Review Comments by Governments on Second Order Draft of Volume 2 of 2019 Refinement to the 2006 IPCC Guidelines for National Greenhouse Gas Inventories
Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

CanadaRejected

Augmentation of coal resources is the additional resource of coal and lignite
found as a result of exploration during a reporting year which, when added tothe previous year’s resource, gives current resource. Further, the augmentationof coal or lignite resource is is a proxy data that may be linked to the drilling
performed in a year and hence to the number of exploration boreholes drilled in
the reporting period. It may not be out of place to mention that the entire
augmented resources are not the sources of greenhouse gas emission but it
indirectly represents the number of coal exploration boreholes since theexploratory drilling is usually carried at known interval over coal bearing areas
for assessment of coal potentiality. The spacing of the boreholes depends on
geological structure, deposit character, nature of data required for mine planners
etc. Augmentation of resource is either presented in the geological reports
prepared by exploration agencies or can be very easily calculated by thedifference of resource of the current year and the previous year.
Proved reserve on the other hand represents the quantities that certainly can berecovered in the future from known deposits under existing economic andoperating conditions. It is not only the reserve found in the reporting year but
also includes the reserves found in past several years. Therefore, proved reservecannot be linked to the number of exploration boreholes drilled in the reportingyear.
Therefore, proved reserve cannot be used as activity data to represent numberof exploration boreholes drilled in a reporting period but augmentation of
resource (or new addition to the resource in a reporting period) may be used forthis purpose.

Accepted withmodification

This new text is to interpret Equation 4.1.2 and how adjustment due to seam gas
utilization and flaring should be made/considered to the seam gas emissions.
Please note that the later is calculated on the basis of Equation 4.1.1. There is
no double-counting of CO2 emissions in Equation 4.1.2 (the fugitive CO2
emission factor in Equation 4.1.1 only refers to formation CO2 that is containedin the seam gas because it does not take into account any scenario of seam gas
utilization and flaring. Therefore, the oxidized CO2 from coal mine methane
flared is not double-counted). Also please note that accounting for the oxidized
CO2 from methane flared is already included in the 2006 IPCC Guidelines (Seetable 4.1.1 and Equation 4.1.5 in the same chapter). This new text is just to echo
it from the view at an aggregate level. Nevertheless, wording of the text has
been further refined to avoid such misunderstandings.

Rejected

The new text under Equation 4.1.2 in the Refinement has explained why "theamount of CO2 contained in the gas recovered and utilized for energy
production" should be subtracted. If seam gas is recovered and utilized forenergy production purpose, then the CO2 contained in the seam gas is held in
the recovered gas until the later is being consumed. This amount of CO2 (alongwith other carbon-containing components in the recovered gas) would bereported under other relevant source categories (instead of fugitive emissions
from mining activities) depending on the end-use characteristics of therecovered gas. There is no underestimation of CO2 emssionns in Equation
4.1.2, or any inconsistency between the Refinement and the Chapter 2, Volume2, of the 2006 Guidelines.

9194

2

4

341

343

These two sentences are unclear. Should clearly differentiate between resource available tobe mined and annual production. Note a more detailed explanation in lines 1166 to 1169.
Replace the term resource augmentation with “proven reserves” or some variation of that
term.

5556

2

4

380

402

The new text addressing fugitive CO2 emissions for coal mines is confusing and could be United States of America
clarified. The new text appears to be addressing the oxidized CO2 when coal mine CH4 isflared. However, the description of "the amount of CO2 contained in the gas that isrecovered and utilized for energy production" is confusing, implying that what is estimatedis the CO2 present in the gas prior to flaring (e.g., see the reference in the new text to CO2
already being included in the fugitive CO2 emission factor for underground mining). This
text also implies a double-counting of CO2 emissions in the revised equation (due toinclusion in the fugitive CO2 emission factor for underground mining and also inclusion
as fugitive CO2 emissions from flaring). The new text section, which is focused on CO2,
also addresses in passing the unburned fraction of CH4 during flaring. Accounting forthese CH4 emissions, due to incomplete combustion at the flare, is appropriate, but it is
not addressed elsewhere in the new text or in the pre-existing text. This should be further
explained and clarified.

6660

2

4

385

386

Equation 4.1.2 elaborated for inclusion CO2: As it currently stands, the equation forreporting CO2 emissions for underground mining activities seems to lead tounderestimation of the CO2 emissions, if those originate from recovered coalbed gas
burned for energy purposes (note that the reporting on CO2 emissions from combustion
for energy purposes of the recovered coalbed gas is treated under Chapter 2, Stationary
Combustion, of the 2006 Guidelines). It is proposed that the authors cross-check theEquation 4.1.2 and supporting text to avoid inconsistency in the 2019 Refinement.

Russian Federation

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Russian Federation

Accepted

6662

2

4

425

425

Editorial: the word "purposes" seems redundant. It is proposed to remove it.

5558

2

4

568

568

Should the word "sole" be inserted before "purpose of gas mining delivery". Or does the United States of America
rest of the sentence also apply when gas is extracted from coal seams for delivery into thenatural gas system as a secondary activity associated with actual coal mining of the seam.
Degasification may be a regulatory requirement for coal mining operations, and theoperator may chose to deliver the gas rather than vent it to the atmosphere. Check that
there is clarity and consistency with Vol 2 Ch4 lines 1380-1382.

6664

2

4

717

717

Equation 4.1.6 elaborated for inclusion CO2: As it currently stands, the equation forreporting CO2 emissions from surface coal mining seems incomplete. It is proposed thatthe authors reconcile the equation and elaborate on it.

6876

2

4

785

785

6878

2

4

979

9196

2

4

5560

2

6668

6292

Authors note
Deleted.

Accepted withmodification"for the purpose of.." has been deleted from the text to remove any ambiguity
regarding intent. The corressponding text in the the Oil and Gas section Vol 2
Ch4 lines 1380-1382 has been alighned with that of the coal section.

Russian Federation

Accepted

Have added a term for "Post-mining emission of CO2" in Equation 4.1.6 forcompleteness. Have also added clarifying text in 4.1.4.1 noting that while nodefault method is provided for estimating Post-mining emissions of CO2 ,countries can provide their own country-specific emission estimate.

Average CO2 emission factor is not correct.
0.65㎥/tonne → 0.44㎥/tonne

Republic of Korea

AcceptedError identified. The text has now been updated.

979

There is only the emission factor for the inventory year 1990 - 2016 in Table 4.1.6 butabandoned underground mines calculation for 2017 or 2018 may be necessary in the next
year because 2019 Refinement will be approved in May 2019. This is one way to provide
an calculation formula like Tier 2.

Republic of Korea

Accepted

The abandoned mines methodology is out of scope. However it is acceptable toupdate this table for years beyond 2016.

1157

1157

Required coal data is often unavailable on a yearly basis. What would be the suggested
solution when data on “resource augmentation” is only available on a decade by decadebasis? Can options be provided for national inventories which do not have this data
available?

CanadaAccepted

Included one small para in section 4.1.6 (5th Paragraph).

4

1161

1161

Is it possible that a country would collect data on the number of exploratory borewells
drilled, and that those data would be relevant to an estimate of emissions? If so, theninsert the word "usually" or "typically" before "readily available".

United States of America

Accepted

Insert the word "usually" before "readily available".

2

4

1170

1171

Figure 4.1.4: The decision tree seems to undermine general concept of inventory
improvement, which builds upon key category analysis. In the 2006 Guidelines, thequestion if the category concerned is key was put in the beginning of each decision tree
and guided further actions of inventory compilers. However, in the present structure ofdecision tree, this question is missing. To maintain concictency in decision treepresentation, it is proposed that the authors reconcile the decision tree to include key
category identification. Furthermore, it is also proposed to include currently missing
reference to Figure 4.1.4 in the text of section 4.1.6.1.

Russian Federation

Accepted

Decision tree updated. Reference inserted in line 983.

2

4

1170

1171

The Decision tree in Figure 4.1.1 needs to accommodate the Tier 3 method option(Borehole specific approach) that is introduced in line 1217.

Australia

Accepted

Decision tree updated.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

1796

2

4

1174

1175

From line 1174-1175, it seems that no information is available in the scientific literature todevelop well-established emission factors for estimating emissions from coal exploration,
whether number of coal exploration boreholes or augmentation of resource is used as
activity data. For this reason, as well as to be consistent with the treatment of othersubcategories (such as Abandoned Surface Mines, Wood Pellet production, Biomass to
Liquid and Biomass to Gas) that if insufficient information is available in the scientific
literature, a methodology should not be provided in the body of the guidelines. Therefore,
It is suggested that section 4.1.6.1 through 4.1.6.6 be moved to the annex part as merely
an indicative methodology or a basis for further research.

China

Accepted withmodification

Text modified in 4.1.6.2.

1798

2

4

1179

1193

Reference should be provided to demonstrate scientific rationality of this method, as well
as source of these default emission factors.

China

Accepted

Additional detail has been provided (lines 1054 to 1060) on the source of theemission factors and method (expert judgement).

6670

2

4

1179

1221

The descriptions of tiers 1 to 3 and the equations 4.1.14 and 4.1.15 seem to be irrelevant
for Choice of Emission Factors sub-section (4.1.6.2). They seem more appropriate to
Choice of Method sub-section (4.1.6.1). It is proposed that the authors consider moving
the description of tiers and the equastions concerned to section 4.6.1, while the emission
factors are retained in the section 4.1.6.2.

Russian Federation

Accepted

Text amended. The description of tiers and corresponding equations have been
moved sub-section 4.1.6.1 and the emission factors have been retained in the
sub-section 4.1.6.2.

6672

2

4

1182

1189

Equation 4.1.14: The equation for estimation of methane emissions from coal explorationbuilds on annual augmentation of entire coal reserves. The estimation method looks
incorrect, because as such, the coal reserves do not produce emissions in a stable state.
The emissions occur with the start of mining activities (exploration, production, treatmentetc.). With this, simple presence of augmented coal reserves cannont be considered as thesource of emissions. Indeed, the exploration boreholes constructed annualy for coalreserves assessment are emission source categories. However, it does not mean that all
greenhouse gases accumulated in augmented coal reserves release through exploration
boreholes (note that the equation 4.1.14 is currently designed in a way that all augmented
coal reserves form the source of greenhouse gas emissions that release through theboreholes). It is proposed that the authors reconcile the design of equation 4.1.14 toconcentrate on the number of exploration boreholes and provision specific emission
factors per exploration borehole.

Russian Federation

Accepted withmodification

Major coal producing countries do present coal resources on an year-to-yearbasis. These may be ascertained from several governmental and nongovernmental reports and links. Therefore, augmentation of coal resources onannual basis can be obtained to a large degree of accuracy. Number of
exploration boreholes drilled annually seems to be a better option. However,this data is not readily available in national statistics. Therefore, we haveconsidered this approach in a Tier 3 method. Tier 1 and Tier 2 methods basedon augmentation of resorces and depth-wise augmentation of resorces
respectively, can be used if data number of boreholes drilled is not available orcannot be collected from coal exploration agencies or corporates.

850

2

4

1185

1193

What is the intended meaning of “Augmentation of Resource”?

