by the reviewer. Country-specificclassifications can be updated over time, but it is notrecommended to change the climate annually due todroughts and other weather events that deviate from longterm averages. 'Long-term mean of annual data should be
used' has been added to the text.

AcceptedAnnex 11A.2 was updated, and the text was clarified.

Accepted

References were checked.

Accepted with
Modification

Countries using Tier 1 have aggregated N input data which
are not appropriate for the suggested method. An
exponential method can be addressed at higher tiers bycountries wishing to do so. We added the reference toGerber et al. 2016 into text, after the sentence "Countries
can also consider an exponential response of N2Oemissions to N application by developing country-specificemission factors"

Accepted

Revised as suggested.

Comment
VolumeID

Chapter

7346

4

12

general

9466

4

12

86

106

9468

4

12

86

183

9470

4

12

125

126

9472

4

12

127

128

9474

4

12

From line

127

To line138

Comment

Country

We have identified some inconsistencies in the chapter. In some sections seems that
HWP could apply to wood extracted from different land uses, while in other parts of thechapter it refers only to HWPs from forest land. ACTION: we would appreciate
Spainconsistency across the chapter, preferably providing ways to estimate emissions andremovals from HWP for all land uses (for example, some countries have plantationsclassified as croplands, and wood is coming out from them, they might need methods andapproaches to estimate associated emissions and removals).
Since there is no text copied from the 2006 GLs in this chapter, the reader is left towonder whether the chapter entirely supersedes chapter 12 of vol 4 in the 2006 GLs.
CanadaClarify in the introduction how this chapter is to be used.
The term "CO2 removals " has a special meaning in the context of the HWP pool andshould be clarified at the beginning of the Chapter. Suggest to move the clarification
Canadaprovided for this term in lines 178-183 as a new term/definition under Section 12.2
(Comment from Ana Blondel: This might need to be discussed).
The distinction between Approaches and Methods is very useful. However the sentenceneeds to be corrected to be consistent with text in lines 170-174. Re-write sentence: "Itfollows that different methods could be applied to implement a particular approach andCanadathat the same method can be used in different approaches." - or replace with lines 170174. The fact that the same method can be applied to different approaches is illustrated
by the use of equations 12.2 and 12.3 in both the stock-change and atmospheric flow
approaches.
Suggest: "…it is possible to apply methods that are 'inventory-based', 'flux data-based' or
Canadamixtures of both".
The distinction between "inventory-based" and "flux-based" methods is not practical. The
only real application of an "inventory-based" method is considered in section 12.4.4.2 andCanadais a T3 method, applicable only to HWP pools that are actually located in the reporting
country. In all other cases, some modelling of decay (through half-lives) is necessary toestablish stocks and stock-changes. Delete these lines.

7336

4

12

143

143

Remove references to accounting as they are not relevant to the reporting methodology:“"At the time of writing this text, the approach for reporting on HWP is under consideration
Spain
by the UNFCCC. Accordingly, this guidance does not prejudge whether one particularapproach should be preferred.” This sentence would better fit in a footnote.

9476

4

12

143

144

the sentence "The approach... by the UNFCCC" is prejudging what will the discussions be
about in the climate negotiations. ACTION: delete the sentence, and delete also
Canada"Accordingly" in the following sentence.

Response

Author's Note

Accepted

The chapter has been reviewed to ensure the wording"forests and other wood producing land categories" is usedconsistently through the chapter.

Accepted

Text has been amended for clarity.

Accepted

The text has been moved to definitions to give it more
prominence.

Rejected

The proposed amendment does not improve the existing
text which is consistent with lines 170-174.

Accepted

The text has been revised accordingly.

Accepted with
Modification

This is an established distinction between types of methods
already covered in previous IPCC guidance. The comments
also contradicts other comments requesting further
clarification. However, as an attempt at clarification, we
have amended some terminology where relevant.

Accepted with
Modification

The text has been amended in the light of comments.

Accepted

The text has been revised accordingly.

Comment
VolumeID

9478

4

Chapter

12

From line

149

To line155

Comment

CountryIt’s understood that the guidance must not change HWP approaches or note any
preference but provide guidance for all approaches in the in the 2006 IPCC guidelines.
The simple-decay approach is included in the 2006 IPCC guidelines, but there is a lack of
guidance for this approach in the 2019 refinement. Therefore, edit the text to state that
Canadathere are 4 main approaches that differ in terms of their conceptual framework andsystem boundaries, by adding the ‘simple-decay’ approach to the main list. The ‘simple
decay’ approach shares the same system boundaries with the ‘production’ approach but if
differs in that it focuses on estimating CO2 emissions from the HWP pool, similar in thisrespect to the ‘atmospheric-flow’ approach.

Response

Author's Note
We believe that a significant improvement in this updated
guidance has been to make a clear distinction between
approaches and methods. In terms of approach, the 'simple
decay' concept is identical to the production approach.
Hence, we are maintaining the 'simple decay' concept as
an approach by providing guidance for the production
approach. The distinction is only in terms of methods.

Accepted with
Modification

The 2006 IPCC GL included some discussion of how to
combine variables under the 'simple decay' concept, but noexplicit guidance was provided on calculation methods. In
some places, guidance relevant to the 'simple decay'
concept in the 2006 IPCC GL is identical to that given for
the 'production' approach. It remains the case that there isno basis for providing exclusive methodological guidancefor calculations relevant for the 'simple decay' concept.
However, in the discussion of Tier 3 methods we haveamended the text so that it mentions the possibility ofapplying a country-specific method reflecting the 'simpledecay' concept.

7338

9480

9482

9484

4

4

4

4

12

12

12

12

162

167

170

175

162

ACTION: replace "HWP pools" by "HWP pool". There is only one HWP pool.

Spain

Accepted

We revised the text in the light of the comment.
We believe that a significant improvement in this updated
guidance has been to make a clear distinction between
approaches and methods. In terms of approach, the 'simple
decay' concept is identical to the production approach.
Hence, we are maintaining the 'simple decay' concept as
an approach by providing guidance for the production
approach. The distinction is only in terms of methods.

The simple-decay approach also focuses on estimating CO2 fluxes from HWP. Thereforechange the text to state: (strikethrough is deleted text, red font is new text) “The ‘stockchange’ and ‘production’ approaches are based on the first conceptual framework and the Canada‘atmospheric flow’ and ‘simple decay’ approaches is are based on the second conceptual
framework.”

