Review Comments by Governments on Second Order Draft of Volume 1 of 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories
Comment ID

Volume Chapter

From line To line

Comment

Response

Authors' note

5236

1

1

1

424

General comment for entire volume 1, chapter 1: This section United Statesneglects to also convey that compilation of a TACCC
of America
inventory report or document is an important foundation tofacilitate preparation of future inventories. A well, documented
inventory can more easily be updated and enable more
efficient use of resources. Documentation of the compilation
processes can facilitate work of future compilers as well.

Accepted withmodification

TCCCA is discussed in section 1.4 as the overarchinggoal of inventory arrangements. Opening paragraph text
in 1.4A has been revised to better reflect the points inthis comment.

806

1

1

34

35

Change a lower case letter to a capital letter for the word used Thailand
at the beginning of the sentence

Accepted

OK: Edited.

1786

1

1

58

242

In the approved outline, it has been set forth to update andChinaclarify the concept of "anthropogenic emissions and removals".
However, there are no relevant texts in this report. This part iswhat the inventory developers need to know about accurately,
and represents the basic information to be given integrally andthe basic concepts to be clearly stated in the volume ofoverview. It is suggested to add those texts and descriptions inaccordance with the decision at the 44th Plenary Session of the
IPCC.

Accepted

Text added to section 1.1 is re-added to the text that wasin the FOD to address this issue, but was mistakenly
excluded from the SOD: "The 2019 refinement provides
supplementary good practice guidance for estimating
and reporting anthropogenic greenhouse gas (GHG)
emissions and removals resulting from land use, landuse change and forestry (LULUCF) activities in chapter
2 volume 4 intended to reduce the impacts of natural
disturbances on trends capturing the impacts of humanactivities, building on chapter 2.3.5 of the 2013 Revised
Supplementary Methods and Good Practice GuidanceArising from the Kyoto Protocol (KP Supplement)."

CountryComment ID

Volume Chapter

From line To line

Comment

1788

1

1

58

242

5238

1

1

58

409

Country

Response

Authors' note

The newly added “national GHG inventory arrangement”
China
mainly refers to the relevant regulations required of developed
countries for annual inventory preparation (the inventory
preparation mechanism in the guidelines as seen in Decision
24/CP.19) under the existing Convention mechanism, with theexamples taken only from UK and South Africa, which are notapplicable for most developing countries.
It is suggested to make it clear in the section “institutionalarrangement” that various national circumstances should be
respected, and highlight that most developing countries
independently arrange inventory preparation mechanisms forand by themselves according to their own capacity, and thus
delete such expressions as “single national entity” that only
apply to the mechanism arrangements for developed countries.
Additionally, the “datasets and flow”, in its current form, gives
no substantial guidance to data collection by countries. To
enhance flexibility, it is suggested to increase the number ofcases from developing countries. Meanwhile taking into
account the realistic data collection at national level, it issuggested to change “annual” to “regular” data collection tobetter guide developing countries in collecting data based on
their national circumstances.

Accepted withmodification

Concept of national circumstances is addressed alreadyin section 1.4.1. Revised text in section 1.4.1.4 toremove some langauge introducing the role of SNE, buthave not removed the term from the chapter. The SNEterm is used as a generic term to define an importantrole needed in the design of GHG inventory activities.
This role is in existence in a number of developed anddeveloping countries even if it is called something
different. Data collection is addressed in detail in
Chapter 2, while section 1.4.2 addresses the managmentof data collection process as part of the overall national
GHG inventory arrangements.

Throughout, be clear on what is good practice and what is just United States
an example. It is difficult to tell in many places.
of America

Accepted

The term "good practice" is only used in the
introduction to the chapter and it is explained there thatthe rest of the chapter provides only suggested
approaches and examples for inventory arrangements.

Comment ID

Volume Chapter

From line To line

Comment

5240

1

60

The information on national arrangements is misplaced, should United States
be streamlined and reorganized. It should be reframed in the of America
context of objectives of this document (methodologicalguidance), in particular data collection. The section could be
reframed as "Practical Considerations in Developing
Arrangements to Compile Inventories" or "Practical
Considerations for Arrangements or Management System toCompile National GHG Inventories." The overall new
information included on national arrangements should be
streamlined. Streamlining suggestions: The intro text can be
refined a proposed 1.5 integrating text from 1.5.1 and can list
key considerations from other new headers as bullets (i.e.
elements countries should consider in developing
arrangements to support continuous inventory compilation fordiverse uses, including domestic and international reporting.
The bullets following a short intro as section 1.5 based oncontent inserted by authors, could be streamlined to include abullet on roles and responsibilities, a bullet on uses of theinventory (replacing commitments), a bullet on documentationof arrangements and finally a bullet on Education, Awarenessraising and Public Access to information." The bullets could
integrate text that is now spread across those relevant
subsection within the new section 1.5. For example roles andresponsibilities would streamline and include text on inventory
agency (1.5.1.5), compilation experts (1.5.3), and roles andresponsibilities (1.5.3.1).

5240 (cont.)

1404

Further all examples inserted such as Tables 1.1-1.8) could belisted as management tools in a text box (i.e. providing list)
and then inserted in an annex vs. in the content of section 1.5.
While the intro indicates its intent to be non-prescriptive, aspresented the examples and information does appear
prescriptive and biased towards certain approaches toarrangements for one country. Concerns with specificlanguage is noted below as other comments. The examples
should be framed as management tools and moved to theannex and include links to other readily available materials.

Country

Response

Authors' note

Accepted withmodification

Section reorganized to separate institutionalarrangements from inventory management tools.
Introduced overarching purpose of inventoryarrangements as supporting achievement of TACCC.
Title of section(s) has not been changed. Improved
logical order of sections on inventory institutionalarrangements (i.e., inventory roles) to all fall under
section 1.4.1, including compiling experts. Section on
inventory management tools has been separated into
new section at end of chapter and labeled as being nonprescriptive and illustrative. Section on tools has notbeen moved to an annex (but instead a separate section).
The revised structure of the text is more logical and lessprescriptive.

Comment ID

Volume Chapter

From line To line

Comment

5242

1

1

60

404

5244

1

1

63

63

9040

1

1

63

64

808

1

1

63

5246

1

1

66

67

5248

1

1

67

5250

1

1

5252

1

1

Country

Response

Authors' note

The inventory compilation steps in the current draft of theUnited States
2006 GL has been removed. The section on compiling anof America
inventory was useful to convey general steps that are repeatedin compiling an inventory each cycle. This information should
be reinstated. The arrangements or inventory management
system supports these overarching tasks, and associate
procedures.

Noted

Section 1.5 of original 2006 IPCC Guidelines has notbeen removed because there was no refinement, and so
was not included in SOD.

Insert “considered” before “prescriptive”

United Statesof America
These sentences are difficult to read. Suggest changing the two Canadalines to: This guidance provides suggested approaches andexamples of national GHG inventory arrangements.

Accepted

Text corrected.

Accepted

Text rewritten and corrected.

Ambiguous texts “It instead, it provides..”

Accepted

Text rewritten and corrected.

The phrase in line 66-67 "…improves over time to a state that United States
they can fully inform national and internationalof America
stakeholders...and meet reporting requirements." as framedsuggests that an inventory cannot be useful for some time,
which is not true. An inventory applying basic methods (i.e.
Tier 1) is still useful and informative. Would also say findalternative framing for "stakeholders" in particular in sentence
67-70 on "inform national and international assessments" vs.
"national and international stakeholders" in this context.

Accepted withmodification

Revised sentence to remove mention of stakeholders andmore generally refer to providing useful information.

70

The sentence starting "It is therefore beneficial..." should be
revised to say "It is beneficial for compilation teams toconsiderAccepted

Sentence deleted as part of rewriting paragraph.

72

91

Text box does not highlight basic broader benefits. Seems that United States
this box could also be placed in Ch. 2 on data collection. The of America
data required to apply Tier 1 methods is also often basic
economic data that should be collected regardless of theinventory. The inventory staff should also communicate
important uses back to data providers/suppliers and this could
also be placed in Ch. 2 vs. Ch. 1.

Accepted withmodification

Revised Box title to remove mention of benefits, which
are discussed earlier in chapter and added section to box
addressing linkages with national statistical systems.
And added text that states how GHG inventory process
should be developed in an integrated fashion with othernational statistical activities.

72

91

Box 1.1 is unnecessary, and suggests a broadening of GHG
United States
inventory arrangements that is not essential for theof America
development of a GHG inventory and could be seen as overly
burdensome. It could be helpful if it was instead characterized
as examples of potential data sources and moved to later in thischapter or in the data collection chapter.

Accepted withmodification

Introduction to Box was added that clarified thediscussion there is about linkages and integration of
GHG inventory processes that will reduce the burden of
inventory compliation.

Thailand

United Statesof America

Comment ID

Volume Chapter

From line To line

Comment

9042

1

1

77

77

5254

1

1

92

92

4672

1

1

92

9044

1

1

93

9046

1

1

5256

1

1790

Country

Response

Authors' note“(e.g. Cities)” has limited application; include states, provinces Canada
and territories.
Use of "Governance" also goes beyond mandate of authors.
United States
See comment on reorganizing and streamlining. Informationof America
included here in 1.5.1 overlaps with and can be added tobackground in 1.5.

Accepted

Text added as per comment.

Accepted

Word "governance" deleted from section title.

Could the IPCC provide some discussion on the importance of Japanthe sustainability of the GHG inventory process? It is
important for the IPCC to recognize that not all countries havethe basis for establishing the necessary institutionalarrangements, and they are very much ad hoc.

Accepted

Text added to section 1.4.1 on sustainable institutionalarrangements.

93

Wordy, suggest to remove “the different”.

CanadaAcceptedPhrase deleted.

95

95

Change “examples common” by “examples of common”.

CanadaAccepted withmodification

Sentence deleted as part of rewriting paragraph.

1

105

105

Commitments can carry different meaning in the context ofUnited States
reporting. This content appears to focus on priority uses of the of America
inventory (i.e. internal reporting obligations.

Accepted withmodification

Term "commitments" replaced with "GHG Inventory
Objectives".

1

1

105

105

It is suggested to change “commitments” to “obligations”,
since the emphasis here lies on the reporting obligations, yet“commitments” is more like goals, which easily leads toambiguity.

Accepted withmodification

Term "commitments" replaced with "GHG Inventory
Objectives".

5258

1

1

105

114

"Commitments" is not an appropriate term to use here. It is too United States
narrow in its legal meaning and the intent of the section is not of America
limited to describing internationally binding obligations, butrather activities that the national GHG inventory supports. As
such we propose saying "activities that the national GHG
inventory supports" instead of "commitments."

Accepted withmodification

Term "commitments" replaced with "GHG Inventory
Objectives".

9048

1

1

105

404

The proposed new text, tables and figures are overly
Canadaprescriptive; the linkage to principles of transparency,
consistency, comparability and completeness is unclear. In
addition, many topics are beyond the scope of actual
methodological guidance. A similar comment on lines 131-137
examplifiy this issue.

Accepted withmodification

Revised text in introduction to section 1.4a that refers to
TACCC and ties inventory arrangements as contributing
to achieving them and sustainable inventory preparation.

5260

1

1

106

106

There needs to be a comma (",") after the word "around" inline 106 to complete this thought.

Accepted withmodification

Text revised for readability.

China

United Statesof America

Comment ID

Volume Chapter

From line To line

Comment

9050

1

1

106

107

5262

1

1

106

5264

1

1

810

1

6592

Country

Response

Authors' note

Wordy and difficult to understand, suggest to change sentence Canada
to: "A useful concept to introduce, coordinate and prioritise
GHG inventory activities is a list of monitoring and reporting
requirements, which may also help other decision making
related to the GHG inventory data."

Accepted withmodification

Text revised for readability.

129

It is unnecessary to include a table on commitments. In
United States
addition, it is not good practice to use such a table to prioritize of America
GHG inventory activities, as these should be prioritized basedon IPCC good practice.

Accepted withmodification

Term "commitments" no longer used, and section refers
to inventory objectives and how/if objectives
interact/conflict/mesh with IPCC good practice.
Discussion of prioritization has also been removed. But
table has been retained as a useful example.

108

108

Accepted withmodification

Term "analysis" has been removed and text in thissection has been rewritten.

1

114

114

There is reference to an "analysis" at the start of line 108,
United States
which an analysis has not been previously mentioned in thisof America
section. This paragraph begins by discussing how introducing
and using monitoring/reporting commitments are useful. As
such, to be consistent with phrasing from line 112, this is theanalysis being referenced in line 108 should say "commitments
analysis".
Typing error on “…Table 1.1.”
ThailandAccepted

Cross references corrected.

1

1

114

114

Accepted

Cross references corrected.

9052

1

1

114

114

Editorial: Replace the "Table 1.1" with "Table1.2" in the endof line 114.
Change 1.1 to 1.2.

Accepted

Cross references corrected.

5266

1

1

116

116

For Table 1.1, in line 116, do other gases refer to precursor
United States
pollutants? (e.g., NMVOCs, NOx). If so, recommendof America
specifying. If that was not the intend, recommend adding themas examples to line 116

Accepted withmodification

Precursors mentioned in note 2 under Table 1.1.

5268

1

1

118

118

Description of temporal resolution could be more clear with an United Statesexample included in the footnote description on line 118.
of America
Recommend adding an example, (e.g. annual; MarchDecember). It is somewhat confusion the distinct differences
between elements lines 118 through 120 related to time

Accepted withmodification

A note under Table 1.1 clarifies with an example themeaning of temporal resolution. Explanations for 'time
series span' and 'reporting frequency' are included innotes under Table 1.1.

6594

1

1

122

122

There is no reference to footnote 8 in the text of Table 1.1. It is Russian
proposed to delete the footnote 8 to the Table 1.1
Federation

Accepted

Note numbering corrected and extra note deleted.

6596

1

1

123

124

Table 1.2, column "Reporting Frequency": Add "Every four
years and..." in front of "...Biennial" in the cell for the row"UNFCCC: National Communication and Biennial Report".

Accepted withmodification

Table revised to separate NC from BUR reporting
frequency.

RussianFederation
CanadaRussianFederation

Comment ID

Volume Chapter

From line To line

Comment

9054

1

1

130

137

5270

1

1

130

9056

1

1

9058

1

5272

Country

Response

Authors' note

The section on the “Organization Structure” and its figure is
Canadaoverly prescriptive and does not provide useuful guidance. At
minimum, it is recommended to revamp and provide guidanceon important elements of an effective organizational structure.
Deletion of this section should also be considered unless theauthors of the 2019 refinement can convincingly demonstratethat this guidance will improve the quality of GHG estimates
being produced.

Accepted withmodification

Refined language for section to be illustrative and notprescriptive.

162

Should be noted under documentation of arrangements in
United States
proposed streamlined text for future compilation cycles toof America
facilitate replication of compilation steps. The institutional
diagram should be moved to annex to this chapter as way to
document or illustrate the arrangements. The diagram is
helpful for communication but does not relay the arrangementsthat connect various boxes to form roles and responsibilities.

Rejected

The text in the box describes generic roles andresponsibilities. Diagram retained in main box ofchapter.

135

135

Change “in the following section” by “in the section 1.5.1.3”. Canada

Accepted

Cross references added.

1

136

136

Text in the Management/Co-ordination box is incomplete.

CanadaAccepted

Text in figure corrected.

1

1

136

137

This example should be simplified. A steering committee is
not necessary and should be removed.

United Statesof America

Accepted withmodification

Language added to section 1.4.1.2 to indicate that
following discussion of components is optional, notprescriptive.

5274

1

1

138

143

Accepted

Replaced "stakeholders" with "actors and stakeholders".