Thailand

Noted

It has already been defined in the text as "new addition of resorce".

1800

2

4

1190

1196

Given that low, average and high CH4 EFs are provided for Equation 4.1.14, some hints
or instructions should be provided so that inventory compilers in practice know how to
select suitable EFs.

China

Accepted

Hints has been provided.

1802

2

4

1197

1213

Reference should be provided to demonstrate scientific rationality of this method, as well
as source of these default emission factors.

China

Noted

The depth-wise approach has been merged with the global average approach.
Additional detail has been provided (lines 1054 to 1060) on the source of theemission factors and method (expert judgement).

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note
Major coal producing countries do present coal resources on an year-to-yearbasis. These may be ascertained from several governmental and nongovernmental reports and links. Therefore, augmentation of coal resources onannual basis can be obtained to a large degree of accuracy. Number of
exploration boreholes drilled annually seems to be a better option. However,this data is not readily available in national statistics. Therefore, we haveconsidered this approach in a Tier 3 method. Tier 1 and Tier 2 methods basedon augmentation of resorces and depth-wise augmentation of resorces
respectively, can be used if data number of boreholes drilled is not available orcannot be collected from coal exploration agencies or corporates.

6674

2

4

1200

1204

Equation 4.1.15: The equation for estimation methane emissions from coal explorationbuilds on annual augmentation of entire coal reserves, which seems incorrect, because coalreserves as such do not produce human-induced greenhouse gas emissions. The humaninduced emissions occur with the start of mining activities (exploration, production,
treatment etc.). With this, simple presence of augmented coal reserves cannont be treatedas a source category. Indeed, the exploration boreholes constructed for coal reserves
assessment are emission sources. However, it does not mean that all greenhouse gases
accumulated in coal reserve release through exploration boreholes (note that the equation
4.1.15 is currently designed in a way that all augmented coal reserves are the source ofgreenhouse gas emissions that release through the boreholes constructed). It is proposedthat the authors reconcile the equation 4.1.15 to concentrate on the number of exploration
boreholes and provision specific emission factors per exploration borehole.

Russian Federation

Accepted withmodification

6294

2

4

1217

1221

The text discussing the Tier 3 method for coal exploration boreholes mentions the use ofgas content and desorption data in determining a high tier approach, which will be usefulfor countries developing a Tier 3 approach. However mention should also be added ofother factors relevant to a Tier 3 approach such as the number of boreholes, permeability
and the impact of management actions such as borehole capping. This would allow
countries to have the flexibility to develop Tier 3 approaches that are best representative otheir circumstances.

Australia

Accepted

Mention of other factors has been made.

6296

2

4

1222

1231

It would be helpful to include a short paragraph here that notes when considering aborehole-specific approach, there is a need to ensure the source boundary distinction
between boreholes that are drilled as part of coal mine production (which are alreadyincluded as part of Undergound and Surface coal mining activities) and those drilled forcoal mining exploration. Inclusion of this will assist inventory compilers to avoid double
counting.

Australia

Accepted

A short paragraph has been included.

6676

2

4

1226

1226

The statement in paragraph is not necessary correct because the augmentation of coalreserves is not necessarily performed annually, and it may not be necessary to produce
new boreholes to assess year-by-year changes in coal reserves, especially if the coal basin
is subject to permanent exploration and processing (production). Furthermore, otherexploration methods have been developed recently which do not require construction of
boreholes or tend to reduce their number as much as practicable. Besides, the equation inline 1226 may have negative result, if coal reserves decrease. It is proposed that theauthors reconcile the guidance on reporting on GHG emissions from coal exploration
based on augmentation concept and concentrate on the treatment of boreholes produced
for exploration purposes.

Russian Federation

Accepted withmodification

6298

2

4

1243

1252

It may be possible that a countries statistics show a reduction in the coal resource quantity
for a particular year. In this case the method may produce a negative emission in that year.
It would be helpful if the text could mention this as being undesirable outcome. In thatcase, guidance could be provided indicating that the activity data time series may need tobe rescaled consistent with methods discussed in Volume 1 Chapter 5 in order to avoid
negative emission outcomes, while maintaining time series consistency

Australia

Rejected

Additional guidance is unavailable.

852

2

4

1244

Typo “Cahpter5”

ThailandAccepted

Mistake corrected!

Major coal producing countries do present coal resources on an year-to-yearbasis. These may be ascertained from several governmental and nongovernmental reports and links. Therefore, augmentation of coal resources onannual basis can be obtained to a large degree of accuracy. Number of
exploration boreholes drilled annually seems to be a better option. However,this data is not readily available in national statistics. Therefore, we haveconsidered this approach in a Tier 3 method. Tier 1 and Tier 2 methods basedon augmentation of resorces and depth-wise augmentation of resorces
respectively, can be used if data number of boreholes drilled is not available orcannot be collected from coal exploration agencies or corporates.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

854

2

4

1594

Should the atmospheric pressure unit be similar throughout the Guidance? Some volumeuse 1 atm for the standard condition, not “101.325 kPa” and it is easy to read for thereader.

Thailand

Rejected

IPCC GLs are under SI units. kPa unit must be used.

856

2

4

1790

Not specific text/unclear for “In the table below,…

ThailandAccepted

Added table # to sentence.

858

2

4

1843

Not specific text/unclear for “The table below…”

ThailandAccepted

Added table # to sentence.

1804

2

4

2058

2062

Error in Equation 4.2.13, “A• EFunconventional gas with flaring or recovery” should be“Aunconventional gas with flaring or recovery• EFunconventional gas with flaring or
recovery”, please check and correct the formula.

China

Accepted

Corrected variable "A".

5562

2

4

1443

1443

The figure titled “Segments included in Natural Gas Systems (1B 2b)”, fails to clearlyhighlight the ADDITIONAL LNG life-cycle stages (namely, Liquefaction; Storage;
Offloading and Onloading; Shipping and Regasification), which should emphasize thedifference in emissions profiles between traditional piped gas and LNG.

United States of America

Accepted withmodification

5564

2

4

1443

1444

United States of America
In the Transmission and Storage segment, there is an emission source described as"Pipeline Transmission & Boosting". Boosting stations are typically described as being in
the Gathering and Boosting segment of the industry. Consider rephrasing this as"Compressor Stations", "Transmission Compressor Stations" or "Transmission
Compression Stations".

Accepted

5566

2

4

1443

1444

For the green arrow between "Pipeline Transmission & Boosting" and "LNG Regasification and Storage", it could be shown as a double arrow, since some LNG storage
may occur after the gas has been transported through a transmission system, e.g., LNG
peak shaving units

United States of America

Accepted

5568

2

4

1482

1482

I thought the term sweetening/amine units refer to H2S removal? Perhaps more
appropriate to use acid gas removal.

United States of America

Accepted withmodification

5570

2

4

1489

1489

Suggest using "…are often stochastic and challenging to quantify" instead of existing text. United States of America

Rejected

5572

2

4

1497

1497

Suggest using "…difficult to access and dangerous for direct measurement" so supplement United States of America
existing text.

Accepted

5574

2

4

1756

1756

Change "The level of available data also varies." to "Data availability may also change".

Accepted

United States of America

LNG is only mentioned in 1B 2b iv in the text, so we remove any wording about
it under the Processing column. We alter the wording under Transmission andStorage to read “LNG Stations and Export/Import Terminals (Liquefaction, Regasification), Transport & Storage.” We connect this with a green arrow to the
LNG truck and ship to represent transportation. Under the onshore plant next
to the underground storage we now state: “LNG Stations and Export/Importterminals (Liquefaction, Re-gasification), transport, and storage”. The boatnext to it has the listing LNG transport (and obviously represents shipping). In
the caption for the figure we now note: “Note: this diagram provides examplesof activities included in the segments of oil systems; it is not intended as a flow
chart or supply chain diagram.”

We revise to “Transmission compressor stations”.

Acid gas removal and sweetening are synonymous. Sweeting and acid gas aredefined in the glossary. We revise: "Formation CO2 removed from natural gas
by the sweetening units at gas processing plants (i.e. for acid gas removal).”The intent of the comment is covered in the existing text.

Proposed wording is clearer than SOD.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

5576

2

4

1871

1872

Typo - the phrase "gas oil ration" should say "gas to oil ratio"

United States of America

Accepted withmodification

5578

2

4

2032

2032

Possible to reference or include an international reference showing where tightsands/shales occur as a guide to helping countries assess the extent of potential
unconventional production? See e.g.,https://www.eia.gov/analysis/studies/worldshalegas/images/fig1map_large.jpg or
https://www.iea.org/ugforum/ugd/

United States of America

Accepted

5580

2

4

2040

2042

Would well "re-drilling" or "re-fracturing" be addressed the same way, as part of the Tier 1 United States of America
exploration approach?

5582

2

4

2105

2106

Typo - the phrase "gas oil ratio" should say "gas to oil ratio"

United States of America

Rejected

It's commonly called gas oil ratio.

5584

2

4

2170

2172

United States of America
Emissions along the LNG value chain are barely described under the “Natural Gas
Systems” subsection – a cursory attempt to do this is in the form of a simple referral to theAmerican Petroleum Institute’s (API) 2015 report on LNG emissions. This is in stark
contrast with the robust description dedicated to Oil systems, from cradle to grave.

Noted

The guidelines are not a supply chain description, but rather a guide forinventory compilers to understand where to report fugitive emissions associatedwith various activities. In the caption of Figure 4.2.1 we write: “ Note: thisdiagram provides examples of activities included in the segments of oil systems;
it is not intended as a flow chart or supply chain diagram.”

6380

2

4

1349

As a general observation the Guidelines tend to see the upstream oil and gas industry as
either gas production or oil production. It should be recognized that many upstream oil
and gas facilities produce and process both. Also, the current approach and terminology
used appears very USA centric and may not reflect the terminology, nature and structureof the oil and gas industry in other jurisdictions.

Australia

Accepted withmodification

We added text on the distinction between oil and gas wells, above eqn 4.2.9,
eqn 4.2.10, eqn 4.2.13 and eqn 4.2.14: if national criterial is there to define theoil and gas well, please follow the national criteral or national documentation.
what is more important is emission should be allcoated to either oil or gas
system, without omission. We have reviewed the terminology and added
additional detail in the main body and the annex to explatin what each term
mean. The oil and gas industry can vary across coutnries and over time. We
have been clear in the text that this is that case and that a country that thinks theappraoch/EF will not be appropriate for the country's natioanl circumstances
can consider otehr data if available.

6382

2

4

1349

Greater clarity is required in the Guidelines to bring the definitions of various products andactivities in line with the way these are generally applied in the upstream oil and gas
industry. In particular greater differentiation and clarity should be provided around theuse of terms “condensate”, and ‘”natural gas liquids”. These tend to be usedinterchangeably in the Guidelines where as in some parts of the industry condensate
generally refers to products that exist as a gas in the reservoir but condense into a liquid atthe surface. Whereas natural gas liquids is generally used to refer to propane and butane(LPGs).