Accepted with
Modification

174

Very true. Move these lines to replace lines 137-138.

Rejected

The two statements are made in different contexts and it is
not appropriate to replace the first statement with thesecond one.

178

This sentence is extremely confusing because it equates a pool with a stand-alone
reporting category. As pointed out in lines 178-183, C stock changes in a pool that involve
transferring the carbon to or from other pools are not emissions or removals, because
they are not C exchanges with the atmosphere. Reporting C stock changes in such a poolin a stand-alone reporting category incorrectly represents such C stock changes as
emissions or removals. This is what results in the corrections described in lines 558-568, Canada
i.e. correcting for exported wood carbon being wrongly reported as emissions from awood producing land. The IPCC, as a scientific body, should recognize that the HWP
pools cannot materially sequester carbon from the atmosphere and recommend that C
stock changes in HWP pools be explicitly reported within the land producing wood
category and not reported as a stand-alone category. Delete lines 175 to 178.

Rejected

The implication of the proposed deletion is out of scope. It
is not within the mandate of the authors to remove (orrecommend the removal of HWP as a separate element ofreporting. Furthermore, we make no explicit presumption
about HWP being represented as a category separate fromcertain other land use categories. However, we have tried
to further clarify the reasons for referring to CO2 removals
in the context of HWP (see Definitions section 12.2).

169

CanadaWe have inserted text towards the start of the section toclarify that discussion of 'production' approach also applies
to the 'simple decay' concept.

Comment
Volume
ID

9486

6258

9488

4

4

4

Chapter

12

12

12

From line

175

184

185

To line

183

219

188

Comment

Country

While this approach (assuming that carbon stocks in HWP pool are considered as"removals") may be the most common approach among countries when estimating theemissions associated with HWPs for inventories, there are other approaches that are
equally valid - i.e. assuming that the removals are associated with the ecosystem changes
on the forest land and that any harvested material is then transferred to the HWP poolwhere it is considered as a pool of emissions. This is the approach that Canada uses
and, for all intents and purposes, it provides the same results as the approach described. Canada
Would suggest, therefore, the addition of a footnote that indicates: "An alternative
approach is to focus on actual emissions and removals on forest land and in the HWPpool as they occur. Under this approach, the transfer of carbon from the forest to the
HWP pool is not treated as an emission (as it is not released to the atmosphere). Rather,
the transfer creates a pool of HWPs from which emissions are then estimated as theyoccur.
The text implies that countries reliant upon FAO data for HWP may assume that there isno net change in carbon stocks stored in 'other industrial roundwood', due to theunreliability of activity data in this respect. However, it should also be described as goodpractice for countries to include within the scope of HWP all roundwood removals from theforest where reliable data is available. For example, in Australia national statistics offer
more comprehensive information on industrial roundwood and fuelwood, and these pools
are included in HWP reporting. This good practice requirement would facilitate a wood
products classification that is consistent with reporting of carbon in forest lands and otherland uses, as described in lines 203-207. This good practice requirement should also be
clarified in the diagrams in Appendix 12A. Currently there is a lack of clarity regarding thelink between carbon removals from the forest, and the later production of the three semiAustralia
finished product pools. Based on the discussion in lines 1026-1038, the guidelines
suggest an inconsistent approach – excluding products which are not part of the threedefined pools semi-finished product pools (i.e. other industrial roundwood, and fuelwood,
if not reported in Equation 2.11). The best way to achieve the principles of avoidance ofomissions or double-counting, and compatibility with other stock change reporting as
described in lines 203-207, is to ensure conservation of carbon mass between forest andwood products reporting. All carbon transfers from the forest, that are not emitted and notreported in Forest lands, should be included as part of HWP reporting. For example, using
the Gain-loss method in Chapter 2.3.1.1, reporting of carbon stocks in forest land
accounts for all roundwood removals, plus fuelwood (See equations 2.11, and 2.20).
Harvested wood products reporting should therefore include all other wood products (i.e.
based on Figure 12.2 this includes all industrial roundwood).

Change to state the 4 approaches, which includes the ‘simple-decay’ approach.

CanadaResponse

Author's Note

Rejected

The comment addresses issues with the presentation of
results for emissions and removals, but the proposedchanges cannot be addressed in the context of thisguidance.

Accepted with
Modification

The proposed use of country-specific data is a Tier 2 orTier 3 method which is supported in the guidance.
Furthermore, the request to modify the approaches would
mean that the existing approaches would not be maintained
which is out of scope. Hence, we have included anelaborated explanation that other industrial roundwood istreated in Tier 1 and Tier 2 methods on the basis of theassumption of a steady-state HWP pool and we have
explained why this HWP commodity class is treated in thisway. We have also clarified that improved treatment ofother industrial roundwood is possible as part of a Tier 3
method.
See revised text in Section 12.4.1.1 and in particular the
discussion of other industrial roundwood in the sub-section,“Definitions for semi-finished wood product commodities”.

Accepted with
Modification

We believe that a significant improvement in this updated
guidance has been to make a clear distinction between
approaches and methods. In terms of approach, the 'simple
decay' concept is identical to the production approach.
Hence, we are maintaining the 'simple decay' concept as
an approach by providing guidance for the production
approach. The distinction is only in terms of methods.
We have inserted text towards the start of the section toclarify that discussion of 'production' approach also applies
to the 'simple decay' concept.

Comment
Volume
ID

9490

9492

9494

4

4

4

Chapter

12

12

12

From line

202

203

207

To lineComment203

Add a paragraph to provide an overview of the ‘simple decay approach’. Suggest
including text in the red font below: The ‘simple decay’ approach estimates fluxes of CO2
to the atmosphere from the HWP pool from wood harvested in the reporting country.
Therefore the “producing country” reports CO2 emissions and removals from HWP. To
clarify how CO2 emission and removal estimates are presented in combination with theForest land and other wood producing land categories suggest adding the following text in
red font: There is an important link between forests and other wood producing land
Canadacategories and the HWP pool. Thus the approach chosen to estimate emissions andremovals from HWP impacts estimation for the land categories. For example, with the‘production’ and ‘stock-change’ approaches carbon stock changes in forests and otherwood producing land categories and the HWP category are estimated separately.
Conversely, with the ‘atmospheric flow’ and ‘simple-decay’ approaches HWP is treated asa pool from forests and other wood producing land categories with emissions occurring as
HWP is produced and consumed.