5276

1

1

141

141

Throughout, the way the term "stakeholder" is used isUnited Statesinconsistent with common use of the term. The national focal of America
point is not a stakeholder to the GHG inventory. It would
seem better to have a steering committee that is uninvolved inpolicy and decision making. The GHG inventory is meant tobe policy-neutral, and therefore a policy advisor role also
seems problematic.
Recommend adding a sentence describing that for some
United Statescountries, various stakeholders may have multiple roles andof America
require necessary capacities that span over various stakeholder
types listed in Table 1.3. This is only a generic guide but not
definitive per national circumstances.

Rejected

It is not suggested in text that a particular entity cannot
have more than one stakeholder or actor roles.

5278

1

1

142

143

Table 1.3: For stakeholder type "data providers", recommend United States
also including "Specific national sectoral or sub-sectoralof America
knowledge of practices and technologies employed, data
sources, policies and key assumptions", as these data providers
may have the best understanding of these items.

Accepted withmodification

Added text to data providers row that they are to havean understanding of data sets provided.

9060

1

1

149

149

Change “stakeholder” to “stakeholders”.

Accepted withmodification

Language in paragraph has been revised.

CanadaComment ID

Volume Chapter

From line To line

Comment

5280

1

1

149

161

9062

1

1

176

202

5282

1

1

198

202

5284

1

1

203

212

5286

1

1

203

5288

1

1

5290

1

9064

Response

Authors' note

Consider use of "individuals involved in the compilation of the United States
GHG Inventory" instead of stakeholder?
of America

Accepted withmodification

Language revised to refer to "actors and stakeholders".

The purpose of Section 1.5.1.5 (The Inventory Agency) is
Canadaunclear and should be re-written to focus on providing
concrete guidance on elements of effective organizational
structures. Currently this section combines organizational
structure with competence.
An example to provide for this paragraph is a sectoral
United States"compiler's manual". This document outlines the specificof America
source/sector, data needs/sources, methods, and thecompilation processes (including estimates, QA/QC,
uncertainty analysis, archiving, etc.). This sort of document
allows for easier transitions between staff turnover in the event
institutional knowledge is lost. The manual can serve as abasic starting point for new staff.
Use of a "steering committee" or "working group" seems to be United Statesagain a very prescriptive example approach or arrangement to of America
support approval of estimates. This also seems more
appropriate to Ch. 6 for QA/QC and improvement planning
based on findings, etc. No other approaches are included forsupporting processes indicated.

Accepted withmodification

Revised introduction to section 1.4 to focus specificallyon types of institutions that could serve as SNE.

Noted

Concept captured under existing concept of "provisions"for inventory compilation. Further information can befound in chapter 6. No changes have been made to thetext.

Accepted withmodification

Language added to beginning of chapter to clearly statethat guidance is not prescriptive.

212

It is difficult to distinguish here between essential"stakeholders" and other stakeholders. For instance, aninventory needs to have an inventory agency, but does notneed a steering committee, but they are treated the same here.

United Statesof America

Accepted withmodification

Edited text in steering committee section 1.4.1.5 to moreclearly indicate that steering committee is optional.

213

279

Section 1.5.2 and subsections should move to section on datacollection 2.1 or 2.2 for tracking data collection

United Statesof America

Rejected

1

219

232

Box 1.2 is a helpful example.

United Statesof America

Noted

The text in this section addresses the management of theinventory process not the technical aspects of datacollection.
Thank you.

1

1

222

223

9066

1

1

223

223

“This data flow diagram is underpinned by a list of all datasets Canada
used in the GHG inventory (see above in 1.5.1.2)” Section
1.5.1.2 does not discuss a list of all dataset used in the GHG
inventory. This section is likely to be 1.5.2.1 LIST OFDATASETS.
(see Table 1.1c). There is no “Table 1.1c”. It is likely that the Canada
author wants to refer to Table 1.5.

9068

1

1

224

224

The following reference is unclear and is not included in“Reference section on page 20, lines 410 to 424”: in South
Africa’s “National System for GHG Estimation andReporting”.

Country

CanadaAccepted withmodification

Text in box revised to clearly indicate it only provides
an example from South Africa and cross references toother sections have been removed from box.

Accepted

Text deleted.

Accepted

Quotations removed, and reference to the BUR added.

Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

8312

1

1

232

232

Forest should be defined with more details such as, Forest
cover and Forest density

Iran

Rejected

5292

1

1

238

238

While there is mention of institutional memory, there is no
mention of how lists of datasets improve the capacity ofarchiving and achieve the overall goals of archiving, whichfacilitate future inventories. Recommend adding language
related to this in paragraph between lines 237 and 239.

United Statesof America

AcceptedBox presents a short summary of the data in South
Africa's GHG inventory. It is a general term for the
relevant data included. We do not want to go into detailsof all of the specific variables included.
Text revised to comment on the beneift to archiving.
Title also revised to "Archive of Datasets".

5294

1

1

239

240

GHGIs require hundreds of databases. This is already tracked United States
through archiving process, so please clarify why is thisof America
necessary.

Accepted

Revised section to clearly indicate this guidance is partof the archiving process.

9070

1

1

243

243

Change” following section” to “section 1.5.2.2”.

CanadaAccepted

Cross reference added.

9072

1

1

277

278

The following reference is unclear and is not included in
Canada“Reference section on page 20, lines 410 to 424”: National
Greenhouse Gas Inventory Templates developed by the UnitedStates Environmental Protection Agency and United States
Agency for International Development hosted by the LEDs
group3”. There is no footnote #3 at the end of this page nor on
any other page of this document.

Accepted

Footnote replaced with reference to EPA templates inreference section.

5296

1

1

283

285

Recommend adding to this sentence that it is advantageous for United Statescompilation experts to understand specific national sectoral or of America
sub-sectoral knowledge of practices and technologies
employed, data sources, policies and key assumptions. In
addition, recommend adding explicit mention of knowledge of
the UNFCCC reporting guidelines, it is not explicitly
referenced.

Accepted withmodification

Added text to section on compilation experts to refer tounderstanding of sectoral processes and practices. And
moved compliation experts section up to section 1.4.1.7
with the other sections on roles.

6598

1

1

288

288

Editorial: There is no Table 1.1c in the text of Section 1.5. It is Russian
proposed to cross-check the relevance of the reference to the Federation
Table 1.1c, otherwise remove it form the text.

Accepted

Table, Figure, and section numbering were corrected in
editorial process.

9074

1

1

288

288

There is no “Table 1.1c”. It is likely that the author wants torefer to Table 1.3.

CanadaAccepted

Table, Figure, and section numbering were corrected in
editorial process.

5298

1

1

301

301

Recommend adding and "and technical analysis" to"Participation in international review processes" starting online 301, to cover the basis of all UNFCCC processes.

United Statesof America

Rejected

9076

1

1

303

303

Change the first “training” to "Countries".

CanadaAccepted

Language in the section is intended to be neutral and notrefer to any particular UNFCCC or other negotiatedprocess. "peer review" is intended to be generic andcovers technical analysis.
Text corrected and sentence revised for readibility.

Comment ID

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From line To line

Comment

5300

1

1

309

318

5302

1

1

310

5304

1

1

317

812

1

2

814

1

2

816

1

818

Response

Authors' note

Section1.5.4.1 on workplans can be integrated into the existing United States
1.5 and box 1.1 that the authors deleted on compiling anof America
inventory. This could have been integrated as part of a "startand plan" step

Accepted withmodification

Section on inventory management tools has been moved
to come after section on inventory compiling, to present
a more logical order of 1) arrangements, 2) process, andthen 3) execution tools.

318

Recommend adding a sentence to this 1.5.4.1 section
United States
paragraph on workplans to include more explicit dates ofof America
deadlines. While Table 1.6 includes a week by week snapshotof the inventory cycle, recommend that the authors recommendthat workplans and their included deadlines/milestones during
the inventory cycle be as explicit as possible, including
specific dates. This will allow for greater transparency,
coordination, and understanding to the team that is compilingthe Inventory.

Accepted

Footnote added to table column on milestones.

318

Table should emphasize archiving. Table can also note thatthese steps will take less time as experience is gained with
developing GHG inventories.

United Statesof America

Accepted

Concept of archiving added to table.

37

Text format error “References 38” (Change to “Reference…… 2.38”)

ThailandAccepted

Corrected by formatting.

68

Text error “Data collection is … system a country puts…”

ThailandAccepted

Paragraph rewritten.

2

No association of Figure 2.1 in text

ThailandAccepted

Reference provided.

1

2

No association of Figure 2.2 in text

ThailandAccepted

Reference provided.

820

1

2

No arrowhead for a feedback line in Figure 2.2 to show proper Thailand
direction of the flow and no “N” for “NO” in the diagram.

Accepted

Modification made.

1792

1

2

817

To enhance flexibility, it is suggested to reformulate "Standard China
software tools should be used for data management." as"Standard software tools could be used for data management".

Accepted withmodification

This paragraph was deleted as data reporting is dealt
with in Chapter 1.

4674

1

2

1287

Could the IPCC include a discussion on "collaboration withJapan
national statistics data agencies" for developing countries witha view to provide practical guidance to the inventory agencies
on developing a program to collect basic statistics that may notexist in the country? The additional information provided isuseful, but does not lead to improvement of the domestic data
which should be used for inventories.

NotedThis concept is already reflected in the main text of
Chapter 2 and in the annex as well.

819

CountryComment ID

Volume Chapter

From line To line

Comment

5314

1

2

1

1

5316

1

2

68

5318

1

2

5320

1

5322

Country

Response

Authors' note

Overarching comment related to volume 1, chapter 2. There is United States
not enough discussion on archiving of collected data. This is of America
an important step regarding data collection that facilitates
inventory compilation, future inventories, and improvements
to inventories and data. It would be useful to emphasize this inrelation to institutional arrangements/governance, particularly
for countries who are performing their first inventories.
Establishing data and inventory archiving as part of their datacollection activities will allow for easier transitions toperforming future inventories. Recommend adding languagethat addresses this key cross-cutting element.

Accepted

Text has been revised and comment considered in therevision. Some text added referencing Chapter 6
guidance on archiving.

81

Perhaps note somewhere that it's possible that a lot of thenecessary data may be available over the internet and can bedirectly accessed by the source leads. It could be helpful tonote that not all data are very complicated to collect, require
MOUs, etc.

United Statesof America

Noted

The concept has been included in the revised text.

74

74

Use of stakeholders is unclear in this sentence or phrase that
"interactions between the inventory compilers andstakeholders will take place may require the most time".
Seems the intent is data providers but it is not stated clearlywith use of "stakeholders".

United Statesof America

Accepted withmodification

Paragraph rewritten.

2

77

77

Households will be expected to provide information on anannual basis?

United Statesof America

Accepted withmodification

The word "households" deleted.

1

2

95

99

Reword to read: "In these cases, it is good practice to make an United States
initial estimate of if the source or sink strength is of similarof America
magnitude to key categories in order to assess and prioritize
the effort required. Such initial estimates can be very roughand may be based on expert judgement as they are intended to
guide resource use and not contribute to the final inventory
totals. If a new source or sink is estimated to be on a scale
similar to the key categories then it is good practice to use Tier
2 or 3 methods."

Accepted withmodification

Modified to improve english.

5324

1

2

95

99

If a Tier 2 or 3 initial estimate of a source is expected to beUnited States"very rough," would it be better for the estimate to initially be of America
made at Tier 1 and then improved in future GHGIs?

Accepted withmodification

Sentence changed already.

5326

1

2

101

103

Figure 2.1 is added but not referenced in the text anywhere.
Paragraph on lines 82-91 could be modified to reference
Figure 2.1 and match the steps in the figure.

Accepted

Reference included.

United Statesof America

Comment ID

Volume Chapter

From line To line

Comment

5328

1

2

101

103

5330

1

2

106

5332

1

2

5334

1

5336

Country

Response

Authors' note

The process diagram for data collection should clarify or find United States
alternate language to replace what "precise the inventory"of America
period means for non-English speakers, such as identify years
to be included or reported in the national inventory.

Accepted withmodification

Diagram redrawn.

106

Suggest deleting "that are the largest." Other factors impact
prioritization such as trends.

United Statesof America

Accepted

Deleted.

110

111

Archiving should be a part of data collection activities thatfacilitate improvements. Recommend adding.

United Statesof America

Accepted

Added.

2

167

168

Add: does it include the full time series to this bullet.

Accepted

The concept of complete time series was added.

1

2

174

174

"A" feedback mechanism. Correcting beginning of thesentence.

United Statesof America
United Statesof America

Accepted

Corrected.

5338

1

2

178

178

Remove "the" after "documented together with".

United Statesof America

Accepted

Removed.

5340

1

2

183

185

Figure 2.2 is added but not referenced in the text. Can add
some introductory text to explain the figure.

United Statesof America

Accepted

Reference to the figure added.

Comment ID

Volume Chapter

From line To line

Comment

5342

1

2

209

231

5344

1

2

209

231

Country

Response

Authors' note

The new guidance in "Restricted data and confidentiality"
United Statesneeds to be better integrated into the existing guidance.
of America
Currently, the section includes both unclear and redundantguidance. The very strong statement at the beginning,"Confidential data can lead to an inventory lacking
transparency and wherever possible the use of confidential
data should be avoided," makes it unclear whether thesubsequent guidance relates to avoiding use of confidential
data altogether (even in aggregated form) or to successfullybalancing confidentiality with transparency. The discussion of
aggregation in paragraphs 2 and 3 is partly redundant with thediscussion of aggregation 236-243, and it is not clear how thetwo discussions are related. Recommend deleting paragraph 2
and moving the discussion in paragraph 3 to the discussion atline 240 to read: "Sometimes, depending on the size andstructure of the original sample, raw data can be aggregated ina way that protects confidentiality and yet produces useful
information for emission inventory purposes. Aggregation
techniques should be selected to avoid the possibility that theconfidential data could be reconstructed using the publishedinventory. On the other hand, care should also be taken tominimize the aggregation as much as possible so as to be astransparent as possible. If, however, there is a need to preserve
confidentiality the NSA, or the body that originally collected
the data, are normally the only ones that can carry out thisadditional treatment of the raw data."

Accepted withmodification

The comment has been taken into account in therevision of the text.

It is not clear which part of the refinement TOC is being
United States
implemented by this refinement to the section on "Restricted of America
data and confidentiality." Confidentiality is not mentioned at
all in the TOC for Volume 1, Chapter 2, and the IPCC Scoping
Meeting Report included only the following recommendation
regarding confidentiality guidance in Chapter 2: "Additional
guidance to activity data collection: Provide clarity on
representative sample Confidential data:o Example of agreement for disclosure confidential
informationo Provisions of examples for incorporating confidential data"
Neither of these examples appear to have been provided in thissection.

Accepted

Example of Confidentiality agreement form andillistrative examples of aggregation of confidential data
have been provided in Boxes 2.0a and 2.0b respectively.

Comment ID

Volume Chapter

From line To line

Comment

5346

1

2

210

211

5348

1

2

229

5350

1

2

5352

1

5354

Country

Response

Authors' note

"Wherever possible the use of confidential data should be
United States
avoided." This statement is overly broad. Often, data that isof America
critical to the development of precise and accurate inventories
is confidential at the level of individual facilities or otherentities. However, it can still be used with little loss oftransparency if it can be aggregated so that the facility-specificdata are masked. The old text from the 2006 Guidelines
includes good guidance on this point.

Rejected

The text is clear "where ever possible" "However, this is
not always possible" etc.

231

Confidential data is often required for higher Tier, more
United Statesaccurate estimates. Therefore, rather than replacing estimates of America
based on confidential data with less accurate estimates basedon non-confidential data, inventory compilers should be urged
to verify estimates based on confidential data with estimates
based on non-confidential data. The compilers can thenprovide transparent verification without sacrificing accuracy.