Australia

Rejected

Low vapor pressure condensate and NGLs are synonymous, and NGLs consistof more substances than just LPGs (see response to comment #6406). We havereviewed the use of the terms NGLs and condensate within the document andthey are used correctly according to definition. The definitions used in chapter
4 are and have been in line with the fuel definitions in chapter 1 that have notbeen subject to refinement. In addition these definitions are in lines with thoseby the International Energy Agency (IEA).We note that industry does notalways consistently adhere to these strict definitions, however. But for the
purposes of the guidelines, we clearly define what is meant (see the glossary, forexample).

6384

2

4

1363

Aggregating emissions from flaring, venting, leaks etc under the umbrella of fugitive
emissions has the potential to cause confusion. Generally, the term fugitive emissions isused in some parts of the upstream oil and gas industry refer to equipment leaks fromprocess components like flanges and valves. Including sources such as flares and vents
under the term fugitives risks causing confusion.

Australia

Rejected

The defition of fugitives for oil and gas systems in the IPCC guidelines has
been in place for years and is out of scope of the 2019 refinement. Throughout
the chapter, the authors have been clear that fugitives include leaks, vents andflaring.

Accepted withmodification

Corrected text to "gas oil ratio".

Reference has been added to the main text.

Edited both oil and gas production to clarify that re-drilling and refracturing are
included in the production segment.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

6386

2

4

1613

There is scope for confusion as what is an exploration activity and what is a production
activity. Generally the upstream oil and gas industry thinks of exploration as those
activities leading up to the discovery of an oil and gas accumulation/field. This is thenfollowed by field appraisal before the field is developed and production operations
undertaken. Noting drilling of new production wells can often occur well into theoperating life of an oil or gas field.

Australia

Accepted withmodification

We have updated our definition of “exploration” to encompass any activities
that may involve fugitive emissions that occur prior to a well’s productive life
(i.e. activities leading up to discovery, field appraisal before development etc.).
In Table 4.2.1 we add for oil exploration: “Includes fugitive emissions
associated with field activities prior to production: prospecting and or
exploratory drilling, field development and both conventional andunconventional well development (construction/drilling, testing, completion,
work overs, any fracture stimulation).”

6388

2

4

1365

We understand in some jurisdictions (USA EPA) define all drilling related activities(exploration drilling, appraisal drilling, development drilling, well completions, well workovers) to be “exploration”. This is not aligned with the industry use of the term
exploration. Simply looking at the IPCC guidelines it is not clear where field appraisaland development drilling activities are to be reported. Do these fall in “exploration”(noting some filed development work may occur will into a field operating life) or‘production” noting the sorts of activities listed under production don’t appear to cover
field development drilling etc. This could be simply clarified by changing the headline of“Exploration” to be “Well Construction”. For example at line 1365 it talks about the oiland gas “system begins at the well head”. This does not appear to acknowledge thevolume of activities and in some cases emissions that occur before the well head is inplace.

Australia

Accepted withmodification

We adopt the definition that the “Exploration” segment of oil and natural gas
systems encompasses all activities that could potentially have fugitive emissions
that occur prior to extraction of hydrocarbons that will be refined anddistributed to end users. Thus, this segment includes: prospecting and/or
exploratory drilling, development work in a field prior to operation, welldevelopment (construction to completion). We retain the word “Exploration”,
however. We revise line 1365: “The system begins during the exploration
process which includes all fugitive emissions associated with activities such asprospecting and/or exploratory drilling, field development and welldevelopment (construction to completion, fracture stimulation), and ends at theconsumer (including fugitive emissions between gas meters and gas appliances,
but not from appliance start-stop losses or appliance combustion).”

6390

2

4

1430

Lines 1430 and 1431 talk about well completions in the context of unconventional
exploration and conventional exploration. The use of the term exploration to describe
field development activities does not reflect the way the term exploration is used acrossindustry.

Australia

Accepted withmodification

We have revised the definition of exploration based on comment #6388 toencompass all activities with fugitive emissions that occur prior to extraction ofhydrocarbons for refining and distribution. We retain the word “exploration”
and revise line 1365: “The system begins during the exploration process, which
includes all fugitive emissions associated with activities such as prospecting
and/or exploratory drilling, well testing, field development and welldevelopment (construction to completion, fracture stimulation), and ends at theconsumer (including fugitive emissions between gas meters and appliances, but
not from appliance start stop losses or appliance combustion)” The guidelines
distinguish between between unconventional and conventional completions(Line 1421) because they have a different emissions profiles for the exploration
segment; thus, we are not considering the product in this differentiation, butrather the fugitive emissions profile. Therefore, we are already differentiatingby emissions source type. In line 1430 we specifically state that: “In thischapter, unconventional exploration refers to exploration that includes wellcompletions with hydraulic fracturing and conventional exploration refers to
exploration that does not include well completions with hydraulic fracturing”.

1431

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

6392

2

4

1365

At present there is no category for reporting emissions related to crude oil processing as
there is for natural gas processing. Generally there is some “processing” of crude oil close
to where it is produced. This may take the form of separating out water and gases, may
involve storage and could extend to crude oil stabilization activities. Note these are
distinctly different from “crude oil upgrading” which is a more involved process andinvolves changing the chemical make-up of the crude. Including the activity of “crude oilprocessing” would remove this confusion. Alternatively “crude oil production” could beclearly defined as “crude oil production and processing” It appears odd that we have asections for natural gas processing but not crude oil processing.

Australia

Accepted withmodification

Any on-site processing of crude oil should be included in crude oil production
and upgrading.
We added a sentence in the first sentence on p. 4.56, including on-site curde oilprocessing, i.e. removing water and gases contained in crude oil.

6394

2

4

1427

The proposed guidelines differentiate (1427) emissions based on if the reservoir that is thesource of the production from a “conventional” or ‘unconventional” resource. The
differentiator should be bases on the nature of the well completion not on the type ofresource being developed.as this can cause confusion for where you have a conventional
reservoir but hydraulic stimulation is still required. Emissions reporting should be basedon the nature of the emissions source, not on the type of reservoir the produced oil and gas
is sourced from. For example if a well is hydraulically stimulated “fracked” emissions forthis operation should be reported irrespective of if the reservoir is conventional or
unconventional. There are plenty of conventional reservoirs that are hydraulicallystimulated. Similarly there should be no differential of the product once it has been
produced. Crude oil is crude oil irrespective of it coming from a conventional reservoir or
unconventional reservoir, unprocessed natural gas is unprocessed natural gas irrespectiveof it being sourced from a conventional reservoirs or a coal seam reservoir or tight gas
reservoir.

Australia

Rejected

The guidelines distinguish between unconventional and conventional
completions (Line 1421) because they have different emissions profiles for the
exploration segment; thus, we are not considering the product in thisdifferentiation, but rather the fugitive emissions profile of the activity.
Therefore, we are already differentiating by emissions source type/activity. Inline 1430 we specifically state that: “In this chapter, unconventional
exploration refers to exploration that includes well completions with hydraulicfracturing and conventional exploration refers to exploration that does notinclude well completions with hydraulic fracturing”.

6396

2

4

1434

As discussed above the category of “exploration” we think is intended to cover much morethan what is understood to be exploration activities in the upstream oil and gas sector. . If
this category was renamed to something such as Well Construction, this it would be clearthat emissions related to any drilling , completion, work over, fracture stimulation or
related activity would be reported here.

Australia

Accepted withmodification

We adopt the definition that the “Exploration” segment of oil and natural gas
systems encompasses all activities that could potentially have emissions that
occur prior to extraction of hydrocarbons that will be refined and distributed to
end users. Thus, this segment includes: prospecting and/or exploratory drilling,development work in a field prior to operation, well development (construction
to completion). We retain the word “Exploration”, however.
We revise line
1365:
“The system begins during the exploration process, which includes all fugitive
emissions associated with activities such as prospecting and/or exploratory
drilling, well testing, field development and well development (construction tocompletion, fracture stimulation), and ends at the consumer (including fugitive
emissions between gas meters and appliances, but not from appliance start stop
losses or appliance combustion)”

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

6398

2

4

1434

Figure 4.2.1 (Oil Systems) As discussed above the category of “exploration” we think isintended to cover much more than what is understood to be exploration activities in the
upstream oil and gas sector. . If this category was renamed to something such as Well
Construction, this it would be clear that emissions related to any drilling , completion,
work over, fracture stimulation or related activity would be reported here.

Australia

Accepted withmodification

We adopt the definition that the “Exploration” segment of oil and natural gas
systems encompasses all activities that could potentially have emissions that
occur prior to extraction of hydrocarbons that will be refined and distributed to
end users. Thus, this segment includes: prospecting and/or exploratory drilling,development work in a field prior to operation, well development (construction
to completion). We retain the word “Exploration”, however.
We revise line
1365:
“The system begins during the exploration process, which includes all fugitive
emissions associated with activities such as prospecting and/or exploratory
drilling, well testing, field development and well development (construction tocompletion, fracture stimulation), and ends at the consumer (including fugitive
emissions between gas meters and appliances, but not from appliance start stop
losses or appliance combustion)”

6400

2

4

1832

In the section under “Production” the use of term “upgrading” may cause confusion.
Upgrading would normally apply to modifying heavy oil such that it can be marketed.
This should not be confused with crude oil processing such as the removal of water. As
discussed above this could be made less confusing if ‘crude oil processing’ was included
or “crude oil production” clearly defined so as to include the processing that occurs near
the site where the oil is produced.

Australia

Accepted withmodification

See comment No. 6392.

6402

2

4

1927

Under the section on Refining, NGLs are identified but not condensate. As discussed
above some part of the industry generally uses NGLs to talk about propane and butane(LPGs). It would be beneficial if greater clarity was provided around the differentiation
between condensate crude oil,. NGLs, etc. noting condensate has more in common with
crude oil than it does with LPGs.

Australia

Rejected

Both NGLs and condensate have been defined in the glossary. NGLs include
LPGs (propane and butane), but also contain other hydrocarbons. Low-vapour
pressure condensate and NGLs are equivalent.The use of NGLs and condensate
in the text are consistent with the definitions.

6404

2

4

1434

Figure 4.2.1 (Gas Systems) The comment as to the lack of clarity provided by describing
the first column as exploration is repeated here. What looks like is intended is drilling,
completions, work overs etc so this column should be described as such . Not exploration
which is a different set of activities.

Australia

Accepted withmodification

We add: Field activities prior to production that have fugitive emissions. e.g.
Prospecting & exploratory well drilling, testing, completion, work overs, etc.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

6406

2

4

1434

Under the column on Production, this would also likely involve condensate separation but
there is no mention of this. As indicated above it would be helpful if terms could be used
to reduce the risk of confusing condensate and NGLs.