Accepted with
Modification

Suggest adding text to this paragraph to highlight the important link between GHG
estimates from HWP and those from forests and other wooded land and the need toinsure consistency and transparency.

Accepted with
Modification

207

208

Change both sentence to state the 4 approaches.

Country

CanadaCanadaResponse

Author's Note
The proposed text is based on a misinterpretation of thesystem boundary of the 'simple decay' concept/approach.
We believe that a significant improvement in this updated
guidance has been to make a clear distinction between
approaches and methods. In terms of approach, the 'simple
decay' concept is identical to the production approach.
Hence, we are maintaining the 'simple decay' concept as
an approach by providing guidance for the production
approach. The distinction is only in terms of methods.
We have inserted text towards the start of the section toclarify that discussion of 'production' approach also applies
to the 'simple decay' concept.

Accepted with
Modification

The text has been amended in the light of the comment as
part of guidance for the 'production' approach.
We believe that a significant improvement in this updated
guidance has been to make a clear distinction between
approaches and methods. In terms of approach, the 'simple
decay' concept is identical to the production approach.
Hence, we are maintaining the 'simple decay' concept as
an approach by providing guidance for the production
approach. The distinction is only in terms of methods.
We have inserted text towards the start of the section toclarify that discussion of 'production' approach also applies
to the 'simple decay' concept.

7340

4

12

208

212

We think that this paragraph goes beyond what is needed for GHG national inventories. It
Spain
is out of the scope of the refinement. ACTION: delete paragraph.

Rejected

The statement in the paragraph is not out of scope. It
merely explains a technical fact related to the application of
the approaches. Furthermore, a very similar statement was
included in the IPCC 2006 GL (please see page 12.5: "Theapproaches that have been identified are mutually
exclusive in the sense that a global or regional estimate ofannual HWP Contribution would only be correct if all thedifferent countries provided estimates using the same
approach ").

Comment
VolumeID

9496

4

Chapter

12

From line

210

To line

211

6280

4

12

213

219

9498

4

12

213

219

9500

4

12

223

227

9502

4

12

236

236

6274

4

12

267

269

Comment

Use of the same approach for estimating HWP emissions is ONE way to avoid double orzero-counting, but it is not the "only" way - as is suggested here. Rather, countries canstill avoid double and zero-counting through a number of specific combinations ofapproaches - e.g. production and simply decay; stock-change and atmospheric flow.
Suggest that this be added to the explanation.

Country

CanadaInstantaneous oxidation is a Kyoto Protocol accounting construct. This concept deals withthe allocation of emissions to different activities or land uses, and between countries, forpolicy purposes (E.g. preferring completeness over the risk of double-counting). The
concept of ‘instantaneous oxidation’ is not relevant to the accuracy or estimation ofemissions – clearly this assumption is inaccurate in almost all cases of forest harvesting(compared to, for example, deforestation). However, as the IPCC has rightly noted in lines
Australia
405-410, accounting by instantaneous oxidation is consistent with previous IPCC
guidance regarding no net change in carbon stock. The concept of steady state pool is an
assumption related to the estimation of emissions – like all T1 assumptions, this may not
be accurate in all cases but can be improved upon using higher tier methods. The
guidelines should avoid prescribing accounting approaches and should focus on theappropriateness and accuracy of estimation methodologies.
This text explains that where the assumption of ‘instantaneous oxidation’ is applied that
CO2 emissions associated with harvested biomass are included implicitly as part of theCO2 emissions and removals from above-ground biomass carbon pools. However, this is Canada
also true when the stock-change’ and ‘production’ approaches are applied. Therefore edit
text to clarify this issue.
Long complex sentence. Perhaps simplify e.g. 223: "…and the data used to estimate…";
Canada227: delete 'and relates'. Typo "national borders".
To enhance clarity, finish the sentence " …countries might need to decide not todistinctly report on HWP, implicitly reporting their HWP emissions as part of land
Canadamanagement emissions and removals."
Figure 12.1 - Guidance on the use of different tier methods should be consistent with
Volume 1, or deferred to UNFCCC for negotiation as part of reporting guidelines (e.g.
para 37 of Annex I reporting guidelines in Decision 24/CP.19). Does this ‘default’assumption represent a T1 assumption (comparable to soil carbon under forest land
Australia
remaining forest land) or a different (lower) tier? How would an ERT be expected tointerpret this guidance? For example, under the ‘instantaneous oxidation’ assumption –are emissions and removals in the HWP pool to be considered “not estimated”, “notoccurring” or “not applicable”?

Response

Author's Note

Rejected

It is not possible to accommodate this request. First of all,as explained in responses to other comments here, interms of approaches, the production approach and thesimple-decay approach are effectively the same approach.
We have clarified that the simple-decay concept is acombination of the production approach in conjunction witha specific calculation method. We believe it is crucial to
avoid confusing approaches with methods. Hence, it isunsurprising that the production approach applied by one
country in combination with what is effectively the
production approach applied in another country does notlead to double-counting or non-counting of emissions. In
the case of the other example cited by the reviewer (thestock-change approach applied by one country in
combination with the atmospheric flow approach applied byanother country) we cannot agree that this would avoid
double-counting or non-counting of emissions. For
example, if a producer country applied the stock-change
approach and exported a significant quantity of woodfeedstock used for energy purposes in a consuming
country that applied the atmospheric flow approach, thiswould lead to double-counting of emissions.

Accepted with
Modification

The discussion in this section has been amended in thelight of the comment

Accepted with
Modification

The discussion in this section has been amended in thelight of the comment

Accepted

Editorial

Accepted with
Modification

Cross-reference to the relevant section has been added.

Accepted with
Modification

The text has been modified in the light of the comment.

Comment
Volume
ID

7342

6248

7344

4

4

4

Chapter

12

12

12

From line

298

345

353

To lineComment

Country

Spain

310

ACTION: move definitions to glossary.