Rejected

The inventory compiler has to balance transparency withaccuracy etc (TCCCA). Comparisons with confidential
data are not transparent and usually not possible if theconfidential data is not released. Many countries
produce complete inventories with little or no
confidential data.

275

276

Insert the word "be" into "there may (be) cases".

United Statesof America

Accepted

Inserted.

2

280

280

Change "extrapolating from" to "estimating based on"United Statesof America

Rejected"Extrapolating from" is better as the estimate will not be"based " on the other country will be used as a guide.

1

2

288

314

Accepted withmodification

Moved from the separate bullet to bullet on facility level
data. Separate bullet is deleted.

5356

1

2

292

293

Within this list, GHGRP seems an approach to list if this list is United States
referring to global data sets that all countries may want toof America
consult, etc. Doesn't seem appropriate to call out GHGRP in
this section. It is only 1 example of a facility-level data setsfor 1 country.
Unclear why it is unlikely that registry data could not be used United States
directly in an emission inventory, recommend deleting thatof America
language.

Accepted withmodification

Language is changed to the following sentence: "maysometimes be used for estimating emissions fromindustrial installations but usually could not be directly
reported in the GHGs emission inventory".

5358

1

2

306

306

How is GHGRP different from facility level data discussed insecond bullet (lines 291-293) recommend combining.

United Statesof America

Accepted

The list has been updated and bullets combined.

5360

1

2

306

306

This should say "The U.S. EPA Greenhouse Gas Reporting
Program (GHGRP) Greenhouse Gas (GHG) data. "United Statesof America

Accepted withmodification"the Greenhouse Gas Reporting Program (GHGRP)EPA USA" - used as an example in bullet on facility
data. The list has been updated in the revised text.

5362

1

2

307

313

Recommend combining these international datasets with bullet United Stateson lines 299-300
of America

Accepted

List of international organisations is combined withbullet on international organisations.

5364

1

2

314

314

Recommend making remote sensing its own bullet / data
category

Accepted

Separate bullet included.

United Statesof America

Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

5366

1

2

360

361

Add that when crosschecking national and international data
sets you should account for any adjustments made to national
totals for inventory purposes (e.g., removal of bunker fuels).

United Statesof America

Accepted

Suggested sentence included in the text.

5368

1

2

446

447

Clarifying that "adapting data for inventory use" will still be a United States
separate heading / section.
of America

Accepted

Separate section.

5370

1

2

559

559

Change last word to below:

United Statesof America

Accepted

Text revised (refer to comment id: 5372 ).

5372

1

2

561

561

Reword to read: "Consider the main parameters effecting
emission or removal rates as shown in Table 2.2"

United Statesof America

Accepted withmodificationline 561 is re-written as "Consider the main parameters
affecting emission or removal rates as shown in Table
2.1a".

5374

1

2

569

573

It seems that this has already been noted, but this is the clearest United Statessummary of the information so I would keep this one andof America
delete others.

Noted

Texts relevant to the comment from line 568-573 aredeleted.

5376

1

2

577

578

Page 2.18, Table 2.2: These comments relate to the “EFUnited States
Sensitive Parameters” under Manure Management. The
of America
bullets on timing of storage, length of storage and time andtemperature distribution between indoor and outdoor storage
all seem similar, in addition to the seasonal and daily
temperature variation and climate bullets. Seems like some
sort of consolidation of bullet points could be made to improve
clarity.

Accepted withmodification

Text revised after discussing with AFOLU sector
experts, Table 2.2 Manure management, as: "Time andlength of storage", "Climate - Seasonal and daily
temperature variation". However we deleted three bullet
points "Length of storage", "Climate", Time andTemperature distribution between indoor and outdoor
storage". Deletion was due to revision and merging oftext in this Manure management.

Comment ID

Volume Chapter

From line To line

Comment

5378

1

2

577

578

5380

1

2

577

577

Country

Response

Authors' note

Page 2.18, Table 2.2: These comments relate to the “EFUnited States
Sensitive Parameters” under Agricultural Soils. For theof America
second bullet on animal manure applied to soils, should thisalso include “deposition of urine and dung by pasture, range
and paddock livestock”, which can be a significant source ofN2O under this category. Or possibly this could be a separate
bullet. For the bullet on “Organic soil cultivation”, should thisbe changed to “Drainage of organic soils” since it’s mainly thedrainage that causes the N2O emissions rather than thecultivation. Also, by emphasizing “cultivation” it could
preclude drained organic soils on grassland where cultivation
may not even take place, but where the drainage is certainly
causing N2O emissions. For the bullet on “Soil type” Iquestion whether this should be included. Soil type (otherthan the split between mineral and organic soils) is not a factor
in the methods for Agricultural Soils from the 2006 IPCC
Guidelines and from a review of the changes being proposed in
the 2019 refinement, I don’t see any reference to soil type. For
the bullet on “Type of AWMS (solid storage, anaerobic
lagoons, etc.)”, I think this should be removed. While use ofdifferent AWMS systems could have an impact on the amountof manure applied to soils, seems like that would be covered
under the second bullet “Animal manure applied to soils”. For
the bullet on “Soil management practices”, I’m not sure whatpractices this would include that are not already covered bythis list. There are no additional practices I’m aware of thatare part of the methodology and aren’t already covered by thislist.

Accepted withmodification

Text revised after discussing with AFOLU sector
experts, Table 2.2 AFOLU/Agricultural soils/Direct andindirect N2O emissions from managed soils, as: 1) we
added separate bullet as " Urine and dung deposited on
pasture, range and paddock by grazing animals", 2)bullet "Organic soil cultivation" is replaced with
"Drainage / management of organic soils", 3) bullet "soiltype" is deleted, 4) bullet “Type of AWMS (solid
storage, anaerobic lagoons, etc.)” is deleted, 5) bullet"Soil management practices" is replaced with "Soilcultivation management practices".

Table 2.2: Change EF Sensitive parameters for stationary toUnited States
read: "CO2: Variable attributes of fossil fuels including carbon of America
content" and add / control technologies to CH4 and N2O. For
mobile add Variable attributes of fuels including carbon
content. (differences in heating values could also impact
results).

Accepted withmodification

Text revised in Table 2.2, EF Sensitive parameters forstationary as: added "CO2: Variable attributes of fossil
fuels including carbon content" and added "control
technologies" to CH4 and N2O. Also, for Mobile we
added "Variable attributes of fossil fuels including
carbon content".

Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

5382

1

2

577

578

Table 2.2: add carbon contents of waste components to waste
incineration EF sensitive parameters

United Statesof America

Accepted withmodification

Comment id 5382, 2504, and 1270 are replied after
discussing with Waste sector experts, as: Solid waste 1) bullet "waste component" is replaced with "waste
composition", 2) New bullet added as "Climaticconditions", 3) New bullet added as "Type andmanagement of landfills", 4) bullet "Life of product isdeleted"; A bullet "Population of the country" in
Wastewater handling is deleted; A bullet "Amount of
incinerated waste per year" in Waste incineration isdeleted.

5384

1

2

577

577

For oil and gas, add "equipment types and practices"

United Statesof America

Accepted withmodification

Text revised in Table 2.2 Fugitive emissions/ Oil andGas, as: added "Equipment type and practices".

5386

1

2

588

588

Accepted withmodification

Text revised in line 588 as "These factors should reflectnational circumstances as far as possible".

5388

1

2

819

819

5390

1

2

821

821

Change sentence to “These factors must be carefully evaluated United States
to ensure they are applicable to the national circumstancesof America
where they are being utilized.”
Provide a link to US EPA inventory management tools
United Statesof America
2.3 Use of Facility Data in Inventories could use some
United States
restructuring and editing. The guidance is repetitive in many of America
places.

Accepted withmodification
Accepted

This paragraph was deleted as data reporting is dealt
with in chapter 1.
Text revised.

5392

1

2

821

821

2.3 could be improved with a mention that there are sometimes United States
multiple choices for which activity data to use to scaleof America
emissions to the national level, and that the compiler should
work with industry and other stakeholders to determine which
best relates to emissions (e.g. petroleum well counts or
petroleum production data). In addition, more detail could be
included on the time series question, where again the compiler
should work with industry and other stakeholders to determine
what technologies/practices were in place in years without
FRD and how to take that into account in the time series.

Accepted withmodification

Text modified.

5394

1

2

824

830

I would also add to this section that facility data from a
United States
reporting program (if collected regularly) can greatly improve of America
trend information in a GHGI, e.g., in a way that use of aconstant EF and annually updated AD cannot.

Accepted withmodification

Text modified.

5396

1

2

831

832

How is the data collected in this sentence different from theUnited States
data collected in the above paragraph. Seems it is in the same of America
category and the write up can be combined.

Noted

Revised sentence.

Comment ID

Volume Chapter

From line To line

Comment

5398

1

2

837

838

5400

1

2

842

5402

1

2

5404

1

5406

5408

Country

Response

Authors' note"…that additional reporting requirements, OR
United States
ADJUSTMENTS TO THE REPORTED DATA" Editof America
suggested in the case that the reporting program cannot bechanged, but the data is from a mix of emissions sources. The
compiler could use expert judgment to assign emissions to e.g.
landfills versus fossil fuel combustion.

Accepted withmodification

Modification was made to text although not to support'adjustment to the reported data' but to note that enhancereporting elements may be needed to support the use of
FRD for GHG inventories purposes from pre-existing
programmes.

843

Consider rephrasing the sentence. The fact that default
United Statesemission factors are used does not mean that the reported data of America
cannot be used to improve GHG inventories. For example, thefacility-level data might provide useful activity data that could
be used to improve the national inventory.

Noted

Clarified text on the use of IPCC default factors. The
various uses of facility data (where relevant) are
discussed in section 2.3.2 and also noted in the firstparagraph to this section.

843

843

Consider rephrasing the sentence. Measurement does notUnited Statesnecessarily mean that the data are "better" than data calculated of America
by other means. For example, engineering calculations canprovide very precise ways of calculating emissions for certain
industries.

NotedThis line (& paragraph) acknowledged potential
improvement to inventory based on facility reported
data. It does not state that 'measured' data are 'better'.
Section 2.3.2.1 tries to outline Quality elements toconsider in ensuring that reported data may be of use byinventory compilers. Also it in the reporting
specification and methods (which will allow industrial
facility to apply engineering approaches as compared todefault factors along with calibrated metering) that will
drive the quality of the information for consideration by
inventory compilers. It is up to each country to identify
their specific requirements such as allowing the use ofengineering approaches with supporting documentationof facility approaches.

2

843

845

Note that it is also a possibility that the compiler may include
some aspects but not all from the FRD. For example, acompiler could use annual activity data from FRD, but
improved EFs from the literature.

United Statesof America

Noted

Various usage of FRD is presented throughout section
2.3.3.

1

2

848

850

Suggest deleting "direct" as there are other uses of FRD that
could be considered and are discussed in this section.

United Statesof America

Accepted

Deleted 'direct' from sentence.

1

2

850

852

Currently, this sentence focuses exclusively on limiting
United Statesburden. To better emphasize the need to balance limitingof America
burden with meeting inventory needs, recommend revising to:"Inventory compilers and legislative groups developing
reporting systems are encouraged to work together to design
an efficient system that meets inventory goals while limiting
burden."Accepted withmodification

Revised sentence to state: '…to streamline and design anefficient system that also meets inventory goals while
limiting burden.'Comment ID

Volume Chapter

From line To line

Comment

5410

1

2

858

859

5412

1

2

871

5414

1

2

5416

1

5418

1

Country

Response

Authors' note

The term "reporting criteria" is not clear. Does this mean the United States
quantities to be reported (data elements) or the factors used to of America
determine when reporting is required (scope)? If the former,
recommend revising sentence to begin "Specifying the data to
be reported (such as fuel quantity, carbon content, heat
content, etc.) and methods appropriately. . ." If the latter,recommend revising sentence to begin "Appropriately defining
the scope (such as emission or consumption thresholds) andmethods for reporting . . ."Accepted withmodification

Modified statement to: "Specifying the information to
be reported…'.

873

Suggest adding "and correct interpretation and use of FRD by United Statesof America
the inventory compiler"

Accepted withmodification

The idea of a common interpretation of data has been
incorporated into lines 871-873 (SOD).

881

882

Here and in Table 2.5, recommend also mentioning that
estimates across facilities in the same source category should
be comparable. That is, they should cover the same sources
within that category and be based on comparable (though notnecessarily identical) methods.

Accepted withmodification

Comment has been considered and concept included in
the revised text "facility GHG estimation methods to be
applied must be at least comparable with .."

2

883

887

May be helpful to add an example here. E.g. "For each
United Statescategory reporting, assess which related elements are available of America
at the national level (e.g. quantity of petroleum produced) andbe sure that that data element is collected along with the FRD(e.g. quantity of petroleum produced by the facility). This willallow the compiler to assess coverage of the reporting programand scale up emissions to the national level."

NotedThis concept is presented in section 2.3.2.2 and in Table
2.5 along with a sample equation for activity data
(Equation 2.3).

2

892

893

For the inventory principle of Consistency, the current text
United States
implies that facility level data should be statistically similarof America
over the time series based on size, operating conditions, etc.
However, there may be legitimate reasons for there to be
outlier data due to site specific circumstances. Outlier facility
data do not necessarily mean that the data are not reliable.

Accepted withmodification

Added footnote to the second bullet to note break intime series may be reasonable with supporting
explanation from facilities.

United Statesof America

Comment ID

Volume Chapter

From line To line

Comment

5420

1

2

892

893

5422

1

2

892

5424

1

2

5426

1

5428

Country

Response

Authors' note

In Table 2.5, the bullets to the right of "Consistency" are not United Statesclear. In the first bullet, it is reasonable to advise that activity of America
data should be reported in consistent units; however, it is notclear what "corrected to the same operating condition" means.
In fact, because "operating conditions" (for example, process
efficiency and capacity utilization) vary across facilities andhave a real impact on emissions, it may not be desirable to"correct" activity data to the same operating conditions. In thesecond bullet, several ideas appear to have been combined.
Recommend breaking this bullet out into two bullets, one ofwhich focuses on time series consistency, and the other ofwhich focuses on consistency of aggregated facility data withother industry statistics for comparable facilities. (The end of
the bullet appears to have extra or missing words.)

Accepted withmodification

Modification made in Table 2.5 to increase clarity.

893

In Table 2.5, in "Consistency" row, recommend adding theUnited States
following in the bullet regarding time series consistency:of America"Time series consistency is addressed by including provisions
to allow splicing of data in the event of methodological or datachanges."

Accepted withmodification

Clarification provided via a footnote.

892

893

In Table 2.5, in "Completeness" row, recommend replacing
United States"facilities" with "emissions" in third line. It is the fraction ofof America
emissions, not facilities, covered that determines thecompleteness of the reported emissions. In many cases, a highpercentage of emissions can be covered even if a relatively low
percentage of facilities is covered (the "80/20 rule").

Rejected

The first bullet is to cover more than just emission
information (this will allow for comparison withnational statistics to help compilers assess and accountoutstanding data due to reporting threshold and de
minimis).

2

892

892

For completeness, add "Emissions coverage-reporting should United States
cover all emissions occurring at a facility and in cases where it of America
does not, it should be clear which sources are included andwhich are not."Accepted withmodification

This idea is presented in Table 2.6. Accepted
recommendation by including a bullet in Table 2.6 toprovide a list of sources not reported due to de minimis
allowance.

1

2

899

902

The use of engineering calculations, site specific emission
factors, and default emission factors can also be ways ofobtaining high quality facility level data

United Statesof America

Noted

Modification included as a footnote (line 888). Footnote#22 (in draft mode of work document).