Australia

Accepted withmodification

We add “condensate removalse” to this column. We note, however, that low
vapor pressure condensate and NGL are synonymous by definition. The
Schlumberger Oil and Gas Glossary defines condensate as “A low density highAPI gravity liquid hydrocarbon phase that generally occurs in association withnatural gas. Its presence as a liquid phase depends on temperature and pressure
conditions in the reservoir allowing condensation of liquid from vapor. The
production of condensate reservoirs can be complicated because of the pressure
sensitivity of some condensates. During production, there is risk of thecondensate changing from gas to liquid if the reservoir pressure drops below thedew point during production. Reservoir pressure can be maintained by fluid
injection if gas production is preferable to liquid production. Gas produced inassociation with condensate is called wet gas. The API gravity of condensate is
typically 50 - 120 degrees.” Further, condensate liquids are “Hydrocarbons thatare in the gaseous phase at reservoir conditions but condense into liquid as they
travel up the wellborn and reach separator conditions. Condensate liquids are
sometimes called distillate.” Natural gas liquids are defined as: “Components
of natural gas that are liquid at the surface in field facilities or in gas-processing
plants. Natural gas liquids can be classified according to their vapor pressures
as low (condensate), intermediate (natural gasoline) and high (liquefied
petroleum gas) vapor pressure. Natural gas liquids include propane, butane,
pentane, hexane, and heptane, but not methane and ethane, since thesehydrocarbons need refrigeration to be liquefied. The term is commonly
appreciated as NGL.”

6408

2

4

1434

Under the section of Processing it lists Offshore Gas Liquification (LNG). LNG isdominantly processed “onshore” with the technology to process gas into LNG offshore atthe very early stages of development. LNG processing is just another type of gas
processing and can occur onshore or offshore. What is important is not the location of theprocessing but the type of processing involved and the associated emissions. LNG
processing for trade on international markets should be differentiated from LNG
processing/storage that is used for managing peak gas demand in distribution networks
and as a supply for LNG for use in road transport, remote power generation etc. While thephysics is the same the plants vary quite differently in scale.

Australia

Accepted withmodification

LNG is only mentioned in 1B 2b iv in the text, so we remove any wording about
it under the Processing column. We alter the wording under Transmission andStorage to read “LNG Stations and Export/Import Terminals (Liquefaction, Regasification), Transport & Storage.” We do not differentiate between
international trade LNG versus LNG used for other usages as the fugitive
emissions associated with processing of all LNG regardless of final use belongs
within 1 B 2 b iv.

6410

2

4

1482

Line 1482 the term ‘gas sweetening’ is used heat but in other parts of the documents theterm ‘acid gas removal’ is used. It would be good if consistent terminology is usedthroughout. Suggest if terms such as ‘sweetening’ are used they should be definedsomewhere.

Australia

Accepted withmodification

Acid gas removal and sweetening are synonymous. Sweeting and acid gas aredefined in the glossary. We revise: "Formation CO2 removed from natural gas
by the sweetening units at gas processing plants (i.e. for acid gas removal).”

6412

2

4

1593

Line 1593 talks about how throughput emissions factors are applicable to throughput atstandard conditions. Please note that some commodities such as Liquefied Natural gas
cannot exist at Standard Conditions so some flexibility is required for some factors.

Australia

Rejected

LNG EFs are expressed in tonnes of emissions per facility (station). They are
not related to temperature and pressure.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

Table 4.2.1 This lists Liquefied Natural Gas Systems under Gas Transmission. While thismay be appropriate for LNG peaking plants and terminals providing LNG for road, ship
and other uses, it’s not appropriate for the internationally traded LNG sector which tends
to have much larger plants which are more aligned with the section on Gas Processing.

Australia

Rejected

1) No evidence to show the international -traded LNG sector are more alignedwith the section on Gas Processing;2) A conservative EFs (1660 tCH4/station) has provided in the text to reflect
the possible high emisison intentsity from LNG import/export station

6414

2

4

1613

6678

2

4

1542

1544

The text in lines 1542 to 1544 (p. 4.44) is the repetition of the text in lines 1772 to 1774
(p. 4.56). This repetition seems unnecessary. To avoid the repetition, it is proposed thatthe authors move text in lines 1542 to 1544 from page 4.44 to page 4.56 to replace thetext in lines 1772 to 1774 (p. 4.56) with it.

Russian Federation

Rejected

We received a lot of comments on FOD that this information was not clear
enough so having it in more than one place is helpful to users.

6680

2

4

1546

1547

Figure 4.2.2: The decision tree seems to undermine general concept of inventory
preparation and its further improvement, which builds upon key category analysis. In the2006 Guidelines and in the 2019 Refinement, the question if the category concerned is key
stands on top, i.e. in the beginning of each decision tree, and guides further actions ofinventory compilers. However, in the present structure of the decision tree, this question isput in the bottom, which seems inconsistent with general guidance in Volume 1 of the2006 Guidelines and the 2019 Refinement. To maintain concictency in decision treepresentation, it is proposed that the authors reconcile the oder of questions in the decision
tree to move the key category identification on top of it.

Russian Federation

Rejected

The question on key category is at the end in practically almost all decision
trees in the energy volume. Therefore this decision tree is in line with almost all
decision trees in volume 2.

6682

2

4

1551

1552

Figure 4.2.3: The decision tree seems to undermine general concept of inventory
preparation and its further improvement, which builds upon key category analysis. In the2006 Guidelines and in the 2019 Refinement, the question if the category concerned is key
stands on top, i.e. in the beginning of each decision tree, and guides further actions of theinventory compilers. However, in the present structure of the decision tree, this question isput in the bottom, which seems inconsistent with general guidance in Volume 1 of the2006 Guidelines and the 2019 Refinement. To maintain concictency in decision treepresentation, it is proposed that the authors reconcile the oder of questions in the decision
tree to move the key category identification on top of it.

Russian Federation

Rejected

The question on key category is at the end in practically almost all decision
trees in the energy volume. Therefore this decision tree is in line with almost all
decision trees in volume 2.

6684

2

4

1557

1558

Figure 4.2.4: The decision tree seems to undermine general concept of inventory
preparation and its further improvement, which builds upon key category analysis. In the2006 Guidelines and in the 2019 Refinement, the question if the category concerned is key
stands on top, i.e. in the beginning of each decision tree, and guides further actions of theinventory compilers. However, in the present structure of the decision tree, this question isput in the bottom, which seems inconsistent with general guidance in Volume 1 of the2006 Guidelines and the 2019 Refinement. To maintain concictency in decision treepresentation, it is proposed that the authors reconcile the oder of questions in the decision
tree to move the key category identification on top of it.

Russian Federation

Rejected

The question on key category is at the end in practically almost all decision
trees in the energy volume. Therefore this decision tree is in line with almost all
decision trees in volume 2.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note
The question on key category is at the end in practically almost all decision
trees in the energy volume. Therefore this decision tree is in line with almost all
decision trees in volume 2.

6686

2

4

1563

1564

Figure 4.2.5: The decision tree seems to undermine general concept of inventory
preparation and its further improvement, which builds upon key category analysis. In the2006 Guidelines and in the 2019 Refinement, the question if the category concerned is key
stands on top, i.e. in the beginning of each decision tree, and guides further actions of theinventory compilers. However, in the present structure of the decision tree, this question isput in the bottom, which seems inconsistent with general guidance in Volume 1 of the2006 Guidelines and the 2019 Refinement. To maintain concictency in decision treepresentation, it is proposed that the authors reconcile the oder of questions in the decision
tree to move the key category identification on top of it.

Russian Federation

Rejected

6688

2

4

1590

1591

The sentence in lines is a repetition of the text in lines 1597 to 1598. It is proposed toremove it to avoid duplication.

Russian Federation

Accepted withmodification

Edited to delete the second occurance in response to another comment.

6690

2

4

1613

1614

Table 4.2.1 provides the description of operations in oil and gas industry. It seems more
approprite for section on the choice of method (Section 4.2.2.1). It is proposed to movetable 4.2.1 to section 4.2.2.1. It is further proposed to include in table sub-titles"Operations with natural gas" and "Operations with oil", to improve the clarity of the table.

Russian Federation

Accepted withmodification

1) The table was moved to Section 4.2.2.2 Choice of method from 4.2.2.1
Choice of method, Decision trees, Tiers.
2) The existing column clearly indicates the operations related to gas and oil
system, so new column is not necessary.

6692

2

4

1766

1769

The text in lines 1766 to 1769 (p. 4.55-4.56) is the repetition of the text in lines 1597 to1600 (p. 4.49). This repetition seems unnecessary. To avoid the repetition, it is proposedthat the authors remove the text in lines 1597 to 1600 from page 4.49, but retain the text inlines 1766 to 1769 (p. 4.55-4.56).

Russian Federation

Accepted

6694

2

4

1823

1828

It is more appropriate to keep all equations in the section on methodological choice(Section 4.2.2.2). It is proposed that the authors to move the Equation 4.2.9 and related
text to the methodological choice section (Section 4.2.2.3). It is further proposed that theauthors include the reference to equation 4.2.9 in the text of the 2019 Refinement.

Russian Federation

Accepted withmodification

6696

2

4

1829

1830

Table 4.2.3: To improve the clarity for the emission factors provided, it is proposed thatthe authors include an additional column entitled "Operation" after the column "Subsegment", where they specify the type of activity (operation) for which the emission factor
has been provided.

Russian Federation

Rejected

The footnote already says what activities are included.

6698

2

4

1829

1830

Table 4.2.3: It is proposed that the authors cross-check the units in the last column of thetable. Looks like the units for Oil exploration are incorrect otherwise some parameter ismissing there.

Russian Federation

Accepted

Correction made.

6700

2

4

1902

1908

It is more appropriate to keep all equations in the section on methodological choice(Section 4.2.2.2). It is proposed that the authors to move the Equation 4.2.10 and related
text to the methodological choice section (Section 4.2.2.3). It is further proposed that theauthors include the reference to equation 4.2.10 in the text of the 2019 Refinement.

Russian Federation

Accepted withmodification

1 - Section 4.2.2.2 contains recommendations on method (Tier) choice andcommon equations for Tier 1, which can be applied to any category. Section
4.2.2.3 is devoted to EFs choice. Equations of section 4.2.2.3 are aimed toclarify application of the EFs. Reallocation of the equation is not reasonable.
2 - The reference to relevant equation has been included in the text.

1 - Section 4.2.2.2 contains recommendations on method (Tier) choice andcommon equations for Tier 1, which can be applied to any category. Section
4.2.2.3 is devoted to EFs choice. Equations of section 4.2.2.3 are aimed toclarify application of the EFs. Reallocation of the equation is not reasonable.
2 - The reference to relevant equation has been included in the text.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

6702

2

4

1909

1910

Table 4.2.4: It is proposed to remove column entitled "Emission source" from table 4.2.4,
as it seems not necessary in the table so far as the level of aggregation of the emission
categories has been described in the text of the 2019 Refinement.

Russian Federation

Rejected

Keeping the column is to keep consistency with IPCC 2006 GLs.

6704

2

4

1920

1924

Equation 4.2.11 seems incomplete. It is proposed that the authors cross-check the equation
and revise it.

Russian Federation

Accepted

Changed

6706

2

4

1920

1924

It is more appropriate to keep all equations in the section on methodological choice(Section 4.2.2.2). It is proposed that the authors to move the Equation 4.2.11 and related
text to the methodological choice section (Section 4.2.2.3). It is further proposed that theauthors include the reference to equation 4.2.11 in the text of the 2019 Refinement.