351

The guidelines should also note that implementing the production approach requires
additional information on how exported products are used by other countries to whichdomestic wood products are exported. For example, are exported woodchips being used
Australia
in paper production, in wood panel production, or as an energy feedstock? This will
influence the choice of half-life and other applicable decay parameters for different
streams of exported products.

400

6282

4

12

401

402

6418

4

12

403

425

6272

4

12

403

425

ACTION: move definitions to glossary.

Spain

Instantaneous oxidation is a Kyoto Protocol accounting construct. This concept deals withthe allocation of emissions to different activities or land uses, and between countries, forpolicy purposes (E.g. preferring completeness over the risk of double-counting). The
concept of ‘instantaneous oxidation’ is not relevant to the accuracy or estimation ofemissions – clearly this assumption is inaccurate in almost all cases of forest harvesting(compared to, for example, deforestation). However, as the IPCC has rightly noted in lines
Australia
405-410, accounting by instantaneous oxidation is consistent with previous IPCC
guidance regarding no net change in carbon stock. The concept of steady state pool is an
assumption related to the estimation of emissions – like all T1 assumptions, this may not
be accurate in all cases but can be improved upon using higher tier methods. The
guidelines should avoid prescribing accounting approaches and should focus on theappropriateness and accuracy of estimation methodologies.
The IPCC 2013 KP Supplement guidance on when to report HWP separately should not
be referred to in this context. In relation to the assumption of ‘instantaneous oxidation,’the KP supplement does not represent scientific data, but simply implements therequirements of Decision 2/CMP.7 and Decision 2/CMP.8 (see for example Figure 2.8.1
Australia
in IPCC (2014)). For example Decision 2/CMP.7 requires that HWP from deforestation
events and HWP used for energy purposes must always be accounted using
instantaneous oxidation – which is inconsistent with the guidance in this refinement. The
accounting approaches should be left to negotiations and are not relevant for the IPCC
Guidance, and the reference to the KP supplement should be removed from this section.
The text on line 403 commences “This section provides guidance on when it is in line withgood practice to not report CO2 emissions and removals from HWP separately”. It is
possible to interpret the sub-section as saying that instantaneous oxidation is the default
assumption (although this is questionable, as it is highly unlikely in practice), and should
be assumed if harvested wood biomass is used for energy purposes, if no activity data
Australia
are available, or if the magnitude of the relevant emissions and removal is small (itsapplication in these three cases is sensible). Presumably, other than those specificsituations, the ‘Stock-change’, ‘Production” or “Atmospheric flow’ approaches should betaken, but this is not made clear. Given this, the reference to IPCC 2006 GL, Section
12.2.1, and IPCC 2014, Section 2.8.2, for further guidance is not helpful.

Response

Author's Note

Rejected

It is important that definitions of specific relevance in thecontext of HWP are included directly in this chapter.
Sometimes this is necessary to clarify a specific meaning in
the context of HWP, which may not apply more generally.

Rejected

The requested guidance is already included in the relevant
sections.

Rejected

It is important that definitions of specific relevance in thecontext of HWP are included directly in this chapter.
Sometimes this is necessary to clarify a specific meaning in
the context of HWP, which may not apply more generally.

Accepted with
Modification

The section has been amended in the light of the comment.
See latest text in Sections 12.4.1 and 12.4.1.2 and to someextent Section 12.4.1.1.

Accepted with
Modification

The section has been amended in the light of the comment.
See latest text in Sections 12.4.1 and 12.4.1.2 and to someextent Section 12.4.1.1.

Accepted with
Modification

The section has been amended in the light of the comment.

Comment
VolumeID

Chapter

6278

12

4

From line

403

To lineComment

Response

Author's Note

425

The text on line 403 commences “This section provides guidance on when it is in line withgood practice to not report CO2 emissions and removals from HWP separately”.
However, the guidance presented is hard to interpret, and it is not clear how much of theguidance is new to these draft 2019 guidelines. I interpret the sub-section as saying that
instantaneous oxidation is the default assumption (although this is questionable, as it ishighly unlikely in practice), and should be assumed if harvested wood biomass is used forAustralia
energy purposes, if no activity data are available, or if the magnitude of the relevant
emissions and removal is small (its application in these three cases is sensible).
Presumably, other than those specific situations, the ‘Stock-change’, ‘Production” or“Atmospheric flow’ approaches should be taken, but this is not made clear. Given this, thereference to IPCC 2006 GL, Section 12.2.1, and IPCC 2014, Section 2.8.2, for further
guidance is not helpful.

Accepted with
Modification

The section has been amended in the light of the comment.
See latest text in Sections 12.4.1 and 12.4.1.2 and to someextent Section 12.4.1.1.

Guidance on the use of different tier methods should be consistent with Volume 1, ordeferred to UNFCCC for negotiation as part of reporting guidelines (e.g. para 37 of Annex
I reporting guidelines in Decision 24/CP.19). Does this ‘default’ assumption represent a
Australia
T1 assumption (comparable to soil carbon under forest land remaining forest land) or adifferent (lower) tier? How would an ERT be expected to interpret this guidance? For
example, under the ‘instantaneous oxidation’ assumption – are emissions and removals in
the HWP pool to be considered “not estimated”, “not occurring” or “not applicable”?

Accepted with
Modification

The text has been amended in the light of the comment.
See latest text in Sections 12.4.1 and 12.4.1.2 and to someextent Section 12.4.1.1.

Accepted with
Modification

The text has been amended in the light of the comment.
See latest text in Sections 12.4.1 and 12.4.1.2 and to someextent Section 12.4.1.1.

Rejected

The comment addresses issues with the presentation of
results for emissions and removals, but the proposedchanges cannot be addressed in the context of thisguidance.

Accepted with

The text has been revised in the light of the comment.

Accepted

The paragraph has been revised in the light of thecomment.

Accepted

The paragraph has been revised in the light of thecomment.