5430

1

2

913

914

CEMS may not be appropriate in all settings

United Statesof America

Noted

Concept reflected in the text.

5432

1

2

913

914

Recommend deleting the bullet regarding setting a de minimis United States
threshold. A de minimis threshold is not a necessaryof America
prerequisite to a facility-level reporting program. Or
alternatively, it should be described as optional.

Accepted withmodification

Text modified.

Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

5434

1

2

913

914

In Table 2.6, recommend adding other parameters that affectemissions, including "Activity level (e.g., production,
feedstock consumption;" "By-product generation rate (ifapplicable);" "Level to which emissions are controlled (e.g.,
destruction efficiency in percent);" and a generic "Other
parameters that affect emissions."

United Statesof America

Accepted withmodification

Modification made to Table 2.6.

5436

1

2

913

913

Add "activity data that corresponds to the national level data United Statesset" (so that it is possible to assess coverage and use data in the of America
GHG inventory" and "activity data on emission controls inplace"

Noted

5438

1

2

913

913

On de minimus, I would rephrase this so that it does notUnited States
appear to be a recommendation (from an inventory compiler's of America
perspective, it's preferable to not have a de minimus), but toinstead state that if the program does have a de minimus, it
should be specified and applied based on X,Y,Z. I would also
move this from the box into the main text.

Accepted withmodification

This requirement is specified (with added modification)by the following bullet in Table 2.5: '• Activity data(such as quantity of each fuel and process feedstock)which contributes to emissions measured based on the
CEM system.'
Point noted and text has been revised to 'Consider …' so
not to appear as requirement but for consideration whendeveloping a reporting regime.

5440

1

2

916

916

Accepted withmodification

Deleted 'developed countries' and modified text.

5442

1

2

934

935

If the situation is different in developing countries, specify
United States
how here, and note the implications. If it is not, deleteof America"developed." Could also consider rephrasing as "In many
countries, national statistics datasets…"
Aligning facility data with national statistics "as much as
United States
possible and to the extent possible". It is not guaranteed thatof America
they will line up exactly, or even line up well depending on the
coverage of them. At some point, it may not be worth theresources required to get them to line up exactly but can still
follow TACCC principles.

Noted

Text modified.

5444

1

2

939

944

United Statesof America

Noted

Clarified that collaboration is applicable for those with'related data elements'.

5446

1

2

961

1097

This is veering a bit off topic. Data needs of agencies not
involved in inventory compilation should not be within thescope of these guidelines.
The discussion appears to be missing time seriesconsiderations when facilities resubmit reported data fromprior years

United Statesof America

Noted

Text modified.

5448

1

2

962

967

This section discusses approaches for use of reported facility United States
data but there is no mention of volume 1, chapter 5 or ensuring of America
time-series consistency. Recommend adding at least a sentencereferencing this.

Noted

Text modified.

Comment ID

Volume Chapter

From line To line

Comment

5450

1

2

976

977

5452

1

2

1027

5454

1

2

5456

1

5458

Country

Response

Authors' note

Suggest deleting this equation. This is not always the case,
United Statesand if this guidance is getting into how to design a FRP, theof America
recommendation should be to have disaggregated emissions
reported (in addition to aggregate of course). Edit to say that
ideally, emissions are reported in a disaggregated manner, suchthat they can be directly assigned to comparable IPCC
categories. The equation is implying that the reported
information is the total emissions, but is not providing any
guidance on how to handle that situation.

Accepted withmodification

Modified text in introduction to 2.3.3.1.

1028

Consider editing this equation to replace the EF term with
United StatesE(subscript)FRP/AD(subscript)FRP to clarify in general terms of America
how the EF is developed from the FRP. Also, clarify that theAD(subscript)NSS term is "national activity data" to avoid
confusing it with FRP AD.

Accepted withmodification

1039

1041

Not sure what the value is of doing this for comparison
purposes if it's not aligned with IPCC reporting sectors.

United Statesof America

Accepted withmodification

1) The subscript 's' is intended to refer to a specificemission source (i.e., fuel combustion by fuel type or byeach type of feedstock use, etc).
2) Clarification is provided in the description of thenotation to indicate EFsFRD is developed based on
facility specific data.
3) Provided clarification in notation to include 'national
activity data'.
Revision made to add clarity.

2

1091

1094

Is it possible that experts from developing countries or from
United Statesother sectors (e.g. waste, agriculture) will not be familiar with of America
these codes (ISIC, SIC, NAICS)? If so, please provide
clarification or please make this guidance more general (itappears geared towards industrial processes, but othercountries may have reporting on waste sector or ag, where therelevant national stats may be quantity of waste disposed,
number of cows, etc. and not be aligned with industrial codes)
and list those codes as examples.

Accepted withmodification

Generalized statement and presented as example.

1

2

1095

1096

Confusing sentence. I think that if the FRD is meeting all of
the previously specified requirements, it should be common
practice to use the FRD to update EFs for the inventory, andthis appears to be what is suggested by the preceding text.

Noted

FRD must meet quality goals (Table 2.4). Modified
sentence.

5460

1

2

1097

1100

I think the more common scenario will be where a FRP is new, United States
and as such no FRP data are available in previous years of the of America
time series.

Accepted withmodification

Removed repetitive statement.

5462

1

2

1135

1144

This information is already provided above. It may better tohave one section on how to address cases of incomplete data
availability, since the guidance is the same whether reporting
was designed specifically for GHG inventories or not.

Accepted withmodification

Revision made.

United Statesof America

United Statesof America

Comment ID

Volume Chapter

From line To line

Comment

5464

1

2

1146

1146

5466

1

2

1146

5468

1

2

5470

1

5472

Country

Response

Authors' note

Incorporate the comment bubbles to the side of the "Start. All United States
data meet quality checks" box into the decision tree. E.g. "Is of America
QA/QC information available?" Yes or no….

Accepted

Generalized decision tree updated (see Figure 2.3).

1146

What does the note mean? Is this presenting a decision tree or United States
an example of the decision process?
of America

Accepted

Clarified that this is just an example. Revised heading.

1146

1146

United Statesof America

Accepted

Generalized decision tree updated (see Figure 2.3).

2

1170

1170

For ease of use of the guidance, could consider restructuring
so that each box in the decision tree has a corresponding
header with guidance in the chapter.
"and how the data have been incorporated into the GHG
inventory"

United Statesof America

Accepted withmodification

Revised text as follows: '...and how the data/information
have been incorporated into the GHG inventory fortransparency purposes and facilitate…'

1

2

1351

1352

Accepted

Suggestions included in the text.

6600

1

2

68

68

Add that BP's "Statistical Review of World Energy" provides a United States
time series of data by country on oil and gas production,of America
consumption and refining, all of the inputs necessary forfugitive emissions for this source.
https://www.bp.com/content/dam/bp/en/corporate/pdf/energyeconomics/statistical-review/bp-stats-review-2018-fullreport.pdf
To maintain consistency with theother chapters of the volume, Russian
it is proposed to replace "system" with "arrangements".
Federation

Accepted

Term changed.

6602

1

2

101

102

Accepted

Reference to the table added.

6604

1

2

183

184

Figure 2.1: There is no reference to Figure 2.1 in the text. It is Russian
proposed to provide the reference and a brief description of the Federation
Figure 2.1 in the text.
Figure 2.2: There is no reference to Figure 2.2 in the text. It is Russian
proposed to provide the reference and a brief description of the Federation
Figure 2.2 in the text. It is further proposed to increase the sizeof Figure 2.2, to enhance its readability.

Accepted withmodification

Modification implemented with additional text.

6606

1

2

360

361

Accepted withmodification

Suggestion considered in the revision of the text.

6608

1

2

446

446

The guidance in the last sentence of the paragraph is unclear. It Russian
is proposed that the authors should clarify, if the international Federation
data could be used for QA/QC of the national data sets,otherwise the international data could be used for inventory
purposes in case the national data are sparse or unavailable.
However, if the latest option is a case, then this guidanceshould be moved in the data section, because it is not
appropriate to keep it here.
The last sentence in the paragraph seems inappropriate. It is
Russianproposed to edit, otherwise delete the last sentence in theFederation
paragraph.

NotedThis is already reflected in the main text of Chapter 2.

Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

6610

1

2

602

603

RussianFederation

Accepted withmodification

Table 2.2 has been revised.

6612

1

2

817

817

Text deleted.

1

2

939

961

RussianFederation
RussianFederation

Accepted

6614

Table 2.3: It is proposed to indicate, which of the literature
data sources included in the Table 2.3 could be used as asource of activity data, emission factors or other parameters
used in the inventory. These clarifications would be useful for
inventory compilers.
It is proposed to make the statement in line 817 more general
by deletion of the text "to developing countries"
General: for consistency purposes, it is proposed to maintainthe use of the same abbreviation for facility reported data
(FRD) both in the text and in the section title

AcceptedSame abbreviation used.

6616

1

2

979

981

Equation 2.1: The equation seems confusing, because facility Russian
emissions regularly comprise source categories that relate toFederationdifferent IPCC sectors. The examples are direct and indirectenergy emissions and emissions related to waste management
attributed to the same facility. It is proposed to clarify what theEquation 2.1 is intended for.

Accepted

Equation modified.

6618

1

2

995

1001

The statement in paragraph is not necessarily correct, because Russian
the facility emissions comprise source categories that may be Federation
allocated to different IPCC sectors. The example is the
combination of direct and indirect energy emissions and theemissions related to waste management for a specific facility.
It is proposed that the authors clarify what they intend to say,otherwise remove the text in paragraph within lines 995 to1001.

Accepted withmodification

Text added to clarify situations relevant to a particularsubsector and the influence of reporting thresholds.

6620

1

2

1057

1072

Equation 2.3: It is not clear, what intention of the equation is.
Especialy unclear the concept of subtraction of facility
reported data from national statistical data, because the latter
may have a potential for underestimation of nationalemissions. It is proposed that the authors explain the rational
behind the Equation 2.3

RussianFederation

Accepted withmodification

Modification implemented with additional text.

6622

1

2

1149

1150

Figure 2.4: It is proposed to increase the size of the figure.
Otherwise it is difficult to read it in the hard copy.

RussianFederation

Accepted

The size of the figure was increased.

6624

1

2

1465

1484

General: It is proposed that in the description of the reference Russian
sources, the clarification is provided which international
Federation
publications could be used as the sources of activity data andparameters necessary for inventory in the forestry sector. Thisclarification is especially important for countries, where data
are sparce or not available.

NotedThis is already reflected in the main text of Chapter 2.

Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

8314

1

2

88

88

Should be added after "forest management", reforestation,afforestation, deforestation, …

Iran

Accepted withmodification

8316

1

2

1467

1467

Foote note under "national forest monitoring": FAO should
facilitate to access national related data provided ininternational and regional levels by different organizations

Iran

Noted

The text was modified as follows: "...major fossil fuelconsumption, major agriculture activities, forests andmajor industries".
No action can be taken because comment is out of scopeof 2019 Refinement.

8320

1

2

105

115

Noted

Comment considered in the revised text.

8322

1

2

166

168

Noted

Comment considered in the revised text.

8324

1

2

173

174

Noted

Comment considered in the revised text.

9094

1

2

156

160

Accepted withmodification

Remote sensing is listed under bullet 1 "Use existingdata".

9096

1

2

183

183

Regarding the importance of the database, it is necessary to
Iranfind specific format and instructions to provide an integrated
the data sources for the countries. This require capacity
building and training.
Providing instruction to complete the data and estimate theIranmissing data
Introduction of similar measurement tools and methods,
Iranspecially for developing countries and capacity building andtraining methods
Given that using remote sensing data and geospatial products Canada
are possible ways to obtain new data, these methods should be
mentioned in this list. Suggest to add new item (iv) as "Useremote sensing data and geospatial products (volume 4,
chapter 3)".
Figure 2.2: Second box on the left that says "Can the data be Canada
collected through measurements, surveys or census,
considering existing resources?" should mention remotesensing and geospatial as possible method for data collection.
Suggest to modify text as: "Can the data be collected throughmeasurements, surveys, census, remote sensing or geospatial
products, considering existing resources?".

Accepted withmodification

Text modified to read: "Can the data be collected
through measurements, remote sensing, surveys or
census, considering existing resources?"

9098

1

2

574

577

Table 2-2: AFOLU is not mentioned at all in this table. If this Canada
was on purpose given that specific guidance for AFOLU isprovided in volume 4, this should be clearly noted either
within the text referring to this table 2-2 in line 575, or as afootnote to the table. Parameters and variables related to for
example: forest characteristics (age-structure, tree densities,etc.), harvested wood products (e.g. carbon conversion factors,
half-life parameters) and land management practices (e.g.
rotation length, thinning frequency, etc.) can greatly affect theemissions/removals in AFOLU and this should be
acknowledged or at least briefly noted in this table applicable
to all sectors.

Noted

9100

1

2

892

892

CanadaAccepted

Addressed in FD.

9102

1

2

927

930

Table 2.5: Third bullet of Comparability, NAICs should be
NAICS (all capital letters).
For consistency, use FRP (facility-reporting programme)
instead of GHG reporting program.

CanadaAccepted

Addressed in FD.

Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

9104

1

2

950

950

For consistency, use FRP instead of GHG reporting program.

CanadaAccepted

Addressed in FD.

9106

1

2

1031

1035

Equation 2.2: order description of variables according to when Canada
it first appears (from left to right) in the equation. EICs
appears first, then IC.

Accepted

Addressed in FD.

9108

1

2

1061

1070

Equation 2.3: order description of variables according to when Canada
it first appears. EICs, IC, ADNS, ADfac, Efs.

Accepted

Addressed in FD.

9110

1

2

1087

1156

For consistency, use FRD (facility-reported data) instead offacility GHG emission reporting program data throughout thetext.

CanadaAccepted

Addressed in FD.

828

1

3

1004

Where is the number 20.2% uncertainty come from?

ThailandAccepted

6638

1

3

1013

1014

It is proposed to increase the size of the Sensitivity Chart,
because it is difficult to read it in a hard copy

RussianFederation

Accepted

The basis for obtaining the result 20.2% when applying
approach 1 has been added.
Implemented.

6626

1

3

167

168

Accepted

Implemented.

6628

1

3

192

194

Accepted

Implemented.

5474

1

3

200

208

Figure 3.1: It is proposed to increase the size of the Figure 3.1, Russian
as it is difficult to read it in a hard copy.
Federation
Figure 3.2: It is proposed to increase the size of the Figure 3.2, Russian
as it is difficult to read it in a hard copy.
Federation
This section should provide guidance on how to identify theUnited Statescauses of uncertainty, since it has made the point that theof America
identification step is critical.

Rejected

6446

1

3

231

234

This addition adds clarity, is an important point, and should
not be removed

Noted

6448

1

3

238

240

UnitedKingdom (ofGreat Britain
and Northern
Ireland)
It is perhaps worth noting that there is diminishing returns
Unitedwith this, and at a certain point the cost of additional sample
Kingdom (ofmay outweigh any potential benefit gained. Suggest the text is Great Britainchanged to: "Uncertainty associated with random sampling
and Northernerror can be reduced by increasing the sample size, although
Ireland)
there are diminishing returns so it is worth considering any
increase in sample size against additional cost and burden."Section refers to the 2006 IPCC Guidelines. It is not theintention to change the guidance already there. To beclear, text has been deleted and "No refinement" label
added under this section.
No change needed.

Rejected

Not relevant in this context. This section focuses on
how to reduce, not in the cost/benefit. In addition,
Chapter 2 covers good practice guidance in relation to
sampling size.

5476

1

3

312

329

Suggest moving these out of the box. These are important
United States
points that can be made more general (though still helpful to of America
point to example in the box) and haven't been made elsewherein this chapter.