Russian Federation

Accepted withmodification

1 - Section 4.2.2.2 contains recommendations on method (Tier) choice andcommon equations for Tier 1, which can be applied to any category. Section
4.2.2.3 is devoted to EFs choice. Equations of section 4.2.2.3 are aimed toclarify application of the EFs. Reallocation of the equation is not reasonable.
2 - The reference to relevant equation has been included in the text.

6708

2

4

1960

1964

It is more appropriate to keep all equations in the section on methodological choice(Section 4.2.2.2). It is proposed that the authors to move the Equation 4.2.12 and related
text to the methodological choice section (Section 4.2.2.3). It is further proposed that theauthors include the reference to equation 4.2.12 in the text of the 2019 Refinement.

Russian Federation

Accepted withmodification

1 - Section 4.2.2.2 contains recommendations on method (Tier) choice andcommon equations for Tier 1, which can be applied to any category. Section
4.2.2.3 is devoted to EFs choice. Equations of section 4.2.2.3 are aimed toclarify application of the EFs. Reallocation of the equation is not reasonable.
2 - Legend to the equation has been included in the text.

6710

2

4

2058

2062

It is more appropriate to keep all equations in the section on methodological choice(Section 4.2.2.2). It is proposed that the authors to move the Equation 4.2.13 and related
text to the methodological choice section (Section 4.2.2.3). It is further proposed that theauthors reconcile the equation 4.2.13 to include the legend. Furthermore, it is proposed toinclude the emissions from natural gas flaring in the Equation 4.2.13, if appropriate.

Russian Federation

Accepted withmodification

1 - Section 4.2.2.2 contains recommendations on method (Tier) choice andcommon equations for Tier 1, which can be applied to any category. Section
4.2.2.3 is devoted to EFs choice. Equations of section 4.2.2.3 are aimed toclarify application of the EFs. Reallocation of the equation is not reasonable.
2 - Legend to the equation has been included in the text.
3 - It it assumed that flaring is already covered by EFs.

6712

2

4

2063

2063

Table 4.2.9: It is not clear from the Table 4.2.9 and supporting text, what operations(emission categories) are included in the emission factor for conventional gas exploration.
In particular, it is not clear, if the natural gas flaring is included in this broad category(note that in the 2006 Guidelines a separte EF factors was provided for natural gas
flaring). It is proposed that the authors clarify, if natural gas flaring is included in theemission factors in Table 4.2.9.

Russian Federation

Rejected

Its noted multiple times in the text that flaring is included.

6714

2

4

2063

2063

Table 4.2.9: It is proposed that the authors cross-check the units for emission factors in thelast column of Table 4.2.9. In particular, it seems like the indication of the number of wells
was not included in the description of units in the last column of the table 4.2.9.

Russian Federation

Accepted

Changed labels to clarfy that it’s new gas wells drilled in a year.

6716

2

4

2110

2115

It is more appropriate to keep all equations in the section on methodological choice(Section 4.2.2.2). It is proposed that the authors move Equation 4.2.14 and related text tothe methodological choice section (Section 4.2.2.3). It is further proposed that the authors
reconcile the equation 4.2.14 to include the legend.

Russian Federation

Accepted withmodification

1 - Section 4.2.2.2 contains recommendations on method (Tier) choice andcommon equations for Tier 1, which can be applied to any category. Section
4.2.2.3 is devoted to EFs choice. Equations of section 4.2.2.3 are aimed toclarify application of the EFs. Reallocation of the equation is not reasonable.
2 - Legend to the equation has been included in the text.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

6718

2

4

2153

2157

It is more appropriate to keep all equations in the section on methodological choice(Section 4.2.2.2). It is proposed that the authors move Equation 4.2.15 and related text tothe methodological choice section (Section 4.2.2.3). It is further proposed that the authors
reconcile the equation 4.2.15 to include the legend.

Russian Federation

Accepted withmodification

1 - Section 4.2.2.2 contains recommendations on method (Tier) choice andcommon equations for Tier 1, which can be applied to any category. Section
4.2.2.3 is devoted to EFs choice. Equations of section 4.2.2.3 are aimed toclarify application of the EFs. Reallocation of the equation is not reasonable.
2 - Legend to the equation has been included in the text.

6720

2

4

2197

2203

It is more appropriate to keep all equations in the section on methodological choice(Section 4.2.2.2). It is proposed that the authors move Equation 4.2.16 and related text tothe methodological choice section (Section 4.2.2.3). It is further proposed that the authors
reconcile the equation 4.2.16 to include the legend. It is further proposed that the authors
explain the rationale for addition of natural gas export and import activities.

Russian Federation

Accepted withmodification

1 - Section 4.2.2.2 contains recommendations on method (Tier) choice andcommon equations for Tier 1, which can be applied to any category. Section
4.2.2.3 is devoted to EFs choice. Equations of section 4.2.2.3 are aimed toclarify application of the EFs. Reallocation of the equation is not reasonable.
2 - Legend to the equation has been included in the text.
3 - The equation account for emissions from LNG export/import stations, notemissoins from natural gas export/impotr itself.

6722

2

4

2205

2205

Table 4.2.12: It is proposed that th authors cross-check the units for emission factors in thelast column of Table 4.2.12 and make them consistent with the units provided in othertables, namely Tables 4.2.9 to 4.2.11. Furthermore, as follows from Tables 4.2.9 to 4.2.12,
the default emission factors for on-shore exploration and production of natural gas weredeveloped based on the data from one geographical region which is North America.
However, the parameters for other geographical regions were not provided. Such approachis inconsistent with the concept of complete geographical coverage introduced in the 2006
Guidelines and previous IPCC inventory guidelines. To enhance geographical coverage ofthe 2019 Refinement, it is proposed that the authors include in the Annex 4A.2 default
emission factors for gas operations that are disaggregated by major geographic regions,where such operations occur. The default emission factors for natural gas operations in
Eastern Eurpore and Western Asia are provided in the attached file. It is proposed toinclude them in the Annex 4A.2

Russian Federation

Accepted withmodification

1) Add a sentence on line 1561-1564, "While the emission factor options aremeant to cover technologies and practices that are common in the oil and gas
industries, technologies and practices can vary significantly. In addition, theaccuracy of factors is dependent on the uncertainty of underlying data. A
country should periodically assess changes in technologies and practices, andchanges in available emissions data, and consider updating estimates using atleast a Tier 2 approach, per good practice."2) The data provided by the commenter will not be included in the text orannex, based on following reasons: ① : the EFs provided from the commentor
comes, basically, from a case study performed in 1998 in Western Siberia(Dedikov et.al, 1999) when on-site measurements were carried out to test theCH4 fugitive/venting rate in natural gas production and transmission systems. A
new study (Uvarova et.al, 2017) performed in 2016 figured out the chemicalcomposition of natural gas in the Russian Federation, including its CO2 content,
by using fugitive/venting/flaring rates measured in 1998 (Dedikov et.al, 1999)
and CO2 EFs were developed.② a peer reviewed study in 2010 concluded theemission factors identified by (Dedikov et.al, 1999) is not applicable to reflect
the real situation nowdays in this region.
(S. Lechtenböhmer & C. Dienst (2010) Future development of the upstream
greenhouse gas emissions from natural gas industry, focussing on Russian gas
fields and export pipelines, Journal of Integrative Environmental Sciences,
7:S1, 39-48, DOI:10.1080/19438151003774463)

6724

2

4

2239

2247

It is more appropriate to keep all equations in the section on methodological choice(Section 4.2.2.2). It is proposed that the authors to move the Equation 4.2.17 and related
text to the methodological choice section (Section 4.2.2.3). It is further proposed that theauthors reconcile the equation 4.2.17 to include the legend.

Russian Federation

Accepted withmodification

1 - Section 4.2.2.2 contains recommendations on method (Tier) choice andcommon equations for Tier 1, which can be applied to any category. Section
4.2.2.3 is devoted to EFs choice. Equations of section 4.2.2.3 are aimed toclarify application of the EFs. Reallocation of the equation is not reasonable.
2 - Legend to the equation has been included in the text.

6726

2

4

2249

2249

Table 4.2.13: It is proposed that the authors cross-check the units for emission factors in
the last column of Table 4.2.13 and make them consistent with the units provided in othertables, namely Tables 4.2.9 to 4.2.11.

Russian Federation

Accepted

Fixed formatting

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

6728

2

4

2232

2233

Table 4.2.14: It is proposed that the authors change the order of presentation of the tiers in
Table 4.2.14 to start with tier 1. It is further proposed that the authors elaborate on thedescription of primary sources for tier 1.

Russian Federation

Accepted withmodification

1 - Changed the order of table 4.2.14. 2 - Detailed description of primerysources for tier 1 is provided in section 4.2.2.3.

6730

2

4

2340

2340

Table 4.2.15: The heading of the Table 4.2.15 does not correspond to its content. The
adequate heading is: "Activity Data Values Required for Use in the Tier 1 Approach to
Estimate Fugitive Emissions from Oil and Gas Systems". It is proposed that the authorschange the heading.

Russian Federation

Accepted

Edited sentence to delete "Guidance on obtaining the"

6756

2

4

3065

3103

To enhance user friendliness and aplicability of the 2019 Refinement, it is proposed thatthe authors provide default temperature conversion factors similar with those provided forgas in table 4A.1.1. The temperature conversion factors should be provided on volume tovolume and mass to mass basis for the major types of oils referred to in the 2006
Guidelines.

Russian Federation

Rejected

The conversion factors for oil can not be provided similar with those provided
for gas. The conversion of oil may be performed on oil density basis. Oil
density may vary in broad scale. There are around 30 pages of values ofpossible oil densities. Including these pages in the GLs is not reasonable. The
references on documents, from which the densities may be taken, are provided.

6758

2

4

3125

3128

It is proposed that the authors elaborate on the description of data in tables 4A.2.1 to4A.2.5 to explain on how these were derived and justify their values.

Russian Federation

Accepted

Added text

6760

2

4

3129

3137

Box 4A.2.1: Following the tittle of the Box 4A.2.1, it provides an example of applicationof the parameters in tables 4A.2.1 and 4A.2.2. With this, it should follow the tables
referred to above. It is proposed that the authors move Box 4A.2.1 after the Tables 4A.2.1
to 4A.2.2.

Russian Federation

Accepted

Moved Box 4A2.1 after the tables 4A2.1 to 4A2.7

6762

2

4

3142

3143

There is no disaggregation for tier 1 emission factors for gas exploration and gas
production, which are important segments of oil and gas industry and are significant
source categories for some countries. It is proposed that the authors develop the tables ondesaggregation of tier 1 emission factors for gas exploration and gas production andinclude them before the Table 4A.2.4.

Russian Federation

Accepted

FOD/SOD developed disaggregated EF for segments with disaggregated EF in2006 GL. Edited the annex to add other segments

6764

2

4

3149

3150

As follows from Tables 4.2.9 and 4.2.10, the default emission factors for on-shore
exploration and production of natural gas were developed based on the data from one
geographical region which is North America. However, the parameters for othergeographical regions were not provided. Such approach is inconsistent with the concept ofcomplete geographical coverage introduced in the 2006 Guidelines and previous IPCC
inventory guidelines. To enhance geographical coverage of the 2019 Refinement, it is
proposed that the authors include in the Annex 4A.2 default emission factors for gas
operations that are disaggregated by major geographic regions, where such operations
occur. The default emission factors for natural gas operations in Eastern Eurpore andWestern Asia are provided in the attached file. It is proposed to include them in the Annex
4A.2.