6276

4

12

416

423

6284

4

12

418

418

9504

4

12

432

436

9506

4

12

492

493

6002

4

12

505

507

9508

4

12

505

507

Country

It seems you should be more explicit about availability of data for Tier 1. Suggest you say(i.e. If no activity data are available from FAOSTAT or other sources as needed for Tier 1 Australia
estimates.).
Recalling the very useful clarification of lines 178-183, a similar caveat should be made in
relation to equation 12.1: when C stock changes from the HWP pool are reported in astand-alone category, they are equated to net emissions or removals. The outcome is that Canada
removals are wrongly attributed to the HWP "category", AND the emissions are wrongly
attributed to the wood producing land category.
Replace "CO2 emissions and removals from HWP" with "C stock changes in HWP".
CanadaI raised this as an issue in the comments to the FOD - this sentence is incomprehensible
and needs rewriting for clarity. If I understand it correctly, the issue raised is that as data
United States of America
quality on HWP production improves, calculations on C stock changes that rely on thosehistorical datasets of varying quality may result in biased estimates.
This sentence should be clarified, it’s unclear as written.

CanadaComment
VolumeID

9510

4

Chapter

12

From line

545

To line593

Comment

Country

The ‘simple-decay’ and ‘atmospheric-flow’ approaches both estimate CO2 fluxes.
Therefore, remove the specific identification of the ‘Atmospheric flow’ approach from thetitle and change the title of this section to: ESTIMATING CO2 -FLUXES ASSOCIATED
WITH HARVESTED WOOD PRODUCTS. This section could then provide clearer
Canadadistinction from the approaches based on carbon stock change estimates. Edit text to not
only summarize the ‘atmospheric flow’ approach but also explain overall construct for flux
based approaches (‘simple decay’ and ‘atmospheric flow) that estimate net removals
from Forest Land and CO2 release from the HWP pool.

Response

Accepted with
Modification

Author's Note
We believe that a significant improvement in this updated
guidance has been to make a clear distinction between
approaches and methods. In terms of approach, the 'simple
decay' concept is identical to the production approach.
Hence, we are maintaining the 'simple decay' concept as
an approach by providing guidance for the production
approach. The distinction is only in terms of methods. The
2006 IPCC GL included some discussion of how to
combine variables under the 'simple decay' concept, but noexplicit guidance was provided on calculation methods. In
some places, guidance relevant to the 'simple decay'
concept in the 2006 IPCC GL is identical to that given for
the 'production' approach. It remains the case that there isno basis for providing exclusive methodological guidancefor calculations relevant for the 'simple decay' concept.
The discussion being referred to in this comment isconcerned with methods, not approaches. However, in thediscussion of Tier 3 methods we have amended the text sothat it mentions the possibility of applying a country-specificmethod reflecting the 'simple-decay' concept.

9512

9514

4

4

12

12

551

558

568

568

What is the issue that this text is intended to clarify ? I have read it several times. Whatpossible misunderstanding about the atmospheric flow approach are you trying to correct.
CanadaWhy does the analyst need this explanation to prepare an estimate? Is the text forsomeone trying to decide if the AF approach fits their policy interests? Please clarify
your intent for this text.
This entire paragraph and equation 12.5 aim to correct for wrongly reporting C stockchanges as emissions and removals - but will not achieve the objective of reporting
emissions and removals where and when they actually occur because the correction
ought to be made also to the land category, not only the HWP pool. A more transparent
Canadaapproach (although not quite reflecting yet where and when emissions occur) would be todefine a parameter InflowCl in equation 12.3 and provide guidance to calculate inflow fromthe sum of wood harvested in the country minus exports plus imports. This will be simpler
and much more transparent then the complicated corrections in equation 12.5.

Accepted

We have clarified that our intent is to explain how Equation
12.5 works.

Rejected

The intention of the comment is unclear, but would appear
to misunderstand the purpose of the existing paragraph,
which is to implement the calculations for the atmosphericflow approach.

Comment
VolumeID

9516

4

Chapter

12

From line

594

To line745

Comment

Country

Include a section on compilation of activity data required for the ‘simple decay’ approach. Canada

Response

Accepted with
Modification

Author's Note
We believe that a significant improvement in this updated
guidance has been to make a clear distinction between
approaches and methods. In terms of approach, the 'simple
decay' concept is identical to the production approach.
Hence, we are maintaining the 'simple decay' concept as
an approach by providing guidance for the production
approach. The distinction is only in terms of methods. The
2006 IPCC GL included some discussion of how to
combine variables under the 'simple decay' concept, but noexplicit guidance was provided on calculation methods. In
some places, guidance relevant to the 'simple decay'
concept in the 2006 IPCC GL is identical to that given for
the 'production' approach. It remains the case that there isno basis for providing exclusive methodological guidancefor calculations relevant for the 'simple decay' concept.
However, in the discussion of Tier 3 methods we haveamended the text so that it mentions the possibility ofapplying a country-specific method reflecting the 'simpledecay' concept.

6580

4

12

602

602

Noted

Editorial. It seems to be a mistake on the allocation to thechapter. TSU to check.

758

Table 12.3, lines 757-8, presents default half-lives of the various HWP categories, derived
from IPCC 2014. Later text in Section 12.6.1, lines 1102-5, then says “Losses of HWP in
use are assumed to result in CO2 emissions to the atmosphere, with no explicit
representation of the subsequent retention of disposed wood in SWDS and eventual CO2
emissions from this pool. Therefore, CO2 emissions from wood in SWDS are included
implicitly in the CO2 emissions due to losses of carbon from the HWP pool in use asreported in the AFOLU sector.” This could be taken to imply that the long decay half-life of Australia
the portion of HWP that is transferred to solid waste disposal sites (SWDS) is somehow
incorporated into the default half-lives of the various HWP categories listed on Table 12.3.
However, it is not made clear that this is the case, and the later section therefore does notprovide the clarification that the title implies. The text needs to be expanded to explain
explicitly how the decay half-life of those HWP that are in SWDS is incorporated in theemissions calculations; if that has not occurred, the text needs to explain why not.

Accepted

The statement that is being referred to in the comment isincorrect and has been deleted from the text.

777

Please consider adding: It is also possible to use country-specific data before 1961 inorder to estimate the total existing HWP pool, if the data is considered to give a more
precise estimate of the HWP pool. It is considered that the products entering the pool
prior to 1900 would be insignificant (IPCC 2006)

Rejected

This is not the section of the guidance to address thissubject. However, we have elaborated the discussion of theuse of historical data in the relevant Section 12.4.2.