Accepted withmodification

The sentences are appropriately related to the example
and would not fit outside the box. However the first
sentence has been removed, and this point has beenclarified in the paragraph in the introductory section.

Comment ID

Volume Chapter

From line To line

Comment

5478

1

3

329

329

5480

1

3

337

6450

1

3

6630

1

6632

Country

Response

Authors' note

I would also add somewhere in this section that sometimes
United Statescollecting improved data to move to higher tiers also results in of America
improved understanding of uncertainty and improved data toquantify uncertainty. Using this new data to quantify
uncertainty could actually result in an increase in calculated
uncertainty. In this case, it does not mean that the compiler
should consider using a lower tier.

Noted

The paragraph has been deleted in response to otherreviewer comment.

885

The uncertainty guidance appears very complicated forUnited States
someone new to GHG Inventories or with limited statisticalof America
background. However, in the worksheet, it appears quite
straightforward, and that all that is needed for an approach 1
calculation is the uncertainty of the AD and uncertainty of the
EF. It would be helpful to make that clearer in the guidance,
and to show more clearly and succinctly how those twoelements could be obtained/calculated.

Noted

Effort has been made to provide a more user-friendly
guidance in Chapter 3 of the MR in addition to theguidance in the 2006 IPCC Guidelines. Specificguidance on how to calculate the uncertainty of AD and
EF should be considered in sectoral chapters.

462

467

Rejected

Sampling error in a census is not mentioned in the text
and there is no reason to modify the existing text.

3

534

578

It might want to be made explicit that sampling error does not United
exist in a census, by definition.
Kingdom (ofGreat Britain
and Northern
Ireland)Equations 3.0 to 3.0c: It is notclear, what one is going to
Russianderive from the equations, because the equal sign is missing Federation
there. Furthermore, the preceding text is unclear on difference
between the equations as well as options for their use forvariance calculations. It is proposed that the authors explain
conditionalities for application each of the equations proposed.

Accepted

The formulas have been deleted based on commentsfrom another reviewer.

1

3

588

590

Accepted

The paragraph has been streamlined.

6634

1

3

596

596

Editorial: It is proposed to revise the paragraph to reduce theredundancies in the text
The Figure 3.2 is referred to as a flowchart, wherease it is a
decission tree. It is proposed to cross-check the reference forappropriateness.

Accepted withmodification

822

1

3

656

Accepted

Text changed from "Figure 3.2 flowchart shows a basic
step-by-step suggestion on how the choice of" to"Figure 3.1a in Section 3.1.2 shows a basic step-by-stepprocess for choosing an".
Corrected.

824

1

3

665

Accepted

Terms using Ui and xi were included in the equation.

RussianFederation
RussianFederation

Inconsistency and unclear definition of Equation 3.1 while
ThailandEquation 3.2 use Un.
Equation 3.2 use “U1, U2, …Un” for Ui. However, xn not xi. Thailand

Comment ID

Volume Chapter

From line To line

Comment

6636

1

3

665

672

5482

1

3

734

749

826

1

3

739

5484

1

3

833

835

9112

1

3

139

140

9114

1

3

161

162

9116

1

3

312

313

9118

1

3

494

577

9120

1

3

585

585

Country

Response

Authors' note

In some cases, when the sum of negative quantities is equal to Russian
the sum of positive ones, the denominator in the Equation 3.2 Federation
may be "0". In that unique occasion estimation of combined
uncertainty with the use of Equation 3.2 makes no sense. It is
proposed that the authors should discuss this case. An optional
solution may be to separately consider uncertainty of each
inventory category and make a combine uncertainty
assessment with the use of multipication approach (Equation
3.1).

Accepted withmodification

Concern is considered in footnote 4. Text has been
added to the footnote emphasizing the implications.

Remove the Tier 2 information from this example since theuncertainty is run for the Tier 1 example.

Accepted

Tier 2 information deleted.

“DC%” is defined but only “DC” is used in the equation.
Thailand
Should they be the same?
The difference here is not clear to me. Isn't the uncertainty of United States
the trend also a confidence interval of expressed asof America
uncertainties in relation to the trend?

Noted

Tier 2 information deleted.

Accepted withmodification

The authors recognize that the explanation is difficult tounderstand, and at the same time difficult to improve.
An example was added to increase clarity.

The uncertainty analysis doesn’t help the inventory compilers Canada
it simply provides information: Replace “it helps the inventory
compilers” with “ it provides information to inventory
compilers".
The improvement plan is not based on the key category
Canadaanalysis and uncertainty assessment, but it considers theinformation provided by these analyses: Replace “ based on”
with “considering the information provided in”.
This statement is not necessary: “It is difficult to know that the Canada
improvements produce more accurate estimates because thecompilers do not have an omniscient view of the emissions (ifthey did, then estimation would be unnecessary)." It would
suffice to say: "Accuracy is not evaluated through uncertainty
analyses, but must be evaluated through validation
procedures”.
This description of different sampling design is too long and is Canada
not appropriate here as it is not specific to inventories; the
IPCC does not need to reproduce standard equations fromstatistical handbooks. Any guidance on sampling should bespecific to inventories while generic text be replaced byreferences to common textbooks or handbooks (e.g. Sarndal etal., 1992).
It is not clear what “It” refers to, please revise this sentence.
CanadaAccepted

Text "it helps the inventory compilers" replaced by "itprovides information to inventory compilers to be used".

AcceptedDone.

Accepted withmodification

The sentence has been deleted. Additional explanation
is included in Section 3.1.1.

Accepted withmodification

The authors believe this section is relevant and should
be kept but agree with the deletion of the equations.

Accepted

Redrafted.

United Statesof America

Comment ID

Volume Chapter

From line To line

Comment

9122

1

3

734

739

9124

1

3

792

805

9126

1

3

833

835

830

1

4

173

Country

Response

Authors' note

While these calculations can be carried out for individual
Canadaanimal categories, since MCF and UE are not specific toindividual animal categories, the uncertainties calculated forindividual animal categories are not independent. Therefore
when the compiler attempts to put the uncertainty of different
animal categories together, using the error propagation
approach then they will significantly underestimate
uncertainty. This is not a good example for the error
propagation equations.
While the inter-correlated variables resulted in low uncertainty Canada
in this case, it is mainly due to the fact that the slurry emission
factor is very high relative to the others and the fractions of
AWMS are relatively equally distributed among the different
manure types. In other examples from other categories, thesmall differences in uncertainty may not be similar and theresults of the Monte Carlo could be heavily skewed and very
different from the error propagation. The example is not ideal;
it should be more clearly acknowledged why, in this case theresults were not very different and that this may not in fact
always be the case.

Noted

The authors agree that the Tier 1 emission factors will
be correlated among animal categories and this could be
sorted out when applying Tier 2. However, this will notshow in this example as the Tier 1 calculation is done
for just one animal category. No changes have been
made to the text.

Accepted withmodification

The authors acknowledge that the results will always
depend on the particular charactheristics of the data.
They still believe that the example is useful. The text
has been changed as appropriate to indicate it.

This sentence is unclear. The trend uncertainty is the range of Canada
the value represented by Emissions at time 1 minus Emissions
at time 0. We express the trend as the percentage change fromtime 0. So the mean difference in emissions may equal 20 Mt+/- 25%, where emissions in time 0 were 200 Mt. Therefore
the emission trend is a 10% increase. However, it could be as
high 25 Mt or as low as 15 Mt. Expressed in percentage thiswould mean the mean change from time 0 to time 1 is 10%,but it could be as high as 12.5% or as low as 7.5%. If I
understand how the trend uncertainty equation works, thatmeans that the trend uncertainty calculated by the equation
should be +/-5%. It is difficult to understand this from thesentence in lines 833 to 835, but it is really important toclarify.

Accepted withmodification

The authors recognize that the explanation is difficult tounderstand. An example was added to increase clarity.

Chemical formula format of N2O

Accepted

Modified.

ThailandComment ID

Volume Chapter

From line To line

Comment

5490

1

4

182

184

5492

1

4

183

6872

1

4

7566

1

6640

Country

Response

Authors' note

Page 4.13, Table 4.1: It seems the last row in the AFOLU
United Statessection (3-Miscellaneous) attempts to cover all the otherof America
sources or sinks that can occur in AFOLU, but are notspecifically mentioned in the table. It may be useful to provide
a more complete listing of them in the 3-Miscellaneousdescription. Seems like at a minimum this would include thenon-CO2 emissions from biomass burning in forestlands,
cropland, grasslands and wetlands. It may also be worth
mentioning the emission/removals included in the 2013
Wetlands Supplement such as the CH4 and N2O from theburning of drained organic soils, the CH4 and N2O fromrewetting of organic soils and N2O from aquaculture.

Accepted

The suggested categories added.

183

For 1B, the 2006 GL (which had as a starting point a split
United States
between coal, oil, and natural gas) were clearer and moreof America
logical. For 1C, unclear that any disaggregation should be
used. Relatively new source for most countries anddisaggregating to the point that it's not key could be a problem.

Accepted withmodification

Text added to clarify when to disaggregate 1C.
Suggestions accepted for 1B.

183

183

In column for "Category aggregation Consideration" of table Republic of
4.1, the sentences for 2B9, 2E, and 2G, are not clear to
Korea
understand.
What is the meaning of significant? If this is a key, then do I
have to disaggregate that category to subcategories for the key
category
analysis? Please provide more explanation.

Accepted withmodification

This text has been clarified "If aggregated gases are key,
disaggregating by gas should be considered where
methods, data sources and assumptions are different to
identify gases that are may be individually key."

4

206

206

Mathematic formula in equation 4.1 should include absolutevalue signs, similarly as in Table 4.2

Accepted

Formula corrected.

1

4

218

219

Accepted withmodification

6642

1

4

257

257

Column E includes Lx,t which is referred to in
explanation under the table. For F it is difficult to findthe correct notation.
Removed.

7568

1

4

264

264

Table 4.2: To enhance the clarity of key category level
Russianassessment estimates, it is proposed to include formulas in the Federation
headings of columns E and F
It is proposed to further elaborte the section, otherwise remove Russian
the footnote 7
Federation
Mathematic formula of eqation 4.2 is not logical, absolute
Finlandvalue signs should be placed differentially
T(x,t) = abs( E(x,t) - E(x,0) ) / sum( abs( E(x,t) - E(x,0) ) )

6644

1

4

281

282

Accepted withmodification

7570

1

4

409

419

Table 4.3: To enhance clarity of key category trend assessment Russian
estimates, it is proposed to include formulas in the headings of Federation
columns F and G
Examples of key category analysis are not updated, i.e. theFinlandrenewed equation 4.2 is not used in calculation. Please updateor remove Tables 4.5-4.11.

FinlandAccepted
Rejected

Accepted

Column F compares the absolute value of the trend forthe category with the absolute value of the trend of theinventory. Column G normalizes the results, naming it
contribution for the trend.
Done for F but it would be confusing for cumulative tohave this function as its relative to the position in thelist.
Examples have been updated.

Comment ID

Volume Chapter

From line To line

Comment

6874

1

4

411

411

5486

1

4

71

5488

1

4

6646

1

6648

Country

Response

Authors' note

Since the equation 4.2 in line 262 for the trend assessment was Republic ofchanged, it is needed to change the example in table 4.6
Korea(That example is for the previous equation in 2006 IPCC GL).

Accepted

Examples have been updated.

71

Add a sentence describing what this list is. E.g. "Keycategories should be subject to the following:"

United Statesof America

Accepted

Added "as elaborated below".

73

73

Recommend revising title of this header; change "rigorous" to United States
perhaps "category-specific", "tailored", or "focused".
of America

Accepted

Used "focused".

5

227

229

The sentence in lines 227 to 229 is a repetition of the grey text Russianin lines 271 to 273. It is proposed to remove the text in lines
Federation
227 to 229 to avoid duplication.

Accepted

Text removed as proposed.

1

5

366

383

Box 5.3: Calculations in Box 5.3 seem to be different from the Russian
guidance provided in the equeation 5.1. It is proposed to cross- Federation
check correspondence between the Box 5.3 and the equation
5.1.

Rejected

Our view is that the equation does follow the example
provided. The bracketted term is the average ratio
derived from the period for which data exists for bothold and new dataset and Xo is the datapoint for whichdata in the old time series exists but does not exist for
the new dataset. Before this is achieved, there needs tobe a test of variability. That is not necessarily reflectedin the equation but is necessary for the use in theequation. For the sake of transparency Box 5.1B has
been amended by calculation examples using equation
5.1 and equation for estimation of standard deviation
with cross-reference to Vol.1, Ch.3, Box 3.0a. In
addition the following text has been included: "Forsimplicity, the average (0.93) has been rounded to two
decimal places".

5494

1

5

462

481

Linear interpolation results in 14.44 (compared to 14.49),
United States
which would seem to be reasonable, given uncertainties, and is of America
far less complicated. Perhaps an example with more years of
missing data would be clearer (e.g. if the example also
calculated emissions for 2001 and 2003).

Noted

Example has been chosen for simplicity reason.

6452

1

6

214

214

Sentence currently ends with 'checks in the energy.' - 'sector' or United
a synonym is missing from the end
Kingdom (ofGreat Britain
and Northern
Ireland)

Noted

The comment refers to 2006 IPCC Guidelines text.
"energy sector" is suitable edit, but it’s a 2006 IPCC
Guidelines text, we can leave it intact.

Comment ID

Volume Chapter

From line To line

Comment

7436

1

339

We strongly suggest to rewrite the section 6.10.2 (Comparison Germany
with atmospheric measurements).
In section 6.10.2 additions to the original text version of 2006
are proposed, which add some confusion. For example, on the
one hand, the 2006 wording in some paragraphs (in subsection 6.10.2.1) is maintained without change, and does notinclude the advancement of the inverse modelling methods. On
the other hand, within the added paragraphs, successful
examples of developments and first usage of inverse models
for independent verification are mentioned. Nevertheless, inthe same sub-section (6.10.2.1) it is virtually warned against
their use as a standard tool for verification (line 364-365).
The suggested procedures in section 6.10.2 should include
more clearly ongoing international initiatives as the Integrated
Global Greenhouse Gas Information System (IG3IS) of WMO
Global Atmospheric Watch (GAW) programme, the GEO
2017-2019 Work Programme (including the GEO Carbon and
GHG initiative), and the Copernicus initiative for CO2
observing systems. A lot of community calls for strengthening
the cooperation between research, systematic observation andapplication are not appropriately reflected in this draft.
It seems like the whole narrative rather discourages
comparisons with independent methods, e.g., by introducing
some technical barriers – steps termed ‘necessary’ (sub-section
6.10.2.6) might be reasonable in one case but not scientificallyjustified or feasible in other cases.

67597436 (cont.)

4676

Country

Response

Authors' note

Accepted withmodification(1) Revised to remove confusing wording retained from2006 IPCC Guidelines;(2) Added GEO and Copernicus references;(3) Revised 6.10.2.6 to weaken restrictions, add more
explanation why S/N and added constrain matters.

Accepted withmodification

Changed to 'verifying national emission inventory
estimates'.

Also, the unduly tight restrictions of the criteria of applying
inverse model estimates in sub-section 6.10.2.7 impede theuse of independent methods. Wording in this sub-section
implies the definition of only one possible method restricting
other reasonable options too strongly.
We urge the authors to clarify that independent verification is
critical for any far-reaching and sensitive issue. Comparisonswith atmospheric measurements enhance the chance to detect‘unknown unknowns’, and allows for the comparison between
different countries and creates credibility.
1

6

343

344

verifying national emissions' should be replaced by 'verifying
national inventory estimates' to be consistent with the section
6.10.