Russian Federation

Accepted withmodification

6880

2

4

1830

1830

The title and contents of the Table 4.2.3 are separated into 3 pages so it is difficult tointerpret the table.

Republic of Korea

Accepted

6882

2

4

1909

1909

The title and contents of the Table 4.2.4 are separated into 3 pages so it is difficult tointerpret the table.

Republic of Korea

Accepted

6884

2

4

1926

1926

The title and contents of the Table 4.2.5 are separated into 2 pages so it is difficult tointerpret the table.

Republic of Korea

Accepted

See comment No. 692

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note
The footnote in table 4.2.4c explains what processes are included in the EF H2-production is not included in the EF.

6886

2

4

1937

1945

In the Box4.2.1, it should make clear whether the emission from producing hydrogen as aintermediate product for oil refineries are already accounted for methodology of fugitive
emissions from oil refinering

Republic of Korea

Rejected

6888

2

4

2063

2063

The title and contents of the Table 4.2.9 are separated into 3 pages so it is difficult tointerpret the table.

Republic of Korea

Accepted

6890

2

4

2117

2117

The title and contents of the Table 4.2.10 are separated into 3 pages so it is difficult tointerpret the table.

Republic of Korea

Accepted

6892

2

4

2159

2159

The title and contents of the Table 4.2.11 are separated into 2 pages so it is difficult tointerpret the table.

Republic of Korea

Accepted

6894

2

4

2205

2205

The title and contents of the Table 4.2.12 are separated into 3 pages so it is difficult tointerpret the table.

Republic of Korea

Accepted

6896

2

4

2249

2249

The title and contents of the Table 4.2.13 are separated into 3 pages so it is difficult tointerpret the table.

Republic of Korea

Accepted

6898

2

4

2584

2584

The title and contents of the Table 4.2.16 are separated into 3 pages so it is difficult tointerpret the table.

Republic of Korea

Accepted

7128

2

4

2146

2147

"Town gas originates from outgassing of hard coal under air exclusion in retort furnace or
chamber kilns. Emissions from these processes are considered in Volume 3 Chapter 3.11
Hydrogen Production." But no estimation method is provided in Vol. 3, Ch. 3.11, since
town gas is not pure H2 formed by complete oxidation of the feedstock. Suggest torephrase or remove the reference to Vol. 3, Ch. 3.11.

NorwayAccepted

The reference has been changed to the transformation chapter. However, no
explicit methodology can be found there. Although it is possible to use theoutputs of CtL to Hydrogen Production, the process analysed in the 2019
Refinement 2006 Guidelines was restricted to the Syngas production.

7134

2

4

1926

1926

Table 4.2.5: Emission factors for offshore oil loading are given with reference to theNorwegian GHG Inventory. The periods chosen for the estimated factors are not uniformwith respect to VRU use, and we do not recommend this use of the inventory. Please doalso check the conversion from the original inventory data. Norway has available EFs anduncertainties both for CH4 and NMVOC.

NorwayAccepted

We have rechecked the values and they are correct. We included additional
information on rationale for selection of the time periods chosen.

7136

2

4

1564

1564

Figure 4.2.5: There seems to be a mistake in the text in the third choice box. The text is "Ifemissions from abandoned wells are a key category, are contributions from abandoned
wells significant". It is suggested that the text should like be "If emissions from oil and gas
operations are a key category, are contributions from abandoned wells significant"NorwayAccepted withmodification

Decision tree is deleted. It is assumed that decision trees on main categories (oiland gas industries) cover subcategory on abandoned wells.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note
The authors note the comments. The first element regarding the fugitive
emissions from storage and loading of feedstock materials and products related
to petrochemical production is out of scope of the Refinement. This was notwithin the terms of reference of the Refinement process. The authors agree that
there is a reporting gap for fugitive emissions from loading and storage ofmaterials in the petrochemical sector, whereas under Energy-refineries there aremethods and Efs presented. The 2006 GLs present specific information on thescope of methane EFs for methanol production only, stating that the default EFs
include fugitive emissions from the storage of crude product. For otherpetrochemical products, the description of scope of default methane EFs is notdefinitive, and therefore it is unclear whether those methane EFs alreadyconsider fugitive emissions from feedstock and product storage and transfer.
We acknowledge therefore that the reporting of fugitive methane could befurther improved, but the team of authors was not mandated to refine thepetrochemical chapter.
Regarding the asphalt blowing, we reject the comment. The IPPU section 5.4.1
is explicit that asphalt production in refineries is excluded from the scope ofreporting in IPPU, whilst the new Energy - fugitives section 4.2.2.3 for 1B2aiv
also explicitly states that emissions from asphalt blowing in refineries areincluded there. The authors consider that this is clear, unambiguous guidance on
best practice for reporting of emissions from asphalt production.”

7400

2

0

0

0

It is well explained that combustion related emissions should be reported under 1.A.1.b,leakage under 1.B.2.iv-v and all process related emissions under 2.B. However, there is
still a high chance of misinterpretation regarding the allocation of emissions fromrefineries with integrated chemical industries and some processes need to be explained
more in detail. In the 2006 Guidelines and also in the refined guidelines, the allocation of
stored refinery products is not straight forward. In chapter 4 Volume 2 line 1951, it isstated that only fuels should be reported under 1.B.2.a.v, and in Volume 3 e.g. under
3.9.2.2 (page 3.74 in 2006 Guidelines) storage of feedstock is part of methanol
production. Other production processes provide neither emission factors nor methods forfeedstocks. Countries with both refineries and chemical industries will need to apply acomplex reporting system with this differentiation, while others with chemical industry
only would underestimate their emissions. If countries produce products dedicated forexport (e.g. naphtha or LPG), emissions cannot be reported with the refined guidelines.
A second incomprehensible aspect is asphalt blowing. This aspect used to be part ofchapter 3 (page 5.14) – now it is included under 1.B.2.a.iv (Volume 2, chapter 4, line
1931). It should be clear where to report emissions from asphalt blowing in order to avoid
double counting.
For both aspects, we recommend providing a graphical presentation, where to report such
emissions.

Germany

Accepted withmodification

7602

2

4

3089

3091

Why is Equation 4A.1.4 here? It seems not to convert anything from one temperature toanother.

FinlandAccepted

8328

GeneralThe emission factors for fugitive emissions in oil and gass section are considered to bevery small, and this results in the output of this sector unrealistic.

Iran

Rejected

The emisison factors were developed following review of available relevant
data. As no data were provided in the comment, no action can be taken in
response to the comment.

8330

GeneralThe software instruction does not provide a definition of the components and fuels, while
the definitions and classification of fuels vary from country to country. This issue faces
uncertainty about data collection (especially in oil and gas extraction and production
sectors).

Iran

Rejected

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

8332

GeneralSome emission factors for N2o, CH4, CO2 are not considered in the Fugitive oil and gas
release section, and there are no national emission factors.

Iran

Rejected

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

8334

GeneralThe units are intended for the oil sector in software based on cubic meters.

Iran

Noted

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

8336

GeneralDistribution coefficients in software 2006 are based on cubic meters, so if the software in
1996 was based on PJ, then the comparison of the coefficients would be difficult.

Iran

Noted

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

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

9198

2

4

1909

1910

Suggested clarifications/corrections:-“Onshore: Most activities occurring with higher-emitting technologies and practices” and“Onshore: Most activities occurring with lower-emitting technologies and practices” N2O
uncertainties should be -10% to +1000%.
-“Onshore: Oil Sands Mining and Ore Processing” uncertainties should be rounded towhole numbers as follows: CH4 ± 30%; CO2 ±25%; NMVOC -30 to +95%.
“Onshore: Oil Sands Upgrading uncertainties” should be rounded to whole numbers as
follows: CH4: -35% to +120%; CO2 ± 15%; NMVOC -60% to +75%; and N2O -25% to+315%.
-Footnote c; last sentence should read: “Includes fugitive emissions from tailings ponds
and the exposed oil sands mine surface.”

CanadaAccepted

Changes made.

9200

2

4

1967

1978

This section needs to include surface casing vent flow and gas migration as possible Other
sources.

CanadaRejected

This should occur in the segment in which the activity takes place as it is not an“accident” or rare event (which is required for the “other” segment).

9202

2

4

2006

2007

Section states that “most methane (around 80%) from offshore abandoned wells is
dissolved in marine water”. However, Table 4.2.8 footnote b says that the offshore
emission factors were developed by multiplying the onshore EFs by 0.02, which would
imply that 98% of methane is dissolved in marine water. Either the footnote is incorrect
and as such, the EFs need to be recalculated or the text needs to be revised.

CanadaAccepted

Discrepancy resolved.

9204

2

4

2116

2117

Footnote c. “Financial year” is not a common term used in the guidelines. Should either
define what financial year means in this context or revise the language.

CanadaAccepted

Footnote c was revised.

9206

2

4

2144

2145

Section states: “If none of the proposals works, a value of 32% sour gas can be applied”.
As stated in the footnote, the 32% value is taken as the average of the Germany (40%) andAustria (25%) sour gas shares and is very arbitrary. It is suggested that the compiler would
be better off speaking to a representative from industry familiar with their national
circumstances, in order to estimate the sweet gas to sour gas ratio.

CanadaAccepted withmodification

9208

2

4

2340

2341

The purpose of Table 4.2.15 is unclear. It’s titled “Guidance on obtaining the activity data
values required …” but it doesn’t seem to offer any guidance. It simply restates theactivity values used in the previous emission factor tables (Tables 4.2.3 to 4.2.13).
Suggest the title be clarified or actual guidance be provided.

CanadaAccepted

We have renamed Table 4.2.15 from GUIDANCE ON OBTAINING THE
ACTIVITY DATA VALUES REQUIRED FOR USE IN THE TIER 1
APPROACH TO ESTIMATE FUGITIVE EMISSIONS FROM OIL AND
GAS SYSTEMS to ACTIVITY DATA REQUIRED FOR USE IN THE TIER
1 APPROACH TO ESTIMATE FUGITIVE EMISSIONS FROM OIL AND
GAS SYSTEMS

9210

2

4

2554

2554

Should refer to Table 4.2.16, not 4.2.15, as indicated.

CanadaAccepted

Corrected.

9212

2

4

3138

3139

Oil Sands Mining and Ore Processing - All - Leaks: There is a notation for a footnote, but
the footnote does not appear to be there.

CanadaAccepted

Footnote notation removed.

9214

2

4

3235

3235

Should also refer to reciprocating compressor - i.e. see also centrifugal compressor andreciprocating compressor.

CanadaAccepted

Added.

It is good practice to ask national experts about national circumstances. We
note this in the footnotes The text has been updated to provide additional
information on determining this fraction (lines 2062 to 2065).

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

Germany

Accepted

What the reviewer means here by "more references" is add better crossreferencing to the other new sections in the 2019 Refinement. More crossreferencing has been added. Although it is possible to use the outputs of CtL toHydrogen Production, the process analysed in the 2019 Refinement 2006
Guidelines was restricted to the Syngas production.