12

690

699

6246

4

12

720

721

7642

4

12

12

757

777

Сan you please give an explanation why in the equation uses imported HWP,when in theapproach "production" the HWP pool consists of all products made from wood that is
Russian Federation
harvested domestically, i.e. those products that are consumed domestically and also
those products that are exported and used in other countries.
The Reference to Australia should read "(Commonwealth of Australia, 2018)". The report
Australia
is published by Australia's Department of Environment and Energy.

We have checked and the numbers are consistent.
We have clarified that imports are included in the equation,
because this needed to exclude imports from the result.

4

4

United Kingdom (of Great
Noted
Britain and Northern
Accepted

6786

6270

footnote 8 seems not consistent if it should be understood as the source for the density

FinlandComment
VolumeID

Chapter

9518

4

12

804

804

4788

4

12

909

909

6250

4

12

939

939

9520

4

12

939

974

9522

4

12

941

941

4790

4

12

942

942

4792

4

12

948

949

4794

4

12

959

959

7348

4

12

From line

975

To line

1068

9524

4

12

975

1086

6004

4

12

980

981

Comment

Country

In the text "It is a modification of RSL by seven factors" it is not clear which "sevenfactors" this text is referring to until
going into the ref "ISO 15686-8:2008" and looking later on to the example given in Box
12.2, where these seven factors are explicitly listed. In order to facilitate the use of thisCanadaguidance and make the text more straightforward, suggest to:1) add some additional text in this line referring more clearly to the seven factors A to G
provided in ref "ISO 15686-8:2008" and/or 2) suggest the reader to look into Box 12.2 fora theoretical example using these seven factors.
There is no “Section 12.5.1.1”. Remove “Section 12.5.1.1”.
Japan
Change title to “Carbon Stock Change’ methods to improve clarity as it’s confusing to call
Australia
these “inventory methods”.
This draft passage sound confused. HWP Stock Inventory methods are synonymous withthe consumption-based approaches of stock-change and atmospheric flow. It would be
Canadabeneficial to make this point directly.
Clarify "…relevant only for HWP that are actually located in the reporting country andCanadacould be used…"
There is no “Figure 12.3”. Remove “Figure 12.3”.
Japan
Request to add Japan as the example of stock inventory methods. The sentence should
be changed to “Examples of such inventories are reported in Gjesdal et al. (1996) forJapan
Norway, in Pingoud et al., (2001) and Statistics Finland (2010) for Finland and Japan’s
2018 National Inventory Report.”"inventories themselves" or "inventory itself"?
Japan

Authors are to be commended for this new section that provides much needed clarity on a
subject matter of growing relevance. However, and in keeping with the principle oftransparency and comparability, the IPCC should go one step further and recommend as Spain
good practice to report emissions from bioenergy explicitly and separately in all HWP
approaches.

we don't think this section belongs to AFOLU chapter. In addition, we don't think it has a
relevant effect in total emissions and removals, and it is only a difference in the time
Canadaemissions/removals are accounted for. We believe that this section creates excessive
burden for inventory compilers, data are not available in most countries and it will
increase uncertainties in inventories. ACTION: delete section 12,5
In my comments on the FOD, I said I thought the draft needed more information on
treatment of bioenergy emissions. I see that the SOD now contains a section dedicated toUnited States of America
this topic, a welcome development. However, there are still some aspects that are notvery clear.

Response

Author's Note

Accepted

The text has been revised accordingly.

Accepted
Accepted with
Modification

Editorial

Accepted

The wording has been amended for clarity.

Accepted with
Modification
Accepted withAccepted with
Modification
Accepted

Rejected

Rejected

Noted

We have revised the text in the light of the comment.

We have revised the text in the light of the comment.
The wording has been amended for clarity.
Japan's method is classified as a combined HWP stock
inventory and flux data method. Text has been amended in
the light of the comment.
Editorial
The proposed amendment is out of scope. We, theauthors, have no mandate to prescribe what countries
should or should not report, and in what way. This is amatter for negotiations amongst countries. We have gone
as far as our mandate allows, i.e. to clarify where CO2
emissions from the burning of wood for energy purposes
are reported, according to the available approaches andmethods. Please also see three paragraphs included at endof Section 12.3.2. Note that these statements are
consistent with a similar statement included in the 2006 GL.
The section simply describes factually where thecontributions are included in estimates and points to therelevant sections of guidance.

Comment
VolumeID

Chapter

From line

To lineComment

Country

6006

4

12

988

991

This paragraph is critically important. It could benefit by including a statement that clearly
indicates that the implicit inclusion of bioenergy CO2 in the AFOLU sector rather than
United States of America
Energy does not imply any particular conclusions about the GHG implications ofbioenergy (e.g., the "carbon neutrality" of bioenergy).

6008

4

12

993

993

Recommend revise sentence to read as: "This is to avoid the possibility of double
counting these emissions in two or more inventory sectors because they are alreadyincluded in the AFOLU chapter".

6260

4

12

994

1038

United States of America

The guidelines suggest that “Harvested wood biomass used directly as energy feedstock”
in Table 12.5 should not sit within the system boundary of harvested wood products.
However, how are these such feedstocks to be distinguished from other fuelwood
reporting? Fuelwood removals from forest and other land uses should be reported as partof Equation 2.11 under the Gain-loss method. For example in Australia, energy use ofAustralia
wood products is distinguished from fuelwood in Equation 2.11 based on residential orindustrial uses - with industrial wood product use included in the Harvested Wood
Products category. Explicit reporting of energy use of wood products (e.g. as part ofEquation 2.11) would improve transparency and accuracy of reporting, and avoid doublecounting or omissions.

Response

Author's Note

Rejected

The purpose of the guidance is to explain how to calculate
CO2 emissions and removals associated with HWP,
including wood biomass feedstocks used for energy
purposes, where these are included explicitly in an"approach", or implicitly elsewhere. The guidance does nottake a pre-judged view on the magnitude of emissions or
removals associated with any type of activity in any sector,
including the LULUCF sector, and including harvested
biomass used for products, including for energy purposes.
The requested inclusion of this sentence may appear to be
simply stressing this point. However, apart from stating
something that should be self-evident and therefore notneeded, the very inclusion of this apparently "neutral"sentence in itself draws attention to the question(argument) as to whether GHG emissions from bioenergy
are significant, or whether bioenergy can be considered"carbon neutral". In this respect, we believe that theinclusion of this sentence would be unhelpful andinappropriate. It could even lead some readers to infer thatthe guidance is expressing some sort of view on this issue.