Japan

Comment ID

Volume Chapter

From line To line

Comment

5498

1

6

344

346

5500

1

6

346

346

6454

1

6

365

366

5502

1

6

369

369

Response

Authors' noteTo provide more context for this update, recommend revising United States
the second sentence to read: "Since the 2006 Guidelines were of America
published, the most notable advances have been achieved in
the application of inverse models of atmospheric transport for
estimating emission at the national scale. An increasing
number of countries are considering applying such models."

Accepted

Revised accordingly.

Recommend inserting a paragraph break between the sentence
ending "countries" and the sentence beginning "An ideal
condition for verification."
Still a considerable scientific progress in this area' should becorrected to 'Still, considerable scientific progress in this area'

United Statesof America

Accepted

Revised.

UnitedKingdom (ofGreat Britain
and Northern
Ireland)United Statesof America

Accepted

Revised (2006 IPCC Guidelines text).

Accepted withmodification

Revised to emphasise the recent progress.

6456

1

6

372

372

UnitedKingdom (ofGreat Britain
and Northern
Ireland)Accepted

Revised accordingly.

5504

1

6

383

390

The sentences at lines 383-385 and 389-390 are somewhat
United States
contradictory and should be better reconciled. The firstof America
sentence states that "inverse modelling is not likely to be
frequently applied as a verification tool of national inventories
in the near future," but the second notes that "inverse
modelling techniques . . . are being applied now in national
inventory estimates," providing a number of examples. To help
reconcile these two sentences, suggest replacing "frequently"
on line 384 with "widely," and inserting "Nevertheless" before
the sentence on line 389.

Accepted withmodification

Revised.

6458

1

6

389

389

inventories, at the end of the line, should be changed toinventory or inventories'

Accepted

Revised accordingly.

6460

1

6

408

408

Should be a comma after 'N2O inventory methodologies'

Accepted

Revised accordingly.

Recommend inserting "already" between "are" and "being" toclarify that, despite the challenges of using atmosphericmeasurements for verification, they are currently being used
for this purpose.
'magnitude of greenhouse gases' should be 'magnitude ofgreenhouse gas'

Country

UnitedKingdom (ofGreat Britain
and Northern
Ireland)UnitedKingdom (ofGreat Britain
and Northern
Ireland)Comment ID

Volume Chapter

From line To line

Comment

6650

1

6

411

439

1794

1

6

419

607

5506

1

6

423

423

4678

1

6

427

431

Country

Response

Authors' note

The application of inverse models may face challenges related Russian
to distinction between natural and human-induced emissions Federationof greenhouse gases. It is proposed that the authors indicate ofthis complexity in the text.
In this section, there are many additions on atmosphericChina
concentration and tracer measurements, and inversion models,
involving a brief description of stable isotope, radioisotope
and atmospheric potential oxygen (APO), which are only
briefly described. It is suggested that when they are firstmentioned, they should be given a science-based description
and definition, including relevant formulas and sources, theirapplication range, uncertainty or limitations. The details are:Lines 419-420: “......complemented by observations of isotopic
ratios, atmospheric potential oxygen (APO), and co-emitted
tracers, such as carbon monoxide.”Lines 540-546: “......and supporting tracer measurements
useful for discriminating between natural fluxes and fossil
emissions, such as atmospheric potential oxygen (APO, as
discussed by Minejima et al., 2012) and radiocarbon 14C in
CO2 (Levin et al., 2003).”
Line 607, Table 6.1: “......Need more CO2 observations
targeting anthropogenic emissions, complemented by APO andradiocarbon observations.”

Noted

The need for distinction stated in other parts of section.

Accepted withmodification

Added text.

After “verification” insert “through atmospheric
United States
measurements”
of America
More implementation details are presented in the IG3IS
Japan(Integrated Global Greenhouse Gas Information System,
http://www.wmo.int/pages/prog/arep/gaw/ghg/IG3ISinfo.html) plan prepared by the Global Atmospheric Watch
program of WMO (DeCola et al., 2017), which will be an up
to date guide for implementing observations and inverse
modelling for inventory verification' should be replaced by'More details are presented in the IG3IS (Integrated Global
Greenhouse Gas Information System) Science Implementation
Plan prepared by the Global Atmosphere Watch (GAW)
program of WMO, which documents "good practice"methodological guidelines for how atmospheric measurements
and analysis methods can deliver valuable information for
inventory verification'' to be consistent with the IG3IS Science
Implementation Plan approved by the 70th session of WMO
Executive Council in June 2018.

Accepted

Revised accordingly.

Accepted

Valid suggestion, replaced ref. to DeCola 2017 by ref.
to IG3IS Plan.

Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

5508

1

6

433

433

For clarity, recommend revising the last sentence of theparagraph to read "Another example of a verification system
based on inverse modeling is also in place in Australia."

United Statesof America

Accepted

Revised accordingly.

5510

1

6

437

437

Regional atmospheric modeling has also been used to verify
United States
halocarbon emissions (HFC-23) from point sources,of America
specifically by Keller et al. Recommend adding "halocarbon
emissions" to the list of emission categories and Keller et al to
the list of references. (See Keller citation at right.)

Noted

Here in the text, emissions at local, facility (single
emitter) scale are mentioned, while Keller 2011 HFC-23
paper deals with larger, regional scale, cited later in text.

4680

1

6

476

476

a system for verifying' should be replaced by 'a verification
system for' to be consistent with the phrase "verification
system" mentioned in lines 431 and 433.

Accepted

Revised a sentence to accommodate the edit.

4682

1

6

476

477

Accepted

Revised accordingly.

6462

1

6

477

477

Accepted

Revised accordingly.

4684

1

6

481

491

National Greenhouse Gas Inventories with AtmosphericJapan
Observations and Inverse Modelling' should be replaced by'national greenhouse gas inventories with atmosphericobservations and inverse modelling' because the initial letter of
each word should be lowercase here.
Emission estimates needs' should be 'Emission estimates need' United
Kingdom (ofGreat Britain
and Northern
Ireland)
The whole texts in lines 481-491 should be formulated asJapanfollows, so that the contents can be better understood:• Surface-based and airborne observations of atmospheric
GHGs are made by, usually, networks of meteorologicalagencies, research institutes and site operators. The
observations need to meet high standards in all procedures
including air sample analysis, data processing, reference gas
maintenance, calibration correction against international
standards, accompanied by metadata on conditions ofmeasurement. Data quality can be better monitored by datasubmission to global databases such as WDCGG (World Data
Centre for Greenhouse Gases). Establishing a national GHG
monitoring network involves optimal network design in order
to set up the observation locations that maximize the effect of
the observations on reducing the uncertainty of the emission
estimates (Nickless et al., 2015; Lopez-Coto et al., 2017). The
guidelines for observation techniques and reference gas
maintenance are provided by such programs as WMO/GAW
and AGAGE (Prinn et al., 2018).

Accepted

Revised accordingly.

JapanComment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

5512

1

6

481

497

United Statesof America

Accepted

Revised accordingly.

6464

1

6

518

526

The formatting should be corrected so that it is clear that
atmospheric observations are a needed component and that
surface-based, airborne, and satellite retrievals are options
under this component
We welcome the mention of the use of inverse model in the
UK as a good example of collaboration with inventory.

UnitedKingdom (ofGreat Britain
and Northern
Ireland)Noted

No action needed.

6466

1

6

526

526

Accepted

Revised accordingly.

5514

1

6

527

596

UnitedKingdom (ofGreat Britain
and Northern
Ireland)
Section 6.10.2.3 has example emission estimates by target gas United Statesand Section 6.10.2.6 has procedures and examples (lines 655 - of America729), If possible would be good to combine examples.
Recommend eliminating Section 6.10.2.3 and combining with
examples in Section 6.10.2.6.

Accepted withmodification

5516

1

6

539

539

Note here also challenges with distinguishing between
United Statesanthropogenic and nonanthropogenic. Note also that satellite of America
and aircraft observations can only collect data on CH4 during
the day.

Noted

832

1

6

546

554

Chemical formula format of CO2

Accepted

There was a misunderstanding that both subsections
give examples, instead section 6.10.2.3 gives overviews,
and section 6.10.2.6 gives procedues backed with
examples, so combining these two is not needed. The
subsection titles were modified to better reflect thecontents.
The difficulty of distinguishing between anthropogenic
and non-anthropogenic is mentioned. This paragraphintends to introduce few typical examples. Use ofsatellite and airborne data is not typical for the national
scale.
Revised accordingly.

5518

1

6

583

595

Accepted withmodification

Added reference to Fraser et al. 2014, corrected thereference list to add Australian NIR 2018.

6286

1

6

592

593

Accepted withmodification

Revised accordingly.

5520

1

6

596

596

It is difficult to evaluate the utility and reliability of theUnited States
methods cited in this example (Australia's modeling of SF6of America
emissions based on atmospheric measurements) without seeing
the underlying analysis. The only citation provided is"Australian Government, 2018)," and there is nocorresponding reference in the list of references at the end of
the chapter.
Request a change from "inventory leakage rates are assumed Australia
and not based on measurements" to "inventory leakage rates
are based on limited measurements"
Recommend including a new section titled "Developing a
United States
Gridded Version of a National Inventory." As noted above,of America
this is a critical step, it is one that the inventory compiler
would need to play a key role in to do so correctly, and there is
no guidance available on how to do so. Please see attachedexample text.

Accepted withmodification

Revised proposed text for gridded inventory andcombined with already existing paragraph.

'and this comparison has got in a better agreement' reads
clumsily - suggest 'resulting in better agreement between
inverse modelling and inventory results'

ThailandComment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

6652

1

6

599

607

The challenge for application atmospheric measurements forverification of greenhouse gas emissions is the distinction
between natural and human-induced emissions of greenhousegases. Additional challenge is attribution of human-induced
greenhouse gas emissions to particular countries. It is
proposed that the authors describe these challenges in section
6.10.2.4.

RussianFederation

Accepted withmodification

Section 6.10.2.4 is discussing the differences between
tracers, and relative difficulties and advantages of theinverse modeling application to those tracers, thus it isbetter to discuss the mentioned challenges in othersections. Challenge of separating anthropogenic fromnatural is mentioned multiple times in the text (forexample in section 6.10.2.1). The difficulty of making
estimate for a single country separation from emissions
by other countries is mentioned in new sentence insection 6.10.2.1.

6468

1

6

638

638

alarmingly' is a needlessly dramatic word (unless this isquoting the authors directly) - 'significantly' will suffice

Accepted

Editorial.

4686

1

6

641

641

UnitedKingdom (ofGreat Britain
and Northern
Ireland)Japan

Accepted

Added to references list.

4688

1

6

652

654

The literature "Matsunaga and Maksyutov (2018)" is referredin the Chapter text, but not listed in the "References" section.
Please include ”A Guidebook on the Use of Satellite
Greenhouse Gases Observation Data to Evaluate and Improve
Greenhouse Gas Emission Inventories, Satellite Observation
Center, National Institute for Environmental Studies, Japan,
129 pp.”https://www.nies.go.jp/soc/en/documents/index.html"It would be more user friendly to provide the source forJapaninformation such as type of observed GHGs and data available
period of each satellite mission for ensuring continuous
availability of satellite observation data.
For example; CEOS Missions, Instruments and Measurements
database online <http://database.eohandbook.com/>

Accepted

Revised. References to literature dealing with this added
to section 6.10.2.4.

834

1

6

657

6470

1

6

660

5522

1

6

664

Typo “PROGAM”

ThailandAccepted

Revised accordingly.

660'implementing such system' should read 'implementing such asystem' or 'implementing such systems'

Accepted

Revised.

664

Change to "from a surface-based or airborne network, orsatellite"

UnitedKingdom (ofGreat Britain
and Northern
Ireland)United Statesof America

Accepted

Revised.

Comment ID

Volume Chapter

From line To line

Comment

5524

1

6

667

668

5526

1

6

668

668

5528

1

6

673

673

6472

1

6

676

676

5530

1

6

677

677

6474

1

6

697

6476

1

6

6478

1

6

Country

Response

Authors' note

In addition to being spatially disaggregated, should
United Statesconsideration be given to temporally disaggregating the prior of America
emissions data to provide a better comparison to when theatmospheric measurements are made. There is potentiallysignificant temporal variability in emissions for example fromsources such as methane from manure management,
enteric/livestock and reservoirs. CO2 flux from lands would
also be different during different times of the year asvegetation grows or dies
Edit to "up-to-date national inventory data, adjusted to include United States
the same time period of the measurement (e.g. same season,of Americasame years) if possible"
Consider adding: "In many cases, steps 1, 3, and 4 are
United States
conducted by research institutions not connected to the GHG of America
Inventory compilation, and steps 2, and 5 are conducted by the
GHG Inventory compiler."
Example 1, Step 1 - ' totally 4 cites'. Presume this should be
United'total 4 sites'
Kingdom (ofGreat Britain
and Northern
Ireland)
The examples in the table above all show good agreement. The United States
guidance does not include steps an inventory compiler should of Americatake if there is not good agreement. For this guidance to be
useful in improving inventories, this is critical. Somesuggested language is attached.

Accepted withmodification

Revised.

Accepted withmodification

Notice of a need for temporal disaggregation added.

Accepted

Revised.

Accepted withmodification

Revised.

Accepted withmodification

The supporting material text submitted with comment
was edited and inserted in the chapter.

697'on route' should be 'en route'Accepted

Revised.

710

710

CBW and DECC haven't been defined at this point

Accepted

Revised. Final checks carried out in the final revision
for editing.

712

712

MHD+CBW should be in brackets

Accepted

Revised.

UnitedKingdom (ofGreat Britain
and Northern
Ireland)UnitedKingdom (ofGreat Britain
and Northern
Ireland)UnitedKingdom (ofGreat Britain
and Northern
Ireland)Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

6480

1

6

732

732

Utility of inverse model estimates for quality checks,
improving the inventory' should read 'The utility of inverse
model estimates for quality checks and improving theinventory'

Accepted

Revised.

6482

1

6

750

750

UnitedKingdom (ofGreat Britain
and Northern
Ireland)UnitedKingdom (ofGreat Britain
and Northern
Ireland)Accepted withmodification

Diminishing return is mentioned in network design
studies, reflected in section 6.10.2.2 text instead.

5532

1

6

758

758

In reference to the flow diagram step that says 'Expand
observation network (and add satellites)' - should this refer tothe diminishing returns of adding more measurement sites?
Are there other steps that could be tried before adding morestations, what about engaging with other countries withverification experience?
Unclear that this is the best approach to do this comparison
United States(developing a national total from the gridded observation and of America
then comparing it to the national GHG Inventory total). It's
great if they match, but if they don't, then what? This is why
it's important to have a gridded version of the national GHG
Inventory, so that any differences can be investigated (e.g. thecompiler can identify which emission sources are occurring in
the area with the mismatch and review relevant AD and EF).

Accepted

Added table entry on action when mismatch is found.

7664

1

6

760

1040

Chapter 6.11 is written with a point of view of models typical Finland
to natural sciences, such as process models used in the
AFOLU sector. Thus, not all guidance, including
documentation and reporting requirements, are appropriate forother kinds of models, such as some transportation models.
Please modify the text and lists of requirements to reflect thevariety of complex models used in the inventories.

Noted

The guidance provided in section 6.12 is notprescriptive to any form of model or modelling
conditions. It is meant to provide guidance on theoverall use of models. Therefore any model use forinventory compilation should follow guidance provided
in section 6.12 to report on the use of any model.

4690

1

6

764

764

National Greenhouse Gas Inventories' should be replaced by'national greenhouse gas inventories' because the initial letterof each word should be lowercase here.

Accepted

Change effected as suggested.

836

1

6

786

Accepted

Change effected as suggested.