Russian Federation

AcceptedA definition of fuel transformation has been added under Heading 4.3.

7398

2

4

2585

3886

We welcome this new comprehensive chapter. To provide a better understanding, wesuggest to add more references. For example, when dealing with solid to gaseoustransformation, a reference to the new chapter “hydrogen production" (Volume 3, chapter
3.11) would be helpful. In addition, in Box 4.2.1 about hydrogen production a reference tofugitive gas distribution would be helpful if coke oven gas is distributed (in form of town
gas).

6732

2

4

2587

2588

It is proposed that the authors supplement the statement on fugitive emissions with thedescription of fuel transformation process and the release of greenhouse gas emissions
during this process.

5586

2

4

2587

2588

Are these sentences needed? The concept appears earlier in the volume, and is not specific United States of America
to fuel transformation.

Accepted

These sentences have been replaced with a definition of fuel transformation.

7586

2

4

2588

2588

Definition (..fossil fuels..) is inconsistent with paragraph 4.3.1, which includes charcoal
and wood pellets.

FinlandAccepted

The word "fossil" has been deleted.

7130

2

4

2594

2596

"Fugitive emissions from the following fuel transformation activities have been included inthis section - charcoal production, coke production, other solid fuels to solid fuels, coal toliquid, gas to liquid, biomass to liquid, biomass to gas, and refineries." We can see noother references to refineries in section 4.3. Are refineries actually included here?

NorwayAccepted

This Chapter does not cover this source. Cross reference has been added"refineries are considered in Chapter 4.2 in this volume."

5588

2

4

2594

2598

The paragraph describing fugitive emissions should reference Table 4.3.1 and only include United States of America
categories listed in the table, e.g., refineries are captured elsewhere.

Accepted

The paragraph has been modified to explain what processes are included in this
Chapter, and what are not included in this Chapter.

6734

2

4

2598

2599

Table 4.3.1. In the last column – “Emissions from the use of this fuel for energy purposes
should be reported under the following categories” subcategories of 1A should beindicated more specifically.

Russian Federation

Accepted withmodification

7588

2

4

2598

2599

Reporting of fugitive biogenic CO2 emissions from fuel transformation under 1B1c seems
to be a remarkable change in the principles of the Guidelines. The reasons andjustifications for this desicion should be made clearly available. Also, it should be clearly
defined, which biogenic CO2 emissions from fuel transformation/production need to bereported (for example: if BtL is mentioned, should fugitive emissions from production of
ethanol or biogas for road transport also be mentioned?)

FinlandAccepted

5590

2

4

2605

2605

Clarify if anthropogenic emissions include CH4, N2O, CO2 or all three.

United States of America

Accepted withmodification

The part of sentence "2 – 7 percent of global anthropogenic emissions" hasbeen deleted in the FD.

6736

2

4

2622

2622

Table 4.3.1. In the last column – “Emissions from the use of this fuel for energy purposes
should be reported under the following categories” subcategories of 1A should beindicated more specifically.

Russian Federation

Accepted withmodification

Column has been removed to simplify the table.

860

2

4

2626

Logic for decision tree in Figure 4.3.1 lack of “No” option in the box “Is national charcoal
production data available?”.

ThailandAccepted"NO" has been inserted down from "Is national charcoal production data
available".

5592

2

4

2626

On Figure 4.3.1 line leading down from "Is national charcoal production data available"
should be No. Also should Yes line leading to Collect data for higher Tiers be comingfrom Is charcoal production a key category? And not Tier 1 box?

United States of America

Accepted"NO" has been inserted down from "Is national charcoal data available" and anarrow has been inserted from rhombus instead of the rectangular.

2626

Column has been removed to simplify the table.

The final modification is written in alignment with AFOLU volume.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

6900

2

4

2626

2626

There is no 'Yes' line for the question of “Is charcoal production a key category?” in
Figure 4.3.1.

Republic of Korea

Accepted"YES" has now been inserted immediately from " Is charcoal production a key
category"

6738

2

4

2626

2627

Figure 4.3.1: The decision tree seems to undermine general concept of inventory
preparation and its further improvement, which builds upon key category analysis. In the2006 Guidelines and in the 2019 Refinement, the question if the category concerned is key
stands on top, i.e. in the beginning of each decision tree, and guides further actions of theinventory compilers. However, in the present structure of the decision tree, this question isput in the bottom, which seems inconsistent with general guidance in Volume 1 of the2006 Guidelines and the 2019 Refinement. To maintain concictency in decision treepresentation, it is proposed that the authors reconcile the oder of questions in the decision
tree to move the key category identification on top of it.

Russian Federation

Accepted

The question on key category is at the end in practically almost all decision
trees in the energy volume. Therefore this decision tree is in line with almost all
decision trees in volume 2.

5594

2

4

2632

2640

Change equation to be on an annual basis, so kg of GHG and units of production would be United States of America
on an annual basis.

Accepted

The title changed to read on "annual basis".

5596

2

4

2636

2636

Delete "by type of fuel"United States of America

Accepted

Text deleted.

5598

2

4

2638

2639

Delete "according to charcoal kiln type", the factors in Table 4.3.2 are not by kiln type.

United States of America

Accepted

Text deleted.

6740

2

4

2647

2648

It is proposed that the authors provide additional guidance on the choice of the emission
factors from Table 4.3.2.

Russian Federation

Accepted

Guidance has been given by indicating that "lower limit correspond to certain
types of kilns, and the upper limit to other types of technology".

5600

2

4

2648

2648

Table 4.3.2 does not seem to be by kiln technology but just default factors per charcoal
production so could delete "according to kiln technology"

United States of America

Accepted

Text deleted.

4698

2

4

2649

2658

There is the description that "There may also be use of fossil fuels in the harvesting,transport and pyrolysis of the feedstock that would be included in the energy sector(Volume 2)" in Box2.2A of Chapter 2, Volume 4. However, the charcoal production data
used as activity data for GHG emissions from charcoal production in accordance with theguidance in 4.3.2.1 charcoal production may not include the amount of biochar used for
agricultural soils because this is not for energy purposes. The clear statement that thebiochar production for all purposes should be included as activity data in this section
should be added, or the additional guidance that GHG emissions from biochar production
except for energy use should be estimated under the AFOLU sector should be added in thesection related to biochar in Chapter 2, Volume 4.

Japan

Accepted

The final modification is written in alignment with AFOLU volume.

6742

2

4

2695

2696

It would be very useful to indicate on the diagram which emission sources considered as
fugitive, as energy and as IPPU sources

Russian Federation

Rejected

The figure is already too crowded and the suggestion cannot be accomodated.

6744

2

4

2695

2696

It is proposed to increase the size of the diagramm because it is difficult to recognise it in a
hard copy.

Russian Federation

Accepted

The diagram has been resized.

5602

2

4

2715

2716

Table 4.3.4 change U = unlikely to N = none, table includes N and only one U that could
be changed to a P.

United States of America

Accepted

The use of notation keys in the table has been simplified, and the defintions
refined.

Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

2716

In Table 4.3.4, Fugitive gas emssion from "coking" production stage might be double
counting of emissions from iron and steel sector, because when emissions from cokeproduction are estimated by Carbon mass balance following the G/L in the IPPU(Vol.3,
Ch.4), it counts the total carbon in that process

Republic of Korea

Accepted

Setence added "Inventory compilers who are using a carbon mass balance
approach to estimate emissions from the iron and steel sector, and who areincluding fugitive emissions in this balance, should not use the methods in thissection to estimate emissions to avoid double counting."

Figure 4.3.3 is under development and some logic are missing.

ThailandAccepted

The decision tree has been finalised.

FranceAccepted

The decision tree has been finalised.

6902

2

4

2715

862

2

4

2717

5212

2

4

2717

2717

In the Figure 4.3.3, there are still items “Under development”.

6904

2

4

2717

2717

In the Figure 4.3.3
1) There is no 'Yes' line for the question of “Is coke production key category?”
2) “Is coke production key category?” → “Is coke production a key category?”3) In addition to the description of figure, it is necessary to detail the logical flow for
choice of methods.

Republic of Korea

Accepted

The decision tree has been finalised.

6746

2

4

2717

2718

Figure 4.3.3: The decision tree seems to be incomplete: the bottom block has not been
filled? while the guidance for Tier 1 has not been provided. It is further proposed that theauthors reconcile the oder of questions in the decision tree to move the key category
identification on top of it.

Russian Federation

Accepted

The decision tree has been finalised.

5604

2

4

2717

2718

Figure 4.3.3 is still under development but is also not referenced anywhere in text. It
could be included as part of text starting on lines 2719.

United States of America

Accepted

The decision tree has been finalised.

6748

2

4

2732

2745

To maintain consistency in the 2019 refinement, it is proposed that the authors elaborateon the Equations 4.3.2 and 4.3.3 to include all greenhouse gases subject to reporting.

Russian Federation

Rejected

Looking at Volume 2, Stationary Combustion, the form of the equation that has
been used is consistent with equation 2.1.

6750

2

4

2732

2745

It is proposed that the authors provide the description of Tier 2 method for estimation
fugitive greenhosue gas emissions from coke production referred to in the decision tree on
Figure 4.3.3.

Russian Federation

Accepted

The section on choice of methods has been rewritten to include explanations ofTier 1, 2 and 3 methods.

5606

2

4

2765

2766

Is the N2O line on Table 4.3.5 needed? Seems like can be deleted.

United States of America

AcceptedLine in table deleted.

6752

2

4

2775

2776

So far as no emission factor has been provided for N2O in Table 4.3.5, it is proposed toremove default uncertainty estimate for N2O from Table 4.3.6.

Russian Federation

Accepted

The default uncertainty estimates have been deleted.

7590

2

4

2783

2797

In Equation 4.3.4, activity data are expressed as amount of coke produced in tonnes,
however emission factors are referred as GHG per TJ. Please correct the equation. Please
add an alternative equation for the cases, where flaring is estimated as volume of COG andcalculated as energy content in TJs. In this case referred emission factors from Vol2
Chapter 2 could be used.

FinlandAccepted

The equation has been corrected and the EF and AD are now presented incompatible terms.

5608

2

4

2785

2810

United States of America
Equation 4.3.4 has activity data listed as coke production, however Choice of Activity
data is based on the amount of COG produced. There is a disconnect between the two andit seems like Equation 4.3.4 should be changed to be referencing COG activity data.

Accepted

The equation has been corrected and the EF and AD are now presented incompatible terms.

Comment ID Volume

Chapter From line

To lineComment

Country

5610

2

4

2821

2821

Confirm if wood pellet production is included in Appendix 4A5 as referenced here or 4A2 United States of America
as referenced in Table 4.3.1

6754

2

4

2823

2991

The Section 4.3.2.4 Gasification Transformation Process seems insufficiently elaborated.
It is proposed to move Section 4.3.2.4 (the text in lines 283 to 2991) to Appendix 4a.3 as
the basis for future methodological development. The current text in Appendix 4a.3 could
be merged with the text in Section 4.3.2.4.

864

2

4

2832

5612

2

4

2839

2840

Reference Table 4.3.7 here and maybe move table up to this part of text. The Table 4.3.7
is not referenced anywhere else.