Accepted

Editorial

Rejected

The table makes no judgements about where harvested
wood biomass used directly as energy feedstock should bereported. It simply clarifies where quantities are estimated,depending on the chosen approach. We note the request at
the end of the comment, but it is not possible to address
this as part of the current update. Specifically, we as
authors, have no mandate to prescribe what countries
should or should not report, and in what way. This is amatter for negotiations amongst countries. We have gone
as far as our mandate specified, i.e. to clarify where CO2
emissions from the burning of wood for energy purposes
are reported, according to the available approaches andmethods. Please also see three paragraphs included at endof Section 12.3.2. Note that these statements are
consistent with a similar statement included in the 2006 GL.

Comment
Volume
ID

6254

9526

4

4

Chapter

12

12

From line

1021

1021

To line

1025

1024

Comment

Country

Table 12.5 is helpful, but the explanation could go into even more detail. The table does
not confront the core problem – that countries using different approaches may doublecount or fail to count emissions at all. Would it be possible to make a *new* table that has Australia
every possible pairing of approaches, to show how biomass used as energy, and biomass
used as feedstock for semi-finished HWP, would be counted, or not counted?

This table is very informative. Please include a column for the ‘simple decay’ approach.

CanadaResponse

Author's Note

Rejected

Out of scope of the 2019 Refinement, because theguidance is about how to estimate, not about the
implications of choosing different approaches. The purposeof this guidance is to provide advice on how to calculate
emissions and removals, given the approaches that havebeen specified. It is important that we remain neutral withregard to the merits or drawbacks of any given approach.
Choices and decisions about the selection of approaches
are a matter for individual countries and negotiations
between them. It is inappropriate for us to influence
countries by expressing value judgements about thesechoices and decisions. We have gone as far as we can, by
highlighting that choices made by different countries could
lead to non-counting or double-counting of emissions please see three paragraphs included at the end of Section
12.3.2. The statement made is consistent with a similar one
included in the 2006 GL.

Accepted with
Modification

We believe that a significant improvement in this updated
guidance has been to make a clear distinction between
approaches and methods. In terms of approach, the 'simple
decay' concept is identical to the production approach.
Hence, we are maintaining the 'simple decay' concept as
an approach by providing guidance for the production
approach. The distinction is only in terms of methods.
We have inserted text in section 12.3 to clarify that
discussion of 'production' approach also applies to the'simple decay' concept.

9528

9530

9532

4

4

4

12

12

12

1028

1035

1071

1028

1037

1078

Text "(i.e. as part of losses from above ground standing biomass)" should differentiate thecase of residues burnt on site. Suggest to replace by: "(i.e. as part of losses from above
Canadaground standing biomass, and as part of biomass burning emissions if the CO2 emissions
from residues burnt on site are not included in the biomass losses)".
Text "(i.e. as part of losses from above ground standing biomass)" should consider thecase of some countries reporting these emissions from the HWP pool. Suggest to replace
by: "(i.e. as part of losses from above ground standing biomass or as part of losses from Canada
the HWP pool within the same year of harvest for those countries using AD/methods thatallow this differentiation".
This section (12.5.2) would benefit from further explanation as to why CO2 emissions arereported in the AFOLU sector, whereas non-CO2 emissions are reported in the Energy
CanadaSector, as the reason for this is not clear from the existing text.

Accepted with
Modification

We have revised the text in the light of the comment.

Rejected

The proposed amendment does not reflect the intention of
the Table and following text (i.e. not to provide methods,
but to clarify the implications of applying different
approaches).

Accepted with
Modification

It is the convention that non-CO2 emissions are estimatedin the Energy sector and that CO2 emissions are estimatedin the AFOLU sector (See Volume 1, Chapter 8).

Comment
VolumeID

Chapter

6420

4

12

1102

1105

6252

4

12

1102

1120

6788

4

12

1105

1105

Please give a link to AFOLU sector where it is reported

1125

An additional step on calculating the outflow is to subtract the quantum of carbon
estimated to be emitted from anaerobic wood decay as methane from the waste sector,
so as to avoid double-counting of waste sector emissions. This does not include any
methane captured and combusted at the landfill site, which should continue to beconsidered an emission from HWP in SWDS.

6256

9534

4

4

12

12

From line

1115

1269

To line1271

Comment

Country

Response

Author's Note

Accepted with
Modification

The text revised according to the comment. Reference to“information” item has been deleted.

Accepted with
Modification

The text revised according to the comment. Reference to“information” item has been deleted.

Russian Federation

Accepted with
Modification

Reference to AFOLU deleted since it refer to the current
report and is not needed

Australia

Accepted with
Modification

The text has been amended in the light of the comment.

Table 12.3, lines 757-8, presents default half-lives of the various HWP categories, derived
from IPCC 2014. Later text in Section 12.6.1, lines 1102-5, then says “Losses of HWP in
use are assumed to result in CO2 emissions to the atmosphere, with no explicit
representation of the subsequent retention of disposed wood in SWDS and eventual CO2
emissions from this pool. Therefore, CO2 emissions from wood in SWDS are included
implicitly in the CO2 emissions due to losses of carbon from the HWP pool in use asreported in the AFOLU sector.” This implies that the long decay half-life of the portion of Australia
HWP that is transferred to solid waste disposal sites (SWDS) is somehow incorporated
into the default half-lives of the various HWP categories listed on Table 12.3. However, it
is not clear that this is the case, and the later section therefore does not provide theclarification that the title implies. The text needs to be expanded to explain explicitly how
the decay half-life of those HWP that are in SWDS is incorporated in the emissions
calculations; if that has not occurred, the text needs to explain why not.
The description of SWDS as an “information item” is inappropriate. It is a matter for the
Conference of the Parties which items are included in CRF reporting. The assumptions
Australiaaround end of service life products being ‘instantaneously oxidised’ is a Kyoto Protocol
accounting construct. The inclusion of HWP in SWDS is of increasing relevance to reflect
recycling of paper products and increasing use of waste-to-energy etc.