5534

1

6

793

Accepted withmodification

Additional bullet points added to account for how
models deal with representation of processes covered by
the models.

813

Japan

What is “E.” in “E. Emission = (Emission factor) x (Activity Thailanddata).”
Additional bullet points in this list could include: 1.) Models United States
can account for more of the environmental and managementof America
influences on emissions/removals than simpler IPCC Tier 1 orTier 2 methods. 2.)Models can allow for estimation ofmultiple emission sources (e.g., direct N2O emissions and soil
C stock changes from mineral cropland soils) in a single
analysis. Coupling the two source categories in a single
inventory analysis can help ensure consistency of activity data
and treatment of the processes and interactions (e.g., C and N
cycling in soils).

Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

4692

1

6

821

821

Japan

Accepted

Change effected as suggested. Proposed change
implemented.

838

1

6

889

National Greenhouse Gas Inventories' should be replaced by'national greenhouse gas inventories' because the initial letterof each word should be lowercase here.
Unclear text “…with Tier 1/2 results.”

ThailandAccepted

Change effected as suggested.

5496

1

6

90

93

Another potential outcome of QA/QC to potentially include:
identification and resolutions of errors (e.g., transcription
errors, omissions, etc.) during the inventory compilation
process. This is a given as part of QC but it is an important
outcome.

United Statesof America

Noted

The suggestion reflects an output and at most a process.
The outcome of such an identification of errors would
lead to an improvement in the estimates or removals
which is an outcome. This is already covered in the firstbullet point. Hence, the text has been kept the same.

7662

1

6

952

1040

Please modify the title "Checklist for ensuring good
Finlandpractice…" by omitting "good practice" in order to avoid
additional good practice guidance for evaluating, documenting
and reporting (on models) on top of good practice and"should" guidance already presented in the chapter. The list of"good practice guidance" in the new chapter on models isalready very extensive and on brink of being beyond means ofa ghg inventory. The checklist includes many new pieces ofadvice on what countries "may" want to evaluate and report,thus please omit "good practice" from the checklist title.

Accepted withmodification

A new sentence has been added to ensure duplication is
avoided.

9136

1

6

552

552

Accepted

Revised accordingly.

9138

1

6

562

568

9140

1

6

607

608

Current wording is slightly misleading (implying the study
Canadaonly related to the United States). Suggest changing “Thestudy focused on a sub-region of the United States….” to the“The study focused, in part, on a sub-region of the UnitedStates….”
The text mentions uncertainty related to inverse modelling
Canadaresults for nitrous oxide and halogenated gases, but nouncertainty figures are given. It would be very helpful if
examples of specific uncertainty ranges were given for models
in particular situations.
The first column of Table 6.1 gives examples of successes
Canadausing atmospheric measurements for verification of GHG
emissions. Although of interest, the clarity of these examples
could be improved if a little more information was provided.
Descriptions of use state “National reporting” or “Nationalemission estimates”. What is the difference? Are
measurements used for verification in both instances? (Areferral is made to the country studies described in section
6.10.2.3, but it does not seem to provide clarification.)

Noted

Accepted

Table revised. More explanation is provided infootnotes.

Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

9142

1

6

737

739

It is indicated that one of the criteria to be satisfied when
Canadaapplying inverse model estimates for comparison with national
inventories is: “Sufficient number of observation sites, andmeasurement frequency for specific gas.” With respect to thenumber of sites, examples are given where anywhere from one
to four sites have been used for particular regions or countries.
Although stated earlier in the chapter that this will vary withthe geography and situation, it would be useful if basic
guidance could be provided on the keys to making a good
choice or at least directing readers to an appropriate reference.

Accepted

Added references to papers discussing required numberof observing stations.

9144

1

6

742

742

It is indicated that a criterion to be satisfied when applying
Canadainverse model estimates for comparison with national
inventories is that: “Uncertainties in the inverse model
estimates are comparable to or lower than those of the GHG
inventory.” No examples of the ranges of uncertainties
associated with inverse modelling are given. Generally,
inventory experts and compilers are quite familiar with typicaluncertainty ranges associated with inventory estimates, but not
those for inverse modelling. It would be very useful if
examples of such ranges could be provided.

Noted

9146

1

6

750

751

(Decision tree for checking the necessary criteria for using
Canadainverse model estimates in the National Inventory
verification.) Decision point: "Expand the observation
network (and add satellites)" should be reworded to "Expand
the observation network (and possibly , add satellites)".
"Adding satellites" is a rather casually-made option, given thescope of this type of undertaking.

Accepted

Revised accordingly.

9128

1

6

339

339

Revise heading of section 6.10.2: atmospheric measurements
are not compared with inventory estimates, rather, emission
estimates derived from atmospheric measurements arecompared to inventory estimates.

CanadaRejected

Section titles of 2019 Refinement follow relevant titlesin 2006 IPCC Guidelines. It is out of scope of 2019
Refinement to revise section titles.

9130

1

6

431

433

Clarify the coverage of operational verification systems in the Canada
UK or Switzerland: are all sources and gases included?

Accepted

Addressed in FD.

Comment ID

Volume Chapter

From line To line

Comment

Country

Response

Authors' note

9132

1

6

506

517

Lines 122-123 define verification as methods that apply
Canadaindependent data, while lines 343-344 state that atmosphericmeasurements can be used to verify national emissions.
However, this paragraph warns that prior inventory estimatesstrongly influence the result of inverse modeling. Therefore thecomparison of inventory estimates with estimates derived fromatmospheric measurements does not provide an independent
verification. Please clarify.

Noted

9134

1

6

538

538

Other articles have noted the challenges of reconciling topdown and bottom-up emissions that are not only from
Northern Europe. Suggest revising the text to expand on
challenges posed by natural emission sources.

CanadaRejected

It was not an authors' intention to list all the available
studies but just to provide an example for Northern
Europe.

9148

1

6

760

761

The guidance given in Section 6.11 is presumably meant toapply only to models used to develop emission estimates, as
opposed to verifying them, but this is not clearly indicated,which could lead to some confusion. It is suggested that one
short statement be added just below the title, making thisexplicit.

CanadaRejectedLines 763-765 of SOD provide relevant information.

9150

1

6

769

769

Is it necessary to have a section on “Why use more complex
Canadamethods”? Could this not simply be integrated into the section
on models?

Noted

9152

1

6

774

777

Stonger wording is needed here to: 1. caution that complex
models are not necessary improvements over simple ones and2. point out the inherent limitations of models when
underlying data are missing.

CanadaAccepted

Addressed in FD.

9154

1

6

793

888

The list of adverse effects is incomplete and as such thisCanadasection is unbalanced. Examples of situations with adverse
effects include: when models are used to replace missing data;
models often lack transparency and are rarely fully
documented; depending on the intended use, model
development may not be cost-effective. Text is clearly biased
in favour of "models".

Accepted

Addressed in FD.

Comment ID

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From line To line

Comment

9156

1

6

796

797

9158

1

6

798

9160

1

6

9162

1

6

Country

Response

Authors' note

The meaning of this statement (describing one of the benefits Canada
of complex models) is unclear: “generally, models may reduce(increase the accuracy of results and usually improve)
uncertainty assessment by providing a system with an
improved structure and more systematic treatment of data”. A
suggested substitute is: “generally, models may reduceincrease the accuracy of results and usually improve reduce
uncertainty assessment by providing words removed: a systemwith an improved analytic structure and more systematic
treatment of data”.

Accepted withmodification

Bullet revised to read: "generally, models may increase
the accuracy of results by an improved representation of
the processes covered by the model and more systematic
treatment of data".

798

Statement unclear. Suggest changing “models can provide an Canada
opportunity to test our understanding of cause-and-effectrelationships, hence to assess the impacts of mitigation efforts”
to: “models can provide an opportunity to test our
understanding of cause-and-effect relationships, hence
potentially assess the impacts of mitigation efforts”.

Accepted

Addressed in FD.

904

905

In our view, it is not necessary to conduct all of the uncertainty Canada
and sensitivity analyses shown, for every model. Therefore,“It is good practice to report:” is suggested to be changed to “It
is good practice to report some or all of the following:”

Accepted withmodification

Text revised to read: "When the model is created ormaterially modified, it is good practice to document(preferably in peer reviewed publications which can bereferenced by an inventory report to avoid duplication):"

948

948

It is indicated that good practice is to report all items on the
Canadagiven list. However, QA is not necessarily conducted on allmodels. Therefore, it is suggested that the item to be reported,“Findings of QA by experts not involved in model
development” should be changed to “Findings of QA by

Noted

experts not involved in model development, when available ”.
6654

1

7

181

214

It is proposed that the authors provide default fraction of
Russianprecursors that completely oxidise to carbon dioxide for each Federation
category (activity) where the emissions of precursors are
estimated. These default fractions should be included in Table
A.7.2.

Noted

Table A7.2 provides the default carbon contents whilst
table A7.1 stipulates that complete oxidation is assumed
for all fuel combustion activities.

Comment ID

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Comment

4694

1

7

286

286

6656

1

7

286

5536

1

7

5538

1

9164

1

Country

Response

Authors' note

There is a description which is "the carbon in NMVOC
Japan
emissions from fueling stations would typically be captured infossil fuel consumption activity data and therefore in emissions
from 1.A." in the column of explanation in this table, but the
carbon in NMVOC emissions from fueling stations may notnecessarily be captured by the emissions from 1.A. because it
depends on the statistical survey method. If the amount of fuelactually refueled to cars is surveyed, the carbon in NMVOC
from fueling stations is not captured by the fossil fuelconsumption data used for 1.A.

Noted

The authors considered this issue and concluded thatmost fuel surveys focus on fuel delivered as opposed toamount of fuel actually refueled to cars and decided tokeep the text as is.

287

It is proposed that the authors provide default values ofemission factors for estimation precursor emissions. The
default emission factors should be included in Table A.7.1,
otherwise separate table should be developed to include
default emission factors referred to in this section.

Noted

The table provides default carbon contents. If complete
oxidation is used, it should be easy for inventory
compilers to estimate emission factors by convertingfrom carbon to carbon dioxide using the ratio of molar
masses.

47

55

Accepted

Revised accordingly.

7

63

63

The current introductory paragraph discussing radiative
United States
forcing & metrics seems misplaced as the first of the chapter. of America
The paragraph starting on line 56 is more appropriately placed
as the introductory paragraph.
Add as a final sentence of the paragraph: "All of these
United Statescompounds can have chemical interactions that may perturbof America
the lifetime and behavior of other atmospheric species, withthe potential for additional radiative effects."

Noted

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

7

46

55

IPCC Guidelines are focused on emissions by sources. This is Canada
unclear in the Introduction. The first paragraph therefore
should: 1) state that national GHG inventory totals need only
account for direct CO2 emissions and that determining CO2
from the atmospheric oxidation of precursors is an optional
calculation, 2) explain that ‘indirect CO2’ occurs due to theoxidation of precursors in the atmosphere and will varydepending on regional atmospheric conditions, and 3) statethat there are currently no IPCC GWPs for CO and NMVOC.

Noted1) The IPCC GL is not to be prescriptive on accounting
rules for what is included, but is to provide method
methodologies for how to estimate emissions. 2) It is
explained in the text already that this CO2 is from theoxidation of CH4, CO, and NMVOCs. The method for
calculation of CO2 from atmospheric oxidation is basedon national scale data that aggregates across local
variation, and the method has been revised to include anoxidation factor to enable countries to apply regional
factors. 3) The IPCC Inventory GLs are intended to be
non-prescriptive regarding selection of metrics for
aggregating GWPs. This chapter only states thatcountries should recognize what their selection of metricincludes and excludes with respect to atmosphericoxidation effects. Section 7.2.1.5 addresses the issues of
metrics with respect to CH4. Given that explanation the
text has not been changed.

RussianFederation

Comment ID

Volume Chapter

From line To line

Comment

9166

1

7

52

54

9168

1

7

127

128

Country

Response

Authors' noteThis text suggests that the “chapter is based on the underlying Canada
assumptions used in the derivation of the GWP and GTP
metrics…” However, the connection is not explained andnowhere else in the chapter are these metrics or theirderivation mentioned. It is therefore suggested that the text of
this sentence (and possibly, the next) be removed.

Accepted withmodification

Further explantion of the implications of different
metrics is included in section 7.2.1.5 with respect tomethane where further explantion is included. Reference
to this section was added. Some text has been removed
that has raised concerns.

Indirect CO2 is not really an ‘input to the atmosphere’. The
Canadause of that term can be misleading to compilers, since it isformed in the atmosphere and not a direct input/release. Moreexact phrasing should be used, for example, "CO2 formation
resulting from the atmospheric oxidation of CH4, CO andNMVOCs". Here, suggest changing “This section provides
guidance on calculating CO2 inputs to the atmosphere fromemissions of carbon-containing compounds that are notincluded under other emission categories” to “This section
provides guidance on calculating atmospheric CO2 formation

Rejected

The proposed alternative language is a process"formation" versus the product (CO2 added to the stockin the atmosphere). Further, the opening paragraph ofsection 7.2.1.5 refers to "CO2 inputs to the atmospherefrom emissions of carbon containing compounds",
which distinguishes it from direct emissions. And thenext paragraph describes the oxidation mechanism. It
does not seem to be productive to dwell on theterminology already used in the 2006 GL for thesecalculations since we are clear that they are distinct fromdirect emissions from sources.

from of precursor gases that are not included under otheremission categories’.
9170

1

7

153

153

Use of "CO2 inputs to the atmosphere" should be replacedwith "formation of atmospheric CO2 from the oxidation of
precursors" to avoid confusion between direct and indirect
CO2.

CanadaRejected

See above with response to line 127.

9172

1

7

155

155

Add context to clarify the use of "indirect CO2" as comparedto"‘direct CO2 input to the atmosphere".

CanadaRejected

See above with response to line 127. The term "indirect
appeared in text twice, which were removed.

9174

1

7

162

162

Replace: ‘CO2 resulting from emissions of…’ with‘atmospheric CO2 formation resulting from the oxidation of….’ to be more specific and clear.

CanadaRejected

See above with response to line 127

9176

1

7

164

164

Replace ‘account’ with ‘calculate’ or ‘estimate’, since molar Canada
ratios are used to estimate precursor gas oxidation. It would
also be useful to add some text to assist compilers inrecognizing that a) some precursor gases remain un-oxidized
and b) that the molar ratio approach does not take into
consideration the actual time for oxidation to occur especiallyfor NMVOCs that have very complex hydrocarbon molecules.

Accepted withmodification

Revised text to replace "accounted" with "estimated" or"included" or "addressed". A) method now includes
oxidation factor, and existing text on uncertainty at theend of section 7.2.1.5 addresses complex NMVOC
oxidation processes.

Comment ID

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Comment

Country

Response

Authors' note

9178

1

7

170

182

Replace ‘input of CO2’ and ‘Input CO2’ with ‘atmosphericCanadaCO2’. The term ‘input’ is misleading since these are not CO2
input/emitted into the atmosphere instead they are formed in
the atmosphere.

Rejected

See above with response to line 127.

9180

1

7

185

185

Need references and justification to support the default values Canadaof 0.6 and 0.83 for NMVOC; it will vary based on speciation
profiles and local atmospheric conditions.

Accepted

Included citation for entire paragraph for both default
values.

9182

1

7

190

190

Replace “accounting” with “list of precursors that contributes Canada

Accepted withmodification

Replaced the word "accounting" with the term
"estimation".

to the formation of CO2 ”. (The method is not an accounting,but an estimation based on approximation.)
9184

1

7

204

207

Some justification (or details from a supporting reference)
Canadashould be provided for the applicability of the default
percentages of mass carbon content presented (i.e., 60%,85%), considering it can range from 51% to 100% for CH4 (asan example).