7592

2

4

2848

2848

Misprint: …fraction of CTL plant CO2…

5614

2

4

2897

2897

Line references carbon content that is of fossil origin, but discussion is concerning coaland gas to liquids, biomass to liquids is not discussed. Does this refer to biogas? If soshould be more clear.

7594

2

4

2899

2899

866

2

4

2902

7596

2

4

2902

5616

2

4

5618

2

7598

Response

Authors note

Accepted

Referencing corrected by replacing Appendix 4A5 with Appendix 4a.2.

Russian Federation

Rejected

As there was enough data to develop this section, the authors agreed that thistext should not be placed in an Appendix.

ThailandAccepted

The text in the figure has been revised.

United States of America

Accepted

The section has been restructured and the table has been moved.

FinlandAccepted

The text has been revised.

United States of America

Accepted

The text has been revised. The phrase was modified and the part "that is offossil origin" was deleted.

should be: Figure 4.3.5.

FinlandAccepted

Adjust figue numbering.

Text format “CO2, CH4, and N2O”

ThailandAccepted

The text has been revised.

2903

Decision tree in Figure 4.3.5 has an endless loop. Box 2 should be divided to two separate
boxes: 1. collect p-s data 2. calculate emissions

FinlandAccepted

The decision tree has been revised.

2911

2967

Equation 4.3.5 has activity data based on feedstock input but for coal to liquids emission
factors listed in Table 4.3.8 and discussed in choice of activity data section is based onamount of syngas produced. So either activity data on syngas should be converted tofeedstock input or formula for coal to liquid should be adjusted to be based on syngas
output.

United States of America

Accepted

Equation 4.3.5 was deleted.

4

2918

2918

The FCFi fraction of fossil carbon is not clear, does this refer to biogas or can this formula United States of America
also be used for biomass to liquids? If so should indicate that is the case.

Accepted

Equation 4.3.5 was deleted.

2

4

2928

2929

Both FSj and EFi should use the same activity unit (either TJ or Gg for both parametres).
Please check the use of subscript j in EFj in the Equation 4.3.6 in question and that ofsubscript i in EFi below the Eq.

FinlandAccepted

Eqution 4.3.5 (New) attended this comment.

5620

2

4

2929

2929

Delete Gg from i/Gg and only include i/TJ since that is what FSj is based on.

United States of America

Accepted

Eqution 4.3.5 (New) attended this comment.

5622

2

4

2952

2956

Confirm Table reference 4.3.14 listed twice in paragraph vs Table 4.3.8 shown.

United States of America

Accepted

Table number is 4.3.10 and referencing has been corrected.

7600

2

4

2997

2997

a word is missing: ..estimates reported by individual plants(?),..

FinlandAccepted

The word "plants" has been added.

Text format “O2”Comment ID Volume

Chapter From line

To lineComment

Country

Response

Authors note

United States of America

Accepted

Additional text added to describe how fugitive CH4 would be generated frompellet production.

5624

2

4

3665

3669

This section could usefully include some additional description of how fugitive CH4
would be generated from pellet production in non-trace quantities such that a country
would want to assess inclusion in an inventory. Is CH4 generated through the heatingprocess? Can CH4 be generated under anaerobic conditions while pellets are stored inlarge piles?

7604

2

4

3698

3698

In this sentence 'Solid fuel' has a different interpretation than generally in the Guidelines:
usually Solid fuels refer to coal derived fuels, wheras Biomass inludes all types of biomass(solid , liquid and gaseous). It would be more consistent to separate Biomasstransformation as a new issue.

Finland

Rejected

For the purpose of this guidance, solid biomass falls within Solid to Solid Fuel
Production category.

7606

2

4

3804

3809

Check the use of subindices i and j (i for gas, j for feedstock); FSi should be changed to
FSj, and CFi to CFj

FinlandAccepted

The equation was reviewed and modified to [EGAS i = (FSj • EFi) • 10-6]. In
other words, to calculate GHG emissions (CO2, CH4 and N2O) from BtL and
BtG, is necessary multiply the total amount of biomass or syngas produced (TJ)
to the Emission Factor of biomass or syngas.

7608

2

4

3855

3859

Check the use of subindices i and j (i for gas, j for feedstock); EFi explanation has bothsubindices i and j.

FinlandAccepted withmodification

844

2

4

98

117

Page number format

ThailandAccepted

846

2

4

153

157

Page number format

ThailandAccepted

848

2

4

190

193

Page number format

ThailandAccepted

The equation has been removed.

Comment ID Volume5554

2

Chapter From line
2

34

To line58

Comment

Country

United States of America
Recommend section 2.3.3.4 be revised to provide more clarity on the accounting andreporting approach of biomass use for energy (biofuels) between chapters of GHG
Inventories. Due to the current language in the 2006 IPCC Guidelines, users of IPCC
methodology, researchers and other interested stakeholders have pointed to the IPCC
guidelines as a point of confusion or misinterpretation of the allocation of reported
bioenergy emissions, its inclusion in national totals, and ultimately the carbon neutrality ofbiomass used for energy. As referenced in the 2006 IPCC Guidelines, “In the reportingtables, emissions from combustion of biofuels are reported as information items but notincluded in the sectoral or national totals to avoid double counting.” This statement has
shown to be misleading in regard to the exclusion of these emissions in the national totals.
To alleviate misinterpretation of the intent of the guidelines, it should be noted that theseemissions are in fact included in national totals. As stated in the previous sentence of the2006 IPCC Guidelines (lines 38-39), “Emissions of CO2 from biomass fuels are estimatedand reported in the AFOLU sector as part of the AFOLU methodology”. However, thecurrent phrasing (i.e., not included in sectoral or national totals) has led to theinterpretation that emissions from biomass combusted for energy (biofuels) are not to be
included because they are carbon neutral. Also highly, recommend inclusion of additional
details explaining the basis and need of the current IPCC approach (i.e., there is a need for
a comprehensive international accounting approach, emphasizing the appropriateness ofquantifying and reporting biomass energy emissions within the AFOLU chapter, captured
in carbon stock changes). Many academic papers and reports, including but not limited tothose included below, reference this topic as an issue of concern. It is recommended that
the IPCC and authors be much more explicit to provide clarity as to the accounting andreporting of biomass use for energy (biofuels) between the Energy and LULUCF chapters,
and its inclusion in national totals.
Example papers (not limited to those listed here): Chatham House (2017). The Impacts of
the Demand for Woody Biomass for Power and Heat on Climate and Forests.; Liu, W. et
al. Analysis of the Global Warming Potential of Biogenic CO2 Emission in Life Cycle
Assessments. Sci. Rep. 7, 39857; doi: 10.1038/srep39857 (2017).; Sedjo R (2013)
Comparative Life Cycle Assessments: Carbon Neutrality and Wood Biomass Energy.
Resources for the Future, Washington, DC, USA, 21p.; Cherubini, F., Peters, G. P.,
Berntsen, T., Strømman, A. H., and Hertwich, E.: CO2 emissions from biomass
combustion for bioenergy: atmospheric decay and contribution to global warming, GCB
Bioenergy, 3, 413–426, doi:10.1111/j.1757-1707.2011.01102.x, 2011.; Zanchi G, Pena
N, Bird N (2011). Is woody bioenergy carbon neutral? A comparative assessment ofemissions from consumption of woody bioenergy and fossil fuel. GCB Bioenergy, 4, 761–
772.; Gunn JS, Ganz DJ, Keeton WS (2012) Biogenic vs. geologic carbon emissions andforest biomass energy production. GCB Bioenergy, 4, 239–242.; Wiloso, E.I., Heijungs,
R., Huppes, G. & Fang, K. (2016). Effect of biogenic carbon inventory on the life cycle
assessment of bioenergy: challenges to the neutrality assumption. Journal of Cleaner
Production 125, 78-85.; Liu, Weiguo & Yu, Zhen & Xie, Xinfeng & Gadow, Klaus &Peng, Changhui. (2017). A Critical Analysis of the Carbon Neutrality Assumption in Life
Cycle Assessment of Forest Bioenergy Systems. Environmental Reviews. 26. 10.1139/er2017-0060.

Response
Accepted

Authors note
Additional detail on biomass has been provided in the FD.

Comment ID Volume

Chapter From line

6658

2

2

6484

2

3

6666

2

4

56

1162

To lineComment

Country

Response

57

Infortunately, Section 12.5, Chapter 12, Volume 4 (AFOLU) of the 2019 Refinement
does not provide clear guidance on how CO2 emissions from buring woody biomass
feedstocks should be reported in the Energy sector. With this, the following text is
proposed for inclusion before the text in line 56: "The CO2 and non-CO2 emissions fromburning wood biomass for energy purposes may be reported in the same country or indifferent countries. To avoid underestimation or double counting of CO2 emissions fromwood biomass burning, it is good practice to identify the approach applied for reporting on
CO2 emissions in the country where the energy feedstocks from harvested wood were
produced. The country should decide on inclusion of CO2 emissions from wood biomassburning in national inventory totals for the Energy sector depending on the approach forreporting CO2 emissions and removals applied by the country-producer of the HWP." The
text in lines 56 and 57 remains unchanged.

Russian Federation

Accepted withmodification

An update of chapter 3.6 of the 2006 guidelines would have been very useful: e.g. biofuelsin the aviation sector are not mentionned at all. The approches to split between domestic
and international flights (section 3.6.1.3) could have been adjusted considering that only
few countries levy tax on domestic aviation fuels,...

United Kingdom(of Great Britain andNorthern Ireland)

Rejected

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

The augmentation of coal reserves is not necessarily performed annually for each andevery mine of the particular coal basin. For economic reasons, it may not be necessary to
produce new boreholes to assess year-by-year changes in coal reserves, especially if thecoal basin is subject to permanent exploration and processing (production). Furthermore,other exploration methods have been developed recently which do not require constructionof boreholes or tend to reduce their number as much as practicable. Consequently,
assessment of changes in and augmentation of coal reserves do not directly relate tonumber of boreholes annually produced for exploration purposes. Alternatively, numberof exploration boreholes constructed annually seems more accuarte and adequate
information on corporate and national exploration efforts. These data are collected by coalcompanies and national stastic offices so far as these are the reports of corporate andnational economic activities performed. It is proposed that the authors reconcile theguidance on reporting on GHG emissions from coal exploration based on augmentation ofcoal reserved and instead develop the guidance based on the information on boreholes
produced for exploration purposes.

Russian Federation

Accepted withmodification

Major coal producing countries do present coal resources on an year-to-yearbasis. These may be ascertained from several governmental and nongovernmental reports and links. Therefore, augmentation of coal resources onannual basis can be obtained to a large degree of accuracy. Number of
exploration boreholes drilled annually seems to be a better option. However,this data is not readily available in national statistics. Therefore, we haveconsidered this approach in a Tier 3 method. Tier 1 and Tier 2 methods basedon augmentation of resorces and depth-wise augmentation of resorces
respectively, can be used if data number of boreholes drilled is not available orcannot be collected from coal exploration agencies or corporates.

1169

Authors note
Additional detail on biomass has been provided in the FD.