Change from three to four approaches, and include the ‘simple-decay’ approach in the list. Canada

Accepted with
Modification

We believe that a significant improvement in this updated
guidance has been to make a clear distinction between
approaches and methods. In terms of approach, the 'simple
decay' concept is identical to the production approach.
Hence, we are maintaining the 'simple decay' concept as
an approach by providing guidance for the production
approach. The distinction is only in terms of methods.
We have inserted text in section 12.3 to clarify that
discussion of 'production' approach also applies to the'simple decay' concept.

9536

4

12

1271

1278

Edit text to clarify that the ‘production’ and ‘stock-change’ approaches focused on
estimating changes in carbon stocks of HWP pools while the ‘atmospheric-flow’ and‘simple-decay’ approaches focus on estimating emissions/fluxes from HWP pools.

CanadaAccepted with
Modification

The requested clarification has been included more
prominently in Section 12.3.

Comment
VolumeID

Chapter

From line

To lineComment

Country

Response

Author's Note
We have deleted the phrase "so-called".

9538

4

12

1275

1278

Describing it as a “so-called” ‘simple-decay’ approach is misleading. The 2006 IPCC
guidelines included guidance for generating inventory estimates using the ‘simple-decay’approach. Therefore, this refinement should build upon this guidance.

CanadaAccepted with
Modification

We believe that a significant improvement in this updated
guidance has been to make a clear distinction between
approaches and methods. In terms of approach, the 'simple
decay' concept is identical to the production approach.
Hence, we are maintaining the 'simple decay' concept as
an approach by providing guidance for the production
approach. The distinction is only in terms of methods. The
2006 IPCC GL included some discussion of how to
combine variables under the 'simple decay' concept, but noexplicit guidance was provided on calculation methods. In
some places, guidance relevant to the 'simple decay'
concept in the 2006 IPCC GL is identical to that given for
the 'production' approach. It remains the case that there isno basis for providing exclusive methodological guidancefor calculations relevant for the 'simple decay' concept.
However, in the discussion of Tier 3 methods we haveamended the text so that it mentions the possibility ofapplying a country-specific method reflecting the 'simpledecay' concept.

6262

4

12

1296

1310

It should be noted that this is the system boundary that most closely aligns with economic
data produced under the System of National Accounts, e.g. GDP reporting. This boundary
Australia
facilitates availability of activity data and reflects the scope of economic and climatechange mitigation policies.

6264

4

12

1313

1314

The diagram shows domestic wood products sequestering carbon from the atmosphere,
where this is not possible. The flow from the forest is the relevant one.

Australia

Accepted with
Modification

6266

4

12

1333

1334

The diagram shows domestic wood products sequestering carbon from the atmosphere,
where this is not possible. The flow from the forest is the relevant one.

Australia

Accepted with
Modification

Rejected

The proposed amendment is out of scope
The text has been modified and an additional figure has
been included to explain what this means in the context of
HWP.
The text has been modified and an additional figure has
been included to explain what this means in the context of
HWP.

9540

4

12

1341

1362

Change title of Section 12.A.2 to Estimating CO2 emissions and removals from HWP on
the basis of carbon fluxes” as a contrast to section 12.A.1. Then include text on the‘simple-decay approach’ with the ‘atmospheric-flow’ approach.

CanadaRejected

We believe that a significant improvement in this updated
guidance has been to make a clear distinction between
approaches and methods. In terms of approach, the 'simple
decay' concept is identical to the production approach.
Hence, we are maintaining the 'simple decay' concept as
an approach by providing guidance for the production
approach. The distinction is only in terms of methods. The
2006 IPCC GL included some discussion of how to
combine variables under the 'simple decay' concept, but noexplicit guidance was provided on calculation methods. In
some places, guidance relevant to the 'simple decay'
concept in the 2006 IPCC GL is identical to that given for
the 'production' approach. It remains the case that there isno basis for providing exclusive methodological guidancefor calculations relevant for the 'simple decay' concept.

6268

4

12

1353

1356

The diagram shows domestic wood products sequestering carbon from the atmosphere,
where this is not possible. The flow from the forest is the relevant one.

Australia

Accepted with
Modification

The text has been modified and an additional figure has
been included to explain what this means in the context of
HWP.

Comment
VolumeID

Chapter

From line

To lineComment

6290

Annexes

92

100

Authors may like to consider data in Bray et al 2015 in the derivation of tier 1 default
values (liveweight and liveweight gain) for Oceania in Tables 10A.1-1, 10A.1-3, 10A.2-1A, Australia
10A.2-1B, 10A.2-1C

7376

7378

7396

4

Country

Response

Author's Note

Accepted with
Modification

The information has been reviewed and considered for
applicability in the Tables suggested.

Accepted with
Modification

Information justifying the classification of the steady statemodelling approach at the Tier 2 level has been added.
Values are provided for all model parameters in Table 2.3C.
Note that the method has been moved to Cropland
Remaining Croplands based on other comments.

4general comment on three-pool steady-state carbon model: we don't think this is a tier 2
approach. ACTION: delete from tier 2 sections across chapters. We could accept having
it in tier 3 sections or in an annex.

4

General comment on references to 2013 WL supplement: we don't agree with any ofthese references. Our main aim is that UNFCCC can accept this refinement as guidelines
for future GHG inventories. The COP never agreed to use 2013 WL for national
inventories, and we believe that including here references to this document will make it
Spaindifficult to have this refinement as basis for future inventories. ACTION: we suggest to
delete all references to the 2013 WL supplement or include the text referred to allow
governments to comment on it and make them an integral part of this refinement, so it
can be seen as an independent document from the WLs supplement.

Rejected

The 2013 Wetlands Supplement is an IPCC Methorolodgy
Report officially adopted/accepted by the IPCC. Decision
IPCC/XLIV-5 which defines the scope of 2019 Refinement
refers to the 2013 Wetlands Supplement.

4

General comment: it has been very difficult to keep track of the changes. In somechapters they are marked in grey, in other chapters they are white, and unchanged text is
in grey, and we have identified several paragraphs that changed and weren't identified.
Spain
We kindly ask IPCC secretariat and authors to ensure that, for the next round ofcomments, the changes compared to 2006 GLs are clearly marked. An untransparent
process can difficult the adoption of this document as future guidance for inventories.

Noted

Every effort will be made for improvement.

Spain