Accepted withmodification

Text has been revised by adding to parenthetial wheredefaults are introduced a reference to supporting data in
Table A.7.3

9186

1

7

209

210

This text indicates: “Boucher et al. (2009) assumes 95% ofCanadaemitted CO2 is oxidized with a range of 51 to 100 percent.”
Without more information, the significance of this statement is
unknown. Further, clarity should be provided here: over whattime period? Why was the 95% figure selected when the range
was so wide?

Noted

The study is cited and users can refer to it for more
information, as is done with other references in the
IPCC GL. The 95% mean value is taken from Boucher(2009). The values closer to 50% are quite rare.

9188

1

7

211

214

Supporting documentation for the duration from ‘minutes to
Canadamonths’ for NMVOCs to oxidize, since it is possible that somespecies may take years while others don’t get oxidized.

Accepted withmodification

Added the word "primarily" to eliminate absolute natureof sentence. The vast majority of NMVOCs by mass
will have short atmospheric lifetimes.

9190

1

7

47

47

Meaning of sentence somewhat unclear. To clarify, suggest
adding the word ‘direct’ to line 47 as follows, “Global
warming potential-weighted greenhouse gas emission totals
are based upon direct greenhouse gas emissions…” Also,
include or list direct greenhouse gases. I.e. Direct greenhousegases with accepted GWPs are CO2, CH4, N2O, HFCs, SF6,
PFCs, NF3’.

Rejected

The term "direct" is not a term used in the IPCC GL,
and there is no definition available in the Glossary for it.
So this chapter should avoid introducing a new
undefined term. However, the core is the reference tochapters 2-5, where methods for emission calculation
are provided. Only this section deals with theatmospheric transformation of carbon containing
substances.

CanadaComment ID

Volume Chapter

From line To line

Comment

9192

1

7

50

840

1

8

52

Country

Response

Authors' noteThis text brings up the subject of radiative forcing metrics, but Canada
it appears to contradict standard IPCC inventory guidance.
How does ‘the use of any radiative forcing metric…’ fromother…‘assessment reports of the IPCC’ ensure comparability
and consistency? This is not in line with IPCC’s guiding
principles for consistent and comparable inventories. The
intention of current text is not clear, but it is suggested thatnew text be substituted, which clearly explains reasons forutilizing the method outlined in this chapter, which is based on
the calculation of indirect CO2 from molar ratios.

Accepted withmodification

The orginal statement has been modified by deleting one
sentence. This remaining statement on metrics is
included to indicate that choice of metric is relevant to
the methods addressed in this chpater, but that theseGLs should not be prescriptive to the current or future
choice of metrics used to address radiative forcing.
Countries that may choose not to apply metrics at all
still have one option for estimating these inputs.

General concerns:
Thailand-Objective of Chapter 8 is to provide the guidance on how toreport national inventory but the chapter outline is not as clear
as it intends. For example, section 8.2 should not start withmiscellaneous points about what sources should or should notinclude in the national inventory (lines 54-85). The content
may start with a prefer coverage in the national inventory
report by sector or source category (energy, IPPU, AFOLU,
Waste, other). Then, other miscellaneous points can be addedor provide a prefer outline of the report.

Rejected

What the reviewer is asking for is already addressed in
Chapters 1 and 4 of Volume 1 including in each
introductory chapter of the sectoral Volumes. Also, it isimportant for the reader to have context of reporting
principles such as those covered in section 8.2 (Gases,
coverage, time frame, sectors and categories) before
getting to section 8.5 dealing with definitions andclassificatons.

Comment ID

Volume Chapter

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Comment

Country

Response

Authors' note

7106

1

8

110

118

The Norwegian Environment Agency has recently performed a Norway
screening study on the potential occurrence of emerging
substances to the Arctic environment. Many of the compounds
have been selected for the study as they have been identified as
chemicals of emerging concern in a recent report from the
Arctic Monitoring and Assessment Programme (AMAP
Assessment 2016: Chemicals of Emerging Arctic Concern,2017). As one of the main findings of the study, five volatilefluoroorganic and related compounds (as listed under) weredetected in Arctic air for the first time. Several of thesecompounds, which are by instance used as liquids in chemicalindustry and medical applications, have not been found inenvironmental samples before. The detection of thesecompounds in Arctic air samples is a potential indication of
long-range transport and persistency. In addition, thesecompounds have no sink in the lower atmosphere and they
have a strong IR-absorbance, which together make it very
likely that they can act as long?lived greenhouse gases. Pleasetake those information into account and consider to include
those compounds in the assessment. A report summarizing thefindings of the study will be published in a couple of weeks.
The substances in question are: PFPHP Perfluoroperhydrophenanthrene (Vitreon, Flutec PP 11) - CAS
306-91-2, PFTBA - Tris(perfluorobutyl)-amine (FC-43) CAS 311-89-7, TCHFB 1,2,3,4?Tetrachlorohexafluorobutane - CAS 375-45-1, DCTFP- 3,5-Dichloro-2,4,6-trifluoropyridine - CAS 1737-93-5,
DCTCB - 1,2-Dichloro-3-(trichloromethyl)benzene - CAS
84613-97-8

Accepted

The authors thank the reviewer for highlighting these
new F-gas observations. The electronics authors
recognize PFTBA as a popular heat transfer fluid usedin electronics manufacturing. Although the compound's
GWP and atmospheric lifetime have not been publishedin the peer-reviewed scientific literature, research by the
manufacturer, as well as the compound's perfluorinatedstructure, indicate that it has a very long atmospheric
lifetime and a 100-year GWP near 10,000. Guidance on
estimating emissions of this and other fluorinatedliquids is provided in Chapter 6 of the Refinement.
Research into the other compounds indicates that they
are used in a variety of applications, some of which are
addressed in the 2006 IPCC Guidelines. For example,
PFPHP is used in cosmetics and medical applications,whose emissions of perfluorinated compounds are
addressed in Volume 3, Section 8.3 of the 2006 IPCC
Guidelines (Use of SF6 and PFCs in Other Products).
The authors will note the other substances as potentiallyof interest for future IPCC research.

5548

1

8

175

178

Recommend adding a sentence or two also indicating that it is United States
good practice to perform recalculations of the time-series asof America
necessary

Accepted withmodification

Suggestion implemented by including a sentence on
recalculation linking to Chapter 5 (section 5.2) ofVolume 1 of the 2019 Refinement (guidance on
recalculations).

Comment ID

Volume Chapter

From line To line

Comment

5550

1

8

254

258

5552

1

8

254

5540

1

8

5542

1

8

Country

Response

Authors' note

Pages 8.30 and 8.33, Table 8.2: The category
United States“3B2—Cropland” indicates that emissions and removals from of America
rice fields including CH4 should be reported in this category,
but the category “Rice Cultivation—3C7” also indicates that
CH4 emissions from rice cultivation should reported in thatcategory. Is it optional on where to report rice CH4, or is thetable wrong? I would also note that in Volume 4, Chapter 1,
Table 1.2 of the 2006 IPCC Guidelines, CH4 emissions fromrice is only included under the Cropland Remaining Cropland
category. However, in Volume 4, Chapter 1, Figure 1.4 of the2006 IPCC Guidelines it only shows rice CH4 under a separate
category 3C “Aggregate sources and non-CO2 emissions
sources on land.” Seems like some clarification should be
provided in Table 8.2 of the 2019 refinement to consistently
show the structure of AFOLU. Depending on how this issueof rice reporting is resolved, it may be necessary to update
Figure 1.4 and Table 1.2 of Chapter 1, Volume 4 of the 2006
IPCC Guidelines as part of the 2019 refinement work.

Accepted withmodification

Thank you for picking this up. Text added to 3B2 tohighlight that 3B2 does not include CH4 emissions fromrice cultivation and that it is included in 3C7. The
methodology for estimation of methane emissions fromrice is provided in section 5.5 of Vol.4, Ch.5 (3B2
Cropland). However, according to Vol.1, Ch8, table 8.2
and also Figure 1.4, Vol.4, Ch.1 methane emissions
from rice cultivation should be reported under 3C.7.

258

Page 8.31, Table 8.2: For the category “Wetlands” should the United States
subcategory of coastal wetlands (from the 2013 Wetlandsof America
Supplement) be included in the table? Also, a subcategory forlands converted to coastal wetlands?

Accepted withmodification

A sentence titled "Emissions estimated for the categories
in the Wetlands Supplement are included in the land use
categories forestland, cropland, grassland as well as
wastewater treatment and discharge. The 2013
Supplement to the 2006 IPCC Guidelines for national
Greenhouse Gas inventories: Wetlands provides
guidance on reporting these categories and the subcategories contained in the supplement" has been addedin section 8.2.1 to clarify the guidance already provided
in the supplement to avoid duplication in guidance.

32

42

Should there be mention of the 2013 Wetlands Supplement in United States
this introductory section? Even a footnote to remind users that of America
the 2013 Wetlands Supplement exists and is available for use
in conjunction with the 2016 IPCC Guidelines and this latest
2019 refinement would be useful.

Accepted withmodification

The Wetlands Supplement is mentioned in section 8.2.1
to highlight the relationship between the reporting
guidance provided in the refinement and that provided
in the supplement with respect to categories andsubcategories related to wetlands.

56

56

Recommend revising this text to be more clear about exactly
where these emissions should be attributed (which country)
based on the end-user. Perhaps providing an example.

Accepted withmodification

The sentence has been revised to be more clear in termsof which category it is referring to and the other gases
affected.

United Statesof America

Comment ID

Volume Chapter

From line To line

Comment

4696

1

8

77

79

5544

1

8

80

5546

1

8

84

842

1

Annex 8A.2

7140

1

Cover page

5306

1

1

365

373

5308

1

1

370

370

9078

1

1

373

373

5310

1

1

374

9080

1

1

9082

1

5312

1

Country

Response

Authors' note

The allocation of CO2 emissions captured for use should beJapanmore flexible because it could be better to report CO2
emissions not under the category where CO2 were captured
but the category where CO2 were used from the viewpoint of
reduction measures. Therefore, "unless it is shown that theCO2 captured is reported in other sectors properly" should add
to the end of this paragraph.

Accepted withmodification

Captured emissions should be reported where they occur
so that the net emissions (emissions - capture) are easy
to verify. However, if CO2 emissions occur during theiruse in another category, the emissions associated withuse should be reported where CO2 is used (see Ch.8,
section 8.2.1).

81

It might help to clarify that the non-CO2 emissions from
United States
combustion of biomass for energy are reported as part of theof America
Energy sector. Also, it would be useful to clearly state thatwhile the CO2 emissions from combustion of biomass arereported in AFOLU, they are not explicitly identified as
emissions from combustion in reporting. This is implied bysaying they are part of the “net changes in carbon stocks” butthis is an important point that many people have been confused
about over the years so additional clarification would be
helpful.

Accepted withmodification

This issue is now addressed in Chapter 1 of Volume 1
under section 1.1 titled "Concepts".

85

Isn’t this also true for N2O resulting from leaching and runoff? United States
These N2O emissions can also occur outside of the countryof America
where the N runoff or leaching occurred.

Accepted

Text amended.

Annex 8A.2 has some table and line crossover to the next page Thailand
without proper break.
Please consider to add EF to the list of abbreviation in Annex Norway
8A.1
Should be noted up front or as part of re-inserted/updated
United Statescompilations steps in the 2006 GL and cross-referenced from of America
roles/responsibilities.
Not just QA and verification, but QC activities too.
United States
Recommend adding.
of America
Change” illustrated below” to “illustrated in Table 1.8 below”. Canada

Accepted

Editing revised. Tables corrected.

Noted

EF addressed in the Glossary.

Accepted withmodification

Added cross reference in Table 1.3 to section on QA/QC
management.

Accepted

Added QC to bullet.

Accepted

Added cross reference to Table 1.8.

381

I would reorder the table to have the IPCC categories listed
first. Clarify what an owning stakeholder is. Is it the source
lead responsible for implementing the improvement?

United Statesof America

Accepted

Column reordered and stakeholder term replaced intable footnote with more specific language.

385

385

Should be in bullet form.

CanadaAccepted

Bullet corrected.

1

386

404

Section 1.5.4.4 (Education, Awareness Raising and Publicaccess to the Information) is beyond the scope of IPCC
Guidance and should be deleted.

CanadaAccepted withmodification

Text in this section has been refined and reduced tofocus more narrowly on role of education in engaging
stakeholders as users of GHG inventory outputs.

1

401

404

Line 401-404 should highlight the policy-neutral, technicalrole of the inventory to inform these other uses. The
inventory’s role is to present findings resulting directly fromthe data.

United Statesof America

Accepted withmodification

Last bullet in list has been deleted.

Comment ID

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From line To line

9084

1

1

236

9086

1

1

105
Table 1.1

9088

1

1

138
Table 1.3

Comment

Country

Response

Authors' note

"Illustrative work plan" for the preparation of GHG inventory Canada
is overly prescriptive; clearly label this text as a possible
example ONLY.
129
This section suggests that information on commitments
CanadaTable 1.2 supported by the GHG inventory be provided. The statedpurpose of Table 1.1 is to provide useful detail on why the
GHG inventory is needed and to define and prioritize the dataand expert needs, which exceeds the requirements of the 2019refinement terms of reference and the purpose of the guidance
document. This type of information may be relevant when
considering improvements, however given that thisinformation does not enhance the emission estimates being
produced, this requirement should simply be removed. Thissection provides an example table to be used (Table 1.2),
which is overly prescriptive.

Accepted

Cross-reference added noting table as example.

Noted

No requirement is specified in section. Text has been
modified to remove mention of commitments. Table isillustrative and an example, and chapter introduction
states that guidance is not intended to be prescriptive.

162“Managing the interests, contributions and involvement of
CanadaTable 1.4 stakeholders” is beyond the scope of this IPCC document andtherefore any guidance on this should be removed.

Accepted withmodification

Language modified to refer to both stakeholders andactors. Sentence on interests changed to state thatinterests should be "understood" not managed.

CanadaNoted

Box cross reference already indicated to be example.

CanadaAccepted

Text corrected to refer to National.

248

This sections provides a table on stakeholder roles andresponsibilities (Table 1.3), however the listed "stakeholders"
are not actual stakeholders, but rather members of theorganization structure. Stakeholders are people or groups
impacted by the GHG estimates and not the people creating theestimates. The provision of a table that defines the role of eachstakeholder/member is overly prescriptive and this section
should be deleted or revamped to provide guidance.
Chapter 6 already provides guidance on roles andresponsibilities with respect to planning, preparation andmanagement of inventory activities. It is unclear what value isbeing added through this duplication.

9090

1

1

213

248

9092

1

1

Table 1.7

354

The 2019 refinements for datasets and dataflows are overly
prescriptive; clearly label this text as possible examples
ONLY.
The table column name is “National Nomenclature” and thenote on line 354 has a mix of “Native nomenclature” and“nomenclature used nationally”. Suggest to only use“national” and be consistent throughout the text.

Comment ID

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Comment

4904

4

1795

A common flaw in the use of complex model is that the user - France
and even sometimes the designer - are not able to track backthe key drivers of their results. This is why an interpretation of
the differences with simpler - Tier 1 or Tier 2 - approachseems to be good practice as well. It would garantee that the
key engines with the "black box" have been identified and areconsistent with the current state of knowledge. Accordingly,
We recommend adding a fourth bullet point to this list of goodpractices pertaining to model evaluation:"It is also good practice to compare the model simulation withsimpler Tier 1 or Tier 2 estimates, and to be able to identify the
key drivers of the possible differences between the higher andlower Tier estimates."

2

1795

Country

Response

Authors' note

Noted

Copied from Volume 4 (Chapter and Line numbers are
not appropriate).